L-98-221, Forwards Proposed Change to BVPS QAP Description Included in Unit 2 Ufsar,For Approval.Change Will Reduce QAP Description Commitments for Units 1 & 2 by Allowing Conditional Release to Site of Matl & Equipment
| ML20198C018 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/08/1998 |
| From: | Jain S DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-98-221, NUDOCS 9812210270 | |
| Download: ML20198C018 (5) | |
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Beaver Valley Power Station Shippingport. PA 150774K)4
!an$o"r VNPresident December 8, 1998 Fox $)i4NN
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"NU*0E. ion L-98-221 U. S. Nuclear Regulatory Commission Attention: Document Control Desk
. Washington, DC ' 20555-0001 l
Subject:
Beaver Valley Power Station, ' Unit No.1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 i
Quality Assurance Program Description Change In accordance with 10 CFR 50.54(a)(3)(iii), this letter forwards a proposed change to the Beaver Valley Power Station Quality Assurance (QA) Program Description included in j
the Unit 2 Updated Final Safety Analysis Report, for NRC approval. This change would j
reduce the QA Program Description commitments for Units 1 and 2 by allowing j
conditional release to the site of material and equipment, where documentary evidence of conformance to procurement requirements is not available prior to installation or use. fmther describes the proposed change, identifies the reason for the change, and provides the basis for concluding that the revised program incorporating this change continues to satisfy the criteria of 10 CFR 50, Appendix B, and the UFSAR QA Program 4
Description commitments previously accepted by the NRC.
. presents the proposed wording changes to the Unit 1 UFSAR and the Unit 2 UFSAR to reflect this change.
i
. If you have any questions regarding this submittal, please contact Mark S. Ackennan, Manager of Safety and Licensing in the Nuclear Services Group, at (412) 393-5203.
3 Sincerely, AM h
Sushil C. Jain j
c:
Mr. D. S. Brinkman, Sr. Project Manager l
Mr. D. M. Kern, Sr. Resident Inspector 0 0 A LIT Y Mr. H. J. Miller, NRC Region I Administrator ENERGY 9812210270 981208 Y PDR ADOCK 05000334(
P PDR
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4' ATTACHMENT 1 4
BACKGROUND-The operations phase QA Program Description for Units 1 and 2, contained in Unit 2 UFSAR Section 17.2,7, " Control of Purchased Material, Equipment, and Services,"
includes the following commitment:
"The documentary evidence that the material and equipment conform to the procurement requirements will have been received at BVPS (Beaver Valley Power Station) prior to installation or use of such material and equipment."
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CHANGE DESCRIPTION In cases where documentary evidence that material and equipment conform to procurement requirements is not available at the site, prior to the installation or use of such material and equipment, the change would allow the associated material and equipment to be installed or used but it shall be considered non-conforming. Until suitable documentary evidence is available at the nuclear power plant site to show conformance with procurement requirements, the affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill t'.e intended safety functions.
REASON FOR THE CHANGE In those instances when documentary evidence that material and equipment conform to procurement requirements is not available at the nuclear power plant site, the change i
would allow conditional release and limited use of such material and equipment at either l
Unit.
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BASIS FOR CONCLUDING THAT THE REVISED PROGRAM I
INCORPORATING THE CHANGE CONTINUES TO SATISFY THE CRITERIA OF 10 CFR 50, APPENDIX B, AND THE SAFETY ANALYSIS REPORT QUALITY ASSURANCE PROGRAM DESCRIPTION COMMITMENTS PREVIOUSLY ACCEPTED BY THE NRC This change is considered to be a reduction in the Unit 1 QA program description commitments previously accepted by the NRC. Unit 1 is committed to Regulatory Guide (RG) 1.33, November 1972, which endorses ANSI N45.2 and ANSI N18.7,1972. The commitment to RG 1.33 is considered part of the Unit 1 UFSAR QA Program description. ANSI N18.7,1972 does not contain provisions to address 10 CFR 50, Appendix B, Criterion II, which states, " Documentary evidence that material and equipment conform to the requirements shall be available at the nuclear power plant or i
fuel reprocessing site prior to installation or use of such material and equipment."
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ATTACHMENT 1 ( continued)
Unit 2 is committed to RG 1.33, Revision 2, which endorses ANSI N18.7,1976 and this RG is considered part of the Unit 2 QA Program description. Paragraph 5.2.6 of this ANSI standard contains a provision which would permit non-conforming material and equipment to be conditionally released, provided that the affected systems are considered to be inoperable and reliance is not placed on such systems to fulfill their intended safety functions.
10 CFR 50, Appendix B, Criterion XV, " Nonconforming Material, Parts, or Components," contains requirenwnts for the establishment of measures to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. This proposed change to the QA Program description for both Units will consider affected systems containing non-conforming materials and equipment to be inoperable and prohibit reliance from being placed on such systems to perform their intended safety functions. This change reflects the controls contained in ANSI N18.7, which the NRC has endorsed through RG 1.33, Revision 2. Therefore, the revised program as a result of this change represents an acceptable method for continued compliance with the requirements of 10 CFR 50, Appendix B and the UFSAR QA Program description commitments previously accepted by the NRC.
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,e ATTACHMENT 2 BVPS-1 UFSAR Rev. (TBD) i 1.3.4.1 Regulatory Guides REGULATORY GUIDE 1.33, NOVEMBER 3,
1972:
QUALITY ASSURANCE PROGRAM REQUIREMENTS (OPERATIONS)
The Duquesne Light Company Operations Quality Assurance Program l
requirements follow the guidance of Regulatory Guide 1.33, November 3,
1972- (including referenced standards ANSI N45.2, f
1971 and ANSI N18.7, 1972 (formerly ANS 3.2)].
f Appendix A of Regulatory Guide 1.33, (Revision 2,
February L
1978), is used as guidance to ensure minimum procedural coverage for plant activities.
The biennial review of safety related plant procedures described in ANSI N18.7 will be replaced by programmatic controls related to procedure review found in plant' administrative procedures, and a maximum six year procedure review period.
Biennial audits of. operating organizations will include a
review of their procedures to provide additional assurance that existing programmatic controls are resulting in the timely revision of their procedures in response to operations experience deficiencies and procedure deficiencies identified by users.
With regard to material and equipment conformance, the following qualification-will be applied at BVPS:
In cases where documentary evidence is not available (to show that the material and equipment conform to the procurement requirements),
the associated material or equipment shall be considered non-conforming.
Until suitable evidence is available at the nuclear power plant site to show the material or equipment is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions.
REGULATORY GUIDE 1.37, MARCH 16, 1973:
QUALITY ASSURANCE REQUIREMENTS FOR CLEANING OF FLUID SYSTEMS AND ASSOCIATED COMPONENTS OF WATER-COOLED NUCLEAR POWER PLANTS The Duquesne Light Company Operations Quality Assurance Program requirements follow the guidance of Regulatory Guide 1.37.
Procedures and/or specifications were developed prior to, and implemented concurrent with the start of the operations phase.
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(from pages 1.3-48 and 1.3-49)
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ATTACHMENT 2 (continued)
BVPS-2 UFSAR Rev. (TBD) 17.2.7 Control of Purchased Material, Equipment, and Services The Operations QA Program establishes measures to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to written procurement documents.
The measures include provisions, as appropriate, for source evaluation and selection, vendor surveillance, source inspection, receipt inspection, examination of tests and/or inspection reports from the supplier, examination of objective evidence from the supplier such as certificates of conformance, or any combination of these.
The extent and frequency of source evaluations shall be governed by factors such as the importance, complexity, quantity of items involved, level of confidence in the supplier established by past performance, and the ability to meet the applicable requirements of 10 CFR 50, Appendix B.
Receipt inspection will be performed by designated individuals, using written predetermined instructions and/or checklists in accordance with the provisions of the Operations QA Program.
The receipt inspection will include examination of material and equipment to assure that the quality had not been impaired during transit, that the correct count had been received, and that required procurement quality records had been received at the site prior to use or installation of the material or equipment.
The documentary evidence that the material and equipment conform to the procurement requirements will have been received at BVPS prior to installation or use of such material and equipment, except for the following:
In cases where documentary evidence is not available, the associated material or equipment shall be considered nonconforming.
Until suitable documentary evidence is available at the nuclear plant site to show the material or equipment is in conformance, affected systems shall be considered inoperable and reliance shall not be placed upon such systems to fulfill their intended
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safety functions.
The Operations QA Program requires that the effectiveness of the control of quality by contractors and suppliers will be assessed by DLc, or its designee, at intervals consistent with the importance, complexity, and quantity of the product or service.
The Operations QA Program also includes measures to assure that source inspections or audits are conducted by qualified personnel to determine conformance to the requirements of procurement documents, specifications, drawings, and applicable codes and standards.
Such inspections and/or audits are determined in advance and performed in accordance with written instructions.
17.2-19