ML20151B588

Forwards Proposed Changes to Updated Fsar,App B Involving Reduction of Commitments in QA Program Description. Equivalent QA Controls Provided to Satisfy 10CFR50,App B Criteria.Reasons for Change Included

ML20151B588
Person / Time
Site:	Fort Saint Vrain
Issue date:	03/29/1988
From:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
P-88078, NUDOCS 8804110034
Download: ML20151B588 (11)

Text

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i 0 Public Service-

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" dr7cIso20two o.n RO WILLIAMS, JR.

March 29, 1988 vct PRESCENT N' man acus Fort St. Vrain

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Unit No. 1 P-88078 U. S. Nuclear Regulatory Commission ATTN:

Document Control Oesk Washington, D.C.

20555 Docket No. 50-267

SUBJECT:

Fort St.

Vrain Updated FSAR, Appendix B, 10CFR50.54 Submittal Gentlemen:

Enclosed are proposed changes to Updated Final Safety Analysis Report, Appendix B, which Public Service Company of Colorado (PSC) has deterrined to involve a reduction in comitments in the FSV Quality Assurance Program description and, in accordance with 10CFR50.54(a)(3),

require NRC approval prior to implementation.

PSC has evaluated these proposed changes and has determined that equivalent quality assurance controls are provided to satisfy the criteria of 10CFR50 Appendix B.

The reasons for change and basis for our conclusions are also included.

PSC is withholding these changes from Appendix B pending NRC approval.

If you have any questions regarding this submittal, please contact Mr. M. H. Holnes at (303) 480-6960.

Very truly yours, hllk dan l R. O. Williams, Jr.

Vice President Nuclear Operations R0W/KFM:bre Enclosure W

nrug8u mane t i P

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O P-88078 March 29, 1988 i

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Rejional Administrator, Region IV A T N : Mr. T. F. Westerman, Chief Projects Section B Mr. R. E. Farrell i

Senior Resident Inspector Fort St. Vrain i

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UPDATED FSAR hpossh Revision %

E.5 n l

t Where certifications are not available, two concrete test I

cylincers representing the first and last one-third of truck mixer contents shall be taken for evaluation of the mixer j

truck, over and above the normal concrete cylinders taken to evaluate the in place concrete.

The concrete batch plant facility shall be inspected to assure that appropriate controls are being exercised with reference to the inspection guidelines set forth by Section 4.3(1) and (2).

1 Preolacement Preparation (Section 4.t.)

Inspection ~ of soils and earthwork will meet the general

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requirennts set forth, with th6 qualification that the extent to which individual inspection requirements are met i

will depend upon the nature and scope of the work to be pe rformed.

f In-Process Tests on Concrete and Reinforcine Steel (Section t

4.8)

Except for normal batch qualification tests (slump, air l

content, temperature and compressive strength) and initial reinforcing steel certifications, the in-process tests t

required by Table B are generally applicable to the periodic i

control which must be exercised with reference to long-term construction type programs.

The in process test requirements of Table B are not considered applicable to short-term modification work as would be required under our l

Operational QA Program.

l B.5.19.7.

ANSI N45.2.6 0 alification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants (a) Scoce and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.58 shall be applied to inspection, examination i and testing activities associated with modification work controlled I by the QA Program and accomplished during the operational phase o'

Fort St. Vrain Unit No. 1, to the extent that such activities a%

comparable in nature and degree to similar activities that occurred during the design and construction phase.

For maintenance and repair activities, it is intended that the onsite operating organization be qualified in accordance with the provisions of ANSI N18.1-1971.

Personnel performing inspection, examinations and testing activities during the op ional phase would be qualified to ANSI N18.1-1971 or y

NSI N45.2.

and QA experience for levels I, II and III should be interpreted to mean equivalent experience in construction, manufacturing, operation or installation activities.

Where codes, standards and specific design requirements are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the

FSAR, the FSAR commitments shall govern.

Later revisions of l

UPDATED FSAR j

Ftcroset Revision K6>

i B.5-39 il I

applicable codes and standarcs may be invoked specifically by the f

i design recuirements where deemed appropriate, consistent with the l

1 overall comitment to maintain the plant in an "equal to or better I

than" ori inal condition.

lD e.ETE

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(b) Soecific Exception V 1

This standar was writte rimarily for co truction

/ this respect ja attivitives,and)itiesinitsentfrety, t be applied d etly to operational achtv

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i ualifications (See 3)

The folleyi levels of cap ty for persons perfor ng ONSEC inspectjet or testing wo are consistent w )i h the reQu)/ements of the stanca but have been revised slightly j@# #

tVreflect operational c1EInditions.

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4 Level I I

To be ce stdered for certificat o, a cancidate must satisfy I

the

}4 wing requirements:

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. gh school graduate o equivalent, plus:

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One (1 of experience in qual,it assurance or engine) [) ng, design, operationJ (

maintenance, t

injpfction or testing of manufacttring, construction.

perations and installation a tfvities; OR l

2)

Demonstration of p

in the inspection discipline based o,n,pa,rpf ciencyst performance, testi g 'or job-related technica vcapabilities; AND (3)

In additi (a) or (b), successfd1 completion of the basi.,dfuality Assurance Indoct'rination Program o

i e uivalent specific trainin /

Lefel II To be considered for ertification, a cand < rate must satisfy j

ene of the following requirements:

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l (1) Graduate of a four yearjtcredited engineering or

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s f(nce college or univerfity, plus:

(a) Two (2) year perience in qualit assurance or engineerjiif, design, operat,ijos{

maintenance, i

inspection or testing o y power plants, or i

epdalent manufacturing.,senstruction, operati s

'rinstallationactiviyies;OR

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j b) One (1) year experience and demoristration of l

proficiency by4ast performance, test 1ng or job- /

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UPDATED FSAR ThefosGD 9evision E(o B.5-40 N

,s relate 44echnical capabil t 'e s.

DCLGTE

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(2) High chool gracuate, o e ivalent, plus:

2n d) Four (4) year of experience in cuat ty assurance j

or engineerd g, design, operations, maintenance,

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inspec*tinortestingofpov,edlantorecuivalentj/

ma n,u t u ri n g ',

construc) ton, installation of

,erational activitie / J4 b) Successful co w etion of the bas [c Quality y

Assurance jndctrination Program r equivalent

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specificfttaining.

Level III

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To be <f ensidered for certifJc tion, a candidate st satisfy are'of the following reogttements:

(1) Gracuate o f -g four year accrest ed engineering or j

science cpliege or universityy51us five (5) year experjenceinqualityassu,ranceorengineering, des)g11' operations, maintenance',

inspection, testing ar s1Tpervi sion thereof,/nf power plants, er etuivalent f

manufacturing, pe11gn, construction, operation or installation,a'ctivities.

At leastyt,wo (2) years of /

f this exp3rtence should be associated with nuclear f

facilyi4es; or, if not, the/ndividual shall h4ve,f

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traicing sufficient to acquaint him thoroughly witVthe

,s d e ty aspects and /tfeneral Quality f requirements of a nu p,ar facility; OR

/,n surance grI[uate,

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(2) High school or equivalent plusten(10).

years experfEnce in general qudity a s sura nceyer engi neepifig,

cesign, oper'a ti on s,

eaintenance, insjedion, testing or supefvision thereof/f power

innt, or equivalent manufacturijg,

design, t

i construction, operatA6'n or installatioVactivities. At least two (2) A ears of this should be associated wJrn nuclear f acilities,e>ifferience or, if not, the-

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i individua,V shall have trainifig suf ficient to acguafnt qu lj>foughly with the,Mafety aspects and,ffeneral him th ity assurance reg'itements of a nuclear acility.

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UPDATED FSAR Ft.pPos ED R e vi 5 4 cP E(o g L.gr Gl_ET E M

,e' Specif g Required Ca; abilities for Inspectieaf ixarination anc ) estine Pers -nel_-t5ectier 3.2) b

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Each person cejt eti toperformunderthelevelsdesige&Ied I

herein shall be physically Capable of performing the assignep/ ask and should deet the following' physical t

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recu rements:

1)

Natural or corrected near-distapce visual acuity such thattheap[cantiscapable,cfreadingJ-lletters,on sta nda rd/Ja eg e r's test t>ce chart for near vis on or equivalent test type;

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(2) tolor vision; and (3) Other medija1 requiremerts for tfA physical de? ands of performy,g tne recuirec activit.tes (such as heart and circuletory concitions).

persc+/

,nel with physical,M estrictions shall by imited to I

ei ormance of onlyj.those tasks for which they are i

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l physically capable. /

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Items (1), (2) and (3) will be mev t the time of initjaf

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certificat,tbn.

Items (1) and (2) Mil be verified at,Aeast l

annually consistent with the-fecertification requir'ements.

TheAnitial physical examijat' ion

(. tem (3)) will not be

,rtverified unless the e, t's an apparent need.

Quality As surartce Division personnet involved in non-destructive ep iination functions wi n be qualified i

t tne requiremen,ts' of SNT-TC-1A as 40'propriate.

Forworkdo

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ere the O H ivision doeswi th'/h,a v e not properly quaJefied NDE

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personnel, personnel pr qualificttiens will be cefained from outsice,sdrces. oper

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E.5.19.8.

ANSI N45.2.8 - Draft 3, Rev. 3, Apr. 1974 Supplementary Ouality Assurance Requirements for Installatten Insoection and Testine of Meenanical Equipment and s

Systems for the Construction Phase of Nuclear Power Plants

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(a) Scoce and Aeolicability This standard was written for construction efforts of nuclear plants and, as such, the requirements set forth and the feasibility, both from an economical viewpoint and a practical viewpoint, are based on the construction situation.

As such, ir;lementation of all the recuirements of this standard for operating plants, consicering the scale of plant modifications versus initial construction, 's not practicable.

The guidance provided by this standard shall be applied to installation, inspection and testing of eechanical equipment and l systems controllec by the QA Program associated with onsite

UPDATED FSAR fhcesed Revision l'6 Table B.5-4 (Page 1 of 2)

ANSI STANDARDS AND REGULATORY DOCUMENTS APPLICABLE TO FSV OPERATIONS QA PROGRAM a) Final Safety Analysis Report - Appendix B (Amendment 32) b) FSV Technical Specifications c) USNRC Quality A'surance Criteria for Nuclear Power Plants, 10CFR50, Appendix B d) WASH-1283, Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants Revision 1,

dated 5/14/74 e) WASH-1284, Guidance on Quality Assurance Requirements During the Operations Phaa of Nuclear Power Plants, dated 10/26/73 f) WASH-1309, Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Pover Plants, dated 5/10/74 g) N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants (Standard) and Regulatory Guide 1.28, June 7,

1972, h) N45.2.1-1973, Cleaning of Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plants (Standard) and Regulatory Guide 1.37, March 16, 1973.

i) N45.2.2-1972, Packaging,

Shipping, Receiving, Storage, and l

Handling of items for Nuclear Power Plants (During the Construction Phase) (Standard) and Regulatory Guide 1.38, March 16, 1973.

j) N45.2.3-1973, Housekeeping during the Construction Phase of I

Nuclear Power Plants (Standard) and Regulatory Guide 1.39, March 16, 1973.

k) N45.2.4-1972, Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Instrumentation and Electric Equipment During the Construction of Nuclear Power i

Generating Stations (Standard IEEE) and Safety Guide 30, August 11, 1972.

1) N45.2.5-1974, Supplementary Quality Assurance Requirernents for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power l

Plants (Standard) and Regulatory Guide 1.94, Rev.1, April 1976.

1 78 m) N45.2.6 91 3).

Qualifications of Inspection. Examination and Testing ersonnel for the Construction Phase of Nyclear Power Plants (Standard) and Regulatory Guide 1.58,Qg&;

Revi$10N 1,$EPTGMBE R 1.980.

Enclosuro to P-88078 1

INSERT NO. 1 (c) SPECIFl; EXCEPTIONS Quality Assurance Division personnel involved in nondestructive testing shall be qualified to the requirements of SNT-TC-1A-1975 except that the maximum recertification interval for level III personnel shall be five (5) years.

For work where the QA Division does not have qualified NDE personnel, personnel with proper qualifications will be obtained from outside sources.

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Enclosuro to P-88078 i

PAGE(S) AFFECTED B.5-38 DESCRIPTION:

Delete reference (Section B.S.19.7) to ANSI N45.2.6 1973. Add reference to ANS! N45.2.6-1978.

a B.5-38 DESCRIPTION:

Delete reference (Section B.S.19.7.a) to ANSI N45.2.6 1973. Add reference to ANSI N45.2.6-1978 Table B.5-4 DESCRIPTION: Delete reference Page 1 of 2 (m) to ANSI N45.2.6-1973 and Regulatory Guide 1.58, August 1973.

Add reference to ANSI N45.2.6-1978 and Regulatory Guide 1.58, Revision 1. September 1980.

B.5-39, B.5-40 and B.5-41 DESCRIPTION: Delete this f

(Section B.S.19.7.b) section in its entirety.

REASON:

These changes will 5

allow update of the Ouality Assurance Division Inspector Certification Program to the requirements of the most recent documents approved by the NRC. The 1978 edition of ANSI N45.2.6 also gives credit I

for experience gained on the job,i.e., certification time as Level I

fulfilling experience requirements for Level II and certification 4

based on demonstration of proficiency when experience falls short of the requirements.

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4 Enclosure to P-88078 I

f PAGE(S) AFFECTED JUSTIFICATION:

Although the education and experience requirements of the 1978 edition of ANSI N45.2.6 are less than the 1973 edition and could be construed as a

reduction in connitment, the i

NRC, through their acceptance of the 1978 edition of N45.2.0 as modified by Reg. Guide 1.58 Rev.

I dated Sept, 1980, has determined that equivalent quality assurance controls are provided.

Public Service Co i

of Colorado will commit to the 1978 edition of ANSI N45.2.6 and Reg. Guide 1.58, Revision 1, dated Sept.,

1080 as the minimum requirements for inspector certification during the operational phase.

B.5-39 DESCRIPTION: Add:

(SectionB.S.19.7.b)

(b) SPECIFIC EXCEPTIONS Quality Assurance Division 1

personnel involved in 1

nondestructive examination functions shall be qualified to the requirements of SNT-TC-1A-1975 except that i

the maximum l

recertification interval for Level III shall be five (5) personnel years.

For work where the QA l

Division does not have qualified NDE personnai, personnel with proper qualifications will be

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obtained from outside sources.

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Enclosure to P-88078 PAGE(S) AFFECTED REASON:

A recertification interval of five (5) years

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rather than three (3) years is in accordance with ASNT published policy (August.

on i.

recertification 1984). This will allow Public Service Co.

level i

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certifications to expire as their correspondirig ASNT J

certifications expire allowing reviews /recertifications to occur simultaneously.

JUSTIFICATION:

Regulatory Guide 1.58 Revision 1 dated i

Sept.,

1980 endorses SNT-TC-1A-1975 for use in the I

qualification of

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nondestructive testing l

4 personnel in conjanction with 4

i any additional requirements l

imposed by ASME See ion III or J

Section XI. A recertification in t.erval of five (5) years rather than three (3) years 6

for Level III personnel will have no direct effect on the l

certification /recertification process for levels I

and 11 personnel.

The Nuclear Regulatory Corrission has a

l previously endorsed the use of 4

five year Level III's for ASME Section III fabrication through the acceptance of ASME Section III Division i Code Case No. N-341 in Reg.

Guide 1.84, Revision 24, dated June, 1986.

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