A830013, Forwards Addl QA Program,App D Info,In Response to NRC 830415 Request.Next Formal Rev to Updated SAR Scheduled for Jul 1983
| ML20076H187 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/25/1983 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| LQA8300135, NUDOCS 8306160464 | |
| Download: ML20076H187 (72) | |
Text
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LQA8300135 April 25, 1983 3M@MDMM3 Mr. John T. Collins APR 2 81983 Regional Administrator J '
U.S. Nuclear Regulatory Commission Region IV __
611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 Subj ect: Cooper Nuclear Station Additional Quality Assurance Program Information NRC Docket No. 50-298, DPR-46
Dear Mr. Collins:
In response to your questions of April 15, 1983 regarding Appendix D to the CNS USAR, the attached information is provided. It is hoped that this will satisfy your concerns pending our next formal revision scheduled for July 1983.
If you should have any questions or comments, pleaue contact me.
Sincerely,
- k. WW
'ay M. Pilant Division Manager of Licensing and Quality Assurance FEW:cmk Attachment ,
F306160464 830425 Lo PDR ADOCK 05000298 fgl P PDR /
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- -4 y - p QUESTIONS ON CNS USAR APPENDIX D REVIEW AND NPPD'S LETTER OF 3/2/83
- 1. Question Page D-2-1, paragraph 2.1, and item 2 of Attachment A of NPPD's 3/2/83 letter indicates that the general manager represents the corporate officer responsible for QA. However, paragraph 3.2.1 on page D-3-1 places this responsibility lover in the organization with the Senior Division Manager, Power Operations. Which statement is correct?
Response The General Manager. represents the highest corporate officer responsible for the Cooper Nuclear Station QA Program. This responsibility has been delegated to the Senior Division Manager-Power Operations and does not change the District's QA Program commitment.
- 2. Question Page D-2-12, paragraph 2.16, provides a list of personnel receiving monthly status report of open NCR's and LER's.
NPPD's 3/2/83 letter did not address the deletion of personnel assigned corrective _ action - this may be an oversight, if not, what mechanism provides the tickler type function? Also, if the general manager is responsible for QA, what. freq. .does he receive this.information?
Response The distribution list for personnel receiving the monthly NCR and LER status report has been corrected to include:
- 1. General Manager
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- 2. Assistant General Manager-Operations
- 3. Personnel assigned corrective action.
- 3. Question Page D-2-13, paragraph 4, refers to ANSI N45-2.9 but does not specify a date for this standard. The previous submittal of the QA program referenced the 1974 standard. Is this an oversight or is the commitment now to the 1979 standard?
Response Paragraph 4 of page D-2-13 has been revised to include the 1974 edition of ANSI N45-2.9. This does not constitute a reduction in the District's QA Program commitment.
4 Question Page D-2-13, paragraph 2.18, references QAI-5 for guidelines for transmitting audit reports. The previous QA program required special personnel to receive audit reports. The QA program is normally the lead document providing commitments for subtier instructions and procedures. If QAI-5 is the used document, it should be furnished with the QA program for NRC review.
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Response Revised paragraph 2.18 of page D-2-13 to 1979 commitment and provided an audit distribution list. This does not constitute
. a reduction in the District's QA Program commitment.
l S. Question Pagcc 0-2-15 and D-2-16, Table I, has had 12 systems deleted that had previously been listed as safety-related. With the l
l exception of the Neutron Source (no longer applicable to CNS),
I the removal of these systems from the safety-related systems i
F L
F-a list has to constitute a reduction in QA commitments. CNS is reviewing this list now. Some of these systems had previously been reviewed (CNS QA Program Amendment 37) and retained on the list. All of the deleted systems should have some level of QA associated with at least portions of each system. If reduction in QA commitment is intended, then this reduction must be addressed along with the rationale for the reduction.
Response Table 1 has been revised to include the systens deleted with the exception of the Neutron Source which is no longer in the Reactor and Reactor Building Closed Cooling Water System which is the same as the Reactor Equipment Cooling System. This does not constitute a reduction in the District's QA Program commitment.
- 6. Question Page D-3-2, paragraph 3.2.2, last sentence, says that the Division Manager of Licensing and QA has a direct line of communication with the Deputy Manager. The organization chart indicates this communication is with the General Manager. Is this an error?
Response This error has been corrected. The Deputy General thnager position was eliminated when the General Manager was replaced in December, 1982. The direct communication line is now with the General Manager. This constitutes an increase in the District's QA Program commitment.
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- 7. Question Page D-4-5 added QAP-2300 and QAP-2400 that were not reflected in Attachment A of NPPD's 3/2/83 letter.
Response Section 4.1.3 of page D.4.5 was revised to include QAP-2300 -
CNS Spent Fuel Campaign and QAP-2400 - Non-Safety Related Reliability Systems. This does not represent or constitute a reduction in the District's QA Program comnitment.
- 8. Question Page D-7-1, items 7.13 and 7.14, indicate 1974 editions of ANSI N45-2.12 and N45-2.13, respectively. The previous program indicated that the latest draft was applicable. The previous OA program was submitted in 1979 and both of these standards - had more recent editors. This needs to be addressed.
Response It has been NPPD's policy to commit to a particular revisien of a given standard at the time of initial commitment to that standard. This is the case for the two ANSI standards mentioned.
i However, later revisions of these standards will be evaluated
- prior to the next formal subnittal of the QA program, and, if found'to be more conservative, will be incorporated.
l This does not change our original QA commitment.
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- 9. Question Section 8 of. Appendix D of USAR addresses numerous standards and Reg. Guides without addressing date or revisioh. Is this intentional?
Response See' response to cuestion 8. Also, please refer to the Table of Contents for Section 8 where Reg. Guides are all identified with a date of revision.
Additional information concerning District's QA Program.
Page d-iv Corrected spelling of Forword.
Page D-4-6 Last sentence under Section 3.3.2 " Station line supervisors changed . reference from CNS-FSAR to CNS-USAR". Does not constitute a reduction in OA Program commitnent.
Page D-4-3 Title of QAI-16 has been changed from " Supplier Qualification"
{ to " Vendor Qualification". Does not constitute a reduction in QA Program commitment.
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. USAR Appendix D - QUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT 2
TABLE OF CONTENTS '
FOREWORD .... . . . . . . . . . . . . .... ... ..... d-iv 1.0 PROGRAM DEFINITION . . . . . . . . . . . . ... ...... . . D-1-1 1.1 Purpose .. . . . . . . . . . . . . . .......... . D-1-1 1.2 Policy . . . . . . . . . . . . . . . ... ....... . D-1-1 1.3 Objectives . . . . . . . . . . . . ........... . D-1-2 1.4 Scope . .. . . . . . . . . . . . . .... ....... . D-1-3 1.5 Definition of Terms . . . . . . . . ........... . D-1-4 2.0
SUMMARY
DESCRIPTION . . . . . . . . . . . .... . .. ... . . D-2-1 2.1 Organization . . . . . . . . . . . .. .. ....... . D-2-1 2.2 Quality Assurance Program . .. . . . . .. ...... . . D-2-3 2.3 Design Control . . . . . . . . . . .. .. ....... . D-2-4 2.4 Procurement Document Control . . . .. . . ...... .. D-2-4 2.5 Instructions, Procedures & Drawings .... . ...... . D-2-5 2.6 Document Control . . . . . .. . . .. .. ........ D-2-6 2.7 Control of Purchased Material, Equipment, and Services . . . . . . . . . . . .... ....... . D-2-6 2.8 Identification and Control of Parts, Materials,
. and Components . . . . . . . . . . . . .. ... ... . . D-2-7 2.9 Control of Special Processes . . . . ... ... .... . D-2-8 2.10 Inspection . . . . . . . . . . . . . ... ... ... . . D-2-8 2.11 Test Control . . . . . . . . . . . .. .. ... ... . . D-2-8 2.12 Control of Measuring Test Equipment . .. . ... ..... D-2-9 2.13 Handling, Storage, and Shipping . . . . .. ...... .. D-2-10 2.14 Inspection, Testing, and Operating Status . ...... . . D-2-10 2.15 Nonconforming Materials, Parts, or Components ..... . . D-2-11 2.16 Corrective Action . . . . . .. . . . ... ... ... . . D-2-12 2.17 Quality Assurance Records . . . . . .... ....... . D-2-12 2.18 Audits . . . . . . , . . . . . . . .. . . ... ... . . D-2-13 i
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. USAR TABLE OF CONTENTS (Cont'd) 3.0 ORGANIZATION AND RESPONSIBILITIES . . . . ............ D-3-1 3.1 General . . . . . . . . . ... ...... . ... .:.. . . .2 b .r . . . sD-3-1 3.2 General Office Management . . . .
- .' . . ......... D-3-1
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3.2.1 Senior Division Manager Power Operations . . . . . ............. D-3-1 3.2.2 Division Manager, Licensing and Quality Assurance . . ....-........ D-3-2 3.2.3 Quality Assurance Manager ... ......... D-3-2 3.2.4 Quality Assurance Staff . ............ D-3-3 3.2.5 Division Manager Power Projects . . . . . . ............ D-3-5 3.2.6 Division Manager Power Operations . . . . . ............ D-3-5 3.3 Cooper Nuclear Station Personnel . . ............ D-3-5 3.3.1 Station Superintendent . . ... ......... D-3-6 3.3.2 Station Line Supervisors . ............ D-3-6 3.4 Safety Review and Audit Board (SRAB) . . . ......... D-3-6 3.5 Station Operations Review Committee (SORC) . . . . . . . . . D-3-7 3.6 Outside Vendors, Contractors, Subcontractors, and Consultants ...... . . . . ... ......... D-3-7 i
4.0 QUALITY ASSURANCE DOCUMENTS . . . . . . . ... ......... D-4-1 4.1 NPPD Internal Documents . . . . . . ... ......... D-4-1 4.1.1 Quality Control Inspection . .. ... ...... D-4-2 4.1.2 Quality Assurance Instructions (QAI) . . ..... D-4-2 4.1.3 Quality Assurance Plans (QAP) . ......... D-4-3 5.0 METHOD OF IMPLEMENTATION . . . . . . . .., .......... D-5-1 l
6.0 RECORDS RETENTION AND DISPOSITION . . . . ... ......... D-6-1 l
7.0 REFERENCES
........ . . . . . . . ............ D-7-1 i
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. USAR TABLE OF CONTENTS (Cont'd.)
8.0 IMPLEMENTATION, WASH-1283, -1284 and -1309 . . . . . . . . . . . D-8-1
. 1 c, 8.1 ANSI N45.2 as endorsed by Regulatory Guide 1.28
.a'D-8-1 a-(6-7-7 2) .ar. -
8.2 ANSI N45.2.1 as endorsed by Regulatory Guide 1.37 (3-16-73) . . .. ..............~....... D-8-2 8.3 ANSI N45.2.2 as endorsed by Regulatory Guide 1.38 .
(3-16-73) . . . ...................... D-8-3 8.4 - ANSI N45.2.3 as endorsed by Regulatory Guide 1.39 (3-16-73) . . . ...................... D-8-4 8.5 ANSI N45.2.4 as endorsed by Regulatory Guide 1.30 (8-11-72) . . . ......................
D-8-5 8.6 ANSI N45.2.5 as endorsed by Regulatory Guide 1.94 (April - 1975) . . . . . . ._. . . . . . . . . . . . . . . . .D-8-6 8.7 ANSI N45.2.6 as endorsed by Regulatory Guide 1.58 (August - 1973) ...................... D-8-7 18 . 8 ANSI N45.2.8 Draft 3 Revision 3 April - 1974 . . . . . . . D-8-8 8.9 ANSI N45.2.9 as endorsed by Regulatory Guide 1.88 (October - 1974 - Revision 2) .. . .. . . . . . . . . . . D-8-8 8.10 ANSI N45.2.10 as endorsed by Regulatory Guide 1.74 (February - 1974) ..................... D-8-9 8.11 ANSI N45.2.11 as endorsed by Regulatory Guide 1.64 (October - 1973) . . . . . . . . . . . . . . . . . . . . . . D-8-9 8.12 ANSI N45.2.12 Draft 3, Revision 4, February - 1974 . . . . . D-8-9 .
8.13 ANSI N45.2.13 Draft 2, Revision 4, April - 1974 . . . . . . D-8-10 8.14 ANSI N18.1 as endorsed by Regulatory Guide 1.8 (03-10-71) . . . ......... . .. . . . . . . . . . . D-8-10 8.15 ANSI N18.7 - 1972 as endorsed by Regulatory Guide 1.33 (11-03-72) . . . .. ....... . ..... . . . . . . . D-8-10 Note: The above ANSI Standards and corresponding Regulatory Guides will serve as the baseline for NPPD commitment to NRC publications . ,
WASH-1283 (5-24-74), WASH-1284 (10-26.73) and WASH-1309 (5-10-74).
Reference to ANSI Standards or Regulatory Guides in the Quality Assurance Program or implementing procedures will apply to the
. revision or issue date as noted above.
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FOREWORD This policy document establishes the policies and practices for Quality
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Assurance to be followed for operation of the Cooper Nuclear Station. Additions, deletions, or modifications to the policies and practices contained herein must have executive approval before such changes can be incorporated into the Quality Assurance Program for Operation.
Copies of this policy document and the Quality Assurance Program shall be serially numbered and shall be issued via a system of controlled distribution which will assure that all copies are maintained up to date at all times.
The Quality Assurance Program documents to implement ' this policy document shall be prepared by Operations, Engineering, Maintenance and Quality Assurance groups in accordance with the policies set forth herein. Additions, deletions, or modifications to that document may be made by the group responsible for its preparation, af ter other groups affected by such change have had a reasonable opportunity to review and comment.
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General Ma ge 4
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USAR COOPER NUCLEAR STATION u QUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT 1.0 PROGRAM DEFINITION - -
In accordance with the conditions'of the Nuclear Regulatory Commission construction permit and operating license for the Cooper Nuclear Station, the management of Nebraska Public Power District recognizes its responsibility for assuring that the Cooper Nuclear Station is designed, constructed, and operated in,such a manner as to provide for the safety of the public. The importance of Quality Assurance in contributing to this safety as well as contributing to station reliability is also recognized.
The initial phases of the overall Quality Assurance Program,
- implemented during design and construction, provided an independent check for the work performed on components, structures, and systems of the station to assure that the design, analysis, materials of construction, manufacture, installation, erection, and construction meet quality standards required to assure reliable and safe operation. The CNS Quality Assurance Program for Operation, as described herein, is implemented to provide an independent quality check on all phases of .
station operation.
1.1 Purpose The purpose of this policy document is to provide a description of the Quality Assurance Program to be followed in the operation of the Cooper Nuclear Station and to provide guidelines for implementation of the policies and procedures described herein. This CNS Quality Assurance Program for Operation '
was developed by Nebraska Public Power District in response to the requirements '
of 10CFR50, Appendix B. This policy document provides a general description of the Quality Assurance Program for Operation and requires that detailed Quality Assurance Procedures be set forth in writing and carried out by each of the responsible organizations or individuals within the District.
1.2 Policy ,
It is the policy of Nebraska Public Power District (NPPD) to use its ,
best efforts to assure that the Cooper Nuclear Station is designed, constructed, '
maintained, and operated in a manner that will provide the highest practical
- degree of safety and reliability. Structures, components, and systems are designed, fabricated, and erected to quality standards appropriate to their importance in the safety function. The Quality Assurance Documents will identify those structures, systems, and components to be covered by the Quality Assurance ;
Program in order to provide continuing compliance with these standards throughout -
the operating life of the station. Additionally, it is the policy of NPPD that activities affecting quality shall be documented by approved instructions, ,
procedures, or drawings and such activities shall be implemented as documented. -
And further, such documentation shall contain adequate qualitative and/or [
quantitative acceptance criteria to provide a measure of accomplishment. [
With regard to assurance of quality in all phases of station operation, it is the policy of Nebraska Public Power District (NPPD) to staff the plant with properly-trained personnel in all responsible positions and job assignments.
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. USAR Sufficient numbers of licensed and senior licensed operating personnel will be available to assure proper operation of the station under all reasonably foreseeable circumstances of. personnel turnover, vacations, disability, and the like.
Supervisory personnel responsible .for- operating Lor, maintaining u- , -
safety-related systems and. equipment shall receive formal instruction in Quality .t Assurance, including basic principles 10CFR50;' Appendix B.~the contents of this policy document, and Quality Assurance documents as applicable.
Trained technical, engineering, and Quality Assurance personnel shall be assigned surveillance and audit tasks to insure compliance with the requirements of the documento which control station operation, such as the NRC license, Safety Analysis Report, Technical Specifications, Operating Manual, QA Program for Operation, and other such controlling documents. Personnel I assignments shall be made by the normal line organization management and will be verified by the QA Department. However, during the time personnel are performing
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QA Functions, they shall be responsible to the QA Department to effect the organizational independence required by the QA Program.
It is the policy of Nebraska Public Power District to maintain quality standards for the entire station which will insure the high degree of reliability ,
and safety needed to meet the overall objectives of supplying dependable electric- /
servicc to its customers.
In summary, NPPD is committed to the continuous development of a Quality Assurance Program which will meet the requirements of 10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and other applicable regulations as may be promulgated by the Nuclear Regulatory ,
Commission. This commitment applies to all NPPD organizations to ass'ure that a high standard of quality will be maintained during nuclear plant operations.
Section 2 of this document presents a summary discussion of the QA Program as applicable to the 18 criteria of 10CFR50, Appendix B.
1.3 Objectives In accordance with the policy statements above, the overall objective (
of the CNS Quality Assurance Program for Operation is to set foi th the Quality 1 Assurance organizational structure and personnel responsibilities and to set l forth guidelines for the preparation of written procedures and controls necessary for quality surveillance and auditing to verify the following:
a) Regulatory criteria, codes and standards, and design bases for l essential safety-related systems (as defined in the CNS QA Program) are
- incorporated into the test, operating and maintenance procedures and instructions ,
l to meet all requirements for nuclear safety and station reliability; l
l b) Components and systems are prepared, calibrated, and preoperationally tested in accordance with approved procedures and instructions prior to nuclear fuel loading and reactor start-up; ,
c) Results of all preoperational tests of essential safety systems and components conform to the requirements of the drawings, specifications, procedures, and instructions, and appropriate reports are prepared to document i that all results of tests meet prescribed acceptance criteria; D-1-2 Revision 0 r,- .-n.- e... -.n._ ,-- g ,_ m -.n , n ,,--e ,._,___..n
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. USAR d) Nuclear Fuel is purchased, designed, manufactured, inspected, ,
packaged, shipped, received, installed, and-operated in the reactor in accordance with approved procedures and instructions, and in compliance with regulatory requirements and license stipulations.
e) The Station is . operated, maintained, tested, refueled nrepaired, ' '
and modified, in accordance with approved procedures and instructions,' and 31n ' ~
compliance with regulatory requirements and ' license stipulations ~and consistent
'with quality standards in effect during design and construction; f) A system is set up and maintained to contro!, safeguard, and permit ready retrieval of quality-related documentation generated for materials and components during the design, fabrication, construction, and operations of CNS.
g) Appropriate and complete reports, records, and logs are initiated and maintained so as to provide a continuing record of quality-related activities associated with station safety and reliability throughout the life of the station.
h) The station personnel are subjected to periodic training, retraining, requalification, and examination such as to maintain and improve their . job skills which are essential to safe and reliable operation of the I station; i) Station security and nuclear fuel accountability and safeguards !
are maintained in accordance with approved procedures and instructions. !
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j) Those nonconformance reports classified as essential shall be properly resolved and are filed in the quality-related record files, j k) Inspection reports issued by NRC are properly resolved and !
documented.
1.4 Scope I
1 The QA Program for Operation applies to those nuclear station l- structures, systems, and components that prevent or mitigate the consequences of l
. postulated accidents which could cause undue risk to the health and safety of the public. The requirements of this program apply to all activities which affect the safety-related functions of those - structures, systems, and components,
! including designing, purchasing, fabricating, handling, shipping, storing, cleaning, - erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service inspection, and modifying, i This program specifically applies to, but is not necessarily limited to the nuclear fuel, the reactor coolant system and its auxiliaries and controls, the reactor protection and engineered safety systems, the reactor containment system, portions of the radioactive waste disposal system, and other systems and components required for safe shutdown of the plant. A tabulation of those structures, systems, and components which are covered by the QA Program is given .
in Table 1. I l I i
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USAR The Quality Assurance activitiesi governing'those structures, systems, and components .shall be generally organized and conducted within the framework of operating activities shown in Section 4.1.3. - m a .
, se on m m :rc :t a2 , . n The Quality Assurancei Criteria in 10CFR50, Appendix B,~are oriented.i;- .
primarily toward engineeringn -manufacturing, rand construction activities.-. m. rm Therefore, it is necessary tor definer by > specific plans and procedures, tthe
manner in which .the NRC Quality Assurance Cr1teria are to be applied to the station operating activities. Such plans and procedures shall be prepared in accordance with the requirements specified in Sections 2.0 and 4.0 of this policy document.
The Specifications, principles, and procedures which controlled the original procurement, fabrication, and construction shall be carried over into the QA aspects of station operation to the greatest extent practicable. It is the intent of NPPD management to maintain, as a minimum, the quality level achieved in the original design and construction. To the extent that different conditions prevail at the time future work is performed, new procedures will be prepared.as necessary and appropriate to accomplish the objectives of this QA Program and to assure that the activities are accomplished in accordance with current requirements if the original requirements were insufficient.
1.5 Definition of Terms Key words and phrases which are-used to characterize this QA Program are defined in a Quality Assurance Instruction (QAI-3) to establish a basis for uniform and consistent interpretation of the Quality Assurance requirements and to pr. ovide some insight into the intent of-these requirements. Definitions of these terms are based upon documents and standards issued by the American National Standards Institute (ANSI), by the NRC Safety and Regulatory Guides, and by the several professional societies involved in standards work (ANS, ASME, IEEE, et al.); or shall be defined on the basis of contemporary usage in the i
nuclear power industry; or shall be defined specifically to convey the intent of this particular program.
To facilitate review and understanding of this policy document, the following basic terms are defined below along with appropriate QA Program requirements.
Quality Assurance All those planned and systematic actions performed for the purpose of establishing a high level of confidence that:
a) Work performed on the project conforms with the requirements of the applicable codes, standards, license stipulations, safety analyses, design
- drawings, specifications, procedures, and instructions; and .
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b) A structure, system, and components will perform satisfactorily in !
service.
The Quality Assurance organization within the District is completely independent from all line-organizations. The NPPD QA Program requires that all personnel performing specific Quality Assurance duties be responsible to the QA organization in order to insure the maintenance of such independence until completion.
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. USAR r N
Quality Control Those activities which deal directly with the measurement, obse rvation, or verification of physical characteristics ot materials, components, or systems which provide a basis for controlling quality to within predetermined limits, or requirements, specifically including adequate quantitative and/or qualitative ,
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acceptance criteria by which an activity can be measured.
Quality Control activities are considered to be inspection activities and are an integral part of the management functions which govern the activities in any given organization. The QA Program requires that controlling documents related to quality-related activities receive QA review to insure incorporation of . quality requirements, including periodic audits, and additionally, that individuals performing quality control activities are other than those actually ,
performing the work.
Quality Assurance Plans Quality Assurance Plans are those documents specifically designed to provide detailed quality requirements for a given functional area. The plans are generated by application. of the 18 criteria of 10CFR50, Appendix B, to each functional area and then deriving the specific quality requirements for that area.
Quality Assurance Ins'tructions Quality Assurance Instructions shall provide . guidelines for surveillance and audit activities of functional areas to be performed by the QA Staff. In addition, where appropriate, they shall define the responsibilities of other CNS organizations for implementation of the QA Program in accordance j with policies and practices herein defined.
Major Design Change A major design change is any permanent change to the facility that requires a Technical Specification change or that may present an unreviewed ,
safety question (10CFR50.59). '
Minor Design Change l A minor design change is any permanent change to the facility judged significant enough to warrant documentation and that does not require a change to l Technical Specifications or present an unreviewed safety question (10CFR50.59).
l Significant Conditions Adverse To Quality l
Any conditions that could affect safety-related system ability to function within design requirements or alter performance characteristics.
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. USAR 2.0
SUMMARY
DESCRIPTION - 10CFR50 APPENDIX B CRITERIA This section defines NPPD commitment to meet the requirements of the 18 criteria of 10CFR50, Appendix B, as it applies to safety-related structures, systems, and components associated.with Cooper Nuclear Station. In addition, it includes NPPD interpretation of the 18 criteria as they apply to an operating nuclear power plant. In the area of Design Control Criterion III, NPPD position on this criteria is oriented towards major and minor. design changes and not the initial design and construction phases.
A comparative cross-reference tabulation of the 18 criteria of Title 10, Code of Federal Regulations, Part 50, Appendix B, against NPPD Quality Assurance program for operation and CNS administrative and work procedures, Power '
Projects Group procedures & instructions are outlined in Table 2 which demonstrates the manner and extent of NPPD compliance with NRC requirements insofar as practicable. l Quality Assurance instructions and plans are tabulated in one column and CNS administrative and work procedures, Power Projects Group procedures &
instructions are listed in a separate column as shown in Table 2.
Significant revisions to Quality Assurance documents shall be subject to the same appropriate review and approval process as the original document before being issued. A controlled distribution will be established for the transmittal of these revised Quality Assurance documents. These revisions shall not change the requirement that NPPD Quality Assurance program for operation to meet the 18 criteria specified in 10CFR50, Appendix B.
Table 1 outlines the safety-related structures, systems, and components ,
covered by the Quality Assurance program.
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2.1 Organization i The General - Manager, through successive levels of management (Figure I), represents the highest level of management for establishment of <
. Quality Assurance policies, goals. and objectives. Specifically, those responsibilities associated with the nuclear facilities have been delegated to l
the-Senior Division Manager of Power Operations and the authority to define and implement the detailed requirements of the Quality Assurance Program. This authority includes the right to direct, enforce, and perform any action required ;
to ensure all activities conducted at Cooper Nuclear Station rr 6 compliance j with 10CFR50, Appendix B. In addition, the personnel assigneo to ae Quality '
t Assurance Department shall have complete independence to perform audits, I
inspections, verifications and shall be independent of those groups performing, i designing, purchasing, fabrication', shipping, storing, cleaning, erecting,
- installing, inspection, testing, operation, maintenance, repairing, refueling.
l in-service inspection and modifying. Figure 1 of the Quality Assurance document
. outlines the QA Department functional organization. Quality Assurance personnel L
shall have sufficient authority and organizational freedom to:
- 1) identify quality problems; I i
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.-. . - . . . - , . . - - - . - - . - - , .-,-, - , _ . - ,-l
FIGURE I m ..;c . i. ,
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r---- General Monoger ,
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1 l
l Asst. G eneral Monoger l Operations
- , \
- j. . .
l I " Senior Division Monoger l Power Operations '
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l
'~~~-~
Division Monoger Licensing & Q. A.
I Licensing & O. A.
Administrative Secretory Quality Assurance Manager
- i 1
l Columbus Q.A. Staff CNS Q. A. Stoff l
- Q.A. Engineers,
- Q.A. Supervisor
- Q.A. Specialist
- Q.A. Specialists (2) l l
- Responsible for Q.A. second level surveillances and third level O.A. audits.
O
Direct Communications m-
I D-2-2 .
,[
m
c:
l \
USAR ,
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- 2) initiate, recommend, or provide solutions for conditions' adverse ' ru - n-to quality;
- 3) verify implementation of solutions. . "- *< ot<"o i a
2.2 Quality Assurance Program. c
_ , , <, .s Implementation of the requirements of the NPPD policy document for QA will require preparation of a body of plans, procedures, and instructions which specifically define the work to be performed and the methods to be used. In preparing these procedures, it is necessary to differentiate between the work procedures and the QA procedures. The District's QA Program will comply with the Quality Assurance guidelines contained in the Orange Book 10-26-73. In those instances involving design, procurement, and installation activities associated with plant modification, design control, procurement control, quality control and quality assurance activities will similarly conform to the guidances provided i within the Gray Book - Wash, 1283- Rev.-1 and the Green Book - Wash, 1309-5-10-75, respectively. Work procedures will be prepared for each important activity of station operation which will clearly define the work to be performed on a step-by-step basis and will identify, where appropriate, the results to be achieved. Mandatory QC or QA inspections or tests will be performed on an independent basis to verify that procedures are being followed (correct results obtained) and will be incorporated into the work procedures directly or by attachment. QA Audit activities, also based on the work procedures, will accomplish the function of verifying that the Quality Control Program is in effect and that QC activities are being carried out as prescribed. ,
l The program shall be implemented in accordance with written, approved I Quality Assurance Plans and the guidelines developed by the Quality Assurance Department.
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Table 1 lists the essential structures, systems, and components associated with Cooper Nuclear Station to be covered by this program. The CNS Operations and Power Projects, with the assistance of the QA Department, will identify essential structures, systems, and components. The Quality Assurance program will provide control over all activities affecting quality of an essential item listed in Table 1 to a degree consistent with their safety-related (
importance. These activities will be governed by approved plans and instructions and these documents shall be followed under controlled conditions. The Quality Assurance documentation will be reviewed periodically to assure that the requirements of the program are being met.
Special process controls, test equipment, tools, skills (training, if required) shall be used during the conduct of inspection, verification and checking activities to assure a high standard of quality and reliability has been ;
obtained on safety-related items covered by the Quality Assurance prograt. Test equipment and special tools will be calibrated against a specified secondary standard.
Designated individuals (which include personnel from CNS Operations.
Power Projects, and/or outside qualified individuals) may be requested to perform j audits and inspections of certain CNS quality-related activities at the direction of the Division Manager of Licensing and Quality Assurance. During these assignments, these individuals will have sufficient organization freedom to identify and recommend corrections for quality deficiencies noted.
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, USAR Services of a qualified consultant in addition-to QA staff personnel are utilized to provide QA indoctrination and on-the-job training for operational personnel and implementation of QA procedures for the QA department, as required. -
In addition, QA Manager and staff members will attend a minimum of one training seminar per year by a qualified agency and/or school. Training for operations personnel is provided by formal sessions conducted by the site QA staff to those
, operators training and/or retraining for NRC licenses. Other operators and maintenance personnel who are involved in safety-related activities.will also be provided training. Training activities will be audited periodically by the QA staff to verify its scope and performance.
2.3 Design Control CNS Administrative Procedure 1.13 and appropriate Power Projects precedures outline the method for identifying, controlling, and implementing any design change within the Cooper Nuclear Station associated with Essential, and Nonessential structures, components, and systems within the primary coolant pressure boundary or accident mitigation or preventing systems. The procedure provides the mechanisn for correctly translating design changes and regulatory requirements into specifications, drawings, procedu'res, and instructions. All design changes initiated at Cooper Nuclear Station will be forwarded to the QA
. Department for review and independent evaluations. All major design changes will be forwarded to Power Projects for interfacing and coordination among participating design organizations. Requirements for prior review and approval for all design changes are specified in CNS Administrative Procedure 1.13 and Power Projects procedures. These evaluations shall review the compatibility of design adequacy with applicable codes, standards, and regulatory requirements.
These design controls apply to items, such as reactor physics, stress, thermal hydraulic and accident analyses, compatibility of materials, accessibility for in-service inspection, maintenance, ' repairs, and delineation of acceptance criteria for inspection and tests. Standard, off-the-shelf items procured for use in Essential systems are subject to review for suitability in the normal I design change review or during review of the procurement docurent by quality assurance and the engineering and/or maintenance departments.
The design change procedure will establish the method of reviews, d interface requirements (with original design organization, if required), j approvals, and the organizations delegated the authority to implement the design change. j When major design char.ges to Cooper Nuclear Station Essential systems, structures, and components are required within the plant, such design changes are
-subject to review and audit by the Safety Review and Audit Board (SRAB) as provided in the Technical Specifications.
_The design-acceptance shall verify or check the design adequacy by calculations methods or suitable qualification testing. Such testing will define l
! test parameters, identification of data to be recorded, the data taker, and l
approval to initiate the test program.
1 2.4 Procurement Document Control
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Cooper Nuclear Station Administrative Procedure 1.11, Power Projects Procedures, Quality Assurance Plans and Instructions- are required to define the applicable requirements, design basis methods, and procedures for procurement of D-2-4 , ,,
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. USAR spare parts, materials, and equipment for essential buclear- systems. These-instructions and procedures shall also include provisions for assuring that the necessary quality requirements are incorporated directly into the purchase order and contracts for essential spare parts. materiair and equipment. These instructions and procedures shall also include provision for assuring that the necessary records are supplied.to the purchaser by the supplier.
The basic principles and practices included in the purchasing procedures are expected to be applicable, in general, to any purchasing activity necessary for operation of the station; however, in the event that procurement is necessary for major modification or repair activities,' some additions may be necessary to provide adequate control.
Procurement procedures presently provide for independent Quality Assurance review of the essential purchasing documents; QA review of bidders lists; QA survey; inspection and qualification of bidders and suppliers; -
engineering and QA; evaluation of engineering and contractor services obtained from outside NPPD; and audit of contractor, vendors and supplier activities.
Change Orders issued on any purchase order will be subjected to the same review and approval as the original order.
In addition, all procurement documents issued on safety-related supplies require that the contractor, vendors, or subcontractors have a Quality Assurance program in accordance with 10CFR50, Appendix B. The Quality Assurance program submitted by a contractor or subcontractor will be audited by NPPD QA to ascertain that they meet the criteria established in 10CFR50, Appendix B.
To the maximum practicable, the as-built drawings and specifications for Cooper Nuclear Station will be utilized in procurement of spare parts, material, and replacement parts.
i Where necessary, because of design modifications, or where it is necessary or desirable to upgrade quality in replacement parts or material, necessary modifications will be made to drawings and specifications to incorporate requirements for currently appropriate quality level. These modifications or upgrading of replacement parts will be accomplished in accordance with approved instructions, procedures, and drawings. These documents i will be subject to SORC review before being implemented.
I 2.5 Instructions, Procedures, and Drawings Quality Assurance activities and other activities which have nuclear safety significance will be prescribed _by documented instructions, drawings, and procedures as appropriate and shall be accomplished in accordance with these instructions, procedures and drawings. These instructions will be sufficiently detailed and explicit so that any supervisor, Quality Assurance inspector, or
, auditor can, by observation, determine whether or not activities are being ,
i satisfactorily accomplished and documented. These documents shall include the l l qualitative and quantitative acceptance criteria necessary to assure satisfactory I completion of the test procedure. Those acceptance criteria should, where j appropriate, require post installation testing prior to returning the component or system to service. Nonroutine maintenance activities on Essential Systems are performed in accordance with Malfunction / Work Request and the required i
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. USAR documentation for special process which includes modification., repair procedures, drawing, etc. , are forwarded routinely to the CNS QA staff 'for review.
2.6 Document Control Administrative control procedures shall be established by the Columbus General Office (G.O.) and Cooper Nuclear Station (CNS) to control the identification, indexing, filing, retention, retrieval, and distribution of quality-related records and documents. Control procedures shall be reviewed and approved by authorized personnel and are distributed to and used at the site of the activity. These procedures shall also ensure that change to quality-related records and documents receive the same level of review and approval as the original document.
Those quality-related records and documents generated and maintained as part of normal station operation will be the responsibility of the CNS Station Superintendent. This responsibility shall also include those quality-related construction records left at CNS by exiting contractors.
The G.O. Records Manager shall be responsible for those quality-related records and documents generated and maintained at the Columbus G.O. This responsibility will include quality-related construction records turned over to the District in accordance with various contractual requirements.
The Records Manager and the CNS Station Superintendent will jointly establish a master list of quality-related documents stored at CNS and the G.O.
This list will be routinely updated by Columbus and CNS document control personnel. The overall objectives of NPPD document control are to:
a) Identify those records and documents which are used to cont ~rol, maintain, modify, or document quality-related activities both at the G.O. and at CNS.
b) Establish an index of quality-related records located at the Columbus G.O. and at CNS so that personnel involved in a safety-related activity can determine which documents are applicable to the activity and whether the documents at hand are of the latest revision.
l l c) Establish a filing system.
d) Establish periods of retention.
e) Establish measures to control distribution and revisions.
The G.O. Records Manager, the CNS Station Superintendent, and the Quality Assurance Department will jointly establish lines of specific responsibility, interfaces, and document control procedures. The requirements established in ANSI N45.2.9 and QAI-7 shall be used in establishing these control l procedures and record storage requirements.
2.7 Control of Purchased Material, Equipment, and Services NPPD receiving inspection instructions provide for determining that all purchased materials, equipment, and services purchased directly or through a contractor, vendor, or subcontractor meet the requirements specified on the original procurement specifications, . such as code,. standards, specifications, D-2-6 Revision 0 l
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. USAR special acceptance testing, material identification, etc." The completed receipt inspection report will become part of the purchase order' package. Procurement documents shall be available at the receiving plant to qualify the receiving inspection.
NPPD procurement instructions provide source evaluation by audit and/or survey of product performance to determine the vendor's quality ~ program effectiveness for their product and their compliance to the applicable 10CFR50 criteria prior to selecting the supplier. These instructions shall describe the methods and techniques used to determine the acceptability of the contractor, vendor, or subcontractor quality assurance program.
The QA Department shall audit and/or survey supplier quality-related activities at intervals consistent with the importance, complexity, and quantity of the item er services during manufacturing and installation to effectively maintain control or quality. Procurement documentation will specify mandatory hold points for witnessing or inspection of purchased materials, equipment, or services if required by NPPD.
Upon receipt at the station, material, parts, and equipment purchased and identified as " Essential" will be placed in a segregated storage area until all inspections are complete and all required certifications and documentation is received. f i
Items in segregated areas will not be issued, by the Station Storekeeper, without the written permission of the Station Superintendent and only then after proper arrangements have been made to assure that necessary steps will be taken to bring all aspects of the particular item into conformance with normal requirements prior to system containing components in " Hold" status being returned to service.
Suppliers of essential equipment shall be required to provide certified documentary evidence that the material supplied conforms to the Purchaee Document '
requirements such as material test report, code required test and inspection, etc. A complete set of Documentation required by the Procurement Document for all essential materials, equipment, and services will be filed at Cooper Nuclear Station.
2.8 Identification and Control of Parts, Materials, and Components To the maximum extent practicable, activities carried out during operation of the Cooper Nuclear Station will comply with the requirements for identification and control of materials, parts, and components as set forth in the as-built drawings and specifications for the station. Where special measures are required to assure proper identification of materials, parts, and components, such requirements will be incorporated directly into the procurement documents for such parts and assemblies. Such identifications which may include heat numbers, serial numbers, or other means of identification of the item will be incorporated on the procurement document to provide means of traceability.
Material received at the station (which has not been properly identified) will be segregated and tagged to indicate a " Hold" status. Except as indicated in Section 2.7 above, such parts will not be issued or used prior to final acceptance. Quality Assurance Instructions and Procedures will incorporate requirements necessary to assure that the identification measures are properly carried out at the station and that unacceptable items will not be used in D-2-7 Revision 0 l
r USAR essential systems and that the Jcomponents to be used in essential systems receive independent verification of ' component identity and applicability prior to installation. -
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2.9 . control of Special: Processes General maintenance procedures will provide for performance of any special processes by qualified personnel using qualified and approved procedures.
Control procedures provide for QA review, inspection and documentation of activities, and for proper integration of QA/QC inspection as necessary. In most cases, the work procedures and the QA Procedures will only be prepared in specific detail when it becomes necessary to apply a specific process in the maintenance, repair, or modification of some portion of the Essential equipment for the station. These procedures shall also require that special processes, such as welding and heat treating, are controlled and completed by qualified i personnel in accordance with qualified procedures, codes, and standards.
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Haintenance modification control methods and Station Operating procedures are reviewed by QA personnel and such review includes verification that necessary Codes, Standards, Quality requireneitts, and acceptance criteria are incorporated to control special processes within the limits necessary for satisfactory accomplishment of design objectives.
2.10 Inspection l Inspection of activities affecting quality (Quality Control) has been
, assigned in this policy document to the organization basically responsible for the performance of the activity. However, personnel assigned to inspection activities will be persons other than those directly involved in the actual performance of the work in accordance with ANS1 N45.2. Quality Assurance audits and surveillance of activities such as maintenance, repair, a modifications -
wi'l include direct inspection; whereas operating functions will be monitored indirectly by observation and examination of individual operating personnel and documentation at intervals consistent with importance of the activity. Direct QA '
or QC inspection will also be made of activities involved in refueling, .
radiochemistry, and environmental monitoring. In many of these activities there will be specific hold points designated for which independent inspections are to f be performed prior to proceeding to the next step of the work. All inspection
! and hold points will be incorporated directly into the work procedures. Special l
inspections, such as those involved in nondestructive examinations and in-service i inspections, will be contracted to qualified vendors. Where appropriate, inspections following work activities should include tests of the component or j system.
Checklists shall be used during inspection activities to verify that '
instructions, procedures, and drawings have been adhered to. The results of ,
V these inspections will be placed in the CNS permanent plant record file. If direct inspection is impossible,' indirect control methods will be specified in i the instructions to provide a method of monitoring process methods and equipment. (
l 2.11 Test Control Each type of test program carried out by the station operating group will be defined by written procedures and instructions. These test programs i include the preoperational tests, start-up test instructions, operational testing l r D-2-8 Revision 0 l
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o .- USAR and , surveillance testing of sttuctures, systems, and components .to demonstrate their capability to perform satisfactorily as a part of an integrated system.
Test programs will be developed for structures, systems, and components to demonstrate their capability to perform satisfactorily following repairs or modification prior to returning to service. Each of these test programs will' be covered by a Test Program Description which identifies organizational responsibilities and methods for controlling interfaces between organizations.
Test procedures will identify the inspector, test performance, and data recorder.
Each type of test program has individual test procedures which include Quality Control provisions, acceptance criteria, and check points observation or checking of important aspects, such as prerequisite conditions for tests or results. In addition, test procedure prerequisites will specify the test instrumentation requirements, environmental conditions, and licensed or certified personnel. All special test procedures, special maintenance procedures, and station operating procedures are routinely reviewed by SORC, of which QA is a member.
Each type of test program will be covered by a Quality Assurance Plan (See Section 2.2 above). Quality Assurance audit activities will be carried out by the station Quality Assurance Staff to assure that tests are being performed in accordance with the requirements of the procedures and that results are evaluated and compared to the limits prescribed for acceptance criteria. In addition, test procedures shall specify test requirements and quantitative and qualitative acceptance criteria where appropriate.
2,12 Control of Measuring and Test Equipment Work procedures shall define the requirements of inspection, maintenance, repair and calibration of all tools, gauges, instruments, and other measuring and testing devices which are used in connection with activities which affect quality of safety-related equipment.
Each instrument, tool, or measuring device necessary for the essential function of Essential systems has been identified (Tech Specs) and placed on a regularly-scheduled program of inspection, test, and recalibration. All test and measuring equipment utilized in calibration of the above process equipment will be tagged with a calibration sticker which shows the date of last calibration and initials of the technician who perforned the calibration. Calibration logs will be maintained to further document in detail the performance and history of calibration activities on essential equipment and systems. These ' logs and histories will be reviewed, as required, to evaluate the calibration performance and frequency, and measures will be taken to make such changes in calibration frequency and procedure as may be necessary.
A Quality Assurance Plan will prescribe the QA functions to be carried out relative to the calibration program. Quality Control and Quality Assurance practices will require independent checks on the calibration activities and will provide for Quality Assurance Surveillance by the station QA staff to assure that procedures are being properly carried out, that adequate records of calibration and testing of measuring equipment are being generated, maintained, and that regularly scheduled adjustments are made to maintain necessary accuracy. For
! equipment used to calibrate process equipment, procedures will define action to be taken should regularly-scheduled calibration checks reveal an out of specification condition exists. As a minimum, a nonconformance report will be issued when any measuring or test equipment used for inspection, test, or j calibration of an essential process equipment is found out of calibration.
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. USAR Resolution of this NCR requires that an investigation be performed to determine the validity of the inspection, test, or calibration performed utilizing the nonconforming measuring or test equipment. Reference and transfer standards, ant traceable to the National Bureau of Standards for. the calibration of applicable .u.
instrument at the CNS, will be maintained at CNS.
Scheduled or unannounced audits by the Quality Assurance Department, the Safety Review and Audit Board, or NPPD management will include review of the calibration program.
2.13 Handling, Storage, and Shipping The work procedures for procurement and control of Essential spare parts, materials, replacement parts, and equipment will include the necessary requirements to control handling, cleaning, shipping, receiving, and storage of Essential parts and material. The Quality Assurance Procedures and Instructions include provisions for inspection and audit activities to assure that these.
procedures are followed and that Essential parts and materials maintained at the station are received, inspected, stored and controlled in such a manner as to prevent degradation. The Station Storekeeper has the responsibility for carrying out all the requirements specified by the approved station procedures to assure that specific QA/QC requirements are met.
I 2.14 Inspection, Te.st , and Operating Status A system of tagging (colored) was instituted during the construction of the Cooper Nuclear Station for the purpose of indicating the status of operation and custody of each item of equipment or system. The practice of custody tagging ,
and safety tagging is an established aspect of safe and orderly operation at !
NPPD. The NPPD status tagging procedure, already in use throughout the syst'em, ;
has been adapted for use in the Cooper Nuclear Station. Where practical, ;
particular emphasis shall be placed on tagging to prevent unauthorized operation or adjustment which could endanger the safety of personnel, damage equipment, or l invalidate the results of tests already performed. In addition, these tags shall indicate abnormal equipment test and inspection status and reference special instructions for equipment located throughout the Cooper Nuclear Station. !
Tagging procedures, where necessary, will require that equipment be tagged and that the associated power supplies, starters, switches and controls on the main control panel be tagged as well to warn against operation. In'some cases, power supplies will be disconnected and tagged to prevent inadvertent operation. Tagging will be controlled by the shift supervisor by requiring that serially-numbered tags, obtained from the control room, be used for all tagging purposes. Records will be maintained in the control room to enable operators and shift supervisors to determine the-status of-the equipment tagged. !
A jumper log will be maintained to provide a method for recording the !
installation and removal of jumpers, fuses, or wire terminal disconnections. j This record will include the location, reason, name of person authorizing action, I and name of person performing the installation.
l Requirements for tagging are -included in all work procedures, and status tagging will be one of the aspects of the work that will be checked by QAP-200.
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USAR 2.15 Nonconforming Materials, Parts, or Components Work procedures for control of ' the storeroom and for control of maintenance activities provide for identificationi and ; tagging of materials, parts, or components which do not conform to requirements (See Section 2.8).
The NCR form of Administrative Procedure 1.10 shall be used by all persons performing operation, maintenance, and quality control functions to record and report:
(a) Deviations from approved procedures; (b) Nonconforming materials, parts, or components received from outside suppliers on essential purchase orders; (c) Nonconforming materials, parts, or components within the plant; (d) Nonconforming materials brought on site without following established receiving and inspection procedures; (e) Orders or recommendations to stop work; (f) Reportable occurrences; f (g) Any other deficiency which violates the intent of the Quality Assurance Program and which could have a significant adverse effect on quality; (h) Deviations which could be reportable under 10CFR21.
A separate report shall be prepared fbr each nonconformance. The intent of this separate report requirement is to simplify follow-up, corrective action, and record keeping. A complete log of all assigned NCR's shall be maintained by the CNS QA staff.
Nonconforming items will be isolated and controlled in such a way as to
- prevent their inadvertent use or installation. Such parts will be reinspected and reviewed for adequacy prior to returning them to the manufacturer, scrapping them, or arranging for them to be reworked to conform. Disposition of a nonconforming item will be determined by the responsible supervisor in conjunction with the QA Staff. Written reports of decisions to repair or rework Essential items will be reviewed and approved in accordance with maintenance and/or design control procedures. ;
Any decision to reduce requirements, to permit use of nonconforming j parts, materials, or components in Essential systems, will be treated as a design j modification and will be subject to the same review and approval process as the original.
Approved Procedures will be utilized for repair and rework of Essential ;
parts and equipment. All such rework will be thoroughly documented, including Quality Control and Quality Assurance Surveillance activities, to assure conformance with the requirements of the specifications, procedures, and other controlling documents.
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. USAR Any item of Essential 3quipment which is , classified as scrap-will be r identified and segregated in such 'a manner to prevent inadvertent use or installation in an essential system.
The QA Department twill compile an : essential nonconformance report J quarterly to enable the Division Manager of Power Operations to establish adverse ~
trends and implement.the appropriate corrective action.
2.16 Corrective Action NRC Regulations which require formal reporting to the NRC of failures, malfunctions, deficiencies, unusual operating experiences, and deviations which may have a significant effect on quality or safety will be reviewed and evaluated by the Station Operations Review Committee and, where appropriate, by the Safety Review and Audit Board on a regular basis. It will be the responsibility of the station personnel. to identify and promptly correct all such deficiencies or t
malfunctions either by improved maintenance, repairs, replacements, or modification. In any case the objective and the corrective action will not only be to correct the existing defect or deficiency, but also to include measures to
, prevent repetition of similar failures elsewhere in the station. Quality Control and Quality Assurance Procedures will provide for inspection and monitoring of corrective action to assure that all such corrective action is performed in accordance with approved written procedures and that the details of the corrective action are properly documented for the permanent station records.
l Quality Assurance Instructions provide a means of prescribing how
- nonconformance reports are to be resolved and by whom; and prescribe the manner in which corrective action is to be documented, reviewed, and accepted. The nonconformance report system is designed as a closed loop system, with completion of corrective action required for closure. In addition, all NCR's written to document Licensee Events shall require QA verification of corrective action before closure.
A monthly status report of open NCR's and LER's shall be prepared by i the CNS QA Staff and routed to the following:
General Manager l Assistant General Manager - Operations Senior Division Manager - Power Operations Division Manager - Power Operations Division Manager - Power Projects Division Manager - Licensing and Quality Assurance Quality Assurance Manager Station Superintendent CNS Department Supervisors ;
Personnel Assigned Corrective Action 2.17 Quality-Assurance Records
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All activities having a significant effect on quality and safety will be thoroughly documented, and all such documentations will be incorporated into the CNS permanent record files. Work procedures and Quality. Assurance Instructions and Plans will also require appropriate physical storage facilities and personnel to maintain these files. Record identification, storage.
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USAR retrieval, access, control, retention, and safeguarding of all such station >
records will be with approval procedures. The CNS permanent record files will consist of all records accumulated during~ engineering and construction plus the records generated during station operation and maintenance as defined in the CNS Technical Specifications. These records shall also include qualification of personnel and status of equipment and procedures. Inspection and test records shall identify the inspector, data taker, method of observation, results, acceptance, and all nonconformance reports used to document nonconformances.
Administrative control of' the files and/or records shall include methods for changing records. Such changes to as-built drawings, operating logs, and the like, must provide clear identification of the change and must be initialed and dated by the person making the change and by persons authorized to approve such changes. ;
i The program will include Audits of CNS and Columbus record files to assure that the procedures and controls are properly implemented. The G.O.
Records Manager and Station Superintendent will prepare detailed procedures for incorporating material into the files and for making decisions on removal and disposal of outdated or superseded material from the files.
The provisions of ANSI N45.2.9-1974, " Requirement for Collection.
Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants" l shall be used for management, retention, and storage of CNS quality-related records.
2.18 Audits Quality Assurance Plans for each principal segment of the station operating activities have been or will be prepared. These QA Plans will identify the nature and extent of Quality Assurance Audit activities which are to be carried out by or under the direction of higher echelons of management. Primary audit responsibility is assigned to the Quality Assurance Manager. Audits under the direction of the Quality Assurance Manager (working with the Safety Review and Audit Board as referenced in Section 3.4) will be conducted according to the QA Plans to verify compliance with the Quality Assurance Program. Audits shall be performed in accordance with written instructions or checklists and conducted l by trained personnel not responsible for areas being audited. Quality Assurance plans and instructions provide a method of determining the effectiveness of the .
Quality Assurance Program implemented for Cooper Nuclear Station. In addition, L other members of the NPPD Executive Management staff in either Power Operations l
-or Power Projects may audit or request audits of specific activities of !
particular concern to them. However, all such audits will necessarily be coordinated in such a way as to avoid unnecessary interference with the operating activities at the station. It is expected that some unannounced audits will be conducted, particularly with regard to those operating activities such as ,
emergency procedures and operator qualifications. Upon completion of the audit, I a formal report will be prepared by the auditor and transmitted to the !
organization audited. All nonconformances identified as a result of these audits l will be documented and appropriate follow-up action will be taken to assure that !
corrective action has been implemented. Follow-up action, including reaudits of I any identified nonconformance area and verification of corrective action, shall I be fully documented and transmitted in the same manner as the original audit.
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.- USAR Audit summary reports shall be transmitted to the following:
a) General Manager b) Assistant General k nager - Operations c) Senior Division Manager --Power Operations d) Division knager - Power Operations e) Division k nager - Licensing and Quality Assurance f) Quality Assurance Manager i
g) Manager Directly Responsible for the Activity l I
h) Division Manager (if affected) e i) QA Record Files ,
Section 4.0 of ANSI 18.7-1972 " Administrative Control:s for Nuclear Power Plants" will be used as a guideline for scheduling and conducting audits.
Further provisions for establishing audit frequency and the audit schedule are described in the Quality Assurance Instructions (QAI-12). The guidelines are flexible to allow frequency adjustment based on audit results.
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TABLE 1 l
$AFETY-RELATED (ESSENTIAL) SYSTEMS COVERED BY THE- QUALITY ASSURANCE PROGRAM
- 1. Nuclear Steam Supply System
- a. Reactor Primary Vessel .
- b. Reactor Primary Vessel Supports ,
- c. Control Rods and Drive System equipment necessary for Scram Operation
- d. Control Rod Drive Housing
- e. Fuel Assemblies
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- f. Core Shroud
- g. Steam Dryer
- h. Steam Separator II. Reactor Coolant Systems
- b. HPCI - High Pressure Coolant Injection System
- c. LPCI - Low Pressure Coolant Injection System
- d. CS - Core Spray System
- e. RCIC - Reactor Core Isolation Cooling III. Reactor Protection and Engineered Safeguard Systems
- b. Rod Sequence Control System
- d. Standby Gas Treatment
- e. Diesel Generators
- f. Electrical Aux Power
- 1. Critical 4160 V Equipment '
- 2. Critical 480 V Equipment-
- g. Neutron Monitoring Systems x 1. APRM
- 4. RBM
- 5. SRM
- h. DC Power Supply
- 1. Nuclear Systen Leak Detection
- j. Containment Isolation System l
- k. Nuclear Boiler and Related Instrumentation I
- m. Rod Position Indicator D-2-15 Revision 0 1
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. USAR TABLE 1 (Cont'd) y _ , .;.. ,
IV. Nuclear Fuel Systems
- a. Refueling Interlocks for Fuel Handling and Vessel Servicing Equipment
- b. Fuel Pool Liner and Gates
- c. Fuel Pool Cooling and Cleanup V. Radioactive Waste Disposal Systems
- a. Process Radiation Monitoring. System .
- 1. Off-Gas Vent Pipe Radiation Monitoring I
- 2. Off-Gas Monitoring
- 3. Aug Off-Gas Monitoring
- 4. Main Steam Line Monitoring
- 5. Reactor Building Vent Monitoring (GE)
- 6. Drywell and Suppression System Leak Rate
- 7. Liquid Process Radiation Monitoring VI. Other Essential Support Systems
- a. Reactor Equipment Cooling
- c. Emergency Bypass Function on Control Room Heating, Vent, and AC .
- d. Reactor "ecirculating (Pressure Retaining Parts Only) I
- e. Class I, II, and III Code Items
- f. Reactor Feed Pumps (Pressure Retaining Parts Only)
- g. Reactor Building H&V VII. Structures (Seismics)
- a. Reactor Building j b. Control. Building l c. Elevated Release Point
- d. Intake Structure
- e. Diesel Generator Building
- f. Radwaste Building (Below Grade) j i
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l NOTE: Even though a system is classified as ESSENTIAL, each individual h component within that system may or may not be Essential.
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. USAR TABLE 2 10CFR50 Appendix B - Cross-Reference Tabulatien 10CFR50 Appendix B
Criterion Program Procedures Procedures I. ORGANIZATION (ANSI N45.2 Section 3)
The applicant shall be responsible for QAI-01 A.P. 1.2 the establishment and execution of the quality QAI-02 A.P. 1.3 assurance program. The applicant may delegate QAI-03 A.P. 1.4 to others, such as contractors, agents, or QAI-04 A.P. 1.5 consultants, the work of establishing and QAI-05 A.P. 1.6 [
executing the quality assurance program, or QAI-06 A.P. 1.7 any part thereof, but shall retain responsibil- QAI-07 A.P. 1.8 ity therefor. The authority and duties of QAI-08 A.P. 1.9 persons and organizations performing activities QAI-09 A.P. 1.10 affecting the safety-related functions of QAI-10 A.P. 1.11 structures, systems, and components shall be QAI-11 A.P. 1.12 J
clearly established and delineated in writing. QAI-12 A.P. 1.13 These activities include both the performing QAI-13 A.P. 1.14 functions of attaining quality objectives and QAI-14 A.P. 1.15 the quality assurance functions. The quality QAI-15 A.P. 1.16 ,
assurance functions are those of (a) assuring QAI-16 A.P. 1.17 l that an appropriate quality assurance program A.P. 1.18 j is established and effectively executed and QAP-100 A.P. 1.19 ;
(b) verifying, such as by checking, auditing, QAP-200 A.P. 1.20 and inspection, that activities affecting the QAP-300 A.P. 1.21 l safety-related functions have been correctly QAP-400 A.P. 1.22 performed. The persons and organizations QAP-500 A.P. 1.23 performing quality assurance functions shall QAP-600 A.P. 1.24 have sufficient authority and organizational QAP-700 A.P. 1.25 freedom to identify quality problems; to QAP-800 A.P. 1.26 i l initiate, recommend, or provide solutions; and QAP-900 A.P. 1.27 f to verify implementation of solutions. Such QAP-1000 )
persons and organizations performing quality QAP-1100 assurance functions shall report to a manage- QAP-1200 ment level such that the required authority QAP-1300 and organizational freedom, including suffi- QAP-1400 cient independence from cost and schedule when QAP-1500 .
opposed to safety considerations, are provided.
QAP-1600 Because of the many variables involved, such QAP-1700 as the number of personnel, the type of activity QAP-1800 being performed, and the location or locations QAP-1900 where activities are performed, the organiza- QAP-2000 tional structure for executing the quality QAP-2100 '
assurance program may take various forms QAP-2200 provided that the persons and organizations assigned the quality assurance functions have 1 i
this required authority and organizational i freedom. Irrespective of the organizational structure, the individual (s) assigned the D-2-17 Revision 0
- USAR TABLE 2 (Cont'd) 10CFR50 Appendix B - Cross-Reference Tabulation 10CFR50 Appendix B CNS QA CNS Admin. Admin.
Criterion -Program Procedures Procedures I. ORGANIZATION (CONT'D) responsibility for assuring effective execu-tion of any portion of the quality assurance program at any location where activities subject to this Appendix are being performed '
shall have direct access to such levels of ;
management as may be necessary to perform this function.
II. QUALITY ASSURANCE PROGRAM (ANSI N45.2 Section 2)
The applicant shall establish at the FSAR Amend A.P. 1.2 NEP -01 earliest practicable time, consistent with the 39 (Policy A.P. 1.3 NEP-04 schedule for accomplishing the activities, a Doc.) A.P. 1.4 NEP-07 quality assurance program which complies with QAI-01 A.P. 1.5 NEP-08 the requirements of this appendix. This pro- QAI-02 A.P. 1.6 NEP-10 gram shall be documented by written policies, QAI-03 A.P. 1.7 NEP-12 procedures, or instructions and shall be QAI-04 A.P. 1.8 NEP-13 carried out throughout plant life in accord- QAI-05 A.P. 1.9 NEP-15 ance with those policies, procedures, or QAI-06 k.P. 1.10 NEP-16 instructions. The applicant shall identify QAI-07 A.P. 1.11 NEP-22 the structures, systems, and components to be QAI-08 A.P. 1.12 covered by the quality assurance program and QAI-09 A.P. 1.13 the major organizations participating in the QAI-10 A.P. 1.14 program, together with the designated func- QAI-11 A.P. 1.15 tions of these organizations. The quality QAI-12 A.P. 1.16 assurance program shall provide control over QAI-13 A.P. 1.17 activities affecting the quality of the QAI-14 A.P. 1.18 identified structures, systems, and components QAI-15 A.P. 1.19 to an extent consistent with their importance QAI-16 A.P. 1.20 to safety. Activities affecting quality shall QAI-17 A.P. 1.21 be accomplished under suitably-controlled A.P. 1.22 conditions. Controlled conditiens include the QAP-100 A.P. 1.23 use of appropriate equipment; suitable environ- QAP-200 A.P. 1.24 mental conditions for accomplishing the QAP-300 A.P. 1.25 activity, such as adequate cleanness; and QAP-400 A.P. 1.26 assurance that all prerequisites for the given QAP-500 A.P. 1.27 activity has been satisfied. The program QAP-600 shall take into account the need for special QAP-700 controls, processes, test equipment, tools, QAP-800 and skills to attain the required quality and QAP-900 the need for verification of quality by inspec- QAP-1000 tion and test. The program shall provide for QAP-1100 indoctrination and training of personnel QAP-1200 performing activities affecting quality as QAP-1300 D-2-18 Revision 0 l
l
, USAR TABLE 2 (Cont'd) 10CFR50 Appendix B - Cross-Reference Tabulation 10CFR50 Appendix B CNS QA CNS Admin. Admin.
. Criterion Program Procedures Procedures II. QUALITY ASSURANCE PROGRAM (CONT'D) necessary to assure that suitable proficiency QAP-1400 is achieved and maintained. The applicant QAP-1500 shall regularly review the status and adequacy QAP-1600 of the quality assurance program. Management QAP-1700 of other organizations participating in the QAP-1800 quality assurance program shall regularly QAP-1900 review the status and adequacy of that part of QAP-2000 the quality assurance program which they are QAP-2100 executing. QAP-2200 III. DESIGN CONTROL (ANSI N45.2 Section 4)
Measures shall be established to assure QAI-03 A.P. 1.13 NEP-11 that applicable regulatory requirements and QAI-04 A.P. 1.18 the design basis, as defined in 50.2 and as QAI-05 A.P. 1.19 ,
specified in the license application, for QAI-07 A.P. 1.24 ;
those structures, systems, and components to QAI-04 I which this appendix applies are correctly QAI-11 translated into specifications, drawings, QAI-13 d procedures, and instructions. These measures I shall include provisions to assure that QAP-800 appropriate quality standards are specified ,QAP-1000 and included in design documents and that QAP-1700 deviations from such standards are controlled. QAP-1800 Measures shall be established for.the selec- QAP-2200 tion and review for suitability of application l of materials, parts, equipment, and processes l that are essential to the safety-related functions of the structures, systems, and components.
Measures shall be established for the identification and control of design inter-faces and for coordination among participating i
design organizations. These measures shall <
include the establishment of procedures among I participating design organizations for the review, approval, release distribution, and revision of documents involving design inter- I faces. 1 The design control measures shall provide for verifying or checking the adequacy of l design such as by the performance of design ;
l reviews by the use of alternate or simplified
- calculational methods, or by the performance i
D-2-19 Revision 0 l
h k
USAR TABLE 2 (Cont'd) -
10CFR50 Appendix B - Cross-Reference Tabulation 10CFR50 Appendix B CNS QA r"CNS Admin. : Admin.
Criterion Program Procedures Procedures III. DESIGN CONTROL (CONT'D) of a suitable testing program. The verifying or checking process shall be performed by individuals or groups other than those who performed the original design, but who may be from the same organization. Where a test program is used to verify the adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualification testing of a prototype unit under the most adverse design conditions. Design control measures shall be applied to items such as the following:
reactor physics, stress, thermal, hydraulic, and accident analyses; compatibility of mate-rials; accessibility for in-service inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and tests.
Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the origi-
- nal design and be approved by the organization that performed the original design unless the applicant designates another responsible organization.
IV. PROCUREMENT DOCUMENT CONTROL (ANSI N45.2 Section 5)
Measures shall be established to assure QAl-09 A.P. 1.11 NEP-10 that applicable regulatory requirements which .QAI-13 A.P. 1.13 NEP-15 are necessary to assure adequate quality are QAI-16 suitably included or referenced in the docu-ments for procurement of material, equipment, QAP-400 and services, whether purchased by the appli- 'QAP-800 cant or by its contractors or subcontractors. QAP-900 To the extent necessary, procurement documents QAP-1400 shall require contractors or subcontractors to QAP-1600 provide a quality assurance program consistent QAP-1700 with the pertinent provisions of this appendix. QAP-1800 D-2-20 Revision 0
E USAR TABLE 2 (Cont'd) 10CFR50 Appendix B - Cross-Reference Tabulation 10CFR50 Appendix B R CNS QAt CNS Admin. Admin.
Criterion Program Procedures Procedures V. INSTRUCTIONS, PROCEDURES, AND DRAWINGS (ANSI N45.2 Section 6)
Activities affecting quality shall be All QAI's All Admin. All NEP's prescribed by documented instructions, proce- Procedures dures, or drawings, or a type appropriate to All QAP's the circumstances, and shall be accomplished in
, accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantita-tive or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
V1. DOCUMENT CONTROL (ANSI N45.2 Section 7)
Measures shall be established to control QAI-01 A.P. 1.3 NEP-01 the issuance of documents, such as instruc- QAI-02 A.P. 1.4 NEP-08 tions, procedures, and drawings, including QAl-07 A.P. 1.12 NEP-12 changes thereto which prescribe all activi- QAI-13 A.P. 1.15 ties affecting quality. These measures shall A.P. 1.18 assure that documents, including changes, are All QAP's A.P. 1.19 reviewed for adequacy and approved for release A.P. 1.20 by authorized personnel and are distributed A.P. 1.22 to and used at the location where the pre- A.P. 1.24 scribed activity is performed. Changes to A.P. 1.26 documents shall be reviewed and approved by the same original review and approval unless the applicant designates another responsible organization.
VII. CONTROL OF PURCHASED MATERIAL, EQUIP-MENT, AND SERVICES (ANSI N45.2 Section 8)
Measures shall be established to assure QAI-09 A.P. 1.11 NEP-13 that purchased material, equipment, and QAI-13 NEP-15 services, whether purchased directly or QAI-16 through contractors and subcontractors, conform to the procurement documents. These QAP-400 measures shall include provisions, as appro- QAP-900 priate, for source evaluation and selection, QAP-1400 objective evidence of quality furnished by QAP-1500 the contractor or subcontractor, inspection QAP-1700 at the contractor or subcontractor source,. QAP-1800
, and examination of products upon delivery.
D-2-21 Revision 0
. USAR i
TABLE 2 (Cont'd) 10CFR50 Appendix B - Cross-Reference Tabulation 10CFR50 Appendix B '
- Criterion Program Procedures Procedures VII. CONTROL OF PURCHASED MATERIAL, EQUIP-MENT, AND SERVICES (CONT'D)
Documentary evidence that material and equipment conform to the procurement require-ments shall be available at the nuclear power ,
plant site prior to installation or use of such material and equipment. .This documen-tary evidence shall be retained at the nuclear power plant site and shall be sufficient to identify the specific requirements, such as codes, standards, or specifications, met by the purchased material and equipment. The effectiveness of the control of quality by contractors and subcontractors shall be ,
assessed by the applicant or designee at j intervals consistent with the importance, !
complexity, and quantity of the product or .
services. l f
VIII. IDENTIFICATION AND CONTROL OF MATERIALS, f PARTS, AND COMPONENTS !
i (ANSI N45.2 Section 9)
Measures shall be established for the QAP-200 A.P. 1.6 identification and control of materials, QAP-300 A.P. 1.7 parts, and components, including partially QAP-400 A.P. 1.11 fabricated assemblies. These measures shall QAP-600 A.P. 1.14 .
assure that identification of the item is QAP-700 A.P. 1.15 maintained by heat number, part number, QAP-900 A.P. 1.17 serial number, or other appropriate means, QAP-1000 either on the item or on records traceable to QAP-1100 the item as required throughout fabrication, QAP-1200 erection, installation, and use of the item. QAP-1300 These identification and control measures QAP-1400 shall be designed to prevent the use of QAP-1500 incorrect or defective material, parts, and QAP-1600 components. QAP-1700 QAP-1800 QAP-1900 ;
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- e. g a
USAR TABLE 2 (Cont'd) 10CFR50 Appendix B - Cross-Reference Tabulation 10CFR50 Appendix B CNS QA CNS Admin. Admin.
Criterion Program Procedures Procedures IX. CONTROL OF SPECIAL PROCESSES (ANSI N45.2 Section 10)
Measures shall be established to assure QAI-04 A.P. 1.6 that special processes, including welding, QAI-05 A.P. 1.7 heat treating, and nondestructive testing, QAI-06 A.P. 1.17 are controlled and accomplished by qualified QAI-13 personnel using qualified procedures in QAI-16 accordance with applicable codes, standards, specifications, criteria, and other special QAP-700 requirements. QAP-800 QAP-1100 QAP-1500 QAP-1600 QAP-1700 QAP-1800 X. INSPECTION (ANSI N45.2 Section 11)
A program for inspection of activities QAI-11 A.P. 1.4 affecting quality shall be established and A.P. 1.6
- executed by or for the organization per- QAP-200 A.P. 1.7 forming the activity to verify conformance QAP-300 A.P. 1.9 with the documented instructions, procedures, QAP-400 A.P. 1.11 and drawings for accomplishing the activity, QAP-500 A.P. 1.13 Such inspection shall be performed by indi- QAP-600 A.P. 1.16 viduals other than those who performed the QAP-700 A.P. 1.17 activity being inspected. Examinations, QAP-800 A.P. 1.19
. measurements, or tests of material or pro- QAP-900 A.P. 1.22 -
ducts processed shall be performed for each QAP-1000 work operation where necessary to assure QAP-1100 quality. If inspection of processed material QAP-1200 or products is impossible or disadvantageous, QAP-1400
, indirect control by monitoring processing QAP-1500
! methods, equipment, and personnel shall be QAP-1600 provided. Both inspection and process moni- QAP-1700 toring shall be provided when control is QAP-1800 inadequate without both. If mandatory QAP-2000 inspection hold points, which require witness- QAP-2100 ing or inspecting by the applicant's designated representative and beyond which work shall not D-2-23 Revision 0
e s d USAR TABLE 2 (Cont'd) 10CFR50 Appendix B - Cross-Reference Tabulation 10CFR50 Appendix B CNS QA CNS Admin. Admin.
Criterion Program Procedures Procedures X. INSPECTION (CONT'D) proceed without the consent of its designated representative are required, the specific hold points shall be indicated in appropriate documents.
XI. TEST CONTROL (ANSI N45.2 Section 12)
A test program shall be established to QAI-04 A.P. 1.9 NEP-10 assure that all testing required to demon- QAI-05 A.P. 1.12 strate that structures, systcas, and compo- QAI-07 A.P. 1.13 nents will perform satisfactorily in service QAI-09 A.P. 1.16 is identified and performed in accordance QAI-12 A.P. 1.17 with written test procedures which incorpo-rate the requirements and acceptance limits QAP-200 contained in applicable design documents. QAP-400-The test program shall include, as appro- QAP-500 priate, proof tests prior to installation, QAP-600 preoperational tests, and operational tests QAT-700 during nuclear power plant operation of QAP-800 structures, systems, and components. Test QAP-900 j procedures shall include provisions for QAP-1000 j assuring that all prerequisites for the given QAP-1100 test have been met, that adequate test instru- QAP-1200 mentation is available and used, and that the QAP-1400 I test is performed under suitable environmental QAP-1500 l conditions. Test results shall be documented QAP-1600
- and evaluated to assure that test requirements QAP-1700 have been satisfied. QAP-1900
( QAP-2100 l QAP-2200 i
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l D-2-24 Revision 0 l
o 4 USAR l
TABLE 2 (Cont'd).
10CFR50 Appendix B - Cross-Reference. Tabulation 10CFR50 Appendix B CNS QA CNS Admin. Admin.
Criterion Program - Procedures Procedures XII. CONTROL OF MEASURING AND TEST EQUIP-MENT (ANSI N45.2 Section 13)
Measures shall be established to assure QAI-04 A.P. 1.7.2 that tools, gages, instruments, and other QAI-05 A.P. 1.9 measuring and testing devices used in activi- QAI-07 ties affecting quality are properly con-trolled, calibrated, and adjusted at speci- QAP-200
, fied periods to maintain accuracy within QAP-300 ,
necessary limits. QAP-400 QAP-600 QAP-700 QAP-900 QAP-1000 QAP-1100 QAP-1200 QAP-1400 QAP-1500 QAP-1600 QAP-1700 QAP-1800 QAP-1900 XIII. HANDLING, STORAGE, AND SHIPPING (ANSI N45.2 Section 14)
Measures shall be established to control QAI-16 A.P. 1.6 the handling, storage, shipping, cleaning and '
A.P. 1.11 preservation of material and equipment in QAP-300 accordance with work and inspection instruc- QAP-1300 tions to prevent damage or deterioration. QAP-1400 Uhen necessary for particular products, QAP-1500 special protective environments, such as QAP-1600 ,
inert gas atmosphere, specific moisture QAP-1700 content levels, and temperature levels, shall QAP-1800 be specified and provided.
D-2-25 Revision 0
3 .
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TABLE 2 (Cont'd) 10CFR50 Apperdix B - Cross-Reference Tabulation 10CFR50 Appendix B CNS QA CNS Admin. Admin.
Criterion Program Procedures Procedures XIV. INSPECTION, TEST, AND OPERATING STATUS (ANSI N45.2 Section 15)
Measures shall be established to indicate, QAI-07 A.P. 1.4 by the use of markings such as stamps, tags, QAI-09 A.P. 1.7.2 labels, routing cards, or other suitable A.P. 1.7.3 means, the status of inspections and tests QAP-200 A.P. 1.7.4 j performed upon individual items of the nuclear QAP-300 A.P. 1.7.5 i power plant. These measures shall provide QAP-400 A.P. 1.7.6
'for the identification of items which have QAP-500 A.P. 1.7.7 satisfactorily passed required inspections QAP-600 A.P. 1.14 and tests where necessary to preclude inadver- QAP-700 ,
tent bypassing of such inspecticns and tests. QAP-900 Measures shall also be established for indi- QAP-1000 cating the operating status of structures, QAP-1100 i systems, and components of the nuclear power QAP-1200 plant, such as by tagging valves and switches, QAP-1400 to prevent inadvertent operation. QAP-1600 I
QAP-1700 QAP-1800 XV. NONCONFORMING MATERIALS, PARTS, OR COMPONENTS (ANSI N45.2 Section 16)
Measures shall be established to control QAI-10 A.P. 1.4 NEP-04 materials, parts, or components which do not QAI-13 A.P. 1.6 conform to requirements in order to prevent QAI-14 A.P. 1.7 their inadvertent use or installation. These A.P. 1.9 l
measures shall include, as appropriate, QAP-100 A.P. 1.10 procedures for identification, documentation, QAP-200 A.P. 1.11 segregation, disposition, and notification to QAP-700 A.P. 1.14
- affected organizations. Nonconforming items QAP-900 A.P. 1.18 shall be reviewed and accepted, rejected, QAP-1000 A.P. 1.25 1 repaired or reworked in accordance with QAP-1100 documented procedures. QAP-1200 QAP-1300 g
! QAP-1400 QAP-1500 QAP-1600 QAP-1700 QAP-1800 l
l D-2-26 Revision 0
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- e
. USAR TABLE 2 (Cont'd) 10CFR50 Appendix B - Cross-Reference Tabulation 10CFR50 Appendix B CHS QA CNS Admin. Admin.
Criterion Program ~ Procedures Procedures XVI. CORRECTIVE ACTION (ANSI N45.2 Section 17)
Measures shall be established to assure QAI-04 A.P. 1.4 NEP-04 that conditions adverse to quality such as QAI-05 A.P. 1.6 failures, malfunctions, deficiencies, devia- QAI-10 A.P. 1.7.1 l tions, defective material and equipment, and QAI-13 A.P. 1.9-nonconformances are promptly identified and QAI-14 A.P. 1.10 n corrected. In the case of significant con- QAI-15 A.P. 1.11 ditions adverse to quality, the measures QAI-16 A.P. 1.14 shall assure that the cause of the condition A.P. 1.18 is determined and the corrective action taken All QAP's A.P. 1.24 to preclude repetition. The identification A.P. 1.25 of the significant condition adverse to A.P. 1.26 quality, the cause of the condition, and the A.P. 1.27 corrective action taken shall be documented and reported to appropriate levels of manage-ment.
XVII. QUALITY ASSURANCE RECORDS (ANSI N45.2 Section 18)
Sufficient records shall'be maintained QAI-06 A.P. 1.3 to furnish evidence of activities affecting QAI-07 A.P. 1.4 quality. The records chall include at least QAI-15 A.P. 1.5 -
the following: Operating logs and the results QAl-16 A.P. 1.6 of reviews, inspection, tests, audits, moni- QAI-17 A.P. 1.7.1 toring of work performance, and materials A.P. 1.7.2 .
analyses. The records shall also include All QAP's A.P. 1.7.3 l closely-related data such as qualifications A.P. 1.7.4 (
of personnel, procedures, and equipment. A.P. 1.7.5 Inspection and test records shall, as a A.P. 1.7.6 minimum, identify the inspector or data A.P. 1.7.7 recorder, the type of observation, the A.P. 1.8 ,
results, the acceptability, and the action A.P. 1.9 taken in connection with any deficiencies A.P. 1.10 noted. Records shall be identifiable and A.P. 1.11 retrievable. Consistent with applicable A.P. 1.12 regulatory requirements, the applicant shall A.P. 1.13 establish requirements concerning record A.P. 1.15 3 retention, such as duration, location, and A.P. 1.16 3 assigned responsibility. A.P. 1.17 0 A.P. 1.18 :
A.P. 1.19 1 A.P. 1.20 A.P. 1.22 A.P. 1.24 A.P. 1.25
- D-2-27 Revision 0
. USAR TABLE 2 (Cont'd) 10CFR50 Appendix B - Cross-Reference Tabulation 3
10CFR50 Appendix B CNS QA CNS Admin. Admin.
Criterion Program Procedures Procedures XVIII. AUDITS .
(ANSI N45.2 Section 19)
A comprehensife system of planned and QAI-04 A.P. 1.4.9 periodic audits shall be carried out to QAI-05 A.P. 1.23 verify compliance with all aspects of the QAI-06 quality assurance program and to determine the QAI-12 effectiveness of the< program. The audits,- QAI-13 shall be performed in accordance with the QAI-16 written procedures or check lists by appro- QAI-17 priately trained personnel not having direct responsibilities in the areas being audited. All QAP's Audit results shall be doedmented and reviewed by management having responsibility in the
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area audited. Follow-up action, including reaudit of deficient areas, shall be taken where indicated.
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4 D-2-28 Revision 0
. USAR 3.0 ORGANIZATION AND RESPONSIBILITIES Nebraska Public Power District is solely responsible for the operation of the Cooper Nuclear Station and will fulfill the objectives set forth in the
- Quality Assurance Program for Operation through its own organization and by contact with qualified contractors and consultants.
3.1 General The overall Quality Assurance Program for Operation shall be conducted in accordance with the three divisions of responsibility which provides for Quality Control, independent Quality Assurance Surveillance, and Quality Assurance Audits.
I Table 3 defines the three levels of QA as they are to be carried out for i station operation and also shows the comparison with similar principles which shall apply on nuclear fuel procurement and on any future major engineering and construction activities for the Cooper Nuclear Station.
The organization of the Cooper Nuclear Station is presented in Figure 2, showing the relationship of the Cooper Nuclear Station organization to other Power Operation and Power Project functions. This chart also shows the relationship of the Quality Assurance functions to other functions in the i department and identifies the three levels of Quality Assurance activities. It is intended that clearly separate lines of responsibility be maintained between those responsible for operating the nuclear station and those responsible for auditing to verify that all quality and licensing requirements are consistently ;
being met via good Quality Assurance Surveillance and Quality Control practices, j-QA responsibilities within each QA levdl will vary depending upon the type of activity involved (See Section 4.1.3). Additional details on individual !
QA responsibilities are given in the paragraphs which follow, together with additional explanation of the interrelationships between the various supervisors i and managers involved.
3.2 General Office Management 3.2.1 Senior Division Manager - Power Operations The Senior Division Manager, Power Operations, is the responsible corporate officer for all Quality Assurance matters for the District.
Specifically, for nuclear facilities, this responsibility includes the quality assurance requirements governing those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The pertinent activities associated with these structures, systems, and components include designing, purchasing, fabrication, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service inspection and modifications that are associated with a nuclear power i.
plant are the responsibilities delegated to the Division Manager of Licensing and j Quality Assurance and the authority to define and implement the detailed requirements of the Quality Assurance program to assure that the activities identified above meet all applicable controlling documentation. This authority includes the right to direct, enforce, and perform any actions required.to insure the high standards of implementing a good quality assurance program.
D-3-1 Revision 0 1
. USAR Responsibility for, and authority over, the Safety Review and Audit Board is retained by the Senior Division Manager as Board Chairman; however, the Division Manager of Licensing and Quality Assurance is the alternate chairman for this Board. Also the Senior Division Manager reserves the authority to conduct, or order the auditing or monitoring of any operations activity, at any time,.to ascertain the effectiveness of the QA Program and to determine that all aspects of the QA Program are being complied with.
3.2.2 Division Manager, Licensing and Quality Assurance The Division Manager of Licensing and Quality Assurance, corporate officer, reporting to the Senior Division Manager of Power Operations, shall have the responsibility and authority for administrating and maintaining the Quality Assurance Program for Operation. Inherent in this responsibility is the authority to accept or reject any or all work, materials, or equipment associated .
with Cooper Nuclear Station and Columbus G.O. He shall also approve all plans, '
instructions, and procedures for defining and auditing the safety-related activities within the Cooper Nuclear Station. The actual functions to be performed shall be defined more completely by the body of Quality Assurance Instructions and Plans required by Section 4.0 of this policy document. He shall
, also have direct responsibility for qualifying suppliers of nuclear safety-related equipment, materials, and spare parts and for auditing the QA/QC i activities of such suppliers.
4 The Division Manager of Licensing and Quality Assurance shall serve as alternate chairman of the Safety Review and Audit Board. The Division Manager of Licensing and Quality Assurance of shall also determine when additional QA personnel shall participate in the Safety Review and Audit Board activities. He shall also be responsible for the scheduling of third level audits as shown on Figure 2 of this policy dotument and scheduling SRAB audits.
The Division Manager of Licensing and Quality Assurance shall personally monitor the Quality Assurance activities to the extent necessary for assuring himself _that the District is complying with the program. He shall j review the effectiveness of the Quality Assurance program with the Senior Division Manager, Power Operations, on a regular basis. In addition, the l Division Manager of Licensing and QA has a direct line of communication with the
! General Manager.
I 3.2.3 Quality Assurance Manager l The Quality Assurance Manager, under the direction of the Division l Manager of Licensing and Quality Assurance, shall have the responsibility and l authority for implementing and maintaining the Quality Assurance Program for
! Operation which will meet the requirements of applicable federal regulations, codes, quality standards, and other safety and environmental conditions that are
. required to assure safe and reliable nuclear power plant operations, l
i The Quality Assurance Manager shall direct the preparation of plans, instructions, and procedures for defining the Quality Assurance functions associated with Cooper Nuclear Station to insure that such activities are conducted in accordance with the Operating License and appedded technical i
specifications. As a minimum, this function includes governing those activities listed in Section 4.1.3. He shall also be responsible for monitoring the D-3-2 Revision 0
. USAR interface between; Power Operations and -Power- Proj ects to insure that plant modifications and repairs receive the proper design reviews and approvals.
The Quality Assurance Manager, or his designee, shall have the responsibility for controlling, administrating, distributing, and coordinating changes and additions to the Quality Assurance Program for Operation, subject to the requirements of'Section 4.0 of this document regarding authority to initiate, review, comment, and issue the various plans and instructions. He shall, in cooperation with the CNS Superintendent, be responsible for providing the training and instruction program required to enabic NPPD personnel to execute this QA program. He shall also establish and implement the program for qualifying suppliers for safety-related equipment, materials, and spare parts and for auditing the QA/QC activities of such suppliers.
As shown in Table 3, he shall have responsibility for accomplishment of third level QA audits and shall obtain assistance and special expertise when q necessary to complete such audits effectively as directed by the Director of Licensing and Quality Assurance.
The Quality Assurance - Manager and staff shall have the necessary organizational freedom and access within Columbus G.O. and Cooper Nuclear Station to institute the necessary quality assurance requirements, identify problems, and ,
pursue prompt corrective action.
The Quality Assurance Manager and staf f shall have the authority to observe operational maintenance, in-service inspection, special processes, repair or modification activities covered by this QA program, and to recommend that work stop_when such activity, in their opinion, does not comply with approved controlling documentation. However, authority to actually stop work shall remain with the Station Superintendent or designee, who will determine whether such stoppage would cause any violation of the Technical Specification or other approved documents governing station operations or whether there are overriding considerations of safety involved.
3.2.4 Quality Assurance Staff Quality Assurance Supervisor The Quality Assurance Supervisor, under the direction of the Quality '
i Assurance Manager, shall be responsible to perform, direct, or coordinate all QA Surveillance activities within Cooper Nuclear Station to determine if conformance i with the NPPD Quality Assurance Program and those applicable federal regulatory regulations as defined in the NPPD QA Manual are being maintained. He shall
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advise and assist the Station Superintendent in all matters which could affect-the Quality of the station. In addition, he shall advise and assist all station j personnel in matters regarding Quality Assurance and Quality Control. When -
required, the CNS QA Supervisor shall assist in review and approval of suppliers for replacement parts or equipment, which includes evaluating suppliers' Quality Assurance programs. The CNS QA Supervisor shall assist in preparation and review
! of the Quality Assurance Instructions and Plans when requested. He shall also be
, responsible for verifying that solutions to safety-related problems have been
! implemented and to perform periodic audits of work associated with those activities listed in Section 4.1.3 on an announced and unannounced basis. NPPD QA personnel at Cooper Nuclear Station shall have unrestricted access - and communication channels at all levels at Cooper Nuclear Station to perform audits, 1
- D-3-3 Revision 0
. USAR surveillances, and observations as required.. Additional specific duties shall be defined in the Quality Assurance Instructions and Quality Assurance Plans issued in accordance with Section 4.0 of this policy document. He shall also serve as a nonvoting member of the Station Operations Review Committee.
Quality Assurance Engineers The Quality Assurance Engineers, under the direction of the Quality Assurance Manager, shall develop the Quality Assurance Plans and Instructions
. required by Section 4.0 of this document. The QA Engineers shall perform preplanned and special audits as directed by the Quality Assurance Manager, both within the Cooper Nuclear Station and at the facilities of outside contractors or suppliers.
The Quality Assurance Engineer as a staff member shall have access to r the Cooper Nuclear Station for the purpose of performing the Quality Assurance l functions defined by this program.
The Quality Assurance Engineer shall assist in the review and approval of suppliers for replacement parts or equipment, which include evaluating suppliers' Quality Assurance Programs. He shall also review procurement specifications and associated drawings to determine if special requirements such as: codes, standards, material, tool, and inspection, etc. , are included with safety-related systems or equipment requisitions generated by Power Projects.
The Quality Assurance Engineers shall coordinate any activities that involve on-site and off-site QA programs and shall also provide assistance to the CNS QA Supervisor when required. In addition, a designated Quality Assurance Engineer shall act for the QA Manager during his absence.
Disagreements or differences of opinion on Quality Assurance matters are expected to be documented and resolved jointly by the Quality Assurance Supervisor or the Quality Assurance Engineer and appropriate supervisory personnel or the Station Superintendent of Cooper Nuclear Station. Where such resolution is not achieved within a reasonable period of time, unresolved differences shall be promptly reported to the Quality Assurance Manager for resolution jointly with the Division Manager of Licensing and Quality Assurance; Division Manager of Power Operations; and the Senior Division Manager, Power Operations.
Quality Assurance Specialists The CNS Quality Assurance Specialists shall be responsible to assist and advise the Quality Assurance Supervisor in all matters which could affect the quality of the station. These duties include procedure preparation, performing QA activities within the station, advise and assist all station personnel in all matters regarding Quality Assurance and Quality Control, verify that solutions to safety-related problems have been implemented, perform random audits of work activities within CNS on an announced or unannounced basis. During the Quality Assurance Supervisor's absence a designated CNS Quality Assurance Specialist i
shall serve as a nonvoting member of the Station Operations Review Committee and act for the QA Supervisor. Additional specific duties shall be as defined in the Quality Assurance and Quality Plans issued in accordance with Section 4.0 of this policy document.
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. USAR Administrative Secretary, Licensing & Quality Assurance The Administrative Secretary, Licensing and Quality Assurance, shall be responsible for administering the controlled document distribution and retrieval and records of distribution' retrieval. In addition, the Administrative Secretary shall be responsible for the preparation of administrative procedures which control and maintain NPPD Columbus G.O. - QA files. Additional specific duties shall be as defined in the Quality Assurance Instructions and Quality Assurance Plans issued in accordance with Section 4.0Lof this policy document.
3.2.5 Division Manager, Power Projects The Division Manager of Power Projects shall be responsible for the l activities defined in QAI-ll for Cooper Nuclear Station.
The Division Manager of Power Proj ects shall provide technical assistance for the ongoing construction and plant modification activities at Cooper Nuclear Station. Those Quality Assurance activities associated with such design modifications will be conducted in accordance with the Cooper Nuclear Station QA program for design and construction. _The QA Plan for construction will be reviewed for consistency with current requirements and revised if appropriate. The activities conducted under the QA Program for design and construction shall be periodically audited by NPPD QA personnel and unresolved differences shall be promptly reported to the Quality Assurance Nbnager for resolution jointly with the Division Manager of Licensing and Quality Assurance; Division Manager of Power Projects; and the Senior Division Manager, Power Operations.
3.2.6 Division Manager, Power Operations The Division Manager of Power Operations reporting to the Senior Division Manager, Power Operations, shall be responsible for assuring that Quality Control activities as defined by the Division Manager of Licensing and Quality Assurance for use within the Cooper Nuclear Station are complied with.
Certain of these responsibilities are delegated to the Cooper Nuclear Station i
Superintendent and consist basically of Quality Control and Inspection functions as defined in Table 3. The actual functions to be performed shall be defined more completely by the body of Quality Control and Quality Assurance Plans and Instructions as listed in'Section 4.0 of this policy document.
The Division Manager of Power Operations shall regularly review station activities for the purpose of keeping abreast of significant quality activities.
For those aspects of Fuel Management QA covered by the QA Program, the Nuclear Fuel Manager, under the direction of the Division Manager of Pouer Operations, shall be responsible to furnish technical assistance as required to the Station Superintendent and the QA Staff. Such reviews shall not replace or supersede the formal audits.
3.3 Cooper' Nuclear Station Personnel l
The operational duties and responsibilities of the Cooper Nuclear Station personnel are fully . described .in Reference 7.6. In addition, the Cooper .
Nuclear Station personnel.are assigned Quality Control and' inspection functions as indicated in Section 3.2.3. Station personnel, under the direction of the D-3-5 Revision 0
. USAR Station Superintendent, are charged-with- the responsibility for _ assuring that the station is tested, operated, and maintained in accordance with approved plans and procedures, and such responsibilities include Quality Control functions.
3.3.1 Station Superintendent The Cooper Nuclear Station Superintendent is responsible for providing the necessary resources and to implement the action required to correct quality problems identified by the QA Supervisor. He shall arrange for designated personnel responsible for operating or maintaining systems or equipment requiring QA to receive formal instruction in Quality Assurance as provided for herein. He shall assign Quality Control Inspection duties, including preparation of necessary procedures, to first-line supervisor, guided by the rule that quality checks must be made by a knowledgeable individual other than individuals performing or responsible for the actual work to be verified by the QA Department.
3.3.2 Station Line Supervisors Reporting to the Station Superintendent will be the heads of five plant functional departments as follows: Operations Supervisor, Engineering Supervisor, Maintenance Supervisor, Chemistry and Health Physics Supervisor, and Administrative Supervisor. The responsibilities for these Line Supervisors are defined in Section XIII, Volume V of the CNS-USAR.
3.4 Safety Review and Audit Board The board must: verify that operation of the plant is consistent with company policy and rules, approved operating procedures, and operating license provisions; review important proposed plant changes, tests, and procedures; verify that licensee events are promptly investigated and corrected in a manner which reduces the probability of recurrence of such events; and detect trends which may not be apparent to a day-to-day observer.
Audits of selected aspects of plant operation shall be performed with a frequency commensurate with their safety significance and in such a manner as to assure that an audit of all nuclear safety-related activities is completed within
, a period of two years. Periodic review of the audit programs will be performed
! by the Board at least twice a year to assure that such audits are being
! accomplished in accordance with appropriate written instructions or procedures and should include verification of compliance with internal rules, procedures (for example, normal, off- normal, emergency, operating, maintenance, surveillance, test and radiation-control procedures, and the emergency and ,
l security plans), regulations involving nuclear safety and operating license provisions; training, qualification, and performance of operating staff; and i
corrective actions following reportable occurrences or unusual events. A representative portion of procedures and records of the activities performed during the audit period shall be reviewed, and in addition, observations of performance of operating and maintenance activities shall be conducted. Written reports of such audits shall be reviewed at a scheduled meeting of the Board and by appropriate members of management including those having responsibility in the
! area audited. Follow-up action, including reaudit of deficient areas, shall be
( taken when indicated. CNS Technical Specifications, Section 6.2, identifies the Safety Review and Audit Board members not shown on Figure 2. Additional SRAB duties and responsibilities are also defined in Section 6.2.
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'USAR 3.5 Station Operations Review Ccmmittee The Station Operations Review Committee (SORC) has been established to advise the Station Superintendent regarding operational safety considerations.
The SORC initially reviewed and evaluated, from an operational safety viewpoint, the following:
Station operating procedures Station testing procedures Station maintenance procedures Station refueling procedures Station spent fuel handling procedures 5
Station radwaste processing and disposal procedures Station radiation control procedures l
Station emergency procedures The SORC shall subsequently review proposed changes to these procedures in accordance with Section 6.2 of CNS Technical Specifications.
The SORC will review and evaluate all abnormal operating conditions, procedural violations, deviations from planned operations, station transients, incidents or accidents, and make recommendations for appropriate action to correct any deficiencies identified. The SORC shall report to the Chairmad of the NPPD Safety Review and Audit Board on all reviews and investigations conducted as required by Section 6.2 of the Technical Specifications.
The SORC will be made up of persons from the CNS supervisory and technical staff members. The SORC meetings will effectively keep these personnel informed of current station operating conditions and operational safety considerations.
Minutes of the SORC meetings will be recorded and, as a minimum, copies will be distributed to the Senior Division Manager, Power Operations (SRAB Chairman); Division Manager of Licensing and Quality Assurance; and the Division Manager of Power Operations. ,
1 The Station Operations Review Committee recommends changes in the facility design or changes to the facility license based upon operating -
experience and station performance evaluations. Station Operations Review l Committee members are identified on Figure 2. Additional SORC duties and '
responsibilities are defined in Section 6.2 of CNS Technical Specifications, i
3.6 Outside Vendors, Contractors, Subcontractors, and Consultants j During the life of Cooper Nuclear Station, it will be necessary to obtain assistance from outside vendors and contractors for some of the work within the station, such as decontamination, major maintenance or repair, D-3-7 Revision 0
. USAR in-service inspection, waste disposal, design of modifications, fabrication or-replacement equipment, and other specialty work.
At all times, outside vendors, contractors, and consultants will work under the direction of the NPPD organization having primary responsibility for the particular work being performed.
In those instances in which outside vendors-or contractors merely furnish personnel to augment the normal station staff for particular activities, such outside contractor personnel shall be required to become qualified, perform their work in accordance with the CNS Quality Assurance documents and other appropriate CNS procedures and instructions.
In those instances in which outside vendors, contractors, and subcontractors are assigned primary responsibility for a particular activity, such outside contractor shall be required to demonstrate that it has a Quality Assurance and Quality Control Program and organization appropriate to the work to (
be performed. Selection of outside vendors or contractors shall require the active participation of the Quality Assuranca Department in evaluating and approving their Quality Assurance Program and reviewing the procurement documents j prior to auarding the contract.
In every instance in which outside contractors have responsibility for I work on safety-related nuclear systems, they shall be contractually required to work within NPPD, Quality Assurance Program, and CNS-approved procedures. In addition, they shall be contractually required to prepare, prior to performing the work, Control Procedures specific to the work to be performed for the Cooper Nuclear Station. Recognized standards or existing proprietary procedures may be used, but they must be specifically invoked in writing and clearly identified as to their applicability to the CNS work.
If any portion of work on safety-related nuclear systems is to be subcontracted, the prime contractor shall require that such subcontractors institute and maintain a Quality Assurance Program comparable and equivalent to that of the prime contractor.
Additionally the NPPD QA organization shall have direct access to and I communication with the contractor's personnel at all levels, both at their home office and in the field. 1 2
Prior to outside vendor or contractor performing work at the Cooper Nuclear Station af ter start of fuel loading, the vendor or contractor and selected representatives from the NPPD Power Operations and Power Projects groups ,
shall jointly develop and enforce written agreemento end procedures which clearly !
define the limits of the work; interface coordination between contractor i personnel and station staf f; status and custody tagging procedures; contractor personnel dosimetry;-and any other aspects which bear on station or personnel security and safety. Such agreements shall be reviewed by the Quality Assurance Department to insure compliance with applicable Quality Assurance Program. ;
i <
As necessary to execute this QA Program, the District may obtain the services of a qualified consultant. When non-NPPD support is obtained, total ,
responsibility for effectiveness of support organizations activities will remain a with NPPD. .
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. USAR Table 3 THREE LEVEL QUALITY ASSURANCE PROGRAM EXPLANATION OF FIRST, SECOND, AND THIRD LEVEL QA RESPONSIBILITIES
(
a) FIRST LEVEL-Quality Control & c) THIRD LEVEL-Quality Assurance Audit ,
Inspection.
Persons performing these audits are An individual other than the one generally not involved in the day- i doing the work will have primary to-day Inspection or Quality responsibility for Quality Control. Control.. functions. Audits will Personnel at this level are charged normally be performed by or under
- with the responsibility for direct the direction of the QA Manager.
inspection, witnessing, and sign- In addition, SRAB shall audit off, attesting that work has been selected activities and programs, performed in accordance with the such as the QA program, to assure quality requirements of the proper program implementation and controlling documents. to insure safe and reliable operation. The designated Division i b) SECOND LEVEL-Quality Assurance Managers shall have the responsibility Surveillance / Audit. for such audit. The SRAB and/or the Licensing and QA department will be This function is performed by the responsible for evaluation of the Quality Assurance Supervisor or his audit results and for verifying designee, as appropriate for work that any corrective action involved. The document which requirements have been implemented.
controls the testing.. operation, design changes, and maintenance under the direction of, or for review and evaluation by this level for use by QC personnel. The Quality Assurance Supervisor is responsible for assuring that
. controlling documents for operation include appropriate quality requirements. During operation, QA is responsible for maintaining surveillance and audits of the work to assure that Quality Control and inspection programs are being carried out and that quality requirements are in fact being met.
Surveillance is the QA Audit l function performed under the ,
direction of site QA personnel, i
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a
-. USAR 4.0 QUALITY ASSURANCE LOCUtfENTS In conformance with 10CFR50 Appendix B, Criterion II, written policies, plans, and instructions shall be prepared to define the Quality Assurance Program to be carried out over the operating life of the station. An identification system shall be set up to clearly distinguish the Operation QA Plans and Instructions from other phases of the overall QA Program.
4.1 NPPD Internal Documents The Quality Assurance Program documents must necessarily be based on work procedures which are prepared by engineering and operating groups. It is necessary to establish clear lines of distinction between the WORK procedures and the QA procedures. 10CFR50, Appendix B, identifies certain WORK procedures and documents which are required in order to have an effective QA Program. However, it is not intended that QA responsibilities include preparation of basic work procedures; it is not intended that basic work procedures be incorporated into the QA Program documents.
The WORK procedures are kept separate from the QA procedures in engineering, manufacturing, and construction, and it is intended that they be kept separate for operations activities. However, mandatory QA/QC checkpoints shall be incorporated directly into, or by attachment to the work procedures to facilitate coordination between the work and its quality control.
Work procedures shall be reviewed by Quality Assurance for proper implementation of this Quality Assurance Program for Operation and for compliance with the criteria of 10CFR50, Appendix B.
Quality Assurance Plans and Instructions and Quality Control Inspection requirements shall be developed in accordance with guidelines given in the following paragraphs.
The format and content of each type of QA document shall be as specified by the Division Manager of Licensing and Quality Assurance and shall be documented by issuance of a Quality Assurance Instruction (QAI-1) as further '
described below.
Af ter QA documents are approved and issued, significant changes shall be reviewed and approved via the same channels as for the original document.
Each such change, when approved and issued, shall be accompanied by a Transmittal Notice.
Particular circumstances may occur while some work is in progress, which necessitates a change to an approved procedure. When such circumstances arise, it is vitally important that the changes be authorized per procedure, and as a minimum, the CNS QA Supervisor shall have the opportunity to review and accept changes prior to implementation. The written record shall clearly show the nature and extent of the change and the reason for requiring such change.
Except in unusual circumstances, changes shall be reviewed and approved in writing via the same channels as the original procedure, prior to adoption of the change. If changes are made or deviations occur in an unusual circumstance, such changes shall still be reviewed and approved as above. If the QA Department does not accept such change or deviation, then, as soon as possible af ter the D-4-1 Revision 0
. USAR unusual circumstance has passed,-the work shall-be corrected to conform to the approved procedures.
4.1.1 Quality Control Inspection The Quality Control Inspection function aust be ' performed by an individual other than those which are actually performing the work being controlled or inspected. The Cooper Nuclear Station Superintendent, as part of his normal management function, is responsible for preparation of the Quality Control requirements of this inspection program; however, the CNS QA Supervisor is responsible to review and accept control methods prior to implementation.
The CNS Quality Assurance Supervisor, working with the Station Superintendent or other responsible supervisor, shall verify that Quality Control Check Points have been incorporated directly into .or by attachments to, the work procedures which shall constitute the stations QC functions and shall periodically inspect work performance to assure that the procedures-containing Quality Control activities are being followed. The QC checkpoints shall identify the specific work which is to be subjected to inspection-or verification and shall provide in detail the elements of work to be inspected which include:
- 1. identity of the inspector or data recorder I
- 2. type of inspection or observation
- 3. results (data to be recorded)
- 4. acceptance (qualitative or quantitative) criteria j j
- 5. method of disposition of nonconformance
- l
- 6. reporting requirements )
In addition, clear instructions shall be given regarding the timing, j frequency or scheduling, and notification requirements for such inspections so as to obtain maximum effectiveness and to minimize delays in completion of the work. (
It must be recognized that certain work, particularly in nonroutine maintenance-or repair, cannot be anticipated. Therefore, work procedures and Quality Control Inspection requirements cannot be prepared until a particular problem has been detected and evaluated.
Routine maintenance and repair of essential systems and components generally requires performance of a complete or partial Surveillance Procedure prior to placing the system back in service. This type of QC (actual performance or functional testing) following completion of work is considered a unique j advantage on an operating facility. Such surveillance testing may be performed by the individuals who performed the maintenance activity, with acceptance of testing by the shif t supervisor acting as the QC agent.
4.1.2 Quality Assurance Instructions (QAI)
From time to time it may be necessary and appropriate to' further {
clarify the nature and extent of the NPPD management commitment to Quality J Assurance for Operation. In addition, it may be necessary to issue further, more l l
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- USAR detailed instructions for compliance with 10CFR50, Appendix B, and this policy document. To accomplish this, the Quality Assurance Manager or his designee shall prepare additional Quality Assurance Instructions (QAI) which shall be approved by the Division Manager of Licensing and Quality Assurance.
Each Quality Assurance Instruction (QAI) shall clearly identify the purpose, conditions, problem, or uncertainty which generated the need for clarification. The authority, policy, regulation, specification, code or standard applicable to the particular problem shall be cited in the Instruction.
Appropriate detailed explanation or instructions shall be developed to clarify matters such as, but not limited to:
QAI-1 Guidelines for Preparation and Issuance of Quality Assurance QAI-2 Controlled Distribution of Quality Assurance Documents QAI-3 Definition of Terms QAI-4 General Guidelines for Quality Assurance Surveillance QAI-5 General Guidelines for Quality Assurance Audits QAI-6 Personnel Qualifications and Training for QA Assignments QAI-7 Quality Assurance Records - Retention, Storage, and Disposition QAI-8 Applicability of NRC Quality Assurance Criteria QAI-9 Guidelines for Establishing Quality Classifications of Components and Materials QAI-10 Nonconformance Reports - Issuance, Control, and Corrective Action QAI-11 Delegation of Specific Responsibilities QAI-12 Guidelines for Audit Frequency and Scheduling QAI-13 Guidelines for'QA Review of Procedures and Documents QAI-14 Disposition of Nonconforming Materials, Parts, and Components QAI-15 Incident Evaluation QAI-16 Vendors Qualification I t
QAI-17 Guidelines for Indoctrination and Training of QA Personnel These approved Quality Assurance Instructions (QAI) shall become a part !
of the CNS Quality Assurance Program for Operation.
4.1.1 Quality Assurance Plans (QAP)
Concurrent with the preparation of work procedures, and prior to the-start of an operating activity, the Quality Assurance Manager shall develop a set i
D-4-3 Revision 0 1
. l,
, USAR J
l of Quality Assurance . Plans. - -These- QA Plans shall become a part of the CNS Quality Assurance Program for Operation and will be distributed to those individuals who are responsible for that particular activity. As a general f guideline in defining the scope of the QA Program, there shall be a QA Plan for ;
each functional area shown below:
QAP-001 Preoperational Test Program QAP-002 Start-up and Full Power Testing QAP-100 Administrative Controls QAP-200 Station Operation QAP-300 Refueling, Fuel Storage and Shipment QAP-400 Instrument and Equipment Calibration and Control QAP-500 Industrial Security QAP-600 Surveillance Testing QAP-700 Nonroutine Maintenance QAP-800 Fire Protection QAP-900 Chemistry. Health Physics and Environmental Monitoring QAP-1000 Nuclear Performance Evaluation - Core Management QAP-1100 Routine Maintenance QAP-1200 Radioactive Waste Treatment and Disposal QAP-1300 Nuclear Materials Safeguards and Accountability QAP-1400 Procurement and Control of Essential Spare Parts, Equipment, Materials and Service QAP-1500 In-Service Inspection QAP-1600 Control of Contractors Working in the Station QAP-1700 Design Changes QAP-1800 Nuclear Fuel Procurement QAP-1900 Emergency Plan QAP-2000 NRC Reporting and Responding Activities QAP-2100 Document Control QAP-2200 SRAB Activities l
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- a. .'
e USAR QAP-2300 CNS Spent Fuel Shipping Campaign
- QAP-2400 Non-Safety-Related Reliability System A guide for the format and content of Quality Assurance Plans shall be specified in a'QA Instruction (QAI-1) to provide uniformity and to assure that each plan is complete and adequate for the purpose intended.
The QAP's shall be prepared by the Quality Assurance Manager or designee and shall be reviewed and approved by the Division Manager of Licensing and Quality Assurance. In addition, when significant changes have been made, the QAP will be routed to the following for review and comment:
Station Superintendent Senior Division Manager, Power Operations (if affected)
Power Projects (if affected)
The QA Plans shall define the specific work in the nuclear station which is to be subjected to Quality Assurance review, surveillance, and audit, and the manner in which such review, surveillance, and audit is to be carried out.
Checklists shall be prepared af ter reviewing the work procedures describing the QA Surveillance or QA Audit guidelines, a) Quality Assurance Surveillance The Quality Assurance Surveillance function is intended to provide an independent check, on a continuing basis that work is being performed in accordance with the requirements of the controlling documents. The Quality Assurance Surveillance activities should not duplicate, one for one, the activities performed for Quality Control Inspection purposes. However, some duplication will occur, incidental to the performance of independent observations made to satisfy both Quality Assurance Surveillance and Quality Control Requirements.
Some primary objectives of Quality Assurance Surveillance are to verify that the Quality Control Inspection Program is in effect and is functioning as intended; that personnel performing Quality Control ' functions are properly qualified; that adequate information is being recorded to provide a , complete and accurate quality history; and that deficiencies are identified, corrected, and recorded; and corrective action taken to prevent recurrence of those types of l deficiencies. l This philosophy shall be taken into account in developing the checklists for Quality Assurance Surveillance activities to be carried out under each Quality Assurance Plan. QA Surveillance shall be as prescribed in appropriate QA Plans and Instructions.
The QA checklists shall identify the area of work to be subjected to surveillance and shall provide necessary instructions. The timing, frequency, or schedule for the surveillance shall be coordinated with the schedule of the work D-4-5 Revision 0
, USAR being evaluated so that the QA Surveillance will have maximum effectiveness with minimum impact on the progress of the work.
b) Quality Assurance Audits As required by 10CFR50, Appendix B, a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the Quality Assurance Program and to determine.the effectiveness of the program.
The audits shall be performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities for the work being audited. The Quality Assurance Manager shall have the responsibility for planning and executing Quality Assurance Audits identified by approved QA Plans. However, the Safety Review and Audit Board, or any manager or executive in the chain of organization above the Station Superintendent, or above the Quality Assurance Manager may initiate and carry out special Quality Assurance Audits within the guidelines provided by this Quality Assurance Program. Audit results shall be reported in writing to the Division Manager of Licensing and Quality Assurance and the results shall be reviewed with the Management responsible for the area of activity audited. Follow-up action, including re-audit of any identified deficient areas and verification of corrective actions, shall be taken and documented as directed by the Quality Assurance Manager.
QAI-5 and QAI-12 include descriptions and timing of types of audits to be performed; guidelines for performing audits; procedures for initiating an audit; guidelines for preparing audit reports.
Each QA Plan will be implemented through the use of the appropriate checklist. On the basis that some Quality Assurance Audits are to be conducted or directed by management, it is essential to maintain a high degree of flexibility in the manner of conducting an audit. It is intended that the QA Plans prc, vide audit guidelines to assure that areas to be audited are sufficiently defined in advance and that audit personnel are adequately prepared to make a meaningful audit with a minimum of interference with the progress of the work. Also, flexibility is required to permit the auditor to adapt his procedures to the conditions existing at the time the audit is made.
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USAR 5.0 METHOD OF IMPLEMENTATION
-The detailed methods of implementation of this Three Level Quality Assurance Program for Operation shall be as provided for in the body of Quality Assurance Instructions and Plans prepared in accordance with Section 4.0.
The Quality Assurance Manager and the CNS QA Supervisor shall review and comment upon appropriate sections of the CNS Procedures manuals to ascertain that necessary quality requirements are included. Procedure changes will be incorporated as necessary to correct identified control deficiencies or needs.
Differences of opinion on QA comments shall be resolved as indicated in Section 3.2.4.
Af ter review of the various station procedures manuals, the Quality Assurance Manager shall prepare the QA Instructions and Plans for the purpose of prescribing, in detail, how the overall QA Program objectives are to be accomplished in each segment of the work to which this QA Program applies. These QA documents shall then be reviewed and commented upon by the CNS staff for the purpose of achieving sound and orderly integration of the Quality Assurance functions into the framework and routines established for licensed nuclear station operations.
After resolution of all operations-related comments, the QA Instructions and Plans shall be approved and issued by the Director of Licensing and QA and shall become the basis for detailed implementation of the QA Program a for Operation. f u
Quality Assurance activities shall be coordinated with the Safety 8 ,,
Review and Audit Board (SRAB) and with the Station Operations Review Committee (SORC). QA activities shall be conducted in a manner and on a schedule which f$
will assure that the organization, supervision, communications, and technical and p'
administrative practices clearly evidence smooth, orderly, controlled, and safe l
execution of all station-operating functions. gy a
i Written reports of all QA activities, including descriptions of d I
deficiencies and resolution thereof, shall be incorporated into the official QA oE file. Corrective action on deficiencies must include resolution of the specific Io c l deficiency and verification that corrective action has been implemented to prevent occurrence of similar deficiencies in the future. A report of QA Audits performed (internal and external) shall be submitted to the Senior Division
((i 4
4 Manager, Fower Operations, by the QA Manager yearly. h[d The Quality Assurance Manager shall maintain an up-to-date summary of d the CNS Quality Assurance Policies, Instructions, and Plans, showing hcw this QA y Program for Operation implements the NRC guidelines contained in 10CFR50, ,
Appendix B. .g l 5 I
It is especially important to realize that a transition period is required, during major modifications, when responsibility for the station is transferred from engineering and construction forces to the operating group. At c the beginning of the test phase, overlapping responsibilities between h construction / engineering personnel and operating personnel require close 8 cooperation of all groups to insure that checkout and testing is done in (8, accordance with approved procedures and consistent with all quality requirements. q o fy D-5-1 Revision 0
[ff w
- USAR 5.0 METHOD OF IMPLEMENTATION -
-The detailed methods of implementation of this Three Level Quality Assurance Program for Operation shall be as provided for in the body of Quality Assurance Instructions and Plans prepared in accordance with Section 4.0.
The Quality Assurance Manager and the CNS QA Supervisor shall review and-comment upon' appropriate sections of the CNS Procedures manuals to ascertain that necessary quality requirements are included. Procedure changes will be incorporated as necessary to correct identified control deficiencies or needs.
I Differences of opinion on QA comments shall be . resolved as indicated in Section 3.2.4.
Af ter review of the various station procedures manuals, the Quality Assurance Manager shall prepare the QA Instructions and Plans for the purpose of '
prescribiag, in detail, how the overall QA Program objectives are to be accomplished in each segment of the work to which this QA Program applies. These QA documents shall then be reviewed and commented upon by the CNS staff for the purpose of achieving sound and orderly integration of the Quality Assurance
, functions into' the framework and routines established for licensed nuclear station operations.
! After resolution of all operations-related comments, the QA Instructions and Plans shall be approved and issued by the Director of Licensing and QA and shall become the basis for detailed implementation of the QA Program for Operation.
Quality Assurance activities shall be coordinated with the Safety Review and Audit Board (SRAB) and with the Station Operations Review Committee (SORC)._ QA activities shall be conducted in a manner and on a schedule Which will assure that the organization, supervision, communications, and technical and ,
administrative practices clearly evidence smooth, orderly, controlled, and safe execution of all station-operating functions.
Written reports of all QA activities, including descriptions of deficiencies and resolution thereof, shall be incorporated into the official QA file. Corrective action on deficiencies must include resolution of the specific deficiency and verification that corrective action has been implemented to 1 prevent occurrence of similar deficiencies in the future. A report of QA Audits performed (internal and external) shall be submitted to the Senior Division Manager, Power Operations, ty the QA Manager yearly.
The Quality Assurance Manager shall maintain an up-to-date summary of the CNS Quality Assurance Policies, Instructions, and Plans, showing how this QA Program for Operation implements the NRC guidelines contained in 10CFR50, Appendix B.
i It is especially important to realize that a transition period is required, during major modifications, when responsibility for the station is transferred from engineering and construction forces to the operating group. At the beginning of the test phase, overlapping responsibilities between construction / engineering personnel and operating personnel require close cooperation of all groups to insure that checkout and testing is done in accordance with approved procedures and consistent with all quality requirements.
I D-5-1 Revision 0
. USAR During this transition to operations control, Quality Assurance effort shall be devoted to verifying that:
a)
Procedures are set up to clearly identify and define authority and responsibility for each item of equipment that has been energized; has been or is being tested; or is defective or deficient.
b)
Procedures are set up for orderly transf er of _ responsibility and authority over each system as the preoperational testing is completed with clear definition of conditions for acceptance by operations, the c) A system of tagging is instituted suitable for use throughout life of the station, which indicated, by tagging, special instructions, or other documentation traceable, the status of each I component or system; the authority placing control tags; and the title of the person who must be contacted before any control tag status change can be made.
personnel and d) Tagging procedures are being followed to protect equipment against injury or damage uhich could be caused by improper or inadvertent change in status of a component or system.
t i~ .
i
s -
b
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-_-_- h. -- -__-_- - ___-__- ________ __ _ _
USAR 6.0 RECORDS RETENTION AND DISPOSITION Instructions have been prepared by the Quality Assurance Manager (QAI-7) which provide guidelines for CNS and G.O. record retention and disposition in accordance with this policy document and applicable regulatory criteria. As a minimum, these procedures cover the following:
a) Records content and location; b) Principal location from which records are to be controlled; c) Complete records inventory and master index; d) Conditions of storage, access, and security; e) System of-records identification, retrieval, and control; f) System of records transfer and disposal.
The station records system which accumulates evidence of Quality Assurance activities shall be thorough and complete, but shall not result in proliferation of 6nnecessary paperwork. The station records system shall permit i efficient retrieval of specific information on request. {
The records for the station shall be designated and referred to as the CNS Records file. Records contained in these files shall be in accordance with regulatory criteria and Section 6.6 of CNS Technical Specifications. As a minimum, the CNS Record File will contain:
- 1) An inventory of records as further described below;
- 2) The Official Files accumulated during engineering and construction;
- 3) Operating logs;
- 4) Results of reviews by management, regulatory agencies, and other j authorities; ;
- 5) Inspection records;
- 6) Test records and results;
- 7) Audit reports; i
- 8) Monitoring and evaluation of work performance;
- 9) Results of material analysis (surveillance specimens, reactor water chemistry, environmental specimens, etc.); ,
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- 10) Qualification of personnel, procedures, and tools or eqaipment.
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7.0 REFERENCES
The following documents were utilized in the preparation of the Quality Assurance Program for Operation of the Cooper Nuclear. Station. It is intended that these documents be utilized on a continuing basis in the performance of Quality Assurance activities for station operation since they offer measurement criteria against which the QA Program can be evaluated.
7.1 Quality Assurance Criteria for Nuclear Power Plants 10CFR50, Appendix B (USNRC).
7.2 Standard of Administrative Controls for Nuclear Power Plants, American National Standard ANSI 18.7 - 1972.
7.3 Safety Analysis Report, Cooper Nuclear Station, Nebraska Public Power i District (NRC Docket 50-298).
7.4 Environmental Report--Operating License Stage, Cooper Nuclear Station, Nebraska Public Power District (NRC Docket 50-298).
7.5 Quality Assurance Program for Engineering. Design, and Construction, Cooper Nuclear Station.
7.6 Cooper Nuclear Station Procedures Manual.
7.7 Safety Rules, Nebraska Public Power District.
7.8 Safety Guides for Water-Cooled Nuclear Power Plants (USNRC), as appropriate.
7.9 Quality Assurance Requirements for Nuclear Power Plants ANSI N45.2 - 1971.
7.10 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants ANSI N45.2.9 - 1974.
7.11 Quality Assurance Terms and Definitions ANSI N45.2.10 - 1973.
7.12 Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.11 - 1974.
7.13 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants ANSI N45.2.12 - Draft 3, Revision 4, February, 1974.
7.14 Supplementary Quality Assurance Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants ANSI N45.2.13 - Draft 2, Revision 4, April, 1974.
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. 8. 0 - IMPLEMENTATION, WASH-1283, -1284.AND -1309-The CNS QA Program for -Plant Operations - will utilize the guidance provided by NRC publications WASH-1283 (5-24-74), WASH-1284 (10-26-73) and WASH-1309 (5-10-74) (" rainbow" series) except as noted in the " Specific Exceptions" of this section.
The existing operational- QA Program does not address all of the detailed requirements set forth in the " rainbow books". A detailed review has been made to determine where the CNS QA Program differs from the ANSI Standards cited in the " rainbow books."
With respect to the applicability of the " rainbow books" and the l associated standards, it is impracticable to apply all of the requirements set I forth by these documents to a plant for which important, and (in some respcets) irreversible commitments, were made 8 to 10 years ago.- It is also impracticable to apply requirements to an operating plant which were intended solely for the design and construction phase. NPPD does not now envision any major modificatiens or additions to Cooper Nuclear Station. In the event that any such construction were undertaken, the District would commit to compliance with the.
applicable portions of the WASH Series ANSI Standards. It is NPPD's intent to apply quality standards to maintenance, repair, and modification activities which will provide results which are equal to or better than the original construction.
The following sections summarize the scope and applicability of ANSI Standards and describe specific exceptions that will be taken in applying the guidance of these documents to the CNS QA Program.
8.1 ANSI N45.2 Quality Assurance Program Requirements for Nuclear Power Plants (a) Scope and Applicability i
The guidance provided by this standard and the associated Regulatory Guides 1.28 and 1.33 shall be applied to the Operational QA Program to those activities affecting the safety-related aspects of the operational phase of CNS.
l Where codes or standards-are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as
< set forth in the SAR, the SAR commitments shall govern. Later revisions of
! . applicable codes and standards may be specifically invoked by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.
(b) . Specific Exceptions Quality Assurance Program (Section 2)
-The QA Program describes the measures utilized to comply with the requirements of 10CFR50, Appendix B. The CNS QA Program conforms to this ANSI
! Standard also, except as noted below.
l Inspection . (Section 11)
First Level inspection has been assigned to plant personnel. Contrary to the requirement of this standard that such persons shall not report directly i .
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e USAR to the same immediate supervisor,.our-program requires only that inspection activities to verify quality of work shall be performed by appropriately qualified persons other than those who performed-the activity being inspected.
To be considered qualified, persons performing inspection or verification activities shall meet the following requirements:
1
- 1) The inspector or verifier did not perform or directly supervise the work.
- 2) The quality of work will be demonstrated by a functional test if a pressure boundary has been breached.
- 3) The verifier's qualifications are reviewed and found acceptable by the QA organization prior to initiating the verification.
- 4) Individuals performing verification functions associated with normal operations of the plant will be qualified to ANSI N18.1-1971.
- 5) Individuals whose qualifications are not required to meet those in ANSI N18.1-1971 and who perform verification activities shall be qualified to ANSI N45.2.6-1973 except that the QA experience cited for Levels I, 11 and III shall be interpreted to mean actual experience in carrying out the types of inspection, examination, and testing activity being performed.
- 6) All nondestructive examinations (radiography, dye penetrant, magnetic particle, and the like) will be performed by personnel qualified and certified in accordance with SNT-TC-1A.
8.2 ANSI N45.2.1 Cleaning of Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plants (a) Scope and General Applicability The guidance provided by this standard and the associated Regulatory Guide 1.37 shall be applied to safety-related maintenance, repair, and modification activities occurring during the operational phase of Cooper Nuclear Station except as noted below.
(b) Specific Exceptions General Requirements (Section 2)
Cleaning requirements for almost all maintenance, repair, and modification work will be considered as a part of the overall job requirements.
In this respect, detailed c1 caning procedures will not generally be prepared as separate documents. Necessary requirements, consistent with the scope of the work, will be included as a part of the overall work instructions. System cleanness is controlled at CNS by the following methods: ,
P
- 1) Parts and components are checked for cleanness dtiring receipt inspection and stored in a manner that will ensure adequate levels of cleanness are being maintained.
- 2) Work instruction will be reviewed by Quality Control to assure that adequate cleaning and access controls are incorporated into work instruction and associated safety-related activities.
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- 3) Parts and components -are inspected for cleanness prior to installation in accordance with CNS maintenance procedures.
- 4) The work area is maintained at a cleanliness level appropriate to the maintenance or modification activity being performed.
- 5) Quality control inspections before, during, and af ter safety-related maintenance or modification activities address system cleanness.
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- 6) Random QA audit and surveillance of safety-related maintenance or modification activities requires verification of part, component, and system cleanness.
Criteria for Cleaning (Section 3)
For cleanness classifications where the scope of plant modification work is such as to make application of the guidance provided by this standard practicable, the cleanness classifications and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work requirements.
For most modification or maintenance work, however, involving only small portions or individual components of larger systems, it is not considered practicable to conduct cleanness tests with ASTM E11-70 Series. Appropriate cleanness will be maintained during the work and preoperational flushing will be conducted, consistent with the scope of the work performed and the original design requirements. Flushing is an additional precaution to insure system cleanness. Controlling the parts and components and the work area has provided CNS with reasonable levels of assurance that system cleanness will be maintained.
In addition to the above, the Water Chemistry Department routinely samples and tests for system cleanliness, corrosion, crud buildup, etc.
8.3 ANSI N45.2.2 Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants (During the Construction Phase)
(a) Scope and Applicability i
The guidance provided by this standard and the associated Regulatory.
Cuide 1.38 shall be applied to packaging, shipping, receiving, storage, and handling activities associated with safety-related items except as noted below.
(b) Specific Exception Our program is structured to identify safety-related equipment and provide for designation of packaging, shipping, receiving, storage, and handling requirements for purchased parts and materials. The classifications of this standard cannot be applied directly to individual spare parts or subassemblies of the parent equipment. Due to difference in volume, complexity, inspectability, etc., the packaging, shipping, handling, and storage requirements of spare parts and subassemblies will necessarily be different from the requirements which may be imposed on the entire component or piece of parent equipment.
The majority of items purchased for an operating plant consist of components, subassemblies, and individual spare parts which could be used in a multitude of dif ferent applications. Such items are purchased to the highest-D-8-3 Revision 0
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Items that require special measures of storage protection will be identified as a part of the purchasing documents. Items that must be stored outdoors (equivalent of Level D) or items that must be stored in covered but unheated conditions (equivalent of Level C) will be evaluated on an individual case basis. However, it is not considered practicable to preclassify individual parts hy levels as required by Section 2.7 of this standard. Shipping and pcckaging requirements for such items will likewise be handled in the purchase order documents, as appropriate.
(c) Implementation The NPPD procurement procedures for safety-related items includes a checklist to verify that the ANS1 N45.2.2 requirements for packing, shipping, receiving, storage, and handling are included in the procurement - document. QA audits and surveillance are performed to verify that the requirements of N45.2.2 are met except as noted in (b) above.
8.4 ANSI N45.2.3 Housekeeping During the Construction Phase of Nuclear Power Plants (a) Scope and General Applicability The guidance provided by this standard and the associated Regulatory Guide 1.39 for control of housekeeping requirements shall be applied to work conditions and other applicable activities which could affect quality of important operational aspects of CNS except as noted below.
(b) Specific Exceptions General Requirements (Section 2)
The plant has been divided in zones for fire protection and security purposes. The zone designated for cleanness in the ANSI Standard are primarily intended for control or work during construction of the plant. Therefore, the CNS facilities will not be classified by the zones designated in the Standard general housekeeping rules. Limitations on eating,. drinking, and smoking are already provided in existing CNS procedures. Where sp'ecial cleanness controls, tool, and material accountability are required for particular types of work, temporary clean areas will be designated and defined in the procedures for accomplishing the work.
Requirements (Section 3)
Fire protection and prevention equipment will be provided as set forth in accordance with NPPD evaluation of the CNS fire protection system as submitted to the NRC on 10/17/76 and 4/6/77.
(c) Implementation Existing maintenance procedures will be reviewed to determine the need for particular cleanness, housekeeping, and control provisions. Where indicated, procedures will be revised to incorporate such provisions, using the guidance of D-8-4 Revision 0
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ANS1 N45.2.3. Appropriate maintenance ' procedures will be updated using these guidelines by July,1979.
8.5 ANSI N45.2.4 Installation, Inspection, and Testing Requirements for !
Instrumentation and Electric Equipment During the Construction Phase of Nuclear Power Generating Stations (a) Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.30 shall be applied to installation, inspection, and testing of electrical equipment and systems associated with on-site safety- related modification work occurring during the operational phase of CNS except as noted below.
Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the SAR and other appropriate design documents, the original design requirements shall govern.
(b) Specific Exceptions Definitions (Section 1.4)
The definition of Class I and Class IE electrical equipment set forth by this standard does not conform to the equipment categories of CNS. Essential electrical items upon which the Operational QA Program is based are included in the SAR Amendment 39. The scope and applicability of this standard shall necessarily be limited to these defined areas.
Procedures and Instructions (Section 2.3)
Appropriate requirements for installation, inspection, and tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the various areas of this standard.
However, in the development of the work package, consideration will be given to the areas outlined in Section 2.3, as appropriate.
Installation, Verification, and Test (Section 4.0, 5.0, and 6.0)
The requirements of the installation and the associated inspections, verifications, and tests are included in the work instructions as appropriate, consistent with the scope of the work and the importance of quality. In the l development of the work instructions, consideration will be given to the guidance provided by Sections 4.0, 5.0 and 6.0 of this standard, and appropriate requirements will be incorporated into the instructions. It is not intended that separate procedures be established which specifically address all of the areas referenced.
l l Applicable Codes, Standards, and Guides (Section 9.0 and Appendix B)
Application of the guidance provided by the additional codes and standards listed in Appendix B will be considered to the extent that such codes and standards provide useful and practical guidance for the work being performed.
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6 USAR Commitment to the guidance of N45.2.4 shall not include commitment to the guidance of referenced standards. (See Regulatory Guide 1.30, Safety Guide 30.)
8.6 ANSI N45.2.5 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.94 shall be applied to activities involving safety- related concrete and structural steel work occurring during the operational phase of Cooper Nuclear ,
Station except as noted below.
(b) Specific Exceptions Procedures and Instructions (Section 2.2)
Appropriate requirements for installation, inspection, and tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the various areas of this standard.
However, in the development of the work package, consideration will be given to the areas outlined in Section 2.2, as appropriate.
Personnel Oualifications (Section 2.4)
The Operational QA Program includes provisions for ensuring that qualified personnel are assigned to monitor work cetivities. (Please refer to Section 8.7 of this document.)
Calibration and Control (Section 2.5.2)
The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied to all measuring and test equipment used by NPPD ot their agents, test laboratories, and contractors. Such requirements, however, will not be imposed on commercial batch plant facilities.
Instrumentation at commercial batch plant facilities will be evaluated by CNS plant management to determine that sufficient accuracy can be obtained and will be verified by an independent QA audit.
Qunlification Tests (Section 3.2.1)
For small quantities of concrete involved in modification work, all concrete must be purchased from comdercial concrete batch plants. For small quantities of concrete, it is unreasonable to expect commercial facilities to shut down normal operations to provide certified aggregate, cement, admixtures, fly ash, water, etc. In this respect, the qualification tests required by Table A for aggregate; cement; admixtures; fly ash, and pozzolans; water and ice will not be required. Appropriate evaluations will be made to determine that good quality and generally-acceptable materials are used. CNS plant management evaluation, coupled with slump tests, air entrainment tests, and concrete cylinder strengths, will provide adequate control and qualification of the concrete. The results of evaluation will be verified by an independent QA audit.
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a USAR Design mixes . consistent with, or.. equivalent to, original. requirements will be specified and the results of the cylinder tests will be evaluated by CNS plant management based on the acceptance criteria associated with the original design mix requirements and will be verified by an independent QA audit.
Protection of-Materials (Section 4.2)
The inspection requirements of Section 4.2 will not generally be performed as the small quantities of concrete involved in modification work will no doubt be mixed using materials already in the batch plant bins. Control of storage of materials would not be practicable.
Measuring, Mixing, and Transporting (Section 4.3)
If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the requirements of ACI-304, ASTM C-94. Where certifications are not available, two concrete test-cylinders representing the first and last one-third of truck mixer contents shall be taken for evaluation of the mixer truck, over and above the normal concrete cylinders taken to evaluate the inplace concrete. The concrete batch plant facility shall be inspected by CNS plant management and the CNS QA staf f to assure that reasonable controls are being exercised with reference to the inspection guidelines set forth by Section 4.3(1) and (2).
Preplacement Preparation (Section 4.4)
Inspection of fills and earthwork will meet the general requirements
-set forth. The extent to which individual inspection requirements are met will depend upon the nature and scope of the work to be performed.
In-Process Tests on Concrete and Reinforcing Steel (Section 4.8)
Except for normal batch qualification tests (slump, air content, temperature, and compressive strength) and initial reinforcing steel certifications, the in-proce'ss tests required by Table B are generally applicable to the periodic 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 by QA at CNS.
(c) Implementation i
Where the need arises, measures will be implemented to meet this standard with the exceptions noted above.
8.7 ANSI N45.2.6 Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants (a) Scope and Applicability
+
The guidance provided by this standard and the associated Regulatory Guide 1.58 shall be applied to inspection, examination, and testing activities associated with safety-related operations, including maintenance, repair, and modification exceptuns noted below.
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's. U g pp.a t (b) Specific Exceptions--
It has always been the belief of CNS and-NPPD thtt, in order to be effective, quality control must be built into the operation of the plant. With this.in mind, CNS incorporated quality control inspection and test functions directly into the station operating procedures. Inspection points are then witnessed and signed-off by members of the operating staff not directly involved in the activity being inspected. Assignment of QC inspectors is a function of station management. The majority of the QC inspections are assigned to engineers, licensed reactor operators, or lead technicians. This method for
.I selecting and assigning inspectors hah ~ assured station uanagement that the best qualified individual (either through education or years of experience) is assigned fi monitor " essential" or safety-related activities. Inspectors will meet ,the requirements listed in paragraph 8.1 (of this amendment) under the part titled " Inspection."
1 The method endorsed by ANSI N45.2.6 places emphasis on certifying g individuals and establishing levels of qualification. It.is our contention that even though an individual is certified and qualified to the appropriate level, he may not be the best inspector in, all situations.
I
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The current method of selecting and assigning QC inspectors at CNS has proven to be very effective. We therefere take exception to Sections 2.0 and 3.0 -
of ANSI N45.2.6. If future operation indicates that our present system is ;
inadequate, the Station Opsrating Review Committee will reevaluate the QC systex and commit to ANSI N45.2.6 or provide an acceptabic alternate.
CNS does not have the in-house capability to perform nondestructive examinations in accordance with SNT-TC-1A. These services are currently contracted to an approved vendor. Any re' quired nondestructive examinations will be performed by personnel who are qualified and certified per SNT-TC-1A.
8.8 ANSI N45.2.8 Supplementary Quality Assurance Requirements for Installation, Inspection,'and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants (a) Scope and Applicability l The guidance provided by this standard shall be applied to '
installation, inspection, and testing of mechanical equipment and systems I associated with on-site safety-related modification work occurring during the
' l operational phase of CNS! g I
Where specific design requireeents included in this standard or i referenced codes and standards are in conflict with original desihn requirements set forth in the SAR and other appropriate design documents, the original design requirements shall govern. g 8.9 ANSI N45.2.9 Requirements for Collection, Storage and Maintenance of l Quality Assurance Records for Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.88 shall be applied to quality assurance records associated with the '
operational phase of CNS.
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) For those design, manufacturing, construction, _and operating records generated prior to implementation of this standard, it is not our intent to 3
-backfit the detailed requirements of this standard to those records. All such
) records, however, have been initially designated for lifetime storage, until L specific review dictates otherwise, and will be stored in the permanent record storage facility. Appropriate record indexes and filing system shall be established to permit reasonable identification and retrieval. The records will be stored and preserved per the requirements of Section 5.0 of this standard.
8.10 ANSI N45.2.10 Quality Assurance Terms and Definitions (a) Scope and Applicability The quality assurance terms and definitions contained in this standard shall be used as guidance and applied as appropriate to the Operational QA Program for CNS.
The use of this standard and the associated Regulatory Guide 1.74 shall be effective immediately. There may be instances where existing procedures contain definitions that may not be in strict accordance with those provided by this standard. As existing procedures are revised, however, such definitions shall be evaluated to determine if all definitions meet those provided by this standard.
8.11 ANSI N45.2.11 Quality Assurance Requirements for Design of Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.64 shall be applied to design activities involving safety-related modification work and the revision or development of plant design documents occurring during the operational phase of CNS.
Where codes, standards, or design requirements are referenced, or are
\ incorporated into the standard by reference, which are in conflict with original
> xldesigncommitmentsasset forth in the SAR, the SAR commitments shall govern.
Later revisions of applicable codes and standards may be specifically invoked by j the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original
/ condition. ,
8.12 ANSI N45.2.12 - 1974 Requirements for Auditing of Quality Assurance Programs for Nuclear Plants (a) Scope and Applicability ,
Except as expressly modified below, the guidance provided by this standard shall be applied to the audit program identified by the Operational QA 1 Program for CNS.
The QA Program will be audited at least once every year and complies with the guidance provided in Regulatory Guide 1.33.
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Follou-up (4.5.1)
The audited organization is required by existing procedures to respond in writing to deficiencies noted in the audit report. A minimum response time is not specified because corrective action varies depending on the nature and extent of the deficiency. However, corrective action is subject to follow-up audits and
} reports to higher management within eight.(8) weeks of issuance of the original l
audit report.
8.13 ANSI N45.2.13 - Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard shall be applied to the procurement of safety-related parts, components, materials, and services during the operational phase of CNS.
(b) Specific Exceptions It must be recognized, however, that equipment and components purchased during the design and construction phase were not purchased on the basis of f)5 , present-day standards, especially with reference to vendor qualification and vendor quality assurance programs. In this respect, replacement parts and spare
- i parts for existing equipment are often limited to sole-source suppliers. Such replacement parts or spare parts are purchased to appropriate quality standards to maintain an " equal to or better than" condition but it is not considered
-practicable to backfit the requirements of the standards to all such vendors.
8.14 ANSI N18.1 - 1971 Selection and Training of Nuclear Power Plant Personnel (a) Scope and Applicability The guidance provided by this standard shall be applied to the selection and training of personnel at CNS.
8.15 ANSI N18.7 - 1972 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants
, -(a) Scope and Applicability The operational QA Program for CNS conforms to the guidance provided by this standard and the associated Regulatory Guide 1.33 excepted as noted below.
(b) Specific Exceptions Where ANSI N18'.7 - 1972 parallels the requirements of ANSI N45.2 through ANSI N45.2.13, exceptions taken shall be applicable to this standard as well. s l
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