ML20072G159

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Forwards Description of Changes Incorporated in Updated Fsar,Qa Program Through Amend 32 & of Changes to Updated FSAR QA Program Since 830311.Changes Since 830311 Will Be Included in Jul 1983 FSAR Rev
ML20072G159
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 06/09/1983
From: Lee O
PUBLIC SERVICE CO. OF COLORADO
To: Jay Collins
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-83203, NUDOCS 8306280343
Download: ML20072G159 (20)


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PUBLIC SERVICE COMPANY OF COLORADO P. O. BOX 840 . DENVER, COLORADO 80205 OSCAR R. LEE June 9, 1983 wce mesm" Fort St. Vrain Unit No. 1 P-83203 Mr. John T. Collins, Regional Administrator ggg,gf/]3 U. S. Nuclear Regulatory Commission, Region IV ,

Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 M i 31983 Arlington, Texas- 76012 i LW Docket Number 50-26[

SUBJECT:

QUALITY ASSURANCE PROGRAM

Dear Mr. Collins:

In July 1982, we submitted to the Commission the FSV Updated Final Safety Analysis Report which incorporated changes made to the facility since its operating license was granted and provided the current description of the FSV QA Program.

In accordance with the requirements of 10CFR50.54 (a)(2), enclosed as Attachment I is the description of changes to the QA Program made with the submittal of the Updated FSAR to that of the original accepted QA Program through Amendment 32 of the original FSAR.

Enclosed as Attachment II is a description of changes made to the Updated FSAR Quality Assurance Program after March 11, 1983.

Pursuant to 10CFR50.54 (a)(3), we have concluded that these changes do not involve a reduction in commitment to the QA Program and our Nuclear Engineering Division will submit these changes in accordance with the requirements of 10CFR50.71 in July 1983.

If you have any questions on this matter, please contact J. W. Gahm, Quality Assurance Manager, at 303-785-2225.

Very Truly Yours,

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8306280343 830609 -

PDR ADDCK 05000267 N P PDR 0. R. Lee, ice President, Electric Production ORL/cm h 1

Attachments Ik

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9 Attachment I DESCRIPTION of CHANGES to the FSAR APPENDIX B

Attachment I Page 1 of 13 Section B.O (Introduction)

An introduction is added to provide an historical perspective and continuity between the Quality Assurance Program described in the original FSAR and that described in the FSAR update.

Section B.1 (General Description of the Initial Program)

This general description of the program is retained as a major heading. Material from the original FSAR is condensed and edited. This information is retained on the FSAR for historical purposes and to provide an. indication, for reference, as to how the Quality Assurance Program evolved from the construction phase into the operating phase.

Section B.2 (Initial Program Organization and Responsibilities)

The title of this section is changed to " Initial" Program Organization and Responsibilities. The material in this section came from the original FSAR but is condensed and edited. The General Atomic Co. role in construction Quality Assurance is discussed but reference is made in the FSAR update introduction to the original FSAR for details of organization and for the organization charts that were in use at that time.

Section B.3 (Implementation of the Program - Design, Construction and Preliminary Test Phase)

The material retained in this section is considered important to retain for reference purposes. It came from the original FSAR but is significantly condensed and edited. The organizations with responsibility for Quality Assurance are described briefly along with their roles and responsibilities. Historical and reference materials are provided to show how Quality Assurance was performed during the preconstruction phase and to describe the roles of the various contractors and subcontractors during the construction phase. Also described is the manner in which Public Service Company personnel participated in the Quality Assurance Program during that phase.

Section B.4 (Status of Program Per 10CFR50, Appendix B - Design, Construction and Preliminary Test Phase)

The tabular comparison between the criteria of 10CFR50, Appendix B, and the Quality Assurance Program as it existed at the time the construction permit was granted has not been retained.

However, this section number is retained and reference is made to the original FSAR for that information.

Attachment I Page 2 of 13 Section B.5 (Introduction)

This section contains the complete description of the Quality Assurance Program for operation. Some material from the original FSAR is retained, but it is extensively edited and condensed. The introductory section is still present and identifies the fact that policy statements are issued by the responsible executives which commit Public Service Company to a Quality Assurance Program and which set forth definite policies regarding implementation of that Program.

The introduction deletes descriptions of the following activities:

A) Pre-Operational Testing B) Start-Up Testing C) Operations D) Maintenance and Repair E) Modification and Design Control F) Refueling G) In-Plant Core Management Section B.5.1 (Organization)

A) Program organizational responsibilities and titles are changed to reflect the current organizational structure as follows:

1) Senior Vice President, Electric Operations is replaced by Vice President, Electric Production
2) Vice President, Engineering and Planning is deleted
3) Quality Assurance Director is replaced with Quality Assurance Manager
4) Supervisor, Quality Assurance Operations and Supervisor, Quality Assurance Services is replaced by Superintendent, Quality Assurance Operations and Superintendent, Quality Assurance Services
5) Plant Superintendent is replaced by Superintendent, Operations I
6) Superintendent, Nuclear Production is replaced by Manager, Nuc;rar Production i

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Attachment I Page 3 of 13

, B) Detailed responsibilities are added for the following:

1) Quality Assurance Manager
2) Superintendent, Quality Assurance Services
3) . Superintendent, Quality Assurance Operations
4) Manager, Nuclear Production
5) Manager, Nuclear Engineering C) A brief listing of responsibilities is added for the following:
1) Station Manager
2) Superintendent, Operations
3) Superintendent, Maintenance
4) Training Supervisor
5) Results Engineering Supervisor
6) Technical / Administrative Services Manager
7) Security Supervisor
8) Maintenance Quality Control Supervisor
9) Technical Services Engineering Supervisor
10) Radiation Protection Manager
11) Nuclear Design Manager
12) Nuclear Services Manager
13) Nuclear Site Engineering Manager D) The Engineering Department titla :s replaced by Nuclear Engineering Division.

E) The statement, " orders or recommendations to stop work will be documented by issuance of a Quality Assurance Deficiency Report", has been deleted.

Section B.S.2 (QA Program)

' A) References to G.A.C., its subcontractors, and the transition period are deleted.

Attachment I

. Page 4 of 13 B) References to Quality Assurance Plans, Quality Assurance Instructions, and Interdepartmental Work Procedures, are deleted.

C) Maintenance and control of special lists of safety-related equipment, previously delegated to the Quality Assurance Department, is now delegated to the Nuclear Engineering Division.

D) The following are added:

1) Reference to Class 1 and Safe Shutdown (Tables 1.4-1, and 1.4-2); items that are covered by the Quality Assurance Program
2) Reference that PSCo is committed to apply the QA program for operation to the engineering procurement, fabrication, installation, operation and maintenance of Nuclear Fuel.
3) The Quality Assurance Manual consists of the "Q" -

series procedures in the Fort St. Vrain Administrative Procedures Manual and conforms to the requirements of 10CFR50, Appendix B by providing an individual procedure to describe the FSV program for each of the 18 criteria.

4) A list of applicable Codes, Standards and regulatory requirements Sa) Reference to a Training Program, to conform to 10CFR19, 20, 50 - App. B, 50 - App. E,'55, 55 -

App. A, 73 and ANSI N18.1 - 1971 Sb) Reference to the Training Program Administrative Manual (TPAM) which specifies policies, procedures and documentation for the Training Program Sc) A detailed description of Quality Assurance Training requirements

6) A requirement that the Quality Assurance Manager submit proposed revisions to the FSAR (as a result of Quality Assurance Program changes) to the Vice President, Electric Production prior to submittal to the NRC

f Attachment I o

Page 5 of 13 Section B.S.3 (Design Controls)

A) Design responsibility is assigned to the Nuclear Engineering Division B) Expands on the Change Notice System C) The following design control measures are added:

1) Design control measures required by 10CFR50, Appendix B are applied to activities such as reactor physics, stress analysis, thermal and hydraulic design and analysis, accident analysis, material selection and compatibility evaluation, evaluation of accessibility for in service inspection, maintenance and repair, and delineation of acceptance criteria for inspections and tests.
2) Qualification testing, when used, shall be of a prototype unit under the most adverse conditions expected in actual service.

D) A statement is added that says, Nuclear Engineering Division procedures require the selection of materials, parts, and components required for modifications to conform to requirements equal to, or more stringent than the original design requirements.

E) Design errors identified after release of a Change Notice package are corrected by reissuing the affected CN and affected design documents.

F) Although safety significant design change review by the Nuclear Facility Safety Committee remains a requirement of the FSV Technical Specifications, specific reference to it in the FSAR is removed.

Section B.S.4. (Procurement Document Control)

A) The following are added; ,

1) Standard Quality Assurance Clauses are added to the-purchase requisition when not included in the technical documents referenced by or included in the purchase requisition package. Clauses are specified by the Nuclear Engineering Division.
2) A requirement for QA review of the purchase requisition to include review of provisions for any required hold, witness or source inspection points.

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Attachment I Page 6 of 13

3) A requirement for QA review of the purchase order to assure that QA provisions on the purchase requisition have not been compromised. QA retains a copy of the P.0, for record purposes.

Section B.5.5 (Instructions, Procedures and Drawings)

A) The following are added:

1) Procedures involving activities affecting quality of safety-related items require review by Quality Assurance.
2) The procedure system conforms to the intent of Regulatory Guide 1.33 and ANSI N18.7.
3) Each Change Notice package authorizing a modification or special repair to the Plant, requires development of a Controlled Work Procedure. CWP's are reviewed by Quality Assurance.
4) All maintenance, inspection, and surveillance activities are performed to procedures imposed by the FSV Administrative Procedures Manual.

B) The following statements are deleted:

1) "As-Built" drawings and specifications will be utilized in the procurement of spare parts, material and replacement parts, and in the operation and maintenance of the plant.
2) "As-Built" drawings will be revised to incorporate new materials or parts requirements.

Section B.5.6 (Document Control)

A) This entire section is deleted. However, reference is made to subsections B.5.2, B.5.3, B.5.4 and B.5.5 for specific descriptions of document controls.

Section-B.5.7 (Control of Purchased Material, Equipment and Services)

A) The subject of supplier selection is expanded to address l evaluation performed by Quality Assurance; evaluations are documented and retained; a listing is maintained of approved suppliers.

B) Supplier control is expanded to address hold, witness, and i inspection points placed in the purchase orders, l

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Attachment I Page 7 of 13 C) A statement is added which calls for the use of pre-prepared checklists to supplement Receiving Report checks, when appropriate.

D) The performance of reviews of physical and chemical properties (certifications), previously designated a QA/QC responsibility, now is designated to be performed by

" qualified personnel".

E) The detailed description of requirements for receiving inspection and completion of required records for safety-related spare or replacement parts, material or equipment is deleted. Reference is made to the FSV Administrative Procedures for this information.

Section B.5.8 (Identification of Materials, Parts and Components)

A) Details on marking and tagging cre deleted. Marking is not addressed.

B) The following requirements are added:

1) Change Notice packages specify the identification designations for any assemblies created by the modification.
2) A copy of the identification tag on the Direct Charge Requisition identifying the item is included in the maintenance or modification work records package.

Section B.5.9 (Control of Special Processes)

A) The following are added:

1) Special process procedures are contained in Quality Assurance Inspection, Welding, and Maintenance Manuals.
2) Nondestructive examination personnel are qualified to the requirements of SNT-TC-1A, American Society for Nondestructive Testing Recommended Practices.
3) A master file of qualified welder documents and NDE qualification records is maintained by the QA Department.

Section B.S.10 (Inspection)

Attachment I Page 8 of 23 A) The following are added:

1) Work performed by the Maintenance Department is inspected by Maintenance Quality Control.
2) All non-maintenance inspections are to be performed by the QA Department.

B) The requirement for qualifications to be documented and maintained current, for personnel performing inspections which require special processes, special controls, or special skills, is deleted. However, it is required that inspection personnel be qualified to the requirements of applicable regulatory requirements.

Section B.5.11 (Test Control)

A) Information on the test activities that must be incorporated into, or referenced in test procedures, e.g.,

inspections or inspection hold points, is expanded.

Section B.5.12 (Control of Measuring and Test Equipment)

A) The content of calibration procedures are expanded upon, i.e., they are required to provide the calibration technique, specific standards required, label or tagging requirements, provisions for recording the calibration data, and identification of the individual verifying the acceptability of the calibration results.

Section B.S.13 (Handling Storage and Shipping)

A) A reference to the FSV Administrative Procedures Manual as having the necessary detailed controls is added.

Section B.S.14 (Inspection, Test and Operating Status)

A) A requirement for equipment affected by maintenance or items withdrawn from operational status to be tagged, is added.

B) The requirement for the use of an "Out-of-Service" tag to indicate status of instruments or controls out-of-service, due to maintenance or calibration requirements, is deleted.

Section B.5.15 (Nonconforming Materials, Parts, or Components)

Attachment I Page 9 of 13 A) The requirement, for items which are dispositioned "use-as-is" or " repair" to be evaluated and approved by QA and qualified engineering disciplines; and for the approvals to be documented, is added.

B) The reference to a Deficiency / Deviation Report is changed to a reference to a Nonconformance Report.

C) Details have been deleted; however, reference is made to the FSV Adminstrative Procedures Manual.

Section'B.5.16 (Corrective Action)

A) A requirement for corrective action requests to be documented and processed on Action Request (AR) forms is added.

B) A requirement that the QA Department maintain a follow-up system to assure effective implementation of corrective action is added.

C) The subject of trend analysis and reporting is expanded.

Data employed includes Nonconformance Reports, Action Requests, monitoring and audit reports, and NRC I & E Reports.

D) Information concerning reporting apparent violation of NRC regulations or significant potential safety hazards is expanded. . Plant Trouble Reports, Action Requests and Nonconformance Reports are designated as vehicles for reporting these conditions. A direct report to the NRC may be made if the conditions are deemed reportable.

Section B.5.17 (Records)

A) The following_ requirements are added:

1) Quality Assurance is to review the FSV Administrative Procedures as they are developed to verify the adequacy and appropriateness of record provisions.
2) Organizations generating records are responsible for their completeness and accuracy; and for accumulation, organization, identification and transmittal to the Records Center.

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Attachment I o Pag @ 10 of 13 B) Details have been deleted; referral is made to the FSV Adminstrative Procedures Manual.

Section B.S.18 (Audits and Monitoring Activities)

A) The following requirements are added:

1) The system of formal audits is supplemented by monitoring actions. Monitoring results are evaluated and considered when developing audit plans and checklists.
2) Auditors and Lead Auditors are selected and qualified in accordance with ANSI N45.2.23 - 1978.
3) Audit results are distributed to management, including Vice President, Electric Production
4) Monitoring activities are described'in the Quality Assurance Monitoring Manual (QAMM).

Section B.S.19 (Implementation, WASH-1283,-1284 and - 1309)

A. ANSI N45.2-1971

1) Specific Exceptions - Inspection (Section 11)

A statement is added that assigns first level inspection of routine preventative maintenance activities to plant personnel in Maintenance Quality Control. This was previously only specified as assigned to " plant personnel". In addition, it is now specified that inspections for work other than routine maintenance are performed by QA Department personnel.

B. ANSI N45.2.3 - 1973

1) Specific Exceptions - Requirements (Section 3)

The response to NRC Branch Technical Position 9.5-1 (Refs. 14 and 15) is referenced rather than I & E Bulletin 75-04 and 75-04A in regard to fire protection and prevention equipment.

C. ANSI N45.2.5 - 1974

1) Scope and Applicability The reference to Regulatory Guide 1.97 is corrected; now reference is to Reg. Guide 1.94.

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Attachment I Page 11 of 13

2) Specific Exceptions - Personnel Qualifications (Section 2.4)

This exception is now deleted; ANSI N45.2.6 is now implemented.

D. ANSI N45.2.12 - 1974

1) Specific Exceptions - Audit Process (Section 4.3.2)

The pre-audit conference, previously stated; to be held with the Director of Quality Assurance; now stated; is held with the Superintendent of Quality Assurance Operations.

2) Specific Exceptions - Post Audit Conference and Follow-up (Section 4.3.3 and 4.5.1) a) The requirement for the audit report to be issued within thirty (30) days to the Director of Quality Assurance is now changed to be issued to the Quality Assurance Manager and forwarded to the organization audited and to the Vice President, Electric Production.

b) The requirements are deleted to:

1. hold a meeting within two (2) weeks following issuance of the audit report to.

review findings and resolve contested deficiencies with the audited organization, and

11. obtain corrective action responses within thirty (30) days following this meeting.

TABLES DELETED

. Table B.1-1 Quality Assurance Program, Essential Elements -

Scope and Applicability Table B.1-2 Elements of Quality Assurance. Required Throughout Plant Life

. Table B.2-1 Three Level Quality Assurance Program for Design, Construction and Preliminary Testing; Explanation of First,.

Second and Third Level QA Responsibilities

Attachment I Page 12 of 13 '

i Table B.5-1 Applicability of 10CFR50 Appendix B, to Quality Assurar;e Alans for Operational QA Program ,

, s Table B.5-4 Typical Quality Assurance Plans; Including ,

Assignment of Responsibilities, Quality Assurance Program for Plant Operation '

Table B.5-5 Nuclear Class I Structures Covered by Fort St.

Vrain Quality Assurance Program for Plant Operation Table B.5-6 Typical Quality Assurance Instructions - Quality Assurance Program for Plant Operation Table B.5-7 Typical Documents Subject to Controlled Distribution TABLES RETAINED Table B.5-3 Three Level Quality Assurance Program for Plant Operation - Explanation of First, Second and Third Level QA Responsibilities (previously Table B.5-2)

Table B.5-2 Minimum Qualifications for Quality A surance Manager (This table deletes the requirement that the QA Manager review Quality Assurance requirements at least every six (6) months by specific training or attendance of trade schools, seminars, conferences, etc. This table was previously Table B.5-3 " Director of Quality Assurance, Basic Qualification Requirements").

TABLES ADDED Table B.5-1 Policies and Guidelines for Electric Production '

Nuclear Activities Table B.5-4 ANSI Standards and Regulatory Documents Applicable to FSV Operations OA Program FIGURES DELETED j Figure B.2-1 Public Service Company of Colorado Functional ,

Organization for Quality Assurance - Design, Construction, and ) ,

Testing, Fort St. Vrain Nuclear Generating Station ', .

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Figure B.2-2 General Atomic Functional Organization for Nuclear Plant Quality Assurance Figure B.5-3 General Atomic Company Quality Assurance Division ,

Organization >

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. Attachm:nt I

- Page 13 of 13 (t

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. , I Figure B.5-4 Quality Assurance and Administrative Interfaces, s PSC QA for Plant Operation

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FIGURES REVISED -

.: Figure $.5-1 Fort St. Vrain Nuclear Generating Station Administrative and Departmental Management Organization Chart (previously Figure B.5-1 "Public Service Company of Colorado, Organization for Quality Assurance for Plant Operation, Fort St.

Vrain Nuclear Generating Station")

lv , Figure B.5-2 Quality Assurance Department Organization Chart

i'- (previously Figure B.5-2 "Public Service Company of Colorado,

, Quality Assurance Department Organization Diagram")

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' - Figure B.5-3 Functional Document Tree (Showing Relationships Between Procedures Which Control Plant Activities), Quality

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I - Assurance Program for Plant Operation (This table has incorporated into it information which was previously available 4 y', from Table B.5-5 " Quality Assurance Program for Plant Operation,

, Relationships Between'Various Quality Assurance. Documents"'and

, % ble B.5-6" Relationships Between Quality Assurance Documents, Administrative Procedures and Work Procedures, Qualfty Assurance cProgram for Plant Oper'ation")

. * ' SECT 10l4 S.6 (Referdnces for Appendix B)

  1. A list of co'respondence r pertinent to the FSAR has been added.

ATTACHMENT A (Questions and Answers)

This is deleted from the FSAR update as a separate attachment.

Answers to the questions which were addressed by this attachment are now incorporated into the body of the update.

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Attachment II DESCRIPTION of CHANGES to the FSAR UPDATE (APPENDIX B) AFTER MARCH 11, 1933

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Attachment II Pago 1 of 4 Section B.5.1.3 (Quality Assurance Related Responsibilities)

Throughout this section, descriptions for subtier management personnel other than Quality Assurance have been revised to conform to descriptions provided in the FSV Administrative Procedure Q-1.

Section B.5.1.3.c.12 (Quality Assurance Related Responsibilities -

Superintendent, QA Services) page B.5-5 The preparation, verification and issuance of "as-installed data" documentation for plant modificaticns, previously a QA Services responsibility, is now deleted. This is now the responsibility of Nuclear Engineering Division.

Section B.S.I.3.e.2 and B.5.1.3.p.3 (Quality Assurance Related Responsibilities - Manager, Nuclear Production and Manager, Nuclear Engineering) page B.5-6 and B.5-8 Specific reference to Quality Assurance review of station and Engineering procedures affecting quality is deleted. Statement added that station and Engineering procedures affecting quality must be compatible with FSV Administrative Procedures Manual which is reviewed and approved by Quality Assurance as described in Section B.5.5.1.

Section B.5.2.1 (Quality Assurance Programs - Program Description) page B.5-9 and B.5-10 Table 1.4-3, previously omitted, was added to the program description.

The second paragraph is revised to read "In addition to safety related equipment, PSCo is also committed to apply po.-tions of the QA program for operation to the Alternate Cooling Method (ACM) equipment, the Fire Protection System, and the Plant Security System." Reference to Nuclear Fuel was deleted since this is safety related and resulted in a redundancy which was not necessary.

" Portions".was added as most, but not necessarily all, of the QA program is applied to the ACM equipment, Fire Protection system and Plant Security System. The Plant Security System was added as this is a additional QA commitment.

Section B.5.2.7 (Quality Assurance Programs - FSV Safety-related Items) page B.5-11 Reference to "special safety-related lists and drawings" has been replaced with " applicable P & I, IB, and IC drawings, and SR-6-2 and SR-6-8 lists." Section 1.4.5.1 and 1.4.5.3 were deleted from a) and b). Table 1.4-3 was added to a) and b). Items c, d, and e were deleted. These changes were necessary to be consistent with the existing Quality Assurance program as described in the FSV Administrative Procedure Manual.

Attachment II Page 2 of.4 Section B.5.2.9.a (Quality Assurance Programs - Quality Assurance Training) and Section B.S.2.10 (Quality Assurance Programs - Work Procedures) page B.5-12 and B.5-13 The terms " quality-related" and " code-related" are deleted in favor of the term " safety-related" in order to eliminate confusion in terminology. Safety-related is more adequately defined in terms of Quality Assurance application ta these items.

Section B.5.2.11 (Quality Assurance Programs - FSAR Quality Assurance Program Changes) page B.5-13 The following is added:

"Those char.ges to the QA program that do not reduce commitments in the program may be made without prior NRC approval. However, those changes must be submitted to the NRC at least annually. Those changes that do reduce program commitments must be submitted to tne NRC and be approved by the NRC before the changes may be implemented". This change was made to reflect the new requirements of 10CFR50.54, which went into effect March 11, 1983. The term

" licensing" is deleted as the report is not made to NRC Licensing.

Section B.5 5.1 (Instructions, Procedures and Drawings - FSV Procedures System) page B.5-17 The statement that " Procedures involving activities affecting quality of safety-related items require review by Quality Assurance personnel", is deleted. In its place is the statement, "The Administrative Procedures Manual is reviewed and approved by the Quality Assurance Department". This change reflects the method of Quality Assurance review of those procedures which affect the quality of safety-related items.

Section B.5.5.2 (Work Control Procedures _1 page B.5-17 "Special Repair" was deleted in favor of " selected non-routine maintenance" for requiring development of a Controlled Work Procedure. This is to provide consistency with the FSV Administrative Manual.

Section B.5.7.1 (Control of Purchased Material, Equipment and Services - Supplier Selection) page B.5-18 A referral to section B.S.19.13 is now added. This reference serves to. tie together the basic information on the subject of evaluation and selection of potential suppliers of safety-related items presented in B.S.7.1 and some additional information found in section B.5 19.13, which describes the implementation of ANSI N45.2.13 (Quality Assurance Requirements for Control of Procuremev of Items and Services for Nuclear Power Plants).

Attachment II Page 3 of 4 Section B.5.10.2.f (Inspection - Inspection Other Than Maintenance) page 8.5-21 The provision is now added allowing for either the signature or the use of a stamp by the inspector or data recorder on the receiving report checklist. This change was needed in order for the FSAR to be consistent with an allowance in the FSV Administrative Procedures for the use of a stamp.

Section B.5.14.3 (Procedure Requirements for Operational Items) page B.5-23 Paragraph is added concerning the independent verification upon return to service of certain critical equipment.

Section B.S.18.4 (Audits and Monitoring Activities - Monitoring Activities) page B.5-27 The statement that "The monitoring functions are defined in the Quality Assurance Monitoring and Manual which includes pre planned procedures, instructions and checklists", is changed to: "The monitoring functions are defined in the Quality Assurance Monitoring Manual which describes the pre planned instructions and checklists used in the QA monitoring procedures." This change does not decrease the QA commitment regarding monitoring activities, but rather serves to clarify the system and reflect the QA monitoring procedures.

Section B.5.19.6.b (ANSI 45.2.5-1974 Supplemental Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants - Specific Exceptions - Qualification Tests) page B.5-35 Provision has been added exempting ASTM A36 steel from certification, except that which is used in the buildings main structural steel.

This is only for purchasing clarification. Applicable specifications, ANSI 45.2.5, ASA B31.7 and B31.1 and GA spec 1-M-2 as well as Reg Guides 1.29, and 1.94, 1.116, 1.123 and 1.124 give no requirements for QA certification of structural materials.

Attachment II

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Page 4 of 4 Section B.S.19.7.a (ANSI N45.2.6-1973 Qualification of Inspection, j Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants) page B.5-36 The statement that " Personnel performing inspection, examinations and testing activities during the operational phase would be qualified to ANSI N18.1-1971 or ANSI N45.2.6-1973 except that QA experience for levels I, II and III should be interpreted to mean actual experience in operation or maintenance of the area involved" is now changed to:

" Personnel performing inspection, examinations and testing activities during the operational phase would be qualified to ANSI N18.1-1971 or ANSI N45.2.6-1973 and QA experience for levels I, II and III should be interpreted to mean equivalent experience in construction, manufacturing, operation or installation activities". This change was necessary to be consistent with the wording of ANSI N45.2.6-1973.

Table B.5-1 (Policies and Guidelines for Electric Production Nuclear ActivitieM page B.5-45 Item number 18; Drug / Alcohol Abuse Policy was added to this table.

This new policy became effective 9-27-82.

Section B.6 (References for Appendix B) page B.6-2 Item 18, PSCo letter dated June 16, 1982, (P-82188), Warembourg to Collins (NRC); subject NUREG-0737, was added.

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