ML20199K065
| ML20199K065 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/18/1997 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9712010001 | |
| Download: ML20199K065 (5) | |
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'C Dave Morey Southern Nuclear tace Prosient Operating Company -
Farley Prejeet P.O. Box 1295 Bdmingham. Alabama 35201 Tel 205 99L5131 SOUTHERN h Novenber 18, 1997 ggg Energ ro Serve YourWorld*
Docket Nos.:
50 348 10 CFR 50.54(a)(3) 50-364 U.S. Nuclear Regulatory Commission ATfN: Docament Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Final Safety Analysis Report Quality Assurance Program Changes Inuntinentation Calibration Labelina Ladies and Gentlemen Pursuant to 10CFR50.54(a)(3), attached is a change to the Farley Nuclear Plant (FNP) Final Safety Analysis Report (FSAR) Quality Assurance (QA) Program Description for your review and approval.
The FNP FSAR QA Program description is located in Section 17.2 of the FNP FSAR. His change is
- ubmitted for approval prior to implementation as specified for a reduction in commitment.
The FSAR QA program description is being revised to reduce the requirement to attach calibration labels or tags at FNP. FNP is currently conunitted to ANSI N45.2.4, " Installation, Inspection, and Testing Requirements for Instrumentation and Electrical Equipment During The Construction of Nucicar Power Generating Statinas." Section 6.2 specifies in part, " Items requiring calibration shall be tagged or labeled on completion indicating date of calibration and identity of person that performed the calibration." FNP proposes an alternative to the requirement to attach a label or tag " indicating the date of calibration and identity of person that performed the cali5 ration." The proposed alternative is to maintain a log that includes calibration date and calibration due date for each instrument requiring calibr;. tion, in lieu of the presently used calibration stickers. Plant documents provide the identity of the person performing the calibratior.
ll If there are any questions, picase advise.
l Respectfully submitted, M
)1&rd (a)Ld g
9712010001 971118 PDR ADOCK 05000348 Dave Morey K
PDR EWC/ cit.calstkl. doc Attachments: 1.10CFR50.54(a)(3) Evaluation
- 2. Marked-Up FSAR pages ec:~ Mr. L A. Reyes, Region 11 Administrator
_ 3 w Mr. L 1. Zimmerman, NRR Project Manager gg
,,, S u V : I Mr. T. M. Ross, Plant Sr. Raident inspcetor e
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ATTACllMENT 1 Final Safety Analysis Report Quality Assurance Program Changes 10CFR50.54(a)(3) Evaluation
ATTACilMENT 1 FinalSafety Analysis Report Quality Assurance Program Changes ICCFR50.54(a)(3) Evaluation MIV91cdlagc.E FSAR page 17.2.27 Rescription of the Changq This proposed change will afTect the FNP Final Safety Analysis Report (FSAR) chapter 17.2 OPERATIONS QUALITY ASSURANCE PROGRAM and will affect the method of documentation of calibration data for test instruments and other components. This proposed change will be reflected in FSAR section 17.2.13
" Test Control." The discussion for Regulatory Guide 1.30 will make reference to an exception being taken to ANSI N45.2.4 paragraph 6.2.1.
Rgasgn for:he Changg In the current FSAR QA program description, SNC is committed to Regulatory Guide 1.30 dated August i1, 1972 that in turn references ANSI N45.2.4-1972. This standard specifies that items requiring calibration be tagged or labeled upon completion indicating date of calibration and identity of person performing the calibration. In practice, FNP personnel afTix a calibration sticker directly to the item containing the required information, These stickers tend to obscure portions of meters and are difficult to remove. In addition, problems with stickers becoming detached from the calibrated item have occurred. As an alternative FNP proposes to maintain a log or database containing the date of calibration specified by ANSI N45.2.4-1972.
The identity of the person performing the calibration is available in retained test procedure records.
Das3 foL'hCAfssptability of the Change The data as required by ANSI N45.2 1972 will be available and a mechanism will be in place to ensure that required calibrations ofinstruments are current, prior to use for a test. The identity of performing personnel will be available if needed. Personnel accountability for proper performance of the calibration will not be diminished since that information will continue to be available. The ability of station personnel to determine all information that is currently provided on calibration stickers will not be diminished. This change does not lessen the documentation requirements of ANSI N45.2-1972, but simply provides an alternate method for retaining that information.
This change will provide the following benefits. Meter faces will not be obscured, and problems with lost or illegible calibration stickers will be avoided. A log or database will be available for personnel to readily determine the calibration status ofitems.
10 CFR Part 50 Appendix B criteria will continue to be satisfied with this change implemented. This change is consistent with methods used at ilatch and Vogtle.
O A'ITACilMENT 2 FSAR Mark Up Page 8
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Results of safety-related tests will identify the test data, data recorder, acceptability, and/or any deficiencies noted.
Any noted deficiencies will be resolved wi.th such acticns documented and included with original test results.
Operations activities involved with the installation, inspection, and testing of instrumentation, electrical equjpment, mechanical equipment, and systems will be accomplished in accordance with Regulatory Guide 1.30, dated August 11, 1972, Quality Assurance i
Requirements for the Installation, Inspection, and Testing of Instrumentation and Electrical Equipment (endorses ANSI N45.2.4-1972),
and with ANS1 N45.2.8 (1974), Supplementary Quality assurance Requirer.ents for Installation, Inspection and Testing of Mechanical Equipment und Systems for the Construction Pheca of Nuclear Power Plants. With the exceptions' listed below, Southern Nuclear Operating Company complies with regulatory Guide 1.30 as addressed in F8AR, section 17.2.
Exception is taken to ANSI N45.2.4 (1972)
" Installation, Inspection, and Testing Requireneuts for Instrurentation and Electric Equipment During the construction Phase of Nuclear Power Generating 3tations", section 6.2.1, which stktes, in part:
" Items requiring ca. cration shall be tagged or labeled on completion indicating date of calibration and identity of perr,on that performed the calibration."
Installed process instruments at Plant Farley kre identified by unique instrument numbers.
These instrument numbers are traceable to calibration schedules and records.
These instruments sre not tagged or labeled with calibration data. Listed below is a cross-reference between sections of these standards and the FSAR subsecticns that discuss compliance with these requirements:
/WSI N15.2.4 S9&tiqu FSAR figbfection 1.1 NA 1.2 NA 1.3 13.5.3, 17.2.1 (APC PGS Department) 1.4 NA 1.5 NA 2.1 13.5.3 2.2 17.2.2, 17.2.3 2.3 17.2.13, 17.2.1 (APC PGS Department) 2.4 17.2.10, 17.2.11 2.5 17.2.12 2.6 17.2.16 3
17.2.7, 17.2.8, 17.2.10, 17.2.13 4
17.2.10, 17.2.11 5.1 13.5.3, 17.2.10, 17.2.13 5.2 17.2.11 17.2-27 REY
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