ML20113H703

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Change Notice 92-03 to Operating QA Manual,Rev 15,App a Re Regulatory Guide 1.37 Paragraph C.4
ML20113H703
Person / Time
Site: Callaway Ameren icon.png
Issue date: 06/30/1992
From:
UNION ELECTRIC CO.
To:
Shared Package
ML20113H700 List:
References
RTR-REGGD-01.037, RTR-REGGD-1.037 NUDOCS 9208050190
Download: ML20113H703 (3)


Text

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OQAM QAt C N '77 - v 2-APPENDIX A l

REGULATORY GUIDE 1.37 (cont.)  :

be allowed where such elements are leachable or where they could i

be released by breakdown of the compounds under expected onviron- l mental conditions, except as provided for in approved design j documents. No-more-than-1500-ppm-sulfur-shal-1 be- allowed-where )

such--elements - ara-leachable -or where -they could-be- released--by beeakdown- of -the-compourida under-expected environmental- condi- ]

tions -except-r as provided- tor-i 9-approved-deM.gm documents. l With regard to Section 5 of A28SI N45.2.1 - 1973 titled Installs-tion Cleanina: The recommendation that local rusting on corrosion resistant alloys be remcVed by mechanical methods is interpreted to mean that local rusting may be removeJ mechanically, but the use of other removal means is not precluded, as determined by 3 engineering or Chemistry. Engineering actions performed in accor- >

dance with this Section of the Standard are conducted with QA/OC involvement ano are subject to OA audit. Procedures for these activition receive a cross-disciplinary review as well as review by the Onsite Review Committee (QA is a permanent member of this committee). For other activities, QA audits and surveillances, and QC inspection activities assure QA/QC involvement.

REGULATORY GUIDE 1. 38 REVISiQH_2 DATED 5/77 Quality Assurance Requirements for Packaging, Shipping, Receiv-ing, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants (Endorses ANSI N45.2.2-1972)

DISCUSSION:

UE complies with the recommendations of this Regulatory Guide with the following clarLfications:

With regard to Section 1.4 of ANSI N45.2.2 - 1972 titled Defini-tions: Definitions in this Standard which are not included in ANSI N45.2.10 shall be used; definitions which are included in ANSI N45.2.10 shall be used as clarified in UE's commitment to Regulatory Guide 1.74.

With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Plann-the ing: (First sentence) The specific items to be governed be identified in Callaway-SP FSAR Table by 3.2-1, Standard shall which lists those structures, systems and components to which the UE QA Program is applied.

With regard to Section 2.3 of ANSI N45.2.2 - 1972 titled Results:

The specific methods for performing and documenting tests and inspections are given in OQAM Sections 10 and 11. The require-ments in these Sections shall be implemented in lieu of the general requirements here. In every case either identical or equivalent controls are provided in the sections of the refer-i enced Standards or documents.

l A-13 Rev. 15 l 6/92 9209050190 920728 PDR ADOCK 05000483 p PDR l

l - OQAM l APPENDIX A Q )/t (N /[J -6 4

gEGULATORY GUIDE 1.37 (cont.i be allowed where such elements are leachable or where they cotild be released by breakdown of the compounds under expected environ-

  1. mental conditions,--exceph eps,provided for in approved- design documenta. /No more than 4b ppm sulfur shall be allowed where')

/such ' elements are leachable or where they could be released by  ;

/bieakdown of the compounds under expected environmental condi tions, except as provided for in approved design documents. j (v With u ~.~~~n.~~

regard to Section 5 of ANSI N45.2.1 - 1973 titled Installa-

~~ ^ -

' ' ~

tion cleanina: The recommendation that local rusting on corrosion resistant alloys be removed by mechanical methods is interpreted to mean e. hat local rusting may be removed mechanically, but the use of other removal means is not precluded, as determined by engineering or Chemistry. Engineering actions performed in accor- r dance with this Section of the Standard are conducted with QA/QC involvement and are subject to QA audit. Procedures for these activities receive a cross-disciplinary review as well as review by the Onsite Review Committee (QA is a permanent member of this committee). For other activities, QA audits and surveillances, and QC inspection activities assure QA/QC involvement.

REGULATORY GUIDE 1 11 REVISION 2 DATED 5/77 Quality Assurance Requirements for Packaging, Shipping, Receiv-ing, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants (Endorses ANSI N45.2.2-1972)

DISCUSSION:

UE complies with tne recommendations of this Regulatory Guide with the following clarifications:

With regard to Section 1.4 of ANSI N45.2.2 - 1972 titled Qgfini- -

tions: Definitions in this Standard which are not included in ANSI N45.2.10 shall be used; definitions which are include 6 in ANSI N45.2.10 shall be used as clarified in UE's commitment to Regulatory Guide 1.74.

With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Plann-ing: (First sentence) The specific items to be. governed by the Standard shall be identified in Callaway-SP FSAR Table 3.2-1.

which lists those structures, systems and components to which the UE QA Program is applied.

With regard to Section 2.3 of ANSI N45.2.2 - 1972 titled Results:

The specific methods for performing and documenting tests and inspections are given in OQAM Sections 10 and 11. The require-ments in these Sections shall be implemented in lieu of the general requirements here. In every case either identical or equivalent controls are provided in the sections of the refer-enced Standards or documents.

A-13 Rev. 15 6/92

4 Attachment 3__to ULNRC-2665 Page 1 July 28, 1992 The following information is provided as a basis for the requested change in OQAM CN 92-03.

Sulfur or its compounds are often trace elements in the types of materials addressed by Reg. Guide 1.37 and other regulatory guides. Based on analyses by our plant architect / engineer, documented in design and installation specifications, an upper limit of 1000 ppm sulfur is acceptable for general applications with stainless steel and nickel-base alloys. Applications for amounts greater than 1000 ppm may be acceptable but will require specific engineering evaluation and approval prior to use.

Identifying-these-limits in our R.G. 1.37 commitments provides a central reference for procurement and application information.

The requested limit is consistent with EPRI Report NP-4449

" Guidelines for Control of Expendable Products" which recommends a limit of 1000 ppm total sulfur content in expendable materials used on stainless steel or nickel alloy.

In: addition, during.the. construction _ phase, the plant Larchitect/ engineer established specification limits for sulfur and other contaminants in' expendable materials ~for use on ASME Section III stainless steel piping. These limits are currently endorsed by the OQAM in the Appendix A commitment to Reg.

Guide 1.37 as described below: ,

" Technical requirements associated with maintenance and-

- modifications shall be equal to or better than.the original requirements (e.g., code requirements,

- material properties, design margins, manufacturing processes, and inspection. requirements), or as required to preclude repetition of defects."

._. ,