ML20137Z950
| ML20137Z950 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/06/1985 |
| From: | Jamila Perry NIAGARA MOHAWK POWER CORP. |
| To: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| RTR-REGGD-01.037, RTR-REGGD-01.094, RTR-REGGD-1.037, RTR-REGGD-1.094 NUDOCS 8512110455 | |
| Download: ML20137Z950 (13) | |
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lA N3M NIAGARA MOHAWK POWER CORPORATION /300 ERIE BOULEVARD WEST. SYRACUSE, N.Y.13202/ TELEPHONE (315) 474-1511 December 6, 1985 Mr. Brian K. Grimes, Director Division of Quality Assurance Vendor Technical Training Center Programs Office of' Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Quality Assurance Topical Report, NMPC-QATR-1
Dear Mr. Grimes:
I discussed with Messrs. J. Gilray and J.
Milhoan by telephone, week ending November 22, 1985, the desirability of taking certain
' exceptions to the Niagara Mohawk commitment to NQA-2 in subject topical report.
I have changed the commitment in the subject report regarding Parts 2.1 and 2.5 of NQA-2.
Niagara Mohawk commits to Regulatory Guides 1.37 and 1.94 and daughter standards ANSI N45.2.1 and ANSI N45.2.5 in lieu of Parts 2.1 and 2.5 of NQA-2.
These commitments are reflected on the attached Appendices and are now consistent with the present commitments identified in the FSAR for NMP-2.
The attached Appendices, Rev. 1 Proposed, include not only the changes related to Parts 2.1 and 2.5 of NQA-2 but also the changes provided in my correspondence to you dated November 20, 1985.
We appreciate your prompt review of the subject document.
Should you have any questions, do not hesitate to notify us.
Sincerely, jsud $ '
ames A.
Perry DJrector of Quality Assurance JAP /ams Attachments Distribution: see attached 0512110455 851206 PDH ADOCK 05000410 jk A
'g e
a:
B.K. Grimes Attachment December 6, 1985 Distribution:
G.T. Ankrum
- U.S. NRC Dr. P. Eapen
- U.S. NRC Region I R.A. Gramm
- U.S. NRC Sr. Resident Inspector J.W. Gilray
- U.S. NRC S. Hudson
- U.S. NRC Sr. Resident Inspector T.E.
Lempges
- NMPC C.V. Mangan
- NMPC R.J.
Pasternak - NMPC T.J.
Perkins
- NMPC G.D. Wilson
- NMPC A.F.
Zallnick
- NMPC W.M.
Bryant
- NMPC W.A. Hansen
- NMPC C.E. Hjort
- NMPC J. Kroehler
- NMPC 4"
NMPC-QATR-1 R:v. 1 Proposed APPENDIX A REGULATORY COMMITMENTS Niagara Mohawk Power Corporation commits to the requirements of the regulations and-industry standards identified in Appendix A subject to the stated interpretations and exceptions in Appendix 8.
REVISION /
DOCUMENT DATE TITLE 1.
10CFR50 Appendix 8 Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
2.
Reg. Guide 1.28 1985 R3 Quality Assurance Program Requirements (Design and Construction) - (Endorses ANSI /ANS NQA-1).
3.
ANSI /ANS-3.2 1982 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.
4.
ANSI /ASME NQA-1 1983 including Quality Assurance Program 83 Addenda Requirements for Nuclear Facilities.
5.
ANSI /ASME NQA-2 1983 Quality Assurance Requirements for Nuclear Power Plants.
6.
Reg. Guide 1.37 1973 RO Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants. (endorses ANSI N45.2.1) 7.
ANSI N45.2.1 1973 Cleaning of Fluid Systems and Associated Components t
During Construction Phase of Nuclear Power Plants 8.
ANSI N45.2.4/
1972/1971 Installation, Inspection IEEE 336 and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations.
A-1
-. =
MMPC-QATR-1 R;v.1 Proposed 9.
Reg. Guide 1.94 1976 R1 Quality Assurance Requirements for Installation,-Inspection, and Testing of Structural Concrete and Structural Steel Ouring the Construction Phase of Nuclear Power Plants. (endorses ANSI N45.2.5)
- 10. ANSI N45.2.5 1974 Supplementary QA Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants.
'f f
A-2 l
l
3 J
s NMPC-QATR-1 Rev. 1 Proposed
' APPENDIX B t
INTERPRETATIONS AND EXCEPTIONS OF APPENDIX A DOCUMENTS I
DOCUMENT INTERPRETATION / EXCEPTION
- 1. 10CFR50 Appendix B None
- 2. Reg. Guide 1.28 a.
Introduction Reautrement - This regulatory guide applies to design and construction of nuclear power plants. Guidance for operations phase QA programs will be addressed in separate regulatory guides.
Interpretation - ANSI /ASME NQA-1 is inclc ad by reference in ANSI /ANS-3.2, e
whitt applies to operations phase QA programs.
Therefore, Niagara Mohawk is committing to ANSI /ASME NQA-1 for operations phase activities, b.
Para. 3.1 Recuirement - Applicable elements of an organization's QA Program should be audited at least annually...
Exception - During the operations phase, applicable elements of the QA program will be audited at least once every two years, j,
in accordance with ANSI /ANS-3.2.
- 3. ANSI /ANS-3.2 a.
General Reauirement - ANSI /ASME NQA-1-1979 is referenced throughout ANSI /ANS-3.2.
Exception - NMPC is committed to ANSI /ASME NQA-1-1983 including 1983 addenda, 1
b.
Pa ra. 1.1 Reauirement - This paragraph refers to
...all activities affecting those functions important to safety..."
ExceDtion - NMPC is committed to a program based on controls applied to safety-related
, systems, components and services.
[
B-1 A
i
)
NMPC-QATR-1 R3v. 1 Proposed c.
Para. 3.4.2 Reauirement - This paragraph establishes requirements for the qualifications of the Onsite Operations organization.
Implementation - In lieu of these controls 0
NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.
d.
Para. 4.0 Reauirement - These paragraphs establish requirements for reviews and audits.
Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs, the related technical specifications and Section 18.0 of this Topical Report.
e.
Section 5 Reauirement - Reference is made within this General section to Appendix for typical activities which should be covered by written procedures.
Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specificatiens.
f.
Para. 5.2.1.6 Reauirement - This section provides rules for the maximum number of hours at a duty station.
Imolementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications, g.
Para. 5.2.2 Reauirement - Portions of this paragraph specify approvals for temporary procedure changes.
Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.
l B-2
NMPC-QATR-1 Rev. 1 Proposed h.
Para. 5.2.7 Reauirement - These paragraphs require the Para. 5.2.16 use of ANSI /IEEE-336-1980.
Imolementation - Appendix A of this Topical,
Report commits to ANSI /IEEE-336-1971.
i.
Para. 5.'2.8 Reauirement - A surveillance testing and inspection program... shall include the establishment of a master surveillance schedule reflecting the status of all planned inplant surveillance tests and inspections.
Interoretation - Independent master schedules may exist for different programs such as in-service inspection (ISI), pump and valve testing, and Technical Specification surveillance testing.
Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and.2 FSARs and the related technical specifications.
j. - Para. 5.2.9 Recuirement - Procedures shall be developed to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.
Implementation - This item is addressed in 4
the Security Plan.
k.
Para. 5.2.13.2 Reauirement - Where requirci by law, regulation or contract requirements, documentary evidence that itqms conform to procurement requirements shali,be available at the nuclear power plant site prior to installation or use of such items.
Interpretation - NMPC requires that the required documentary evidence be available at the site prior to use, but not necessarily prior to installation.
This allows installation to proceed under specified conditions while any missing documents are being obtained, but precludes dependence on the item for safety purposes.
B-3 1
NMPC-QATR-1 Rev. 1 Proposed 1.
Para. 5.2.7 Reauirement - These paragraphs refer to Para. 5.2.10 ANSI /ASME N45.2.5-1978, ANSI N45.2.8-?975, Para. 5.2.13.4 ANSI /ASME N45.2.1-1980 and ANSI /ASME N45.2.2-1978.
Exception - NMPC is committed to ANSI /ASME
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NQA-2-1983 for major modifications.
m.
Para. 5.2.7 Reauirement - This paragraph refers to ANSI /ASME 03843-80.
Exception - In lieu of this referenced standard, NMPC will comply with the protective coating controls described in applicable sections of the Nine Mile Point Units 1 and 2 FSARs.
i n.
Pa ra. 5.2.15 Reauirement - This paragraph establishes administrative controls for the review, approval and control of procedures.
Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.
o.
Para. 5.2.16 Reauirement - Records shall be made and equipment suitably marked to indicate calibration status.
ExceDtion - In some instances size or locations of installed plant instrumentation precludes attaching calibration labels directly on the instrument.
In such cases, the label may be placed adjacent to the instrument or the instrument shall be uniquely identified and traceable to its calibration records.
(See item 3h) p.
Para. 5.3 Reauirement - This paragraph establishes administrative controls for written procedures.
Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.
B-4
NMPC-QATR-1 Rev.1 Proposed q.
Para. 5.3.9.3 Reauirement - This paragraph suggests ANSI /ANS 3.7.1-1979, ANSI /ASME 3.7.2 and ANSI /ANS 3.7.3-1979 for additional guidance in preparation of Emergency Plan Implementing Procedures.
O
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Exception - In lieu of ANSI /ANS 3.7.1,
.2, and.3 described in ANSI /ANS 3.2, NMPC will comply with the emergency preparedness controls described in applicable sections of the Nine Nile Point Units 1 and 2 FSARs.
- 4. ANSI /ASME NQA-1 a.
Supplement 2S-2 Reauirement - The American Society of Nondestructive Testing Recommended Practice No. SNT-TC-1A, June 1975 Edition and its applicable supplements shall apply as requirements to NOE personnel covered by this Supplement.
Exception - NMPC is committed to ASNT Recommended Practice No. SNT-TC-1A, June 1980 and its applicable supplements, b.
Supplement 2S-3 Reauirement - Personnel who participate in quality assurance program audits shall be qualified in accordance with ANSI /ASNE NQA-1 supplement 2S-3.
Exception - Personnel who perform audits for the Safety Review and Audit Board (SRAB) are not required to be so qualified.
c.
Supplement 4S-1 Reauirement - Reviews (of procurement Section 3 documents) shall be performed and documented... prior to contract award.
Exception - Documents may be released for bid or contract award before completing the necessary reviews. However, these reviews are completed before the item or service is relied on for its safety-related function, or before work has progressed to the point where it would be impractical to reverse the action taken.
d.
Supplement 7S-1
. Pa ra. 8.1 Reauirement - Where required by code, regulation or contract requirement, documentary evidence that items conform to procurement document requirements shall be available at the nuclear facility site prior to installation or use.
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NMPC-QATR-1 Rev. 1 Proposed Interpretation - NMPC requires that the required documentary evidence be available at the site prior to use, but not necessarily prior to installation.
This allows installation to proceed under specified conditions while any missing documents are being obtained, but precludes dependence on the item for safety purposes.
e.
Supplement 7S-1 Para. 8.2.4 Reauirement
... post-installation test requirements shall be mutually established by the purchaser and supplier.
Interpretation - In exercising its ultimate responsibility for its QA program, NMPC establishes post-installation test requirements, giving due consideration to supplier recommendations.
5.
ANSI /ASME NQA-2 a.
General Applicable parts of this standard will be applied to activities related directly to major plant modifications only (i.e. those under the direction of Nuclear Engineering).
-b.
Part 2.1 Reauirement - this section gives QA requirements for cleaning of fluid systems and associated components.
Exception - NMPC is committed to Reg. Guide
~ #
1.37 (see Appendix A item 6) c.
Part 2.5 Reauirement - this section gives QA requirements for installation, inspection and testing of structural concrete, structural steel, soils and foundations.
ExceDtion - NMPC is committed to Reg. Guide 1.94 (see Appendix A item 8)
I c.
Part 2.15 Reauirement - This section gives QA requirements for hoisting, rigging and transportation of items for nuclear power plants.
Exception - NMPC is committed to the requirements of applicable heavy load reports for Nine Mile Point Units 1 and 2.
B-6
NMPC-QATR-1 Rev.1 Proposed d.
Part 2.20 Reauirement - This section outlines QA requirements for subsurface investigations for nuclear power plants.
Exception - In lieu of Part 2.20 of NQA-2,
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NMPC will comply with the subsurface controls described in the applicable sections of the Nine Mile Point Units 1 and I
2 FSARs.
l 6.
General Applicable parts of this Reg. Guide will be applied to activities related directly to major plant modifications only (i.e. those under the direction of Nuclear Engineering).
b.
Para. C.3 Reauirement - The water quality for final flushes...
...shall be at least equivalent to the quality of the operating system water.
Exception - NMPC is conmiitted to the stated requirement except for the oxygen content.
c.
Para C.4 Reauirement - This paragraph gives precautions on chemical compounds that could contribute to intergranular cracking or stress corrosion cracking in austenitic stainless steel and nickel based alloys.
Exception - Expendable materials, i.e.,
inks and related products, temperature indicating sticks, tapes, gummed labels, wrapping materials (other than polyethylene),' water soluble dam materials, lubricants, NDT penetrant materials, and couplants that contact stainless steel or nickel alloy surfaces are in accordance l
with the Nine Mile Point Unit 2 FSAR position for Regulatory Guide 1.38, Revision 2.
7.
Section 3.1.2 Reautrement - this section gives the requirements for Class B cleanness.
Exception - Upgraded piping systems and components constructed of carbon steel materials will meet Class 8 cleanness requirements except for final flushing / cleaning which may exhibit rust staining in accordance with Class C cleanness requirements.
l 8-7
^
NMPC-QATR-1 Rev. 1 Proposed b.
Section 3.2 Reauirement - This section gives water quality requirements for cleaning.
Exception - Due to seasonal conditions, l
freshwater from Lake Ontario will have an l
allowable upper pH limit of 8.5.
8.
ANSI N45.2.4/IEEE-336 Applicable parts of this standard will be applied to activities related directly to major plant modifications only (i.e. those f
under the direction of Nuclear Engineering).
9.
Reg. Guide 1.94 No Exceptions
- 10. ANSI N45.2.5-1974 a.
General Applicable parts of this standard will be applied to activities related directly to major plant modificztions only (i.e. those under the direction of Nuclear Engineering).
b.
Para. 5.3 Reauirement - This paragraph gives the requirements for assembly and erection.
Exception - Bolt holes generally will not be burned (oxygen cut).
If holes must be burned, the following criteria will be followed: a) after cutting, the edges of the cut will be ground or reamed back a minimum of 1/32 in., and b) the final bolt hole dimensions will not' exceed those given in the Specification for Structural Joints Using ASTM A325 or A490 bolts.
c.
Para. 5.4 Reauirement - This paragraph establishes the criterion for determining correct bolt length as at least two threads extending beyond the face of the nut.
Exception - For NMPC the criterion established for correct bolt length is one thread extending beyond the face of the nut, d.
Para. 5.5 Reauirement - This paragraph gives requirements for welding inspertion.
Exception - All reinforcing bar splices made by arc welding, except those splices welded to metal embedments, will be selected on a random basis for radiography and inspected in accordance with AWS 012.1.
Splices welded to metal embedments will be inspected in accordance with AWS 12.1.
{
B-8
NMPC-QATR-1 Rev. 1 Proposed e.
Para. 6.2.2 Reauirement - This paragraph gives the requirements for evaluating mechanical (Cadweld) splice test results.
7 ExceDtion - Exceptions regarding mechanical splicing of safety-related reinforcing bars are in accordance with the Nine Mile Point Unit 2 FSAR position for Regulatory Guide 1.10.
f 9
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