ML20204B952

Ack Receipt of 781005 NRC Ltr Accepting Recently Proposed Rev to Topical Rept#ETR-1001,Ebasco Quality Assurance. Manual.Forwards Rev Pages Which Will Affect Subj Facils

ML20204B952
Person / Time
Site:	Harris, Waterford
Issue date:	11/09/1978
From:	Tenzer B EBASCO SERVICES, INC.
To:	Haass W Office of Nuclear Reactor Regulation
References
NUDOCS 7811150193
Download: ML20204B952 (12)

Text

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EBASCO S imVI C E S I N 0 il it l' O H 11 E Il i UTILITY C O N S ti LT A !J T S - E N GIN E E R S - CONSTRUCTORS TWO Ill.CT OR SIRI:LT N LW YOHH, N.Y.10006 CABLR ADDRE&S "ESASCON" November 9, 1978

, Mr. Walter P. Ilaass, Chief Quality Assurance Branch Division of Project Management  ;

U S Nuclear Regulatory Commission i Washington, D. C. 20555 l

Dear Mr. Haass:

This is to acknowledge receipt and thank you for your letter of October 5,1978 to [

our Mr. L F C Reichle accepting recently proposed revisions to Ebasco Topical Report No. ETR-1001, "Ebasco Nuclear Quality Assurance Program Manual'.' The revisions are being included in the Topical Report. j In accordance with your request, thirty-five (35) copies of the revised or new sec-tions (initial page only on the case of Section QA-I-1), each including updated 3 Table of Contents, the Nuclear Regulatory Commission letter of acceptance of October '

5, 1978 .and transmittal memorandum for the package, are transmitted.

The following of our existing contracts will be covered by Change 6 to ETR-1001:

Carolina Power & Light Co. Shearon Harris Nuclear Power Station Units 1,2,3,6 4 Houston Lighting & Power Company Allens Creek Nuclear Power Station Unit 1 Louisiana Power & Light Company Waterford Steam Electric Station Unit 3 l

Washington Public Power Supply System Nuclear Projects 3 and 5 Since Preliminary Safety Analysis Reports for all of the above contracts were dock-eted prior to October 19, 1977, the exceptions stated in Sections QA-III-13, Revision 2, paragraph 3.2, page 2 of 2, and in the EBASCO POSITION under REGULATORY CUIDE 1.94 in APPENDIX 11, Revision 0, page 3 of 4, apply.

Very truly yours, BET /mc B E Tenzer Attachments Director, Materials Engineering cci F Liederbach and Quality Assurance C J Hale, NRC Region IV, 0.I.& E B R Mazo O .h k

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TO: Assignee of Ebasco Nuclear Quality Assurance Program Manual No.

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FROM: F F Ford, Quality Program Coordinator'

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SUBJECT:

EBASCO NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL (ETR-1001)

Table of Contents, Revision 6 of 10/20/78 l Section QA-I-1, Revision 4 of 10/20/78 l Section QA-III-13, Revision 2 of 10/20/78 APPENDIX II, Revision 0 of 10/20/78 One copy each of the below listed revised pages are transmitted for insertion in your copy of the Ebasco Nuclear Quality Assurance Program Manual (in blue binder).

Superseded pages are to be destroyed.

Table of Contents, Revision 6, pages 1 and 2 of 2. These replace existing Table of Contents, Revision 5 pages of the same number.

Section QA-I-1, Revision 4, QUALITY ASSURANCE PROGRAM, page 1 of 12. This replaces existing Section QA-I-1, Revision 3, page 1 of 12. Note that un-revised pages of this section are not included in this transmittal and therefore should not be discarded from your manual.

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( Section QA-III-13, Revision 2, CONTROL OF MEASURING AND TESTING EQUIPMENT, pages 1 and 2 of 2. These replace existing Section QA-III-13, Revision 1 pages of the same number.

APPENDIX II, Revision 0, EBASCO POSITIONS ON US NUCLEAR REGULATORY COM-MISSION REGULATORY GUIDES, pages 1 thru 4 of 4. These are new pages to be inserted at the rear of the manual af ter APPENDIX I.

NRC (Walter P. Haass) letter dated October 5, 1978 tc L F C Reichle ac-cepting the revisions. This is for insertion in the front of the manual behind the original NRC letter of acceptance dated May 12, 1975, and re-places NRC letter of acceptance dated July 26, 1977 pertaining to change No. 5.

An index tab divider sheet for new Appendix II is included for insertion in the back part of your manual behind Appendix 1, and ahead of Updating Status Memos, in the event an Appendix II index tab is not already in place.

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6109 6/2 75 PAGE I OF ESA5CO SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED g.

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c a... M,..g.L os . , , os TABLE OF CONTENTS nevision 6 ']

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Part I - General Section Title- Rev. No. Date QA-I-l Quality Assurance Program 4 10/20/78 R6 QA-I-2 Organization and Responsibilities- 2 9/30/76 QA-I-3 Personnel Indoctrination and Training 2 8/11/77 Program in Quality Assurance

-QA-I-4 Design Control 1 8/11/77 QA-I-5 Quality Assurance Evaluation of 1 9/30/76 l Supplier / Contractors QA-I-6 Quality Assurance Records 0 3/14/75 Part II - Engineering Offices j

Section Title Rev. No. Date l

1 QA-II-1 Instructions, Procedures and Drawings 1 9/30/76 l QA-II-2 Document Control 1 9/30/76 l

QA-II-3 Procurement Document Control 0 3/14/75

-QA-II-4 Purchasing 1 4/16/76 QA-II-5 Supplier Surveillance 1 8/11/77 QA-II-6 Nonconformances 1 8/11/77 QA-II-7 Corrective Action 0 3/14/75 QA-II-8 Control of Special Processes 0 3/14/75 QA-II-9 Quality Assurance Audits I 11/16/76 O

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6 61094A/2 74 PAGE 2 OF 7 HLlCLEAR QUALITY A550RANCE PROGRAM MANUAL SECTiow O ESASCO SERVICES mcomponave TABLE OF CONTENTS Part III - Construction Site Section Title Rev. No. Date QA-III-1 Instructions, Procedures and 1 4/16/76 Drawings QA-III Document Control 1 4/16/76 QA-III-3 Procurement Control 0 3/14/75 QA-III-4 Construction Site Procurements 3 8/11/77

-QA-III-5 Supplier,' Contractor Surveillance 2 8/11/77 QA-III-6 Nonconformances 1 9/30/76 QA-III-7 Corrective Action 1 8/11/77 QA-III-8 Control of Special Processes 0 3/14/75 QA-III-9 Quality Assurance Audits 0 3/14/75 QA-III-10 Identification and control of Items 0 3/14/75 QA-III-11 Inspection 1 8/11/77 ,

QA-III-12 Test Control 0 3/14/75 QA-III-13 Control of Measuring and Testing 2 10/20/78 R6 Equipment QA-III-14 Control of Receiving, Handling and 1 4/16/76 Storage QA-III-15 Inspection, Test and Operating Status 0 3/14/75 Appendix I Terms and Definitions 1 9/30/76 Appendix II Ebasco Positions on U.S. Nuclear Regulatory Commission Regulatory Guides 0 10/20/78 R6 O  ;

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PACE 1 or 17 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION tBA5CO 5ERVICES IN CoR PoR AT E D AA T_1 A4 RE VISION 4

1. a6, esopau touw, twainuam DATE -10/20/78

$ c ,.. . , <p, . n a u c ........ QUALITY ASSURANCE PROGRAM 1.0 SCOPE The purpose of this section is to describe the Quality Assurance Program of Ebasco Services Incorporated and its applicability to safety-related activities.and ser-vices performed by Ebasco in the design and construction of nuclear power stations.

This Program has been designed to meet the requirements of the United States Nuclear

~

Regulatory Commisrion 18 Quality Assurance Criteria of 10CFR50, Appendix B. It has ,

also been designed to meet the regulatory position of the following US NRC Regulatory .

Guides and ANSI Standards, with exceptions and clarifications as stat'ed inAppende'x II of8' this manual:

1. Reg. Guide 1.28 Rev. O,(6-72) 8. Reg. Guide 1.70 (Chap.17) Rev.2 (9-75) ,

2. " "

1.30 "

0 (8-72) 9. " "

1.74 Rev.0 (2-74) ,

3. " "

1.37 "

O (3-73) 10.

" " 1.88 2 (10-76) R4 l

4. " "

1.38 "

2 (5-77) 11.

1.94 1 (4-76) '

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5. " "

1.39 " 2 (9-77) 12.

1.116 OR(5-77) l

6. " "

1.58 " b (8-73) 13. " "

1.123 1 (7-77) '

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" " " 14. Standard N45.2.12, i

7. 1.64 2 (6-76 ) " ' '

. Draft 3, 4 (2-74)

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[m4able I-1.1 provides a matrix wh,1ch shows the sections of the Ebasco Nuclear Quality l Assurance Program Manual that correspond to the requirements of 10CFR50, Appendix 1 R4 B and US NRC Regulatory Guide 1.28, Rev. O. The Ebasco Qual,ity Assurance Program l' 1s comprised of: The Ebasco Nuclear Quality Assurance Program Manual, written corporate policies, procedures, departmental instructions, and drawings related to l' quality. Table'I-1.2 provides a matrix of the principal implementing procedures with 10CFR50, Appendix B. Table I-1.3 is a listing of these procedures by citle.

The Ebasco Nuclear Quality Assurance Program Manual has been designed to meet the requirements of 10CFR50.34 (7) for a quality assurance program description. It will be incorporated into applicable portions of safety analysis reports by reference as provided by 10CFR50.32*.

The Ebasco Quality Program is in force at Ebasco Engineering Offices and Construction Operat ions. Ebasco Engineering Offices are those district organized units where design, engineering, procurement and related functions are performed. Construction Operations encompass those activities related to the construction of a nuclear power station. Ebasco's responsibility for.. implementing the Ebasco Quality Program shall begin at'the commencement of activities affecting quality and shall end with the turn-over of completed systems to the Client.

Definitions pertaining to the Ebasco Quality Program are listed in Appendix I of this manual.

2.0 QUALITY ASSURANCE FYCINEERING 2.1 The Ebasco Quality Assurance Engineering Department is responsible for p

establisning new, and updating existing quality assurance requirements. In addition, this department is responsible to administer and enforce the implemen-tation of the Ebasco Quality Assurance Manual.

6109 4/2 75 PAGE I OF 2  ;

EB A5CO SERVICE 5 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPoAATED OA-III-13 i O. ,g J.sg[ CONTROL OF MEASURING ,

2 g 2.. ... 6 . . . . . . . < AND TESTING EQUIPMENT ae vision I. _

omic 10/20/78 1.0 SCOPE 1.1 This section describes the requirements for control, calibration, adjustment and maintenance of measuring and testing devices used at the construction site for performing tests and inspections of safety-related items. These devices shall be calibrated and adjusted at specified,. predetermined intervals using equipment having known valid relationships to nationally recognized standards.

1.2 The activities described herein shall be performed in accordance with written instructions, procedures, and/or drawings that have been developed and accepted in accordance with the requirements of Section QA-III-l of this Manual.

2.0 RESPONSIBILITIES The Site Quality Control Staff shall be. responsible for performance of the following: -

2.1 Establish a list which includes the measuring and testing devices O- to be calibrated and the frequency of calibration of these devices.

The method and interval of calibration shall be based on the type of device, stability characteristics, required accuracy and other conditions affecting measurement control..

2.2 Assure that the measuring and testing devices used are of the proper range, type and accuracy to verify conformance to established requirements.

2.3 Maintain a master calibration file for each measuring and testing device which includes at least the following information:

(a) name of device (b) device serial and/or identification number (c) frequency of calibration (d) date of last calibration (e) name of party performing last calibration (f) due date for next calibration 2.4 Assure that all measuring and testing devices are marked with calibration due dates when possible. When this marking is not possible, alternative methods of tracing the device to its calibration date (such as serialization) shall be employed.

2,5 Assure that all measuring and testing devices are calibrated in accordance. with the requirements of this section and that the required

\~ documentation is provided.

PAGE 2 o, 2 81094 A/2 75 NUCLEAR QUALITY ASSURANCE PROGP.AM MANUAL SECTION

/ EBASCO SERVICES CONTROL OF MEASURING QA-III-13

("7/ mcomponarro AND TESTING EQUIPMENT 2.6 Develop and maintain a system for issuance, collection and return of all measuring and testing devices. This system shall provide for the identification of personnel withdrawing devices, methods for issuing devices and methods for the collection and/or return of devices at prescribed calibration times or as othetvise required.

3.0 GENERAL 3.1 The standard of calibration utilized by those performing the calibration shall be in accordance with recognized criteria such as Departments of Weights and Measures, ASTM standards or others which are traceable to the National Bureau of Standards. If no national standards exist, the basis for calibration shall be documented.

3.2 Measuring and Test Equipment (M&TE) shall be calibrated against working '

standards having tolerances not greater than one fourth (k) the tolerance '

of the M&TE. Tolerances greater than one fourth (k) shall be acceptable '

when limited by the state of the art. Reference standards shall be calibrated against higher level standards of closer tolerance. R2 For projects with Preliminary Safety Analysis Reports docketed on or before '

O October 19, 1977, M&TE shall be calibrated against working standards V having tolerances not greater than the tolerance of the M&TE. Reference '

standards shall be calibrated against higher level standards of closer ' l tolerance.

3.3 Methods shall be employed to assure proper handling, storage and care of the M 6 T E in order to maintain its required accuracy. R2 3.4 Any M & T E found to be out of calibration shall be recalibrated. R2 When M & T E is found to be out of calibration, an evaluation shall R2 be made to ascertain the validity of previous inspection or test results and the acceptability of components inspected and/or tested since the last calibration check. When it is necessary to assure the acceptability of suspect items, the original required inspections and/or tests shall be repeated using properly calibrated eauipment.

3.5 If any of the M & T E is consistently found to be R2 out of calibration, it shall be repaired or replaced.

3.6 Inspection and test reports shall include identification of M & T E R2 used to perform the inspections and/or tests.

3.7 The Quality Assurance Site Supervisor shall be responsible for the performance of reviews and audits in accordance with Section QA-III-9 of the Manual to the extent necessary to assure compliance with the

/ requirements of this Section.

4.0 RECORDS 4.1~ Records pertaining to this section shall be maintained in accordance with Section QA-I-6 of this manual.

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. EBA5CO $ERVICES - HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL $5cTioH INCoRPORATeo.

l i EBASCO POSITION 9 ON US NUCLEAR g

[c ... ...g7.. MIc.oo. REGULATORY COMMISSION REGULATORY GUIDES Ae Vi$lON O l l pare 10/20/78 4 c.ap n. .. ..c .. .

e q REGULATORY GUIDE 1.28 QUALITY ASSURANCE PROGRAM REQUIREMENTS (DESIGN AND l CONSTRUCTION) (SAFETY GUIDE 28, REVISION 0, 6/72)

EBASCO POSITION Ebasco commits to comply with the regulatory position as written, with no exceptions or clarifications to'the guide.

REGULATORY GUIDE 1.30 QUALITY ASSURANCE REQUIREMENTS FOR THE INSTALLATION, 4 INSPECTION, AND TESTING OF INSTRUMENTATION AND i ELECTRIC EQUIPMENT (SAFETY GUIDE 30, REVISION 0, 8/72)

EBASCO POSITION a Ebasco commits to comply with the regulatory position as written with no exceptions

or clarifications to the guide.

l i REGUALTORY CUIDE 1.37 QUALITY ASSURANCE REQUIREMENTS FOR CLEANING OF

' 1 FLUID SYSTEMS AND ASSOCIATED COMPONENTS OF WATER-() ERASCO POSITION COOLED NUCLEAR POWER PLANTS (REVISION 0, 3/73)

Ebasco commits to comply with the regulatory position as written, with no exceptions or clarifications to the guide.

REGUALTORY GUIDE 1.38 QUALITY ASSURANCE REQUIREMENTS FOR PACKAGING, SHIPPING, STORAGE AND HANDLING OF ITEMS FOR

' WATER-COOLED NUCLEAR POWER PLANTS (REVISION 2, 5/77)

EBASCO POSITION l

Ebasco commits to comply with the regulatory position with the following clarifica-tions:

1 CLARIFICATION Item-ANSI N 45.2.2-1972 Ebasco believes the intent of the ANSI Subdivision 2.7 classification of protection levels is met if equipment identified in Level B and C categories which was specifically designed for outdoor environment is stored at Level D (outdoor) conditions.

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sios4a/2 7s paos ? or 4 NUCLEAR QUALITY AS$URANCE PROGRAM MANUAL SECTION '

g,,) E8A5CO SERVICE 5 EBASCO POSITIONS ON US NUCLEAR REGULATORY COMMISSION REGULATORY GUIDES APPENDIX II REGULATORY GUIDE 1.38-(cont.)

Regulatory Position Ebasco believes that storage conditions should be such C.1.c and C.2.c that desiccants, their bags and tapes should not be sub-jected to leaching or radiation. Even if accidental leaching or radiation occurs, desiccants and tapes are removed prior to component installation. Subsequent routine flushing and/or cleaning would remove any harmful residues.

Ebasco will impose the more readily interpretable require-ments of 0.25% maximum halogens for desiccants (c.1.c) and 0.10% halogen and sulfur content for tape (C.2.c)

REGULATORY GUIDE 1.39 HOUSEKEEPING REQUIREMENTS FOR WATER-COOLED NUCLEAR POWER PLANTS (REVISION 2, 9/77)

EBASCO POSITION Ebasco commits to comply with the regulatory position . ;a the following clarifica-O tion:

CLARIFICATION Item-General Ebasco acceptance applies only to the regulatory require-ments for controls at the site during the construction phase and not to the operational aspects of this guide or the referenced documents.

REGULATORY GUIDE 1.58 QUALIFICATION OF NUCLEAR POWER PLANT INSPECTION, EXAMINATION, AND TESTING PERSONNEL (REVISION 0, 8/73)

EBASCO POSITION Ebasco commits to comply with the regulatory position as written, with no exceptions or clarifications to the guide.

REGULATORY GUIDE 1.64 QUALITY ASSURANCE REQUIREMENTS FOR THE DESIGN OF NUCLEAR POWER PLANTS (REVISION 2, 6/76)

EBASCO POSITION Ebasco commits to comply with the regulatory position as written, with no exceptions or clarifications to the guide.

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slossA/27s PAos 9 or 4 HUCLEAR QUALITY AS$URANCE PROGRAM MANUAL SECTION EBA5CO SERVICE 5 EBASCO POSITIONS ON US NUCLEAR REGULATORY mcomponareo APPENDIX II COMMISSION REGULATORY GUIDES REGULATORY GUIDE 1.70 STANDARD FORMAT AND CONTENT OF SAFETY ANALYSIS (Chapter 17) REPORTS FOR NUCLEAR POWER PLANTS (REVISION 2, 9/75)

EBASCO POSITION The Quality Assurance Program and its applicability to safety related activities and services performed by Ebasco in the design and construction of nuclear power plants is fully delineated in this topical report (ETR-1001).

REGULATORY GUIDE 1.74 QUALITY ASSURANCE TERMS AND DEFINITIONS (REVISION 0, 2/74)

EBASCO POSITION Ebasco commits to comply with the regulatory position as written, with no exceptions or clarifications to the guide.

REGULATORY CUIDE 1.88 COLLECTION, STORAGE, AND MAINTENANCE OF NUCLEAR O

\ POWER PLANT QUALITY ASSURANCE RECORDS (REVISIONS 2, 10/76)

EBASCO POSITION Ebasco commits to comply with the regulatory position as written, with no exceptions or clarifications to the guide.

REGULATORY GUIDE 1.94 QUALITY ASSURANCE REQUIREMENTS FOR INSTALLATION, INSPECTION AND TESTING OF STRUCTURAL CONCRETE AND STRUCTURAL STEEL DURING THE CONSTRUCTION PRASE OF NUCLEAR POWER PLANTS (REVISION 1, 4/76)

EBASCO POSITION Ebasco commits to comply with the regulatory position as written, with no exceptions or clarifications to the guide for projects with Preliminary Safety Analysis Reports docketed on or after October 19, 1977. For prior projects Ebasco will comply with the applicable Safety Analysis Report and other associated commitments as approved by the NRC.

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1 stoo4A/a 7s ,, g y g y NUCLEAR QUALITY A$$URANCE PROGRAM MANUAL SECTION Es 5Co 5ERvlCES EBASCO POSITIONS ON US NUCLEAR REGUAI. TORY ]

eopp, ,,g9 APPENDIX II COMMISSION REGUALTORY GUIDES REGULATORY GUIDE 1.116 QUALITY ASSURANCE REQUIREMENTS FOR INSTALL-ATION,' INSPECTION, AND TESTING OF MECHANICAL EQUIPMENT AND SYSTEMS (REVISION 0-R, 5/77)

EBASCO POSITION Ebasco commits to comply with the regulatory position with no exceptf ons or clarifi-cations to the guide.

REGULATORY GUIDE 1.123 QUALITY ASSURANCE REQUIREMENTS FOR CONTROL OF PROCUREMENT OF ITEMS AND SERVICES FOR NUCLEAR POWER PLANTS (REVISION 1, 7/77)

EBASCO POSITION Ebasco commits, to comply with the regulatory position with no exceptions or clarifi-cations to the guide.

ANSI N45.2.12 REQUIREMENTS FOR AUDITING OF QUALITY ASSUR-

/ . .ANCE PROGRAMS FOR " LEAR POWER PLANTS (DRAFT 3, REVISION 4, 2/74)

EBASCO POSITION i

As presently written, EBASCO commits to comply with this standard with no exceptions of clarifications.

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f  %,+g UNITED STATES pi >

NUCLEAR REGULATORY COMMISslON g g W ASHINGTON, D. C. 20565 V s gv j

/ OCT 5 1978 Mr. Leonard F. C. Reichle Vice-President -

Ebasco Services. Incorporated Two Rector Street New York, New York 10006

SUBJECT:

NRC ACCEPTANCE OF REVISION T0 QA TOPICAL REPORT By letters datcd February 13, 1978 and September 11, 1978, you submitted Revision 6, consisting of revised pages, to the Ebasco Topical Report No. ETR-1001. The revisions concern clarification of scope and comit-ments to certain NRC Regulatory Guides.

We have evaluated the proposed revisions and have found that they do not change our prior conclusions. Your revised topical report meets the criteria of Appendix B to 10 CFR Part 50 and is therefore acceptable.

To use the topical report in license applications, applicants need only reference this topical report in Section 17 of the Safety Analysis Report.

We do not intend to repeat our review of this topical report when it is A referenced in an application. In addition, the provisions of this topical V report revision may be implemented inuediately on all ongoing activities within the contractual restraints of existing contracts for nuclear power plants. In this regard, identify in your transmittal letter those existing contracts that will be covered by Revision 6 to ETR-1001.

Should regulatory criteria or regulations change such that our conclusions about this topical report are invalidated, we will notify you. You will be given the opportunity to revise and resubmit it should you so desire.

Programttic changes by Ebasco to this topical report are to be submittect to the NRC for review prior to implementation. Organizational changes are to be submitted no later than 30 days after announcement.

Please replace our letter of July 26, 1977 shown in your topical report with this letter and submit 35 copies to the NRC.

Should you have any questions regarding our review or if we can provide assistance, please feel free to contact me or Mr. Fred Liederbach on (301) 492-7741.

Sincer ly.

- W Walter P. Haass, Chief

/3 Quality Assurance Branch

() Division of Project Management

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