ML20217D408

Safety Evaluation Accepting Proposed Changes to Maintain Calibration Info Required by ANSI N45.2.4-1972

ML20217D408
Person / Time
Site:	Farley
Issue date:	03/24/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217D407	List: ML20217D402 ML20217D408
References
NUDOCS 9803300011
Download: ML20217D408 (2)

Text

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p C*%q\ UNITED STATES g j NUCLEAR REGULATORY COMMISSION o WASHINGTON. D.C. 30006 4001 SAFETY EVALUATION BY THE OFFICE OF NUCI FAR REACTOR REGULATION QUALITY ASSURANCE PROGRAM DESCRIPTION CHANGE SOUTHERN NUCI FAR OPERATING COMPANY. INC.. ET AL.

JOSEPH M. FARI FY NUCI FAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-384

1.0 INTRODUCTION

By letter dated November 18,1997, as supplemented by letter dated February 23,1998, Southem Nuclear Operating Company, Inc. (SNC) requested a change to the Farley Nuclear Plant (FNP) Final Safety Analysis Report (FSAR) Quality Assurance (QA) Program Description pursuant to 10 CFR 50.54(a)(3). SNC proposed an altemative to the requirement to attach labels or tags to installed process instruments. The proposed attemative is to maintain a log or data base that includes calibration information specified by ANSI N45.2.4-1972 for each installed process instrument requiring calibration in lieu of the presently used calibration stickers. This change was requested because the existing practice of affixing calibration stickers directly to the instruments tends to obscure portions of the meters and the stickers are difficult to remove, in addition, occasional problems with stickers becoming detached or illegible have occurred.

2.0 EVALUATION SNC is committed to Regulatory Guide 1.30, " Quality Assurance Requirements for the Installation, inspection, and Testing of instrumeritation and Electric Equipment," dated August 11,1972, which in tum, references ANSI N45.2.4-1972 " Installation, inspection and Testing Requirements for Instrumentation and Electric Equipment During the Conttruction of Nuclear Power Generating Stations." Section 6.2.1 for tests of installed equipment specifies, in i part, *ltems requiring calibration shall be tagged or labeled on completion indicating date of l calibration and identity of person that performed the calibration." The requested change to the i FNP QA Program Description is:

With the exceptions listed below, Southem Nuclear Operating Company complies with Regulatory Guide 1.30 as addressed in FSAR, section 17.2.

Exception is taken to ANSI N45.2.4 (1972) " Installation, inspection, and Testing Requirements for instrumentation and Electric Equipment During the Construction Phase of Nuclear Power Generating Stations", section 6.2.1, which states, in part: " Items requiring calibration shall be tagged or labeled on completion indicating date of calibration and identity of person that performed the calibration." installed process instruments at Plant Farley are identified by 9803300011 980324 PDR ADOCK 05000348 P PDR

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unique instrument numbers which are readable at the instrument. These j instrument numbers are traceable to calibration schedules and records. These calibration schedules or records contain the same information as required by ANSI N45.2.4(1972). These schedules or records are readily accessible to  !

personnel who are required to check calibration status as required by goveming I procedures. These instruments are not tagged or labeled with calibration data. i Section ll, " Acceptance Criteria," of Standard Review Plan (SRP) Section 17.2, " Quality i Assurance During the Operational Phase," contains provisions for the use of attematives to the acceptance criteria contained in SRP 17.2 provided they are evaluated by the staff and are considered to be in compliance with pertinent NRC regulations. Criterion 12.5 of ERP 17.1, which is referenced in SRP 17.2, requires that measuring and test equipment be labeled or tagged or "othenese controlled" to indicate the due date of the next calibration. Based on the staffs review, it was determined that SNC's proposed change is an acceptable altemative to tagging installed process instruments with calibration data in that:

1. unique instrument numbers are readable at the instrument,

2. the instrument numbers are traceable to calibration schedules and records,

3. the calibration schedules and records contain the same information as required by ANSI j N45.2.4-1972,

4. these schedules and records are readily accessible to personnel who are required to check calibration status as required by goveming procedures, and

5. the above altemative to tagging or labeling installed process instruments with calibration data is "otherwise controlled" by its description in the requested change to the FNP QA Program Description.

3.0 CONCLUSION

The staff finds that the requested change to maintain the calibration information required by  !

I ANSI N45.2.4-1972 for the installed process instruments requiring calibration in a log / data base represents an acceptable attemative to the acceptance criterion contained in SRP Section 17.2.

The proposed changes are acceptable and continue to meet the pertinent requirements of 10 CFR Part 50 Appendix B.

PrincipalContributor: R. Smith Date: March 24, 1998 T*

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