ML20078P857
| ML20078P857 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 12/05/1994 |
| From: | IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| To: | |
| Shared Package | |
| ML20078P855 | List: |
| References | |
| NUDOCS 9412200284 | |
| Download: ML20078P857 (113) | |
Text
< ss---
17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.
2.0 INTRODUCTION
17.2.0.1 Scope To maintain the high quality of plant systems and equipment during operation, maintenance, repair, modification, and refueling of the Duane Arnold Energy Center (DAEC), a comprehensive quality assurance program has been implemented.
The objective of this program is to maintain managerial and administrative control over the operations of and activities relative to safety-related structures, systems, equipment, and components during the operating life of the DAEC. This program is designed to meet the intent of Appendix B to 10 CFR Part 50.
17.2.0.2 Corporate Policy IES Utilities Inc. considers the operation of the DAEC to be an l extension of the basic policies established and documented for design, construction, and startup.
The policies and procedures identified within this report regarding " operating phase" will form the basis for plant-life operation of the DAEC.
Where contractors and suppliers are used during the life of the operating DAEC, their function will be controlled by the Operational Quality Assurance Program.
It is the objective of IES Utilities Inc. that the DAEC shall be l operated effectively, efficiently, and in such a manner as not to jeopardize the health or safety of the public.
17.2.1 ORGANIZATION 17.2.1.1 Scope 1
IES Utilities Inc. has established an operating organization that I l is structured to support DAEC operating requirements as well as l meet corporate needs in other areas. This overall organization i is described in UFSAR Chapter 13, Conduct of Operations, Section 13.1, Organizational Structure for IES Utilities Inc. The l organization chart, which identifies both the "on-site" and "off-site" organizational elements that function under the cognizance l l
of the quality assurance program, appears as Figure 13.1-1, IES l Utilities Inc. Corporate Organization. Chapter 13 describes the l l quality assurance responsibilitios of each of the organizational elements noted on the organization chart.
l 17.2-1 Revision 15 l To be determined 9412200284 941205 PDR ADOCK 05000331 P PDR
1 i
Additional detail concerning the Quality Assurance Department is ,
presented in Chapter 17.2, Section 17.2.1.2.
The responsibility and authority for the establishment and j execution of the Operational Quality Assurance Program for the !
l operation of the DAEC will be retained by IES Utilities Inc. l l
17.2.1.2 Manager, Corporate Quality Assurance '
The Manager, Corporate Quality Assurance reports to the Vice )
President - Nuclear and is assigned the primary responsibility for ensuring that quality requirements relative to the safe I operation of the DAEC are identified and met. l l
Fulfilling the responsibilities of the Corporate Quality l Assurance Department requires significant communication with the l DAEC, the Nuclear Licensing Department, the Emergency Planning ]
l Department, the Nuclear Business Unit, the Engineering l Department, the Training Department, and the Purchasing l Department.
The Manager, Corporate Quality Assurance is responsible for ,
preparing and maintaining the Operational Quality Assurance !
l Program and the Quality Assurance Department implementing l procedures.
The Manager, Corporate Quality Assurance is also responsible for 1 evaluating the effectiveness of the Operational Quality Assurance i Program and issuing periodic reports to the appropriate levels of l management. Effectiveness of the Operational Quality Assurance l Program at the DAEC is determined through internal audits and i surveillances and through analysis and trending of reported l conditions adverse to quality. The Manager, Corporate Quality I l Assurance also provides support for the procurement of materials l l and equipment through audits, surveillances, and evaluations of l suppliers and contractors for quality capabilities and ,
l performance and maintains the list of approved suppliers for )
l nuclear procurements. I I
l The Manager, Corporate Quality Assurance also evaluates the j effectiveness of the Operational Quality Assurance Program I through reviews of plant operation, maintenance, modification, l and testing documents for inclusion of adequate quality I requirements and for inclusion of inspection, witness and hold l points; and provides the necessary support to perform these l inspections and tests. Other responsibilities include performing l receiving, in-process, and final inspections.
17.2-2 Revision 15 To be determined
I Training responsibilities include assuring that Quality Control l personnel maintain proficiency and certification in l nondestructive examination (NDE) techniques and other inspection l activities. Certification in NDE requires coordination with the l Corporate Level III NDE. Other training responsibilities include l the training of Quality Assurance Department personnel and l Nuclear Generation Division personnel relative to the Operational l Quality Assurance Program. l l
The Manager, Corporate Quality Assurance provides direct support l to the nuclear Safety Committee and assures that Quality l Assurance Department personnel are designated to support the l Operations Committee. l l
17.2.1.2.1 Stop Work Authority The Manager, Corporate Quality Assurance has the authority to issue a stop work instruction to the organization that has direct responsibility for the work. Only the Vice President - Nuclear has the authority to override the stop-work instruction.
17.2.2 OPERATIONAL QUALITY ASSURANCE PROGRAM 17.2.2.1 Scope IES Utilities Inc. has established an Operational Quality l Assurance Program that applies to those structures, systems, and components, that are safety-related and those activities that affect those structures, systems, and components that are safety-related. Safety-related structures, systems, and components are those that ensure the integrity of the reactor coolant pressure boundary, shut down the reactor, and maintain the reactor in a safe shut down condition, or prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
17.2.2.2 Basis 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, and certain regulatory guides, form the basis for the Operational Quality ;
Assurance Program. Appendix A to UFSAR Chapter 17.2 identifies '
the particular regulatory guides to which IES Utilities Inc. is l .
committed and which are included in the basis for the Operational )
Quality Assurance Program.
I 17.2-3 Revision 15 I To be determined
1 l i t i t
l 17.2.2.3 Identification of Safety-Related Structures, Systems, Components and Items The pertinent requirements of the Operational Quality Assurance Program apply to all activities affecting the safety-related functions of those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. A current list of safety-related structures, systems and components is contained in Section 3.2 of the DAEC Updated Final Safety i Analysis Report. This list includes structures, systems, and I components identified during the design and construction phase and may be modified as required during operations consistent with their importance to safety.
1 The list of safety-related structures, systems and components l from Section 3.2 of the DAEC Updated Final Safety Analysis Report j is further defined in data bases through the assignment of plant I specific unique identifiers. These data bases include items in l addition to safety-related structures, systems and components and )
are maintained by the Manager of Engineering.
17.2.2.4 Operational Quality Assurance Program Implementation The implementation of the Operational Quality Assurance Program j l by IES Utilities Inc. is directed toward the assurance that l operating phase activities and maintenance activities are i conducted under controlled conditions and in compliance with applicable regulatory requirements, including 10 CFR Part 50, Appendix B. Management personnel responsible for the conduct of safety related activities are responsible for providing approved procedures before initiating the activity.
l The IES Utilities Inc. Operational Quality Assurance Program is implemented via four levels of documents:
l e Quality Assurance Manual e Nuclear Generation Division Manual e Departmental Procedures e Departmental Instructions.
l 17.2.2.4.1 Quality Assurance Manual The Quality Assurance Manual is the highest level internal quality program document that implements UFSAR/DAEC-1 Chapter 17.2, Quality Assurance During the Operations Phase. It is l directed to those IES Utilities Inc. organizations responsible for safety-related activities. The Quality Assurance Manual presents upper management philosophy and concepts to the middle management level, defines organizational responsibilities, and identifies organizational interfaces.
17.2-4 Revision 15 To be determined
17.2.2.4.2 Nuclear Generation Division Manual ,
The Nuclear Generation Division Manual contains administrative l procedures that are common to the Nuclear Generation Division. l These divisional administrative procedures eliminate the need for l separate departmental procedures addressing the same subject. l ,
l 17.2.2.4.3 Departmental Procedures l
The Departmental Procedures are organizationally unique documents j that describe the activities of each< department within IES l l Utilities Inc. that has responsibilities for the operation, l )
maintenance, or modification of the DAEC. The Departmental Procedures specify how to accomplish a specific activity.
l 17.2.2.4.4 Departmental Instructions The Departmental Instructions are unique to the department and activity for which they have been prepared. Departmental Instructions provide the specific, detailed information necessary to perform an activity. Departmental Instructions are issued at the discretion of the responsible manager and are not required l for all activities.
17.2.2.5 Control of IES Utilities Inc. Suppliers l IES Utilities Inc. may employ the services of l architect-engineers, NSSS suppliers, fuel fabricators, constructors, and consultants to augment IES Utilities Inc. l )
capabilities. These organizations are required to work under a quality assurance program to provide the control of quality activities consistent with the scope of their assigned work. The quality assurance programs of such organizations are subject to review, evaluation, and acceptance by the IES Utilities Inc. l Corporate Quality Assurance Department before the initiation of I activities affected by the program.
17.2.2.6 Indoctrination and Training The indoctrination, training, and retraining of personnel who participate in safety-related activities are provided in five broad areas: operator training, quality assurance indoctrination, technical training, radiation safety indoctrination and training, and emergency preparedness training.
f The Operator training provided to senior reactor operators and reactor operators is under the cognizance of the Plant Superintendent - Nuclear and Manager, Nuclear Training.
17.2-5 Revision 15 To be determined
i l The quality assurance indoctrination provided to IES Utilities l Inc. personnel is under the cognizance of the Manager, Corporate j Quality Assurance and the Manager, Nuclear Training.
l The technical training provided to IES Utilities Inc. engineering t personnel is under.the cognizance of the Manager of Engineering i and the Manager, Nuclear Training. The training may be provided in a number of ways, from self-study courses to formalized ;
courses at the DAEC Training Department and educational institutions.
l Indoctrination and training provided to IES Utilities Inc. !
personnel and contract personnel relative to performing work in areas that are potentially hazardous because of radioactivity are ,
under the cognizance of the Radiation Protection Manager and the '
l Manager, Nuclear Training. :
l The indoctrination and training provided to IES Utilities Inc.
personnel and contract personnel relative to emergency )
preparedness is under the cognizance of the Manager, Emergency Planning and the Manager, Nuclear Training.
17.2.2.7 Management Review and Audit l The status of the IES Utilities Inc. Operational Quality Assurance Program is periodically made known to management. A periodic report is prepared by the Manager, Corporate Quality Assurance and submitted to the Vice President - Nuclear.
An annual audit of the operational Quality Assurance Program is conducted to evaluate the effectiveness of the overall program.
Direction for these audits alternates between the Vice President
- Nuclear and the Safety Committee. The Safety Committee audit is in accordance alth the Technical Specifications requirement for a biennial audit of the quality assurance program. These ,
alternating audits complement each other and provide an annual 1 evaluation.
17.2.3 DESIGN CONTROL 17.2.3.1 Scope The design, modification, addition, and replacement of safety-related structures, systems, and components at the DAEC is controlled to ensure that appropriate measures are implemented and to ensure that "as-built" quality is not degraded. The plant l design is defined by IES Utilities Inc., the NSSS supplier, i architect / engineer, and selected suppliers. Design drawings and ;
specifications illustrate the general arrangement and details of safety-related structures, systems, and components and define the 17.2-6 Revision 15 To be determined i
t i
requirements for ensuring their continuing capability to perform their intended operational or safety design function.
Design activities include the correct translation of regulatory requirements and design bases into specifications, drawings, written procedures, and instructions that define the design.
Design analyses regarding reactor physics, stress, seismic, thermal, hydraulic, radiation, and accident analyses used to produce design output documents are performed when appropriate.
Design verification is performed.
Procedures establish requirements, assign responsibilities, and provide control of design activities to ensure performance in a planned, controlled, and orderly manner.
17.2.3.2 Design Responsibility The design and engineering effort is the responsibility of the Manager of Engineering within the Nuclear Generation Division. l Assistance may be provided by other engineering organizations; individuals providing that assistance are required to perform their activities in compliance with the IES Utilities Inc. l ,
Operational Quality Assurance Program. The design of nuclear l fuel reloads is the responsibility of Reactor Engineering. l l
17.2.3.3 Design Criteria 1 I
Design requirements and changes thereto are identified, documented, reviewed, and approved to ensure the incorporation of appropriate quality standards in design documents. Design 1 requirements and quality standards are described to an ;
appropriate level of detail in design criteria. Any exception to quality standards will be listed. Criteria for modifications to structures, systems, and components will consider, as a minimum, the design bases described in the UFSAR. All design criteria will be satisfied in the design.
17.2.3.4 Design Process Controls The organization performing design will have the responsibility for design control unless specified otherwise. The control of design will be specified in procedures. These procedures will include instructions for defining typical design requirements; communicating needed design information across internal and external interfaces; preparing, reviewing, approving, releasing, distributing, revising, and maintaining design documents; performing design reviews; and controlling field changes.
l 17.2-7 Revision 15 To be determined
Design control involves measures that include a definition of '
design requirements; a design process that includes design ,
analysis and the delineation of requirements through the issuing I l of drawings, specifications, and other design documents (design i outputs); and design verification.
The design process establishes controls for releasing technically adequate and accurate design documents in a controlled manner L with a timely distribution to responsible individuals and groups. )
l' Documents and revisions are controlled through the use of written procedures that apply to the issuer, distributor, and user to prevent inadvertent use of superseded documents. Document control procedures govern the collection, storage, and maintenance of design documents, results of design document
- reviews, and changes thereto. Design documents subject to l procedural control include, but are not limited to, specifications, calculations, computer programs, the UFSAR when used as a design document, and drawings, including flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single-line diagrams, structural systems for major facilities, site arrangements, and equipment locations.
l l 17.2.3.5 Design Interface Control
, Design interfaces with external and internal organizations l
participating in the design are controlled. The design interface measures ensure that the required design information is available in a timely fashion to the organization (s) responsible for the design. 1 17.2.3.6 Design Verification The applicability of previously proven designs, with respect to )
meeting pertinent design inputs, including environmental conditions, will be verified for each application. Where the design of a particular structure, system, or component for a specific application has been subjected to a previous verification process, the verification process need not be duplicated for subsequent identical applications. However, the original design and verification will be documented and referenced for the subsequent application.
l When changes to previously verified designs have been made, I design verification will be required for the changes, including an evaluation of the effects of those changes on the overall design.
17.2-8 Revision 15 To be determined
Design verification will be performed by competent individuals ;
who:
e have not participated in the original design but may be from the same organizational entity, i
e do not have immediate supervisory responsibility for I the individual performing the design, !
I e have not specified a singular design approach, e have not ruled out certain design considerations, and i
e have not established the inputs for the particular 1 design aspect being verified. :
Under exceptional circumstances, the design verification may be performed by the originator's supervisor provided:
e the supervisor is the only technically qualified individual in the organization competent to perform the i verification, e the need is individually documented and approved in i advance by the supervisor's management, and !
e QA audits cover the frequency of occurrence and effectiveness of the supervisor as design verifier to guard against abuse.
Cursory supervisory reviews do not satisfy the intent of ;
providing a design verification.
If errorr or deficiencies in the design process are detected during the design verification cycle or during audits, resolution of errors and deficiencies will be the responsibility of the design engineer, who must provide documented evidence of resolution to the appropriate levels of management.
Acceptable verification methods include, but are not limited to, any one or a combination of the following:
- 1. Design reviews
- 2. Alternative or simplified calculational methods
- 3. Performance of suitable qualification testing.
The method selected will consider the item's complexity, previous operational experience, and importance to safety.
17.2-9 Revision 15 To be determined
The results of the design verification efforts will be clearly documented, with the identification of the verifier clearly indicated and filed. The documentation of results will be auditable against the verification methods identified by the responsible design organization.
17.2.3.6.1 Design Reviews Design reviews will be sufficient to verify the appropriateness of the design input, including assumptions, design bases and applicable regulations, codes and standards, and that the design is adequate for the intended application of the design.
Design reviews can range from multi-organization reviews to single-person reviews. The depth of review can range from a detailed check of the complete design to a limited check of the design approach, calculations, and results obtained.
17.2.3.6.2 Calculations Alternative, simplified calculations can be made, or a check of the original calculations may be performed, to verify the correctness of the original calculation. Where computer programs are used, the program verification will be documented and the inputs shall be considered in the design review.
17.2.3.6.3 Qualification Testing Design verification for some designs or specific design features may be achieved by suitable qualification testing of a prototype or initial production unit.
In those cases where the adequacy of a design is to be verified by a qualification test, the testing will be identified and documented. Testing will demonstrate the adequacy of performance under conditions that simulate the most adverse design conditions.
17.2.3.7 Changes To Design Documents Changes to design documents receive a review and approval process as eq~tvalent to original design documents. Design documents issue by the original architect-engineer, NSSS supplier, and other irganizations may be changed and revised by the responsible l design organizations within IES Utilities Inc. or contracted by l IES Utilities Inc.
17.2-10 Revision 15 To be determined
17.2.3.8 Independent Review Committees Independent of the responsibilities of the design organization, the requirements of the Operations Committee and the Safety Committee, as specified in the Technical Specifications, will be satisfied.
17.2.4 PROCUREMENT DOCUMENT CONTROL i
17.2.4.1 Scope Procurement document control applies to documents employed to procure safety related materials, parts, components, and services j required to modify, maintain, repair, test, inspect, or operate !
the DAEC. IES Utilities Inc. controls procurement documents by l !
written procedures that establish requirements and assign l responsibility for measures to ensure that applicable regulatory i requirements, design bases, and other requirements necessary to ;
ensure quality are included in documents employed for the )
procurement of safety related materials, parts, components, and l services. ,
i 17.2.4.2 Procurement Responsibility i
The responsibility for the initiation of a purchase requisition l 1s that of the organization that ultimately has the responsibility for the procurement.
17.2.4.3 Quality Classification i
Each item or service to be procured is evaluated by the !
Engineering Department to determine whether or not it performs a l safety-related function or involves activities that affect the function of safety-related materials, parts, or components and to appraise the importance of this function to plant or public safety. For those cases where it is unclear if an individual l piece (that is, part of a safety-related structure, system, ;
component, or service) is governed by the Operational Quality Assurance Program, an engineering evaluation will be conducted.
The evaluation will classify the safety relationship of the service or questionable component parts or items of safety-related structures, systems, or Components.
17.2.4.4 Quality Requirements in Procurement Documents Procurement document control measures will ensure that appropriate regulatory requirements, design bases, and other i requirements are included in the procurement process.
Originating and reviewing organizations shall require that the following be included or invoked by reference in procurement documents, as appropriate:
17.2-11 Revision 15 To be determined
. . q l
- 1. Requirements that the supplier provide a description of his quality assurance program that implements the applicable criteria of 10 CFR Part 50, Appendix B, and that is appropriate for the particular type of item or service to be supplied. Certain items or services will l require extensive controls throughout all stages of manufacture or performance, while others may require only a limited control effort in selected phases.
- 2. Basic administrative and technical requirements, including drawings, specifications, regulations,
! special instructions, applicable codes and industrial standards, and procedural requirements identified by
' titles and revision levels; special process instructions; test and examination requirements with i l corresponding acceptance criteria; and special l l requirements for activities such as designing, l identifying, fabricating, cleaning, erecting, l
packaging, handling, shipping, and storing.
- 3. Requirements for supplier surveillance, audit, and l inspection, including provisions for IES Utilities Inc.
access to facilities and records and for the identification of witness and hold points.
- 4. Requirements for extending applicable requirements to lower-tier suppliers and subcontractors. These l requirements will include right-of access by IES l Utilities Inc. to sub-supplier facilities and records.
- 5. Requirements for the supplier to report certain nonconformances to procurement document requirements and conditions of their disposition.
- 6. Documentation requirements, including records to be prepared, maintained, submitted, or made available for review, such as drawings, specifications, procedures, procurement documents; inspection and test records, -
personnel and procedural qualifications, chemical and physical test results, and instructions for the retention and disposition of records.
- 7. Requirements for supplier-furnished records.
- 8. Applicability of the provisions of 10 CFR Part 21 for safety-related items, to the extent that a loss of their function may cause potential substantial safety hazards. Certain items, as off-the-shelf items, will be exempt from this requirement.
17.2-12 Revision 15 To be determined I
1
- _ _ _ - - _____ ______ ________-_____-____-___________N
- 9. Requirements for packaging and transportation as !
necessary to prevent degradation during transit. i 17.2.4.5 Acquisition from Other Licensed Nuclear Power Plants ;
i Items may be procured from another NRC-licensed nuclear power l plant provided that the procured item meets the requirements of l !
the DAEC procurement specification. If the item was originally l procured by the other utility as a " basic component" as defined ,
in 10 CFR Part 21, then.the reporting requirements of the l ,
regulation are accepted by IES Utilities Inc.- IES Utilities Inc. l ;
shall notify the original supplier in writing of this. item (s) ;
change in ownership to give the original supplier the opportunity l to change the 10 CFR Part 21 notification records. l 17.2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2.5.1 Scope Instructions, procedures, and drawings will be generated to provide direction and guidance to ensure that safety-related activities are performed correctly. The need for, content of, and depth of detail of the instructions, procedures, and drawings will be consistent with the importance and complexity of that 1 activity. :
l 17.2.5.2 Content The content of the instructions, procedures, and drawings will be !
appropriate to the activities being performed.
Instructions and procedures will include, as appropriate, scope ;
or purpose, responsibilities of individuals performing the work, ;
the information needed, and required output and acceptance !
criteria. !
Drawings will be prepared using industrially accepted standards.
17.2.5.3 Compliance l l
Following approval and issuance of instructions, procedures and l drawings, respective activities will be performed in accordance l l with the documents. If an activity cannot be accomplished due to l ;
an inadequacy of the document, the document will be formally l l revised to reflect the manner in which the activity is to be l ,
performed. l 17.2-13 Revision 15 To be determined i j
17.2.6 DOCUMENT CONTROL 17.2.6.1 Scope i
The organization responsible for the documents will establish l measures to ensure that the documents, including changes, are l reviewed for adequacy and are approved for release by authorized l personnel. The responsible organization also establishes l measures to ensure the documents are distributed to and used at the location where the prescribed activity is performed and are controlled. -
I 17.2.6.2 Preparation l Administrative techniques will be established that define the l documents to be issued and controlled, identify the current l revision or issue of the document, and identify the individuals I who are to receive the document.
l The types of documents that are controlled by IES Utilities Inc.
include the following:
J
- 1. Specifications
- 2. Drawings
- 3. Procurement documents 1
- 4. Quality Assurance Manual I
- 5. Nuclear Generation Division Manual l
- 6. Departmental Procedures
- 7. Safety analysis reports and related design criteria documents
- 8. Welding Manual
- 9. Computer codes.
17.2.6.3 Review and Approval Documents that are specified as being controlled documents are reviewed to ensure that regulatory, technical, and quality l dssurance requirements have been appropriately addressed; that i review comments have been considered and resolved; and that the document is approved before issuance and use.
l l The review and approvals required for instructions, procedures I l and drawings will be established by the organization responsible l for those documents. Reviews will be performed by knowledgeable l personnel other than the originator. Review and approval will l l occur prior to issuance or implementation of the changed l l document. I I I I
17.2-14 Revision 15 To be determined
1 0 17.2.6.4 Distribution and Use Documents will be issued before the commencement of the activity l to be controlled by that document. The mechanism for l distribution will provide assurance that the controlled document arrives at the point of use; the user will provide assurance that the document to be used is the proper document and revision.
When formal distribution lists are ur9d to prescribe an established distribution, they will be maintained current to reflect changes in assigned responsibilities.
Document transmittals will be reviewed for accuracy and dated and made suitable for transmittal. The recipient is informed of what is being transmitted and of the status of the documents being transmitted.
An acknowledgment of the receipt of controlled documents by recipients may be required if the organization responsible for the document deems such controls necessary.
The organization responsible for the use of the document will establish administrative controls to provide for positive identification and prevent the loss of such documents. The l administrative controls will have provisions to remove obsolete documents, thereby precluding the possibility that the wrong documents or revisions will be used.
17.2.6.5 Changes to Documents Changes to documents previously released will be reviewed, approved, dated, and dietributed in the same manner as the original document.
Personnel who review changed documents will have access to pertinent background information upon which to base their l approval. Reviewers shall have adequate understanding of the l requirements and the intent of the original documents, including I source documentation. Revisions will be reviewed and approved by l the same organizations that performed the original review and l approval unless another qualified organization is designated. l I i Revised instructions and procedures will reflect the new revision and date and clearly identify the scope or portion of the instruction and procedure being changed.
Documents that have been approved by the original designers of l the DAEC will be revised by the IES Utilities Inc. Engineering l Department. l 17.2-15 Revision 15 l To be determined l i
l
17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7.1 Scope Purchased material, equipment, and services are controlled to ensure that the specified technical and quality requirements are obtained. The responsibility for the control of purchased material, equipment, and services is that of the Corporate Quality Assurance Department in close cooperation with the Engineering Department, DAEC, and the Purchasing Department. The technique used for the control of purchased material, equipment and services includes, as appropriate, source evaluation and selection, objective evidence of quality furnished, inspection at the source, supplier's history of providing a satisfactory 1 product, and examination of the product on delivery. j l l 17.2.7.2 Source Evaluation and Selection Potential suppliers are evaluated. These evaluations are performed by qualified personnel to determine the capability of the supplier to provide the items or services.
Suppliers are evaluated on the basis of one or more of the following: 1
- 1. Capability to comply with the requirements of 10 CFR 50, Appendix B, applicable to the type of material, j equipment, or service being procured. ;
- 2. Past records and performance for similar procurements to ascertain the capability of supplying a manufactured product or services under an acceptable quality assurance system.
- 3. Audits or surveys of supplier's facilities and quality assurance program to determine the capability to supply a product that satisfies the design, manufacturing, and quality requirements.
- 4. The certification of the supplier by the ASME.
- 5. The results of audits performed by other utilities and consultants.
, The supplier's bid proposal is reviewed and evaluated to ensure l that the bid is responsive to the procurement documents.
Depending on the importance of the item or service and its iraportance to safety, a post-award meeting may be held to discuss the requirements of the procurement document.
l 17.2-16 Revision 15 To be determined 1
1
17.2.7..; Inspection or Surveillance at the Source Subsequent to the award of a purchase order, a surveillance / inspection plan may be prepared. The extent of the plan will consider the complexity and importance of the item or service, supplier's past performance, and those aspects of the manufacturing process that may not be verified at receipt inepection.
The plan will establish, as appropriate, the frequency of surveillance / inspection; processes to be witnessed, inspected, or verified; the method of surveillance / inspection; and documentation requirements.
Activities specified in the plan will be conducted at the supplier's facilities by qualified personnel using approved procedures that provide for the following as applicable:
- 1. Reviewing material acceptability
- 2. Witnessing in-process inspections, tests, and nondestructive examination
- 3. Reviewing the qualification of procedures, equipment, and personnel
- 4. Verifying that fabrication or construction procedures and processes have been approved and are properly applied
- 5. Verifying quality assurance / quality control systems, to the extent necessary l
- 6. Reviewing document packages for compliance to i procurement document requirements, including qualifications, process records, and inspection and test records j l
- 7. Reviewing Certificates of Compliance for adequacy.
- 8. Verifying that nonconformances have been properly controlled. l l
Hold points specified in the procurement document will be l complied with and IES Utilities Inc. will be notified in a timely l l manner when hold points are reached.
A method will be established to provide information relative to l the characteristics that have been inspected at the source and l the characteristics that are to be inspected on receipt. '
17.2-17 Revision 1" To be deterr..ened
o .
17.2.7.4 Receipt Inspection
.l Items purchased by IES Utilities Inc. are controlled at the final destination by the performance of a receipt inspection. The extent of the receipt inspection depends on the importance to safety, the complexity, the quantity of the product or service, and the extent of source inspection, source surveillance or audit that was performed.
t Receipt inspection is performed by trained and qualified personnel in accordance with approved procedures and acceptance criteria before the installation or use of the item (s) to preclude the placement or use of nonconforming item (s).
Documentary evidence will demonstrate that materials and equipment conform to the procurement requirements.
If receipt inspection indicates that the item is unacceptable, the item is treated as nonconforming.
17.2.7.5 Post-installation Testing Acceptance by post-installation test mey be used following one of the preceding verification methods. Post-installation testing is used as the prime means of acceptance verification when it is difficult to verify item quality characteristics, the item requires an integrated system check out or test, or the item cannot demonstrate its ability to perform when not in use. Post-installation test requirements and acceptance documentation are l established by IES Utilities Inc.
17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 17.2.8.1 Scope Materials, parts, and components will be identified and controlled to ensure that the correct materials, parts, and components are used during fabrication, manufacture, modification, repair, and replacement.
It is the respon11bility of the organization responsible for the engineering design and procurement to include the requirements )
for proper identification and control in the procurement <
documents.
It is the responsibility of the supplier for maintaining the traceability of materials, parts, and components t an >ughout fabrication and shipment.
17.2-18 Revision 15 To be determined
1 It is the responsibility of the DAEC for maintaining the !
traceability of materials, parts, and components throughout i repa*r, replacement, modification, and installation. I 1
17.2.2.2 Identification Identification will be applied in locations and by methods that will not affect the fit, function, or quality of the item.
The identification of the item will be maintained by a unique l method such as heat number, part number, serial number, batch number, or other appropriate means in a form that is durable and ,
legible.
The identification may be on the item or on records traceable to the item. Where feasible, direct placement of the identification on the item will be by stamping, marking, tags, labels, or other similar methods.
Where direct placement of identification on the item is not fear'ble, proper controls will be established that ensure direct po' e identification of the item. Where physical id 4 1 cation is either impractical or insufficient, physical !
separation, procedural control, or other approved means will be employed.
1 Receipt inspection will verify that identification for received !
l items is complete and accompanied by appropriate documentation.
When an item is subdivided, the identification will be imm'diately transferred to the sub-parts so that all sub parts c lin the appropriate identification label.
Any identification that will be obliterated or hidden by surface coatings or surface treatments will be reestablished or will be traceable by administrative means.
Standard catalog items or off-the-shelf items may be identified by catalog number or other appropriate designation.
17.2.8.3 Verification and Control The items will be controlled and the identity of the item verified.
Inventory and storage controls will be established at the DAEC to ensure proper traceability of items.
The correctness of the item will be verified on withdrawal from storage and before the initiation of the repair, replacement, and modification.
17.2-19 Revision 15 To be determined
17.2.9 CONTROL OF SPECIAL PROCESSES 17.2.9.1 Scopo Special processes are those controlled fabrications, tests, and final preparation processes that require the qualification of procedure, technique, and personnel and that are performed in accordance with applicable codes and standards. Certain special processes require interim in process controls in addition to final inspection to ensure quality.
The control of special processes is the joint responsibility of the Engineering Department, the DAEC, and the Corporate Quality Assurance Department.
The Engineering Department is responsible for providing technical l expertise relative to materials, metallurgy, welding, brazing, l special processes and nondestructive examination (NDE).
l Nondestructive examinations will be performed under the direction l of the Engineering Department by the Corporate Quality Assurance l Department or IES Utilities Inc. approved suppliers.
17.2.9.2 General Requirements Measures will be established to ensure that special processes are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.
Written procedures will be reviewed or prepared before use to ensure that special processes are controlled and accomplished.
These procedures will describe the operations to be performed, the sequence of operations, the characteristics involved, the limits of these characteristics, measuring and test equipment to be used, acceptance criteria, and documentation requirements.
Special processes will be accomplished in accordance with written procedures and process sheets, or their equivalent.
Personnel will be trained and qualified in accordance with applicable codes and standards.
Equipment used to perform special processes or measure or test the product will be qualified, before use, in accordance with applicable codes, standards, specifications, or procedures.
The extent and period of training, qualification, and testing of personnel and equipment will be in accordance with applicable codes, standards, specif ations, or procedures.
17.2-20 Revision 15 To be determined
1 17.2.9.3 Personnel Qualification The personnel who perform nondestructive examinations will be certified to the precise technique to be used and for the proper level of expertise.
A Level III Examiner will be responsible for qualifying and ,
certifying, in accordance with the IES Utilities Inc. written l practice, the IES Utilities Inc. personnel who perform l nondestructive examinations.
17.2.9.4 Verification and Control The procedures, process sheets, personnel, and equipment will be verified as appropriate, before the initiation of work at the DAEC. '
The Corporate Quality Assurance Department will determine that '
suppliers performing special processes at the DAEC have sufficient Controls before the initiation of the work.
The Engineering Department will determine that personnel l performing special processes have current qualifications.
17.2.9.5 Special Protective Coatings (Paint)
The application of a special protective coating shall be t controlled as a special process when the failure (i.e. peeling or t spalling) of the coating to adhere to the substrate can cause the malfunction of a safety-related structure, system or component. l Special process coatings shall be applied by qualified personnel using qualified materials and equipment, and approved procedures.
Documentation shall include identification of the following:
- person applying the coating (and qualification) e material used
- procedure used (and qualifying procedure if different) e tests performed and results
- date of application of coating a traceability of coating location.
17.2-21 Revision 15 To be determined
17.2.10 INSPECTION 17.2.10.1 Scope A program for the inspection of safety-related activities at the DAEC will be established and executed to verify conformance with applicable documented instructions, procedures, drawings, and specifications.
l The responsibility for the receipt, in-process and final inspection of materials, parts, and components affecting quality is that of the Corporate Quality Assurance Department. The l responsibility for the performance of nondestructive examinations l is that of the Engineering Department.
17.2.10.2 General Requirements A program for the inspection of activities affecting quality will be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
Inspection will be performed by individuals other than those who performed the activity being inspected. Inspections will be performed by personnel using appropriate equipment in accordance with applicable codes, standards, and procedures.
Procedures, instructions, or checklists will be established and used that identify the characteristics to be inspected, ,
inspection methods, special devices, acceptance and rejection criteria, methods for recording inspection results, and groups responsible for the inspection. Special preparation, cleaning, and the use of measuring devices will be included.
Inspections will be planned to identify where in the sequence of work each inspection activity will be performed, to what extent, procedures to be used, and mandatory hold or witness points.
Repairs, modifications, or replacements will be inspected in accordance with the original inspection requirements or acceptable alternatives.
Sampling methods and process monitoring will be used when inspection is impossible or disadvantageous.
17.2.10.3 Process Monitoring Process monitoring of work activities, equipment, and personnel will be used as a control if inspection of processed items is impossible or disadvantageous. Both inspection and process i
17.2-22 Revision 15 )
To be determined l l
1 1
monitoring will be provided when control is inadequate without both. As an alternative, a suitable level of confidence in structures, systems, or components on which maintenance or modifications have been performed will be attained by inspection.
As appropriate, an augmented inspection program will be implemented until such time as a suitable level of performance has been demonstrated.
The monitoring of processes will be performed to verify that activities affecting quality are being performed in accordance with documented instructions, procedures, drawings, and specifications.
17.2.10.4 In-Service Inspection Required in-service inspection, including nondestructive examination, pressure tests, and in-service tests of pumps and valves, will be planned and executed. The results of these examinations and tests shall be documented, including corrective actions required and the actions taken.
The basis for the in-service inspection program is the ASME Boiler and Pressure Vessel Code,Section XI, 1980 Edition with Addenda through Winter 1981. The specific issue and addendum of requirements beyond the base commitment is as specified in 10 CFR Part 50, Section 50.55a(g), except where specific exemptions have been granted by the NRC.
The Engineering Department has the overall responsibility for developing the inspection program, for ensuring compliance with the ASME Code Section XI rules, and for evaluating the inspection results. The inspection plans shall be updated as required to !
accommodate the as-built condition of the DAEC. j 1
17.2.10.4.1 Ten Year Inspection Program The Ten-Year Inspection Program includes inspections and tests of those pressure boundary welds and materials as defined in ASME )
Boiler and Pressure Vessel Code,Section XI. Also included are l the pressure boundary welds and materials that are defined as l
" Augmented" in-service inspections. The Ten-Year Inspection Program identifies the welds and items to be examined, the frequency of such examinations, the methods, and confirms the continuing acceptability of the selected welds and items.
The Engineering Department has the responsibility for conducting l the planned nondestructive examinations (NDE) and providing the i services of the Corporate NDE Level III Examiner as required by )
Code. l l
l 17.2-23 Revision 15 To be determined I
17.2.10.4.2 In-service Testing Program The DAEC has the responsibility for conducting the ASME Boiler and Presaure Vessel Code,Section XI, pump and valve tests, system pressure tests, and snubber tests. These performance tests to verify operational readiness are part of the plant '
performance program.
17.2.10.5 Personnel Qualification Personnel performing inspections and examinations, or accepting the results of inspections and examinations, will be trained and qualified in accordance with governing codes, standards, and regulations. The personnel will be competent and cognizant of the technical requirements of the work activity. Qualification records will be maintained by the organization responsible for the individual (s) performing the inspections.
17.2.10.6 Documentation and Records Inspection and examination activities will be reported on a form that indicates the date of the activity, identification of inspector or examiner, and rejection or acceptance of the item (s).
17.2.11 TEST CONTROL 17.2.11.1 Scope Testing will be performed at the DAEC to demonstrate that safety-related structures, systems, and components perform satisfactorily in service. The testing program will include the following, as appropriate:
- 1. Qualification tests for design verification
- 2. Proof tests before installation
- 3. Pre-Operational tests
- 4. Operational tests.
17.2.11.2 General Requirements The tests will be performed in accordance with approved written test procedures that incorporate the requirements and acceptance limits. The test procedure will identify the item to be tested and the purpose of the test.
Test procedures will include provisions for ensuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. The test 17.2-24 Revision 15 To be determined
l 1
l
_ procedure will incorporate directly,.or by reference, the l following requirements:
- 1. Performance of tests by trained personnel.who are qualified in accordance with applicable codes and standards
- 2. Verification of test prerequisites
- 3. Identification and description of acceptance or rejection criteria
- 4. Instructions for performing the test.
17.2.11.3 Surveillance Testing ,
1 Provisions will be established for the performance of surveillance testing to ensure that the necessary quality of systems and components is maintained, that facility operations l are within the safety limits, and that limiting conditions of l operation can be met. The testing frequency will ime at least as !
frequent as prescribed in the Technical Specifications. The l i
provisions for surveillance testing will include the preparation of schedules that reflect the status of planned surveillance tests. Qualified plant staff will perform surveillance tests.
17.2.11.4 Personnel Qualification ;
I Personnel performing testing will be trained and qualified. The i personnel will be competent and cognizant of the technical ;
requirements of the work activity. l 17.2.11.5 Documentation and Records Test procedures and results will be documented and approved by qualified personne1..
Test results shall be documented and indicate that the prerequisites and other test requirements have been met.
17.2.12 CONTROL OF MEASURING AND TEST EQUIPMENT 17.2.12.1 Scope The responsibility for the control of measuring and test equipment and permanently installed plant instrumentation, is that of the DAEC. The control measures will include the identification and calibration of the equipment to the activity.
The requirements contained within this section do not apply to devices for which normal industry practice provides adequate control, that is, tape measures, rulers, and measuring glasses.
17.2-25 Revision 15 To be determined
17.2.12.2 General Requirements Measures will be established for the control, calibration, and adjustment of measuring and testing devices.
y Calibration intervals will be based on required accuracy, the use of equipment, stability characteristics, or other factors affecting the measurement.
The following requirements will be specified in written procedures that are used to control measuring and test equipment:
- 1. Identification.of equipment and traceability to calibration data
- 2. Calibration methods, frequency, maintenance, and control
- 3. Labeling and marking of portable equipment to indicate due date for next calibration. Due dates for '
permanently installed plant equipment are controlled by means of a central record system.
- 4. Provisions for determining the validity of previous measurements when equipment is determined to be out of calibration.
- 5. Traceability of reference and transfer standards to '
nationally recognized standards. When national standards do not exist, the basis for calibration shall be documented.
Calibration may be performed at the DAEC or by qualified laboratories using competent personnel.
Equipment that is consistently found to be out of calibration shall be repaired or replaced.
When the accuracy of the measuring or test device can be adversely affected by environmental conditions, special controls will be prescribed to minimize such effects.
17.2.12.3 Traceability The measuring and test equipment will be traceable to the item on which the equipment has been used.
When calibration, testing, or other measuring devices are found to be out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the l
17.2-26 Revision 15 l To be determined i l
l
l acceptability of devices previously tested from the time of the previous' calibration.
L 17.2.13 HANDLING, STORAGE, AND SHIPPING i i
17.2.13.1 Scope The handling, storage, shipping, cleaning, and preservation of I material and equipment will be controlled to prevent damage, deterioration, and loss.
It is the responsibility of the organization initiating procurement to specify any special instructions and requirements for packaging and handling, shipping, and extended storage. 1 It is the responsibility of the DAEC to provide for the proper l handling and storage of material and equipment upon receipt and throughout repair, replacement, and modification. !
17.2.13.2 General Requirements Measures will be established to control the handling, storage, shipping, cleaning, and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.
When necessary for particular products, special protective environments such as inert gas atmosphere, temperature levels, and specific moisture-content levels will be specified and provided.
Consistent with the need for preservation, material and equipment will be suitably cleaned to prevent contamination and degradation. The cleaning method selected will in itself not damage or contaminate the material or equipment.
17.2.13.3 Shipping When required to prevent contamination or to prevent damage during shipment, special packaging methods will be specified and implemented.
Special-handling requirements, if required, will be specified in the shipping instructions. The package should be appropriately marked to indicate that special handling or storage requirements are necessary.
Markings of packages will conform to applicable Federal and state i regulations. l l
l l
17.2-27 Revision 15 !
To be determined ;
17.2.13.4 Radioactive Materials Measures will also be established to control the shipping of licensed radioactive materials in accordance with 10 CFR Part 71.
These measures will apply to the use of shipping containers only, and not to the design and fabrication of shipping centainers for which an NRC certification is required unaer Part 71.
17.2.13.5 Handling The requirements for special handling will be considered when the item is moved from the receipt point to the storage area and from the storage area to the point of use. Special-handling equipment will be periodically tested and inspected.
17.2.13.6 Storage Materials and equipment will be stored to minimize the possibility of damage or lowering of quality from the time an item is stored on receipt until the time the item is removed from storage.
The manufacturers' recommendations are considered; however, the relaxation of manufacturers' storage requirements may be implemented if the storage recommendations are not reasonably necessary to preclude equipment degradation. Material and equipment will be stored at locations that have a designated storage level. The various storage levels will be defined and will have prescribed environmental conditions. The storage conditions will be in accordance with dealgn and procurement requirements to preclude damage, loss os deterioration due to harsh environmental conditions. Items 4aving limited shelf life will be identified and controlled to p eclude the use of items whose shelf life has expired.
17.2.14 INSPECTION, TEST, AND OPER7.'ING STATUS 17.2.14.1 Scope Measures will be established to ensure that necessary inspections of items have not been inadvertently bypassed or that systems or components are 'ot inadvertently operated.
17.2.14.2 General Requirements Measures will be established to indicate, by the use of marking such as stamps, tags, labels, routing cards, log books, or other suitable means, the status of inspection, test and operating status of individual structures, systems, or components.
17.2-28 Revision 15 To be determined
Procedures will provide.for controls to preclude the inadvertent use of nonconforming, inoperative, or malfunctioning structures, systems, or components.
The procedures will include the following:
- 1. Identification of authority for application and removal ;
cf status indicators-
- 2. The use of specific status indicators
- 3. Provisions for maintaining the status of the structures, systems, or components until removed by an appropriate authority.
17.2.14.3 Inspection and Test Status Measures will be established to provide for the identification of items that have satisfactorily passed required inspections and tests.
Only items that have passed inspection or testing will be used in the manufacture or installation of an item.
Documented procedure requirements will include the following:
- 1. Maintenance of the status of the item throughout fabrication and installation
- 2. Use of status indicators such as stamps, tags, markings, or labels either on the items or on documents traceable to the items
- 3. Provisions for controlling the bypassing of required inspections, tests, and other critical operations.
Items at the DAEC will be identified by status indicators to indicate whether they are awaiting inspection, acceptable for use, unacceptable, or in a hold status pending further evaluation.
17.2.14.4. Operating Status Procedures relating to the operational status of safety-related structures, systems, and components, including temporary modifications, will include the following:
- 1. Authorization for requesting that equipment be removed from service 17.2-29 Revision 15 To be determined
- 2. Checks that must be made before approving the request ;
- 3. Approval of the action to remove the equipment from service
- 4. The actions necessary to isolate the equipment and l responsibility for performing these actions
- 5. The actions necessary to return the equipment to its operating status and responsibility for these actions.
Equipment and systems in a controlled status will be identified.
Plant procedures will establish controls to identify the status-
- of inspection and test activities associated with maintenance, )
instrumentation, and control system calibration and testing. The status of nonconforming, inoperative, or malfunctioning l structures, systems, and components will be documented and identified to prevent inadvertent use.
The Technical Specifications establish the status required for safe plant operation, including provisions for periodic and non-periodic tests and inspections, of various structures, systems, and components. Periodic tests may be operational tests or tests following maintenance, and non-periodic tests may be made ;
following repairs or modifications.
i 17.2.14.5 Sequence Change Control Procedures will include the control of the sequence of required I tests, inspections, and other operations when important to safety. To change these controls, the individual procedure must be changed, which requires the same review and approval cycle as that which authorized the original procedure.
17.2.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS 17.2.15.1 Scope The nonconformance reporting system is established to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation. The responsibility for identification, documentation and segregation of nonconforming materials, parts, or components and notification to affected organizations, is that of the Corporate Quality Assurance Department. The responsibility for the disposition of the nonconforming materials, parts, or components is that of the Engineering Department, DAEC, and the Corporate Quality Assurance Department.
4 17.2-30 Revision 15 To be determined i
17.2.15.2 Identification and Segregation The identification and segregation will be sufficient to prevent inadvertent use or installation of the nonconforming item.
Material, parts, or components for which nonconformances have been identified will be immediately segregated, when practical, in areas that are reserved for nonconforming items. When segregation is impractical, administrative measures will be used, such as tagging, roping off the area, etc.
17.2.15.3 Reporting and Disposition The reporting mechanism will provide the means to disposition the nonconforming material, part, or component.
The nonconformance report will identify the item, describe the nonconformance, and contain sufficient information to evaluate the nonconformance. The nonconformance report will be transmitted to the proper organization (s) for evaluation and disposition.
17.2.15.4 Disposition The disposition will be limited to one of the following:
use-as-is, rework to original requirements, repair to an acceptable condition, or reject.
For disposition of use-as-is and repair, a technical justification will provide assurance that the item will function as originally intended. 4 1
Items that are to be repaired or reworked will be required to be reinspected or rotested to determine that the original or new acceptance criteria have been satisfied.
17.2.16 CORRECTIVE ACTION I 17.2.16.1 Scope Corrective action control measures will be established to ensure ;
that conditions adverse to quality are promptly identified, i reported, and corrected. l 17.2.16.2 Conditions Adverse to Quality Conditions adverse to quality such as failures, malfunctions, l deficiencies, deviations, defective material and equipment, l nonconformances, and abnormal occurrences will be promptly l identified and corrected. I i
17.2-31 Revision 15 To be determined
l The Nuclear Licensing Department is the responsibe for l administration of the Corrective Action Program. Administrative l responsibilities include receipt, tracking, assignment of actions I to appropriate personnel for correction, and classification of l the reported conditions as a condition adverse to quality or a l significant condition adverse to quality.
l l The Corporate Quality Assurance Department will perform an l analysis of reported conditions adverse to quality to identify l negative trends in quality performance and to determine if there l are any broad programmatic areas where trending reveals a l significant condition adverse to quality. This analysis will be l performed at least annually and will be reported to appropriate l levels of management. This analysis will be documented and i l retained as a quality assurance record.
i 17.2.16.3 Significant Conditions Adverse to Quality l I !
Significant conditions adverse to quality that impede the implementation or reduce the effectiveness of the program will be controlled. These conditions will be reported to appropriate management and evaluated. The cause of a significant condition adverse to quality shall be determined, and corrective action will be taken to preclude repetition. Significant adverse l conditions may include, but are not limited to, a recurring condition for which past corrective action has been ineffective, significant trends adverse to quality, or significant Operational Quality Assurance Program deficiencies.
17.2.16.4 Reporting of 10 CFR 21 Defects and Non-compliances A 10 CFR 21 defect and noncompliance is defined as one which could reasonably indicate a potential substantial safety hazard.
l A procedure has been established, and appropriate posting i provided in accordance with the provisions of 10 CFR Part 21, so l that IES Utilities Inc. employees will be aware of the methods by l which 10 CFR Part 21 defects and non-compliances are reported to the NRC.
l The President and Group Executive, Energy Delivery and Nuclear l Group and the Vice President, Nuclear, are designated as the IES l Utilities Inc. officers responsible for reporting defects and non-compliances, as appropriate, to the NRC.
17.2.17 QUALITY ASSURANCE RECORDS l l
17.2.17.1 Scope l Quality assurance records will be prepared, identified, collected, and protected so that adequate evidence of activities affecting quality is available.
17.2-32 Revision 15 To be determined
i 17.2.17.2 Preparation and Identification of Quality Assurance Records The organization responsible for the activity will also be
. responsible for the preparation and identification of the quality r assurance records that attest to the quality of that activity.
< As a general criterion, those documents that reflect the as-built condition of an item, component, system, or plant, and those documents that attest to the quality of an activity, item, ,
structure, or system will be treated as quality assurance records. Also, the qualification records of inspection, examination and testing personnel, and quality assurance audit i personnel, are classified as quality assurance records.
Quality assurance records will be legible, accurate, and complete.
17.2.17.3 Collection and Protection of Quality Assurance Records ;
r The quality assurance records will be collected, indexed, classified, and protected. !
The organization that generates the quality assurance record will be responsible for collecting the records. The collected quality assurance records will be classified as either lifetime or non-permanent quality assurance records. The lack of a classification will mean that the quality assurance record is a lifetime record.
The quality assurance records that have been identified and collected will be suitably protected against fire, theft, and damage. The manner in which the records are protected will be consistent with the retention period.
17.2.17.4 Record Storage on Optical Disks Records may be stored on an optical disk storage system which utilizes a write once read many (WORM) system. The image of each record shall be placed onto two optical disks, with verification of the image on each record. Should any of the images be illegible, the hard copy record is maintained as the record. One optical disk shall be used for on-line access and the second optical disk shall be stored in a records storage facility meeting the requirements for single copy storage or in a separate remote location meeting the requirements of IES Utilities Inc. l commitment to ANSI N45.2.9-1974.
17.2-33 Revision 15 To be determined
l l
l l
To ensure permanent retention of records, the records stored on ;
an optical disk are acceptably copied onto a new optical disk '
before the manufacturer's certified useful life of the original disk is exceeded. Records copied shall be verified.
Periodic random inspections of images stored on optical disks are performed to verify that there has been no degradation of image )
quality. )
1 Should it become necessary to replace the optical imaging system with a new system which is not compatible, the records stored on ;
the old system shall be converted onto the new system prior to I the old system being taken out of service. This cenversion process shall include a verification of the records converted.
l 17.2.17.5 Transfer or Destruction of Records The organization responsible for the quality assurance record will be responsible for the transfer of that quality assurance record for the purposes of microfilming and/or lifetime storage.
The transfer of quality assurance records from one organization to another organization will be accomplished by a formal mechanism that provides for the acceptance of the quality assurance record.
The destruction of quality assurance records will be accomplished only with the approval of the concerned organizations.
17.2.18 AUDITS 17.2.18.1 Scope l
A comprehensive audit program will be established and l implemented. l l
The audit program will be sufficient to verify compliance with j the Operational Quality Assurance Program and to determine the i effectiveness of the Operational Quality Assurance Program.
The responsibility for the audit system will be that of the Corporate Quality Assurance Department, the Safety Committee, and the Vice President - Nuclear.
17.2.18.2 Audit System i
The audit system will be applied to those organizations, both l external and internal to IES Utilities Inc., that are involved in safety-related activities.
17.2-34 Revision 15 To be determined
o o 17.2.18.2.1 External Organizations The audit program for suppliers is the responsibility of the Corporate Quality Assurance Department. Audits will be scheduled at a frequency commensurate with the status and importance of the activity.
In general, the audit schedule will be responsive to the performance of audits before the initiation of an activity to ensure that the proper controls are in place, during the early stages of the activity to determine that the proper controls are being implemented, and near the end of the activity to determine that all specified requirements have been met.
In general, the audit schedule will also include the performance of audits during the activity, assuming that the activity occurs over a sufficient length of time, to determine that the proper controls are being applied and no problems are occurring.
17.2.18.2.2 Internal Organizations The audit program for the internal IES Utilities Inc. l organizations is the responsibility of the following:
1.The Corporate Quality Assurance Department, to determine the compliance of the other organizations to the Operational Quality Assurance Program and to evaluate performance.
- 2. The Safety Committee, to determine the compliance of the DAEC to the Technical Specification requirements and license provisions and to evaluate performance.
- 3. The Vice President - Nuclear, to determine the overall effectiveness of the Operational Quality Assurance Program.
A prominent factor in developing and revising audit schedules l will be performance in the subject area. The audit schedule will l be revised so that weak or declining areas get increased audit I coverage and strong areas receive less coverage. l l
The following internal areas will be audited at least once per 24 l months, except where a specific frequency is listed. l l
I
- a. The conformance of facility operation to provisions l I contained within the Technical Specifications and I applicable license conditions. l l
t b. The performance, training and qualifications of the l facility staff. l ,
1 17.2-35 Revision 15 q To be determined l
]
1 c. The results of actions taken to correct deficiencies l l occurring in facility equipment, structures, systems, l or methsd of operation that affect nuclear safety at l least once per 6 months.
l l d. The performance of activities required by the Quality l Assurance Program to meet the criteria of Appendix "B",
I l e. The DAEC fire protection program and implementing ;
l procedures. !
l l l f. Independent fire protection and loss prevention l l inspection and audit annually, utilizing either i l qualified offsite licensee personnel or an outside fire I l protection firm. An inspection and audit by an outside i l qualified fire consultant shall be performed at l 1 intervals no greater than three years. l 1
l g. Any other area of facility operation considered i l appropriate by the Safety Committee or the President. j
\
l h. The radiological environmental monitoring program and I the results thereof at least once per 12 months.
l l 1. The OFFSITE DOSE ASSESSMENT MANUAL and implementing l procedures.
l l j. The PROCESS CONTROL PROGRAM and implementing l procedures.
I l k. The performance of activities required by the QC l Program for effluent and the vendors QA Program for l radiological environmental monitoring.
l l 1. The Secarity Plan and implementing procedures at least I once every 12 months (specified by regulation).
l l m. Access Authorization at least once per 24 months
] (specified by regulation).
I ,
l n. Fitness for Duty at least once every 12 months l (specified by regulation).
l l o. Emergency Plan and implementing procedures at least 1 once per 12 months (specified by regulation).
I j p. Radiological Protection at least once per 12 months l (specified by regulation).
l l q. Design change package safety evaluations.
l 17.2-36 Revision 15 To be determined l
4 & 5 17.2.18.3 Personnel Training and Qualification The personnel who participate in audits will have sufficient experience and/or training to fulfill their role in the audit.
Personnel who perform as Lead Auditors will be trained, qualified, and certified.
A Lead Auditor will review the experience of each potential team member, determine their acceptability to perform the audit, determine if any additional training is required, and ensure that the additional training is performed if required. ;
17.2.18.4 Performance of Audit The selected audit team shall collectively have experience or i training commensurate with the total scope of the audit.
Audit checklists will be developed for the total scope of the l audit.
The audit shall be initiated by a pre-audit conference to i introduce the audit team and to confirm the scope and plan of the !
audit. A pre-audit planning meeting as defined in Appendix A may be substituted for the pre-audit conference.
Audits shall be concluded by the Audit Team with a post-audit conference at which the Audit Team will discuss the audit findings and clarify any misunderstandings.
17.2.18.5 Report and Closeout of Audit Findings The audit will be documented by an audit report signed by a Lead Auditor.
The audit report shall be sent to the responsible management of the audited organization.
The audit findings will be tracked to ensure that corrective action has occurred.
The Corporate Quality Assurance Department will evaluate the responses to the audit findings. The evaluation will include the necessity for re-audits, submittal of documentation, or any other means of verifying the corrective action. Statements by the audited organization that define the corrective action may be accepted.
17.2-37 Revision 15 To be determined
a ea The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred prior to closure of the audit findings.
Inadequate or unresponsive corrective action will be brought to the attention of appropriate levels of management.
C:\17-2.kep\17.2.R15 17.2-38 Revision 15 To be determined
IES Utilities Inc. l Appendix A to UFSAR/DAEC-1 Chapter 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Quality Assurance Program Description (QAPD)
INTRODUCTION This Appendix describes the manner by which the IES Utilities l Inc. Operational Quality Assurance Program for the Duane Arnold l Energy Center (DAEC), as set forth in the Quality Assurance Program Description (QAPD), UFSAR Chapter 17.2, conforms to NRC Regulatory Guides listed in the June 6, 1990, letter from Region III (Miller) to Iowa Electric (Liu) and certain other commitments previously contained in Table 2-1 of the Quality Assurance Manual. Comments and clarifications to these specific commitments are identified in this Appendix.
IES Utilities Inc. position on each ANSI standard which is l endorsed by a Regulatory Guide to which IES Utilities Inc. is l committed is stated in either the UFSAR or the QAPD. Other ANSI standards are not requirements for IES Utilities Inc. even if l.
they are listed as references in a standard endorsed by a Regulatory Guide to which IES Utilities Inc. is committed. (Such i standards may, of course, be used as guidance.) However, a section of a standard which is specifically referred to in a standard endorsed by a Regulatory Guide to which IES Utilities l Inc. is committed is a requirement for IES Utilities Inc. unless I an exception is stated.
IES Utilities Inc. is not committed to ANSI N45.2 for the l operational phase. Regulatory Guide 1.33, Revision 2, Section B,
" Discussion" states ANSI N18.7-1972, along with ANSI N45.2-1971,
" Quality Assurance Program Requirements for Nuclear Power Plants", was endorsed by Regulatory Guide 1.33. The dual ;
endorsement was necessary in order for the guidance contained in the regulatory guide to be consistent with the requirements of Appendix B to 10 CFR Part 50; however, this dual endorsement caused some confusion among users. To clarify this situation, ANSI N18.7-1972 was revised so that a single standard would define the general quality assurance program " requirements" for the operation phase. This revised standard was approved by the American National Standards Committee N18, Nuclear Design Criteria. It was subsequently approved and designated N18.7-1976/ANS-3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants", by the American National Standards Institute on February 19, 1976. Therefore, for the operations phase, where a standard endorsed by a Regulatory Guide refers to the uce of ANSI N45.2 in conjunction with that Standard, IES Utilities Inc. inserts the ANSI Standard l N18.7-1976.
17.2 A-1 Revision 15 To be determined j i
1
7 i
1.' s
.i t
1.0 REGULATORY GUIDE 1.8, " Personnel Selection and-Training" ;
COMMENTS.AND CLARIFICATIONS: ,
t l IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
l 1.1 IES Utilities.Inc's. commitment is to Regulatory Guide'1.8, Revision 1-R, September 1975.(reissued May ;
'1977), which endorses ANSI N18.1-1971. However, the '
l IES Utilities Inc. commitment is to ANSI /ANS 3.1-1978, which is a revision of N18.1-1971.
1.2 With respect to selection and training of' security-l personnel, IES Utilities Inc. does not commit to the j standard [ ANSI N18.17-1973 (ANS 3.3)]' referred to in ;
ANSI /ANS 3.1-1978, Sections 1'(Scope) and 6 l (References). The IES Utilities Inc. training and qualification plan for security personnel complies ;
with 10 CFR Part 73, Appendix B. l i
2.0 REGULATORY GUIDE 1.26, " Quality Group Classifications and Standards for Water , Steam , and Radioactive-Waste-Containing Components of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
l The IES Utilities Inc. commitment to Safety Guide 26 (3/23/72), Quality Group Classifications and Standards, is stated in UFSAR Chapter 1.8, Conformance to NRC Fegulatory Guides.
3.0 REGULATORY GUIDE 1.28, " Quality Assurance Program Requirements (Design and Construction)"
COMMENTS AND CLARIFICATIONS:
This Regulatory Guide (Safety Guide 28, dated June 7, 1972) endorses ANSI N45.2 and is not applicable to the operating .
phase. DAEC's operational QA program is based on l Regulatory Guide 1.33, Rev. 2, as stated in UFSAR Section !
1.8.
4.0 REGULATORY GUIDE 1.29, " Seismic Design Classification" COMMENTS AND CLARIFICATIONS: !
l l The IES Utilities Inc. commitment to Safety Guide 29 l (6/7/72), Seismic Design Classification, is stated in UFSAR Section 1.8, Conformance to NRC Regulatory Guides.
17.2 A-2 Revision 15 To be determined
.----..-.c_. . . _
e i ,
f 5LO REGULATORY GUIDE 1.30, " Quality Assurance Requirements for !
the Installation, Inspection, and Testing of Instrumentation and Electric Equipment" COMMENTS AND CLARIFICATIONS: -;
i IES Utilities Inc. complies with the Regulatory l Position of- l this Regulatory Guide with the following clarifications 5.1 The IES Utilities Inc. commitment is to Safety Guide l' 30, dated August 11, 1972 and therefore by reference to ANSI N45.2.4-1972 which it endorses. ;
l 5.2 For maintenance and modification activities, IES l !
Utilities Inc. shall comply with the Regulatory l i
Position established by this Regulatory Guide in that the quality assurance program requirements. included j therein (subject to the clarifications below) shall apply. Technical requirements associated with maintenance and modification activities shall be ;
equal to or better than the original-requirements (e.g., Code requirements, design and construction specification requirements, and inspection requirements). >
5.3 Regulatory Position C.1 states that ANSI N45.2.4-1972 should be used in conjunction with~ ANSI N45.2-1971. .
In lieu of this, IES Utilities Inc. uses ANSI l l N45.2.4-1972 in conjunction with ANSI N18.7-1976. ;
5.4 Section 2.2(5)(d) of ANSI N45.2.4-1972 requires evidence of compliance by manufacturer with purchase requirements, including quality assurance requirements, before the requirements of ANSI N45.2.4-1972 are implemented. In lieu of this, IES l Utilities Inc. may proceed with installation, l inspection, and testing activities for equipment lacking its quality documentation provided that this equipment has been identified and controlled in accordance with IES Utilities Inc.'s nonconformance l reporting system.
5.5 With respect to Section 2.5.2 of ANSI N45.2.4-1972, l calibration and control covers two classes of instrumentation used by IES Utilities Inc.: (1) l portable equipment and (2) permanently-installed equipment. With respect to permanently-installed instrumentation, in lieu of marking the equipment to indicate the date of the next required calibration, a computer-based preventative maintenance' program is used. Once a permanently-installed instrument is ,
l 17.2 A-3 Revision 15 i To be determined l i
- .' c identified as needing control, a calibrction frequency is assigned, and the information'is entered into the data base. The calibration task is then automatically tracked and tasked by the data base. A "DO NOT USE Until Tested and Calibrated"'or equivalent sticker is applied to instruments not calibrated before their due date and to instruments unacceptable for use. The provisions of ANSI N45.2.4-1972, Section 2.5.2, are applied to portable equipment. -
5.6 Section 3 of ANSI N45.2.4-1972 regarding
" Preconstruction Verification" states it is necessary to verify that the quality of an-item has not suffered during the interim period and it is not intended to duplicate inspections but rather verify that items are in a satisfactory condition for installation. Verifications and checks are then required. In lieu of these verifications and checks, l IES Utilities Inc. considers the provisions of QAPD Sections 17.2.8 (Identification and Control of Materials,. Parts, and Components) and 17.2.13 (Handling, Storage and Shipping) to be equivalent.
5.7 The last paragraph of Section 6.2.1 of ANSI N45.2.4-1972 requires that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identity of person who performed the ;
calibration. In lieu of this, for permanently- t installed instrumentation, the calibration status is reflected in a computerized preventive maintenance ,
program as described in Section 5.5 above. 1 6.0 REGULATORY GUIDE 1.33, " Quality Assurance Program.
Requirements (Operation)"
COMMENTS AND CLARIFICATIONS:
l IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications: )
i 6.1 The commitment is to Regulatory Guide 1.33, Rev. 2, l February 1978, and to ANSI N18.7-1976/ANS-3.2 which it endorses.
6.2 Regulatory Guide 1.33 Regulatory Position, Section !
C.2, also lists fifteen Regulatory Guides and ANSI ;
standards that are referenced in ANSI N18.7-1976/ANS- l l 3.2. The IES Utilities Inc. position with respect to ,
each of these standards is stated elsewhere in this i Appendix A.
17.2 A-4 Revision 15 To be determined
- . - ._ - - - _ ~ -
. i
~'
i 6.3 Regulatory Guide 1.33 Regulatory Position,'Section l ,
C.4, refers to Section 4.5, " Audit Program", of ANSI l N18.7-1976/ANS-3.2 and lists specified audit l '
frequencies for three (3) audits. The frequencies [
for audits are.now specified in UFSAR Section l 17.2.18.2.2. l !
6.4 Section.4.3.2.3 (Quorum for Independent Review. l 4 Program) of ANSI N18.7-1976/ANS-3.2 indicates a. -i Quorum for formal meetings "... shall consist of not ,
less than a majority of the principals, or' duly I appointed alternatives..." Additionally, "the ;
chairman-(or his duly appointed alternate)~shall be ;
presentJfor all formal meetings". Section 6.5.2.6 of i Appendix A (Technical Specifications) to the' Facility Operating License indicates "A Quorum of the Safety Committee shall consist of the Chairman or Vice Chairman and at least four members with a maxfmuu of 1 . two alternates as voting members". The requirements ;
of the Technical' Specifications as stated above shall govern.
L 6.5 With respect to Section 4.3.4 (1), Subjects Requiring l Independent Review, of ANSI N18.7-1976/ANS-3.2, the DAEC Safety Committee is not required to review-safety evaluations of changes in the facility which ,
are completed under 10 CFR Part 50.59. ;
6.6 Section 5.1 (Program Description) of ANSI N18.7- l 1976/ANS-3.2 requires a " summary document" for the Quality Assurance Program. The QAPD and Appendix A L thereto fulfill this requirement for IES-Utilities l l Inc. l 6.7 Section 5.2.2 (Procedure Adherence) - Temporary _ l procedure changes which do not change the intent of .
the procedure are required to be approved by two members of the plant staff, of which one shall hold a senior operators license. In lieu of one of these i members being the on-shift senior operator, a non- :
shift senior licensed operator may approve of these ;
temporary changes consistent with the DAEC Technical Specifications.
6.8 Paragraph 6 of 5.2.6 of ANSI N18.7-1976, states: l ,
"where required documentary evidence is not l available, the associated equipment or materials must I be considered nonconforming in accordance with l .
Section 5.2.14. Until suitable documentary evidence l is available to show the equipment or material is in l d conformance, affected systems shall be considered to l l
17.2 A-5 Revision 15 !
To be determined )
l
- . -= . . . . - -
~. ..
-l be inoperable and. reliance shall not be placed on l such systems to. fulfill their intended safety
.l functions." This paragraph applies to those
'l situations where documentation necessary to l demonstrate the operability (performance) of the '
l . equipment is missing. Missing inspection and test l documentation which does not affect confidence in the l- operability.of the subject equipment may be evaluated l in accordance with the nonconformance reporting l system and a determination of operability made l consistent with the guidelines of NRC Generic Letter
- l. 18.
l 6.9 Section 5.2.7 (Maintenance and Modifications) of' ANSI N18.7-1976/ANS-3.2 lists six standards that are to be applied.to activities occurring during the l operational phase that are comparable to related activities during design and construction. Five of )
these standards are addressed elsewhere in this i Appendix A.
)
l IES Utilities Inc. does not follow one of those listed, ANSI N101.4-1972, Quality Assurance for Protective Coatings Applied to Nuclear Facilities.
l See UFSAR Section 17.2.9.5 for IES Utilities Inc.'s controls relative to "Special Protective Coatings".
l 6.10 With respect to Section 5.2.9 (Plant Security and' Visitor Control) of ANSI N18.7-1976/ANS-3.2, the DAEC Security Plan meets the stated requirements.
However, the Standard references ANSI N18.17 for l guidance. IES Utilities Inc. is not committed to I ANSI N18.17. The DAEC Security Plan complies'with 10 I CFR Part 73. 1 I
l 6.11 Section 5.2.15 (Review, Approval.and Control of Procedures) of. ANSI N18.7-1976/ANS-3.2, fourth paragraph requires:
" Plant procedures shall be reviewed by an individual knowledgeable in the area affected-by the procedure no less frequently than j every two years to determine if changes are necessary or desirable."
17.2 A-6 Revision 15 To be determined y $+mt4r *y .a-P =---*y 7, ~y .i..-g - -.6 , m + = = - e,e..- cc r-+- -m.mm
7 This requirement is replaced by the following:
" Plant procedures shall be reviewed, in accordance with the following, to determine if changes are necessary or desirable:
- 1) Non-routine procedures, such as emergency operating procedures, off-normal procedures, those that implement the emergency plan, and others where usage may be dictated by an event, shall be reviewed at least every two years by an individual knowledgeable in the area affected by the procedure.
- 2) The procedures which have a frequency of use which exceeds two years, shall be reviewed prior to use, or every two years by an individual knowledgeable in the area affected by the procedure.
- 3) Routine plant procedures which are not addressed by (1) and (2) above shall be maintained through use of the procedure revision process. The need for changes to these procedures are identified through other processes, such as: plant modifications; nonconformance reporting system; test control; performance of operations and maintenance activities; updates to the Updated Final Safety l Analysis Report (UFSAR); vendor manual control; reviews of industry operating experience; Operating / License Amendments; design specification changes; control of procedure changes; Quality Assurance audits; training; and other routine activities under the Quality Assurance Program. In addition, on a frequency not to exceed 2 years, an independent audit or assessment of a representative sample of routine plant procedures shall be performed to evaluate the effectiveness of the procedure review and revision program.
6.12 Section 5.2.16 (Measuring and Test Equipment) of ANSI l N18.7-1976/ANS-3.2 requires that equipment be suitably marked to indicate calibration status.
Section 5.2.16 refers to ANSI N45.2.4-1972, which requires (Section 2.5.2, Calibration and Control) that equipment be suitably marked to indicate date of 17.2 A-7 Revision 15 To be determined
next required calibration and (Section 6.2.1, Equipment Tests) that items requiring calibration be tagged or labeled on completion, indicating date of l calibration and identity of the person who performed the calibration. See the discussion provided in l Section 5.5 of this document for IES Utilities Inc.'s commitment.
l 6.13 Instead of the format specified in Section 5.3.9.1, (Emergency Procedure Format and Content) of ANSI l N18.7-1976/ANS- 3.2, of IES Utilities Inc.'s DAEC l Emergency Operating Procedures (EOPs) are in a l flowchart format. The contents of the DAEC l Engineering Operating Procedures are in accordance l with the guidelines of the BWR Owner's Group (BWROG)
Emergency Procedure Guidelines, as reviewed and approved in the NRC Safety Evaluation Report, BWROG EPG, Revision 4, September 1988.
7.0 REGULATORY GUIDE 1.37, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
l IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
7.1 The commitment is to Regulatory Guide 1.37, Revision 0, 3/16/73, and to ANSI N45.2.1-1973 which it endorses.
Il l 7.2 IES Utilities Inc. shall comply with the Regulatory Position established in this Regulatory Guide for maintenance and modification activities in that the quality assurance program req:tirements included therein shall apply. Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (e.g., Code requirements, design and construction specification requirements, and inspection requirements).
17.2 A-8 Revision 15 To be determined
8.0 REGULATORY GUIDE 1.38, " Quality Assurance Requirements for packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
IES Utilities Inc. complies with the Regulatory Position of l this Regulatory Guide with the following clarifications:
8.1 The IES Utilities Inc. commitment is to Regulatory l Guide 1.38, Revision 2, May 1977, which endorses ANSI N45.2.2-1972. However, the IES Utilities Inc. l commitment is to the later version of this Standard, ANSI /ASME N45.2.2-1978.
8.2 The applicability of the requirements of Section 3 and 4 and the Appendix of ANSI N45.2.2, and the paragraphs of the Regulatory Guide relating to these Sections (C.1.c, C.1.e, and C.2), is limited to the procurement of major plant equipment replacements; they are not applied to procurement of operating plant spares and modifications.
l 8.3 The shipping damage inspections required by Section 5.2.1 of ANSI N45.2.2 will be performed by ,
Storekeepers prior to unloading in lieu of ANSI l N45.2.6 certified inspectors. A shipping damage ;
inspection is performed by ANSI N45.2.6 certified '
l inspectors at a later point in the receiving process for applicable items.
9.0 REGULATORY, GUIDE 1.39, " Housekeeping Requirements for Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
IES Utilities Inc. complies with the Regulatory Position of l this Regulatory Guide with the following clarification:
9.1 The IES Utilities Inc. commitment is to Regulatory l ,
Guide 1.39, Revision 2, September 1977, and to ANSI !
N45.2.3-1973 which it endorses.
17.2 A-9 Revision 15 To be determined
l l
l 10.0 REGULATORY GUIDE 1.54, " Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
l IES Utilities Inc. is not committed to Regulatory Guide l 1.54, June 1973. IES Utilities Inc.'s controls relative to protective coatings are contained in UFSAR Section i 17.2.9.5.
11.0 REGULATORY GUIDE 1.58, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" COMMENTS AND CLARIFICATIONS:
l l IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
l 11.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.58, Revision 1, September 1980, and to ANSI N45.2.6-1978 which it endorses.
11.2 ANSI N45.2.6-1978 Section 1.0, " Applicability", first paragraph, states that this standard applies to personnel who perform inspections, examinations, and tests during fabrication prior to and during receipt of items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.
l At IES Utilities Inc., the qualification of Quality l Control personnel (IES Utilities Inc. or contractor employees) performing inspection or examination work at the plant shall be in accordance with Regulatory Guide 1.58 (ANSI N45.2.6-1978). Personnel performing testing activities shall have appropriate experience and training to assure competence in accordance with Regulatory Guide 1.8 (ANS 3.1-1978).
11.J Regulatory Position C.1 of Regulatory Guide 1.58 states that "for qualification of personnel (1) who approve preoperations, startup, and operation test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, startup, and operational tests, the guidelines contained in Regulatory Guide 1.8, " Personnel Selection should be followed in lieu of the l guidelines of ANSI N45.2.6-1978". IES Utilities Inc.
complies with this Regulatory Position and, furthermore, test procedures are reviewed and 17.2 A-10 Revision 15 To be determined
l l
l approved by a committee consisting of members I representing a broad range of experience in engineering, operation and quality assurance; the tests shall be performed by qualified personnel and i monitored by quality assurance personnel, to ensure l compliance with the test procedure requirements.
11.4 ANSI N45.2.6 Section 1.2, " Applicability", third paragraph, requires that this standard be used in )
conjunction with ANSI N45.2. IES Utilities Inc. is l j not committed to ANSI N45.2. 1 i
11.5 ANSI N45.2.6 Section 1.2, " Applicability", fourth !
paragraph, requires that this standard be applied to j organizations other than IES Utilities Inc. The l l specific applicability of this standard to other l organizations is specified on a case-by-case basis in the procurement documents issued to those suppliers I of materials and services. i 11.6 Regulatory Guide 1.58 Revision 1, in Section B, l
" Discussion", endorses ASNT Recommended Practice No. i SNT-TC-1A-1975 for the qualification of I nondestructive testing personnel. In accordance with l the IES Utilities Inc. ASME Section XI program the l j 1980 Edition with addenda through Winter 1981 govern. '
Section IWA-2300 of this Code requires nondestructive personnel to be qualified to SNT-TC-1A-1980.
In accordance with Regulatory Guide 1.147, ASME Code Case N-356, and IES Utilities Inc. ASME Section XI l Relief Request NDE-006, the recertification period for NDE Level III personnel shall be every five years as opposed to the three years as stated in SNT-TC-1A-1980, paragraph 9.7.1.
12.0 REGULATORY GUIDE 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
IES Utilities Inc. complies with the Regulatory Position of l this Regulatory Guide. The IES Utilities Inc. commitment l is to Regulatory Guide 1.64, Revision 2, June 1976, and to ANSI N45.2-11-1974 which it endorses.
17.2 A-11 Revision 15 To be determined
e -
13.0 REGULATORY GUIDE 1.74, " Quality Assurance Terms and Definitions" COMMENTS AND CLARIFICATIONS:
l IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
l 13.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.74, February 1974, and to ANSI N45.2.10-1973, which it endorses.
l 13.2 IES Utilities Inc. has adopted the definition of
" Audit" which appears in ANSI /ASME N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants, in lieu of the definition in ANSI N45.2.10-1973.
14.0 REGULATORY GUIDE 1.88, " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records" COMMENTS AND CLARIFICATIONS:
l IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
l 14.1 The IES Utilities Inc, commitment is to Regulatory Guide 1.88, Revision 2, October 1976, and to ANSI N45.2.9-1974 which it endorses.
14.2 Section 3.2.2 of ANSI N45.2.9-1974 specifies establishment of an "index". As we understand this term, it can include a collection of documents or indices (some of which may be computer-based) which, when taken together, supply the information attributed to an "index" in the Standard. Record retention requirements for records are specified.
The specific retention times for records are indicated when the records are transmitted for i permanent storage. IES Utilities Inc. utilizes computer-aided retrieval systems to index and locate records. ;
14.3 Section 5 of ANSI N45.2.9-1974, " Storage, Preservation and Safekeeping", provides no !
distinction between temporary and permanent i facilities. To address temporary storage, the i following position is established: Active records :
(those completed but not yet duplicated or placed on !
microfilm) may be temporarily stored in one-hour fire rated file cabinets until such time as they are 17.2 A-12 Revision 15 To be determined l
l l
l
o .
duplicated or microfilmed. Open-ended documents--
those revised or updated on a more-or-less continuing basis over an extended period of time (e.g. personnel qualification and training documents) and those which are cumulative in nature (e.g. nonconforming item logs and control room log books)--are not considered as QA records since they are not " complete". These types of documents shall become QA records when they are issued as a specific revision, when they are filled-up or discontinued, or on a periodic basis when the completed portion of the on going document shall be transferred to permanent storage as a
" record".
14.4 The requirements of Section 4.3 (Receipt Control) of ANSI N45.2.9-1974 are implemented only for the permanent record files and not for temporary record files.
14.5 The requirements of Section 5.3 (Storage) of ANSI N45.2.9-1974 are implemented only for the permanent )
record files and not for temporary record files.
l 15.0 REGULATORY GUIDE 1.94, " Quality Assurance Requirements for '
Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase l of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
IES Utilities Inc, complies with the Regulatory Position of l this Regulatory Guide with the following clarifications: )
i 15.1 The IES Utilities Inc. commitment is to Regulatory l l Guide 1.94, Revision 1, April 1976, and to ANSI l N45.2.5-1974 which it endorses, j 15.2 For modification activities IES Utilities Inc. shall l comply with the Regulatory Position established by this Regulatory Guide in that the quality assurance program requirements included therein shall apply.
Technical requirements associated with modification activities shall be equal to or better than the original requirements (e.g., Ccde requirements, design and construction specification requirements, '
and inspection requirements). j I
17.2 A-13 Revision 15 To be determined
l I
O o l
16.0 REGULATORY GUIDE 1.116, " Quality Assurance Requirements for l Installation, Inspection, and Testing of Mechanical l Equipment and Systems" '
COMMENTS AND CLARIFICATIONS:
l IES Utilities Inc. complies with the Regulatory Position of l this Regulatory Guide with the following clarifications- l I
l 16.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.116, Revision 0-R, June 1976, with first page j revision May 1977, and to ANSI N45.2.8-1975 which it !
endorses.
l 16.2 IES Utilities Inc.'s commitment to this Regulatory Guide is applicable to maintenance and modification activities in that the quality assurance program requirements included therein shall apply. Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (e.g., Code requirements, design and construction specification requirements, and inspection requirements).
17.0 REGULATORY GUIDE 1.123, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
l IES Utilities Inc. complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
l 17.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.123, Revision 1, July 1977, and to ANSI N45.2.13-1976 which it endorses.
18.0 REGULATORY GUIDE 1.144, " Auditing of Quality Assurance Programs for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
l IES Utilities Inc, complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
l 18.1 The IES Utilities Inc. commitment is to Regulatory Guide 1.144, Revision 1, September 1980, and to ANSI N45.2.12-1977 which it endorses.
18.2 Secti n 1.1, " Scope", and Section 1.2,
" Applicability", of ANSI N45.2.12-1977 reference ANSI l N45.2. IES Utilities Inc. is committed to ANSI 17.2 A-14 Revision 15 To be determined i
i . . i j
l N18.7-1976 for the operational phase, consistent with its commitment to Regulatory Guide 1.33.
18.3 Regulatory Position C.3.b(1) states that external audits, after the award of a contract, are not necessary for procurement actions where acceptance of the product is in accordance with Section 10.3.2,
" Acceptance by Reviewing Inspection", of ANSI N45.2.13-1976. The suppliers of products that meet this requirement are included on the IES Utilities l i Inc. external audit schedule and are audited on a l triennial basis.
18.4 ANSI N45.2.12, Section 4.3.1 " Pre-Audit Conference" For internal audits, a " pre-audit planning meeting" i may be substituted for the " pre-audit conference."
The pre-audit planning meeting should accomplish the following:
- 1) The Lead Auditor to present the proposed audit plan and an opportunity for the audited organizations to provide input to the proposed audit plan.
- 2) Introduce the Lead Auditor and identify proposed audit team members. Those audit team members available will be introduced.
Note: Non-utility team members are usually not available at these meetings.
- 3) Counterparts are invited to these audit planning meetings as part of the planning process.
- 4) The audit schedule is presented, including a tentative exit date. The final exit date is announced separately during the audit period.
- 5) The channels of communication are opened at the audit planning meeting through ,
participation in the audit planning process.
- 6) Following the audit planning meeting, the Lead Auditor will finalize the audit plan.
19.0 REGULATORY GUIDE 1.146, " Qualification of Quality Assurance -
Program Audit Personnel for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
IES Utilities Inc. complies with the Regulatory Position of l this Regulatory Guide with the following clarifications:
19.1 The IES Utilities Inc. commitment is to Regulatory l Guide 1.146, August 1980, and to ANSI N45.2.23-1978 which it endorses.
17.2 A-15 Revision 15 To be determined
. - - ~. . . _ - - . . . ._ - - . . -.- . . .. - -
1 i
.e ..
19.2 ANSI N45.2.23 Section 1.2 references ANSI N45.2. For l IES Utilities Inc., the entities subject to audit are defined in 10 CFR 50 Appendix B and ANSI N18.7-1976.
l This is consistent with IES Utilities Inc.'s commitment to Regulatory Guide 1.33 which endorses ANSI N18.7-1976, in lieu of ANSI'N45.2.
l 20.0 REGULATORY GUIDE 1.155, " Station Blackout" 2
l COMMENTS AND CLARIFICATIONS: !
I I l IES Utilities Inc. complies with Appendix A, " Quality l l Assurance Guideline for Non-Safety Systems-and Equipment," !
l to Regulatory Guide 1.155, Revision 1, August 1988.
l l 21.0 REGULATORY GUIDE 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams !
and the Environment" ,
i' COMMENTS AND CLARIFICATIONS l IES Utilities Inc. complies with the Regulatory Position in I Regulatory Guido 4.15, Revision 1, February 1979.
l 22.0 ASME B&PV Code,Section XI, 1980 Edition with Addenda ,
through Winter 1981 :
COMMENTS AND CLARIFICATIONS:
l The IES Utilities Inc. commitments relative to the Ten-Year ;
Inspection Program and the Pump and Valve Test Program are i established separately in formal correspondence with the i Nuclear Regulatory Commission and incorporated into l appropriate IES Utilities Inc. documents. ,
i i
Procedur\Apx17 2.kep i 17.2 A-16 Revision 15 To be determined l p --w-,v---g,~w- - - - - 4 - e - -
m *---
7 i
.. 6 Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description
- 1. Name Change - Various Sections Identification of the Change:
UFSAR 17.2 and Appendix A thereto have been revised throughout to reflect the change in the name of the utility from Iowa Electric Light and Power Company to IES Utilities Inc.
Reason for the Change:
The name of the company was changed with the merger of Iowa )
Electric Light and Power Company and Iowa Southern Utilities. This change in utility name was previously communicated to the NHC via N-94-0018 of January 21, 1994 (J. Franz, Jr. to Dr. Thomas J. Murley.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments" The change in utility name is administrative. This change did not affect personnel, organizational structure, or the implementation of the Operational Quality Assurance Program.
This change is not a reduction in commitment. 1
- 2. 17.2.1.2, Manager, Corporate Quality Assurance Identification of the Changes:
The communication links for the Manager, Corporate Quality l Assurance have been updated to reflect the current I organizational structure.
The " Outage Manager" was deleted as a direct interface since i this position now reports to the Plant Superintendent-Nuclear.
i The previous position in the " Nuclear Fuels Group" was absorbed into the new Nuclear Business Unit group.
The responsibilities of the Quality Assurance Procurement Supervisor ( 17.2.1.2.1), Quality Assurance Assessment Supervisor (17.2.1.2.2), Quality Control Supervisor (17.2.1.2.3) and the Quality Assurance Training Coordinator (17.2.1.2.4) have all been incorporated under this position.
Page 1 of 36
m
, a Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Note: Changes which affected the responsibilities of the previously defined positions are addressed under those specific positions.
In support of this change, paragraphs 17.2.1.2.1, 17.2.1.2.2, 17.2.1.2.3, and 17.2.1.2.4 have been deleted and section 17.2.1.2.5 renumbered as 17.2.1.2.1 (Stop Work Authority).
Reason for the Changes:
In April 1994 a more effective organizational structure was adopted at DAEC. This reorganization resulted in the above described changes at the Manager level of the organization.
The incorporation of resporsibilities from those positions which previously reported . the Manager, Corporate Quality Assurance was done in supp .t of simplifying the QAPD and to allow future organizational flexibility without impacting the QAPD.
Basis for Coacluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments" The changes in ccmmunication links for the Manager, Corporate Quality .Tssurance are administrative in nature and continue to comply with the provisions of 10 CFR 50 Appendix B and the previous QA program commitments. These changes do not result in a reduction in commitment.
The incorporation of responsibilities previously assigned below the Manager, Corporate Quality Assurance to the Manager, Corporate Quality Assurance has no impact on the responsibilities of the Quality Assurance Department. This change is administrative in nature and is not a reduction in commitment.
- 3. 17.2.1.2.1, Quality Assurance Procurement Supervisor Identification of the Changes:
The description of the responsibilities of the Quality :
Assurance Procurement Supervisor have been deleted. These responsibilities are now listed as being as signed to the Manger, Corporate Quality Assurance. There are no changes in the previously stated responsibilities.
Page 2 of 36 )
l i
l
]
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Reason for the Changes:
Assigning these responsibilities to the Manager, Corporate Quality Assurance simplifies the QAPD and allows for future organizational flexibility without impacting the QAPD.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments" This change has no impact on the responsibilities of the Quality Assurance Department. This change is administrative in nature and is not a reduction in commitment.
- 4. 17.2.1.2.2, Quality Assurance Assessment Supervisor Identification of the Changes:
The description of the responsibilities of the Quality Assurance Assessment Supervisor have been deleted. These responsibilities are now listed as being assigned to the Manager, Corporate Quality Assurance with the following changes: l e responsibility "for the implementation of the i corrective action program" is deleted a responsibility for " trending program" is replaced with responsibility for " performing analysis and trending of reported conditions adverse to quality" e responsibility for " coordinating the review of divisional procedures that are responsive to the requirements of this Operational Quality Assurance Program" is deleted.
The description of the organizational structure under the QA Assessment Supervisor has been deleted.
Reason for the Changes:
The " implementation of the Corrective Action Program" is the responsibility of all personnel (i.e., all personnel are responsible for the initiation of corrective action documents). The administration of the Corrective Action Program, formerly performed by the Quality Assurance Department, is now assigned to the Nuclear Licensing Department.
Page 3 of 36
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description The previously-specified responsibility for the " trending program" was not clear. The responsibility for trending is more clearly described as " performance of analysis and trending of reported conditions adverse to quality."
Further discussion on this change is provided in the " reason for the changes" for section 17.2.16.2.
The responsibility for " coordinating the review of divisional procedures that are responsive to the requirements of this Operational Quality Assurance Program" is deleted because this function is not an effective use of the Quality Assurance Department resources. See the description of changes for Section 17.2.6.3.
The description of the organization is unnecessary and has been deleted. Furthermore, there are no longer separate groups for the performance of audits and surveillances.
Personnel have now been assigned to functional areas.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
Responsibility for " implementing the corrective action program" was deleted from the responsibilities of the Quality Assurance Department because all appropriate personnel must have that responsibility consistent with the provisions of 10 CFR 50 Appendix B, Criterion XVI,
" Corrective Action". In fact, the Corrective Action Program has been implemented by all personnel and continues to be so implemented. In addition, responsibility for the administration of the Corrective Action Program has been assigned to the Manager, Nuclear Licensing.
The above-described change regarding the " trending program" clarifies the purpose of trending (i.e., perform analysis and trending of reported conditions adverse to quality).
This change is consistent with the provisions of 10 CFR 50 Appendix B, Criterion XVI, " Corrective Action". This change is not a reduction in commitment. For further details regarding corrective action, see the changes described for section 17.2.16.2.
The deletion of the responsibility for " coordinating the l review of divisional procedures that are responsive to the !
requirements of this Operational Quality Assurance Program" l 1s a reduction in commitment from that previously specified (See UFSAR Section 17.2.6.3). However, this change is consistent with the requirements of 10 CFR 50 Appendix B Page 4 of 36 i
i
9 3 Discuns!.on of Changes Attachment 2 in tha quality Assurance to NG-94-4459 Pron. a Description Criterion V, "Instruc .ms, Procedures, and Drawings" in that 10 CFR Part 50 Apg slix B does not require a review of these documents by Quality Assurance. Quality Assurance Department resources are better utilized in defining the requirements and policies at the Quality Assurance Manual level rather than in reviewing the implementing procedures which are the responsibility of each department. Quality Assurance can then also better utilize its resources in verifying that the requirements and policies are being appropriately implemented through verification activities versus in-line review activities. In conclusion, this is a reduction in commitment, but not a reduction in the effectiveness of the Operational Quality Assurance Program.
See also section 17.2.6.3 concerning this change.
The change in organizational structure in this area is an improvement in the utilization of staff resources with a stronger emphasis on specialization in functional areas.
This change is consistent with the provisions of 10 CFR Part 50, Appendix B, Criterion I, organization. This change is not a reduction in commitment.
- 5. 17.2.1.2.3 Quality Control Supervisor Identification of the Changes:
The description of the responsibilities of the Quality Control Supervisor have been deleted. Those responsibilities are now listed as being assigned to the Manager, Corporate Quality Assurance with the following changes, e responsibility for " preparing receiving inspection plans" is deleted e responsibilities relative to the Ten Year Inservice Inspection Program, including performance of required examinations and evaluation of indications of defects have been deleted e The word " Additionally" has been deleted e responsibility for training Quality Control personnel in non-destructive examination and other inspection activities has been changed to responsibility for assuring that such personnel maintain proficiency and certification ,
l Page 5 of 36
j Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Reason for the Changes:
The responsibility for " preparing receiving inspection plans" was removed because this is very prescriptive,'and the Quality Control Supervisor already has the assigned responsibility for " performing receiving, in-process, and final inspections". Quality Control Engineering continues to prepare " receiving inspection plans" at this time, but it is anticipated that this function may be performed by the Procurement Engineering group in the future. Tne requirements for receiving inspection are specified by Engineering.
The responsibilities for the Ten Year Inservice Inspection program have been deleted from the Quality Control Supervisor because the Corporate Level III NDE now reports to the Engineering Department. This change provides for a more efficient organizational structure since the Engineering Department previously had overall responsibility for developing the inspection program as defined by section 17.2.10.4. The responsibility for training of NDE personnel is now assigned to Engineering which is the reason for modifying the description of responsibilities for the Quality Control Supervisor.
The removal of the word " additionally" from the beginning of the third paragraph is editorial.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
The removal of the specific responsibility to " prepare receiving inspection plans" eliminates reference to a very -
specific activity which supports the receiving inspection process required by 10 CFR 50 Appendix B Criterion VII,
" Control of Purchased Material, Equipment and Services".
The Quality Control Supervisor remains resoonsible for the performance of " receiving inspection" (a function required by 10 CFR 50 Appendix B Criterion VII) and continues to perform this function consistent with the provisions of 10
! CFR 50 Appendix B Criterion V, " Instructions, Procedures and Drawings". Only the specific of who prepares the " receiving i'
inspection plan" has been removed. Further details regarding " Receiving Inspection" are stated in section 17.2.7.4. This change is not a reduction in commitment.
Page 6 of 36
Discussion of Changes Attachment 2 l in the Quality Assurance to NG-94-4459 l Program Description 1 Responsibilities relative to the Ten Year Inspection Program have been removed from Quality Assurance and added to the -
responsibilities of the Engineering Department. This change results in the transfer of responsibility for the i I
performance of this function, and transfer of the Corporate Level III NDE to the Engineering Department. No change in the overall commitments of the Operational Quality Assurance i Program occur as a result of this change. (This change is !
also reflected in sections 17.2.1.2.3.1, 17.2.9.1, 17.2.9.4, 17.2.10.1, and 17.2.10.4.1). Additional details regarding l the change include the following: l j
e Quality Control Inspectors are currently certified in NDE disciplines, and will continue to be in the future.
The maintenance of these certifications is now accomplished as a support function from Engineering '
(the Corporate Level III NDE) as opposed to directly in the past when the Corporate Level III was a member of the Quality control staff.
e The duties of the Corporate Level III NDE are not affected by this change.
e NDE examinations during refuel outage periods will continue to be performed by contract personnel which have been evaluated by IES Utilities Inc.
e Quality Control personnel will continue to support the ,
performance of NDE examinations during on-line periods l of operation.
e This change does not result in any change in the personnel who perform these tasks. The same individual j remains as the designated Corporate Level III NDE. j In conclusion, the Operational Quality Assurance Program continues to implement the Ten Year Inspection Program at )
the same level as in the past. The Ten Year Inspection i Program is unaffected by this change. This is not a l reduction in commitment.
The removal of the word " Additionally" is an editorial change only. This is not a reduction in commitment.
Page 7 of 36 i
I l
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description J
- 6. 17.2.1.2.3.1 Corporate Level III NDE Identification of the Change:
Paragraph 17.2.1.2.3.1 which described the responsibilities of the Corporate Level III NDE has been deleted from UFSAR Section 17.2.
Reason for the Changes:
The Corporate Level III NDE now reports to the Engineering Department instead of reporting to the Quality Control Supervisor.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
The acceptability of this change is provided under the description of changes for Section 17.2.1.2.3. Also refer to UFSAR Section 17.2.10.
- 7. 17.2.1.2.4 Quality Assurance Training Coordinator.
Identification of the Change:
The description of the responsibilities of the Quality Assurance Training Coordinator have been deleted. These responsibilities are now listed as being assigned to the !
Manager, Corporate Quality Assurance. There are no changes in the previously stated responsibilities.
Reason for the Changes: ,
Assigning these responsibilities at the Manager, Corporate Quality Assurance simplifies the QAPD and allows for future organizational flexibility without impacting the QAPD.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
This change has no impact on the responsibilities of the Quality Assurance Department. This change is administrative in nature and is not a reduction in commitment. ,
i Page 8 of 36
i I
l l
1 Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description
- 8. 17.2.2.3, Identification of Safety-Related Structures, Systems, Components and Items The following changes have been made in UFSAR Table 3.2-1 which identifies all safety-related structures, systems, and components:
8.A UFSAR Table 3.2-1, Item X.1, Piping within outermost isolation valves Identification of Change:
In Item X.1, " Piping, within outermost isolation valves" for the Low Pressure Core Spray System and in j the Footnotes section (located on pages T3.2-7 and l T3.2-16 respectively, of UFSAR Table 3.2-1), footnote j in was removed. The footnote read:
This system includes reactor head spray Reason for the Change: I Reactor head spray is no longer used at DAEC. This was removed in 1987 by Design Change Package 1385. To ensure consistency between Table 3.2-1 and the other portions of the UFSAR, this footnote was deleted.
Basis for Concluding that the Change is Acceptable Under Section 50.54(a)(3)":
The change updates Table 3.2-1 to reflect the current plant design following design change package 1385.
This change does not impact the application of the ,
Quality Assurance Program Description as previously. j reviewed and approved by the NRC and continues to '
satisfy the provisions of 10 CFR Part 50 Appendix B.
8.B Item XIX.4, Piping beyond outermost isolation valves Identification of Change:
In Item XIX.4, " Piping, beyond outermost isolation valves", for the Reactor Water Cleanup System (located on pages T3.2-10 and 20 of UFSAR Table 3.2-1), the following " comment" was added:
Segments of the RWCU piping have been replaced with IGSCC-resistant materials.
Page 9 of 36
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Reason for the Change:
The " comment" was added to item XIX.4 to provide ,
additional information recording that segments of the !
Reactor Water Cleanup System piping have been replaced i with Intergranular Stress Corrosion Cracking resistant :
materials. ;
Basis for Concluding that the Change is Acceptable ,
Under Section 50.54(a)(3)":
This comment is for clarification only. It does not impact the classification of the RWCU system or affect its descripcion relative to the Quality Assurance Program Description. This change is not a reduction in commitment.
8.C Item XXIV.1, Piping for the Emergency Service Water System Identification of Change:
In Item XXIV.1, " Piping" for the Emergency Service Water System (located on page T3.2-11 of UFSAR Table ,
3.2-1), the Construction Code was changed from USAS l B31.7 to ANSI B31.1.0-1967.
Reason for the Change:
i The change in the construction code for the Emergency Service Water (ESW) system is the result of discovery [
of additional information during the continuing work on ,
the Design Bases reconstitution program. This change l provides the correct construction code for ESW System. l 1
Basis for Concluding that the Change is Acceptable l Under Section 50.54(a)(3)": l The Design Bases reconstitution process has identified -
additional information which is being incorporated into l UFSAR Table 3.2-1 to reflect the original construction code for the ESW System. The identification of this construction code does not impact the application of the Quality Assurance Program Description to the ESW piping system as previously reviewed and approved by the NRC. This change is not a reduction in commitment.
Page 10 of 36
Discussion of Changes Attachment 2 ,
in the Quality Assurance to NG-94-4459 Program Description l 8.D Item XXVI.3, Reactor Building Closed Cooling Water (RBCCW) Piping and Valves, Other" Identification of Change:
Item XXVI.3, " Piping and valves, other" (located on page T3.2-12 and T3.2-16 of UFSAR Table 3.2-1) for the Reactor Building closed Cooling Water System has the following changes:
Construction Code changed from "no entry" to "USAS B31.1.0" Quality Assurance Requirements changed from "B" to "no entry" Seismic Category changed from "I" to "NA" Footnote is regarding the application of Seismic Category I criteria was deleted Reason for the Change:
During the performance of the Design Bases -
reconstitution activities, additional information was discovered concerning the Reactor Building Closed Cooling Water (RBCCW) System Construction Code. It was concluded that the application of the seismic Category and Quality Assurance Requirements to the RBCCW System outside of the primary containment isolation valves was incorrect. The RBCCW piping and valves beyond the outermost containment isolation valves are not safety related. These changes correct errors in the previous classifications.
Basis for Concluding that the Change is Acceptable Under Section 50.54(a)(3)":
Item XXVI of UFSAR Table 3.2-1 is the Reactor Building Closed Cooling Water System. Item XXVI.3 covers piping and valves located outside of the primary containment isolation valves. This equipment performs no safety function and therefore the Quality Assurance Program need not apply. Consistent with footnote f to UFSAR Table 3.2-1, supports in portions of non-seismic category I lines passing through rooms containing safeguard equipment are seismic category I. However, I
Page 11 of 36
t Discussion of Changes Attachment 2 l In the Quality Assurance to NG-94-4459 l Program Description r the Reactor' Building Closed Cooling Water System is not seismic in and of itself. ;
The application of an Appendix B'QA Program and seismic 1
class I to this portion of the RBCCW system was ]
erroneous. j In conclusion, UFSAR Table 3.2-1 was incorrect.
Reclassification of the RBCCW system " Piping and ,
Valves, other" (beyond the outboard' containment isolation valve) is not a reduction in commitment based on the requirements of the governing regulations and ;
the DAEC design requirements although it could be ,
classified as a reduction in the previous commitment :
recorded in UFSAR Table 3.2-1. On this basis, this i change is categorized as a reduction in commitment from l~
that previously specified, reviewed and approved by the NRC. ;
8.E Item XXXV, Essential A-C Power System ;
Identification of the Changes:
1 In Item XXXV, " Essential A-C Power System" (located on pages T3.2-1, 2, 13, and 21 of UFSAR Table 3.2-1), the description was changed to " Auxiliary A-C Power System", Product Structure Codes R21, R35 and R43 were I removed, and the following comment was added:
The Auxiliary AC Power System is composed of the 4160 VAC Switchgear, the 480 VAC Load Centers, and the 480 VAC Motor Control Centers. The Instrument AC Control Power System (R20) is not within the boundary of the Auxiliary AC Power System'and'does not perform a safety function, but was upgraded to a Class IE power source by DCP 1411 to support Post Accident Monitoring instrumentation for Regulatory Guide 1.97. l Reason for the Change The changes in the above description are the result of I continuing work on the Design Bases reconstitution program and the identification of errors in UFSAR Table ,
3.2-1 based on the supporting design basis ]
documentation. i l
Page 12 of 36 !
I I
+,
y y ,-w, - wn-,-, , , --1 --c --r-.mm---... . - - , . . ..---,-r - - - - , - - - - - - . , , , - , . . - - - - , . , , -
i Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Product Structure Code R21 was removed because it is a blank code that is not used for any system.
Product Structure Code R35 which is used for Lighting and Distribution panels, was removed because the R35 '
Panels do not perform a safety function, are not Claes lE, and are not part of the Auxiliary A-C Power System.
Since this line item only applies to those components with a safety function, the codes given in the table are not applicable and Product Structure Code R35 <:an be removed.
Product Structure Code R43 which is used for the Standby Diesel Generator System was removed because it is already covered under UFSAR Table 3.2-1 Item XXIX.
The comment was added to this line to clarify the boundary of the Auxiliary AC Power System and to clarify the safety status of the Instrument AC Control Power System.
Basis for Concluding that the Change is Acceptable ,
Under Section 50.54(a)(3) [
These changes provide additional information which was identified during the Design Bases reconstitution process and ensure consistency between Table'3.2-1 and Section 8.3 of the UFSAR which describes the DAEC onsite power system. These corrections do not impact the application of the Quality Assurance Program Description previously reviewed and approved by the NRC and continue to satisfy the provisions of 10 CFR Part 50 Appendix B.
I 8.F Item XXXVII.1, Piping, Pumps and Valves" Identification of Change:
In Item XXXVII.1, " Piping, pumps and valves", for the River Water Supply System (located on page T3.2-13 of '
UFSAR Table 3.2), the Quality Group Class was changed from 'no entry' to 'D+QA'.
Reason for the Change: ;
The change in the above Quality Group Class is the ,
result of continuing work on the Design Bases i reconstitution program and the identification of Page 13 of 36
Discussion of Changes Attachment 2 -
in the Quality Assurance to NG-94-4459 Program Description additional information for the River Water Supply (RWS)
System.
Basis for Concluding that the Change is Acceptable Under Section 50.54(a)(3)":
This change provides additional information which was not previously available for the RWS System. This change is consistent with the design basis and Quality Assurance Program Description as previously reviewed and approved by the NRC. The provisions of 10 CFR 50 Appendix B continue to be applied.
8.G Item "g" on UFSAR Table 3.2-2 Identification of Change:
In Item g on UFSAR Table 3.2-2 (located on page T3.2-23 of UFSAR Table 3.2-2), the code for valves was changed from MSS-66 and MSS-SD-66, to MSS-SP-66.
Reason for the Change:
This change corrects a typographical error.
Basis for Concluding that the Change is Acceptable Under Section 50.54(a)(3)":
The change to this item is strictly editorial and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC.
- 9. 17.2.2.4.2 Nuclear Generation Division Manual Identification of the Changes:
This section is revised to better describe the purpose and contents of the Nuclear Generation Division Manual. The l changes to this section include the following:
e insertion of the word " administrative" before the word
" procedures" e deletion of the phrase " applicable to more than one department within the division" and replacement with
" common to the Nuclear Generation Division" Page 14 of 36
)
l
l 1
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description i
e deletion of the phrase " provide mechanisms which facilitate the flow of information and documents across departmental lines and also" e revised the end of the last sentence from " procedures which address the same subject" to " procedures addressing the same subject".
In summary, this section has been revised to state more simply the purpose of the Nuclear Generation Division Manual, which is to have a common set of administrative procedures for common processes, eliminating the need for each department within the Division to have a procedure on the same subject.
Reason for the Changes:
Section 17.2.2.4.2 was revised to simplify the purpose of the Nuclear Generation Division Manual and remove prescriptive language. The overall purpose of the Nuclear Generation Division Manual is to reduce the number of individual procedures when one common divisional procedure will moet the needs for all departments (i.e., no need for individual departmental procedures as described in section 17.2.2.4.3). This change is also facilitated br the removal of the Quality Assurance Department'from the review of
" divisional" procedures. See the changes to section 17.2.1.2.2 above.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
The changes to section 17.2.2.4.2 regarding the Nuclear Generation Division Manual reflect a simplification in regards to when procedures would be placed in this manual as opposed to having separate Departmental Procedures. This change does not modify the DAEC commitment to procedures required by 10 CFR Part 50 Appendix B, Criterion V,
" Instructions, Procedures and Drawings". This change is not a reduction in commitment.
l I
Page 15 of 36
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description
- 10. 17.2.3.2 Design Responsibility Identification of the Chango:
This section revises the responsibility for the design of nuclear fuel reloads from the Nuclear Fuels Group to Reactor Engineering. In addition, the " Engineering Department" is replaced with " Manager of Engineering".
Reason for the Change:
The DAEC reorganization focused on improved organizational effectiveness and resulted in the following changes related to nuclear fuels:
a The previous " Nuclear Fuels Group" was composed of the Principal Engineer, Nuclear Fuels. This position is now in the Nuclear Business Unit and has primary l responsibility for the financial aspects of nuclear fuel activities.
s The responsibility for design of nuclear reloads has i been assigned to Reactor Engineering. l l
s The change from " Engineering Department" to " Manager of j Engineering" is to focus the responsibility on a ,
position as opposed to an organization. l Basis for Concluding the Change Continues to Satisfy 10 CFR )
50 Appendix B and Previous QA Program Commitments"-
l In accordance with the provisions of 10 CFR 50 Appendix B, i Criterion I (Organization) and Criterion III (Design Control), the responsibilities for " design control" are to be clearly specified. The above changes result in the responsibility for the design and engineering effort and the
" design of nuclear reloads" being clearly specified and ,
assigned. The commitment to the " design of nuclear reloads" !
remains, but the work is done by a different group. These !
changes are not a reduction in commitment from that '
previously specified and approved by the NRC.
Page 16 of 36
1 Discussion of Chances Attachment 2 in the Quality Assurance to NG-94-4459 Program Description,
- 11. 17.2.4.5, Acquisition from Other Licensed Nuclear Power Plants Identification of the Change:
In the first line, "NRC licensed" is replaced with "NRC-licensed".
The first sentence has also been revised from "... Iowa Electric purchase specification is equivalent to that of the ;
other utility, and the quality assurance requirements of )
Iowa Electric have been satisfied" to "that the procured ;
item meets the requirements of the DAEC procurement specification".
The second sentence has "then" added after 10 CFR Part 21, and the last portion of the sentence which previously stated
" transferred to Iowa Electric Light and Power Company" 1 replaced with " accepted by IES Utilities Inc."
The last sentence has been revised from " Iowa Electric Light and Power Company shall notify the original supplier in writing of this item (s) change in ownership to ensure appropriate 10 CFR Part 21 reporting from the original supplier" to "IES Utilities Inc. shall notify the original supplier in writing of this item (s) change in ownership to give the original supplier the opportunity to change the 10 CFR Part 21 notification records."
Reason for the Change: 1 The first change is only an editorial change.
The changes to the first sentence make it clear that the governing specification for purchase is the DAEC specification. The previous language could be interpreted that the other licensed nuclear power plant specification l governed. This change makes it clear.
The changes to the second sentence focus on the application of 10 CFR Part 21 for this type of purchase. " Accepting" responsibility for 10 CFR Part 21 reporting is more accurate than " transferring".
The changes to the last sentence clarify that IES Utilities Inc. can only " notify" (not ensure) the original supplier to update their records for 10 CFR Part 21 reporting.
I i
Page 17 of ;
1 3--o g . , - - , , , , -~
l I
I Discussion of Changes Attachment 2 ]
in the Quality Assurance to NG-94-4459 l Program Description Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
The above described changes to this section are all editorial in nature. These changes do not affect the
- process by which IES Utilities purchases items from other licensed nuclear power plants from that which was previously 4
reviewed and approved by the NRC. These changes are not a reduction in commitment.
- 12. 17.2.5.3, Issuance (of Instructions, Procedures and j Drawings)
Identification of the Changes:
, Section 17.2.5.3, entitled " Issuance" is replaced in its j entirety by Section 17.2.5.3 entitled " Compliance". The i- contents of the previous Section 17.2.5.3 and the location of the same materials after the change are described below: 1 The first paragraph previously stated:
"The organization responsible for the activity being described is responsible for the issuance of the instructions, procedures, and drawings."
The issuance of instructions, procedures and drawings is already addressed by Section 17.2.6.4, " Distribution and Use".
The deletion of this paragraph eliminates duplication and confusion over which organization performs the distribution.
The organization actually performing the distribution l
varies. It is important that the mechanism for distribution of controlled documents be established as stated in Section 17.2.6.4.
l The second paragraph of Section 17.2.5.3 previously stated:
1 "The instructions, procedures, and drawings will be issued before the commencement of the activity to be controlled by that instruction, procedure, and i
drawing."
l These requirements are addressed in the new Section 17.2.6.4 (Distribution and Control) which states
" Documents will be issued before the commencement of the activity to be controlled by that document."
Page 18 of 36 l
l l
l
I 1
i Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description The third paragraph of Section 17.2.5.3 previously stated: l l
"Once instructions, procedures and drawings have been approved and issued for use, the activities will be performed in accordance with the documents. If the activity cannot be accomplished, the document will be formally revised to reflect the manner in which the activity is to be performed.
These requirements are all addressed in the revised Section 17.2.5.3.
The fourth paragraph of Section 17.2.5.3 previously stated: J
" Revised instructions, procedures, and drawings will be reviewed and approved by the same organizations ano individuals (or equivalent positions) that reviewed and approved the original document."
The contents of this section are addressed in the revised Section 17.2.6.5, " Changes to Documents".
Reason for the Changes:
These changes have been made to eliminate confusion in regards to responsible organizations, and repetition of material in sections 17.2.5 and 17.2.6, and, in general, to improve the content of these two sections.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
Section 17.2.5.3 was relocated and rewritten as described above under the " description of changes". These changes result in improved clarity of the material contained in section 17.2.5.3 and Section 17.2.6. These changes are editorial in nature and do not affect the Quality Assurance Program commitments as previously reviewed and approved by the NRC. These changes are not a reduction in commitment.
- 13. 17.2.6.1, Scope Identification of the_ Change:
A period was placed after the word " personnel" in the fourth line and a new sentence added which states:
Page 19 of 36
l s
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 i Program Description "The responsible organization also establishes measures l' to ensure the documents are distributed to and used at the location where the prescribed activity is performed and are controlled."
Reason'for the Change:
t This change more clearly states which organization is responsible for the distribution of documents. In some ;
cases, the organization that is responsible for the document .i provides the document to another organization for actual 4 distribution and control (typically a document control :
center). i
?
Basis for Concluding the Change Continues to Satisfy 10 CFR j 50 Appendix B and Previous QA Program Commitments":
i This change permits an organization other than the ,
organization that is responsible for the document to perform the functions of distribution and control. The provisions
+
for " document' control" remain fully implemented in accordance with the requirements of 10 CFR Part 50 Appendix ,
B,. Criterion VI, " Document Control". This change provides !
additional flexibility, but remains consistent with'the l previous Quality Assurance Program commitments as approved ,
by the NRC, and consistent with the provisions of 10 CFR j Part 50 Appendix B. This change is not a reduction in ;
commitment.
i
- 14. 17.2.6.2, Preparation
?
Identification of the Change:
l The first two sentences of this section are combined !
eliminating reference to the " organization responsible". !
The new sentence now states: -l
" Administrative techniques will be established that !
define the documents to be issued and controlled, l identify the current revision or issue of the document, i and identify the individuals who are to receive the !
document."
I i
Reason for the Change: ;
i This change provides for some organizational flexibility in j the issuanco and control of documents. A central document 4 control center organization typically provides a service to l l
Page 20 of 36 ,
i 1
)
Discussion of Changes Attachment 2 ,
in the Quality Assurance to NG-94-4459 Program Description the other organizations in regards to document issuance and control.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
This change permits distribution and control of a document to be performed by an organization other than the one that initiated the document. The provisions for " document control" remain fully. implemented in accordance with the requirements of 10 CFR Part 50 Appendix B, Criterion VI,
" Document Control". This change provides additional flexibility but is consistent with the previous Quality Ascurance Program commitments as approved by the NRC and with the provisions of 10 CFR Part 50 Appendix B. This change is not a reduction in commitment.
- 15. 17.2.6.3, Review and Approval Identification of the changes:
In the first paragraph of this section, the term "and contractual" is removed.
The second paragraph of this section regarding Quality Assurance Department review of divisional procedures is deleted. ,
The third paragraph of this section regarding revision of controlled documents is deleted. The contents of this paragre h are addressed in Section 17.2.6.5 on " Changes to Documents". i The fourth paragraph of this section regarding changes to I design documents is relocated to Section 17.2.6.5. The only j change to this section is the name of the utility as described earlier.
A new second paragraph is added which states: "The required review and approvals for instructions, procedures, and drawings will be established by the organization responsible for those documents. Reviews will be performed by knowledgeable personnel other than the originator. The review and approval will occur prior to issuance or implementation of the change.
Page 21 of 36 I
I l
i i
Discussion of Changes Attachment 2 l in the Quality Assurance to NG-94-4459 Program Description Reason for the Changes:
The terms "and contractual" were removed because they are unnecessary. From a document control perspective, the regulatory, technical and quality requirements are stated in the specifications which are referenced in the contracts. ,
The reference to " contractual" requirements is a ;
duplication.
The deletion of the second paragraph removes the Quality Assurance Department from the review and approval of divisional procedures. This allows the Quality Assurance i Department to better utilize its resources in the development and maintenance of the Quality Assurance Program and policies and in the verification of procedural compliance with the Quality Assurance Program, policies, and implementing procedures.
The third paragraph of this section is rewritten and placed in UFSAR Section 17.2.6.5 entitled " Changes to Documents".
The fourth paragraph addresses changes to design documents, a subject better addressed in 17.2.6.5, " Changes to l Documents".
Paragraph 17.2.6.3 previously addressed revisions to documents versus the initial review and approvals. Initial review and approval is now addressed in this section and revisions addressed in section 17.2.6.5, " Changes to Documents".
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
Deletion of "and contractual" removes unnecessary and duplicative language. This is an e.dministrative change and is not a reduction in commitment.
The removal of the Quality Assurance Department from the review and approval of divisional procedures is categorized as a reduction in commitment since this change results in the Quality Assurance Department discontinuing an activity previously reviewed and approved by the NRC. However, this change is consistent with the provisions of 10 CFR Part 50, Appendix B in that 10 CFR Part 50 Appendix B, Criterion VI, Document Control, does not require the assessment organization to be involved in the review and approval of procedures that implement the Quality Assurance Program.
Page 22 of 36
I Discussion of Changes Attachment 2 ;
in the Quality Assurance to NG-94-4459 :
Program Description ,
i The quality of procedures are assessed in accordance with the provisions of 10 CFR Part 50, Appendix B, Criterion XVIII, Audits. This change is classified as a reduction in- '
, commitment.and will not be implemented pending review and approval by the NRC.
The changes to the third paragraph result in the relocation
-of'the provisions for document review and approval to i Section 17.2.6.5, " Changes to Documents". See the. ,
i evaluation of Section 17.2.6.5 for further details on this ;
change. ;
f The changes to the fourth paragraph result in the relocation ;
of this material to Section 17.2.6.5, Changes to Documents, j See the evaluation for Section 17.2.6.5. l The'new paragraph addresses the initial review and approval [
of instructions, procedures, and drawings and is consistent ;
with the previous DAEC commitments as defined by ANSI N18.7- t 1976. This is an editorial enhancement to the QAPD. This is [
not a reduction in commitment.
- 16. 17.2.6.4, Distribution and Use Identification of the Change:
{
A new sentence has been added to this section which states: (
" Documents will'be issued before the commencement of f the activity to be controlled by that document. j Reason for the change:
The substance of this statement was previously contained in Section 17.2.5.3 (Issuance). Its relocation results in ,
better organization of the materials (i.e., all issues related to " distribution and use" of documents is now located in this section). ;
Basis for Concluding the Change continues to Satisfy 10 CFR ,
50 Appendix B and Previous QA Program Comunitments": }
This change only moves language from one section to another. -;
This is an administrative change and does not impact the !
Quality Assurance Program commitments as previously reviewed ,
and approved by the NRC. This is not a reduction in commitment. j 1
Page 23 of 36 ;
t
?
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description
- 17. 17.2.6.5, Changes to Documents Identification of the Changes:
The following changes have been made to this section:
8 The review and approval process for revised documents has been rewritten.
5 The provision regarding DAEC access to the original design documents has been deleted. The provision previously located in Section 17.2.6.3 regarding DAEC revision of original designer documents has been relocated to this section. Language regarding the availability of original design documents is removed.
Reason for the Changes:
The above described changes have been made for the following reasons (respectively):
m The changes regarding the review process for revised documents now more clearly specifies the requirements consistent with the IES Utilities Inc commitment to ANSI N18.7-1976 and as committed to in UFSAR 17.2 Appendix A.
5 The relocation of the requirements regarding DAEC revision of original design documents to this section revealed a conflict with previous language in this section. It is now clear that the DAEC is authorized to revise design documents provided by the original designers. The removal of language regarding DAEC access to original design documents is consistent with the IES Utilities Inc responsibility for maintaining the design of the DAEC and the implementation of a design basis reconstitution program.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
The provision for the review and approval of revised documents has been enhanced in this revision. This enhancement is consistent with the provisions of 10 CFR Part 50 Appendix B, Criterion VI, Document Control.
The changes regarding the review process for changed documents better reflects the requirements contained in the Page 24 of 36
Discussion of Changes Attachment 2 ,
in the Quality Assurance to NG-94-4459 Program Description ,
IES Utilities'Inc commitment to ANSI N18.7-1976, as I previously approved by the NRC. This change is not a i reduction in commitment.
t Two UFSAR Sections (17.2.6.3 and 17.2.6.5) previously:
addressed changes to. design documents provided by the i original designers. The revisions of this submittal result !
in a single statement in Section 17.2.6.5, " Changes to Documents". It is now clearly stated'that the DAEC can [
revise the documents provided by the original designers. i Documents not available are addressed through Section 17.2.3 '
(Design Control).and through implementation of a design basis reconstitution program. These changes are !
administrative in nature and do not affect the previous Quality Assurance Program commitments as reviewed and approved by the NRC. .These changes are not a reduction in !
commitment. [
- 18. 17.2.9.1 Scope l Identification of the Change: :
The third paragraph of this section is revised to reflect a '
transfer of responsibility for the performance of nondestructive examination activities from the Corporate !
Quality Assurance Department to the Engineering Department. i Specifically, the third paragraph is revised to read as i follows:
"The Engineering Department is responsible for providing technical expertise relative to materials, metallurgy, welding, brazing, special processes and nondestructive examination (NDE).
' Nondestructive examinations will be performed under the direction of the Engineering Department by the Corporate Quality Assurance Department or IES Utilities-Inc approved suppliers."
Reason for the Change:
The Corporate Level III NDE has been transferred from the Quality Assurance Department to the Engineering Department to provide for improved efficiency and effectiveness in the planning and performance of nondestructive examination activities.
Page 25 of 36
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and. Previous QA Program Commitments":
See discussion of section 17.2.1.2.3 (item 5 above) for the basis.
- 19. 17.2.9.4, Verification and Control Identification of the Changes:
The last paragraph of this section has been revised as follows:
o The phrase " Corporate Quality Assurance Department" has been replaced with " Engineering Department" e The term "DAEC" was removed Reason for Change:
The Engineering Department is now responsible for the performance of all special processes, including NDE.
The term DAEC was removed to clarify that all personnel performing special processes (whether DAEC or contractor) must have current qualifications.
Basis for Concluding the Change Continues to Satisfy 10 CFR l 50 Appendix B and Previous QA Program Commitments":
For the organizational change, see the description of changes in section 17.2.1.2.3 (item 5 above). !
l The removal of "DAEC" is a clarification.
These changes are not reductions in commitment. I l
- 20. 17.2.9.5, Special Protective Coatings (Paint) j Identification of the Change:
The term " Quality Level I" is replaced with the term
" safety-related".
Page 26 of 36
I Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Reason for the Change:
The term " Quality Level I" is not defined in UFSAR 17.2, but is equivalent to " safety related" in the implementing .
procedures of IES Utilities Inc.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
This change is administrative only. In the IES Utilities Inc program for implementation of the Quality Assurance Program, the terms " safety-related" and " Quality Level I" are synonymous. This change in terms has no effect on the Quality Assurance Program commitments previously reviewed and approved by the NRC.
- 21. 17.2.10.1, Scope Identification of the Change:
This section is revised to state that the Corporate Quality Assurance Department is responsible for receiving, in-process and final inspections, while the Engineering Department now has responsibility for performing of nondestructive examinations.
Reason for the Change:
The Corporate Level III NDE now reports to the Engineering Department. This is consistent with the changes described i in item 5 above (discussion of Section 17.2.1.2.3). l 1
Basis for Concluding the Change Continues to Satisfy 10 CFR j 50 Appendix B and Previous QA Program Commitments". )
The change described in this section has previously been described in item 4 above (discussion of section 17.2.1.2.3). This change is not a reduction in commitment.
- 22. 17.2.10.4.1, Ten Year Inspection Program Identification of the Change:
The responsibility for conducting the planned nondestructive examinations (NDE) and providing the services of the Corporate Level III NDE is changed from the Quality Assurance Department to the Engineering Department. i l
l Page 27 of 36 I
i
. o Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Reason for the Change:
See item 5 above (discussion of Section 17.2.1.2.3) for the previously-described reason for this change.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
See item 5 above (discussion 17.2.1.2.3) for the basis for the change.
- 23. 17.2.16.1, Corrective Action, Scope Identification of the Changes:
The last sentence of this section, " Corrective action is necessary to correct omissions and problems in the operational Quality Assurance Program", has been deleted.
Reason for the Changes:
The sentence deleted implies that corrective action is applied only to activities associated with the " Operational Quality Assurance Program".
This focus is too narrow. The corrective action system is to be used to correct conditions adverse to quality throughout all activities in the operation of the DAEC consistent with 10 CFR 50 Appendix B Criterion XVI, Corrective Action.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
Application of " corrective action" as defined by 10 CFR Part 50 Appendix B is not limited to conditions within the
" Operational Quality Assurance Program". The removal of the abovo-quoted sentence eliminates the possibility that the scope of corrective action could be interpreted narrowly.
In fact, the scope of the program has included corrective actions for any conditions adverse to quality and will continue to do so. This change enhances the " Corrective Action" section of the Operational Quality Assurance Program Description consistent with the provisions of 10 CFR Part 50, Appendix B, and the Quality Assurance Program commitments as previously reviewed and approved by the NRC.
This change is editorial and is not a reduction in commitment.
Page 28 of 36
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 l Program Description l
- 24. 17.2.16.2, Conditions Adverse to Quality Identification of the Change:
This section has been rewritten. Two paragraphs previously found in Section 17.2.16.3 have been revised and moved to this section. Some detail as to how conditions adverse to quality are reported has been removed from 17.2.16.2. This section now also clearly states the Corrective Action Program is administered by the Nuclear Licensing Department.
Reason for the Changes:
This section is intended to describe the Quality Assurance Program as it applies to " conditions adverse to quality".
As previously written, the section specified techniques by which conditions adverse to quality are identified. Part of the program description for " conditions adverse to quality" was included in the next section, "Significant Conditions Adverse to Quality". As revised, the Quality Assurance Program for " conditions adverse to quality" is more clearly described in a less prescriptive manner. The description also recognizes that responsibility for administration of the Corrective Action Program is now in the Nuclear Licensing Department.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
Revised Section 17.2.16.2 is consistent with the previous IES Utilities Inc. Quality Assurance Program commitments as defined by 10 CFR Part 50 Appendix B, Criterion XVI,
" Corrective Action" and the IES Utilities Inc commitment to Regulatory Guide 1.33 in regards to " conditions adverse to quality". This change results in a clearer description of the Operational Quality Assurance Program with respect to implementation of the Quality Assurance Program for
" conditions adverse to quality".
The change in responsibility for administration of the Corrective Action Program from the Quality Assurance Department to the Nuclear Licensing Department is also consistent with the provisions of 10 CFR Part 50 Appendix B, in that the regulation does not specify which organization must perform this function. IES Utilities Inc believes the change improves the Operational Quality Assurance Program in that the Quality Assurance Department is now independent of this administrative duty and can independently assess the Page 29 of 36
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description effectiveness of the Corrective Action Program. This change in responsibility for administration of the Corrective Action Program does not impact the implementation of the Corrective Action Program and is completely consistent with the previous commitments to the implementation of a Corrective Action Program.
The other changes are editorial improvements in Operational Quality Assurance Program Description and do not affect any commitment. In summary, the above changes are completely consistent with the previous Qual (ty Assurance Program commitments, as reviewed and approved by the NRC.
- 25. 17.2.16.3, Significant Conditions Adverse to Quality Identification of the Change:
The first two paragraphs of this section have been edited and moved to Section 17.2.16.2. The last paragraph was revised by adding the phrase "but are not limited to" when describing the types of conditions that may be classified as a "significant condition adverse to quality".
Reason for the Changes:
The first two paragraphs of this section previously addressed " conditions adverse to quality" and were relocated to section 17.2.16.2 as explained in item 24 above.
The phrase "but are not limited to" has been added to make clear that these are just examples of conditions which may be classified as "significant conditions adverse to quality".
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
The above described changes are editorial improvements in the description of the Corrective Action Program. The overall content of this section with respect to "significant conditions adverse to quality" is unchanged. This section remains consistent with the provisions of 10 CFR Part 50 Appendix B, Criterion XVI, and the Quality Assurance Program ,
commitments as previously reviewed and approved by the NRC. j These changes are not a reduction in commitment.
l Page 30 of 36 i l
l
e .
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description
- 26. Section 17.2.16.4, Reporting of 10 CFR 21 Defects and Non-compliances Identification of the Change:
The phrase "and appropriate posting provided in accordance with the provisions of 10 CFR Part 21" has been added after the word " established" in the second paragraph.
The title " President and Chief Operating Officer" has been replaced with the title " President and. Group Executive, Energy Delivery and Nuclear Group".
The term "Part" is also added to 10 CFR 21 (i.e. to 10 CFR Part 21).
Reason for the Change:
The added phrase in the second paragraph now makes it clear that there are two separate actions: 1) establishing a procedure and 2) that appropriate posting in accordance with the provisions of 10 CFR Part 21 is performed.
This title was changed as a result of the actions resulting from the merger of Iowa Southern Utilities and Iowa Electric Light and Power Company into the new company, IES Utilities Inc. These changes were previously communicated to the NRC.
10 CFR Part 21 is more accurate.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
The changes to this section: title change, inserting "Part" in 10 CFR Part 21", and clarifying the establishment of a procedure versus one requirement for posting are all editorial and grammatical changes. IES Utilities Inc.
remains committed to the implementation of a program for reporting of defects and noncompliances in accordance with the provisions of 10 CFR Part 21 as previously reviewed and approved by the NRC. These changes are not a reduction in commitment.
Page 31 of 36
6 .
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description
- 27. 17.2.18.2.2, Internal Organizations Identification of the Change:
Audits previously specified by the DAEC Technical Specifications and required by the NRC regulations have been added into this section.
Reason for the Change:
This change is consistent with the guidance provided by the NRC in Generic Letter 93-07 and previous submittal by Detroit Edison. Implementation of this change will permit some additional flexibility in implementing a performance-based audit program.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
In accordance with the requirements of 10 CFR Part 50, l Appendix B, Criterion XVIII, Audits, a comprehensive system of planned and periodic audits shall be carried out to:
e verify compliance with all aspects of the Quality Assurance Program and to e determine the effectiveness of the program.
The frequency of audits previously specified in the DAEC Technical Specifications have been relocated to section 17.2.18.2.2. This continues to satisfy the requirements of 10 CFR 50, Appendix B, Criterion XVIII, Audits and is not a reduction in commitments.
- 28. UFSAR Section 17.2, Appendix A, Section 6.0 Identification of the Changes / Clarifications A new paragraph 6.3 is added to UFSAR 17.2 Appendix A.
This new paragraph recognizes the incorporation of audit frequencies into UFSAR Section 17.2.18.2.2 and no longer relies on Regulatory Guide 1.33 Rev. 2, position C.4 as governing for the audit frequencies specified there.
Subsequent paragraphs are also renumbered as a result of this new paragraph.
Page 32 of 36
r
.j Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Reason for Change:
This change is made to reflect a performance-based approach to auditing of programs and organizations. This change incorporates the Lead Plant submittal by Detroit Edison in support of the Great Lakes QA Managers, a group of Midwestern utilities of which IES Utilities Inc. is a participant.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
IES Utilities Inc. reiaains committed to an extensive audit program for auditing activities at the DAEC over a two year cycle. This change only incorporates a performance-based approach to these audits during the two-year period, which may result in some audits being performed more frequently than required. Other audits may be performed less frequently when justified by performance in a particular area but the period between audits cannot exceed two years (except fire protection which is triennially).
In conclusion, the changes described herein are administrative and relate to the scheduling of audit activities. An audit program consistent with the provisions of 10 CFR Part 50 Appendix B, Criterion XVIII, (Audits) remains in effect as previously reviewed and approved by the NRC. This change is not a reduction in commitment.
- 29. UFSAR Section 17.2, Appendix A, Section 6.0 Identification of the Changes / Clarification:
A new paragraph 6.8 is added to UFSAR 17.2 Appendix A.
Section 5.2.6 of ANSI N18.7-1976, states:
"where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered to be I inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions." I Page 33 of 36
e 'e -l Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description Clarification:
l The above paragraph applies to those situations where the.
missing documentation for.the inspection or test-is that' 'i documentation necessary to demonstrate the operability (performance) of the equipment. Missing inspection and test documentation which doe 9 not affect the confidence in the :
operability of the subject equipment may be evaluated in ;
accordance with the nonconformance-reporting system and a ,
determination of operability made consistent with the- l guidelines of NRC Generic Letter 91-18. >
Subsequent paragraphs are renumbered as a result of this new paragraph. j Reason for the Change: ;
Equipment which lacks documentary evidence of inspection or ;
test results is evaluated within the nonconformance control '
system. The lack of documentation, in and of itself, may not warrant declaring equipment inoperable.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments" IES Utilities Inc. is committed to declaring equipment ]
inoperable where the lack of documentary evidence brings the !
operability of the subject equipment into question.
However, the lack of documentary evidence for some inspections and tests would not necessarily (situation dependent) bring into question the operability of the .
equipment. Not all inspections and tests are conducted to support a determination of operability. Situations in which documentary evidence is missing are documented and ;
evaluated within the nonconformance reporting system. The evaluation of the nonconforming condition may result in no ,
concerns regarding operability and a determination of .
operability made consistent with the guidance contained in NRC Generic Letter 91-18.
In conclusion, this is a clarification regarding the !
determination of operability of equipment when documentary evidence for inspections and tests is missing. This !
clarification is consistent with the original intent of ANSI !
N18.7-1976 Section 5.2.6 and is therefore not a reduction in ;
commitment.
l Page 34 of 36 l
a ,e Discussion of Changes Attachment 2 in.the Quality Assurance to NG-94-4459 Program Description
- 30. UFSAR Section 17.2, Appendix A, Section 6.0 Identification of the Change:
Paragraph 6.13 (formerly 6.11), regarding the " content" and
" format" of Emergency Operating Procedures (EOPs) has been-revised to more clearly state that the " content" of the DAEC EOPs are based on revision 4 of the BWROG Emergency Procedure Guidelines and that the " format" of the DAEC EOPs are of a flowchart format.
Reason for the Change:
To clearly state the basis for " content" of the DAEC EOPs, and to state these EOPs are in a flowchart format.
Basis for Concluding the Change Continues to Satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
This change is editorial. The BWROG EPGs continue to be followed in-the implementation of the DAEC EOPs. This change is not a reduction in commitment.
- 31. UFSAR 17.2 Appendix A, new Paragraph 20 Identification of the changes:
A new paragraph 20 is added which states:
- 20. Regulatory Guide 1.155, " Station Blackout" COMMENTS AND CLARIFICATIONS:
IES Utilities Inc. complies with Appendix A, " Quality Assurance Guidance for Non-Safety Systems and Equipment," to Regulatory Guide 1.155, Revision 1, August 1988.
Subsequent paragraphs of UFSAR 17.2 Appendix A are also renumbered in support of insertion of this new paragraph 20.
Reason for the Change:
The reason for this change is to capture the Operational Quality Assurance Program commitment for the Station Blackout program previously made in letter NG-94-0283, John F. Franz, Jr. to Dr. Thomas E. Murley of the NRC, dated February 10, 1992 in response to the Station Blackout rule of 10 CFR 50.63.
Page 35 of 36
1 4 .. a j l
Discussion of Changes Attachment 2 in the Quality Assurance to NG-94-4459 Program Description l 1
Basis for Concluding the Change Continues to satisfy 10 CFR 50 Appendix B and Previous QA Program Commitments":
l This is a new commitment consistent with the previous l submitted by IES Utilities Inc. (then Iowa Electric Light ;
and Power Company) under the Station Blackout Rule (10 CFR j 50.63) of February 10, 1992.
I C \17-2.kep\qapd2.mem Page 36 of 36
l l
s '~, TABLE 3.2-1 INDEX Syse SysNome SysCode I Reactor System sti
!! Nuclear BolLer System 821
!!! Recirculation System B31 IV CRD Mydroutic System C11 V Stencby Liquid Control System C41 VI Neutron Monitorire System C51 VII Reactor Protection System C71
{
VI!! Process Radiation Monitors 011 l
IX RNA System E11 X Low Pressure Core sprey E21 XI NPCI System E41 l
XII RCIC System E51 l XI!! Fuet Service E @ipment F11
{
XIV Reactor Vesset Service E@lpment F13 l XV In Vesset Service E @ipment F14 '
XVI Refusting Equipment FIS XVII Storage E @lpment F16 XVlli Redweste System Gli XIX Reactor Water Cleerse System G31 XX fuel Poot Cooline and Cleerup System G41 XXI control Room & Remote Shutdoim PenetsM11 C61 XXII Local Penets and Rocks M21 XXIll offsee System N62 XXIV Emergency Service Water E13 XXV RNA Service Water System E12 XXVI RSCCW P42 XXVII Well Water System P46 XXVI!! Pneumatic Systems T48 P50 XXIX Diesel Generator Systems R43 XXX Containment Atmosphere Control System T48 XXXI Stenchy Gas Treatment System T46 XXXII ECCS Equipment Area Cooling System T41 l XXXIII Power Conversion System N11 N21 Xvrtu c h te Storage and Tr em P11 ,
^!IU F 3 :'#e-c Power Syst E J M 24 ^*5 "':
- XXXV XXXVI 1Z5/250 Volt a-c rower sysi-
~ nu
] !
XXXVII River Water S w ty W10 XXXVill MSIV Leekage Control 821 XXXIX NVAC XXXX Miscellaneous Components I
1 l
l T3.2-1 Revision 10 - 6/92 )
1 l
1 l
)
TABLE 3.2-1 INDEX Sys# SysName SysCode XXXVI 125/250 Volt d c Power System R42 XXXIV Condensate Storage and Transfer System P11 XXX Contalryment Atmosphere Control System T48 XXI control Room & Remote Shutdown PanelsN11 C61 IV CAD Nyormulle System C11 XXIX Diesel Generator Systems R43 XXXII ECCS Equipsont Area Cooling System T41 XXIV 8 - aancy Service Water It
-g13 XXXV
[ _
f
' e c Power Syst M_
KX Fuel Pool Cooling and CLeerup system 04 1 XIII Fuel Service E@lpeent F11 XI NPCI system E41 XXXIX NVAC XV In Vessel Service E gipment (14 XXII Local Penets and Rocks N21 X Low Pressure Core Spray E21 XXXX Miscellaneous Components '
XXXVIII MSIV Leeksee Control B21 VI Neutron Monitoring System C51 II Nucteer Beller System 821 XXill Offges System N62 XXVIII PneumetIc Systems T48 P50 XXXIII Power Conversion System N11 N21 VIII Process Radiation Monitors 011 XVIII Redweste System G11 XXVI RBCCW P42 XII RCIC System E51 VII Reactor Protection System C71 I Reactor System att XIV Reactor vessel Service Equipment F13 ;
XIX Reactor Water Cleerup System G31 III Recirculation System 831 l
XVI Refueling Equipment F15 XXV RNA Service Water System E12 IX RNR System Ett .
XXXVII River Weter S w ly W10 l XXXI Standyr Gas Treatment System T46 l V Standry Liquid Control System C41 XVII Storage Egalpeent F16 XXVII Well Water System P46 l
)
i l
T3,2-2 Revision 10 - , 92 l
l l
UFSAR/DAEC-1 Table 3.2-1 DAEC Ctessification of Components in Systems
~
Equivalent -
Scope Ouetity ouetity ASME of Safety Code Construction Grote Assurance Seismic 5 & PV Code Principal Component Stpply Class Ctess Code Ctess Req. Category PG Date Secticn III Footnotes Comments (e) (b) (c) (d) (e)(f) (g) (h) (i)
I Reactor System all
- 1. Reactor vesset GE/C 1 A ASME Section III, 1 M 5 A B I -
1 id -
Edition, Sisumer 1%7 Addende
- 2. Reactor vesset steport skirt GE 1 A ASME Section III, 1965 A B I - -
1d -
Edition, Stammer 1%7 Addende
- 3. R: actor vesset appurtenances. GE 1 A ASME Section III,1%5 A 8 I - 1 1d -
pressure retalning portions Edition, Stammer 1%7 Addende
B I - - - -
Steel)
- 5. Reactor internet structures, GE 2 A ASME Section III,1%5 NA s I - -
Id.1u -
engineered safety features Edition, Stammer 1967 Addendo
- 6. Reactor internet structures, other GE Other - - NA B I - -
tu -
- 7. Control rods GE 2 - -
BA B I - - - -
- 8. Control rod drives GE 1 1 Section III, Ctess 1 A B I - - - -
eppurtenances
- 9. Core styport structure GE 2 A ASME Section III,1%5 NA B I - NG Id.1u -
Edition, Stauner 1%7 Addende
- 10. Power range detector hardware GE 2 - - e a I -
2 1a,1b . -
- 11. Fuet essemblies CE 2 - -
NA s I - - - -
Edition, Summer 1967 Addende
- 13. R:fueting bettous GE Other - - - -
NA - - - -
II mucteer solter Systen 521
- 1. vessets, tevet instrtmentation GE 1 - -
A s I -
1 - -
condensing cheebers
- 2. vessets, N2 occumulators s 2 2 ASME Section III - B I 02/26/73 2 - -
- 3. Piping, retlef vetve discharge a 3 3 USAS 831.7-1969 C s I 07/30/70 3 - -
- 4. Piping, sein steem within GE 1 -
ANSI 331.1.0 + Code cases A B I 12/05/69 1 la,1b -
outermost isolation valve N-2,u-7,N-9,N-10
- 5. Pipe styports, mein steen GE 1 1 Requirements for Ctess 1 A B I 02/26/71 1 piping steports in ANSI 331.7.
- 6. Pipe restraints, mein steen a 2 - -
NA B I -
2 - -
- 7. Piping, other within outennost a 1 1 USAS 531.7-1%9 A s I 07/30/70 1 te,1b -
Isoletion velves
- 8. Pipins, inktrumentation beyond s Other -
USAS 531.1.0-1967 -
s - - -
1e,1b -
outermost isolation vetves T3.2-3 Revision 11 - 04/94
_ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____ _ _ _ - _ _ _ _ _ _ _ __ _ = _ _ --- e-
UFSAR/DAEC-1 Table 3.2-1 -
DAEC Classificr, tion of Ccaponents in Systems l
E pivalent
. Scope Quality Guality ASME
- of Safety Code Construction Grote Assurance seismic 8 & PV Code Principet ra5-=wnt St@ ply Ctess Class Code Class Req. Category PO Date Section III Footnotes Comments (a) (b) (c) (d) (e)(f) (g) th) (i)
- 9. Safety valves GE 1 1 ANSI S31.1.0, Addenda and A B I 12/30/69 1 If -
applicable code cases or NDE standards of 531.1.
j Code Cases N2,NT,N9,N10
- except that the acceptance standards for Class 1 valves in the Draft ASME Code for Pumps and Valves for Nuclear Power may be applied. Use ANSI 16.5 or NSS-SP-66 for design
- 10. Estlef valves GE 1 1 ANSI B31.1.0, Addands and A 8 I 12/30/69 i If -
appticable code cases or NDE standards of 831.1.
Code cases N2,NT,N9,N10 except that the acceptance standards for Class 1 valves in the Draft ASME Code for Pumps and Valves for huclear Power may be applled. Use Aust 16.5 or NSS-SP-66 for design it. valves, main steam isolation GE 1 1 ANSI B31.1.0, Addenda and A B I 10/15/69 1 If -
valves applicable code cases or NDE standards of 831.1.
Code cases N2,NT.N9,N10 except that the acceptance atenderds for Class 1 valves in the Draft ASME Code for Pumps and Valves for Nucteer Power may be applied. Use ANst 16.5 or NSS-SP-66 for design
- 12. valves, other, isolation valves 3 1 1 ASME Code for Ptaps and A 3 I 10/16/70 1 If -
and within valves for Nuclear Power
- 13. valves, instrtmentation beyond B Other -
USAS 831.1.0-1%7 - - - - -
1s,1b.1f -
outensost isolation valves
- 14. Mechanical modules, GE 2 - -
a s I - -
1c -
Instrumentation, with safety f metion
- 15. Electrical modules with safety GE 2 - -
NA B I - -
Ic -
f mction
- 16. Cable, with safety fmetion B 2 - - - '
s I - - - -
III Recirculation System 531
- 1. Piping GE 1 -
ANSI B31.1.0 + Code Cases A B I 12/05/69 1 te,1b -
N2,NT,N9,N10 T3.2 4 Revision 11 - 04/94
UFSAR/DAEC-1 Table 3.2-1 .
DAEC Classific"_ tion e.f Components in Systems Ecpalvetent Scope cuality cuality ASME -
of Safety Code Construction Group Assurance Selsele 5 & PV Code Principal rn5.n,wnt S@ ply Clase Class Code Class Req. Category PO Date Section III Footnotes Comments (a) (b) (c) (d) (e)(f) (g) (h) ti)
- 2. Pipe suspension, recirculation GE 1 1 Recpairements for Class 1 A I 02/26/71 1 - -
line piping sgports in ANSI 331.7.
- 3. Pipe restraints recirculation line GE 2 - -
NA B I -
2 - -
and valves for Nucteer-Power or lef and acceptance requirements of ANSI B31.1 Code Cases NT,N9,N10 +
Design Guide for sizing pressure parts in ASME Bolter and Pressure Wesset Code (19681 Section III, Class C.
- 5. V;tves GE 1 1 Requirements for Class 1 A B I 03/20/70 1 If -
valves in Draf t ASME Code for Ptaps and vatves for Nuclear Pouer and requirements applicable to valves in ASME Section III (1968 Edition plus addendal, articles 1 and 8.
'6. Motor, ptmp GE Other -
NEMA Standards NA D I - -
1x -
- 7. Electrical modates, with safety GE 2 - -
NA s I - -
1c -
function
- 8. Cable with safety ftmetion 8 2 - - -
8 I - - - -
- IV CRD Nydraulic System C11
- 1. V;twes, isolation, water return a 1 1 ANSI B31.1.0 or ASME Code A B I 12/19/T2 1 If -
tine for Pumps and Valves for Nuctear Power, Ctass 1, or ASME Section III, 1971 Edition, Class 1
- 2. V;twes, scram discharge volume GE/B 2/2 2 ASME Code for Ptaps and 5/8 8/B I/I 12/19/T2 2 ff -
tines Vetves for NucLeer Power
- 3. V;twes insert and withdraw Lines GE/B 2/2 2 ANSI 831.1.0 or ASME Code S/S 8/8 I/I 12/19/72 2 If -
for Ptaps and Valves for Nuclear Pouer or ASME Section III, 1971 Edition, Class 1
- 4. V;twes, other 8 Other 2 ASME Section III, 1971 D D NA 12/19/72 -
1a,1f,1L Tes Edition
- 5. Piping, water return line within B 1 1 ASME Section III, 1971 A B I 12/19/72 1 - -
Isolation talves Edition
- 6. Piping, scram discharge voltme a 2 2 ASME Section III, 1971 5 3 I 12/19/72 2 - -
Lines Edition T. Piping, insert and withdrau lines B 2 2 ASME Section III, 1971 B B I 12/19/T2 2 - -
Edition T3.2-5 Revision 11 - 04/94
UFSAR/DAEC-1 Tabts 3.2-1 .
DAEC Classific ti:vi sf ra=ranents in systema Equivatent Scope Que1ity Gua1ity ASME .
of Safety Code Construction Grotp Assurance Selamic a & PV Code Principal Component Stpply Class Ctaas Code Class Req. Category PO Date Section III Footnotes Comments (a) (b) (c) (d) (e)(f) (g) (h) (i)
- 8. Piping, other s other 2 ASME section III, 1971 D D NA 12/19/72 -
ta,1b,1t Yes Edition
- 9. Cydraulic control imit GE 2 - - special a I - - -
Yes
- 10. Electricot mo &tes, with safety GE 2 - -
NA 5 I - -
Ic -
function
- 11. Cable, with safety fmetion a 2 - - -
3 I - - - -
V Stan@y Liquid Controt System C41
- 1. stan 6r liquid control tank GE 2 -
API-650 and ASME section s 5 I -
2 -
Yes VIII, Div. 1
2 le -
valves for Nuclear Power
- 3. Ptap motor GE 2 - -
NA a I - - - -
2 If -
Valves for nuclear Power
- 5. V;tves, isolation and within 8 1 1 ASME Code for Ptaps and A a I 10/16/70 1 ff -
Valves for nuclear Power
- 6. V2tves, beyond isolation valves 5 2 2 ASME Code for Ptaps and B a I 10/16/7D 2 If -
Valves for Nuclear Power
- 7. Piping, within isolation valves a 1 1 USAS B31.7-1969 A 8 I 07/30/70 1 la,1b -
- 8. Pipins, beyond footation valves a 2 2 USAs B31.7-1969 8 5 I 07/30/70 2 1a,1b.1m -
- 9. Electrical modules, with safety GE 2 - -
NA 8 I - -
1c -
function
- 10. Cable, with safety fmetion S 2 - - -
8 I - - - -
VI Neutron Monitoring system C51
3 s I -
2 la,1b -
s 8 I -
2 If -
- 4. Cable, IRN and APAM a 2 - - -
B I - - - -
VII seactor Protection System C71
- 1. Electrical modules GE 2 - -
NA B I - -
Ic -
- 2. Cable a 2 - - -
a I - - - -
VIII Process Radiation Monitors 011
- 1. Electrical modules for main steam GE 2 - -
NA a I - -
1c -
tine and reactor butIding ventitation monitors t
- 2. Cable for main steam line and a 2 - - -
8 I - - - -
reactor buttding venti 1ation monitors IX RMR System E11
- 1. Heat enchangers, primary side GE 2 s ASME Section III, Class a 5 5 I Os/15/69 2 - -
and TEMA-C
- 2. Heat exchangers, secondary side GE 3 -
ASME Section VIII, Div. 1, C B I Os/15/69 3 - -
and TEMA-C
shutdoen cooling Isotation valves
- 4. Piping, other s 2 2 usAS m31.7-1969 s s I 07/30/70 2 la,1b - -
T3.2-6 Revision 11 - 04/94
UFSAR/DAEC-1 Tabla 3.2-1 ,
DAEC Classification af Components in Systems Egsivalent Srape Quality Quality ASME .
of Safety Code Construction Grotp Assurance Seismic 5 & PV Code Principal Component Supply Class Class Code Class Req. Category PO Date Section III Footnotes Comments (a) (b) (c) (d) (e)(f) (g) (h) (i)
and valves for nuclear Power or IDE and acceptance requirements of ANSI 331.1 Code Cases N7,N9,N10 +
Design Guide for sizing pressure parts in ASME Boller and Pressure Vessel Code (19681 Section 111, Class C.
- 6. Ptsp motors GE 2 - -
NA 8 I - - - -
cootIng lines Valves for nuclear Power
- 8. Valves, Isotation, other 8 2 2 ASME Code for Ptaps and B 8 I 10/16/70 1 If -
Valves for Nuclear Power
- 9. Valves, beyond isolation valves a 2 2 ASME Code for Ptaps and B B I 10/16/70 2 If -
Valves for Nuclear Power
- 10. Mechanical modJtes GE 2 - -
B a 1 - -
Ic- -
- 11. Electrical modsles, with safety GE 2 - - NA a I - -
Ic -
function
- 12. Cable, with safety function B 2 - - -
8 I - - - -
X Lou Pressure Core Spray E21
- 1. Piping, within outermost isolation B 1 1 USAS E31.7-1 N A B I 07/30/70 1 la,1 In -
-j( -
valves
- 2. Piping, beyond outermost isolation a 2 2 USAS 531.7-1969 s B I 07/30/70 2 1a,1b -
v tves
- 3. Piping, floody line to condensate B Other -
USAS 831.1.0 C 5 I - -
la,1b -
Btorage tenk
and Valves for mucteer Power or NDE and acceptance re w irements of ANSI 331.1 Code Cases NT,N9,N10 +
Design Guide for sizing pressure parts in ASME soiter and Pressure vesset Code (19681 Section III, Class C.
- 5. Ptap motors GE 2 - -
NA B I - - - -
- 6. Valves, footation and within 8 1 1 ASME Code for Ptaps and A 5 I 10/16/70 1 If -
Valves for nuclear Power
- 7. V tves, beyond outermost isolation 5 2 2 ASME Code for Pumps and B B I 10/16/70 2 If -
valves
- Valves for Nuclear Power
- 8. V;tves, flood, line to condensate B Other -
USAS B31.1.0 C B I - -
If -
storage tank
- 9. Electrical modates with safety GE 2 - -
4A B I - -
1c -
function T3.2-7 Revision 11 - 04/94
, UFSAR/DAEC-1 Table 3.2-1 .
DAEC Clasilfic: tion dif Components in Systems Eqtsivalent Scope Quetity Quetity ASME -
of Safety Code Construction Group Assurance Seismic 8 & PV Code Principal Component Stpply Class Class Code Class Req. Category PO Date Section III footnotes Comments (a) (b) (c) (d) (e)(f) (g) (h) (i)
- 10. Cable, with safety finction s 2 - - -
B I - - - -
XI NPCI System E41
- 1. Piping, within outerrest isolation B 1 1 USAS 531.7-1969 A B I 0T/30/70 1 1a,1b -
valves
- 2. Piping, beyond outermost isolation a 2 2 USAS 831.7-1969 s a 1 07/30/70 2 te,1b -
valves
- 3. Piping, return test line to e other -
USAS B31.1.0 D D NA 07/30/70 -
Ia,1b,1r -
condensate storage tank beyond second isolation valve
and Valves for Nuclear Power or W E and acceptance requirements of ANSI B31.1 Code Cases NT.N9,N10 +
Design Guide for sizing pressure parts in ASME Bolter and Pressure vessel Code (19681 Section III, Class C.
- 5. v twes, isolation and within 3 1 1 ASME Code for Ptsps and A B 1 10/16/70 1 If -
Valves for Nuclear Power p.Vtves,returntestlineto B Other -
USAS 531.1.0 0 D NA 10/16/70 -
If -
condensate storage beyond second isolation valve
- 7. Vacutse ptmp discharge tine B Other -
USAS 831.1.0 0 0 NA - -
la,1b -
- 8. Valves, other B 2 2 ASME Code for Ptsps and 3 3 I 10/16/70 2 If -
Valves for Nuclear Power
- 9. Turbine GE 2 -
NEMA Standards for NA B I 07/29/69 -
la Tes Mechanical Drive steam Turbine
- 10. Electrical modules, with safety GE 2 - -
NA B I - -
1c -
ftmetion
- 11. Cable, with safety function 5 2 - - -
B I - - - -
XII RCIC System E51
- 1. Piping, within outermost isolation B 1 1 USAS 831.7-1969 A B I 07/30/70 1 la,1b -
valves
- 2. Piping, beyond outermost isolation B 2 2 USAS B31.7-1969 s a I 07/30/70 2 la,1b -
valves
- 3. Piping, return test line to B Other -
USAS 831.1.0 D D NA 07/30/70 -
Ia,1b,1r -
condensate storage tank beyond second Isolation valve l
i T3.2-8 Revision 11 - 04/94
, UFSAR/DAEC-1 Tabts 3.2-1 .
DAEC Classification of r=panents in Systems Equivalent Scope Quality Quetity ASME -
of Safety Code Construction Group Assurance Seismic 5 & PV Code Principal rmyanent Supply Class Class Code Class Req. Category PO Date Section III Footnotes Comuments (a) (b) (c) (d) (e)(f) (g) (h) (i)
2 le -
and valves for Nuclear Power or NDE and acceptance requirements of ANSI 331.1 Code Cases NT,N9,N10 +
Design Guide for sizing pressure ports in ASpE Solter and Pressure Vesset Code [19681 Section III, Class C.
- 5. W.tves, isolation and within B 1 1 ASME Code for Pumps and A B I 10/16/10 1 ff -
valves for Nuctaar Power
- 6. V;tves, return test line to B Other -
USAS B31.1.0 D D NA 10/16/70 -
If -
condensate storage beyond second -
isolation valve T. Vacuum pump discharge line B other -
USAS 831.1.0 D D NA -
2 1a,1b -
- 8. V;twes, other 8 2 2 ASME Code for Pumps and a B I 10/16/70 2 If -
valves for Nuclear Power
- 9. Turbine GE 2 -
NEMA Standards for NA 8 I D7/29/69 -
1g Tes Mechanical Drlwe Steam Turbine
- 10. Electrical mo& tes, with safety GE 2 - -
NA B I - -
Ic -
ftmetion
- 11. Cable, with safety ftmetion B 2 - - -
8 I - - - -
XIII Fuel Service Equipment F11
- 1. Fuet preparation machine GE 3 - -
NA B I - - - -
- 2. General purpose grapple GE 2 - -
NA B I - - - -
XIV Reactor vesset Service Ecpalpment F13
- 1. Steam line plugs E 3 - -
NA B I - - - -
- 2. Dryer and separator sting and head E 2 - -
NA 8 I - - - -
strongback
, XV In-Wesset Service Ecpilpment F14
- 1. Control rod grappte GE 2 - -
NA B I - - - -
XVI Refueling Equipment FIS
- 1. R1 fueling equipment platform GE 2 - -
NA 8 I - - - -
assembly XVII Storage Ecpalpment F16
- 1. Fuet storage racks GE 2 - -
NA B I - - - -
- 2. Defective fuel storage container GE 3 - - -
3 I - - - -
XVIII Radmaste System G11
- 1. Tanks, Atmospheric GE/B Oth/Oth - API-650 or AWWA-D100 or CSD D/D NA/N4 07/16/70 -
1h Yes ANSI B96.1 or egalvatant plus NDE per ASIE Section VIII Div. 1.
- 2. Heat exchangers GE/8 Oth/Oth - -
D/D D/D NA/WA - - - -
- 3. Piping and valves, containment B 2 2 USAS 531.7-1969 s s I -
2 1a,1b -
isolation T3.2-9 Revision 11 - 04/94 l
, UFSAR/DAEC-1 table 3.2-1 .
DAEC Clasalfict. tion af Components in Systems Equivalent .
Scope euetity ouetity ASIE .
of Safety Code Construction Grong Assurance Seismic 5 & PV Code Principet Component Supply Class Ctess Code Ctess Req. Category P0 Date Section III Footnotes Comments (e) (b) (c) (d) (e)(f) (5) (h) (i)
- 4. Piping, other B Other 3 USAS 531.7-1969 C80 D NA - -
la,1b,1j Yes
- 5. Pmps GE Other 3 ANSI B31.1.0 or ASME Code CSD D NA 07/03/72 - 1e,1) -
for Pigs and Va1ves for Nucteer Power, Class 3, or ASME Section III, 1971 Edition, class 3
If.1j -
system Va'ves for mucteer Power
- 7. Velves, other 5 other 3 ANSI B31.1.0 or A$pE Code C80 D NA - -
If,1) -
for Ptaps and Valves for Nucteer Power, Class 3, or ASME Section III,1971 Edition, Ctess 3
- 8. Mechanical modates GE Other - -
C80 D NA - -
Ic,1) -
XIX Reactor Water Clearsy ::ysten G31
- 1. Vessets: fitter /demineralizer GE Other C ASME Section III C 5 I 12/17/70 3 It -
- 2. Neet enchangers GE Other -
ASME Section VIII and C 8 1 09/25/67 3 ft -
TEMA-C
- 3. Piping, within outermost isolation 5 1 1 USAS 331.7-1%9 A e I 07/30/T0 1 t e,1t, velves
- 4. Piping, beyond outermost isolation 5 v;tves Other 3 USAS B31.7-1969 C B I 07/30/70 3 1a,1b 1o,1t Ye5 y
$. Pumps GE Other 3 ANSI S31.1.0 or ASME Code C B I 12/23/69 3 le,1t -
for Pumps and Valves for Nucteer Power, Ctess 3, or ASME Section III, 1971 Edition, Class 3
- 6. V:tves, icoletion vetves and 5 1 1 ANSI B31.1.0 or ASME Code A B I -
1 if stithin for Ptaps and valves for Nucteer Power, Ctess 1, or ASME Section III, 1971 Edition, Ctess 1
- 7. V;twes, beyond outermost isolation GE/8 Oth/Oth 3 ANSI 831.1.0 or ASME Code C/C B I -
3 ff,10,1t -
we1ves for Ptaps and Va1ves for Nucteer Power, Ctess 3, or ASME Section III, 1971 Edition, Class 3
- 8. Mechanical modules GE Other - - -
B ' - -
Ic.1t -
XX Fuel Pool Cooling and Clearsy System G41
- 1. Vessels, filter /desineralizers GE Other -
ASME Section VIII, Div. 1. C D NA - - - -
- 2. Vessels, other B Other -
ASME Section VIII, Blv. 1. -C D NS -
3 - -
- 3. Neet enchangers GE Other -
ASME Section VIII, Div. 1, C D e4 12/23/69 3 - -
and TEMA-C T3.2-10 Revision 11 - 04/94 l
UFSAR/DAEC-1 Table 3.2-1 .
DAEC Ctescificction of Components in Systems Equivalent Scope eue1ity euetity ASuE -
of Safety Code Construction Grote Assurance Seismic a & PW Code Principet Component Steply Ctess Ctess Code Ctess Req. Category PO Date Section III Footnotes Comments -
(a) (b) (c) (d) (e)(f) (s) (h) (i)
- 4. Ptaps CE Other 3 ANSI B31.1.0 or AsME Code C D NA -
3 - -
for Ptaps and Velves for Nucteer Pomer, Class 3, or ASME Section III, 1971 Edition, Class 3
- 5. Piping s Other 3 USAS 331.T-1969 C D NA - -
te -
- 6. V;twee s other -
ANSI 331.1.0 or ASE Code C80 D NA - -
If -
for Ptaps and Valves for Nucteer Power, Ctess 3, or ASME Section III, 1971 Edition, Class 3 XXI Control Room E Remote Shutdoun PanelsM11 C61
- 1. Electrical modates, with safety GE 2 - -
NA B I - -
Ic -
ftmetion
- 2. Cable, with safety function s 2 - - -
3 I - - - -
XXII Local Penets and Rocks N21
- 1. Electrical modJtes, with safety GE/s 2/2 - -
5/- 5/B I/I - -
Ic -
function
- 2. Cable, with safety function 5 2 - - -
a I - - -
XXIII Cffees System N62 g
- 1. Tanks GE Other -
AWWA D100 or API-650 -
D NA 10/21/T1 -
1h -
l
- 2. neat eschengers GE Other -
Section III & TEMA-C -
D NA 11/20/T2 - - -
- 3. Piping e Other 3 ASME Section III-1971 -
D NA 07/27/72 - Ik Yes
- 4. Pumps GE Other - -
D D NA - -
1e,1k Yes
- 5. Velves, flou control B Other - -
D D un - -
If,1k ves
- 6. V;tves, other 5 other - -
D D NA 11/29/T1 -
If,1k Yes
- 7. Mechanical modules GE Other - -
D D 24 - -
Ic -
- 8. Pressure vessets GE Other -
0 D NA 10/21/T1 - - -
XXIV Emergency Service Water E13 - gNSI r A B38.I 0 - 4%7 i 1. Piping
- 2. Pmps 5
B 3
3 3 b" " ' _ '
3 ASME Code for Ptaps and 0+e4 D+en s
s I
I 07/30/70 3
3 le Yes k
l Valves for Nucteer Pouer
- 3. Pump motors a 3 - - -
B I - - - -
l 4. Valves a 3 3 ASME Code for Ptsgo and D+04 s I 10/16/70 3 If --
Vatves for leucteer Power
- 5. Electricet modates, with safety a 3 - - -
B I - -
Ic -
function
- 6. Cable, with safety function a 3 - - -
3 I - - - -
XXV Rus Service Water System E12
- 1. Piping 5 3 3 USAS 331.T-1969 C 3 I 07/30/70 3 1p . -
- 2. Pumps s 3 3 ANSI 331.1.0 or ASME Code C 5 I -
3 1e -
for Ptaps and VeIvos for uucteer Power, Ctess 3, or ASME Section III, 1971 l
- Edition, Ctess 3
- 3. Ptap motors e 3 - - -
3 I - - - -
l T3.2-11 Revision II - 04/94
, UFSAR/DAEC-1 Tebt2 3.2-1 -
DAEC Classification of Componenta in Systems Equivalent Secpe Ouetity cuatity ASME of Safety Code Construction Group Assurance seismic 5 & PV Code Principet ra-wwwnt Steply Class Ctess Code Class Req. Category PO Date Section III Footretes Comiments (e) (b) (c) (d) (e)(f) (g) (h) (i)
- 4. V;tves B 3 3 ASME Code for Pumpe ord C B I 10/16/T0 3 If,1p -
Velves for mucteer Power
- 5. Electrical modules, with safety B 3 - - -
B I - -
1c -
fisiction
- 6. Cable, with safety fisiction B 3 - - -
B i - - - -
XXVI ROCCW P42
- 1. Piping, and volves forming port of 8 2 B ASME Nucteer Vessels Code B B I 07/30/70 2 - -
primary contelrunent batsidery Section III, Entension of Containment Code Cases 1425, 1426 & 1627
- 2. Piping and valves inside drywell B Other -
U$AS 331.1.0 0 5 - -
1s -
XXVII
- 3. Piping and volves, other Welt Water System P46 B Other - / (15A5 k.,__ 53 I. l.0-)D 8- I IM - -
s -
p
- 1. Piping and vetves forming part of B 2 B AJHE !:ucteer vessels Code, B 8 I - - - -
primary contelrweent boundary 54ttien III, Extension of Coi'teirinent Code Cases 142f, 1426 & 142T
- 2. Piping and valves inside drywell B Other -
USAS 831.1.0 D 8 I - -
Is -
- 3. Piping and valves, other B Other -
usAs 831.1.0 D - NA - - - -
XXVIII Pneuuntic Systems T4B P50
- 1. Citrogen vessets, accumulators, B 2 2 ASME Section III -
B I 02/26/73 - - -
supporting safety-related systeme
- 7. Mitrogen piping and vetves in B 2 2 ASME Section III -
B I - - - -
lines between above occunutators and safety-related systenis
- 3. Nitrogen piping and valves forming B 2 2 ASME Section III -
B I - -
Ib -
part of containment botsidery
- 4. Instrument air vessets, B 3 - - -
B I 02/26/T3 - -
acessutators, suppertIng safety-related systess
- 5. Instrument air piping and volves B 3 - - -
B I - - - -
in lines between above accunutators and safety-related systems XXIX Diesel Generator Systens R43
- 1. Day tanks B 3 -
API-650 or AIAM-D100 or C B I - - - -
ANSI 896.1 or espivetent plus NDE per ASME Section VIII, Div. 1.
- 2. Piping ord velves, fuel ott system B 3 3 USAs 831.T for pipe and C B I - - - -
and dieset service water system ASME Code for Pumps and Velves for Nucteer Power
- 3. Ptsps, fuel oil system and diesel B 3 3 ASME Code for Pumps and C B I - - - -
service water systee Velves for Nucteer Power
- 4. Pupp motors, fuel ott system and B 3 - - -
B I - - - -
dieset service water systen
- 5. Dieset-generators B 2 - - -
B I - - - -
T3.2-12 Reviston 11 - 04/94
7 UFSAR/DAEC-1 Tablo 3.2-1 .
DAEC Ctesalficction cf ramparmita in Systems Eqtaivalent Scope Ouality Quotity ASME -
of Safety Code Constructite Group Assurance seismic 5 & PV Code Principet Component Supply Class Class Code Ctess Req. Category PO Date Section III Footnotes Coussents (s) (b) (c) (d) (e)(f) (g) (h) (i)
- 6. Electrical modates with safety B 3 - - -
B I - -
1c -
ftmetton
- 7. Cable, with safety ftmetion 5 3 - - -
B I - - - -
- 8. Dieset fuel storage tanks B Other -
API-650 or mam-D100 or C a I - - - -
ANSI B96.1 or eosivetent plus NDE per ASpE Section -
VIII, Div. 1.
- 9. Diesel Air Start system B 2 - - -
8 I - - - -
XXX Conteltvernt Atmosphere Control System T48
- 1. Piping and velves from primary 5 2 5 ASME Nucteor Vessets Code B B I 07/30/70 - - -
contelrveent through outer section III, Extension of isolation valve Code cases 1425, 1426 and 1427 XXXI Stan 4 y Gas treatment system T46
- 1. Att components with safety a 3 - - -
a I - - - -
ftmetion, including offges stock dilution fans XXXII ECCS Equipment Aree CootIng system t41
- 1. Att components with safety a 3 - - -
a I - - - -
functione XXXIII Power Conversion system ull N21
- 1. Main steen piping from outboerd 5 other -
USAs B31.1.0 D+eA B I 07/30/70 -
la Tes MSIV to turbine stop valves and branch Line piping up to and including first volve
- 2. Steen piping and vetves, other 8 Other -
USAS 531.1.0 D+e4 -
54 07/30/70 -
la -
- 3. Reector feedseter piping and B 1 1 USAS B31.7-1969 A B I 07/30/70 1 to,1b,1f -
nives, RPV to outermost footetton valve
- 4. Reactor feedwater piping and 3 Cther -
USAs 531.1.0 D+G4 -
NA 07/30/70 - le,1f Yes velves, other XXXIV Condensate Storage and Transfer system P11
- 1. Condensate storage tank e other -
API-650 plus auseented NDE D+QA -
NA 07/30/70 -
ti Yes of welds
- 2. Piping and volves -
5 Other -
USAS 531.1.0 0 D NA - -
If,1q -
3, rther c " "'h*e - -
D D NA - - -
1 --^':. e-c Power A4RDZ 19
. Au em - s with setety sylten llelL-24 N 3 a 4 - - -
8 I - - - -
g function XXXVI 125/250 volt d-c Power system R42
- 1. All components with safety 5 2 - - -
3 I - - - -
ftmetion XXXVII River Water st9pty W10
- 1. Piping, pises and valves 3 Aust 831.1.0 D'QA I B e - -
If -
- 2. Intake treveling screen, trash B 3 - -
3 I - - - -
rakes
- 3. Ptap motors s 3 - .- -
a I - - - -
T3.2-13 Revision 11 - 04/94 l
- , UFSAR/DAEC-1 Tabla 3.2-1 .
DAEC Closalfic:.tlen af ramy==wnts la Systems Equivalent-Scope Ouetity Gustity ASIE -i of Safety Code Construction Grote Assurance Seismic 8 & PV Code Principet r W Steply Class Class Code Ctess Req. Category PO Date Section III Footnotes Comuments (a) (b) (c) (d) (e)(f) (g) (h) (i)
I XENVIII NSIV Leekage controt 821
- 1. Piping and vetves to to the first 8 1 1 ANSI B31.7 A B I - -
1e,1b,1f -
lootetton volve of the irtoord subsystem
- 2. elping and vetves, other a 2 2 AsNE Section III-1974 -
B 1 - -
le,1b,1f -
- 3. 5 towers CE 2 - -
B B I - - - -
XXXIX WAC
- 1. Controt room -
3 - - -
B I - - - -
- 2. Pump house -
3 - - -
5 I - - - -
- 3. Emergency dieset generater room -
3 - - - 3 I - - - -
- 4. Reector building secondary -
3 - - -
B I - - -
- contelrunent isolation despers
- 5. Dettery rooms -
3 - - -
B I - - - -
- 6. Intake structure -
3 - - -
B I - - - -
- 7. Essentist switchseer roome -
3 - - - 3 I - - - -
XXXX ElscelIeneous Components
- 1. Reactor cultding Crane s 3 - - -
a I - - - -
- 2. Contelrunent Penetrations for 8 2 - - - 3 I - - - -
Process Piping and Electricot e
s T3.2-14 Revision 11 - 04/94- l
, IIFSAR/DAEC-1
, =
Table 3.2-1 DAEC Classification of Components in Systems Footnotes .
Footf Footnote Systems a GE = General Electric; 5 = Sechtet; C = Cg&l; IE = Ious Electric Light & Pouer Co.
b 1, 2, 3, "other* = safety etesses defined in section 3.2.4; "unc= = unclassified as defined in section 3.2.4.
c The e pipment shalt be constructed in accordance with the codes listed in Table 3.2-2, if
] no Code of Construction is provided in this table. The term " construction", as used in this UFSAR, includes provisions for design, meterlsts, fabrication, erection, testing and inspection.
d 5 = The e pipment shalt meet the p etity assurance requirements of 10CFR50, Appendix 3, in accordance with the p etity assurance program described in Chapter 17. D = The equipment shall be constructed in accordance with the p etity assurance re girements consistent with good practice for steam power plants.
e I = The equipeent shett be constructed in accordance with the seismic requirements for the safe shutdom eartheeke, as described in Section 3.T. Seise c Design. NA = The seismic requirements for the safe shutdoun earthquake are not applicable to the e p ipment.
f Portions of 'non-seismic category I' piping (seismic category NA) possing through rooms contelning safeguard equipment are seismicetty supported es seismic category I.
g Date on the purchese order for the component. Were provided, this con be used to establish the code edition and addende in effect for the component, h This cottman is for information only. the Code Class given t.vre is that which would apply if the current edition of section Ill were to be used as the Code of Construction. The colisei under the heeding " Code Ctessa shall be used to determine the actuel Construction Code class of the item.
I A "yes" in this cottaus signifies there is a comment regarding the item at the end of Table
, 3.2-1.
la The foltoving items are alplicable to instrument, sempting or smelt bore (3/4" NPs and I-10, Il-7, 11-8, 11-13, II-4, III-1, IV-4. IV-8, V-T, V-8, i smetter), as noted: **(1) Lines 3/4" and saatter d ich are port of the reactor coetent VI-1. IX-3, IX-4, X-1, X-3, X-2, XI-3, ul-1, ul 7, xl-2, boundary shett be safety Class 2. **(2)Att instrument lines d ich are connected to the XII-T, Mil-2, XII-1, III-3, XVIII-4, XVIII 3, XIX-4, MIM-3, reactor cootent pressure bomdery and are utilized to actuate safety systems shett be xx-5, xxxIII-3, xxxIII-1, xxxIll-4, xxxill-2, xxxVIII-2, safety Ctess 2 from the outer Isolation velve or the process shutoff velve (root volve) to xxxVIII-1, the seneing instriment. **(3)Att Instrument tines which are comected to the reector cootent pressure bomdery and are not utilized to setuste safety systems shett be Guelity Crote D from the outer Isolation velve or the process shutoff velve (root velve) to the sensing instrumentation. **(4)Att other instrument lines through the root volve shall be of the same ctossification as the systemt to which they are ettsched, encept those Lines that contain en excess flow check volve (EFCV) are classified as tuotity Groty D beyond the EFCV. See Figure 3.2-2. **(5)Att other instrument lines beyond the root volve, if used to actuate e safety system, shett be the same cleosification es the system to which they are attached. **(6) Att other instrueent lines beyond the root velve, if not used to actuate e safety system, shell be Guelity Group D. **(T)Att sample lines from the outer isolation vetve or the process root volve through the remainder of the sampling system ehett be euelity Grote D.
Ib ANSI B31, Code Case 78 applies for g31.7 Ctess 1 and Ctess 2 pipe and fittings 3/4= nominst I-10, II-T, II-8, 11-13. II-4, III-1, IV-8, V-8, V-T, VI-1, pipe size (urs) and smelter. Ix-4, In-3, x-2, X-3, x-1, XI-2, MI-1, XI-3, MI-T, XII-1,
. XII-3, XII-T, XII-2, avlII-3, XVIll-4, XIX-3, XIX-4, XXVIII-3, xxxIII-3, xxxVIII-2, xxxvIII-1, Ic A modde is an essembly of interconnected components dich constitute en identlfleIde 11-14, 11-15. Ill-7, IV-10, V-9, VI-3, VII-1, VIII-1. II-10, device or piece of e pipment. For example, electrical modules include sensors, power IX-11, X-9, MI-10, XII-10, XVIII-8, XIX-8, xxI-1, xxii-1, supplies, and signet processors. nochenical modules include turbinee, strainers, and mulII-7, xxiv-5, xxv-5, xxtu-6, orifices.
Revision 11 - 04/94 l
UFSAR/DAEC-1
! Taida 3.2-1 DAEC Ctesaf ficstion cf Components in systems M i Footnotes i
Footf Footnote Systess j .
I 1d GE Specification 21A11004S (Ref. 243) adds the following code repirements to the neoctor I-1, I-2, 1 3, I-5, I-9, vessel: The Winter 1967 Addende to the ABIE Code Section III is not to be included as e i basis for purchese of this vesset, encept es follows: 1)Charpy impact tests per N-331.2 of j the Winter 1967 Addende will be furnished; 2) Welds are to be ultrasonicotty enemined using j the anste been method described by N-625 of Winter 1967 Addende; 3)The changes to Article 4-Design by the Winter 1967 Addende are included; 4)The addition of Appendia In-eustity
! Control and mondestructive Emaninetion Methods is included.
l 1a For piasp designe, the applicalde etess, section, or subsection of the referenced ASME S&PV III-4, v-2, Ix-5, x-4, XI-4, XII-4, xvill-5, XIX-5, MFIII-4, Code as used as a guide in calculating the thickness of pressure-retaining portions of the xxiv-2, MNV-2,
- ptsup and in sizing cover botting. For enssple, use ASME Section III, Ctess C,1968 l Edition, for e design guide for cuality Grotp A & 8 ptsups. For Quotity Group D below 150 j pois and/or 212 deg. F, manufacturer's standard ptmp for service intended may be used.
If Aest s16.5 or Mss-sP-66 apply for velves tuote Nss-sP-66-1964 was withdrawn from II-9, 11-10, II-11, 11-12. 11-13 III-5, IV-1, IV-2, IV-3, i publication in favor of Aust 816.34-19731. IV-4, v-4, v-5, v-6, VI-2 IM-8 Ex-9, Ix 7, x-T, I-6, x-8, MI-5, XI-6, XI-8, XII-5, XII-6, mII-8, XVIII 6, XVIll-7, XIX-6, XIn-7, xx-6, xxIII-6, xxIII-5, unty-5, xxv-4, xxxIII-3, xxxIII-4, xxxIV-2, xxxvil-1, xxxvill-1, xxxvIII-2, 13 The RCIC and NPCI turbines do not fett within the applicable design codes. To assure that XI-9, XII-9, l i
the turbines are fabricated to the standards casameneurete with their safety and performance respairements, Generet Electric hee established specific design roupstrements for these .
components.
I Ih Entsting API /AIAm stenderds and supplementary requirments aply. Tanks are to be xvill-1, xxIII-1 constructed to meet the intent of API Standards 620 or 650 or Alam standard D100 for those :
fuel, oft, or water storage tanks.
, 11 The condensate storage tank will be designed, fabricated and tested to meet the intent of XXXIV-1, ,
! API Standard 650. In addition, the specifications for this tank will respaire 100K surf ace examinetton of the side weit to bottom joint and 1001 volumetric eneminetton of the side l wett weld joints.
1J ASME Section VIII, Division 1, and USAs 531.1.0 apply downstream of the outermost isolation XVIII-4, XVIII-5, xvIII-6, xvill-7, XVIII-8, ,
i volves. i Ik The geseous rechseste system piping, pimps and volves containing geseous restseste shett be xxIII-3, xxIII-4, xxIII-5, xxIII-6, t constructed in secordance with the applicable codes of euelity Grong D.
It some of this piping was etso constructed to B31.1.0 IV-4, IV-8, to Some lines. such as ECS-9 (drain to filter /demineratizerL are eless 3, non-seismic. v-a.
Qn _H: _ ,1 - _r_ " . Z - --T--,_
DELETE D 5*,
- J Y-Lines in.u-I and BCB-2 are nucteer etess 3, accorains to Bechtet specification M-190.
la MIM-4, miM 4 ,
1p The RNRSW backweek line (GBD-62 and 380-63) is non-seismic, according to Bechtet xxv-1, xxv-4, specifiestion M-190, sheet 234.
Iq Portions of this system which stopty suction for NPCI, RCIC, and Core spray from the xxxty-2, Muxlv ,
, condensate storage tank are seismic category I.
? 1r The return line to the condensate storese tank was etessified as "0" by techtet in the XI 3, XII-3, 4 0-tist (Ref. 225) eral was built that way by techtet, powever, these lines are actually euelity Group D, with no en requirement. Thet is the way these lines are ctessified in !
i this table. L
. Is The techtet e-tiet (Ref.- 225, item 2.4365) notes this item as e. However, the entry refers to techtet specificetten N-119 (Reference 252). This decisment addresses selenic Category I xxvi-3, xxvt-2, xxvil-2, -
g' supports only. Therefore, enty the supports in this itse have a respoirement for epselity ,
esourance and are Selenic Category I.
j It The techtet e-list (Ref. 225, item 2.1510) notes this itas as e. newever, enty pipe MIM-1, xtu-2, XIM-4, XIM-5 XIM-7, Mix-8, -
hangers and styperts provide a specification (N-119, Ref. 252) as a reference. Therefore, +
only pipe hengers and sipports for_ this item are seismic category I and have speclet j euelity Assurance respairements. :
4 !
i j
T3.2-16 NCVI SI*' I I - "IIN'I l 1
d
UFSAR/DAEC-1 i
Tabte 3.2-1 ,
, DAEC Clasalfic tion af Components in Systems Footnotes Foot 9 Footnote Systeen .
tu See GE doctment NEDC-31853 (Ref. 2) Nunne Arnold Design Safety Standards", Appendia A, for I-5, I-6, I-9, l stress and deforention limits for this iten.
Iv DELETED 1m This item includes the 24 volt D.C. Power System. VI-3, la The recirc gamp motors are not seismic category I. However, per 2149213 sections 4.1.8.3.5 III-6,
& 4.1.6, they must be seismicetty o p ted so es not to breech the Integrity of the reactor coolant pressure bowedsry.
l T3.2-17 Revision 11 - 04/94 l
IIFSAR/DAEC-1 Tebte 3.2-1 DAEC Ctessification of Components in Systeams rm-nts Sysf/Compf Comments IV T 1 The destyi and cenetruction specificottons for the hydreutic control telt (NCU) do invoke such codes and stenderds es can be reesonably applied to Individuet ports in developing regfred quality levels, but these codes and standards are espplemented with additionet rewirements for these ports and for the remaining ports and deteits. For exemple: (1) ett melds are liquid-penetrant inspected; (2) ett socket welds are checked for minimum ensegement and end gap between pipe and socket bottom by a merking technipe; (3) ett welding was performed by quellfied welders; (4)ett work was done per written procedures. The following exemples are typical of the problems associated with codes designed to control field-essend>ted components when applied to the design and production of factory fabricated specletty components: **1. The NCU nitrogen gas bottle is a sp m forging that is mechanicotty joined to the acesmulator. It stores the energy required to scram o drive et low vesset pressure. It nos been code steeped since its introduction in 1966, etthough its size exempts it from mandatory steeping. It is constructed of a meteriet ilsted by the ASME g4PV Code,Section VIII, that was selected for its strength and forsebility. "2. The scram occtmatator is joined to the NCU by a split fienge joint chosen for its compect desten to facttitste both esseebty and maintenence. . goth the desien and construction confora to the 331.1.0 piping code. This joint, which requires e design pressure of 1750 pois, has been proef tested to 10,000 psi. "3. The acetamateter nitrogen shutoff volve is a 6,000 pel cartridge valve whose copper ettoy meteriet is listed in the ASME g4PV Code,Section VIII. The volve was chosen for <
this service partly because it is p etified by the U.S. gevy for submarine service. **4. The directionet control volves are solenoid pilot-operated valves that are st&ptete moteted on the NCU. The valve has a body specletty designed for the NCU, but the operating parts are i identicet to e commercial vetve with a proven history of settsfactory service. The pressure retaining parts are steintess steet attoys chosen for service, fabrication and mognetic properties. The manufacturer carmot substitute a code meteriet for that used for the solenoid core tube. The foregoing exemples are not seent to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those petity levels are not strictly applicebte to speclet equipment and part designs. Groi ,e etessification is generetty applicable i
because the codes and stenderds invoked by that ctessificetlan contain cieuses that permit the use of manuf acturer's stonderds and proven design techniwes that are not explicitly defined within those codes. This was steptemented by the p etity control techni v es described above.
IV 4. 2 gechtet built these items to ASME Ctess 2 stenderds, based on the piping ctesses given on the P&lO (see peregraph 3.2.T). However, based en the GA classification of these iteam, they should have been Ctess 3. The higher etess is shown on this table, etthough Class 3 is justifiable ord
- would make more sense with the 04 Group D designation.
IV
- 8. 1 The design and construction specifications for the hydraulic control unit (NCU) do invoke such codes and stenderds er can be reasonably applied to individuet ports in developing rewired petity levels, but these codes and standards are supplemented with additionet requirements for these ports and for the remaining ports and deteits. For esempte: (1) ett welds are liquid-penetrant inspected; (2) ett socket welds are checked for minimum engagement and end gap between pipe and socket bottom by a morting technipe; (3) ett welding was performed by quotified welders; (4)ett work was done per written procedures. The following emanu>tes are typicot of the problems associated with codes designed to controt field-esseebted components e en applied to the design and production of factory fabricated specletty components: "1. The NCU nitrogen ges bottle is a span forging that is mechanicotty joined to the accamestator. It stores the energy required to scram o drive et low veneet pressta e. It has been code stesped since its intrechaction in 1966, etthough its size essepts it from mandatory stamping. It is constructed of e enteriet listed by the ASME g4PV Code, Section Vltl, that was selected for its strength and forsebility. "2. The scram occumuletor is joined to the NCU by a split 1 flenge joint chosen for its compact design to facilitate both essembly and maintenance. goth the design and construction conform to the g31.1.0
! piping code. This joint, dich requires e design pressure of 1750 pois, has been proof tested to 10,000 psi. "3. The acessautator nitrogen shutoff velve is a 6,000 pel cartridge velve whose copper elloy meteriet is listed in the ASfE BSPV Code,Section VIII. The volve was chosen for-1 this service partly because it is quellfied by the U.S. Navy for submarine service. **4. The directionet control valves are solenoid pilot-operated valves that are subplete mounted on the NCU. The volve has a body specletty designed for the NCU, but the operating parts are 1 identical to e commerclet velve with a proven history of satisfactory service. The pressure retaining parts are steintess steet attoys chosen for service, fabrication and magnetic properties. The manufacturer cannot siestitute a code materiet for that used for the solenoid core tihe. The foregoing exemples are not seent to justify one pressure integrity p olity levet or another, but to demonstrate that the codes and stonderds invoked by those quality levels are not strictly applicable to speclet e p ipment and part designs. Group a classification is generetty applicebte because the codes and stensords invoked by that classification conteln clauses that permit the use of manufacturer's standards and proven design technipes that are not explicitly defined within those codes. This was supplemented by the p etity control techni pes described above.
IV 8. 2 sechtet built these items to ASME Ctess 2 stenderds, based on the piping ctesses given on the PSIO (see peregraph 3.2.7). However, based on the e4 ctessification of these items, they should have been Ctess 3. The higher class is shown on this tabte, etthough Ctess 3 is justiflebte and would make more sense with the SA Group D designation.
r a
ry T3.2-18 Revision 11 - 04/94
tIFSAR/DAEC-1 Table 3.2-1 ,
DAEC Ctessificction cf Components in Systems Comments j Sysf/Compf Cosoments =
j IV T 1 The design eral construction specifications for the hydroutic control tstit (NCU) do invoke such codes and standards es can be reasonably applied to
] Indivl&et ports in developing rewired petity levels, but these codes and standards are supplemented with additional rowirements for these ports and for the remaining ports and details. For eneupte: (1) ett welds are ti p id-penetrant inspected; (2) ett socket welds are checked for minimus engeomment and end gap between pipe and socket bottom by a merking technip e; (3) ett welding was performed by quellfled welders; (4)ett
] work was done per written proce &res. The following examples are typical of the problems associated with codes designed to controt fletd-essembled components een applied to the design and pro &ction of factory fabricated speeletty components: **1. The NCU nitrogen gas bottle 3
is a spun forging that is mechanically joined to the scensuutetor. It stores the energy re wired to scram a drive et low vesset pressure. It has been code stamped since its intro & ction in 1966, although its size enempts it from mandatory stamping. It is constructed of a meteriet listed by the ASE g&PV Code,Section VIII, that was selected for its strength and forumbility. **2. The scram acessmutator is joined to the nCU by a split
- flange joint chosen for its compact design to facilitate both sesembly and meintenance. Both the design and construction conform to the 831.1.0 piping code. This joint, dich rewires e design pressure of 1750 pois, has been proof tested to 10,000 psi. "3. The occteutator nitrogen shutoff velve is a 6,000 poi cartridge volve whose copper alloy meteriet is ilsted in the ASME B8PV Code,Section VIII. The valve was chosen for this service pertly because it is p etified by the U.S. Navy for se merine service. **4. The directionet control vetves are solenoid pilot-operated vetves that are edplate mounted on the NCU. The volve hos a body specletty designed for the WCU, but the operating parts are identical to a commercist volve with a proven history of settsfactory service. The pressure retaining parts are stainless steet altors chosen for service, fabrication and magnetic properties. The manufacturer cannot s e etitute a code meterlat for that used for the solenoid core tihe. The foregoing examples are not seent to justify one pressure integrity petity level or another, but to demonstrate that the codes and standards Invoked by those p etity levels are not strictly applicebte to speclet equipment and part designs. Grotp D classification is generally applicable l because the codes and standerde invoked by that ctessification contain clauses that permit the use of manufacturer's standards and proven design i
techni p es that are not explicitly defined within those codes. This was styptemented by the petity control techni p es described above.
V 1. 1 The stantasy tipid control storage tank is designed, fabricated, inspected, and tested to meet the intent of API Standard 650 and the ASME g&PV Code,Section VIII, Division 1. Att butt welds are given spot radiographic exeelnetton. Liquid-penetrant inspection is conducted per the ASME Code,Section VIII, Division 1, on the following welds: "(1)Att tort notate welds below and including the overflow notate are enemined internetty and externetty to the tank. **(2) Alt fillet and socket welds receive e random esamination.
V 1. 2 The construction of the accumulator is in accordance with the re wirements of the ASME BSPV Code,Section VIII, Division 1. An ASME stamp is
' required. Other codes applied to the acetenutator are se followst "(1) ANSI B16.11
- Forged Steel Fittfnes, Socket Welded and Threeded". **(2)AND 10050 *gosses, Standard Dimensions for seeket Seet Straight Threed". .-
VI 3. 1 See IELP tetter to the USuec, me-91-2652, dated 8/27/91, for inctusion of the 24 V D. C. Power Stypty with this item.
XI 9. 1 The NPCI turbine is categortred as machinery and thus dres not felt within the ctessification groips as eerlier identified. To ensure that the.
turbine was fabricated to the standards commerwiurate with its performance rewirements, Generet Electric hos established specific design re w irements for this component, se follows: **(1)Att welding was quellflod in accordance with Section IX of the ASME BSPV Code. **(2)All 4 pressure retaining costings and fabrications were hydrotested to 1.5 m design pressure. "(3)Att high pressure castings were radiogregwd occording to ASM E-94 (20E coverage, minimus), ASTM E-142 (severity level 3), A$m-71, ASTM 186, or ASTM-200. "(4)As-cost surfaces were magnetic porticle or tipid-penetrant tested according to the ASME 58PW Code,Section III,1968 Edition, peregrapt N323.3 or N323.4. **(5) Wheel and shaft forgines were uttrosonicetty tested according to ASTIl A308. "(6)eutt welds were redlegraphed according to the ASME 38PV Code,Section III,1968 Edition, peregraph N624, and magnetic porticle or timid penetrant tested eccording to ASfE Section III, peregraph N626 or N62T.
- (T)motificetten made en any major repairs and records maintained. "(8)secord system and traceability according to the ASME BSPV Code, Sectior III, 1968 Edition, IX 225. **(9)Contret and identificetten according to the ASME 88PV Code,Section III,1968 Edition. IX-226. "(10) Procedures conform to the ASME 88PV Code,Section III, 1968 Edition, IX-300. **(11) Inspection personnet are w ellfied according to the ASME 88PV Code,Section III, 1968 Edition, IX 400. (APEO-A61-052, cameent 10)
XII 9. 1 The RCIC turbine is categorized as machinery and thus does not felt within the classification groips es eerlier identified. To ensure that the turbine was fabricated to the standards _ a nte with its performance re pirements, Generet Electric has established specific design
~
re p irments for this component, se follows: "(1)ALL welding wee wellfled in accordance with Section IX of the ASME 58PV Code. **(2)Att pressure retalning costings and fabeleetions were hydrotested to 1.5 m deelen pressure. "(3) Alt high pressure costings were radiographed according to Asm E-94 (20E coverage, miniesse), ASTM E-142 (severity level 3), ASTM-71, ASTM-186, or ASTM-280. **(4)As-cost surfaces were magnetic porticle or tipid-penetrent tested according to the ASIE BSPV Code,Section III,1968 Edition, peregraph N323.3 or m323.4. "(5)neieel and shaft forgings were uttresonicotty tested according to AS M A305. "(6)tutt welds were radiographed according to the ASME BSPV Code,Section III,1968 Editten, peregraph N624, and magnetic particle or liquid penetrant tested according to A$sE Section III, peregraph b626 or u62T.
- (T)mott!!cetion made en any mejor repairs and records molntained. **(8)secord system and traceability according to the ASME BSPV Code,Section III,1968 Edition, IX 225. ""Montrol and identification according to the ASME 88PV Code,Section III,1968 Edition, IX-226. **(10) Procedures conform to the ASME SSPV Coce,Section III, 1968 Edition, II-300. "(11) Inspection personnet ere petified according to the ASME BSPV Code,Section III, 1968 Edition, IX-400. (kPED-A61-052, Comment 10)
T3.2 Revision 21 - 04/94
i
?, -
UFSAR/DAEC-1 Tabts 3.2-1 3 9AEC Classificction of Components in Systems 4
- ra===nts i ~'
Sys#/Compf Comments =
XVIII I 1 U g rocessed ti pid radioactive weste piping and e p ipment pressure ports instetted prior to January 1, 1933, were ctessified as euelity Grote C.
Ugrocessed tipid radioactive weste piping and epigment pressure ports instelled r i: ,-t to January 1, ige 3, may be included in euelity Gro, D with added petity control (D+eA) in accordance with tNr desip guldence contained in segulatory culde 1.143, gewision 1, modified as follows:
"(1)Peregraphs C.1.1.3, C.2.1.3, and C.3.1.3 - The cemettment is Limited to the seismic design methods used in the orfsinet construction of the DAEC and is not greraded to segulatory Guide 1.143, gewision 1, regirements. "(2)Peregraph C.4.3 - Systems will be fabricated in accordance ,
with good operability, maintenance, and repetrability practices. "(3)Peregraph C.6 - Att of peregraph C.6 is reptoced in its entirety by the following sentence. "Att safety rotated systems er portions of systems shett be designed, fabricated and instetted in accordance with euelity Level II re yfrements."
l NVIII 4. 1 Unprocessed liquid radioactive weste piping and equipsont pressure ports instetted prior to January 1,1933, were classified as Quality Grom C.
j Ugrocessed liquid radioactive weste piping and epipment pressure ports instetted edeequent to January 1, Igg 3, may be included in Ouelity Group D with added petity control (D+en) in accordance with the design guidance centeined in segulatory culde 1.143, gewision 1, modified as follows: ,
"(1)Peregraphs C.1.1.3, C.2.1.3, and C.3.1.3 - The conneitment is limited to the seismic design methods used in the original construction of the DAEC and is not wrgraded to segulatory guide 1.143, gewision 1, requirements. "(2)Peregraph C.4.3 Systems will be fabrirsted in accordance with good operability, maintenance, and repairability practices. " (3)Peregraph C.6 - Att of peregraph C.6 is reptoced in its entirety by the ,
, following sentence. "Att safety reteted systems or portions of systems shett he designed, fabricated and instetted in accordance with cuetity l
i XXIII N Levet II requirements."
- 3. 1 The construction codes used for Offees pipe, ptmps, and velves were USAS 331.T; ASME Sections III and VIII; and the Draf t Ptap and Valve Code. To
~p t
identify the correct code for a component it is necessery to resserch the receiving inspection files (File 02.321). There are two reasons that
~
, several codes and detes were applied. The first reason is that the Offges desi p was changed during Procurement / Construction. The second reason
] is that the codes were changing rapidly during the period of the design. The project correspondence which records edien the Offges system
] construction code was changed is given in APED-g62-076. '
s XXIII 4. 1 The construction codes used for offges pipe, pumps, and vetves were usAs g31.T; ASME Sections III and VIII; and the Draf t Pts, and valve Co&. To j identify the correct code for a component it is necessary to research the receiving inspection files (File e2.321). There are two reasons that 6 4 severet codes and detes were applied. The first reason is that the Offges design was changed during Procurement / Construction. The second reeson l Is that the codes were changing rapidly during the period of the design. The project correspondence editch records ideen the offges system i construction code was changed is given in APED-g62-376. ,
I XXIII 5. 1 The construction codes used for Offees pipe, pumps, and volves were USAS 331.7; ASME Sections III and VIII; and the Draf t Pimp and Valve Code. To ,
identify the correct code for a component it is necessery to resserch the receiving inspection flies (File 02.321). There are two reesens that j i severet codes and detes were applied. The first reason is that the Offges desipi was changed during Procurement / construction. The second reason ;
is that the codes were changing rapidly & ring the period of the design. The project correspondence editch records edien the Offges system !
construction code was changed is given in APES-g62-gT6. '
i RMIII 6. 1 The construction codes used for Offges pipe, pumps, and velves were USAS 331.T; ASME Sections III and VIII; and the Draf t Pimp and Velve Code. Io !
, identify the correct code for a component it is necessory to resserch the receiving inspection files (File 02.321). There are two reasons that ,
several codes and detes were opplied. The first ressen is thet the Offges design esos changed & ring Procurement / Construction. The second reason t
! is that the codes were changing rapidly & ring the period of the design. The project correspondence editch records edien the Offges system t j construction code was changed is given in APED-g62-376. '
) XXIV 1. 1 Emergency service us&r system meets the pressure integrity regirements of Gustity Grote D, including the additionet quality assurance l l
requirements for "criticet" piping, as stated in section 17.1.g.1. ALL inspection records will be retained according to the eustity Assurance .
Program of Chapter IT. These records include date pertaining to the quotificetten procechares and enemination results.
j XXXIII 1. 1 For Mein Steam and Turfsine gypass piping and volves, ett inspection records were retelned according to the eustity Assurance Program of Chapter ;
i 17. These records Iry.tude date pertaining to the cysetificetten of inspection persarmet, esamination proceshares, and emaninetion results. l j XXXIII 1. 2 Turbine stop, Control, and gypese Velves: A certification was obtained from the venders of these volves Indicating that ett cast pressure-retaining parts of a site and configuration for uhich votametric esamination methods are effective have been esamined by radiographic .
methods by quotified personnet. Uttrosonic esamination to esysivetent standards are used as an etternettve to radiographic methods. f
. XXXIII 1. 3 The main steam piping between the outermost containment leetetten volves ip to the turbine step velves, the main turbine bypass piping up to the !
I turbine hypees volves and ett branch IIne carmacted to these pertlens of the emin steen and turt Ine bypees piping up to the first vetve capable of I timely actuation are eteesified so gustity groep e and meet the additlenet epselity oneurance respairements for "criticet" piping, as stated in ,
Section 17.1.8.1, Schechste IV.
! XXXIII 1. 4 The first velve capable of timely actuatica in branch lines cormected to the main steam lines between the outermost containment isolation vetves ;
and turbine step volves and corwoocted to the turbine hypees volves meets ett of the pressure integrity respairements of euelity Group g, including +
- _ - - the additlenet apselity assurance rosystrements for "criticet" piping, as stated in section 17.1.8.1, schestate IV.
- 'i- I Sep.. t. et ts e auct4 g l.n
' *d _
i 6n eg.,rst wat M .2-20 Isscc rum.t et.;I, = _
eu a % = u g yd
,,g ,go,gg - 04/94 l
UFSAR/DAEC-1 Tabte 3.2-1 ,
DAEC Clasalficction cf Components in Systems Comuments .
Sys#/Compf Comuments
- XXXill ~I~ 5 All inspection records for the mein steem and turbine bypees piping and the first velve in the branch lines comected to this piping were retained eccording to the sumitty Assurance Program of Chapter 17. These records include data pertaining to the quellfication of inspection persomet, examinetton procedures, and examination results.
XXXIII 4. 1 Meteriets used in feeduster control velves are as follows: **(1) Valve body is ASTM A105 Gr. II. **(2)velve bonnet is ASTM A105 Gr. It and A234 Gr. WPs.
XXXIII 4 2 Emaninetion and testing requirements for the feedseter control valves are se follows: **(1)Att pressure retaining castings are radiographed, after finst heet treatment, in accordance with the ASME BSPV Code,Section III, Appendix IX, paragraph 330 and ASTM E142. Discontinuities are judged by ASTM ET1, E196, and E280. **(2)Att accessible surfaces of att pressure retalning castings are examined in finished condition, efter finet heet treeteent, by either Llauld penetrant methods per peregrech N323.4 or magnetic particle methode per paragraph N323.3, with acceptance criterie per peregraph N323.4 of the Stammer 1969 eddende to ASME Section III. **(3)Att pressure retaining forgings are emanined in the es-furnished condition by the ultrasonic method per peregraph N322 of the Summer 1969 Addends to ASME,Section III.
XXXIV 1. 1 The condensate storage tank wee designed, fabricated, and tested to meet the Intent of API Standard 650. In addition, the specifications for this tank require (1) 100% surface emaninetton cf the side watt to bottom joint and (2) 100% volumetric examinetton of the side watt weld joints.
xxxlv 1. 2 Page T3.2-5 of the UFSAR (Ref. 233) says that the CST is non-seismic.
GENERAL 1 331.1.0 and 331.7 were originetty pietished es USA Standards (USAS), but are now designated as ANSI Standards.
GENERAL 2 Se additionet meteriet eneminetton requirements of Section 17.1.8.1 for piping and velves.
j GENERAL 3 code ef fective date is obtained by the Purchese order date for the perticular component (see Table 3.2-1) or by referring to Table 3.2-2.
tyv 7(e. k ;ff 4e /,_ fpk 4 coyesc/ a o[ 22x V4o VAc. su 'S s h w.<. y 2%.
W 4L /*a/ c.z., /-c s,- a,.,ef R th &C- MorS.- C. =-r 8-d ('. < r k .r , ~7%<' .
l
b'O*1 &- At<. Ca,, /, A few ~ S)"#& M2e) s 'r -s o & " A. ~-r L <
d*v / -
-el C ,. ^%:Ca7 A c. A~ fysk , a ,g 4o J p~adm
- 'Yb/p k4% /J ~ 7 gpy.e ,r.c A,, c&ss.u ,o-~ ~-
'~ 9 w - e, ,c wp-s ,y n. u a
,,,,,.,c 4 ,,;,,w a ,c,.,
b> Ay / A~y d e- 4 4 77 T3.2-21 Revision 11 - 04/94 l
1 UFSAR/DAEC-1 i -
~'
4 TeMe 3.2-2 Sheet 1 of 2 CLASSIFICATION AND CODE COMPLIANCE REQUIREMENTS 1
For tems which do not have a specNic construction code usted in Table 3.2-1, the foGowing codes, including their addende and applicable code cases, ki e#ect at the Ilme of component purchase order date, have been appAnd. In case of a conAlct between this table and Table 3'2-1. Table 3.2-1 shed govern.
Safety Class (SC) Components Ordered on or Ousity Grg Components Ordered or AfterJan.1,1970 Components Ordered on na**% Components M Before Jan.1,1970 and before July 1,1971 or AAerJuly 1,1971 1
SC-1 Vessels ASME Secelon IN,' lie Ed., ASME Section lit,'68 Ed., ASME Section N1,71 Ed.,
Group A Classes A,C; Class A Class I; '
a P%dng USAS B31.1.0;M# USAS B.31.7, Class 1;MMM NASNBst % ;N I Pumps M & valvesM USAS B31.1.0;M# ASME NP&VC Class 1;M Heat suchen0ers TEMA Codo# TEMA Code # TEMA Code #
SC-2 Vessels ASME Secelon IN,'80 Ed., ASME Section IX,'ee Ed., ' ASME Section III,71 Ed.,
! Group B Classes B,C;# Classes B C;# rhee== MC# or2; I , Piping USAS B31.1.0;M# USAS B31.7, Class N;MM# NA&NC subsections; I
PumpsM & Velves M USAS B31.1.0;M# NP&VC Classlil;M -
Heat exchangers TEMA Code;# TEMA Code # 'TEMA Code #
Tanks # # #
l SC-3 Vessels ASSE Secelon Vill,'118 Ed., ASME Secdon Vill,' Ele Ed., ASSE Section Ill '71 Ed.,
Group C Div.1; Div.1; Class 3; P5ing USAS B31.1.0;M# USAS B31.7, ClasslilMM FA&@ =W; Pumps M & valvesM USAS B31.1.0M# NP&VC ClassIll;M I
Heat Exchangers TEMACode# TEMA Code # 'TEMA Code #
Tanks # # #
1 I
Power Plant Vessels ASME Secelon VNI,'88 Ed., ASME Section VNI, *EIS Ed., ASME Section Vill,71 Ed.,
(piping systems) Div.1; Div.1; Div.1; Group D P4dng
- USAS B31.1.0;M# USAS B31.1.0;M# USAS B31.1.0MM PumpsM & volvesM USAS 831.1.0;M# USAS B31.1.0;M# USAS B31.1.0M#
Heat exchangers TEMA Code # TEMA Code # TEMA Code #
Tanks # # #
Note: Footnotes onlogowing page.
T3.2-22 Dowlainn 11 - nd/QA l
- - - _ - - ----. _ _ - _ _ - _ __. ___ _ __, .~. _ ___ . _ - - - - - _ - - - _ _ _ . _ _ - - - - _ _ _ - _ _ _ -______ - - - _____ - - ______ -
UFSAR/DABC-1
^
Table 3.2-2 Shoot 2 of 2
<mwlCADON AND CODE COMPUANCE REQUIREMENTS l a USAS B31.1.0-1967 plus appEcable code r==a= Requirements of ANSI Nudear Code Cases N-2, N-7. N-9, and N-10 are appucable for Group j A (RCPB) components ordered before January 1,1970.
b USAS B31.7-1969 plus appucable code cases f
For dotated piping / equipment r4maniaratinn, refer to Table 3.2-1.
d
! Components required to be stamped to Section lit of the ASME B&PV Code are stamped wth the applicable ASME Code symbol, and the l required Bilniparty k= par *=i was performed by an authortred Inspector. .
- For pump designs, the appNcable dass, section, or admarting of the referenced ASME B&PV Code is used as a guide in cairsamamg the thickness of pressure 4 staining poreans of the pump and in sinng cover bdung. For example, use ASME Secdon M. Class C for Group A&B pasnp design guide. For Group D below 150 poig and/or 212*F. Marshner's Standard pump for service intended may be used.
4 8 Tubader Exchanger Manufacturer's Aaeacimalan (TEMA) Code ^4 ._.^ were applied using ri===== appropdate to each heat exchanger's dtsy cyde. _
8 nss-se-6 (rsss-se-ss)
- y forvelwas (. _^ ^ T : Z - iS64 was wthdrawn kom pede= Man in favor of ANSI B16.34-1973).
ANSIB16.5 , U__ __ -
i h
_ \J 1
% 1 ruh Wh h 194 d w the W of M B&PV Code W M.M N-153 for stamping and thkd-party inspecdon.
Metal coraminmera veessi and penetradons (extensions of w " _ __ ^.) are ASME, Secdon M, stamped Qass B or MC (memmenne NA&NE),
j and Bio required thidparty inspection shmE be performed by an andhortred trispartar.
j l Exisdng APVAWWA standards and supplementary rW _.a apply. Tanks are to be designed,imbriemand, constructed, and tested to most the keert of API Standants 620 (Recommended Roles for Deelyn and Constmcdon of Large Wakled Low Pressure Storage Tanks) or of 0 (Weided Steel Tanks for 05 Storage) or AWWA Standard D100 (standard for steel tanks, stand pipes, reservoirs, and elsweled tanks for
- water stomos) for these fuel, ot, or water storage tanks.
ANSI B31. Code Case 78 applies for B31.7 Class I and Qass li pipe and Meings 3/4 inch nominal pipe size and smeBer.
8
- , These codes were odginagy published as USA Standards (USAS), tus are now designa'ad as ANSI Standards.
{ ASME Code for Pumps and Velves for Nuclear Power (or Nuclear Pump and Valve Code).' This was incorporated into ASME Section til after j the constriareinriof DAEC.
i
, T3.2-23 Revision 11 - 04/94 l
_ _ _ _ _ _ _ _ _ _ _ . - _ - _ _ _ _ _ _ _ _ _ _ _ _ - 1 _ _ _ _ _ _ _ _-- _ _ , , . , - - - - _ - _ _ _ _ , _ _ _ _ _ _ -
___ __.____ _ _ _ e-_ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _