AECM-87-0131, Rev 6 to Operational QA Manual (Oqam)
| ML20236G759 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/31/1987 |
| From: | Cloninger T, Kingsley O, Landy R SYSTEM ENERGY RESOURCES, INC. |
| To: | |
| Shared Package | |
| ML20236G739 | List: |
| References | |
| AECM-87-0131, AECM-87-131, MPL-TOP-1A, NUDOCS 8708040378 | |
| Download: ML20236G759 (329) | |
Text
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i INTRODUCTION This Manual describes the Operational Quality Assurance Program estab-11shed by Miesteefppi-Pewer-6-bighe-Gempany-(MP&L) System Energy Resources, j Jnc. (SERJ) to assure that its nuclear power plants are operated in accordance with applicable regulatory requirements and in a manner which protects the public health and safety. The Operational Quality Assurance Program conforms to the criteria established in Appendix B to 10CFR50, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," and to the Regulatory Position in applicable NRC Regulatory Guides and industry standards as delineated in Appendix A to this Manual. Guidance in the preparation of this Manual was obtained from the NRC's " Standard Review Plan" (NUREG-75/087). The Quality Assurance Program described herein is applicable to all MP6b l SERI nuclear ~ power plants which reference it in Section 17.2 of: their Updated Final Safety Analysis Report. The program applies to all operational phase activities (including pre-operational and startup testing) which af fect the safety-related functions of those structures, systcas and components which prevent or mitigate the consequences of postulated accidents which could cause undue risk to the health and safety of the public. I I OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 I INTRODUCTION Page 1 of 1 INTRODUCTION l J260QAMT.NTRO - 1
FOREWORD This Manual prescribes the Operational Quality Assurance Program Policies established by MP&E SERI to control operational phase safety-related activities for the Grand Gulf Nuclear Station. The program described in these Policies complies with the requirements of Appendix B to 10CFR50 and incorporates . appropriate provisions of applicable industry standards and NRC Regulatory l Guides, as delineated'in Appendix A to this Manual. Compliance with.the requirements set forth in this Manual is mandatory for all personnel involved in safety-related activities for the Grand Gulf i Nuclear Station. j Copies of this Manual are numbered for control and will be kept up-to-date by the issuance of revisions, as necessary. The Director, Quality Assurance Programs is responsible for control of the Manual and issuance of revisions. The holders of the Manual are responsible for keeping their copy current by appropriately handling revisions.
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O' D.VKingsle - i T. E. Clon'inger
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ce President Nucle Engineering Vice Presi , r Operations nd Support R. J. Larldy
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Vice Preside , Hwn .ecourece and Administrate on j OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 FOREWORD Page 1 of 1 FOREWORD J260QAMINTR0 - 2 l i
TABLE OF CONTENTS
' POLICY TITLE REV. DATE Policy 1 Organization 6 Policy 2 . Quality Assurance Program 6 Policy 3 Design Control 6 Policy 4 Procurement Document Control 6 Policy 5 Instructions, Procedures and Drawings 6 Policy 6 Document Control 6 Policy 7 Control-of Purchased Material, Equipment and Services 6 Policy 6 Identification and Control of Material, Parts and Components 6 Policy 9 ' Control of Special Prccesses 6 Policy 10 Inspection 6 Policy 11 Test Control 6 Policy 12 ' Control of Measuring and Test Equipment 6 Policy 13 Handling, Storage and Shipping 6 Policy 14 Inspection. Test and Operating Status 6 Policy 15 Nonconforming Materials, Parts or Components 6 Policy 16 Corrective Action 6 Policy 17 Quality Assurance Records 6 !
Policy 18 Audits 6 l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev 6 TITLE: TABLE OF CONTENTS TABLE OF Page 1 of 2 CONTENTS J260QAMINTRO - 3
J 1 ). I TABLE OF CONTENTS POLICY TITLE REV. DATE Appendix A Conformance'of SERI Operational 6 l Quality Assurance Program to NRC Regulatory Guides and ANSI ! Standards j l Appendix B , Document Control Responsibility 6 For Quality Related Documents ]' Appendix C Operational Quality Assurance 6 Program Impicmenting Procedures Record of Revisions Entered 2 6/1/81 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: TABLE OF CONTENTS TABLE OF Page 2 of 2 CONTENTS
-J260QAMINTRO - 4
.1.0 ORGANIZATION m
1.1 PURPOSE ! This Policy describes-the SERI organizations and key personnel responsible , for developing, implementing and verifying the effectiveness of the I
~0perational Quality. Assurance Program for the Grand Gulf Nuclear Station'.
1.2 -SCOPE l t This Policy. defines the organizational structure and delineates the authority, responsibility and lines of. communication for SERI organizations performing functions covered by the Operational Quality Assurance. Program. Certain of tihese functions may be delegated to other qualified .organi-
..zatio'ns,.but responsibility for the program is retained and exercised by SERI.
l j 1.3 ORGANIZATION AND RESPONSIBILITY j Clear and definitive lines of authority, responsibility and communication are established for all SERI organizations involved in the Operational Qut.lity Assurance Program. These lines extend from the highest management level.through intermediate levels to and including the onsite operating organization and offsite organizational elements. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 1 of 16 Policy 1
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'The organizational 1 structure and functional responsibility assignments are' ,
1
, i such that attainment of program objectives is accomplished by those who
;have been assigned responsibility for performing the work, and verifica-tion of conformance to established requirements is accomplished by qualified personnel who do not have responsibility for performing or directly supervising the work.
3 1 l Organizational structure and lines of authority, responsibility and communication are depicted in the organizational charts included at the-end of this Policy. The dashed line between the Director, Quality Assurance Programs and the President & Chief Executive Officer indicates
' guidance on Quality Assurance policy matters and a direct escalation path.
1.3.1 President & Chief Executive Officer Ultimate responsibility for providing top level direction of all j activities associated with the safe and reliable operation of
.the Grsnd Gulf Nuclear Station rests with the President & Chief Executive Officer of the Company. The President & Chief Executive Officer provides guidance with regard to corporate quality assurance policy. He delegates authority and responsibility for the development, implementation and verification of the Operational Quality Assurance Program to the appropriate SERI organizations through the Vice President, Nuclear Operations and the Vice President, Nuclear Engineering & Support. He maintains a continuing awareness of quality assurance matters and monitors effectiveness !
of the program through status reports prepared by the Director, Quality Assuranee Programs. OPERATIONAL OUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 2 of 16 Policy 1 J 250QAM.1 -2 1 _________________j
.1.3.2 Vice Presidsnt, Nuclear Operations ,
I j The Vice' President, Nuclear.. Operations reports directly to the President & Chief Executive Officer and is responsible f for the administration of all functions associated with the operation of the Grand Gulf Nuclear Station, excep't those .
' delegated to the Vice President, Nuclear Engineering & Support.-
i He maintains a continuing involvement in quality assurance , matters and assesses the scope, status,' implementation and H effectiveness of the program through contact with and review of reports issued by the Director, Quality Assurance Programs. It is the Vice President, Nuclear Operation's responsibility to assure that the requirements of the Operational Quality Assurance Program are implemented by the organizations under his direction. 1.3.3 Director, Quality Assuranee Programs The Director, Quality Assuranee Programs fBQA) reports directly to the Vice President, Nuclear Engineering & Support and is delegated the overall authority and responsibility for i establishing, controlling and verifying the implementation and .j adequacy of the Operational Quality Assurance Program (including ) i preoperational and startup testing). This includes the establishment of corporate quality assurance policies, goals and objectives. He is assisted by the Manager, Nuclear G4te Quality Assurance Services; Manageer-Programe-QueMey-Assurence; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 3 of 16 Policy 1 J250QAM.1 - 3 )
M:negar, k;df0s Quality Systems A;sur na'4 end a etaff of quality assurance personnel in residence both in the General Office and at the plant site. The primary duties and responsibilities of the Director, l Quality Assuranee Programs include: 1.3.3.1 Developing and controlling the eeneent-of-ehe Opera-tional Quality Assurance Program and the content of this Manual, including the approval of changes thereto and providing interpretations thereof; i 1.3.3.2 Directing the activities of the General Office quality assurance staff, and the quality assurance staff located at the plant site, in verifying the implementation of the Operational Quality Assurance Program; i 1.3.3.3 Reporting to the Vice President, Nuclear Engineering & i Support and the President & Chief Executive Officer on i the status and adequacy of the Operational Quality 1 Assurance Program; i l 1.3.3.4 Reviewing and approving Opereefenel Quality Assurance ! Procedures; i l l l j l 1.3.3.5 Providing for review of and concurrence with documents l as specified in Appendix B of this Manual; 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION ' Page 4 of 16 Policy 1 J250QAM.1 - 4 , I t - - - - - - - - - - - - - - - - - - - - - - - -
[. l 1.3.3.6 Directing training for quality ensurance personnel; l providing quality assurance input to the training and indoctrination programs for personnel performing quality-related activities; and providing for the j i approval of certificat4.on for all Quality Assurance Personnel. i i 1.3.3.7 Maintaining adequate communications with regulatory I agencies, suppliers, contractors and other SERI organizations on Quality Assurance matters; 1.3.3.8 This section deleted in Revision 4. l 1.3.3.9 Planning and performing supplier evaluations, source inspections, inspections, source quality verification and audits; 4.3.3.10 Developing and carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements; 1.3.3.11 Providing for periodic review and analysis of NRC and I SERI Quality Assurance nonconformance documents to detect possible adverse quality trends. l 4 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 5 of 16 Policy 1 J250QAM.1 - 5
The Director,_ Quality AssurInse Progrews is. independent of undue l 1
' influences and responsibilities for schedules and costs, and has j sufficient authority and organizational freedom to identify quality problems, recommend solutions and verify implementation of solutions. If acceptable solutions cannot be reached he has the responsibility and authority to escalate these matters to i l
the President & Chief Executive Officer. He has the authority, as delineated in the appropriate Quality Assurance Procedure, to L initiate action to stop unsatisfactory work and control further , processing, delivery, or installation of nonconforming items or continuation of nonconforming services pending correction of the nonconforming conditian. The-minimum-quelfficeefen-requirements-fer-the-peefefen-ef-the i Bfreeterr-Que14ty-Assurance-eve-ee-deserfbed-in-ANSI /ANS-Bv4 I fBreft-4G/79)r-Peregraph-4r4r67--Gee-Appendfw-A, 1.3.4 Manager, Neeleer 64ee Quality Assurance Services The Manager, Neeleer Site Quality Assurance fMN6QA) Services reports to the Director, Quality Assuranee Programs and.is located at the plant site. He directs the quality assurance staff located at the plant site and the General office in enditer-menteering, inspections (except for receipt inspec-tions), nondestructive examination and reviews of plant site j l activities--including the activities of the plant staffrand the q huclear Plant Engineering staff freview-ef-design-deenmente-onlytv-the-etereup-seeffy-and-enstee-eenereceere-and-een-auteente to verify implementation of the Operational Quality OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 6 of 16 Policy 1 J250QAM.1 - 6 ____-- _ ___o
l Assurance Program at the plant site. He is responsible for ] coordinating the review of all SERI procedures, as delineated in Appendix B to this manual to assure quality requirements are addressed; development, interpretation and maintenance of the j Operational Quality Assurance Program and Procedure Manuale. He is responsible for the control, processing, tracking, dispoei-tioning, and verification of nonconformance documente. He has. the authority, as delineated in the appropriate Quality Assurance Procedure, to initiate action to stop unsatisfactory work and control further processing, delivery or installation of nonconforming items or continuation of nonconforming services pending correction of the nonconforming condition. 1.3.5 GGNS General Manager The GGNS General Manager reports to the Site Director GGNS and is delegated the responsibility and authority for assuring the safe, reliable and efficient operation of the plant within the constraints of applicable regulatory requirements and the operating license. He supervises the operating plant staff; approves Plant Administrative Procedures; authorizes implementa-tion of design changes and plant modifications; implements repairs; reports appropriate matters to management and the Safety Review Committee; and generally administers plant opera-W .is on a day-to-day basis. He has overall responsibility for execution of the Operational Quality Assurance Program at the plant site; except for implementation and testing of design changes and plant modifications and the preoperational testing OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 7 of 16 Policy 1 J250QAM.1 - 7
1_' on Unit 2;.and has the' authority to stop work if an activity at i the Plant is not in conformance with program requirements. He j has overall' responsibility for developing systems to manage the-storage and retrieval of records within the Neelear'Producefen . Depasemene SERI and for coordinating the turnover of contractor vendor records. It is the responsibility of the GGNS General Manager to assure that these functions are performed in 'j l accordance with the requirements of the Operational Quality. 1 Assurance Program. ! l The GGNS General Manager is assisted in carrying out his responsibilities by the Manager, Plant Operations; the Manager, Plant Maintenance and the Manager, Plant Support a6 well as the operating plant staff--which includes individuals knowledgeable in plant radiation protection,-erefningy and plant security. In addition, the GGNS General Manager oversees the activities of the Plant Safety Review Committee and provides for necessary liaison with the Safety Review Committee of which he is a member. 1.3.6 This Section deleted.in Revision 4 1.3.7 Director, Nuclear Licensing end-Safety The Director, Nuclear Licensing-and-Safety reports to the Vice President, Nuclear Operations and is responsible for directing the activities of the Nuclear Licensing-and-Safety Staff. He is assisted by the Manager, Nuclear Licensingt and the Manager, Neelear-Safety-and-Gempliance Licensing Supporty-ee-well-ee-ehe OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE:' ORGANIZATION Page 8 of 16 Policy 1
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ll 1 Nasisce-Lfsensing-ind-Safety-Serff. The Nuclear Licensing end-Safety Staff is responsible for securing the licenses.and permits required to construct and' operate the plant. The Nuclear Licensing-and-Safety Staff also provides technical assistance.in.the ar9as of safety analysist-emergency-pienningt and fire protection. This staff provides support to the Vice-President, Nuclear Operations in matters related to Safety Review Committee activities. It is the responsibility of the Director, Nuclear Licensing-end-Enfety to assure that these functions are performed in accordance with the requirements of the Operational Quality Assurance Program. 1.3.8 Director, Nuclear Plant Engineering The Director, Nuclear Plant Engineering reports to the Vice President, Nuclear Engineering 6 Support, and is responsible for directing the activities of the Nuclear Plant Engineering Staff. The-Nuclear Plant Engineering, consisting of the Nanager, Operational Analysie; Manager, Engineering Support; Manager, Nuclear Design and their respective staffs are-Geeff-ke re-sponsible for plant design, design review, modifications, chemical / environmental analysis, special processes,-and op-erational analysis programar , and accident and transient l analyses. It is the responsibility of the Director, Nuclear Plant Engineering to assure that these functions are performed I in accordance with the requirements of the Operational Quality q Assurance Program. The Director, Nuclear Plant Engineering is l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 9 of 16 Policy 1 . J250QAM.1 - 9 __________J
responsible for reviewing flPE design docunente for compliance with the Operational Quality Assurance Program requirements and
. concurring with the same.
1.3.9 Safety' Review Committe'e (SRC) Committee composition, responsibility and authority, subjects to-
~
be' reviewed, administrative controls, and' reporting' requirements-i are addressed in Section 6 of the Technical Specifications for the applicable nuclear generating station.
" 1.3.10- Plant Safety Review Committee (PSRC)
Committee composition, responsibility and authority, subjects to be reviewed, and reporting requirements are addressed in Section l6 of.thel Technical Specifications for the applicable nuclear generating station. l i 1.3.11- Manager, Purchasing and Manager, Contract Administration The Manager, Purchasing and Manager, Contract Administration are responsible for perf~orming procurement activities in ac-
- j. cordance with the Operational Quality Assurance Program, as coordinated with the Site Director CGNS; GGNS General Manager; i ' Manager, Unit 1 Projects; the Director, Nuclear Licensing-end
- . Safety; the Director, Nuclear Plant Engineering; the Director,
*' Quality Assueenee Programe; the Director, Nuclear Support; the Director, Corporate Services and other appropriate SERI personnel.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE:- ORGANIZATION Page 10 of 16 Policy 1
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J _1;3;12- :Other Organizations
'Other organizations, contractors, or consultants may be dele-gated certain functions which fall under.the Operational Quality Assurance Program. In such cases, SERI shall retain responsibility for the delegated work.
1.3.13 Minimum Qualifications of Quality Assurance Personnel I The qualification requirements and experience levels for key H quality assurance personnel are such as to assure competence i commensurate with the responsibilities of-the position and are j described in ANSI /ANS 3.1-(Draft 12/79). See Appendix A. Key quality assurance personnel include the Director,-Quality , Assurance Programs and, the Manager, Nueleer 64ee Quality- ; i Aeeurencer, Services and the Manager, Quality Systems. i L 1.3.14 This section deleted in Revision 5 1.3.15 Meneseer-Unfe-9-Geneeruee4en Unit 2 Construction Superintendent The Menegery-Unfe-E-Genservetten Unit 2 Construction Superintendent reports directly to the Vice President, Nuclear l Engineering & Support and is immediately responsible for administration of all functions associated with the preopera-tional testing of the Grand Gulf Nuclear Station Unit 2. It is the Menegery-Unfe-G-Geneerneesente Unit 2 Construction Superintendent 's responsibility to assure that the requirements of the Operational Quality Assurance Program are implemented by OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 11 of 16 Policy 1
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i i h -the organizations.under his direction.. The Mansgser-Unte-E-Genetruetten Unit 2 Construction Superintendent maintains a continuing involvement 1n preoperational phase testing, quality
. assurance matters, and sssesses the implementation'and-effectiveness of the program through contact with and reports furnished by the Director, Quality Assurance Progrows.
% '1.3.16 Director, Nuclear Support-The Director, Nuclear Support reports to the Vice President, Nuclear Engineering & Support and is responsible for directing Lthe activities of the Nuclear Support Department. The Nuclear Support Department, consisting of the Manager, Nuclear Services 6' Fuels;. Manager, Radiological and Environmental' Services; Manager, Contract Administration; and their respective statis
' provide technical support in the areas of environmental li-
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censing and permitting; health physics; environment.a1 pro-tectionr; chemistry; waste management; fuel cycle management-including the control of the design activities associated with u
- nuclear core design (except those activities associated with accident and transient analyses); developing, bidding, awarding and administering contracts; and, departmental administration.
It'is the responsibility of the Director, Nuclear Support to assure that these functions are performed in accordance with the requirements of the Operational Quality Assurance Program. I 1.3.17 This section deleted in Revision 5 l 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 i TITLE: ORGANIZATION Page-12 of 16 Policy 1 ]
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h 21.3.18' .Minnger, AOdfes Quality: Systems -Anne:nne
^
The Manager, Quality A' dies u Systems Assueenee fMAQA) reports ~ directly to the Director, Quality Aesweenee Programe and is located at the General office. .He directe quality assurance
~ etaff located at the plant aite and.the Generat office and He is responsible for planning, scheduling, coordinating and performing all~ internal peegram audits and monitoring, source quality verifications, receipt inspections, audits of oneite contractors and coneuttante and offeite suppliereendite.
~He assures' performance of the quality review of procurement j documents; performs pre-award evaluations of suppliers; and is responsible for coordinating source inspection. and-reeefpe inepeetiens He is responsible for trend analysis and reporting
-of reeutta to the appropriate levels of management as required by Quality _Accurance Procedures. He plane, echedulee and coordinates the training and certification of Quality Assurance personnet. He coordinates and/or implemente administrative services for the Quality Assurance Organization. In addition,-
he coordinates, -develope and issues Quality Assurance reporte as required by SEHI Management and appropriate procedures. He has A the authority, as delineated in the appropriate Quality ) Assurance Procedure, to initiate action to stop unsatisfactory work and control further processing, delivery or installation of nonconforming items or continuation of nonconforming services-pending correction of the nonconforming condition.
-OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ' ORGANIZATION Page 13 of 16 Policy 1 J250QAM.1 - 13
1.3.19 Managery-Programe-Qualfey-Assuranee i l
- Fh e-Me ne s,e ry-P r e g r eme-Qu e 14 e y- Ae eur a n ce-(MPQ A}-r ep or te-d ir e c ely 4
ee-the-Pireceeer-Quelfey-Assurenee-and-fe-leeeeed-at-the-General Officer--He-fe-respenefble-fer-ceerdinating-ehe-review-ef-ell nuclear-producefen-deparement-preceduceer-es-defineeeed-in Appendfx-B-ee-thfe-menuel-ee-eesure-quelfey-requiremenee-ere addressedt -developmener-interpreteefen-and-mefneenenee-ef-the Opereefenel-Quelfey-Assueenee-Progrew-end-Precedure-Manualer--He assuree-treeking-ef-quelfey-releted-Open-leemer-eenduet-ef-trend enelysie-and-reperefng-ef-resules-ee-the-apprepefeee-levele-ef manegemene-ee-required-by-Quelfey-Assurance-Precedureer--He piener-schedules-and-eeerdinates-the-trefning-end-eerefficetten ef-Quelfey-Ameurenee-pereennelv--He-eeerdinates-end-fsplemenes adminfeereefve-servfees-fer-the-Quelfey-Assurance-Orgenfeettent in-edditteny-he-eeerdinseeer-develope-and-feenee-Quelfey Assuranee-reperee-es-required-by-SER1-Managemene-and appropetete-procedurces This section deleted in Revision 6. 1.3.20 Manager, Unit 1 Projects The Manager, Unit 1 Projects reports directly to the Site Director GGNS and is responsible for modification costs and schedules, for project management direction, and for coordination with the Director, Nuclear Plant Engineering; the Manager, Plant Modification and Construction; and the GGNS General Manager. He is also responsible for providing administrative direction to the Manager, Plant Modification and Construction for the implementation and testing of design OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 14 of 16 Policy 1 J250QAM.1 - 14 _ _ _ _ _ _ _ _ _ _
l 1 chengas and pl:nt modifications. It is tha Manager, Unit l' Projects responsibility to assure that the requirements of the Operational Quality Assurance Program are implemented by the-l organizations under his direction. 1.3.21 Vice President, Nuclear Engineering & Support l l 4 The Vice President, Nuclear Engineering & Support reports directly to the President & Chief Executive Officer and is responsible for the administration of all functions associated with engineering and support of GGNS. He provides guidance with regard to corporate quality assurance goals and objectives to the Director, Quality Assurenee Programs. He maintains a continuing awareness of quality matters through applicable inspection reports and management audits of the program. He is also responsible for coordination of corporate quality assurance j matters, as they relate to procurement. 1 i 1.3.22 Site Director GGNS The Site Director GGNS reports directly to the Vice President, Nuclear Operations and is responsible for training. He also providinges management direction to the GGNS General Manager and the Manager, Unit 1 Projects. It is the responsibility of the Site Director GGNS to assure that these functions are performed ; in accordance with the requirements of the Operational Quality Assurance Program. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 15 of 16 Policy 1 J250QAM.1 - 15
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1 r , i.3.23- . Manager, ' Dneriency Preparedness
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.O The Manager, Emergency Preparedness reporte directly to the Vice President, Nuclear Operations and is responsible for the
- Emergency Preparedness program and associater' activities.' It is y the responsibility of the Manager, Dnergency Preparedness to
' assure these functions are perfonned in accordance vithLthe.
Requirements of the Operational Quality Accurance Program. bj. 1.3.24 Manager, Operational Analysis t I i
.. 1 The Manager, Operational Analysis is responsible for carrying out the activities of the Independent Safety Engineering Group (ISEG)'ae described in Technical Specification 6.2.3.
4 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
< TITLE: ORGANIZATION Page 16 of 16 Policy 1 LJ250QAM 1 t L' - ._ .- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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2'.0 ' . QUALITY ASSURANCE PROGRAM
. 2.1 '- PURPOSE-l This Policy describes'the. Operational Quality Assurance Program estab-kr lished by MPE SERI for the Grand Gulf Nuclear Station.
2.2 SCOPE This' Policy describer the Operational Quality Assurance Program in terms of the. objectives to be accomplished, the requirements to be met, and the implementation and control mechanisms which'have been established. The total program is described throughout this Manual. p 2.3 APPLICABILITY
- The requirements of:the Operational Quality Assurance Program apply to all individuals or organizations performing functions during the operational' phase which' affect the quality of safety-related structures, systems, n i components or services.
Operational phase functions to which the program applies include: design-ing, purchasing, fabricating, handling, shipping, storing, cleaning, I erecting, installing, inspecting, testing (including preoperational and I startup), auditing, operating, maintaining, repairing, refueling, and modifying (Except major modifications which may be excepted and covered under an NRC accepted construction QA Program per 0QAM 3.5.18. See Appendix A).. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE:' QUALITY ASSURANCE PROGRAM Page 1 of-12 Policy 2
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L t2.4. POLICIES, COALS AND OBJECTIVES l. Corporate quality assurance policies, goals, and objectives are summarized in the statement that all individuals and organizations within MP6b SERJ who perform quality-related activities have personal and corporate
" responsibility to assure that the Grand Gulf Nuclear Station is designed, constructed and operated in a manner which protects public health and safety and promotes reliable and efficient operation.
The Operational Quality Assurance Program is designed to provide the mechanism for assuring that these policies, goals, and objectives are achieved. 2.5 PROGRAM DESCRIPTION : The Operational Quality Assurance Program, as' described throughout this Manual, delineates the seasures established by MP&L SERJ to assure that activities whfch affect t6e quality of safety-related structures, systems, components and services are performed in a controlled manner and are sufficiently documented to provide objective evidence of compliance with established requirements. I The Operational Quality Assurance Program is documented by written policies, procedures, and instructions; and shall be carried out throughout the life of the plant in accordance with these policies, procedures, and instructions. These documents convey MP6b SERI quality OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 2 of 12 Policy 2 J250QAM.2 - 2
assurance philosophy and requirements to all levels of managsment and to all organizations and individuals involved with program implementation. The applicable Policies of the Operational Quality Assurance Program are mandatory for safety-related activities and functions as described in this Manual. The Operational Quality Assurance Program applies to all activities, l including the use of expendable'and consumable matarials, affecting the safety-related functions of those structures,-systems and components which prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The program is designed'to comply with the requirements of Appendix B to 10CFR50, {
" Quality Assurance Criteria for Naclear Power Plants and Fuel Reprocessing Plants" and with the Regulatory Position in applicable NRC Regulatory Guides and ANSI Standards as listed in Appendix A to this Manual.
A listing of structures / systems / components designated safety-related is included in the UFSAR for the applicable nuclear generating station. A' Q-list which contains as a minimum those structures / systems / components designated as safety related in the UFSAR plus those selected non-safety j related' structures / systems / components to which the Quality Assurance Program applies is issued and maintained current. l Nuclear Plant Engineering is responsible for the development and maintenance of this Q-List in accordance with written procedures which delineate the contents of the Q-List. The procedures will assure that l structures / systems / components listed in the UFSAR are contained in the OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 3 of 12 Policy 2 LJ250QAM.2 - 3 -] l L_w_ . . I
'Q-list. fThe distribution of the Q-List will be procedurally controlled.
p The positions authorized to approve changes to the Q-List'are designated
'in: Appendix B of this Manual.
The applicable requirements of the program are also. imposed upon con-tractors, suppliers and consultants. Development, control, and use of computer programs for design control activities--as described in Policy 3 for safety-related structures, systems and components--will be conducted in accordance with the Opera- ! tional QA Program. 2.5.1 Operational Quality' Assurance hanual The Operational Quality Assurance Manual consists of MP&L SERI quality assurance policies, goals, and objectives and has been o developed in accordance with applicable regulations, codes, and standards. It describes the Operational Quality Assurance-Program'and delineates the responsibilities and requirements impoced by the program for the performance of safety-related activities. The Director, Quality Aeeurence Programs is responsible for maintaining the Manual and controlling its distribution, including revisions thereto,~in accordance with approved Quality Assurance Procedures. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 4 of 12 Policy 2 J250QAM.2 - 4 1
- Revisions to the_ Manual will be processed per 10CFR50.54(a).
2.5.2 Implementing Policies, Procedures and Instructions L The; Operational Quality Assurance Program is implemented through the use of written, approved policies, procedures and instruc -
,tions generated by the organizations responsible for.the per-formance'of the specific functions as outlined in Appendix B of this Manual..
The Quality Assurance Procedure Manual contains the implementing procedures for.the quality functions performed by the Quality j Assurance Organization. '!,ality Assurance Procedures provide measures to assure that quality-related activities are performed in a controlled manner and are documented to provide objective evidence of compliance with program requirements. The Director, Quality Assurance Programs is responsible for approving Quality Assurance Procedures prior to implementation. Quality-related functions performed by other organizations are controlled and documented in accordance with procedures prepared, approved and controlled by the organization performing the function. These procedures assure that the functions are accomplished in a controlled manner, with specified equipment, under suitable environmental conditions, and that prerequisites have been satisfied prior to inspection or testing. Plant Administrative Procedures provide the means whereby quality-related activities at the plant site including those of OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 5 of 12 Policy 2 J250QAM.2 1 i the Plane Modification and Construction Section are controlled and documented to provide' objective evidence of comp 11ance with program requirements. The CC'.) ueneral Manager reviews and approves all Plant Administrative Procedures with the Manager, Unit 1 Projects'also reviewing and approving those Plant-Administrative Procedures controlling the activities of the _ Plant' Modification and Construction Section. Nuclear Support Administrative Procedures provide'the means for assuring that the quality-related activities of the Nuclear Support Staff are controlled and documented to provide objective evidence'of compliance with program requirements.. Nuclear. Support Administrative Procedures are. reviewed and approved by the Director, Nuclear Support. Nuclear Licensing and-Safety Administrative Procedures provide the means for assuring that the quality related activities of the Nuclear Licensing end _ Befety Staff are controlled and documented to provide objective evidence of compliance with program requirements. Nuclear Licensing end-Safety Administrative Procedures are reviewed and approved by the Director, Nuclear Licensing end-Gefety. . Nuclear Plant Engineering Administrative Procedures provide for assuring that the quality-related activities of Nuclear Plant Engineering' are controlled and documented to provide objective evidence of compliance with program requirements. Nuclear Plant Engineering Procedures are reviewed and approved by the Director, Nuclear Plant Engineering. The GGNS General Manager also reviews and
. approves Nuclear Support Administrative Procedures and Nuclear Licensing end-Safety Administrative Procedures which provide for OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 6 of 12 Policy 2 J250QAM.2 - 6
tp offlusnt end environmental monitoring and Emargency Plan im . F p1ementation. Corporate Services Administrative Procedures provide the means for assuring that the quality related ac-tivities of the Corporate Servicea Staff are controtted and documented to provide objective evidence of compliance uith program requirements. Corporate Services Administrative Procedures are reviewed and approved by the Director, Corporate Services. Required quality reviews and concurrence are per-formed by.the Director, Quality-Ansuranee Programe,'as described in Appendix B to this Manual. Appendix C to this Manual provides a matrix of Quality Assurane procedures cross-referenced to the criteria of Appendix B to 10CFR50 which they implement. 2.5.3 Indoctrination and Training Indoctrination and training programs are established for both onsite and offsite personnel performing quality-affecting activ-ities by the organizations responsible for the activities. These programs are implemented by appropriate training plans and procedures which assure that: 2.5.3.1 Personnel responsible for performing quality-affecting activities are instructed as to the purpose, scope and implementation of manuals, procedures and instructions; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 7 of 12 Policy 2 J250QAM.2 .7
. _ _ . . _ - _ _ _A
2.5.3.2 Personne1' performing quality-affecting activities-are trained and qualified in the principles and' techniques of the activity being performed;
.3.3 Proficiency of personnel performing quality-D affecting activities is maintained by retraining .
reexamining or decertifying; 2.5.3.4 The scope, method and objective of the training t' are documented; 2.5.3.5 Records of training sessions are prepared and maintained, including identification of the content, the attendees and the date the training was conducted. 2.5.4 This.section' deleted in Revision 5. 2.5.5 Resolution of Disputes Disputes arising between MP&L SERI organizations on any quality assurance matter which cannot be resolved by management of'the involved organizations will be referred to the Vice President. Nuclear Engineering & Support or the Vice President, Nuclear Operations for tesolution. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 8 of 12 Policy 2 LJ250QAM.2 - 8
L. 4 L,' l 2.5.6 Quality Responsib111 ties-i p-Quality responsibilities for the implementation of major activ-
.ities addressed.in this Manual are designated.in the: individual policier *? this Manual.
'2.5.7- Preoperational Testing and Plant Turnover !
i The' Unit 2 Construction Superintendent, who is responsible for
'the administration of,all Unit 2 construction and preoperational j 1
phase activities for the plant, provides the managemenc j i interface with the principal contractors.in' planning and 1 1 providing for preoperational testing and plant turnover. The f GGNS General Manager who is responsible for the administration' i of.'all startup testing activities for the plant, provides the i management interface with the principal contractors in' planning and providing for startup testing and plant turnover. The. Unit 2 Construction Superintendent is responsible fel the performance of preoperational phase testing, and the GGNS General Manager is i responsible for the performance of startup testing. Each is I also responsible for plant turnover activities (i.e., turnover j from construction testing to MP6b SERJ Plant Staff) with support supplied.by the principal contractors. Prior to the actual turnover, written procedures are developed by these.organiza- ! tions for the control of the transfer of all portions of the plant, including documentation. l 4 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 9 of 12 Policy 2 J250QAM.2 Appropriate Quality Assurance Procedures provide for auditing and inspection of preoperational testing, startup and plant i turnover activities to verify conformance with Operational Quality Assurance Program requirements. The GGNS General Manager is responsible for the control of the turnover of construction records and documentation from contractors and suppliers. , 2.5.8 Definitions The terms and phrases given in the " Definition" portions of the ANSI Standards endorsed by this Program in Appendix A shall apply as well as those given in pertinent sections of the applicable portions of Title 10, Code of Federal Regulations. i l As used throughout this Operational Quality Assurance Program and i implementing procedures, the following words shall be cont' oed to have the special definitions given: 1 2.5.8.1 Shall - A requirement considered enforceable by the appropriate regulatory body. 2.5.8.2 Should - A recommendation, but not an enforceable requirement. Management expects each employee using plant directives to carry out any "should" statement unless circumstances prevent or l necessitate a deviation. In those unucual l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 ! TIT 1.E: QUALITY ASSURANCE PROGRAM Page 10 of 12 Policy 2 f J250QAM.2 - 10 l
i
' occurrences where deviation is necessary, the employee must justify the exception to the responsible Manager.
4 2.3.8.3 May - An option, neither a recommendation or a requirement. e - 2.5.8.4 Must - A requirement normally established by MP&L SERI management or may be used to meet regulatory intent. 2.5.8.5' -Additional items are defined in Appendix A (see under Regulatory Guide 1.74), individual Quality Assurance Procedures and other. quality documents. U 2.5.8.6 Any words'which have not been defined'in 1 through 5 above or item 7 below shall be as defined in a contemporary collegiate dictionary.
-by a well known publisher or authority.
2.5.8.7 Will - Is defined the.same as Shall. 2.5.9- Quality Assurance Position Statements Quality Assurance Position Statements are issued when considered necessary by the Director, Quality-Assurance Programs, for use in interpretation of certain commitments in the Operational Quality Assurance Manual. These statements are not a part of OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 11 of 12 Policy 2
;J250QAM.2 __ _ _ _ _ _ _ _ _ _ _ _ _
r (.1-',
. l the NRC accepted Operational Quality Assurance Manual,'and are l
\
being included in the manual binder only for the' convenience of 1
-the users.
I 1 , 2.5.10 Resolution of Differences _ Every attempt has been made to include the pertinent require-monts from.' external documents, included in this Program by'the commitments in Appendix A, within these Policies; no known conflicts exist between those commitments and these Policies. Differences arising during future reviews or implementation of the Program, must be brought to the attention of-the 31 rector, Quality-Assurance Programs who-wfH initiates changes to the commitments or the Policies ar necessary to resolve the differences. The provisions delineated in these Policies shall take precedence over differing requirements given elsewhere until the Director, Quality-Assueenee Programs has evaluated the issue and' determined which requirement (s) must be modified. I r OPERATIONAL QUALITY ASSURANCE MANUAL Rev 6 TITLE: QUALITY ASSURANCE PROGRAM Page 12 of 12 Policy 2 J250QAM.2 - 12
l l t l 3.0. DESIGN CONTROL i 3.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by NPd& SERI to control design activities affecting safety-related structures, systems and components for the Grand Gulf Nuclear Station. 3.2 SCOPE This Policy delineates responsibilities and defines requirements for the development and implementation of design control measures to assure that design activities are carried out in a planned, controlled and orderly manner. 3.3 APPLICABILITY The requirements of this Policy apply to all organizations performing design functions on safety-related structures, systems or components during the operational phase of nuclear power plant activities. 3.4 RESPONSIBILITY 3.4.1 Responsibility and authority for the control of design ac-I tivities related to modifications or changes to plant safety-related structures, systems or components (including control of accident and transient ar.alyses, but excluding nuclear fuel and nuclear core design--see 3.4.5) during the operational phase are OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL Page 1 of 9 Policy 3 J250QAM.3 - 1 _
l delegated to the Director, Nuclear Plant Engineering. The GGNS General Manager authorizes the design modification or change to be implemented by the Manager, Unit 1 Projects. The Director, Nuclear Plant Engineering is responsible for assuring that procedures are developed and implemented to control the design activities of Nuclear Plant Engineering in accordance with the requirements of this Policy. 3.4.2 The' reviewing of proposed 10CFR50.59 changes is. completed as required by the Technical Specifications. This is described in appropriate procedures. When a proposed change.is requested, the Director, Nuclear Plant Engineering-makes initiates the design changer-and-the-Bireeeeer-Nuetear Licensing-and-Safety performe-the-lfeeneing-revfew-end-asences-eubafteel-te-the-Befety-Revfew-Gemmisseer (except in cases related to nucicar fuel and core desi:n) and assures submittat of the design change package, including the safety evaluation per 20CFRSO.59, to the Plant Safety Review Committee (PSRC). The Manager, Nuclear Services & Fuete is responsible for initiating design changes related to nuclear fuel and core design and for coordi- i nating with Nucicar Licensing and Nuclear Plant Engineering in the development of required 1CCFR50.69 evaluation (s) and subnittat of the design change description and evaluation (s) to the PSRC. The Manager, Plant Modification & Construction is responsible (except in cases related to nuclear fuet) for the i OPERATIONAL' QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL Page 2 of 9 Policy 3 J250QAM.3 - 2 i l l
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t; .i b, I coordination of scheduling and instattation of plant . 3
-modification, bettermente and repairs once approved by the.
i- ' 'l l PSRC.. The GGNS General Manager is responsible for the l echeduling and~ installation of nuclear fuet and core related design changes once approved by the PSRC. The' Secretary of the Safety Revieu Ccmittee (SRC) assurce the review of the safety evaluation by the SRC. The Director, Nuclear Licensing is responsible for developing a sumary of the safety evaluation and cubmittal of the sumary 'to the NRC, as required by 10CFR50.59. 1 3.4.3 Organizations supplying material, equipment or services are responsible for complying with the requirements of this Policy to the extent specified in the applicable procurement documents, and for imposing them on their contractors and suppliers, as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 3.4.4 The Director, Quality-Assurance Frograme is responsible for reviewing eGGeite nuclear fuel and nuclear core (excluding accident and transient' analyses) design documents.for compliance with Operational Quality Assurance Program requirements and con-curring.with same; for monitoring the implementation of design control measures by offsite organizations; and for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program OPERATIONAL QUALITY. ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL Page 3 of 9 Policy 3
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requirements, including the' requirements of this Policy. Those 1 effefte design documents include the type design documents originated, reviewed and approved by MP&b-effsfee-ergenfeeefene (fneluding-Nuelear-Piene-Engineering) the Manager, Nuclear j i Services & Fuels. The-Menegery-Nuclear-Site-Quelfey-Assuranee I fs-reepensible-fee-eeviewing-NPE-deefgn-deeumente-fer-eempliance wfeh-0pereefenal-Quelfey-Assurence-Peegram-eequiremenes-and eeneureing-wfeh-ehe-eamer f 3.4.5 Responsibility and authority for control _of design activities i related to modification of or changes to nuclear fuel or nuclear core design (excluding control of accident and transient anal-ysis activities - See 3.4.1) are delegated to the Manager, i i Nuclear Services 6 Fuels. He manages and coordinates the f
. activities of nuclear fuel suppliers and other appropriate organizations. The Manager, Nuclear Services & Fuels is in-volved in: providing design inputs; providing interface control; reviewing all " accept-as-is" or " repair" dispositions for i
nuclear fuel or core configuration nonconformances. In addition he may perform design verification. The Director, Nuclear Support is responsible for assuring that procedures are de-veloped and implemented for the above design activities in accordance with the requirements of this Policy, i l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL Page 4 of 9 Policy 3 EJ250QAM.3 - 4 4
3.4.6 R3: possibility and authority for control of' 'd a::ign activit1Gs (including accident and transient analyses, but eneeps ex-
.cluding modification of or changes to nuclear fuel or nuclear core design) are delegated to the Director, Nuclear Plant Engineering. Generally, the Director, Nuclear Plant Engineering is involved in: providing design inputs, providing interface control; controlling design output; and performing design verification. The Director, Nuclear Plant Engineering is responsible for assuring that procedures are developed and I
implemented for the above design activities in accordance with ! the requirements of this Policy and will provide or concur with all " accept-as is" or " repair" dispositions (including accident and transient analyses, but eneeps excluding Ger modification of or changes to nuclear fuel or nuclear core design) for non-contormances. The Director, Nuclear Plant Engineering is re-eponsible for reviewing NPE design documente for compliance uith the Operational Quality Assurance Program requirements and concurring with the same. 3.5 REQUIREMENTS 3.5.1 Organizations having design responsibilities shall develop procedures, consistent with the scope of their responsibilities, to provide measures for the control of their design activities. I I l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL Page 5 of 9 Policy 3 J250QAM.3 - 5 i L___
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3.5. 2 . Proceduras shall ba davslopsd to assure that cpplicable.
' design inputs such as design bases, regulatory requirements,.
codes and standards are identified and documented, and are-correctly' translated into design output documents such as specifications, drawings, procedures and instructions. I 3.5.3. . Procedures shall provide for the identification and documen-tation of appropriate quality standards to be specified.in the design documents. Deviations and changes from these quality'
. standards-shall be' controlled.
3.5.4 Procedures'shall. include measuresLfor: the control of' design. analyses such as reactor physics, seismic, stress, thermal, hydraulic, radiation, and accident analyses; compatibility of materials; accessibility for inservice inspection, maintenance,- and: repair.. 3.5.5 Provisions shall be made in the procedures for the selection of suitable materials, parts, equipment, and processes which include the use of. valid industry standards and specifications. 3.5.6 Procedures shall require that designs be reviewed to assure that: design characteristics can be controlled, inspected and tested, as appropriate; and, inspection and test criteria are identified. Such reviews shall be documented. J i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL' Page 6 of 9 Policy 3 J250QAM.3 - 6
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. . j
1 5 N -3.5.7 Matorials, parta and equipment which are standard, commar-cial-(off-the' shelf), or which have. been previously approved for a'different application shall be reviewed for suitability prior to selection. Such reviews shall be documented. 3.5.8- Procedures shall provide for the control of' design' inter-faces' for managing the flow of design infonnation between organizations. Systematic methods shall be established for communicating needed design informatic2 across the interfaces, including changes to the design information as the work progresses. L 3.5.9 ~ Procedures shall include requirements to verify that the design is adequate and that it. meets the specified design inputs. .The extent of the design verification required shall be
.a function of.the importance to safety of the item, the complexity of the design, the degree of standardization, the state-of-the-art and the similarity with previously proven designs. In each case however, standardized or previously proven designs shall be reviewed for applicability prior to use. !
3.5.10 Acceptable verification methods shall include, but not be limited-to, design reviews, alternate calculations, or qualification testing. If a test program is used to verify the adequacy of a design, qualification testing of a prototype unit
.under the most adverse design conditions which are appropriate, shall be used.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL Page 7 of 9 Policy 3 )
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3.5.11 Individuals or groups responsible for design reviews or other verification activities shall be identified in the procedures and their authority and responsibility shall be defined and contcolled. Design verification shall be performed by any j cowjetent individuals or groups other than those who performed l the origirel design but who may be from the same organization. This veri 2' cation may be performed by the originator's supervisor i provided the supervisor is the only technically qualified individual available and the appropriate clarification provisions listed in Appendix A to this Manual are met. 3.5.12 Design and specification changes, including those originating onsite, shall be subject to the same degree of control as the original design and approved by the original design organization unless another qualified, responsible organization is specifically designated. 3.5.13 Errors and deficiencies in the design process, including computer programs, that could adversely affect safety-related structures, systems or components shall be documented, and corrective action taken to preclude repetition. 3.~ 5 .14 Proposed modifications or changes which involve an unre-viewed safety question or a change to the technical specifi-k cations shall be handled in accordance with procedures which ' address the requirements of 10CFR50.59. q l Rev. 6 j OPERATIONAL QUALITY ASSURANCE MANUAL TITLE: DESIGN CONTROL ( Page 8 of 9 Policy 3 I J250QAM.3 - 8 l _. _ - _ _ - _ _ _ . _ _ . ________-_a
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.Dcsign rscords shall ba mzintainad by ths GGNS Gsnaral' 13.5.15; Manager in~accordance with Policy 17.0 of this Manual. 1 3.5.16 This Section. Deleted.in Revision 4.
l-o L ~3.5.17 Plant Procedures are provided to assure that responsible plant 1 personnel are made aware of design changes / modifications which
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may directly-affect the performance of their duties. 3.5.18. During operational phase activities of a unit and while the A-E/ Constructor or his suppliers are performing design.or construction activitles for that-unit, another unit, or for e r shared facilities at GGNS,-MP&b SERI may choose to purchase similar services (i.e., design or construction) for the operating unit (s). If such services are purchased: 3.5.18.1 They shall be procured in accordance with the requirements of Policies 4.0 and 7.0 and ANSI N45.2.13 (as modified and included in Appendix A of the OQAM); 3.5.18.2 They shall be in accordance with the QA program (A-E/ l Constructor's or his suppliers') in effect for similar activities on other or the same unit (s) or for shared-facilities; and 1
-I OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
. TITLE: DESIGN CONTROL Page 9 of 9 Policy 3
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_ _ -___- _ _ A
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I 3.5.18.3'. Th2'QA Progrcm shall be reviswad bylMP E SERIQ_uality-
~ Assurance to assure that any additional requirements which t
are considered necessary to assure quality have been included. 1 l I-0PERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
.. TITLE: DESIGN CONTROL Page 10 of 9 Policy 3
,J250QAM.3 - 10 l
i 4.0 PROCUREMENT DOCUMENT CONTROL I 4.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by MP&b SERI to control procurement documents for safety-related mater.ial, equipment and services for the Grand Gulf Nuclear Station. 4.2 SCOPE This Policy delineates responsibilities and defines requirements for l \ l procurement document preparation, review, approval and change control in order to assure that purchased safety-related items and services will conform to established, specified requirements. 4.3 APPLICABILITY The requirements of this Policy apply to all procurement documents for safety-related material, equipment and services purchased by or for MP&L SERI during the operational phase of nuclear power plant activities. 4.4 RESPONSIBILITY 4.4.1 All organizations participating in the preparation of pro-curement documents for safety-related items and services during the operational phase are responsible for developing their own procedures or using generic procedures-firevy-Neelear-preduetten OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: PROCUREMENT DOCUMENT CONTROL Page 1 of 8 Policy 4 J250QAM.4 - 1
l f B:pserasne-Persedress). 'In either case procuramant documsnt. control procedures which address the requirements of this 1 Policy, applicable to their scope of activities, shall be implemented.
.i 4.4.2- The GGNS General Manager is responsible for'onsite' procure-ment document control.- He is responsible'for assuring procurement activities performed by the Plant Staff are procedurally controlled in accordance with the requirements of this Policy. This includes preparation, review, approval and issue of procurement documents.
4.4.3 The Manager, Andfee Quality Systems Assueenee is responsible for performing quality reviews of procurement documents, prior to issuance, to verify conformance to the requirements of this Policy. The Manager, Programe Quality-Assurance Services is responsible for reviewing procedures for procurement document control to assure that they address the applicable requirements of this Policy. Lower tier instructions may be reviewed by individuals (other than the preparer) of the organization preparing the documents if such individuals have been indoc-trinated in the Operational Quality Assurance Program. The
~
Manager, Pregeams Quality Systems Assuranee is responsible for indoctrination and certification of these individuals. t j OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 l TITLE: PROCUREMENT DOCUMENT CONTROL Page 2 of 8 Policy 4 l. J250QAM.4 - 2 i l
4.4.4 -Tha Director, Nuclear Support and Director, Nuclear Licensing .i end-Safety are delegated the responsibility for' assuring that general office procurement activities performed by the Nuclear Support Staff and Nuclear Licensing'and-Safety Staff respectively, are procedurally controlled in accordance with the requirements of this Policy. This includes preparation, review, approval and issuance of procurement documents. 4.4.5 Organizations supplying material, equipment.or services are responsible for complying with the applicable requirements of-this Policy, as specified in the appropriate procurement
'documente and for imposing them on their contractors and suppliers, as applicable. They are also responsible for verifying, through surveillance or audits, that the. requirements are being adequately implemented.
'4.4.6 The Director Quality-Assuranee Programs is responsible for assuring implementation of procurement document control measures and for quality review of procurement documents and procedures.
He is also responsible for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy. 4.4.7 The Manager, Purchasing 6-Seeres and the Manager, Contract Administration are responsible for performing procurement activities, in accordance with the Operational Quality Assurance Program, as coordinated with the Director, Nuclear Support; the OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: PROCUREMENT DOCUNINT CONTROL Page 3 of 8 Policy 4 I J250QAM.4 - 3 _ _-____._-______D
Director, Nuclear Licensing cn3-6:Es2y; ths Director, Nuclear Plant Engineering; the GGNS General Manager; the Director, Quality AssureneeProgrars, and the Manager, Unit 1 Projects, the j Director, Corporate Services and other appropriate SERI per-sonnel as delineated in appropriate procedures. 4.4.8 The Director, Nuclear Plant Engineering is responsible for , assuring procurement activities performed by the Nuclear Plant Engineering Staff are procedurally controlled in accordance with the requirements of this Policy. This includes preparation, review, approval, and issue of procurement documents. 4.4.9 The Unit 2 Construction Superintendent is responsible for assuring procurement activities to support preoperational 1 testing ara procedurally controlled in accordance with the i requirements of this Policy. This includes preparation, review, approval, and issue of procurement documents. 4.4.10 The Manager, Unit 1 Projects is responsible for assuring procurement activities to support the implementation and testing of design changes and plant modifications are procedurally controlled in accordance with the requirements of this Policy. This includes preparation, review, approval and issue of procurement documents. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: PROCUREMENT DOCUMENT CONTROL Page 4 of 8 Policy 4 J250QAM.4 - 4 ______a
4.5 . REQUIREMENTS 4.5.1 Procedure's shall be established by the responsible organiza-
/ tions to clearly delineate the sequence of actions to be accomplished to control the preparation. review, approval and issuance of procurement documents for safety-related items and j services.
4.5.2 The. procedures shall assure that procurement documents issued at all levels of procurement include provisions for.the following, as applicable:
~
4.5.2.1 A statement of the scope of work to be performed by the contractor or supplier; 4.5.2.2 Identification of the design basis technical requirements by reference-to specific drawings, specifications, codes, regulations, industrial standards or'other documentation, including revisions thereto, that describe the items or services to be furnished; 1 4.5.2.3 Identification of test, inspection and acceptance q requirements, and any special instructions and requirements for such activities as design, fabrication, identification, cleaning, erecting, packaging, handling, shipping and extended storage; i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 I TITLE: PROCUREMENT DOCUMENT CONTROL Page 5 of 8 Policy 4 J250QAM.4 - 5 ___x__-________
4.5.2.4 Identifu.ation of the quality assurance program . l requirements which must be complied with by the contractor or supplier; 4.5.2.5 Stipulation that the provisions of 10CFR21 apply; 4.5.2.6 Identification of the documentation, such as drawings, specifications, procedures, fabr! cation and inspections plans, inspection and test records, personnel and procedure qualifications, and chemical ; and physical test results to be prepared and maintained by the supplier or contractor and requirements for submittal to MP6b SERI for review and' p approval; 4.5.2.7 Identification of those records to be retained, controlled and maintained by the supplier or contractor and those to be delivered to MP6b SERI prior to use or installation of the procured item; 4.5.2.8 MP6 bis SERI's right of access to the supplier's f acil-ities and records for source quality verification, inspection and audits, as deemed necessary; 4.5.2.9 Extension of applicable requirements to lower tier subcontractors and suppliers, including MP6b si SERI's right of access to facilities and records; ( l i i q OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: PROCUREMENT DOCUMENT CONTROL l l Page 6 of 8 Policy 4 i ! J250QAM.4 - 6 l l
1 4.5.2.10 Subject to the clarification of ANSI N45.2.13, j l Section 8.2, given in Appendix A of this program, l l reporting and approving the " Accept-as-is" or " Repair" f dispositions of nonconformances; 4.5.2.11 MP6ble SERI's right to hold shipment if procurement document requirements, including those for documentation, have not been fulfilled. 4.5.3 The procedures shall assure that procurement documents are subjected to technical and quality review by qualified personnel e and are approved by designated individuals prior to issuance. The review and approval shall be documented and available for verification. 4.5.4 Review and concurrence with the adequacy of quality require- 3 ments shall include verification that the requirements are j correctly stated, inspectable and controllable; that there are adequate acceptance and rejection criteria; and that the
. procurement documents have been prepared, reviewed and approved in accordance with the requirements of this Policy.
4.5.5 Changes or revisions to procurement documents shall be sub-jected to an equivalent review and approval as the original 3 documents, and such review and approval shall be documented. Exceptions to this include changes in quantity, estimated price, cost codes, taxes, format or editorial changes that do not affect the quality of the item or service. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 j TITLE: PROCUREMENT DOCUMENT CONTROL l Page 7 of 8 Policy 4 i J250QAM.4 - 7
L I 1 4.5.6 Procurement documents for spare or replacement parts for safety-related structures or systems shall be subject to control at least equivalent to those required for purchase of original equipment, or those specified by a properly reviewed and approved revision to the origitia1' requirements. 1 I I 1 l i i i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: PROCUREMENT DOCUMENT CONTROL Page 8 of 8 Policy 4 J250QAM,4 - 8 ______ 1
l l L 5.0. INSTRUCTIONS,' PROCEDURES AND DRAWINGS g
- 5.1 ' PURPOSE :
1
' This Policy; describes the Operational Quality Assurance Program measures established by MP6b SERJ to assure that all activities affecting-the quality or z
safety'of.the Grand Gulf Nuclear Station'are prescribed and' accomplished s - in accohdance with documented instructions, procedures, drawings.or other
~ documents appropriate'to the circumstances.
- 5.2: SCOPE This Policy delineates responsibilities and defines requirements for the
- development and' implementation of measures designed to assure that safety-related activities are preceribed and accomplished in accordance with documented instructions, procedures or drawings.
5.3:. APPLICABILITY. The-requirements of this Policy apply'to all individuals or organizations performing activities which affect the quality of safety-related items during the operational phase of nuclear power plant activities. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Page 1 of 5 Policy 5 J250QAM.5 - 1
i 4 5.4. RESPONSIBILITY 5.4.l' All organizations performing activities during the opera- ; tional phase which affect the quality of safety-related i structures, systems and components are responsible for per-forming, these activities in accordance with documented instructions, procedures or drawings. It is the responsibility l of th'e managers of these organizations to assure the development, review, approval and control of instructions, procedures and drawings necessary to control their safety-related activities in accordance with the requirements of this Manual. It is the responsibility of the Vice President, Nuclear Engineering & Support.-end the Vice President, Nuclear operations and the Vice President, Human Eeaources and Administration to ensure that those instructions, policies, L procedures and drawings that cross internal organizational lines interas1-te-the-Nuelese-Produceden-Bepacement integrate and I function in accordanc.e with the above. 5.4.2 This section deleted in Revision 3. 5.4.3 During the operational phase, the GGNS General Manager is responsible for assuring that adequate inspection plans; test calibra. tion, special process, maintenance, and repair procedures; drawings, specifications and other safety-related documents and revisions thereto are used. During the implemen- l jh , I L s tation and testing of design changes and plant modifications.
'.i'( ' . ~
N OPERATIONAL,; QUALITY ASSURANCE MANUAL Rev. 6
.TITLEt' INSTRUCTION
S. PROCEDURE
S AND DRAWINGS Page 2 of 5 Policy 5 J220@AMo3 - 2
-the Mansgar,' Unit 1 Projects is responsible for assuring that L ^
inspection plans; modification and test procedures; drawings, specifications and other safety-related documents and. appropriate revisions'thereto are used. Preoperational pnase testing is the responsibility of the Unit 2 Construction Superintendent. The Director. Quality Aeeuwenee-Programs is responsible for the performance of nondestructive examinations. The Manager, Pregrene Quality Assurenee- Services is responsible for performing'the quality review of procedures, and determining that the necessary QA requirements are included. The-Manageer
- t. Neelear-Stee-Quality-Aeeurence He is responsible for determining the need for inspection requirements in design-ee work documents. Documents which contain administrative controls-which specify quality assurance requirements will also be reviewed by the Manager, Pregeene Quality-oeeweenee Services.
Lower tier documents may be reviewed by individuals (other than the preparer) of the organization preparing the documents if such individuals have been indoctrinated in the Operational J Quality Assurance Program. The Manager, Programe Quality Systems Assurance is responsible for indoctrination and certifi-cation of these individuals. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Pago 3 of 5 Policy 5 J250QAM.5 .3 m__
5.4.4 Tha Diractor, Quality-Azcarnero Programs is responsible for reviewing and/or approving instructions, procedures or drawings as indicated in Appendix B of this Manual and for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy. 5.5 REQUIREMENTS 5.5.1 Written instructions, procedures, drawings, or other docu-ments appropriate to the circumstances shall be used to provide measures for complying with the requirements of the Operational Quality Assurance Program. 5.5.2 Directions commensurate with the nature of the activity shall be prescribed in instructions, procedures and/or drawings i for the performance of activities affecting quality. The activities shall then be performed in accordance with the instructions, procedures and/or drawings. 5.5.3 Instructions, procedures or drawings shall include quantita-tive and/or qualitative acceptance criteria for verifying that the activities have been satisfactorily accomplished. i
)
l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 ' TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Page 4 of 5 Policy 5 j J250QAM 5 - 4 j
5.5.43 .The responsible organizations shall establish procedures which def'ine responsibilities and clearly delineate the' sequence
'of actions to be accomplished in the preparation, review, approval and control of instructions, procedures, or drawings, and changes thereto.
5.5.5 Safety-related administrative procedures must reference-documents used in their preparation. 5.5.6 When the NRC accepts changes to a policy or an appendix which result in more restrictive requirements, affected implementing procedures must be issued or revised within 120 days. If procedures cannot be revised or issued within 120 days, the man-ager of the affected organization (s) must approve a schedule detailing when the required changes will be accomplished. If. the; approved changes are less restrictive, the more restrictive t- requirements must be complied with until the old procedures are revised or new procedures are issued. When changes to procedures (more restrictive) are required by changes to NRC regulations or by Bulletins or Orders, the required procedures shall be changed within 120 days or as stipulated in MP&ble SERJ's response to the Bulletin or Order or as set forth in the Regulation. The more restrictive time frame shall be met. h ( i l L i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Page 5 of 5 Policy 5 J250QAM.5 - 5 L__ - - _ - -
6.0 DOCUMENT CONTROL ] l l 6.1 PURPOSE l This Policy describes the Operational Quality Assurance Program measures established by MP6b SERI to control safety-related documents for the Grand ; 1 Gulf Nuclear Station. 6.2 . SCOPE l i This Policy delineates responsibilities and defines requirements for the review, approval, issuance and control of documents and changes or revisions thereto, which prescribe all activities affecting quality or safety. 6.3 APPLICABILITY l The requirements of this Policy apply to all individuals or organizations performing functions which affect safety-related structures, systems or components during the operational phase of nuclear power plant activities. 6.4 RESPONSIBILITY 6.4.1 Responsibility and authority for the control of safety-related documents during the operational phase are delegated to the individuals / organizations specified in Appendix B of this OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DOCUMENT CONTROL Page 1 of 7 Policy 6 J250QAM.f - 1
---------a
Manus 1.' Thay are responsible for developing and impicasnting procedures to control the review. approval'and issue of documents in accordance with the requirements of this Policy. 6.4.2- Organizations supplying material, equipment or services are responsible for complying with the' applicable requirements of i
.this Policy as specified in the appropriate. procurement-documents,'and for imposing them on their contractors and suppliers, as applicable. They are also responsible for assuring, through surveillance or audits, that the requirements are being adequately implemented.
-6.4.3 This'section deleted in Revision 4.
6.4.4 The' Director, Quality-Ameurance Programs is responsible for monitoring document control activities and for carrying out an audit program, as described in Policy 18.0 e,f this Manual, to verify compliance with Operational Quality Assurance Program require-ments, including the requirements of this Policy. 6.5 REQUIREMENTS 6.5.1 Procedures shall be established and implemented by the responsible organizations to provide for the control of documents, incJuding changes thereto, which prescribe all activities affecting quality or safety. These procedures are identified in Appendix B to this Manual. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DOCUMENT CONTROL Page 2 of 7 Policy 6 J250QAM.6 - 2
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_-________a
6.5.2 The proceduras shc11 idzntify tha documents to be con-trolled. As a minimum, they shall include: Don'.gn Specifications Design Manufacturing, Construction and Installation Drawings ( I Procurement Documents Quality Assurance Manuals, Procedures and Instructions Operating Procedures i Operating and Special Orders [ ( Maintenance and Modification Procedures Manufacturing Inspection and Test Procedures Equipment and Material Control Procedures Refueling Procedures Updated Final Safety Analysis Report i Design Change Requests / Packages OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DOCUMENT CONTROL Page 3 of 7 Policy 6 J250QAM.6 - 3
it ;Dasign Change: Notices a 7 Nonconformance Reports p Q-List: y
.6.5.3' -The. procedures shall specify the individuals or organiza-tions responsible for the preparation, review, approval, issuance and control of the documents, and revisions thereto.
6.5.4 Review of documents for a'dequacy shall be performed by
, knowledgeable personnel other than the originator.. Reviewers shall have access to. pertinent background information and,shall
'have adequate" understanding of requirements and intent of the document.-
6.5.'5 . Documents shall be approved for issue by authorized person-nel prior to release and shall be distributed in accordance with current, documented distribution lists. 6.5.6 Master lists or their equivalents shall be established and maintained to identify the current statv'4 sf instructions,
-procedures, specifications, drawings and procurement documents.
The lists shall be available to responsible personnel to preclude the use of superseded documents. ,1 OPERATIONAL QUALITY-ASSURANCE MANUAL Rev. 6 TITLE: DOCUMENT CONTROL Page 4 of 7 Policy 6 J250QAM.6 '4
1 i l t 6.5.7' . Documents;tequired to perform a specific activity shall be i available at the location where.the activity is to be performed
, prior'to. commencement of the activity. Cancelled.or superseded 3
.documentsfshall be controlled to prevent their inadvertent use..
'1
.i b '6.5.8 Unless delegated to other. appropriately qualified organiza-tions, changes to' documents shall be reviewed and approved by ]
; the same organizations that performed the original review and o
.]
approval. ' l' 6.5.8.1 Changes sna11 be included in the documents (i.e., 1 procedures or instructions)' prior to implementation of the change, except in those cases where adequate procedural controls allow implementation of changes prior to revision of the. original document. These changes, if considered permanent, shall be
' incorporated into the original document in a timely manner as defined by the Quality Assurance organization.
6.5.8.2 Prior to issuance of an Operating License on Unit 2, l and after the initial use of the procedure on Unit 2, temporary changes shall be incorporated in the next J revision of the affected procedure or within six months, whichever occurs first. l
' OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DOCUMENT CONTROL l Page 5 of 7 Policy 6 J250QAM.6 - 3'
+ a, 6.5.8.3 Unit 1 Preoperational and Startup Test procedures'- ,
including temporary changes, shall-be evaluated and
. revised as necessary prior to being utilized on Unit 2, 6.5.8.4 Preoperational and Startup Testing Procedures are one-time-use procedures. Permanent changes'are not required.to be incorporated in a revision of these procedures until and unless the procedure is used again.
6.5.9 In addition to initial review and approval.. procedures for operational phase activities shall be subject to subsequent periodic reviews with.a specified frequency dependent on the type.and complexity of the activity involved. 6.5.10 Plant procedures (as defined in' Technical Specification 6.8.1) shall be reviewed by an individual knowledgeable in the area affected no less frequently than every two years or prior to use if the procedure / instruction is not used routinely to determine if changes are necessary or desirable. A revision of the pro-cedure constitutes a procedure review. The two year cycle began j on June 16, 1982 with issuance of the Operating License for Unit 1. 6.5.11 Following any modification to a plant system and prior to initiation of any activity affected by the modification, the applicable procedures shall be reviewed to determine if changes are required. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 j TITLE: DOCUMENT CONTROL Page 6 of 7 Policy 6
.J250QAM.6.- 6 a:__-_--________ __ _ .
A documented review ofl applicable procedures shall be per-
~
~ 6.5.12 formed following'an accident, an unexpec'ted transient, significant operitor error,.or equipment malfunction which
~
results in a reportable event, to determine if changes are I? . required to prevent recurrence. L 6.5.13 Review and approval of documents, and changes thereto..shall
- . be documented to the extent necessary co provide evidence of.
coupliance with the requirements of this Policy. i. 1 l J k OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 I-
' TITLE: DOCUMENT CONTROL-Page 7 of 7 Policy 6 l- iJ250QAM.6 !
- 7. 0 CONTROL'OT-PURCHASED MATERIAL, EQUIPMENT AND SERVICES i,
g 17.1 -PURPOSE' This. Policy; describes'the Operational Quality Assurance-Program measures established by MP&L SERJ to control the procurement of safety-related material, equipment and services for.the Grand Gulf Fuclear Station. 7.2 SCOPE This Policy delineatesfresponsibilities and defines requirements for the control of activities performed during.the procurement of safety-related items and services in order to assure that such items and services' conform to the procurement documents.
~7.3 APPLICABILITY
-The requirements of this Policy apply to all safety-related material, equipment and services procured for'the operational phase of nuclear power plant act1vities, and to all individuals or organizations participating in the procurement of such items or services.
17.4 RESPONSIBILITY 7.4.1 . Responsibility and authority for controlling the procurement of safety-related material, equipment and services during the operational phase are delegated to the Director, Nuclear Support; the Director, Nuclear Licensing and-Safety; the OPERATIONAL-QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 1 of 9 Policy 7 J250QAM.7 - 1
1 Director, Quality-Aeeurence Prograns; the Director, Nuclear l Plant Engineering; the GGNS General Manager (for startup testing i and operations); the Director, Corporate Services; and the 1 4 Manager, Unit 1 Projects. It is the responsibility of these individuals to assure that the requirements of this Policy, which are applicable to their scope of activities, are implemented in accordance with written approved procedures. These activities include, as appropriate: source evaluation and selection; evaluation of objective evidence of quality furnished by the supplier; source inspection; audit, and/or source quality verification; examination of items upon delivery. 7.4.2 Organizations supplying safety-related material, equipment and services are responsible for complying with the applicable requirements of this Policy, as stipulated in the procurement documents, and for imposing them upon their contractors and suppliers na applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 7.4.3 The Director, Quality-Assurance Programs is delegated the responsibility for assuring implementation of procurement activ-1 j ities at the plant site. He is responsible for inspection as necessary to assure compliance with the requirements of this Policy. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 2 of 9 Policy 7 1 J250QAM.7 - 2
7,4.4 The Director, Quality-Asstelara Programs is responsible for assuring the implementation of Operational Quality Assurance Program requirements relative to procurement activities, including: the quality evaluation of suppliers, source inspec-tions, source quality verification and an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements, l including the requirements of this Policy. l 7.5 REQUIREMENTS 7.5.1 Measures shall be established, implemented and documented by the appropriate organizations, consistent with their scope of responsibilities, to assure that purchased material, equipment and services, whether procured directly or through contractors, conform to the procurement documents. These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the supplier, inspection, source quality verification and audit at the source, and/or examination of items upon delivery. 7.5.2 Procedures shall be established to provide for the selection of suppliers based on one or more of the following:
)
7.5.2.1 An evaluation of the Supplier's Quality Assurance ; 1 1 Program / Manual / Procedures, as appropriate. {
]
l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 j TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 3 of 9 Policy 7 J250QAM.7 - 3
l 7.5.2.2 Review and evaluation of historical quality per- ! k formance data; 7.5.2.3 Source qualification programs; 7.5.2.4 Source quality surveys; 7.5.2.5 Through the Coordinating Agency for Supplier l-Evaluation (CASE) using the current revision of the l CASE Register. When the CASE Register is used for commercial (catalog and off the-shelf) items, reference to the CASE Register shall provide adequate documentary evidence of source evaluation. Commercial 1 items are those that do not require unique design or j special engineering specifications; or are 1. l manufactured to national standards or by processes l generally automated or highly repetitive; or there is l little chance for error during manufacture to affect their safety-related characteristics. For items which are not commercial or which require unique design or , special engineering specifications, a copy of the qualifying audit report shall be obtained and reviewed for adequacy and applicability prior to selection; 7.5.2.6 Through the NRC's " Licensee Contractor and Vendor Inspection Status Report" (white book) for contractors with IE letters confirming Quality Assurt.nce Program implementation; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF PURCHASED MATERIAL, EQU1PMENT AND SERVICES Page 4 of 9 Policy 7 J250QAM.7 -'4
7.5.2.7 Through docun.ented information received from others (architect-engineer, NSSS supplier, other-utilities, ASME, etc.) indicating a program meeting appropriate Quality Assurance Program requirements. The procedures shall specify the organizations responsible for
. l performing technical and quality evaluations, the methods of evaluation and the criteria for supplier acceptance.
To facilitate pre-award supplier evaluation, telephone surveys may be conducted by Quality Assurance as established by Quality Assurance Procedures. Other means of supplier pre-award evaluation are also established by Quality Assurance Procedures. 7.5.3 Evaluation and selection of the supplier shall be performed in accordance with written procedures by qualified quality assurance and technical personnel prior to or concurrent with award of the procurement document. Items which have been manufactured or are to be manufactured prior to this concurrence with the contractor or supplier Quality Assurance Program will be acceptable, but shall not be relied upon to fulfill any safety-related function until after the item is shown to meet procurement requirements (including QA Program). l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 5 of 9 Policy 7 J250QAM.7 - 5 s
!. m > g 7.5.4 .ResuIts of supplier evaluations shall be documented:and re-
.)
'tained on file. Any deficiency identified during-a sopp11er' _
evaluation shall be resolved early enough in'the procurement f cycle to prevent the deficiency.from adversely affecting the qualit'y of the purchased product or' service.
.7.5.5 Procedures shall be established to provide for evaluation and.
If g verification activities such as source inspections', source quality verification or audits, as necessary, to assure the quality'of the item and to verify supplier conformance to procurement document requirements. l> l 7.5.6' Inspection procedures shall specify the characteristics or processes to be witnessed, inspected or verified, and accepted. The method of verification and the extent of' documentation. required; and those responsible for implementing the. inspection. Source quality verification procedures shall specify the. characteristics or processes to be witnessed, observed or verified, including the method of verification and the extent of documentation required. Audits shall be performed in accordance with procedures which implement the requirements of Policy 18.0 of this Manual. 7.5.7 The extent and' frequency of evaluation and verification ac- I tivities shall be a function of the relative importance, com-plexity and quality of the item procured and the supplier's quality performance. Source inspections, source quality i verifications and audits may not be necessary when conformance
/
-OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE:' CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 6 of 9 Policy 7
, J250QAM.7 - 6
- _ _ - . - - - _ - _ - . _ _ _ _ _ - - _ - - - - _ _ - - - - - -c
'T-1 of an'_ item to procursmant requiramants'can be verified by l
receipt inspection, review of test reports,-or other means. 7.5.8 Receipt inspection of1 supplier-furnished items shall be proce-dura 13v controlled to assure: that the items are properly identified and correspond with the identification on the receiving documentation; that the items and acceptance records are inspected and judged acceptable in_accordance with prede-l -. l termined instructions prior to installation or use; that in-spection records or certificates of conformance are available at H- the plant site prior to installation or use of the item; and, that items accepted and released are identified as to their
' inspection status prior to storage or use.
l l Prior to issuance of'an Operating License (OL) for Unit 2, l Startup may install equipment or parts for which all documen-tation has not yet been received at the plant site: such installation and use will be on a " risk basis" such that a failure to subsequently receive all of the required documenta-tion may require the equipment or parts to be remsved and may invalidate any testing which has been accomplished. Startup may j operate such installed equipment, but they may not rely on the affected system to fulfill its safety-related function. l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF-PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 7 of 9 Policy 7 J250QAM.7 - 7 I
,, Controls in Plant and Quality Assurance Procedures will cover this conditional release process, and will. assure that the applicable procedural and administrative aspects of this Policy (7.5.8) and Policies 8.5.8, 14.5.5 and 15.5.5 of the Operational Quality Assurance Program are fulfilled.
7.5.9 Records required to be furnished by the supplier shall be specified in the procurement documents, as stipulated in Policy 4.0 of this Manual. These records shall be reviewed and accepted by personnel specifically designated to perform this activity. These personnel will be designated in accordance with applicable procedures. Other-NPB SERJ organizations may beiused when their areas of expertise provide an adequate basis for such a review. (e.g., Nuclear Services & Fuels could review records from nuclear fuel suppliers.) 7.5.10 The records shall include, as a minimum, documentation that= identifies the purchased. item and the specific procurement requirements (e.g., codes, standards, specifications) met; and documentation which. identifies procurement requirements which have not been met. Subject to the clarification of ANSI N45.2.13, Section 8.2, given in Appendix A of this Manual, such documentation shall include a description of those non-conformances dispositioned " accept-as-is" or " repair." l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 8 of 9 Policy 7 J250QAM.7 - 8 J
7.5.11 Where supplier certificates of conformance are used to identify the requirements met by the item, the certificates of conformance shall be periodically evaluated by audits, independent inspections or tests to assure that they are valid. 7.3.12 Spare or replacement parts for safety-related systems or components shall be procured, fabricated and controlled in accordance with present QA programmatic controls and technical requirements at least equivalent to those used for the original item, or those specified by a properly reviewed and approved revision to the original requirements. 7.5.13 When a supplier is removed from the Qualified Suppliers List, procedures shall assure that any outstanding purchase orders for that supplier are reviewed, and appropriate action taken to assure that materials subsequently received from that supplier are handled and dispositioned as nonconformances. 7.5.14 if-erigfeel-A6ME-Gede-peres-were-erdered-frem-the-helder-ef en-ASHE-Gede-6tempr-and-spere-er-replacement-pares-eve-erdered frem-e-nen-ABME-Gede-Stemp-supp14 err-the-perefens-of-the-QA centrele-whfeh-were-wefved-beeeeee-of-ABME-eeeepted-pregram shell-be-assurede--Bueh-peres-ehell-be-precured-frem-a-supplier with-e-QA-Program-evalueeed-e'-eeeepenble-for-meeting-9QAM requiremenee-and-wheeever-Gede-speeffie-feems-are-requirede This section deleted in Revision 6. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 9 of 9 Policy 7 J250QAM.7 - 9
f8.0 -IDENTIF2 CATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS ~ T8 .1 PURPOSE-This Policy. describes the Operational Quality Assurance Program measures-established by MP&b'SERJ to provide for the identification and control of safety-related material,-parts and components for thel Grand Gulf Nuclear Station. Ji~ 18.2 SCOPE This Policy delineates responsibilities.and defines requirements for the identification'and control of safety-related items in order to assure that-gg -only. correct:and' accepted items are used or installed. i. 8.3? APPLICABILITY The requirements of this Policy apply to all individuals or organizations participating in the procurement, fabrication, receipt, storage,
~ ; installation, operation, modification or repair of safety-related items during the operational phase of nuclear power plant activities.
l 8.4 RESPONSIBILITY j 8.4.1 Responsibility and authority for the identification and control of materials, parts and components during the opera-tienal phase are delegated to.the GGNS General Manager except, ) during implementation and testing of design changes and plant ; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
~ TITLE: IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS Page 1 of 5 Policy 8
'J250QAM.8 - 1
-nodifiestions, the Managsr, Unit 1 Projects is responsible for this activity.~They are responsible for assuring that procedures i
are established to address the applicable requirements of this Policy, and that identification and' control of safety-related i L items is maintained in accordance with the procedures from procurement of the item through fabrication, storage, installation and use. 8.4.2 Organizations supplying' safety-related material, equipment and services are responsible'for complying with the applicable requirements of this Policy, as stipulated in the procurement documents, and'for imposing them on their contractors and suppliers as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 8.4.3 The Manager, Quality Systems and Fthe Manager, Neelene este Quality-Asentence Services de are delegated the responsibility for assuring implementation of identification and control requirements for items at the plant site by receipt inspec-tions and other inspections, respectively. The Manager, i Pregreme Quality-Aeeurence services is responsible for reviewing procedures and the-Manageer-Nuclear-6ste-Qualfty Assueence-fee-eeview-ef work documents to the extent necessary to verify conformance to the applicable requirements of this , Policy. ! OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ' IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS Page 2 of 5 Policy 8 J250QAM.8 - 2 _ _ _ _ _ _ _ = _ _ _ _ - - - - - !
i
- 8. 4. 4 ' The Director, Quality-Assurance Progrens has the responsibility for' carrying out an audit program, as described in Policy 18.0
-of this Manual, to verify conformance with the requirements of
- the Operational Quality Assurance Program, including the requirements of this Policy.
8.5 REQUIREMENTS 8.5.1 Procedures shall be established and implemented to provide for the identification and control of safety-related materials, parts and components, including partially fabricated subessem ' blies, in order to assure that only correct and accepted items are used and installed. 8.5.2 The procedures shall be developed by the appropriate organ-izations'to cover the various stages from procurement of the item through fabrication, receipt, storage, installation, use, modification or repair. 8.5.3 The procedures shall provide assurance that a unique identi-fication of items is maintained, such as by part number, serial number, heat number, drawing identification number or other appropriate means. 8.5.4 The procedures shall assure that identification is maintained either on the item or on records traceable to the item. Physical identification, such as by marking or tagging, shall be used to I the maximum extent practical. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: IDENTIFICATI,0N AND CONTROL OF MATERIALS, PARTS AND COMPONENTS Page 3 of 5 Policy 8 J250QAM.8 - 3
l l 8.5.5 When epscified by codss, standcrds, procurement documsnto, or l other requirements; identification shall be such that items are traceable to appropriate documentation (e.g. specifications, drawings, purchase orders, manufacturing and inspection documents, nonconformance reports, physical or chemical mill test reports). l l 4 6.5.6 Where identification marking is employed, the marking shall i be clear, unambiguous and indelible, and shall be applied in such a manner as not to affect the fit, function or quality of i the item. 8.5.7 Markings shall be transferred to each part of an item, if ' 1 subdivided, and shall not be obliterated or hidden by surface treatment or coatings unless other means of identification are substituted. 8.5.8 Procedures shall provide for the verification and documen-l tation of correct identification of items prior to release for fabrication, assembling, shipping, storage or installation. Icems may be conditionally released under adequate procedural controls. These controls shall assure that the system, subsystem, or component that receives such items is considered inoperable, no reliance shall be placed on such system, subsystem, or component for fulfilling their intended safety function. The Manager, Nuclear Site Quality-Assuranee
/
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS Page 4 of 5 Policy 8 J250QAM.8 - 4
f}
- in Services shall review'and concut with' conditional' releases.
Applicable procedural;and administrative' aspects of this Policy-
~
h p, ' i:(8.5.8) and.' Policies 7.5.8, 14.5.5 and 15.5.5-of the operational Quality Assurance' Program shall be' fulfilled.. T 4 1
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OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS Page 5 of 5 Policy 8 J250QAM.8 5 s
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,, ~ '9.0'. CONTROL OF:SPECIAL' PROCESSES:
a ~ r: 9.1 PURPOSE .t
'This-. Policy' describes the Operational Quality Assurance Program measures established by MP&L SERI to provide for the control of safety-related special processes for the Grand Gulf Nuclear Station.
9.2 LSCOPE 1 Th'is Policy delineates responsibilities and defines requirements for the control of special processes including, but not limited to, cleaning, hea_ treating, welding, nondestructive examination or unique fabricating or testing processes.which require. interim in-process controls.-
~
.9.3 APPLICABILITY The requirements of this Policy apply to all individuals or organizations performing special processes during the operational phase of nuclear power plant activities under this Operational Quality Assurance Program.
9.4 RESPONSIBILITY 9.4.1 Responsibility and authority for the control of special processes,exceptnondestruchivhexamination,attheplantsite , during the operational phase are delegated to the GGNS General Manager. During the implementation and testing of design changes and plant modifications, the Manager, Unit 1 Projects is i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF SPECIAL PROCESSES Page 1 of 4 Policy 9 J250QAM.9 - 1 i
responsible for ensuring that special processas are controlled in accordance with procedures developed by the GGNS General Manager. Responsibility and authority for the control of nondestructive examination are delegated to the Director, Quality-Assuranee Programs. They are responsible for assuring that special processes are performed in accordance with procedures ~and instructions which implement the requirements of this Policy. They are also responsible for assuring that contractors who'are delegated responsibilities for the onsite performance of special processes, impose the applicable-require-ments of this Policy on their internal operations and on their contractors and suppliers.
~9.4.2 Offsite organizations responsible for the performance of special processes shall be subject to the applicable require-ments of this Policy as specified in the appropriate procurement documents. Individuals or organizations responsible for the preparation of procurement documents shall assure that the applicable requirements of this Policy are included, as stip-ulated in Po11cy 4.0 of this Manual.
9.4.3 The Manager, Peegrene Quality-Aseneenee Services is responsible for reviewing Plant Administrative Procedures and Nuclear Plant Engineering Procedures controlling special processes, and the Menegery-Nuclear-Site-Quelfey-Ameurence for reviewing work I documents and inspection of special process activities, ) i inexcluding nondestructive examinations, to the extent necessary l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 y TITLE: CONTROL OF SPECIAL PROCESSES C Page 2 of 4 Policy 9 "J250QAM.9 - 2 ;
i i to verify conformance to ths rsquiremsnts of this' Policy. Lowar i tier instructions may be reviewed by individuals (other..than'the i preparer) of the organization preparing the documents, if such individuals have been indoctrinated in the Operational Quality
~ Assurance program. The Manager, Pregeene Quality Systems Asevennee is responsible for indoctrination and certification of 1
.these individuals.
9.4.4 The Director, Quality-Aeeweenee Programs has the responsibility for. monitoring the special process control measures of offsite organizations, and.for carrying out an audit program, as described-in Policy 18.0 of this Manual; to verify conformance
-vith the requirements of the Operational Quality Assurance Program, including the requirements of this Policy.
) 9'.4.5 The Director, Nuclear Plant Engineering has the responsibility for assuring that special process' standards and specifications are established to address the applicable requirements of this Policy. He is also responsib3e for reviewing and approving all' contractor special process standards prior to use at the Plant Site. 9.5 REQUIREMENTS 9.5.1 -Procedures shall be developed and implemented by the respon-sible organizations to assure the control of special processes including, but not limited to, chemical cleaning, heat treating, welding and nondestructive examination. OPERATIONAL QUALITY ASSURANCE MANUAL- Rev. 6 TITLE: CONTROL OF SPECIAL-PROCESSES Page 3 of 4 Policy 9 J25CQAM.9 - 3
w 9'5.2
. Special processes shall be accomplished under controlled s' ' conditions'in accordance withiapplicable' codes, standards,.
specifications or other special. requirements. 9.5.'3 Special' processes shall be performed byfpersonnel qualified in accordance with applicable codes., standards, specifications, or other special requirements. 9'.5.4 Equipment'and procedures used in the? performance of.special l processes shall be qualified in v :ordance with applicable.
, codes, standards, specifications or other special requirements.
v i 9.5.-5 Qualification records of personnel,' equipment and procedures associated with specfal processes shall be established, 1 bk ' maintained and kept current. t x 9;S.6 For cpecial *!ccesses not covered by existing' codes or T . standards,4cr whereLitem quality requirements exceed the
~
requiremehtsofexistingcodesorstandards,thenecessary qualifications of personnel, procedures and equipment shall be I
. defined and documented.
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84 st n y c OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ' CONTROL OF SPECIAL PROCESSES Page 4 of 4 Policy 9 J250QAM.9 - 4.
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i 10.0 INSPECTION 10.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by Mp6L SERI to provide for the inspection of activ-ities affecting the safety of the Grand Gulf Nuclear Station. l l 10.2 SCOPE This Policy delinentes responsibilities and defines requirements for the development and implementation of a program for the inspection of activities affecting safety in order to verify conformance to the documented instructions, procedures and drawings for accomplishing the activity. 10.3 APPLICABILITY The requirements of this Policy apply to all inspections performed on safety-related structures, systems or components during the opera-tional phase of nuclear power plant activities. 10.4 RESPONSIBILITY 10.4.1 overall responsibility and authority for establishing and implementing an inspection program at the plant site during the operational phase are delegated to the Director, Quality-AssureneePrograms and the GGNS General Manager. During the implementation and testing of design changes OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION Page 1 of 9 Policy 10 _____________J2300AL 30_- 1
and plant modifications, the Manager, Unit 1 Projects, in conjunction with the Director, Quality-Assurance Programe, is responsible for these activities. The Director, i Quality-Assuranee Programe is responsible for assuring that procedures / instructions developed for the performance of work operations include appropriate inspection requirements and for assuring that inspections and examinations are performed and documented where necessary to assure quality. The GGNS General Manager and the Manager, Unit 1 Projects (for implementation and testing of design changes and plant modifications) are responsible for assuring that measure-ments and tests of materials, products or activities are performed and documented for each work operation where necessary to assure quality. 10.4.2 The Manager, Neeleer Site Quality-Assuranee Services is delegated the responsibility for assuring that the onsite inspection program (except for receipt inspection) is carried out in accordance with the requirements of this Policy. The Manager, Quality Systems *e delegated the responsibility for assuring that the oneite receipt inspec-tion program is carried out in accordance with the require-mente of this policy. The Manager, Programs Quality
-Assurance Services is responsible for reviewing Plant Administrative Procedures which control work instructions, modification and repair instructions; preoperational and startup test procedures; and other documents to assure that they contain the appropriate inspection requirements.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION Page 2 of 9 Policy 10 J250QAM.10 - 2
. Lower tier instructions may be reviewed by individuals (other.than the preparer) of.the organization preparing the documents if such individuals have been indoctrinated in the Operational Quality Assurance Program. The Manager, Pregeeme Quality Systems Assueenee is responsible for indoctrination and certification of these individuals. The Manager, Pregeene Quality-Assuennee Services is etse responsible for developing end-ehe-Menegery-Nuclear-6fte Quelfey-Aeeurence-fee-implementing procedures for the
. performance of aZZ quality inspections.
~
ef-plane-efte eetiv4eieer The Manager, Quality Systems and the Manager, Quality Services are responsible for implementing inspec-tion procedures (receipt inspection and other inspections, respectively). The coordination of activities concerning the training and certification of all quality inspectors shall be accomplished by the Manager, Pregenme Quality Systems
-Assurenee; Level III inspectors are appointed. All safety-related work authorizations will be reviewed by the Manager, Nuelear-Site Quality-Assurance Services for determination of any quality inspection requirements.
Procedures or work authorizing documents which control repetitive tasks are reviewed initially and when revised for inclusion of inspection requirements. 10.4.3 MP&L SERJ may delegate the responsibility for implementing certain portions of the inspection program to other organizations. However, MP&L SERI retains the ultimate responsibility for assuring that all aspects of the inspection program are carried out. At the plant site, the OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION-Page 3 of 9 Policy 10 n_ REYsraOLR@ o 2
Manager, Quality Systems and the Kznzger, Nzeksac-Gite >
-Quality-Aeoneenee Services are te responsible for assuring that inspection activities (receipt inspection and other
\
inspection, respectively) assigned to outside organizations i are accomplished in accordance with the requirements of '
- this Policy.
1
- 10. 4. 4 '- Organizations supplying safety-related material, equipment .
h and services are responsible for complying with the appli-cable requirements of this Policy, as stipulated in the procurement documents, and for imposing them upon their contractors and suppliers as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 10.4.5 The Director, Quality-Assurance Programs is responsible for qualification of inspectors and has the responsibility for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with the requirements of the Operational Quality Assurance Program, including the requirements of this Policy. 10.5 REQUIREMENTS 10.5.1 Inspection requirements shall be included in applicable specifications, drawings, procedures, instructions or other documents which prescribe and control safety-related activities. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION Page 4 of 9 Policy 10 J250QAM.10~ - _ _ _ _ _ - _ _ _ _ _ _ -
I . -
' # ~
c 10.5 2.
. The,se inspection' requirements shall be translated into a documented inspection program, to be implemented by the responsible organizations in accordance with written pro-
cedures, which. verifies that the activities are accomplished in accordance with the specifications, drawings, procedures or instructions.
4 10.5.3 Inspection procedures, instructions or checklists shall include provisions, as required, for'the following: 1; 10.5.3.1 Identification of characteristics and activities to be inspected; 10.5.3.2 Identification of the individuals or organizations responsible for performing the inspection activities; 10.5.3.3 ' Identification of acceptance and rejection i, , criteria; 10.5.3.4 A description of the method of inspection; 10.5.3.5 Recording evidence of the comp 1'etion and verification of a manufacturing, inspection or test operation; 10.5.3.6 Recording the identity of the inspector or data recorder and the results of the inspection operation; and, OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 i TITLE: . INSPECTION Page 5 of 9 Policy 10 ; i -.__ _1__ 1____ RRB etrc L na e 9
10.5.3.7 Specifying the necessary measuring and test equipment', including the accuracy requirements.
-Accuracy may be specified by requiring a specific model or type of instrument. ,
1 i 10.5.4 The e;.plicable drawings and specifications shall be avail-at te for use with the inspection procedures, instructions or checklists when an inspection operation is being carried out. 10.5.5 Inspections shall be performed by qualified personnel who are independent of those individuals who performed the activity being inspected. Inspection of operating activ-ities (work functions associated with normal operation of the plant, routine maintenance, and certain technical ser-vices routinely assigned to the onsite operating organiza-t' ion) may b'e conducted by second-line supervisory personnel or by other qualified personnel not assigned first-line supervisory responsibility for conduct of the' work. When inspections of operating activities are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following controls shall be met: 10.5.5.1 The quality of tha work can be demonstrated through a functional test when the activity involves breaching of pressure retaining items; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
-TITLE: INSPECTION Page 6 of 9 Policy 10 J250QAM.10 - 6 j
10.5.5.2 The qualification criteria for inspection personnel are reviewed and found acceptable by the Quality Assurance organization prior to initiating the inspection. 10.5.6 Personnel performing inspections which require specialized qualifications or skills shall be qualified in accordance with applicable codes, standards or licensing requirements, and their qualifications and certifications shall be docu-mented and kept current. 10.5.7 If mandatory inspection hold points are required, the spe-cific hold points shall be specified in the appropriate drawings, specifications, procedures or instructions. The inspection program shall provide assurance that work does not progress beyond the hold point until released by the designated authority, and that required notification and l acknowledgement has been satisfied prior to work l continuing. 10.5.8 If inspection is impossible or disadvantageous, indirect control shall be provided by monitoring processing methods, equipment, and personnel. Inspection and process monitoring shall be utilized if control is inadequate 1 1 l without both. l 10.5.9 Instructions addressing maintenance, modifications, repairs or replacements shall be reviewed by qualified i personnel (other than the preparer) who have the knowledge OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION t Page 7 of 9 Policy 10 E__ __ 2EY$rucLRtit m R.
I required to determine the need for' inspection, identifica-tion of inspection personnel, and documenting inspection results. Lower tier instructions may be reviewed by 1 individuals (other than the preparer) of the organization preparing the documents if such individuals have been indoctrinated in the Operational' Quality Assurance Program. The Mhnager, Peegeene Quality Systems Assurance is responsible for indoctrination and certification of these individuals. I 10.5.10 ' Modifications, repairs and replacements shall be inspected in accordance with the original design and inspection requirements or documented engineering approved alternatives. 10.5.11 Inspection data and results shall be evaluated by designated personnel to assure that the inspection objectives have been met and that items requiring action or follow-up are identified and documented. l 10.5.12 Records shall be kept in sufficient detail to provide ade-i quate confirmation of the inspection program. Records shall be maintained in accordance with Policy 17.0 of this J t Manual. l I l 10.5.13 Inspections need not be performed for each specific work activity. Procedures used for assigning inspections shall require the following to be evaluated in assignment of l inspections. , l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 ' TITLE: INSPECTION Page 8 of 9 Policy 10 J250QAM.10 - 8 l
L. b !' , 10.5.13.1 Complexity, magnitude or criticality of the work. l 1 I
'l 10.5.13.2 Documented engineering inspection requirements.
EL- 10.5.13.3 Design organization inspection requirements. ) 10.5.13.4' Components safety impact. 10.5.14 Inspections shall be performed on repetitive, routine and rework items as determined by the Manager,.Neeleer 64ee Quality-Assueenee Services. h l 1 1
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l i
.0PERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION Page 9 of 9 Policy 10 J250QAM.10 - 9
J11;0 TEST CONTROL 11.1 PURP,0SE'
'This Policy' describes the Operational Quality Assurance Program
~
measures established by MP6b SERJ to control testing of safety-related structures, systems and components for the Grand Gulf Nuclear Station.
'11.2 SCOPE
/
'l This Policy delineates responsibilities and defines requirements for the establishment and implementation of a test program to assure that testing required to demonstrate that safety-related items will perform satisfactorily in service is-identified, accomplished and documented.
11.3 APPLICABILITY The requirements of this Policy apply to all testing performed on safety-related structures, systems and components during the opera-tional phase of nuclear power plant activities and also to required preoperational testing. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: TEST CONTROL Page 1 of 6 Policy 11
-J250QAM.11 - 1
11.4 RESPONSIBILITY l 11.4.1 The responsibility and authority for the development and implementation of maintenance and surveillance testing programs during the operational phase are delegated to the GGNS General Manager. The responsibility and authority for the development and implementation of testing programs for i design changes and plant modifications are delegated to the ' Manager, Unit 1 Projects. The responsibility and authority for the development and implementation of preoperational phase testing programs are delegated to the Unit 2 Con-struction Superintendent. They are responsible for assuring that the test programs are established and implemented in accordance with procedures and instructions which address the requirements of this Policy. They are also responsible for assuring that contractors who are delegated onsite testing responsibilities impose the applicable requirements of this Policy on their internal operations and on their contractors or suppliers. 11.4.2 Organizations responsible for conducting offsite testing are subject to the applicable requirements of this Policy as specified in the appropriate procurement documents. Indiv1 duals or organizations responsible for the preparation of procurement documents shall assure that the applicable requirements of this Policy are included, as stipulated in Policy 4.0 of this Manual. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 I TITLE: TEST CONTROL Page 2 of 6 Policy 11 J250QAM.11 - 2 ,
11.4.3 This section deleted in Revision 3. }: 11.4.4 The Manager, Nuclear Glee Quality-Aeeerence Services is delegated the responsibility for assuring implementation of t'st e activities at the plant site by inspection. The Managery-Programe-Quelfey-Aseneenee He is responsible for reviewing test programs and Plant Administrative Procedures which control testing to verify conformance to the require-ments of this Policy. Lower tier instructions may be reviewed.by. individuals (other than the preparer) of the I organization preparing the documents if such individuals have been indoctrinated in the Operational Quality Assurance Program. The Manager, Pregrene Quality Systems Assurance is responsible for indoctrination and certifi- { cation of these individuals. 11.4.5 The Director, Quality-Assurance Programs has the responsi- . bility for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with the requirements of the Operational Quality Assurance Program, including the requirements of this Policy. 11.5- REQUIREMENTS i 11.5.1 A test program shall be established and implemented to assure that testing required to demonstrate that a safety-related structure, system or component will perform ] l OPERATIONAL QUALITY /SSURANCE MANUAL Rev. 6 TITLE:~ TEST CONTROL Page 3 of 6 Policy 11 . l
'J250QAM.11 - 3 l 1
satisfactorily-in service is identified and documented, and that the testing is performed in accordance with written, controlled test procedures.
.11.5.2 The test program shall be implemented by the responsible organizations to cover all required testing, including pro-totype tests .preoperational tests, initial start-up tests, surveillance-tests. and tests associated with plant maintenance and modifications during the operational phase.
11.5.3 This section deleted in Revision 3. 11.5.4 This section deleted in Revision 3. 11.5.5 Surveillance testing during the operational phase shall be performed to provide assurance that failures or substandard performance do not remain undetected and that the required reliability of safety-related systems is maintained. A surveillance testing schedule (s) shall be established reflecting the status of all planned in-plant surveillance tests and inspections. Frequency'of surveillance tests may ! l be related to the results of reliability analyses, the-frequency and type of service, or age of the item, as I appropriate. ; 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 l TITLE: TEST CONTROL Page 4 of 6 Policy 11
'J250QAM.11 - 4 I 1
i 11.5.6 Tests performed following plant modifications, repairs or t replacements shall be conducted in accordance with the original design and testing requirements or engineering ) approved, documented alternatives. Testing shall be suffi-cient to confirm that the modifications or changes reason-ably produce expected results and that the change does not reduce safety of operations. 11.5.7 Written procedures for performing the tests shall incorpo-rate or reference the following, es applicable: 11.5.7.1 A description of test objectives; 11.5.7.2 The requirements and acceptance limits contained in applicable design and procurement documents; 11.5.7.3 Instructions for performing the test; 11.5.7.4 Test prerequisites (e.g. calibrated instrumen-tation; adequate and appropriate equipment; trained, qualified, and licensed or certified personnel; assurance of completeness of the item to be tested; suitable and controlled environ-mental conditions; and provisions for data collection and storage); l 11.5.7.5 Hold points or witness points for inspection by j designated personnel; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: TEST CONTROL Page 5 of 6 Policy 11 l l J250QAM.11 - 5 .l l l
i
)
11.5.7.6 Acceptance and rejection criteria; ,
-1 11.5.7.7 Methods of documenting or recording test data and !
d results. ! 11.5.8 The documented test results shall be evaluated and their acceptability determined by qualified individuals or organ-izations as designated in the procedures. i OPERATIONAL QUALITY ASSUR/RCE MANUAL Rev. 6 TITLE: TEST CONTROL Page 6 of 6 Policy 11 J250QAM.11 - 6
12.0 CONTROL OF MEASURING AND TEST EQUIPMENT i l 12.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by MP&L SERJ to provide for the control of measuring and test equipment used in the performance of safety-related activ-ities for the Grand Gulf Nuclear Station. 12.2 SCOPE This Policy delineates responsibilities and defines requirements for the calibration, maintenance and control of measuring and test equip-ment used in safety-related applications in order to assure the re-quired accuracy of such equipment. 12.3 APPLICABILITY l The requirements of this Policy apply to all tools, instruments, testing equipment and measuring and control devices used in inspec-tions, measurements, tests or monitoring of safety-related compenenta, systems or structures during the operational phase of nuclear power plant activities. The requirements of this Policy do not apply to rulers, tape measurers, levels and other such devices if normal commercial prac-tices provide sufficient accuracy. l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF MEASURING AND TEST EQUIPMENT Page 1 of 6 Policy 12 J250QAM.12 - 1
- 12. 4 '. RESPONSIBILITY' L
12.4.1 Responsibility and authority for the control of-measuring
.and test' equipment at the plant site during the operational phase are delegated to the GGNS General Manager. .During implementation and testing of design changes and plant
'l'{
modifications, the Manager, Unit 1 Projects is responsible for ensuring that all M&TE utilized are controlled.in accordance with procedures developed by the GGNS General Manager. They are responsible for assuring that proced:res are developed to implement the requirements of this Policy. 12.4.2 Organizations supplying materials, equipment or services are responsible for complying with the applicable require-ments of this Policy, as specified in the appropriate procurement documents and for imposing them on their contractors and suppliers, as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 12.4.3 The Manager, Neelear-Gite Quality Systems Assurance is delegated the responsibility for assuring by audit ce inepectfen the control of measuring and test equipment at the plant site. The Manager, Quality Services is delegated the responsibility for assuring by inspection the control of measuring and test equipment at the plant site. The Manager, Peegrame Quality Assuranee Serviese is responsible for reviewing Plant Administrative Procedures which govern OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF MEASURING AND TEST EQUIPMENT Page 2 of 6 Policy 12 J250QAM.12 - 2 I
f equipment control' instructions to verify conformance to'the-
. requirements of this Policy. Lower tier ~1 instructions may be reviewed by individuals..(other than the preparer)'of the j organization preparing the documents, if such individuals
' have been indoctrinated in the Operational Quality Assurance Program. The Manager, Pregeene Quality Systems m . Assurance.is responsible for indoctrination and certifica-
, tion of these individuals.
l 12.4.4 The Director. Quality-Assurance Programs has the responsi-bility for carrying out an. audit program, as described in Policy 18.0 of this Manual,-to verify conformance with the requirements of the Operational Quality Assurance Program, including'the requirements of this Policy.
- 12.5 REQUIREMENTS 12.5.1 Organizations performing safety-related functions which require.the use of measuring and' test equipment such as instruments, control devices, gages, tools, fixtures, cal-ibration standards and nondestructive test equipment shall establish and implement procedures to control the calibra-tion, maintenance and use of such equipment.
12.5.2' Procedures shall assure that measuring and test equipment used for measurements, tests or calibrations is of the- 1 L proper range and type and is controlled, calibrated, adjusted and maintained at specific intervals, or prior to use, to assure necessary accuracy. l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF MEASURING AND TEST EQUIPMENT- Page.3 of 6 Policy 12
I 12.5.3 The method and interval of calibration shall be estchlished for each device or generic grouping thereof, and shall be based on the type of equipment, stability and reliability characteristics, required accuracies and other conditions affecting calibration. 12.5.4 Procedures shall provide methods for the positive identifi-cation of all measuring and test equipment included under the calibration system, documentation of its calibration status; and traceability to documented calibration test data, i 12.5.5 Installed operations measuring and test equipment requiring calibration shall be labeled, tagged or otherwise 5 controlled in accordance with written, approved procedures to assure that approved calibration intervals are not exceeded. Portable measuring and test equipment may be similarly controlled; but shall, as a minimum, be clearly labeled to indicate the date on which the current { calibration expires. Portable measuring and test equipment that has exceeded the approved calibration interval shall not be used for measurements or tests. 12.5.6 Calibration standards shall be traceable to nationally recognized standards; or, where national standards do not exist, provisions shall be established to document the basis for calibration. In order to establish this OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF MEASURING AND TEST EQUIPMENT Page 4 of 6 Policy 12 J250QAM.12 - 4
traceability, calibrating standards should have a greater i accuracy than the standard being calibrated and possess cufficient range and' stability to assure that the standard being calibrated is within the required tolerance. Calibrating standards with the same accuracy as the standard being calibrated shall be allowed if it can be
'shown t'o be adequate for the requirements and the basis of.
acceptance is documented and evaluated by a technically knowledgeable individual and authorized by' responsible management. 12.5.7- Measuring and Test Equipment (M&TE) should be calibrated against standards (for the purpose of calibration M&TE is defined-as that equipment, whether permanently installed or portable, used to calibrate permanent plant devices) that have an accuracy of at least four times the. required accu-racy of the M&TE being calibrated. A standard of lesser accuracy shall be allowed provided that the basis of acceptance is docuuented, evaluated for adequacy by a technically knowledgeable individual and authorized by l responsible management. Calibration of permanent plant devices shall be.against M&TE having sufficient accuracy, greater than the device being calibrated, to assure that the system containing the device is within the specified system tolerance. The basis for determining the greater than e.Jcuracy of the M&TE used shall be reproducible, either by engineering demonstration l I OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 l
' TITLE: CONTROL OF MEASURING AND TEST EQU1PMENT Page 5 of 6 Policy 12
.J250QAM.12 - 5
= _ _ _ _ _ - _ - _ _
n or documentation. Wh'en an accuracy is.specified'in the:
. Technical Specifications or bases thereof, this accuracy may be used in lieu of one determined by engineering
! demonstration or documentation.
12.5.8' Measures shall be established to assure that, if a piece of 1^ measuring and test equipment is found to be out of calibra-tion, an evaluation shall be made and documented, in accor-dance with Policy 15.0, to verify the validity of previous tests and the acceptability of devices tested since the time of the last calibration. A permanent plant device which is found out of calibration, but within the tolerance given in the Technical Specifications, may be adjusted. Such cetions shall be documented, but they need not be evaluated or processed as specified in Policy 15.0. 12.5.9 If any calibration,. testing or measuring device is consis-
.tently found to be out of calibration, it shall be repairtd or replaced.
1-1 1 i l 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 j
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13.0 HANDLING, STORAGE AND SHYPPING 13.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by MP&L SERI to control the handling, storage and shipping of safety-related materials, components and systems for the Grand Gulf Nuclear Station. 13.2 SCOPE 1 i This Policy delineates responsibilities and defines requirements for handling, storage and shipping, including cleaning, packaging and preservation of safety-related items in order to assure that the requisite quality of the items is maintained until they are used or incorporated into the nuclear power plant. 13.3 APPLICABILITY The requirements of this Policy apply to all individuals or organiza-tions participating in the cleaning, handling, packaging, preserva-tion, shipping and storage of safety-related items during the operational phase of nuclear power plant activities. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: HANDLING, STORAGE AND SHIPPING Page 1 of 6 Policy 13 J250QAM.13 - 1
13.4 RESPONSIBILITY 13.4.1 During the operational phase at the plant site, and excluding preoperational testing, the responsibility and authority for control of handling, storage and shipping, including cleaning and preservation, are delegated to the GCNS General Manager. During the implementation and testing of design changes and plant modifications, the Manager, Unit 1 Projects is responsible for these activities. The responsibility and authority for the control of handling, l l 5 storage and shipping, including cleaning and preservation, : involved with preoperational phase testing programs, are delegated to the Unit 2 Construction Superintendent. They are responsible for assuring that procedures are established to address the applicable requirements of this Polley and that work and inspection activities are accomplished in accordance with the established procedures, 13.4.2 Organizations supplying safety-related material, equipment and services are responsible for complying with the appli-cable requirements of this Policy, as stipulated in the procurement documents, and for imposing them on their con-tractors and suppliers as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: HANDLING, STORAGE AND SHIPPING Page 2 of 6 Policy 13 J250QAM.13 - 2
I i 13.4.3 The Manager, Nuclear 64ee Quality-Assuranee Services is i 1 delegated the responsibility for inspection of the control of handlingy and storage and shipping at the plant site (excluding the varehouse-related) including during' pre-operational and startup testing. The Manager, Quality Systeme is delegated the responsibility for varehouse-related inspection (including receipt inspection) of the. control of handling, storage and shipping at the ' plant eite i including during preoperational and startup testing. The Manager, Pregrene Quality Assuranee Scruices is responsible for reviewing Plant Administrative Procedures to verify conformance to the applicable requirements of this Policy. Lower tier instructions may be reviewed by individuals (other than the preparer) of the organization preparing the documents, if such individuals have been indoctrinated in the Operational Quality Assurance Program. The Manager, Progeeme Quality Systems Assuranee is responsible for indoctrination and certification of these individuals. 33.4.4 The Director, Quality-Assurance Prograws has the responsi-bility for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with the requirements of the Operational Quality Assurance Program, including the requirements of this Policy. i i i l 1 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 ]
. TITLE: HANDLING, STORAGE AND SHIPPING Page 3 of 6 Policy 13
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p i L13.5 ' REQUIREMENTS,
.i 13.5'1 4 Procedures shall be established to: control' handling,.
. storage andishipping, including cleaning, packaging and preservation of safety-related materials, components and ;
, systems. The procedures may be. developed to cover generic l> '
l' ~ classifications of items which require equivalent. levels of .! 1' protection and gentrol during handling, storage and L
' shipping.' Classified items shall.be restricted to that; level or' higher'for each of the particular handling, d storage and shipping operations; and a change in the.
L - j J classification of an item shall only be made in accordance- ') with'a written, engineering approved procedure. 13.5.2 The? procedures shall be developed by the appropriate organizations to cover the various stages from fabrication or manufacture of the items to incorporation.into the plant. 13.5.3 The procedures'shall address the applicable design and s regulatory requirements; codes and standards; and manufac- I turer's recommendations as approved by MP&L SERJ engineering personnel for the prevention of damage, deterioration or loss prior to installation or use. Source quality verification or inspection operations necessary to i verify conformance to the established criteria shall be i included in procedures, and documentation of the j verification activities shall be required. OPERATIONAL QUALITY ASSURANCE MANUAL' Rev. 6 l TITLE: HANDLING, STORAGE AND SHIPPING l Page 4 of 6 Policy 13 1 J250QAM.13'- 4
y yp
'13.5.4- -Packaging and pres.ervation procedures'shall provide assur-g, -
.ance if adequate protection against corrosion, contamina-tion,![ physical damage or any effect which would lower the O quality of the item or cause it to deteriorate during ship-ping, handling or storage. Special protective environments, 4
special coverings, inert gas atmosphere, allowable moisture-content', and temperature level shall be specified as required and cheir existence verified and documented. 13.5.5' Cleaning procedures shall provide assurance that nececsary cleaning operations are carried pet prior to packaging, storag'e or installation. The: level of cleanliness required and verification and documentation requirements shall'be specified in the procedures. 13.5.6 -Procedures'shall be-provided to assure that proper marking and labeling of items and containers is accomplished to provide identification and necessary instructions during packaging, shipment and storage. 13.5.7 Measures for receipt inspection of items, disposition of received items and control of nonconforming items shall be addressed in procedures which implement the applicable requirements of Policies 7.0 and 15.0 of this Manual. 4 : s
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13.5.8 Detailed handling procedures shall be provided for all items that require s'pecial handling. Special handling tools and equipment'ahr.ll be provided and controlled to ensure safe and adequate handling. These tools and equip-
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- OPERATIONAL QUALITY ASSURANCE MANUAL
' TITLE: . HANDLING, STORAGE AND SHIPPING Page 5 of 6 Policy 13
ment shall be maintained.. inspected and tested in accordance with written procedures at established intervals i.
-to. ensure their reliability and availability for use.
13.5.9; Storage; procedures shall provide for methods of storage and the control of items in. storage which will minimize the possibility of damage or deterioration during storage. Periodic inspections of storage areas shall be performed
.and documented to verify compliance with storage 1 procedures. Release of items for installation shall also be l
procedurally controlled. l^
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13.5.10 Until Unit 2 has completed construction and all material has been turned over to MP&L SERJ, administrative controls si.all be established for the transfer of Bechtel procured and controlled items to the MP&b SERJ Operational Quality Assurance Program. L. 1 1'
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OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: HANDLING, STORAGE AND SHIPPING Page 6 of 6 Policy 13 l
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T gt w3p: t 14.0 INSPECTION, TEST AND OPERATING STATUS
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14.1 PURPOSE This Policy describes the Operational Quality Assurance Program measureo established by MP&L SERI to identify aad control the inspection, test and operating status of safety-related structures, systems and components for the Grand Gulf Nuclear Station. 14.2 SCOPE This Policy delineates responsibilities and defines requirements for identifying and controlling the inspection, test and operating status of safety-related items in order to assure that required inspections and tests are performed and the acceptability of items is known, and to prevent the inadvertent operation of items which are in a con-trolled status. 14.3 APPLICABILITY The requirements of this Policy apply to all individuals or organiza-tions performing functions on safety-related structures, systems and components during the operational phase of nuclear power plant j i activities. l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION, TEST AND OFFRATING STATUS Page 1 of 5 Policy 14 J250QAM.14 - 1
14.4 .RESPONS1ElLITY 14.4.1 During the operational phase, responsibility and authority for identifying and controlling the test and operating status of safety-related items, excluding preoperational testing, are delegated to the GGNS General Manager. The responsibility and authority for identifying and controlling the test and operating status of safety-related items involved in preoperational phase testing programs are delegated to the Unit 2 Construction Superintendent. The Director. Quality-Assuranee Programs has the responsibility and authority for identifying and controlling the inspec-tion, test, and operating status of safety-related items. They are responsible for assuring that procedures are developed and implemented to address the applicable requirements of this Policy. 14.4.2 Organizations supplying safety-related material, equipment and services are responsible for complying with the appli-cable requirements of this Policy, as stipulated in the procurement documents, and for imposing them on their con-tractors and suppliers as applicable. They are also re-sponsible for verifying, through surveillance or audits, that the requirements are being adequately 1mplemented. 14.4.3 The Manager, Programe Quality-Assurance Services is responsible a:r reviewing Plant Administrative Procedures to verify conformance to the applicable requirements of this Policy.
. OPERATIONAL QUALTTY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION, TEST AND OPERATING STATUS Page 2 of 5 Policy 14
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l Lower tier instructions may be reviewed by individuals , (other than the preparer) of the organization preparing the l documents if such individuals have been indoctrinated in the Operational Quality Assurance Program. The Manager, Pregreme Quality Systems -Assuranee is responsible for indoctrination and certification of these individuals. L 14.4.4 ihe Director, Quality-Assurance Programs has the responsi-bility for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with F-Operational Quality Assurance Program requirements, .{ including the requirements of this Policy. 14.5 REQUIREMENTS 14.5.1 Procedures shall be established and implemented by the organizations responsible for the fabrication, storage, installation, test, and operation of safety-related struc-tures, systems and cr>ponents to assure that the inspection, test and operating status of such items is identified, controlled and made known to affected organizations. h 14.5.2 The procedures shall require that the status of inspections and tests be indicated by the use of appropriate status indicators such as stamps, tags, labels, routing cards, 4 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION, TEST AND OPERATING STATUS Page 3 of 5 Policy 14 J250QAM.14 - 3 c.
.e shop travelers, or other suitable means.
Suitable means may include identification numbers which are traceable to 4 inspection and test records. 14.5.3' The procedi.res shall identify the status indicator to be used and provide for its control, including responsibility and authority for application and removal. 14.5.4 Bypassing of required inspections, tests or other critical operations shall be procedurally controlled with concurrence by Quality Assurance.- Where necessary to preclude inadvertent bypassing of required inspections and tests, the procedures shall provide for the identification of items which have passed such inspections and tests. 14.5.5 In cases where documentary evidence is not available to confirm that an item has passed required inspections and tests, that item shall be considered nonconforming and processed in accordance with Policy 15.0. Affected systems shall also be evaluated for operability in accordance with the. Technical Specifications and reliance shall not be placed on any such systems (which are evaluated as inoperable) to fulfill their intended safety functions.
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14.5.6 Procedures shall be provided to require identification of , 1 the operating status of. systems, components, controls, or support equipment in order to prevent inadvertent or unauthorized operation. These procedures shall require OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION, TEST AND OPERATING STATUS Page 4 of 5 Policy 14 J250QAM.14 - 4 , 1 L _. _ _ _ _ _ _ - _ _ _ _ _ _ - -
control measures :such'as locking or tagging to secure'and
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= identify equipment in a controlled status. Independent verification shall,be required, where appropriate, to ensure.that necessary measures, such as tagging equipment,
'have been implemented correctly.
14.5.7 Temporary modifications shall be controlled by approved procedures which include a requirement for independent verification. A-log shall-be maintained of the current status of such temporary modifications. 14.5.8 Nonconforming services and nonconforming, inoperative or malfunctioning structures, systems, components or materials
'shall be identified and controlled in accordance with the requirements of. Policy 15.0 of this Manual.
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t 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS (Including Items, Services and Activities) 15.1 PURPOSE This Policy describes the Operational Quality' Assurance Program measures established by Mp6L SERI to identify and control safety-related items, services or activities for the Grand Gulf Nuclear Station which do not conform to established requirements. i 15.2 SCOPE This Policy delineates responsibilities and defines requirements for the identification and control of nonconforming safety-related items, services or activities in order to assure that the nonconforming conditions do not compromise quality or safety. 15.3 APPLICABILITY The requirements of this Policy apply to all individuals or organiza-tions performing functions on safety-related structures, systems, materials, parts or components during the operational phase of nuclear power plant activities. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 1 of 7 Policy 15 J250QAM.15 - 1
.15.4^ RESPONSIBILITY
, 15.4.1 , Responsibility and authority for the identification and-control of nonconforming items, services and activities during the operational phase are delegated to the Director, Nuclear Plant Engineering (for engineering); the Manager,
. Unit 1 Projects (for implementation and testing-of design changes and plant modifications); the Unit 2 Construction Superintendent (for preoperational phase testing); the Director, Nuclear Support (for nuclear fuel or core items);
the GGNS General Manager; the. Director, Quality AeenraneePrograms; and the manager of the organization performing the activity. It is the responsibility of these individuals to assure that the requirements of this Policy
.which are applicable'to their scope of activities are implemented in accordance'with documented procedures. All personnel are responsible for reporting detected nonconfor-mances in accordance with the procedures applicable to their particular organization.
15.4.2 Organizations supplying material, equipment or services are responsible for complying with the applicable requirements of this Policy, as specified in the procurement documents, and for imposing them on their contractors and suppliers, as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 2 of 7 Policy 15
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>..;. '15.4.3 The Manager, Nue&eae Site Quality-Asentenee Servicae is delegated the responsibility for assuring implementat. ion of -
the identification and control of nonconforming items, l services and: activities by endit-ce inspection (sxcluding receipt inspection) of plant site operations phase L activities, including preoperational and startup testing to verify conformance to the applicable requirements of this
; Policy. The Manager, Quality Systems is delegated the -
responsibility for assuring implementation of the identi-
. fication and control of nonconforming iteme, services and-
. activities by audit or receipt inspection of plant 'eite operations phas'e activities, including preoperational and startup testing to verify conformance to the applicabis requirements of this Policy.
The Manager, Quality Services is delegated the responei-bility'for control, processing, tracking, dispositioning, and verification of nonconformance documente for ptant site . operatione phase activities, including preoperational and startup testing to verify conformance to the applicable requirements of this Policy. 15.4.4 'The Director, Quality-Aeoneenee Programe has the responsi-bility for. carrying out an audit program, as described in Policy 18.0 of this Manual, to verify'conformance with the-requirements of the Operational Quality Assurance Program, including the requirements of this Policy. He is also OPERATIONAL' QUALITY ASSURANCE MANUAL Rev. 6 TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 3 of 7 Policy 15 J250QAM.15 - 0
l l J responsible for the periodic review and analysis of NRC and MPE SERJ Quality Assurance nonconformance documents to detect possible adverse quality trends. 15.5' REQUIREMENTS 15.5.1. Procedures shall be established by the responsible organizations to identify and control nonconforming safety-related items, services and activities. The procedures shall include provisions for identification, documentation,. segregation, review, disposition and notification to affected organizations, as appropriate. 15.5.2' The procedures shall specify the individuals or organiza-tions responsible for the' disposition and approval of non-
-conforming items, services or activities, including an independent review and acceptance.by the appropriate
. quality organization, and shall provide for documentation to identify the item, service or activity; describe the nonconformance; document the disposition-and inspection requirements; and provide signature approval of the' !
disposition. Unless evaluated as having no impact on satisfactory performance, nonconformances are corrected or resolved prior to the initiation of the preoperational test program on the item. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: NONCONFORMING MATERIALS, PARTS l' OR COMPONENTS Page 4 of 7 Policy 15 l 'J250QAM.15 - 4' f j
15.5.3' 'Emagures ahn11 be established to procedurally control further processing, delivery or installation of a noncon-
-forming item or continuation of a nonconforming service or i
activity, pending a decision on its disposition. ) f 15.5.4 In order to prevent its inadvertent use or installation, a-nonconforming item shall be identified by marking or tagging and shall be physically segregated, where practical. If physical segregation'is not practical, identification of the item as nonconforming by marking or- ! l tagging shall be acceptable. Where marking or tagging is not feasible, nonconforming items may be controlled by the use of appropriate documentation. Markings or tags used to identify nonconforming items shall be removed after resciution of the nonconforming condition. 15.5.5 Nonconforming items, services or activities shall be reviewed and dispositioned in accordance with documented procedures. Items may be dispositioned in the following ways: 15.5.5.1 Accept-as-is; 15.5.5.2 Scrap; I 15.5.5.3 Rework to conform to a drawing or specification; I i l 15.5.5.4 Repair in accordance with an engineering approved j procedure. l . OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 I TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 5 of 7 Policy 15 E __JRE@NL N 0 $L
i Items received without the necessary documentation shall be
' controlled. ' Acceptance of such items will be withheld pending receipt of required documentation or the items will be considered nonconforming.. j i
15.5.6 The acceptability of rework shall be verified by reinspecting or retesting the item to the original requirements, or by an equivalent method which has been reviewed and approved. The acceptability of repair shall be verified by reinspection, or retesting the item by an 1 . l engineering approved method even though the item still may not conform to the original requirements. Inspection, o testing, rework and repair shall be documented. 15.5.7 For items dispositioned " accept-as-is" or " repair," a description _of the change, waiver or deviation shall be documented to record the change and denote the as-built condition. Documentation verifying the acceptability and approval of such items shall also be required. l 15.5.8 Nonconformance reports with " accept-as-is" or " repair" dispositions submitted by contractors or suppliers shall be reviewed and concurred with by the designated individuals and shall become a part of the inspection records to be submitted with the item. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
-TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 6 of 7 Policy 15 J250QAM.15 - 6
15.5.9 Nonconformance reports shall be periodically reviewed and analyzed to detect possible adverse quality trends, and the resulta shall be reported to management for review and assessment. e l I a l l l 1 l 1 l l 1 1 I l i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 7 of 7 Policy 13 J250QAM.15 - 7
16.0 CORRECTIVE ACTION 16.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by MPhb SERI to provide for the correction of conditions adverse to the quality or safety of the Grand Gulf Nuclear Station. 16.2 SCOPE This Policy delineates responsibilities and defines requirements for the identification, documentation, reporting, and correction of conditions adverse to quality or safety, including requirements for f the determination of cause and corrective action to preclude the I 1 recurrence of significant conditions adverse to quality or safety. 16.3 APPLICABILITY The requirements of this Policy apply to all individuals or organiza-tions performing functions which affect safety-related structures, systems or components during the operational phase of nuclear power plant activities. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CORRECTIVE ACTION Page 1 of 5 Policy 16 l J250QAM.16 - 1 1 __ ________a
i a: 16.4 RESPONSIBILITY ] t 16.4.1: Responsibility and authority for the development and, control of measures to assure corrective action during the operational phase are delegated to the Site Director GGNS;
' Director, Nuclear Plant Engineering; Director, Nuclear Support; Director,'1!uclear' Licensing end-Safety; and the Director, Quality AestueeneePrograns. They:are responsible
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for assuring that pro,cedures'are established, in accordance. with the requirements of this Policy to provide for the identification, documentation, and correction of conditions adverse to quality or safety. They are also responsible for assuring that corrective action implemented is designed to prevent recurrence of significant adverse conditions. 16.4.2 All organizations performing quality or safety affecting activities are responsible for incorporating into the. appropriate procedures, measures for identifying and reporting conditions which may warrant-corrective action. Responsibility.for determining and implementing necessary , corrective action is delegated to the organization per- l forming or controlling the activity. During the opera- l tional phase, the responsibility for the determination and ; implementation of corrective action onsite, excluding preoperational testing activities, is delegated to the GGNS General Manager. During implementation and testing of design changes and plant modifications, the Manager, Unit 1 Projects is responsible for this activity. The responsibility for
' OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
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- the determination and implementation of corrective action associated with preoperational phase testing programs,is delegated to the Unit 2 Construction Superintendent.
16.4.3 This section deleted in Revision 4. 16.4.4 Organizations supplying material, equipment or services are responsible for complying with the requirements of'this Policy as specified in the appropriate procurement documents, and for imposing them on their contractors and suppliers as applicable. .They are also responsible for verifying, through surveillance or audits, that the requirements are being. adequately implemented. 16.4.5 The Director, Quality-Aesurance Programs has the responsi-bility for carrying out an audit program, as described in Policy 18.0 of this Manual; to verify conformance with i Operational Quality Assurance Program requirements, including the requirements of this Policy; for the-periodic review and analysis of NRC and MP&L SERJ Quality Assurance nonconformance documents to detect possible adverse quality trends; for reporting such items, if any, to the Vice President, Nuclear Engineering & Support and the Vice President, Nuclear Operations for further action. I i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CORRECTIVE ACTION Page 3 of 5 Policy 16 J250QAM.16 - 3 i' _ _ _ _ _ _ _ _ - _ _ _ _ _ - _
16.5 REQUIREMENTS 16.5.1 Procedures shall be established and implemented by the responsible organizations, consistent with the scope of their activities, to provide measures for the identification, documentation, reporting and correction of conditions adverse to quality or safety. ,
-16.5.2 The procedures shall provide for the evaluation of conditions such as nonconformances, failures, malfunctions, deficiencies, violations, deviations, reportable occurrences, 10CFR21 items, and defective material and equipment to determine the need for corrective action and to identify possible adverse quality trends.
l 16.5.3 The procedures shall require that action be promptly initi-t ated and adequately documented by the responsible organiza-tion to correct the condition and to determine if action is-necessary to preclude its recurrence. 16.5.4 The documentation to be used to report conditions adverse to cuality or safety and request corrective action, and the appropriate distribution and control thereof, shall be specified in the procedures. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CORRECTIVE ACTION Page 4 of 5 Policy 16
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m y I L16.5.5 The. procedures shall provide'for follow-up reviews by'the appropriate organizations to verify proper implementation of the corrective action and to'close out the documentation. 16.5.6 For significant conditions adverse to. quality or safety,. the cause of the conditions, and.the corrective action I taken which is-designed to-prevent recurrence of the event-shall be documented and reported to appropriate levels of management for review. 16.5.7 Nonconforming materials, parts and components (including items', services and activities) sha11Lbe identified, con-
-trolled.and dispositioned in accordance with' procedures.
which impJement the requirements of Policy 15.0'of this Manual. 4 i i OPERATIONAL QUALITY ASSURANCELMANUAL Rev. 6 TITLE: CORRECTIVE ACTION. Page 5 of 5 Policy 16 J250QAM.16 - 5
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[17.0. QUALITI ASSURANCE' RECORDS
'17.11 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by MP&L SERJ for the' collection,' storage, and maintenance of quality assurance records for the Grand Gulf Nuclear Station.
-17.2 ' SCOPE 1
1
-This Policy delineates responsibilities and defines requirements for the development'of a records management system to' provide for the collection, storage, and ma'ntenance i of quality assurance rec'ords.
Quality-assurance records include those records which furnish documentary evidence.of the quality of items and of activities affecting quality.
.17.3 APPLICABILITY The requirements of this. Policy apply to all individuals or organiza-tions participating in the collection, storage or maintenance of quality assurance records during the operational phase of nuclear power plant activities.
i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE RECORDS Page 1 of 6 Policy 17 J250QAM.17_- 1;
17.4 RESPONSIBILITY 17.4.1 Responsibility and authority for the development of a records management system are delegated to the Vice President, Nuclear Operations. This includes responsibility for the collection, storage and maintenance of quality assurance records generated during design and construction, as well as during the operational phase. He shall assure that records are collected, stored and maintained in accordance with procedures which address the requirements of this Policy. Responsibility for the development of the required procedural controla for the collection, storage and maintenance of quality assurance records is delegated to the GGNS General Manager. 17.4.2 The GGNS General Manager is responsible for the collection, storage and maintenance of records generated onsite and j I required to be maintained at the site including GGNS l records generated by the Plant Modification and Construc-tion Section. Such records include those necessary to operate and maintain the facility and meet regulatory requirements. Such records shall be identified in the appropriate Plant Staff Procedures or the Plant Modification and Construction Section Procedures developed to meet the requirements of this Policy. l f l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE RECORDS Page 2 of 6 Policy 17 J250QAM.17 - 2 l
m. ii 17.4.3 Tha M: nager, Nmbre Sita Quality-Am:eInre Services and ? the Manager, Quality Systems are in delegated the responsi-bility for assuring implementation of the collection, storage, and maintenance of those quality assurance records onsite which are under the control of the GGNS General Manager. The Manager, Pregeese Quality-Assueenee Services is responsible for reviewing Plant Administrative pro-cedurest and the-Manageer-Nuclear-6 fee-Quelfey-Aseveenee fee-eeviewing work documents and for performing inspections to the extent necessary to verify conformance to the requirements of this Policy. Lower tier instructions may be ' reviewed by individuals (other than preparer) of the organization preparing the documents if such individuals ! have been indoctrinated In the Operational Quality Aseurance Program. The Manager, Peegrams Quality Systems. Assueenee is responsible for indoctrination and certifi-cation of these individuals. 17.4.4 The CGNS General Manager is responsible for the collection, storage and maintenance of records generated by the Nuclear Support Staff, Nuclear Licensing end-Safety Staff, Nuclear Plant Engineering end-Genetruction Staff, and those records transmitted to the GGNS General Manager. This includes quality assurance records generated by Quality Assurance. 1 Records to be maintained by the GGNS General Manager shall ; be identified in the appropriate Nuclear Support, Nuclear l l Licensing end-Befeey, and Nuclear Plant Engineering and Gensernetten Administrative Procedures developed to meet the requirements of this Policy. OPERATIONAL. QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE RECORDS Page 3 of 6 Policy 17 MNE o 9 - - - . _ _ _ _ _ _ _ _ _ _ _ _
17.4.5 The Director,' Quality -Assurance Programs is responsible for the collection and storage of quality assurance records generated by Quality Assurcnce until such time as they are transmitted to the GGNS General Manager. Such records shall be identified in the appropriate Quality Assurance Procedures developed to meet the requirements of this Policy. [ 17.4.6 Other organizations whose scope of activities require the i generation, collection, storage or maintenance of quality assurance records shall establish procedures to assure { compliance with the applicable requirements of this Policy. Contractors and suppliers are responsible for complying with the requirements of this Folicy to the extent , I specified in the appropriate procurement documents, and for imposing them on their contractors and suppliers, as j applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 17.4.7 The Director, Quality-Assurance Programs has the responsi-bility for carrying out an audit program, as described in j l Policy 18.0 of this Manual, to verify conformance with l Operational Quality Assurance Program requirements, including the requirements of this Policy. 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE RECORDS Page 4 of 6 Policy 17 J250QAM.17 - 4
17.5 REQUIREMENTS I l 17.5.1 A system for the collection, storage and maintenance of { l quality assurance records--including provisions for identification, classification, indexing, retention, preservation, safekeeping, retrievability and disposition--shall be established. 17.5.2 The records system shall define requirements and responsi-bilities for records transmittals, retention. and mainte-nance, subsequent to the completion of a work activity, consistent with applicable codes, standards and procurement documents. Measures to assure that the required records have been received and are acceptable shall be established. 17.5.3 The records system shall provide measures to assure that records are identifiable and retrievable. Retention periods of sufficient duration to assure the ability to reconr,truct significant events and satisfy regulatory or statutory requirements shall be specified. Inspection and test records shall contain the following where applicable. 17.5.3.1 A description of the type of observation; 17.5.3.2 Evidence of completing and verifying a manu-facturing, inspection, or test operation; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE RECORDS Page 5 of 6 Policy 17 , J250QAM.17 - 5
217.5.3.3~ The date and'results of the inspection or test; 17.5.3.41 Information'related to conditions adverse-to l quality; 17.5.3.5 Inspector or data recorder identification; 17.5.3.6 Evidence as to the acceptability of the results.
.17.5.4 Storage f'acilities for quality assurance records shall be.
designed to prevent recordo' damage'or loss, to the maximum extent practical; or as a-satisfactory alternative, dupli-cate record shall be stored in a separate remote location. l 17.5.5 Records and documentation requirements are specified in the other Policies of this Manual. Quality assurance records include, but are not limited to: design records, such as specifications and drawings; procurement documents; operat-ing logs and' procedures; principal maintenance and I modification documents; results of reviews, inspections, f) tests, audits, material analyses; monitoring of work i performance; personnel, procedures, and equipment qualification records; nonconformance reports; corrective action documents; and 10CFR evaluations (i.e., 10CFR50.59, ; 10CFR21). ) l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE RECORDS Page 6 of 6 Policy 17
'J250QAM.17 - 6.
18.0 AUDITS. 18.1 PJRPOSE-
.This Policy describes the Operational Quality Assurance Program measures established by MP6L SERI to provide a comprehensive audit program for'the Grand Gulf Nuclear Station.
18.2 SCOPE This Policy-delineates responsibilities and defines requirements for
- the development and implementation of a' comprehensive program of planned and documented audits designed'to verify compliance with, and assess the effectiveness of, the Operational Quality Assurance Program.
18.3 APPLICABILITY The requirements of this Policy apply.to all internal and external audits performed by or for MP&L SERI during the operational phase of nuclear power plant activities. 18.4 RESP 0MSIBILITY 18.4.1- Responsibility and authority for the MP&L SERI audit program are delegated to the Director, Quality-Aeeneance Programs. He , is responsible for the development and implementation of a program of planned and documented audits to verify l compliance with all aspects of the Operational Quality OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: AUDITS Page 1 of 6 Policy 18 i- AMdh
- L _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _
l Assursnce Program and to assess its effsetivansas. Ha is
. responsible for assuring that procedures are developed -in-accordance.with the requirements of this Policy, to provide for both internal and external audits. He is responsible for performance of audits to verify plant conformance to the Technical Specifications; audits of operational phase activities (including activities of the Startup Organiza-tion); and audits of contractors and suppliers performing onsite and offsite activities. He shall also assure that audit results are documented and reported't'o appropriate management, and that prompt corrective action is taken to eliminate nonconformances detected during the course of' audits.
l 18.4.2- This section deleted in Revision 3. 18.4.3 Organizations supplying material, equipment or services are j
~!
responsible for auditing their internal operations and- 1 their contractors and suppliers, as stipulated in the appropriate procurement documents, in order to verify compliance with the quality assurance program requirements specified in the procurement documents. l 18.4.4 The section deleted in Revision 5. l i I i l OPERATIONAL' QUALITY ASSURANCE MANUAL Rev. 6 ! TITLE: AUDITS l Page 2 of 6 Policy 18 J250QAM.18 - 2
'18.5 -REQUIREMENTS-Lt-18.5.1- 14 comprehensive program of planned and documented audits
'shall be established and implemented by the Quality Assur-d
-ance Organization ^to verify compliance with all aspects of
- the Operational Quality Assurance Program.- The audit
-program shall be carri^ed out in accordance with written- <t i
approved procedures which address the requirements of this Policy. a 18.5.2' The audit program shall provide for both internal and 3, external audits. Internal audits shall include audits of the. procedures and performance of all MP6L SERI organizations whose activities affect the quality of safety-related structures, systems and components. External audits shall~ include audits of the practices, procedures and instructions of contractors and suppliers who provide safety-related material, equipment or services. 18.5.3 Audits shall provide an objective evaluation of quality-related practices, procedures, instructions, activities, , and items; and review of documents and records. 18.5.4 Audits of operating plant activities shall include, as a 1
, ,, minimum, those specified in the Technical Specifications for the applicable nuclear generating station.
l l v OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: AUDITS Page 3 of 6 Policy 18 i
~J250QAM.18 .3 I H
^
l _ _ _ ______________--__-_______A
~
- 1. l aph, +.
((. p '18.5.5 Audits shall be performed by trained, qualified personnel not having' direct responsibilities in the areas being
. audited.: . Qualification and training requirements for Jauditors shall be established and documented and records of-N auditor' qualifications shall be maintained and kept
~
current. Personnel selected for quality assurance audit
, assignments shall have experience or-training commensurate.
with the scope, complex.1ty, or special nature of the activities to be audited. 18.5.6. An audit schedule shall be developed, maintained, reviewed and updated, as necessary. The audit schedu)e shall address the following minimum requirements: R 18.5.6.1- Auditing shall be initiated as early in the life b; of an activity as practical to assure timely J implementation of quality assurance program requirements. 18.5.6.2 Audits shall be scheduled on the basis of the status and importance of the activities to be audited. 18.5.6.3 Those specified in the Technical Specifications ! for the applicable nuclear generating station. xt. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
! TITLE: AUDITS g t; - Page 4 of 6 Policy 18 W - J250QAM.18. 4 J
1 e - - - . .- _ . _ - _ _ _ _ _ _ - _ _ -
18.5.7 Individual audits shall be performed in accordance with documented plans and checklists which describe the audit and provide for an objective evaluation of the status and adequacy of the areas being audited. The " objective evaluation" referenced is not to be confused with the evaluation statement in ANSI N45.2.12 to which MP6b SERJ has provided a clarification. See Appendix A. 18.5.8 Audit results, including nonconformances detected during the audit, shall be documented and reviewed with the supervisor or manager having responsibility in the areas audited. Distribution of audit reports shall include management of the audited organization, and appropriate MP6b SERI management. 18.5.9 Management of the audited organizations shall be responsible for ccrrecting nonconformances identified during an audit. They shall assure that corrective action is scheduled, accomplished as scheduled, and documented. The corrective action shall be designed to prevent the recurrence of significant conditions adverse to quality. (See also Appendix A Regulatory Guide 1.144, Item 11.) 18.5.10 Deficient areas shall be reviewed or reaudited on a timely basis to verify implementation of corrective action. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: AUDITS Page 5 of 6 Policy 18 J250QAM.18 - 5
-__ __ ___=__ -
18.5.11 Audit results shall be analyzed to detect adverse quality trends and to evaluate the effectiveness of the Operational Quality Assurance Program. Results of such analyses which indicate adverse quality trends shall be reported to I
\ appropriate management for review and assessment. , 7D.
18.5.12 Records shall be generated and retained for all audits, i including . individual audit plans, audit reports, written replies, and records of corrective action. (See also
, Appendix A, Regulscory Guide 1.144, Item 13.)
18.5.13 MP6b SERJ interprets the requirements of Technical Specification 6.5.2.8, which requires that audits shall be performed under the cognizance of the SRC, to be met by the following: The SRC shall review the results of audits of nuclear activities conducted in accordance with the MP&L SERI Operational Quality Assurance Manual. Audits shall be
, conducted and results shall 'se reviewed in the areas listed in Technical Specification 6.5.2.8.
x 1 t at b 3 OPERATIONAL QUAtlTY ASSURANCE MANUAL Rev. 6 TITLE: AUDITS ] Page 6 of 6 Policy 18 J250QAM.18 - 6 l q
l w j APPENDIX A ll Conformance of MP&b SERI Operational Quality Assurance _ Program to NRC Regulatory' Guides and ANSI Standards U
- In each offthe ANSI standards, other documents (i.e.-other standards, codes, regulations,' tables, or appendices) required to be included as a part of the standard are either identified at.the point of reference or are described in a l
. special section of the standard., The specific. applicability or acceptability of;these listed standards, codes, regulations or appendices is either covered in other specific areas in the' Operational QA Program. . including appendices, or l
l such documents are not' considered as Quality Assurance Program requirements, although they may be used as guidance. NRC-Regulatory Guide 1.8 " Personnel Qualification and' Training" (2nd Proposed RevisionL2) - Endorses ANSI /ANS 3.1 (Draft 12/79) 1~ The Operational Quality Assurance Program complies with those requirements of Sections.l..0, 2.'0, 3.0, 3.1, 3.2, 3.2.1, 3.2.2, 3.2.3, 3.3, 4.0, 4.1, and 4.4.5
- of ANSI /ANS:3.1'(Draft 12/79) that are applicable to the Quality. Assurance organization (both onsite and offsite) with the following clarifications:
- 1) With regard to the term " Bachelor's Degree" as used in the draft Standard, the following qualifications may be considered equivalent 1
to a Bachelor's Degree: ! 1 Rev. 6 1 of 67 J250QAMAPPENDIX 1 - 1 q i
APPENDIX A- !
- a. 4 years of formal schooling in science or engineering, )
- b. 4 years of applied experience at a nuclear facility in the area j J
for which qualification is sought,
- c. 4 years of operational or technical' experience / training in nuclear power, or d.. any combination of the above totaling.4 years. l
]
i
- 2) With regard to Section 4.4.5 of ANSI /ANS 3.1 (Draft 12/79) titled i Quality Assurance: MP&L SERJ will comply with Paragraph 4.4.5 as originally stated in ANSI /ANS-3.1 - 1978 which reads as follows:
At the time of it.ttial core loading or assignment to the active position, the rea pnsible person shall have six. years experience in the field of quality assuranca, preferably at an operating nuclear plant, or operations supervisory experience.. At least one year of this six years experience shall be nuclear power plant experience in the overall implementation of the quality assurance program. (This experience shall be obtained within the quality assurance organization.) A minimum of one year of this six years experience shall be related technical or academic training. A maximum of four years of this six years experience may be fulfilled by related technical or academic training, i.. The' applicability of this Guide / Standard to other personnel in the MP6L SERJ l .. Organization is addressed other Sections of the FSAR and the Technical l Specifications of-the individual nuclear facility. Rev. 6 i 2 of 67 J250QAMAPPENDIX 1 - 2 1
'i.
APPENDIX A NRC Regulatory Guide 1~.26 ~" Quality Group Classification, and Standards for Water, Steam, and Radioactive Waste Containing Compnnents of Nuclear Power Plants" (Rev. 3, 2/76) l l
)
k The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarification: MP&L SERI may choose not to use'the specific A, B, C and D level classification
. system set forth in this Guide. HP&L SERJ generally followed the requirements of this Guide in' developing the list of structures, systems and components ("Q"
' List) to which the program will apply. The MP&L SERJ "Q" List will describe the items to.which the Operational Quality Assurance Program will apply in lieu of
.the guidance contained in this Regulatory Guide.
l l
. _ _ _ . _ _ _ _ _ . . . _ _ _ _ . . . . . _ _ _ _ _ _ _ _ . . . _==.____...... ___ _..._____....... ___..__
NRC Regulatory Guide 1.28 " Quality Assurance Program Requirements (Design and Construction)" (6/72) - Endorses ANSI N45.2 - 1971. This Guide and the Standard it endorses have been superseded for operations , 1 activities by Regulatory Guide 1.33 and ANSI N18.7 - 1976 which it endorses.
. The Operational Quality Assurance Program complies with i'egulatory Guide 1.33 )
and ANSI-N18.7 - 1976 as stipulated in Appendix A to that Program; therefore, Regulatory Guide 1.28 (Safety Guide 28) and ANSI N45.2 - 1971 which it endorses are not considered necessary and are not included as part of the Program. ! l 1 Rev. 6 ! 3 of 67 J250QAMAPPENDIX 1 - 3
._ - - _ . _-- _ - _2
A"PENDIX'A.
'NRC: Regulatory Guide 1~.29 " Seismic Design Classification" (Rev'. 3, 9/78)
The Operational. Quality Assurance Program complies with the requirements of H 'this Guide with the following clarification: For operations phase maintenance and modification activities which are _ comparable in nature and extent to similar activities conducted during the
. construction phase, MP6L SERI shall'either control these activities under this Operational-QA Program or under an NRC accepted Construction QA Program (per 0QAM 3.5.18). When this Operational QA Program is used, MP&L SERI shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated.with the maintenance or modification shall be the original requirements or better (e.g.,
code requirements, material properties, design margins, manufacturing processes, and inspection requirements). NRC Regulatory Guide 1.30 " Quality Assurance Requirements for the Installation, Inspection, and Testing of. Instrumentation and Electric Equipment"-(8/72) - Endorses ANSI N45.2.4 - 1972. l i i I Rev. 6 4 of 67 J250QAMAPPENDIX 1 - 4' I s _ a i
i APPENDIX A
'The Operational Quality Assurance Program complies with the requirements of ]
this Guide with the following clarifications:
- 1) 'For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, MP&L SERI shall either control these activities under this Operational QA Program or under an NRC accepted Construction QA Program (Per OQAM 3.5.18). . Wh'n e this Operational QA Program is used, MP&L SERJ shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic /adminis-trative requirements included therein (subject to the clarifications l in item 2 below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with maintenance and
. modifications shall be the original requirements or better (e.g.,
l code requirements, material properties, design margins, manufacturing proc' esses', and inspection-requirements).
- 2) Additional clarifications for ANSI N45.2.4 - 1972 are indicated for specific sections below.
l ! Section 1.4 - Definitions in this Standard which are not included in ANSI N45.2.10 N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in MP&L SERJ ; commitment to Regulatory Guide 1.74. l Section 2.1 - Planning requirements, when necessary, will be incor-porated into maintenance and modification procedures. Rev. 6 l 5 of 67 J250QAMAPPENDIX 1 - 5
_ _ = _ - - _ _ _ _ . _ _ _ - - _ _ _ _ _ _ - . - - - _ _ _ _ _ _ _ _ _ _ _ - _ . _ - - _ - ____ _ - _ _ _ - . _ _ - _ - - - _ _ _ _ _ _ _ _ _ - _ _ _ _ -
'i
+ '
APPENDIX A
'Section 2.3 - Procedures and' Instructions will be implemented as set forth in Policies 2, 3, 5,10, and 11 of the Operational QA Program and by compliance with the individual nuclear facility Technical Specifications and ANSI N18.7 as set forth in Appendix A to that Program in lieu of the requirements set forth here.
'Section 2.4 - Results will be implemented as set forth in Policies 10,~11 and 17 of the Operational QA. Program and by compliance with ANSI N18.7 as set forth in Appendix A of that Program in lieu of the
! requirements-set forth here. Section 2.5.2 - Calibration and Control. The third sentence of this section' states in part, "... equipment shall be suitably marked to indicate date of next. required calibration." MP&L SERI will utilize,. a computerized system to indicate the calibration status of installed operations measuring and test equipment in lieu of marking or tagging the individual item. Section 3 - Preconstruction Verification will be implemented as I follows: (1) is re' quired only for modifications (2) will be imple-1 4 mented with the clarification that " approved instruction manuals" shall be interpreted to mean the manuals provided by the supplier as required by the procurement order--these manuals will not be' reviewed and approved, per se, by MP6L SERJ; (3) no special checks will be made by the person withdrawing a replacement part from the warehouse-- equivalent controls are assured by compliance with ANSI N45.2.2 as Rev. 6 6 of 67 J250QAMAPPENDIX 1 - 6
l i APPENDIX A set forth in Appendix A to the Operational QA Program; and, (4) will j i be complied with as stated, by individual technicians as part of the maintenance / modification process. l l Section 4 - Installation will be implemented by inclusion, as necessary, in the appropriate maintenance or modification procedure, I where such procedures are used. Standard HP&L SERI maintenance practices require that care be exercised in the six areas listed whether a procedure is required or not. Section 5.1 - Inspections, including subsections 5.1.1, 5.1.2, and the first sentence in 5.1.3, will be implemented as set forth in Policy 10 of the Operational QA Program. The inspection program will incorporate, as applicable, those items listed in these subsections. The remaining sentence in 5.1.3 is covered in equivalent detail in MP&Lle SEEI's commitment to ANSI N18.7, Section 5.2.6; the requirements as set forth in that commitment will be implemented in lieu of the requirements stated here. Section 5.2 - Tests, including subsections 5.2.1 through 5.2.3, will be implemented as set forth in Policies 3 and 11 of the Operational QA Program. The test program will consider the elements ouclined in this Section, where applicable, when developing test requirements for inclusion in maintenance and modification procedures. In some cases, j l testing requirements may be met by post-installation surveillance l testing in lieu of a special post installation test. l l l Rev. 6 L l l 7 of 67 l J250QAMAPPEND1X 1 - 7 I . _ _ - _ _ _ _ _
APPENDIX A Section 6 - Post-Construction Verification is not generally-l considered applicable at operating facilities.becaur- ci the' scope of the work and the relatively short interval between installation and operation. Where considered applicable, as in modifications, the elements described in this Section will be considered in the development and implementation of inspection and testing programs as described in Policies 3, 10 and 11 of the Operational QA Program. With regard to Section 6.2.1 of ANSI N45.2.4 - 1972 titled Equipment Tests: The last paragraph of this Section deals with tagging and labeling. MP&L SERJ will comply with an alternate last paragraph which reads: "Each safety-related item of process instrumentation is identified with a unique number. This number is utilized in instrument maintenance records so that current calibration status, including data such as the date of the calibration and identity of person that performed the calibration, can be readily determined. Such information may also be contained'on tags or labels which may be attached to installed instrumentation." Section 7 - Data Analysis and Evaluation will be implemented as stated herein after adding the clarifying phrase "Where used" at the beginning of that paragraph. Section 8 - Records will be implemented by conformance with Policy 17 of the Operational QA Program and ANSI N45.2.9 as set'forth in Appendix A to that Program. Rev. 6 8 of 67 J250QAMAPPENDIX 1 - 8 l
APPENDIX A. NRC Regulatory Guide 1.33 " Quality' Assurance Program Requirements (Operation)" (Rev. 2,~2/78) - Endorses ANSI N18.7 - 1976. The Operational Quality Assurance Program complies with the requirements of
'this Guide with the following clarifications:
1). Paragraph C.3 of Regulatory Guide.1.33 (and Section 4.3.4 of ANSI N18.7 which it references) will be implemented as required by the applicable nuclear' facility Technical Specifications which define
" Subjects Requiring Independent Review."
- 2) Paragraph'C.4.a of Regulatory Guide 1.33 (and Section 4.5 of ANSI N18.7 which it references) will be implemented as. required by the applicable nuclear facility Technical Specifications which d fine the L
" Audit Program" to be conducted. The audit program is further defined and will be. implemented as required by the commitment to ANSI N45.2.12 as stated in Appendix A of the'0perational QA Program.
- 3) Paragraph C.S.a of Regulatory Guide 1.33 (and Section 4.4 of ANSI N18.7 which it references) will be implemented with the clarification that the Plant Safety Review Committee shall perform this activity.
- 4) Paragraph C.5.d of Regulatory Guide 1.33.(and Section 5.2.7.1 of ANSI N18.7 which it references) will be implemented by adding the clarifying phrase "Where practical" in front of the fourth sentence of the fifth paragraph. The Regulatory Guides changing of the two uses of the word "should" in this sentence to "shall" unnecessarily i
Rev. 6 9 of 67 J250QAMAPPENDIX 1 - 9
APPENDIX A restricts MP&ble SERI's options on repair or replacement parts. It is not always practical to, test parts pilor to use. For modifications where these requirements are not. considered practical, a review in accordance with the provisions of 10CFR50.59 will be conducted and documented.
- 5) ' Paragraph C.S.e of Regulatory Guide 1.33-(and-Section 5.2.13.4 of ANSI N18.7 which it referenees) will be implemented subject to the same clarifications made.for ANSI N45.2.2 elsewhere in Appendix A to the Operational QA Program.
- 6) Paragraph C.5.f of Regulatory Guide 1.33 (and Section 5.2.19(2) of ANSI N18.7 which it references) will be implemented with the substitution of the word " practical" for the word "possible" in the last sentence.
- 7) Paragraph'C.5.g of Regulatory Guide 1.33 (and Section 5.2.19.1 of ANSI N18.7 which it references) will be implemented with the addition of the modifier normally" after each cf the verbs (should) which the Regulatory Guide converts to "shall." It is MP&ble SERI's intent to fully comply with the requirements of this paragraph, and any conditions which do not fully comply will be documented and approved by management personnel. In these cases, the reason for the exception shall also be documented. The documentation shall be retained'for the same period of time as the affected preoperational test.
Rev. 6 10 of 67 J250QAMAPPENDIX 1 - 10
i APPENDTX A .! 8)- With regard to Section 3.4.2 of' ANSI N18.7 - 1976 titled :l Requirements for the' Onsite Operating Organization: Training standards referenced in this Section will be implemented if such I st'andards are included'in Appendix A to the Operational QA Program or in Technical Specifications or are otherwise part of the license of 1 the individual nuclear' facility. MP&ble SERI's method of documenting i and otherwise meeting the remainder of the requirements of this j
-l Section are set forth'in Policies 1 and 2 of the Operational QA i 1
i Program and in the Technical Specifications of the individual nuclear 1 !- l' facility.
- 9) 'With regard to Section 4.1 of ANSI N18.7 - 1976 titled General The MP&L SERF audit program will be implemented in accordance with and to meet the requirements of: ANSI N45.2.12 as endorsed in Appendix A; Policies 2, 16 and 18 of the Operational QA Program; and the requirements of the individual nuclear facility Technical Specifications.
10).. With regard to Section 4.2 of ANSI N18.7 - 1976 titled Program
Description:
Two aspects are addressed in this Section: audits and independent reviews. The. independent review program is implemented as required by the Technical Specifications of the individual nuclear. facility and by Policies 1 and 2 of the Operational QA Program. The MP&L SERI audit program will be described in accordance with and to meet the requirements of Rev. 6 l
-J250QAMAPPENDIX 1 - 11
- .___-_-__a
h P-f f ANSI N45.2.12 as endorsed in Appendix A of the Ope a QA
- Program, the requirements of the individual nuclear facility Technical Specifications, and Policies 16.and 18 of the Operational QA Program.
- 11) With regard to Section 4.3 of ANSI N18.7 - 1976 titled Indepen/ent Review Process: The requirements of this Section, including all of its subparts, shall be met by compliance with the Technical Specifications' requirements of the individual nuclear facility.
- 12) With regard to Section 4.5 of ANSI N18.7 - 1976 titled Audit Program:
The MP&L SERI audit program will be implemented in accordance with and to meet the requirements of: ANSI N45.2.12 as endorsed in Appendix A; Policies 2, 16, 17 and 18 of the Operational QA Program; and the requirements of the individual nuclear facility Technical Specifications.
- 13) With regard to Section 5.1 of ANSI N18.7 - 1976 titled Program
Description:
The fourth sentence in this Section required a
" summary document"; MP&L SERI has submitted' Appendix C.to the Operational QA Program and interprets this Appendix to fulfill the requirements for a summary document.
- 14) With regard to Section 5.2.2 of ANSI N18.7 - 1976 titled Procedure Adherence: The temporary change requirements of this Section are delineated in the Technical Specifications for activities occurring after the Operating License (OL) is issued; the requirements of the Rev. 6 12 of 67 J250QAMAPPENDIX'l - 12
APPENDIX A Technica1' Specifications shall be used in lieu of the general re-L quirements in this Section to control temporary changes. For tem-porary changes which occur under this. Program during preoperational and.startup testing prior to issuance of an OL, MP&L SERI will comply with this Section with the clarification that another Test Supervisor or Shift' Supervisor or other member of the Plant Staff'(limited to Shift Superintendent, responsible Section Supervisor, Manager Plant Operations, or GGNS General Manager) knowledgeable in the areas affected by the change, may approve changes which require the signer to hold an SRO license. When'there'is a requirement to " implement" or " address" a procedure, actions prescribed by procedures shall be accomplished. This does not necessarily imply that in all cases the operator, engineer, or 1 i technician has a copy of the procedure in-hand and signs-off a l' checklist as each. step or function is performed.
- 15) With regard to Section 5.2.6 of ANSI N18.7 - 1976 titled Equipment Control: MP&L SERI will comply with the " independent verification" re-quirements based on the definition of this phrase as given under our commitment to Regulatory Guide 1.74.
The third sentence of the fourth paragraph requires independent verification "when appropriate." Where significant exposure to radiation, which is determined by the cognizant Health Physics personnel, would result from such verification, they shall advise Operations of current radiological conditions. Operations will then Rev. 6 13 of 67
-J250QAMAPPENDIX 1 - 13
' APPENDIX A
' decide,whether or not the. confidence gained from the independent verification-is worth the' additional radiation exposure. .In all-s cases,. radiation doses will be As Low As Reasonably Achievable (ALARA).
Since MP&L SERJ'sometimes uses descriptive names to designate equipment, the sixth paragraph, second sentence is' replaced with:
" Suitable means include identification numbers or other descriptions which are traceable.to records of the status of inspections and
)$/ tests." J. _ The first sentence in the seventh patagraph will be complied with after clarifying " operating personnel" to mean trained employees assigned to, or under.the control of, MP&L SERI management at an-opareting nuclear facility.
- 16) With regard to Section 5.2.7 of ANSI N18.7 --1976 titled Maintenance and Modification: Since some emergency situations could arise which might preclude preplanning of all activities, MP6L SERJ will comply with an alternate to the first sentence'in the second paragraph which reads:
"Except in emergency or abnormal operating conditions where immediate actions are required to protect the health and safety of the public, to protect equipment or personnel, or to prevent the deterioration of' plant conditions to a possibly unsafe or unstable level, maintenance q 1
or modification of equipment shall be preplanned and performed in accordance with written procedures. Where written procedures would Rev. 6 14 of 67
'J250QAMAPPENDIX 1 - 14 4 i
APPENDIX A be required and are not used, the activities that were accomplished shall be documented after-the-fact and receive the same degree of review as if they had been preplanned." l l l For those system run-in activities that take place prior to issuance i of an Operating License, the Startup Engineer may direct work by i MP6b SERI Operations or Maintenance personnel to restore the system I to design drawing requirements, provided the work and actions are properly documented and that quality and engineering evaluations are obtained. These evaluations may be obtained after-the-fact.
- 17) With regard to Section 5.2.7.1 of ANSI N18.7 - 1976 titled Maintenance Programs: MP&L SERI will comply with the requirements of the first sentence of the fifth paragraph, where practical. This clarification is needed since it is not always possible to promptly determine the cause of the malfunction. In all cases, MP6b SERI will l
initiate proceedings to determine the cause, and will make euch determinations promptly, where practical.
- 18) With regard to Section 5.2.8 of ANSI N18.7 - 1976 titled Surveillance Testing and Inspection Schedule: In lieu of a " master surveillance schedule," the following requirement shall be complied with: "A surveillance testing schedule (s) shall be established reflecting the status of all in-plant surveillance tests and inspections."
i Rev. 6 15 of 67 J250QAMAPPENDIX 1 - 15
APPEEDTX A
~19) With regard t'o Section 5.2.9 of ANSI N18.7.- 1976 titled Plant Security and Visitor Control: The requirements of the individual-nuclear facility Security Plan shall be implemented in lieu of these
. general requirements.
- 20) With regard to Section 5.2.10 of ANSI N18.7 - 1976 titled Housekeeping and Cleanliness Control: The requirements of this Section, beginning with the last sentence of the first paragraph and continuing through the end of the Section, will be implemented as described in MP&Me SERI's commitments to ANSI N45.2.3 and N45.2.1 as set forth in Appendix A to the Operational QA Program.
- 21) -With regard to Section 5.2.13.1 of ANSI N18.7 - 1976 titled Procurement Document Control: The words "the same" in the last sentence are replaced with the words "an equivalent."
- 22) With regard to Section 5.2.15 of ANSI N18.7-1976 titled Review, Approval and Control of Procedurest The third sentence in Paragraph three is interpreted to mean: Applicable procedures shall be re-viewed following an accident, an unexpected transient, significant operator error, or equipment malfunction which results in a report-able occurrence. The first sentence in Paragraph four is interpreted to mean: 'Routinety used or Administrative type procedures uitt be reviewed no tees frequently than every tuo years, but proceduree l uhich are only used infrequently, i.e., every three to five years, vill be reviewed prior to use.
I ) y Rev. 6 16 of 67 ] J250QAMAPPENDIX 1 - 16
- __ __ __ A
~
APPENDIX A. l
- 23) With regard to Section 5.2.17 of ANSI N18.7-1976 titled Inspections:
, Not all inspections will require generation of a separate inspection L
i report.' Inspection requirements may be integrated into appropriate
~
L procedures or other documents with the procedure or document serving as the record. However, records of inspections will be identifiable and retrievable. p l
- 24) With regard to Section 5.3.9 of ANSI N18.7 - 1976 titled Emergency Procedures: As directed by the NRC, MP6L SERI will follow a format
-for emergency procedures which is " symptom" based as opposed to
" event" based as stipulated in Section 5.3.9.1. Since MP&b SERJ will have these " symptom" based procedures,'" event" based procedures will not normally be provided.
- 25) With regard to Section 5.3.9.2 of ANSI N18.7 - 1976 titled Events of Potential Emergency: NRC review of the FSAR has identified all natural occurrences which affect the nuclear facility. Therefore, HP6b SERI will interpret item (11) to mean the natural occurrences which have been evaluated in the FSAR for the individual nuclear facility.
- 26) With regard to Section 5.3.9.3 of ANSI N18.7 ~1976 titled Procedures for Implementing Emergency Plan: MP&Lis SERI's NRC accepted Emergency Plan for each nuclear facility will be implemented in lieu of the re-
.quirements in this Section.
Rev. 6 17 of 67
-J250QAMAPPENDIX 1 - 17
_-________________-__-_a
APPENDIX'A L 27) With Regard to,Section 5.2.18 of ANSI N18.7 - 1976 titled Control of Special-Processes: The last four words of the first sentence are clarifie'd by inserting the word " approved" before the word
" procedure": We shall use qualified personnel and approved procedures.
28)L With regard to_Section 5.2.7 of ANSI N18.7 - 1976 titled Maintenance and Modification: The first sentence of the first. paragraph could be interpreted to require the same degree of inspection for all main-tenance-activities as was provided during construction. When viewed in conjunction with Section 5.2.17, the third paragraph, we believe-the actual intent is clear. 'We shall'prov'ide inspections comparable
'in nature andLextent to that provided during construction if the
. maintenance / modification work is comparable in nature and extent.
l '
- 29) With1 regard to Section 5.3.5(4) of ANSI N18.7 -1976 titled Supporting Maintenance Documents: MP6b SERI may choose to include material from vendor manuals in any-of three ways. (1) The applicable section of the manual may be duplicated, referenced in, and attached'to the procedure. .(2) The procedure may simply state >
that the manual or a specific section-is to be followed for- i performing a particular function; the manual must then be used in conjunction with the procedure for performing the activity. (3) The
- pertinent material from the manual, either as originally written or as modified by the author / reviewers of the procedure, may be written into and become a part of the procedure.
Rev. 6 18 of 67
'J250QAMAPPENDIX 1 - 18
.l I ~~
APPEND 1X A-In optionsL(1) and (3).above, the material meets the requirement to I receive "the same level of review and' approval,as operating ! L- procedures" since the material is reviewed'as part of the procedure review process. In option (2), the requirements shall be deemed to e i have been fulfilled by requiring a copy of the pertinent manual-l (manual sections) to be available to and considered by persons conducting the review'of the procedure. ] l q l
- 30) With regard to Section 5.2.16 of ANSI N18.7 .1976 titled Measuring.
andLTest Equipment: The second sentence of the third paragraph states " Records shall be made and equipment suitably marked.to indicate calibration status." MP&b SERI will utilize a computerized system to indicate the calibration status of installed operations measuring and test equipment in' lieu of marking or tagging:the individual item. l-
........-- .. _= ....-- ..................---- _-- ........--......-- ...-------
NRC Regulatory Guide 1.37 " Quality Assurance Requirements for Cleaning of Fluid ~ Systems _and Associated Components of Water-Cooled Nuclear. Power Plants" (3/73) Endorses ANSI N45.2.1 - 1973. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications: l Rev. 6 19 of 67 J250QAMAPPENDIX 1 - 19
U APPENDIX A 1)'~-With' regard to Paragraph C.3 of Regulatory Guide 1.37: The water quality for. final flushing of fluid systems and associated components shall be at least equivalent to the quality.of the operating system - water except for the oxygen. and: nitrogen content, but this does' not
' infer that chromates or other additives, normally in the system water,-will be added to the flush' water.
.2) With regard to Paragraph C.4 of Regulatory Guide 1.37: Expendable materials, such as inks and related products, temperature indicating.
sticks, tapes, gummed labels, wrapping materials (other than poly - ethelene), water soluble dam materials, lubricants,'NDT penetrant materials and couplants, which contact. stainless steel or nickel alloy surfaces shall not contain lead,-zinc, copper, mercury, cadmium-and other low melting point metals, their alloys or compounds, as basic and essential chemical constituents. Prescribed maximum levels of water leachable chlorides, total halogens, and sulphur and its compounds shall be imposed on expendable products.
- 3) With regard to'Section 5 of ANSI N45.2.1 - 1973 titled Installation Cleaning: The recommendation that local rusting on corrosion resistant alloys be removed by mechanical methods is interpreted to. 1 mean that local rusting may be removed' mechanically, but the use of other removal means is not precluded.
- 4) For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted i
during the construction phase, MP&E SERI shall either control these
)
activities under this Operational QA Program or under an NRC accepted Rev. 6 20 of 67 J250QAMAPPENDIX 1 - 20
s APPENDIX A
. Construction QA Program (Per 0QAM 3.5.18). When this Operational QA' u
Program is used, MP&b SERI shall. comply with the-Regulatory Position
-established in this Regulatory Guide in that QA programmatic /;
administrative requirements included-therein (Subject.to the stated clarifications) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with the maintenance or-modification shall be'the original requirements or better (e.g., code requirements,. material properties, design margins, manufacturing processes, and inspection requirements). l 5)' With regard to Section 1.4 of ANSI N45.2.1 - 1973 titled Definitions: Definitions in this Standard which are not' included in ANSI N45.2.10 shall be used; all; definitions which are included in ANSI N45.2.10 shall be used as clarified in MP&ble SERI's commitment to Regulatory Guide 1.74.
- 6) With regard to Section 9 of ANSI N45.2.1 - 1973 titled Records: -MP&b SERI shall maintain records in accordance with and to meet the I-requirements of Policy 7 of the OQAM and ANSI N45.2.9 as specified in Appendix A.
- 7) Throughout this Standard, references are made to cleanness associated with initial installation. When this Standard is used for oper-ations, qualified supervisory maintenance personnel determine what f items within a particular cleanness level are appropriate. As an example, the Reactor Internals are initially classified as Level B.
Section 3.1.2 requires this cleanness level to have " metal clean" Rev. 6 21 of 67 J250QAMAPPENDIX 1 - 21
APPENDIX A surfaces and either a visual inspection or dry white-cloth wipe. After use.in the reactor coolant system, MP&b SERJ does not intend to clean a component until it has a bright " metal clean" surface, nor do we (from.an ALARA and accessibility considerations) intend to perform a dry white-cloth wipe. Components which have been removed from plant systems of established cleanliness levels may be considered to be of the same cleanliness as the system from which they were removed. Such components need not be reeleaned prior to reinstallation provided that measures are taken to - Prevent degradation of the'previously existing state of' cleanliness.
\
NRC Regulatory Guide 1.38 -." Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" (Rev. 2, 5/77) - Endorses ANSI N45.2.2 - 1972. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) With regard to Section 1.4 of ANSI N45.2.2 - 1972 titled Definitions:
Definitions in this Standard which are not included in ANSI N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 , will be used as clarified in MP& bis SERI's commitment to Regulatory Guide 1.74. Rev. 6 22 of 67 J250QAMAPPENDIX 1 - 22
APPENDIX A
- 2) With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Planning:
(first sentence) The specific items to be governed by the Standard shall be identified on the Q-List. However, the Standard (as modified by the clarifications in Appendix A) is part of the Operational QA Program and will, therefore, be applied to those structures, systems, and components which are included in that Program.
- 3) With regard to Section 2.3 of ANSI N45.2.2 - 1972 titled Results:
The specific methods for performing and documenting tests and inspections are given in Policies 10 and 11 of the Operational QA Program. The requirements in these Policies will be implemented in lieu of the general requirements here.
- 4) With regard to Section 2.4 of ANSI N45.2.2 - 1972 titled Personnel Qualifications: Specific requirements for personnel qualifications and training are set forth in Policy 2 and in the commitments to training standards in Appendix A of the Operational QA Program. These requirements will be implemented in lieu of the general requirements stated in this Section.
- 5) With regard to Section 2.7 of ANSI N45.2.2 - 1972 titled Classification of Items: MP6b SERI may choose not to explicitly use the four level classification system. However, the specific require-ments of the Standard that are appropriate to each class will generally be applied to the items suggested in each classification and to similar items. ,
Rev. 6 23 of 67 J250QAMAPPENDIX 1 - 23
4 ' i\ APPENDIX A 6)' With' regard'to;Section 3.2;1 of ANSI N45.2.2 --1972 titled Level A Items: As an alternate.to the requirements for packaging and containerizing items in storage to control contaminants.(Items (4) . t and (5)), MP&L SERI may' choose a storage atmosphere which is free of
- harmful contaminants in concentrations that could produce damage to.
stored items. Similarly (for Item (7)) MP&b SERI may obviate the need for, caps and plugs with an appropriate' storage atmosphere, and may choose to protect weld end preparations and threads by controlling the manner in which the items are stored. These'clarifi-cations apply whenever items (4), (5) or (7) are subsequently referenced and to Section 3.5.1 titled Caps'and Plugs and Section 3.4 titled Methods of Preservation.
- 7) With regard to Section 3.3 of ANSI N45.2.2 - 1972 titled Cleaning:
I~ (Third sentence) MP&b SERI interprets." documented. cleaning methods" to allow generic cleaning procedures to be written.which are implemented, as necessary, by trained personnel. Each particular cleaning operation any not have an individual cleaning procedure, but the generic procedures will specify which methods of cleaning or which type (s) of solvent may be used in a particular application.
- 8) With regard'to Section 3.4 of ANSI N45.2.2 - 1972 titled Methods of Preservation: (First sentence) MP&b SERI will comply with these requirements subject to the clarifications of Section'3.2.1 (4) and (5) above, and the definition of the phrase " deleterious corrosion" to mean that corrosion which cannot be subsequently removed and which adversely affects form, fit, or function.
Rev. 6 24 of 67 J250QAMAPPENDIX 1.- 24
_7 . _ _ - - - - _ - _ _ _ , , - - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ s APPENDIX A i) 9 With~regardit o'Section 3.6 of ANSI N45.2.2 - 1972 titled Barrier and y. Wrap Material and Dessicants:- This section requires the use of f nonhalogenated materials'in contact with austenitic stainless steel. Refer to RegulatoryfGuide 1.37 above for the MP&L SERI position.- I L !
- 10) With regard to Section 3.7.1 of ANSI N45.2.2-1972' titled Containers:
Cleated, sheathed boxes may be used up to 1000 lbs. rather than 500 lbs. as specifted in 3.7.1(1). This type of box is safe for, and has
~ been tested for, loads up to-1000 lbs. Other national standards allow this-(see Federal Specification PPP-B-601). Special qualification testing may.be required for loads above 1000 lbs.
11). With regard to Section 3.7.2 of ANSI N45.2.2 - 1972 titled Crates'and Skids: Crates or skids will be used on equipment with a gross weight of 500 lbs. or more. Skids or runners will normally be fabricated
-from 2 X 4 inch nominal lumber size, minimum, and laid flat except where this is impractical because of the small dimensions of the container. If forklift handling is required, minimum floor clearance for forklift tines will be provided.
i
- 12) Uith regard to Section 4.2.2 of ANSI N45.2.2. - 1972 titled closed I
Carriers: The use of fully enclosed furniture vans, as recommended ; i in (2), of this Section is not considered a requirement. MP&b SERI will assure adequate protection from weather or other environmental conditions.by a combination of vehicle enclosure and item packaging. 1 1 I Rev. 6 25 of 67 J250QAMAPPENDIX 1 - 25
i; , i .y p l; ' h<V APPENDIX A
- 13) Withf reg'ard to Sections'4.3,'4.4 and 4.5 of ANSI N45.2.2-1972 titled, j/g g '
respectively, Precautions During, Loading and Transit, Identification cand Marking, and Shipment from' Countries Outside the United States: p MP6b SERI will comply with the requirements of these'$ections subject to the clarifications'taken to other Sections which are referenced y ;c L therein. l: l
- 14) With regard to Section 5.2.1 of ANSI N45.2.2 - 1972- titled Shipping Damage Inspection: Warehouse personnel will ncrmally V, visually scrutinize incoming shipments for damage of the types listed s a in-this'Secidan,this'activityisnotnecessarilyperfornedpriorto unloading. Since all required items receive the Item Inspection of Sectior) 5.2.2, separate documentation of the Shipping Damage Inspection is not necessary. Release of the. transport agent after unloading and the signing for receipt of the shipment may be all of the action taken to document completion of the Shipping Damage Inspection. Any nonconformances noted will be documented and dispositioned as required by Policy 15 of the Operational QA Program.
The' person performing the visual scrutiny during unloading is not considered to be performing an 1nspection function as defined under Regulatory Guide 1.74; therefore3 while he vill be trained to perform this function, he may not be certified (N45.2.6) as an Inspector.
- 15) With regard to Section 5.2.2 of ANSI N45.2.2 - 1972 titled Item Inspection: The-second division of this subsection requires six additional inspection activities if an item was not inspected or examined at the source. MP&b SERI will consider that a source inspection has been conducted if the supplier of the item is required l Rev. 6
' (
26 of 67
'J250QAMAPPENDIX 1 - 26
i APPENDIX A to comply with ANSI N45.2.2 for the purchased item and if the supplier's program has been audited and found acceptable in the area (i.e. the supplier performs a source inspection of his supplier or conducts a receipt inspection that includes, as applicable, the six , I additional items listed). i I
'16) With regard to Section 6.1.2 of ANSI N45.2.2 - 1972 titled Levels of Storage: Subpart (2) is replaced with the following:
(2) Level B items shall be stored within a fire resistant, weathertight, and well ventilated building or equivalent enclosure. This building shall be situated and constructed l so that it will.not normally be subject to flooding; the floor shall be paved or equal, and well drained. If any outside waters should come in contact with stored equipment, such equipment will be labeled or tagged nonconforming, and then the nonconformance document will be processed and evaluated in accordance with Policy 15. Items shall be placed on pallets or shoring or shelves to permit air circulation. The building shall be provided with heating and temperature control or their equivalent to reduce condensation and corrosion. Minimum temperature shall be 40F and maximum temperature shall be 140F or less if so stipulated by a manufacturer. Rev. 6 27 of 67 J250QAMAPPENDIX 1 - 27 L ___ _ _ _ - - - - - - - _ _ _ _ - _ - - - - -
/
APPENDIX A
- 17) With regard to Section 6.2.1 of ANSI N45.2.2 - 1972 titled m
Access'to Storage Areas: Items which fell within the Level D classification of the standard will be stored in an area which may be posted to limit access, but other positive controls such as fencing or guards will not normally be provided.
- 18) With regard to Section 6.2.4 of ANSI N45.2.2 - 1972 titled g t- Storage of Food and Associated' Items: Tha sent'ence is replaced with 3
the folJcuing: "The use or storage of food, drinks, and salt tablet dispensers in any storage' area shall be controlled and shall be limited to designated areas where such use or storage is not i ' deleterious to stored items." .
\
'l A,
, 4
- 19) With regard to Section 6.2.5 of ANSI N45.2.2 - 1972 titled e
Measures to Prevent Entrance of Animals: The sentence is replaced with the following: " Warehouse personnel shall be alert to detect evidence of rodents or small animals in indoor storage areas. If any such evidence is detected, a survey or inspection will be utilized to determine the extent of the damage; exterminators or other appropriate measures shall be used to control these animals to minimize possible contamination tod mechanical damage to stored material." s*
- 20) With regard to Section 6.3.3 of ANSI N45.2.2 - 1972 titled Storage of Hazardous Meterial: The sentence is replaced with the following:
Hazardous chemicsis, paints, solvents, and other materials of a like Rev. 6
, 28 of 67 ;
3250QAMAPPENDIX 1 - 28 . l _ _ _ _m_ _ _ . _ _
x
; c.
' APPENDIX A nature shall be stored in approved cabinets or containers which are' x::' ~'
inot in close proximity'to installed systems required for safe
?"
shutdown."
-21) With regard to Section 6.4.2 of ANSI N45.2.2 - 1972 titled Lfh Care of Items: The following alternates are provided.for indicated subpart:
'(5) " Space heaters in electrical equipment'shall be energized unless
~
- a. documented engineering evaluation determines that such~ space-heaters'are not. required."
((6) "Large (greater than or. equal'to 50 HP) rotating ilectrical'
~
equipment sha11 be given insulation resistance tests cn a
~
scheduled basis unless a documented engineering evaluation determines that such tests'are not required." I (7)'~" Prior to being placed in storage, rotating' equipment weighing over approximately 50 pounds shall be evaluated by engineering personnel to determine if shaft rotation in storage is required; the results of the evaluation shall be documented. If rotation is required, it shall be performed at specified intervals, be documented, and be conducted so that parts receive a coating of lubrication where applicable and so that the shaft does not come to rest in the same position occupied prior to rotation. For l i 'long shafts or heavy equipment subject to undesirable bowing, l: i, shaft orientation after rotation shall be specified and 1 obtained." Rev. 6 L. , _ 29 of 67
- J250QAMAPPE!OIX 1 - 29
l i APPENDIX A l 22): With regard to Section 6.5 of ANSI N45.2.2 - 1972 titled R:moval of Items from Storage: MP&b SERJ does not consider the last sentence { of this Section to be applicable to the Operations Phase due to the relatively short period of time between installation and use. The first centence of the Section is replaced with: "MP&b SERI will ] develop, issue, and implement a procedure (s) which cover (s) the removal of items from storage. The procedure (s) will assure that the status of all mater 2a1 issued is known, controlled, and appropriately dispositioned."
- 23) With regard to Section 6.6 of ANSI N45.2.2 - 1972 titled Storage Records: MP&L SERJ will comply with the requirements of this Section with che clarification that, for record purposes, only the access of personnel without Key Cards into indoor storage areas shall be recorded. Unloading or pick-up of material shall not be considered
" access," nor shall inspection by NRC or other regulatory agents, nor shall tours by non-MP&b SERI employees who are accompanied by MP&b SERJ employees.
- 24) With regard to Section 7.3 of ANSI N45.2.2 - 1972 titled Hoisting Equipment: Re-rating of hoisting equipment will be considered only when absolutely necessary. Prior to performing any lift above the ,
load rating, the equipment manufacturer must be contacted for his approval and direction. The manufacturer must be requested to supply i a document granting approval for a limited number of lifts at the new 1 rating and any restrictions involved, such as modifications to be j i Rev. 6 30 of 67 l J250QAMAPPENDIX 1 - 30 j
1 . APPENDIX A l J
'mada to'the equipment, the number of lifts to be made at the new m
rating, and the test lift load. At'all times, the codes governing 3 re-rating of hoisting equipment must be observed. l 1 I 1 i NRC Regulat'ory Guide 1.39' " Housekeeping Requirements for Water-Cooled Nuclear Power Plants" (Rev. 2, 9/77) - Endorses ANSI N45.2.3 - 1973. The Operational Quality Assurance ~ Program complies with the requirements of r this Guide with the following clarification:
- 1) For operations, phase maintenance and modification activities which are comparable in nature.and extent to similar activities conducted during the construction phase, MP&L SERI shall either control these activities under this Operational QA Program or under an NPC accepted Construction QA Program (Per OQAM 3.5.18).
'When this Operational QA Program is used. MP&b SERI shall comply'with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (Subject to the clarifications in item 2 below) shall apply to these maintenance and 1
modification activities even though such requirements may not have been in effect originally. Technical requirements associated with the maintenance or
. modification shall be the original requirements or better (e.g., code requirements, material properties, design margins, manufacturing processes, and-inspection requirements).
I Rev. 6 i 31 of 67
'J250QAMAPPENDIX 1 - 31 i
) 4
~
. APPENDIX A' , 1 2)' Specific clarifications for ANSI N45.2.3 :1973 are indicated for l
- specific Sections below.
l Section"1.4 - Definitions: Definitions in this Standard which are.not 1 l included in ANSI.N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in MP& Lie SE'RT's q commitment to Regulatory Guide 1.74. Section-2.1 - Planning: MP&L SERJ may choose not to utilize the five-level zone designation system, but will utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with Company policy in the areas of housekeeping, plant and personnel safety, and fire protection. Cleanliness will be maintained, consistent with the work being performed, so as to prevent the entry of foreign material into safety-related systems. This will include, as a minimum, documented l-cleanliness inspections which will be performed prior to system closure. As necessary, (e.g., the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies will be established when major portions of the reactor system are opened for inspection, ma tenance or repair. Additional housekeeping requirements will be implemented as required for contiol of radioactive contamination.
'Section 2.2 - Procedures and Instructions: Appropriate procedures will be written and implemented.
Rev. 6 32 of 67 J2500AMAPPEND1X 1 - 32 3 l
?: r i
~ .i' APPENDIX A Section 3.1 - Control of Site Area: Not applicable.to the Operations
-i . phase.-
l l Section 3.2 - Control of Facilities: MP&L SERI may choose not to utilize the five-level zone designation system,'but'will utilize-standard janitorial and work practices to maintain a level of j cleanliness commensurate with Company policy in the areas of .) housekeeping, plant and personnel safety, and fire protection.. Cleanliness will be maintained, consistent.with the work being performed, iso.as to prevent the entry of. foreign material into safety-related' systems. This will include,.as a minimum, documented cleanliness inspections which will be performed prior to system closure. As necessary,1(e.g., the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies will-be~ established when major' portions of the reactor system are opened for inspection, maintenance or repair.. Additional' housekeeping requirements will be implemented as required for control of radioactive contamination. Section 3.3 - Materials and Equipment: The first paragraph in this Section is not applicable to the Operations phase.
'Section 3.4 - Construction Tools, Supplies, and Equipment: Not applicable to the Operations phase.
Rev. 6 i 33 of 67 ! J250QAMAPPENDIX 1 - 33 l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .)
i D !jE I jv APPENDIX A l- Section13.5 - Surveillance, Inspection, and Examination: Subparagraph 9- (1) is not applicable to the Operations phase; (2), (3) and (4).will h . be. ' implemented.- , ,\ Section 4 - Records: The requirements of Policy 17 and ANSI.N45.2.9-as set forth in Appendix A of the Operational QA Program shall be implemented in lieu of.the requirements of this Section. Section 3.2.3 - Fire Protection and Prevention: The accepted' Fire . t ' Protection Plan shall be used in lieu of.the general requirements in-this section. NRC Regulatory cuide 1.-58 " Qualifications of Nuclear Power Plant' Inspection, Examination, and Testing Personnel" (Rev..l. 9/80) - Endorses ANSI N45.2.6 - i 1978. !
.The Operational Quality. Assurance Program complies with the requirements of
~
'this Guide with the following clarifications:
- 1) MP&b SERI may choose not to apply the requirements of this Guide to those personnel who are involved in day-to-day operations, surveil-lance, maintenance and certain technical and support services whose ;
)
qualifications are controlled by Technical Specifications or other l i Operational QA Program commitment requirements. l t Rev. 6 34 of 67 J250QAMAPPENDIX 1 - 34
e
. APPENDIX A-With regard to Section.1.2'of ANSI N45.2.6 - 1978 titled
~
[2) Applicability:-The' third paragraph requires that the' Standard be used in; conjunction with ANSI N45.2; MP&b SERJ no longer specifically commits-to ANSI N45.2'in the Operational QA Program.- The' fourth
-paragraph requires-that the Standard be imposed'on. personnel other than MP6b SERJ employees, the. applicability.of the Standard to suppliers'will.be' documented and applied, as appropriate, in the procurement documents.for such suppliers.
l .3) 'With regard to Section 1.4 of ANSI N45.2.6 - 1978 titled Definitions: Definitions in-this Standard which are not included in ANSI N45.2.10 will be'used; all-definitions which are-included in ANSI N45.2.10 will be used as clarified in MP&Lis SERJ's commitment to Regulatory Guide 1.74. 4)! 'With regard to'Section 2.5 of ANSI N45.2.6 - 1978 titled Physical: MP6b SERI will implement the requirements of'this Section with the
. stipulation that. where no special physical-characteristics are required,'none will be specified. The converse is-also true: If no special physical. requirements are stipulated by MP&b SERJ, none are considered necessary.
'5) With regard to Section 3.5 of ANSI N45.2.6 - 1978 titled Education and Experience - Recommendations: MP6b SERJ reserves the right to
> use personnel who do not meet all the educational and experience re-quirements of this Section provided: The use of personnel who do not mee:: these requirements shall be the exception rather than the rule and each such case shall receive a documented management evaluation Rev. 6 35 of 67 J250QAMAPPEND1X 1 - 35 e _ _ - _ _ _ _ - _ _ _
APPENDIX A and justification for the exception. An example of a docum:nted management evaluation and justification would be one which includes objective criteria (examination,-review of actual work performed) to demonstrate that equivalent competence is possessed by such an individual. NRC Regulatory Guide 1.64 " Quality Assurance Requirements for the Design of Nuclear Power Planta." (Rev. 2, 6/76) - Endorses ANSI N45.2.11 - 1974. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted i during the construction phase MP6b SERI shall either control these activities under this Operational QA Program or under an NRC accepted Construction QA Program (Per 0QAM 3.5.18). When this Operational QA Program is used, MP6b SERI shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic /
administrative requirements included therein (subject to the clarifications listed below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with maintenance and modifications shall be the original requirements or f I better (e.g., code requirements, material properties, design margins, ] 1 manufacturing processes and inspection requirements). ! l Rev. 6 36 of 67 J250QAMAPPENDIX 1 - 36
APPENDIX A-
- 2)'- With:rsgardLto Paragraph'C.2(1) of Regulatory Guide 1.64::.If in an exceptional circumstance the designer's immediate Supervisor'is the only technically qualified-individual available, this review can be conducted by the Supervisor, providing that: (a) the other pro-visions of-the Regulatory Guide are satisfied, and (b) the justific-ation is individually documented and approved in. advance by the j Supervisor's management, and-(c) qualityEassurance audits cover frequency and effectiveness of use of Supervisors as. design verifiers- -
to guard against abuse.
- 3) With regard to'Section 1.4 of ANSI N45.2.11 - 1974 titled Definitions: Definitions in this Standard which are not included in ANSI N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in MP&Lis SERJ's comm1tment to Regulatory Guide 1.74.
4)' -With regard to Sections.2.1 (last paragraph), 2.2 (Items 12 and 13), Section 9, and Section 11 (including subsections 11.1 through 11.7) _of ANSI N45.2,11_- 1974: The MP6b SERI' Audit Program will be implemented in accordanca with and to meet the. requirements of: ANSI N45.2.12 as endorsed in Appendix A; Policies 2, 3, 16 and 18 of the Operational QA Program, and the requirements of the individual nuclear facility Technical Specifications in lieu of the audit requirements. stated in the referenced sections.
- 5) With regard to Section 5.2.4 of ANSI N45.2.11 - 1974 titled Documentation: For the documentation of interdisciplinary design reviews, there must be documented evidence of the acceptability of Rev 6 37 of 67 J250QAMAPPENDIX 1.- 37 {
._ _ _ - . - ___ _ - _ _ a
APPENDIX A design documsnts orLportions thereof, prior to release.(material, stress, physics, mechanical, electrical, concrete, etc.). The
' signature or initials of those who determine the acceptability of the design. relative.to their respective disciplinary area of concern
.i should be on the document or on a separate form traceable to the !
' document. A document that indicates the reviewer's comments need not be retained. I
- 6) MP&b SERI does not require the SAR to be a design document. However,
..if'the SAR.contains any design or design input that has not been previously documented, reviewed and approved in accordance.with the requirements contained in the 0QAM or another approved design control QA program and if the SAR is used as a design document during the design process, that specific information must be controlled and verified in accordance with the commitments here and Policy 3 of the 0QAM. I e
- 7) 'With regar'd to Section 6.1 of ANSI N45.2.11 - 1974 titled General:
The third paragraph in this Section stipulates certain requirements I relative'to "the results of design verification." MP&b SERI may comply with these requirements by having the Reviewer (s) sign and I date.an appropriate document providing the following cond1tions are l I also met: l a) Documented engineering / design procedures are established which-cover the-extent of design review. Rev. 6 t. 38 of 67
'J250QAMAPPENDIX'1 - 38
APPENDIX A b) The procedures idantify the duties of the Reviewar and the extent of thic responsibility for which he attests with his signature. c) The procedures specify the extent of documentation necessary for the type of design verification applicable to the complexity of the design. d) The signature and date is affixed in accordance with the procedures.- l 1 HP6b SERI shall also permit initials to be used in lieu of the signature ! required above IF a file is maintained to correlate characteristic initials versus individuals such that each set of characteristic initials can be traced to an individual. This correlation must be readily available to NRC inspector whenever the document is being use'd.
- 8) The timing of design verification is not mentioned in the Standard, i
MP6b SERI shall perform verification in a timely manner. If other than by qualifications testing of a prototype or lead production unit, veri-fication should be completed prior to release for procurement, manufacturing or construction or release to another organization for 1 use in other design activities. In those cat s where this timing cannot be met, the design verification may be deferred, providing
~
that the justification for this action is documented and the un-l verified portion of the design output document and all design output i documents, based on the unverified data, are appropriately identified and controlled. Site activities associated with a design or design Rev. 6 39 of 67 J250QAMAPPENDIX 1 - 39
APPENDIX A changa shall not proceed without verification past the point where the installation would become irreversible without extensive de-molition and rework. In all cases, the design verification shall be completed prior to relying upon the component, system, or structure , to perform its safety-related function.
- 9) With regard to Section 10 of ANSI N45.2.11 - 1974 titled Records:
MP6b SERI shall maintain records in accordance with and to meet the requirements of Policy 17.0 of the 0QAM and ANSI N45.2.9 as specified in Appendix A. The additional requirements of the first sentence of the second paragraph in this Section shall also be met.
--------------------=_ =------------------ .-----------------------
NRC Regulatory Guide 1.74 " Quality Assurance Terms and Definitions" (2/74) - Endorses ANSI N45.2.10 - 1973. Tne Operational Quality Assurance Program complies with the requirements of 4 this Guide with the following clarifications: j i
- 1) MP6h SERI reserves the right to define additional words or phrases which are not included in this Standard. Such additional definitions will be documented in appropriate procedures and/or in attachments /
appendices to the Quality Assurance Procedures Manual, or in Policies of the Operational QA Program. See Policy 2, Paragraph 2.5.8.
- 2) In addition to the Standard's definition of " Inspection," MP6h SERI will use the following: " Inspection (When used to refer to activi-ties that are NOT performed by quality organization personnel) -
Rev. 6 40 of 67 ) J250QAMAPPENDIX 1 - 40 l l l \ _ _ _ _ _ _ _ _ _ _ _ - 1
Y APPENDIX A Examining, viewing closely, scrutinizing, looking over or otherwise
- checkin'g activities. Personnel performing these functions are~not
.- necessarily certified to ANSI N45.2.6." I When'MP6b SERJ intends fo'r Inspections to be performed in accordance with the Operational QA Program by personnel certified as required by that Program and for activities defined by " Inspection"'in ANSI N45.2.10,. appropriate references to the quality assurance organization which will perform the activity or to Quality Assurance Procedures to be used for performing the activity will be made.- If such references are NOT made, inspections are to be considered under the additional definition given above. Inspections to meet the intent of 10CFR50 Appendix B are described in Policy 10 of the 0QAM.
- 3) In addition to the Standard's definition of " procurement documents,"
' HP6b SERJ will utilize the definitions given in ANSI N95.2.13 and in z Regulatory Guide 1.74. The compound definition is given as follows:
" Procurement documents - Contractually binding documents that identify and define the requirements which items or services must meet in order to be considered acceptable by the purchaser. They include documents which authorize the seller to perform services or supply equipment, material or facilities on behalf of the purchaser (e.g. contracts, letters of intent, work orders, purchase orders, or proposals and their acceptance, drawings, specifications, or instructions which define' requirements for purchase)."
Rev. 6 41 of 67 J250QAMAPPENDIX 1 - 41
I v 3 k p -- a
' APPENDIX A
- 4) " Program Defic'iencies"'(Not' defined in ANSI.N45.2.10, but used and.
defined d'ifferently in ANSI N45.2'12) - Failure to develop, document' or implement. effectively any applicable element of the Operational QA Program. 5). " Quality Assurance Program Requirements" (Not defined in ANSI
- -- F45.2.10 but.used and' defined differently in ANSI N45.2.13)'- Those
' individual _ requirements of the Operational QA Program which, when p invoked in total or in part, establish the requirements of'the quality assurance program for the activity being controlled.
Although not specifically used in'the Operational QA Program, ANSI N45.2 may be imposed - upon MP&L-s SERJ's suppliers.
- 6) This section deleted in Revision 4.
- 7) " Independent Verification" - Verification by an individual ~other than the person who performed the. operation or activity being verified that required actions have been completed. Such verification will not
.,e require confirmation of the identical action when otherLindications provide assurance or indication that the prescribed activity is in fact complete. Examples include, but are not limited to: verification of a breaker opening by observing remote breaker indication lights; verification of a set point (made.with a voltmeter or ammeter for
- example) by observing the actuation of status or indicating lights at the required panel-meter indicated value, verification that a valve i
has been positioned by observing the starting or stopping of flow on meter indications or by remote value positions indicating lights. Rev. 6 1 42 of 67 J250QAMAPPENDIX 1 - 42
I APPENDIX'A 8). "NRC accepted. Construction QA Program" -- (1) a program for design or construction which was reviewed by the QA' organization'of'the NRC and accepted for'use;;(2) the revision'of that NRC accepted program which' is in effect at the time that MP&b SERJ authorizes commencement of
~
- work; and-(3) a' program which'the MP&b SERJ Quality Assurance-organization reviews-and concurs that the QA Program controls are acceptable for the activity to be. performed. (
Reference:
OQAM 3.5.18)'
- 9) ' "S'pecial Processes" - Processes which are controlled and' monitored in accordance'with approved procedures where required quality levels cannot be assured by inspection of the processed articles alone, or where.it is more effective to control the process than inspect the completed article.
- 10) " Permanent Plant Device" (when used with respect to instrumentation)
.A' device, permanently installed, which functions as a part of a system and is used for monitoring a process variable in the plant.
- 11) - "Concurrence" (when used with respect to and in association with a review activity)'is defined to mean: (1) a review of a document or portion thereof under consider:11on; (2) a conclusion that all pertitient and necessary requirements (within the purview of the one
, . performing the review) have been included; and, (3) essential 1
agreement and belief that the manner in which the requirements have J been' addressed will produce the intended results. j I l l l Rev. 6 43 of 67 JJ250QAMAPPENDIX 1 - 43
APPENDIX A t fl NRC Regulatory Guide 1.88 " Collection, Storage and Maintenance of Nuclear l Power Plant Quality Assurance Records"(Rev. 2, 10/76) - Endorses ANSI N45.2.9-1974. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications: l l 1) With regard to Section 3.2.1 of ANSI N45.2.9 - 1974 titled l l Generation of Quality Assurance Records: The phrase " completely i filled out" is clarified to mean that sufficient information is
- recorded to fulfill the intended purpose of the record, l
- 2) With regard to Section 3.2.2 of ANSI N45.2.9 - 1974 titled Index:
The phrase "an index" is clarified to mean a collection of documents or indices which, when taken together, supply the information attributed to "an index" in the Standard. The specific location of a record "within a storage area" may not be delineated (e.g., The specific location within a computer record file may not be constant. Further, MP6L SERI may utilize a computer assisted random access filing system where such location could not be readily " documented," nor would such a location be " relevant.") The storage location will be delineated, but where file locations change j with time, the specific location of a record within that file may not always be documented. Rev. 6 44 of 67 J250QAMAPPENDIX 1 - 44
- g. .
F APPENDIX A
- 3) With regard to Section 4.2 of ANSI N45.2.9 - 1974 titled Timelinass:
MP&kle SFRI's' contractual agreement with its contractors and j suppliers will constitute fulfillment of.the requirements of this Section.
- 4) With regard to Section 5.4 of ANSI N45.2.9 - 1974 titled L.
Preservation: The following clarification is substituted for the current' subsection 5.4.2 " Records shall not be stored loosely. They shall be secured for storage in file' cabinets or on shelving in containers." The following clarification is substituted for the current subsection 5.4.3 " Provisions shall be made for special processed records (such .l 1 as, radiographs,' photographs, negatives, microfilm and magnetic media)
-to prevent damage from excessive light, stacking, electromagnetic fields, temperature and humidity as appropriate to the record type."'
5)_ With regard to Section 5.5 of ANSI N45.2.9 - 1974 titled Safekeeping: Routine general office and nuclear site security systems and access controls are provided: no special security systems shall be established for record storage areas.
- 6) With regard to Section 5.6 of ANSI N45.2.9 - 1974 titled Facility:
This Section provides no distinction between temporary and permanent facilities. To cover temporary storage, the following clarification is added: " Active (in-process) records will be stored in one-hour fire rated file cabinets. In general, records shall not be maintained ~) in temporary storage for more than three months after completion. Any
; Bev. 6 45 of 67 J250QAMAPPENDIX 1 ,
-____ _ _ u
i APPENDIX A g exceptions to this requirement must be evaluated and approved by tha l Director, Quality'AeencaneePrograms; a list of all such excepted 'j records sh'all be maintained and'available for NRC review. Exceptions may. include records needed,on a continuing basis for an extended period of time (e.g., personnel qualification and training records, equipment history records) and records which are cumulative in nature (e.g., nonconforming. item logs)." Paragraph 4, subsection 3 is clarified to require a two-hour minimum
-fire rating to be consistent with the 1979 version of the Standard and NRC Criteria for Record Storage Facilities (Guidance-ANSI N45.2.9, Section 5.6) issued 7/1/80.
Paragraph 4,. subsection 9 is clarified to read: "No pipes or
. penetrations except those providing fire protection, lighting, temperature / humidity control, or communications are to be located within'the facility.. All such penetrations shall be sealed or dampered to comply with a minimum two-hour fire protection rating."
7). With regard to Section 5.3 of ANSI N45.2.9 - 1974 titled Storage: The first sentence is clarified by stating that an individual shall be designated and assigned the responsibility for enforcement of written record storage procedures for each record storage location. The term
" custodian" may or may not be used as part of that designation.
Rev. 6 1 46 of 67 J250QAMAPPEND1X 1 - 46
'l
.APPENDTX A i NRC Regulatory Guide:1.94 " Quality Assurance Requirements for Installation, l
Inspection,.and Testing of Structural Concrete and Structural Steel during the , 1 Construction Phase of Nuclear Power Plants" (Rev. 1, 4/76) - Endorses ANSI q N45.2.5 1974. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, MP6b SERI shall either control these activities under this Operational QA Program.or under an NRC accepted Construction QA Program (Per 0QAM 3.5.18). When this Operational QA Program is used, MP6b SERI shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic /.
administrative requirements included therein shall apply to these maintenance and modification activities even though such requirements may not'have been in effect originally.- Technical requirements associated with maintenance and modifications shall be the original requirements or better (e.g., code requirements, material properties. design. margins, manufacturing processes and inspection requirements). 1
- 2) With regard to Section 1.2 of ANSI N45.2.5 - 1974 titled Applicability: The first sentence in-this Section is not applicable to the operations phase. MP6b SERI shall comply with the third sentence in this Section with the clarifications that "importance of the item or service involved" is interpreted to mean those to which Rev. 6 47 of 67 J250QAMAPPENDIX 1 - 47
__- ___ -_ ___-__-____-_ - _ _ Q
y __ _ _ _ _ _ _ , _ - - _ l '.- APPENDIX A the 0QAM cpplies', and the extent.of' coverage shall be defined by. supervisory maintenance personnel by the way in'which they implement the other requirements of this Standard. n
-In the second paragraph of this Section, MP&L SERI shall substitute the words." maintenance and modification" for the word " construction" as the modifier of " procedures."
- 3) With regard to Section 1.3 of ANSI N45.2.5 - 1974 titled Responsibility: This Sectlon's requirements are met by the j definitions for positions and the organizational responsibilities outlined in the Technical Specifications, Policy 1 of the 0QAM and the position descriptions for plant personnel.
4)' With regard to Section 1.4 of ANSI N45.2.5 - 1973 titled Definitions: Definitions in this Standard which are not included in ANSI N45.2.10 shall be used: All definitions which are included in ANSI N45.2.10 shall-be used as clarified in MP&Lis SERJ's commitment to Regulatory Guide 1.74. ! 1
- 5) With regard to Section 2.1 of ANSI N45.2.5 - 1974 titled Planning:
Planning requirements, when necessary, shall be incorporated into maintenance and modification procedures.
- 6) With r'egard to Section 2.5.2 of ANSI'N45.2.5 - 1974 titled Calibration and Control: The last sentence of this section requires that all items inspected with M&TE which is found to be out of calibration shall be considered unacceptable. We will comply with an Rev. 6 48 of 67 J250QAMAPPENDIX 1 - 48
APPENDIX A altsrnate which will require evaluation to determina'the validity of previous measurements..This alternative is consistent with ANSI N45.2.4 Section 2.5.2; ANSI N45.2.1, Section 2.5.2; ANSI N45.2.8, Section 2.8.2; ANSI N45.2.13, Section 7.4.2, and ANSI N18.7, Section 5.2.16.
- 7) With regard to Section 5.5 of ANSI N45.2.5 - 1974 titled Welding:
HP6b SERI will comply with inspection requirements of the applicable welding codes identified in the FSAR and any exceptions thereto. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ = = = - -______________________________ ____________________ NRC Regulatory Guide 1.116 " Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems" (Rev. 0-R, 6/76) - Endorses ANSI N45.2.8 - 1975. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, MP6b SERI shall either control these activities under this Operational QA Program or under an NRC accepted Construction QA Program (Per OQAM 3.5.18). When this Operational QA Program is used, MP6b SERI shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic /
administrative requirements included therein shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements Rev. 6 49 of 67 J250QAMAPPENDIX 1 - 49
APPENDIX A associated with maintenance end modifications shall be the original requirements or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).
- 2) With regard to Section 1.1 of ANSI N45.2.8 - 1975 titled Scope: The last paragraph of this Section is not applicable to the operations phase. The applicable portions of the requirements of this Standard shall also be applied after fuel load; therefore, the last twenty-two words in the last sentence of the second paragraph under this Section I
are also not appropriate to the operations phase.
- 3) With regard to Section 1.2 of ANSI N45.2.8 .1975 titled Applicability: The first sentence in this Section is not applicable to the operations phase. MP&L SERJ shall comply with the third !
sentence in this Section with the clarifications that "important mechanical systems to be covered" is interpreted to mean those to which the 0QAM applies, and "the extent of coverage" shall be defined by supervisory maintenance personnel by the way in which they implement the other requirements of this Standard.
- 4) With regard to Section 1.3 of ANSI N45.2.8 - 1975 titled Responsibility: This Section's requirements are met by the definitions for positions and the organizational responsibilities outlined in the Technical Specifications, Policy 1 of the 0QAM and the position descriptions for plant personnel.
Rev. 6 50 of 67 J250QAMAPPENDIX 1 - 50 i
3
-APPENDIX.A i4 :5)" ~With regard.to Section 1.4 of ANSI.N45.2.8;- 1975 titled Definitions:
Definitions in this Standard which are not included in ANSI N45.2.10-
~
i ishall be used: All-definitions which are included in ANSI N45.2.10 shall be 'used as clarified in MP&ble SERJ's commitment - to Regulatory ) i Guide'1.74. ! l i 6)' Withl regard to Section_2.1 of ANSI.N45.2.8 - 1975 titled Planning: Planning' requirements, when,necessary,'shall be incorporated into maintenance and modification procedures. NRC Regulatory Guide 1.123 " Quality Assurance Requirements for Control of-Procurement of Items and Services for Nuclear Power Plants" (Rev. 1, 7/77) - Endorses ANSI N45.2.13 .1976. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) .With regard to Section 1.3 of ANSI N45.2.13 - 1976 titled-Definitions: With two exceptions (Procurement Document and Quality Assurance Program Requirements) definitions in this Standard which are not included in ANSI N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in MP6Lle SERJ's commitment to Regulatory Guide 1.74. The two exceptions are defined in Appendix A under Regulatory Guide 1.74.
Rev. 6 51 of 67 J250QAMAPPENDIX 1:- 51 a_=:____-:___-____ _ _
I APPENDIX'A
^2) =With regard to_Section-1.2.2_of ANSI N45.2.13 --1976' titled Purchaser's Responsibilities: )
Item c'is one of the options which may be used by MP&b SERJ to assure
. quality; however, any of the options given in 10CFR50, Appendix B,
')
Criterion VII as' implemented by Policies 4 and 7 of the. Operational QA-Progrc.m may also be used.
- 3) With regard to.Section 3.1 of ANSI, N45.2.13 - 1976 titled Procurement Document Preparation, Review and Change Control: The ;
phrase "the same degree of control" is stipulated to mean " equivalent leve1Iof review and.' approval." The changed document may not always be: rereviewed by the originator; however, at least an equivalent level of management / supervision shall review and approve any changes.
- 4) With regard.to'Section 3.4 of ANSI N45.2.13 - 1976 titled Procurement Document Control: MP&L SERJ will meer the requirements of Policies 4 and 7 of the Operational QA Program in lieu of the requirements specified in this Section.
- 5) With regard to Section 5.3 of ANSI N45.2.13 - 1976 titled Preaward Evaluation: MP&b SERJ will comply with an alternate paragraph which i
reads: "Except in unusual circumstances (e.g., replacement parts are needed to preclude the development of some unsafe condition at a nuclear facility), a preaward evaluation of the Supplier shall be performed as required by the Operational QA Program." Rev. 6 52 of 67 J250QAMAPPENDIX 1 - 52
1 I APPENDIX A i
' 6) . . With ragard to Section_6.4'of' ANSI-N45.2.13 - 1976 titled-Control of f;
I Changes in Items'or Services: The phrase "the Operational-QA .,
]
i il . ;
' Program" will be inserted.in lieu of." ANSI N45.2, Section.-7." )
i I 7). With regard to Section 8.2 of ANSI-N45.2.13 - 1976, titled j Disposition: The third sentence of item b is revised to read: 1 7 I i l Nonconformances to-the contractual procurement requirements or 1~ Purchaser approved documents which consist of one or more of the I following shall be submitted to the Purchaser for approval of l the recommended disposition prior to shipment when the noncon-formance could adversely affect the end use of a module or shipable camponent # relative to. safety, interchangeability, operability, reliability, integrity, or maintainability:
- 1) Te'chnical or material requirement is violated;
- 2) Requirement in Supplier documents, which have been approved by the Purchaser, is violated; 3).Nonconformance cannot be corrected by continuation of the original manufacturing process or by rework; and/or l I
- 4) The item does not conform to the original requirement even i j
though the item can be restored to a condition such that the capability of the item to function is unimpaired. 1 I I Rev. 6 j 53 of 67 J250QAMAPPENDIX 1 - 53 l
li xn n
]
APPENDIX A I
# A module is an assembled device, instrument, or piece of equipment l agy n '
identified by serial' number or other identification code, having been evaluated by inspection and/or test for conformance to procurement - requirements regarding end'use. A shippable component is a part or w (( subassembly of a device, instrument, or piece of equipment which is ! shipped as_an individual item and which has been evaluated by in-spection and/or test'for conformance to procurement requirements regarding end use. 4' If? ' sq.0 f
- 8) With regard to Section 12 of ANSI N45.2.13 - 1976 titled Audit of
~ Procurement Program: The MP&b SERJ audit program will be implemented in accordance with and to meet the requirements of: ANSI N45.2.12 as endorsed in Appendix A; Policies 2, 4 and 18 of the Operational QA Program, and the requirements of the individual nuclear facility Technical Specifications.
'9) Paragraph C.6.e of Regulatory Guide 1.123 (and Section 10.3.4 of-ANSI N45.2.13 which it references) shall be implemented as originally L
"Y written (i.e. with the verb "should" instead of the verb "shall"). This. flexibility is necessary because MP&L SERI may not always be able
-to obtain agreemnnt with a Supplier. MP&L SERJ retains the ultimate responsibility for perf ormance of purchased equipment. The appropri-ate MP&L SERI engineering discipline will exercise this management /
engineering prerogative with respect to the final decision on post installation test requirements. i
~
l Rev. 6 k 54 of 67 J250QAMAPPENDIX 1 - 54 I
- -us:: i
APPENDIX A j
- 10) With regard to Section 11 of ANSI N45.2.13 - 1976 titled Quality 4 Assurance Records: HP6b SERI shall maintain records in accordance with and to meet the requirements of Policy 17 of the 0QAM and ANSI N45.2.9 as specified in Appendix A.
NRC Regulatory Guide 1.144 " Auditing of Quality Assurance Programs for Nuclear Power Plants (Rev. 1, 9/80) - Endorses ANSI N45.2.12 - 1977. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) With regard to Section 1.4 of ANSI N45.2.12 - 1977 titled Definitions: With two exceptions (Program Deficiencies and audits) the definitions in this Standard which are not included in ANSI N45.2.10 will be used: All definitions which are included in ANSI N45.2.10 will be used as clarified in MP& bis SERI's commitment to l
Regulatory Guide 1.74. The excepted definitions are defined in I l Appendix A under Regulatory Guide 1.74.
- 2) With regard to Section 2.2 of ANSI N45.2.12 - 1977 titled Personnel Qualification: The qualification of MP6b SERI audit personnel will be accomplished as described to meet the requirements of ANSI N45.2.23 - 1978 as endorsed in Appendix A and Policies 2 and 18 of the Operational QA Program.
1 l Rev. 6 55 of 67 J250QAMAPPENDlX 1 - 55
A, o
~
[3Y . APPENDIX A; . 3). With regard.to.Section 2.3-(and s6h, sections 2.3.1 through 2.3.3)>of ( .y- ' ' ' 7 g. LANSI N45.'2.12 - 1977 titled Training: The training of:NP&b SERIs
, e < .
'4 audit' personnel will'be accomplished ~as described to meet the require-e
'mentatof ANSI.N45.2.23 - 1978 as endorsed in,nppendix A and-Policies-2.
. ?-
and 18'of q,,the Oyetational QA Program.
., 1 w
- 4) With' regard to.Section 2.4 of ANSI N45.2.12 - 1977 t'itled Maintenance 1
ofPtbfidiency: JThe maintenance of proficiency of MP&b SERI. audit u
;personnelwillbeacgomplishedasdescribedto.seettherequirements N y~ ,
of'AhSp\45.2.231978 asfendorsed in Appendix A and Policies 2 and 18 s-3 , p' <' of thd 0perational QA Program.. }3): s (, ; '~ 'c4rt pp Li 5) With reg'ard to Section 3.3 of ANSI N45.2.12 - 1977 titled ; Essential Elementsof the Audit System: MP6b SERI will comply with subsection 3.3.5 as it'was originally written'(subsection.3.2.5) in a y p (c r-r ANSI N45.2.12, Draft 3, Revision 4: " Provisions for reporting on the effectiveness of the qualitytassurance program to the responsible
- manage.meht For the. auditing organization (MP&b SERJ), ef festiveness 'is W
reported as required by tie individual nuclear facility Technical 9 [ N. . Specifications and paragraphs (currently numbered 1.3.1, 1.3.2 and " A , g 1.3.15)idn Poliep 1 of'the Operational QA Program. Other than audit 4y g i s reports,'MP&b EERJ may not directly report on the < effectiveness of
% ? ,
, i.-
'I :the . quality assurance programs to the audited organization when such 3
organiddticos are outside of MP&b SERJ.
. f,. >1 'f' x
i 1, , Subsection 3.3.6 requirements are considered to be fulfilled by
'. t %s .
7 compliance 't,[f th the organization and r4uting measures outlined in 4; C.
* ,, /the Operaticd al QA Program. . O j gj, 4
i, 4. ,
$e[ Rev. 6 e ,s
. .s. 56 of 67 y J25qQAMAPPENDIX:1 - 56 r; ,
[ . _
- b. <
a :
-APPENDIX A Subsection 3.3.7 requires verification of effective-corrective action on'a " timely basis." Timely basis is interpreted to mean within the framework or period of. time for completion of corrective' action that is accepted by the organization. Each finding requires a response I and a corrective action completion date; these dates are subject to revision (with the approval of the quality organization) and must be escalated to higher authority when there is a disagreement between the audited'and the auditing organization on what constitutes " timely corrective action."
6)' With regard to Section '3.' of ANSI N45.2.12 - 1977 titled Scheduling: Subsection'3.5.3.1 is interpreted to mean that MP&L SERI may procedurally control qualification of a contractor's or supplier's quality assurance program prior to awarding a contract or purchase order by means other than audit.
- 7) With regard to Section'4.3.1 of ANSI N45.2.12 - 1977 titled Pre-Audit Conference: MP&L SERI will comply with the requirements of this Section by inserting the word "Kormally" at the beginning of the first sentence. This clarification is required because, in the case of certain unannounced audits or audits of a particular operation or work activity, (Monitoring Audit Report) a pre-audit conference might interfere with the spontaneity of the operation or activity being audited. In other cases, persons who should be present at a pre-audit conference may not always be available: such lack of availability should not be an impediment to beginning an audit. Even in the above examples, which are not intended to be all inclusive, the material Rev. 6 57 of 67 J250QAMAPPENDIX 1 - 57
l ' APPENDIX A p , set forth in Section 4.3.1 will be covered (if. considered necessary or desirable as determined by the Audit Team Leader.by signature on
;thel audit report) during the course of the audit.
- 8) .With regard to Section 4.3.2 of ANSI N45.2.12-1977 titled Audit Process:
(a)' Subsection 4.3.2.2'could be interpreted to limit auditors to.the-review of only objective evidence; sometimes and for some program. elements, no objective evidence may be available. MP6b SERJ will: comply with an alternate sentence which reads: "When available, objective evidence shall be examined for compliance with quality asssurance program requirements. If subjective evidence is used (e.g., personnel interviews) then the audit report must indicate how the evidence was obtained." (b) Subsection 4.3.2.4 is modified as follows to take into account the fact that some nonconformances are virtually " obvious" with respect to the needed corrective action: "When a nonconformance or quality assurance program deficiency is identified as a result of an audit, unless the apparent cause, extent, and corrective action are readily evident, further investigation shall be conducted by the audited organization in an effort to identify the cause and effect and to determine the extent of the corrective action required." Rev. 6 58 of 67 J250QAMAPPENDIX 1 - 58
I" APPENDIX A (c). Subsection 4.3.2,5 contains a recommendation which is clarified with the definition of " acknowledged by a member of the audited , i organization" to mean that "a member'of the audited organization L has been informed of the findings;" it does not mean that that person agrees with the~ findings. Agreement or disagreement with
.a finding may be expressed in the response from the audited organization.
(d) ' Subsection 4.3.2.7 is not considered applicable as written. MP&L i SERI will comply with an alternate sentence which reads: " Corrective l action taken as a result of the last previous audit of'the same area shall be re;iewed'or reaudited, if necessary,.to evaluate the effectiveness of the action to resolve the identified nonconformance." l 9) With regard to Section 4.3.3 of ANSI N45.2.12 - 1977 titled Post-L Audit Conference: MP&b SERI will substitute and comply with the following paragraph: "For all external audits, a post-audit conference shall be held with management of the audited organization to present audit findings and clarify misunderstandings; where no adverse findings exist, this conference may be waived by management of the audited organization: such waiver shall be documented in the audit report. Unless unusual operating or maintenance conditions preclude attendance by appropriate managers / supervisors, a port-audit conference shall be held with managers / supervisors for all internal audits for the same reasons as above. Again, if there are no adverse Rev. 6 59 of 67 J250QAMAPPENDIX 1 - 59 i --- u - - - . - -
p APPENDIX A findings, management ~of the internal audited organization may waive the post-audit conference: such waiver shall be documented in'the audit report."
' 10) With regard to Section 4.4 of. ANSI N45.2.12'- 1977 titled Reporting:
(a)' This Section requires that.the audit report shall be signed by i
'the audit' team leader; this is not always the most' expeditious route to take to assure that-the audit report is issued.as soon as practical.-MP&b SERJ will. comply'with Section 4.4 as clarified in the following opening: "An audit report, which shall be signed by the audit team lesder,.or his supervisor in his absence, shall provide:" In cases where the audit report is not signed by the Lead Auditor due to his absence, one record copy'of the report must be signed by the Lead Auditor upon his return. The report shall not require the Lead Auditor's
. review / concurrence / signature if the Lead Auditor is no longer employed by MP&b SERJ at the time the audit report is issued.
.(b) MP&L SERJ will comply with subsection 4.4.3 clarified to read:
" Supervisory. level personnel with whom significant discussions were held during the course of pre-audit (where conducted),
audit, and post-audit (where conducted) activities." (c) Audit reports may not necessarily contain an evaluation statement regarding the effectiveness of the quality assurance
- I J
Rev. 6 60 of 67 J250QAMAPPENDIX 1 - 60
APPENDIX A program elemrnts which ware eudited, as required by subsection 4.4.4, but they will provide a summary of the audited areas and the results. (d) Subsection 4.4.6 requires audit reports to include recommendations for corrective actions; MP&L SERI may choose not to comply with this requirement. Instead, MP&L SERI auditors / Iead auditors are required to document all adverse audit findings. The procedure for processing nonconformance documents allows the auditor / lead auditor'to document actions which are considered necessary to correct the finding, the auditor / lead auditor may also document actions which are considered unacceptable for correcting the finding: the nonconformance document with these
" Auditor Recommendations" is then transmitted to the audited organization. In addition, the auditor / lead auditor or l
l appropriate QA Supervisor is required to review corrective action taken for the nonconformance document and determine if it is acceptable. Any disagreements must be escalated to higher management for resolution. (e) The last paragraph in Section 4.4 deals with distribution of audit reports. MP&L SERI will comply with these requirements after substituting the following for the last sentence: "The audit report shall be issued within thirty working days after the last j l day of the audit." (
- 11) With regard to Section 4.5.1 of ANSI N45.2.12 - 1977 titled By Audited Organization: MP&L SERI will comply with the following I clarification of this Section: " Management of the audited organization Rev. 6 61 of 67 f J250QAMAPPENDIX 1 - 61 I
i
J 7 APPENDIX'A-or. activity shalll review and investigate all adverse audit findings, i i as necessary, to determine and schedule appropriate-corrective' action )
- I including action to prevent recurrence. They shall respond, in 'l l
L writing, within' thirty working days after the date of issuance of the audit report clearly stating the corrective action taken or planned to prevent recurrence and the results of the investigation if conducted. However,. written response is not necessary if corrective action is taken and verified prior to' thirty days. The audited organization 3 shall take appropriate action to assure that corrective action is accomplished as scheduled." The DQADirector, Quality Programs may, at his discretion, waive the requirement for a supplementary response.
- 12) With regard to Sections 3.4 and 4.2.1 of ANSI N45.2.12 - 1977 titled Audit Planning and Written Plan respectively: In the case of a Monitoring Audit Report. provisions for " Written Plan" is met by the overall audit planning documents, which may include the. audit plan.
The audit plan is encompassed by the individual audit report 1 (although may not be identified uniquely as audit plan). In the case l of Monitoring Audit Reports the written plan may appear in a different form. l
- 13) Paragraph C.3.a of Regulatory Guide 1.144 (and Section 3.5.2 of ANSI f N45.2.12 which it references) shall be implemented by meeting the audit requirements of the GGNS Technical Specifications for audits under C.3.a(1). Audits under C.3.a(2) are not covered by this OQAM.
Rev. 6 1 62 of 67 J250QAMAPPENDIX 1 - 62
l l APPENDIX A
- 14) Paragraph C.3 b(2) first centence is replaced with the following:
Each Supplier is evaluated initially to determine the acceptability i ee of his quality assurance program. If acceptable, the Supplier is 1 placed on the qualified Supplier list. When-enffiefene-werk-to-in i pregress-ee-demeneereee-thee-the-ergenteetten-te-implementing-e , 1 l quelfey-eesurance-program-en-endie-is-performed-and-ehe-eriennial a persed-will-begine--A-formel-evelueesen-ef-ehe-Guppiter-fe-performed , I each-year-ee-determine-if-a-reeudie-te-required-during-ehe-upeeming years Audite, when used as the celected method of cource verification, i should be conducted as follove: L I 8 1 Paragraph C.3.b(2), second paragraph is replaced with the follouing: An cvaluation of the supplier should be performed annually. This evaluation must be formal, with the results documented and approved by responsible QA management; and it must consider pertinent factors such as the results of other audits, history of performance of product and/or purchased service, and effectiveness of implementation of the Supplier's QA program. This annual evaluation shall consider the complexity of the component concerned and the degree of quality and process control required by the manufacturing effort. As a result of the evaluation, Suppliers requiring a formal reaudit are identified. Regardless of the results of the evaluation, eeefve l Suppliers teneepe-ehese-excluded-under-GrBrbft)-ebevel shall be re-audited every three years. Paragraph additions to C.3.b(2) are as follows: Previously evaluated and approved active suppliere, for which audit is not the selected method of source verification, should be evaluated concurrent with Rev. 6 f I 63 of 67 J250QAMAPPENDIX 1 - 63
APPENDIX A the avard of a contract. Regardless of the reeutta of the evat-uation, active suppliere (except those erotuded under C.3.b(1) above) ehatt have been ecurce verified (audit, surveillance or inspection) within tuo yeare prior to award of a contract or have source ver- .i ification performed.
)
Inactive Suppliers shall be evaluated prior to supplying safety-related items or services. An audit shall be conducted IF required , to determine the acceptability of procured items or services (i.e., ! acceptability cannot be determined by receipt inspection or one of l the other methods allowable under 10CFR50, Appendix B, Criterion VII).
- 15) Paragraph C.4.a of Regulatory Guide 1.144 (and Section 3.5.3.3 of ANSI N45.2.12 which it references) shall be implemented with the clarification that the Director, Quality-Assuranee Programe or his designee shall determine which reorganizations or procedure revisions are "significant."
- 16) With regard to Section 5.1 of ANSI N45.2.12 - 1977 titled General:
MP&b SERI shall maintain records in accordance with and to meet the requirements of Policy 17.0 of the 0QAM and ANSI N45.2.9 as specified in Appendix A.
- 17) With regard to Section 4.3.2 of ANSI N45.2.12 - 1977 titled Audit Process: Subsection 4.3.2.6 is modified as follows to account for the fact that immediate notification is not always possible: " Conditions requiring immediate corrective action (i.e., those which are so Rev. 6 !
64 of 67 l J250QAMAPPENDIX 1 - 64 ____-__________O
APPENDIX-A savara thet any dalay would be undesirable) shall bs' reported to management of the audited organization. Where responsible management
. personnel are available (such as at an operating nuclear power plant), these conditions chall be reported immediately. If respon-sible management personnel are not available (such as at a Supplier's shop on a back shift or for items discovered during a review of vendor supplied materials), these conditions shall be reported as soon as practical. l
)
NRC Regulatory Guide-1.146 " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" (Rev. O, 8/80) - Endorses ANSI N45.2.23.- 1978. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) With respect to Section 2.2 of ANSI N45.2.23 - 1978 titled Qualification of Auditors: Subsection 2.2.1 references an ANSI B45.2 (presumed to be N45.2); the Operational QA Program does not include a commitment to this standard; therefore, MP&L SERI will comply with an alternate subsection 2.2.1 which reads:
Orientation to provide a working knowledge and understanding of the Operational QA Program, including the ANSI standards and Regulatory Guiden included in Appendix A of that Program, and MP&ble SERI's precedures for implementing audits and reporting results. Rev. 6 i 65 of 67 J250QAMAPPENDIX 1 - 65
APPENDIX A
- 2) With respect to Section 4.1 of ANSI N45.2.23 - 1978 titled Organizational Responsibility: MP&L FERI will comply with this Section with the substitution of the following sentence in place of the'last' sentence in the Section.
The Director, Quality-Assurance Programs, Managery Neeleer 64ee QueHey Assurance, Manager,-Audsee Quality Systems Assurance or Lead Auditor shall, prior to commencing the audit, assign personnel who collectively have experience or training commen-surate witi. the scope, complexity, or special nature of the activities to be audited. Self-initiated Monitoring Audit Reports (MARS) will be performed by. qualified auditors, but no assignment is made " prior to commencing the audit" since it is self-initiated.
- 3) With respect to Section 3.2 of ANSI N45,2.23 - 1978 titled Maintenance of Proficiency: MP&L SERI will comply with the require-ments of this Section by defining " annual assessment" as one which takes place at least every twelve (12) months (to a maximum of fifteen
[15]) and which uses either the initial date of certification or the last annual assessment date (not the calendar year) as the starting l l date for determining when such annual assessment is due. , l l I 1 1 Rev. 6 66 of 67 J250QAMAPPENDIX 1 - 66
APPENDIX A
- 4) Mith respect to Section 5.3 of ANSI M45.2.23 - 1978 titled Updating of Lead Auditors' Records: MP&b SERI will substitute the following sentence for this Section:
l Records for each lead Auditor shall be maintained and updated ! during the period of the annual management assessment as defined in Section 3.2 (as clarified). i
- 5) With respect to Section 5.4 of ANSI N45.2.23 - 1978 titled Record l Retention: MP&L SERI will substitute the following sentence for this Section.
Qualification records shall be retained as required by the Operational QA Program.
- 6) With regard to Section 2.3.1.3 of ANSI N45.2.23 - 1978 titled Other Credentials of Professional Competence 1 Add "This includes R0 (maximum of 1 credit) and SRO (maximum of 2 credits) licenses" to last sentence of this subsection.
i Rev. 6 l 67 of 67 l J250QAMAPPENDIX 1 - 67 ______-____~
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~ INTRODUCTION
-This Manual describes the Operational Quality Assurance Program estab-lished by System Energy Resources, Inc. (SERI) to assure that its nuclear power
. l6 plants are operated in'accordance with applicable regulatory requirements and
.in a manner which protects the public health and. safety. The operational Quality Assurance Program conforms to the criteria established in Appendix B to
,10CFR50, " Quality Assurance Criteria for Nuclear Power Plants and Fuel-Reprocessing Plants," and to the Regulatory Position in applicable NRC Regulatory Guides and industry standards as delineated in Appendix A to this
~
Manual. Guidance in the preparation of this Manual was obtained from the NRC's
" Standard Review Plan" (NUREG-75/087).
The Quality Assurance Program described herein is applicable to all SERI nuclear power plants which reference it in Section 17.2 of: their Updated l6 Final-Safety Analysis Report. The program applies to all operational phase activities (including pre-operational and startup testing) which affect the safety-related functions of those structures, systems and components which
. prevent or n:itigate the consequences of postulated accidents which could cause undue risk to the health and safety of the public.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 j INTRODUCTION I Page 1 of 1 INTRODUCTION J260QAMINTRO.A - 1
FOREWORD This Manual prescribes the Operational Quality Assurance Program Policies established by SERI to control operational phase safety-related activities l6 for the Grand Gulf Nuclear Station. The program described in these Policies complies with the requirements of Appendix B to 10CFR50 and incorporates appropriate provisions of applicable industry standards and NRC Regulatory Guides, as delineated in Appendix A to this Manual. Compliance with the requirements set forth in this Manual is mandatory for all personnel involved in safety-related activities for the Grand Gulf Nuclear Station. Copies of this Manual are numbered for control and will be kept up-to-date by the isouance of revisions, as necessary. 'The Director, Quality Programs is 6 responsible for control of the Manual and issuance of revisions. The holders of the Manual are responsible for keeping their copy current by appropriately handling revisions. T. H. Cloninger 0. D. Kingsley, Jr. Vice Presidente Nuclear Engineering Vice President. Nuclear Operations and Support
=
R. J. Landy / Q Vice President",' Human Resources and 6 Administration l l
)
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 FOREWORD Page 1 of 1 FOREWORD J260QAMINTRO.A - 2 1
-,-7_--_.-_
f
, /-
TABLE OF CONTENTS
. TITLE REV. DATE POLICY-Policy 1- Organization 6 Policy 2! ' Quality. Assurance Program 6
- Policy 3 Design Control 6 Policy 4 Procurement Document Control 6 Policy 5 Instructions, Procedures and Drawings 6 Policy 6 Document Control 6 Policy 7 Control of Purchased Material, Equipment and' Services 6 Policy 8 : Identification and Control of Material, Parts and Components 6 l .
Policy 9 Control of Special Processes 6 Policy 10 Inspection, 6 Policy-11 Test Control 6 Policy 12 Control of Measuring and Test Equipment 6 Policy 13 Handling. Storage and Shipping 6 Policy 14 Inspection, Test and Operating Status 6 Policy 15 Nonconforming Materials, Parts or Components 6 Policy 16 Corrective Action 6 Policy 17- .Quality Assurance Records 6 Policy 18 Audits 6 OPERATIONAL QUALITY ASSURANCE MANUltL Rev. 6 TITLE: TABLE OF CONTENTS TABLE OF Page 1 of 2 CONTENTS J260QAMINTRO.A - 3
TABLE OF CONTENTS POLICY TITLE REV. DATE Appendix A Conformance.of SERI Operational 6 Quality Assurance Program to NRC l6 Regulatory Guides and ANSI Standards Appendix B Document Control Responsibility 6 For Quality Related Documents Appendix C Operational Quality Assurance 6 Program Implementing Procedures Record of Revisions Entered 2 6/1/81 OPERATIONAL QUALITY ASSURANCE MANUAL- Rev. 6 TITLE: TABLE OF CONTENTS TABLE OF Page 2 of 2 CONTENTS J260QAMINTRO.A - 4 1
( 1.0 ORGANIZATION-s 1.1 PURPOSE This Policy describes the SERI organizations and key personnel responsible I for developing, implementing and verifying the effectiveness of the ; Operational Quality Assurance Program for the Grand Gulf Nuclear Station. 1.2 SCOPE This Policy defines the organizational structure and delineates the authority, responsibility and lines of communication for SERI organizations performing functions covered by the Operational Quality Assurance Program. Certain of these functions may be delegated to other qualified organi-zations, but responsibility for the program is retained and exercised by SERI. 1.3 ORGANIZATION AND RESPONSIBILITY Clear and definitive lines of authority, responsibility and communication are established for all SERI organizations involved in the Operational Quality Assurance Program. These lines extend from the highest management level through intermediate levels to and including the onsite operating organization and offsite organizational elements. The organizational structure and functicnal responsibility assignments are j such that' attainment of program objectives is accomplished by those who have been assigned responsibility for performing the work, and verifica-tion of conformance te established requirements is accomplished by l qualified personnel who do not have responsibility for performing or directly supervising the work. Organizational structure and lines of authority, responsibility and communication are depicted in the organizational charts included at the end of this Policy. The dashed line between the Director, Quality Programs 6 and the President & Chief Executive Officer indicates guidance on Quality Assurance policy matters and a direct escalation path. 1.3.1 President & Chief Executive Officer Ultimate responsibility for providing top level direction of all activities associated with the safe and reliable operation of the Grand Gulf Nuclear Station rests with the President & Chief Executive Officer of the Company. The President & Chief Executive Officer provides guidance with regard to corporate quality assurance policy. He delegates authority and responsibility for the development, implementation and verification of the Operational { Quality Assurance Program to the appropriate SERI organizations through the Vice President, Nuclear Operations and the Vice I President, Nuclear Engineering & Support. He maintains a continuing awareness of quality assurance matters and monitors effectiveness j of the program through status reports prepared by the Director, i 6 Quality Programs. 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 1 of 8 Policy 1 J250QAM.1A - 1 l J
1.3.2 Vice President, Nuclear Operations The Vice President, Nuclear Operations reports directly to the President & Chief Executive Officer and is responsible for the administration of all functions associated with the f-{ operation of the Grand Gulf Nuclear Station, except those delegated to the Vice President, Nuclear Engineering & Support. f He maintains a continuing involvement in quality assurance matters and assesses the scope, status, implementation and effectiveness of the program through contact with and review of 3 reports issued by the Director, Quality Programs. It 6 r is the Vice President, Nuclear Operation's responsibility to assure that the requirements of the Operational Quality Assurance Program are implemented by the organizations under his direction. 1.3.3 Director, Quality Programs l6 i 6 The Director, Quality Programs reports directly to the Vice President, Nuclear Engineering & Support and is delegated the overall authority and responsibility for establishing, controlling and verifying the implementation and adequacy of the Operational Quality Assurance Program (including preoperational and startup testing). This includes the establishment of corpo-rate quality assurance policies, goals and objectives. He is assisted by the Manager, Quality Services; Manager, Quality 6 Systems and a staff of quality assurance personnel in residence both in the General Office and at the plant site. The primary duties and responsibilities of the Director, 6 Quality Programs include: 1.3.3.1 Developing and controlling the Operational Quality 6 Assurance Program and the content of this Manual, including the approval of changes thereto and providing interpretations thereof; [' ,1.3.3.2 Direc' ting the activities of the General Office quality assurance staff, and the quality assurance staff located at the plant site, in verifying the implementation of the Operational Quality Assurance Program; 1.3.3.3 Reporting to the Vice President, Nuclear Engineering & Support and the President & Chief Executive Officer on the status and adequacy of the Operational Quality Assurance rrogram; 1.3.3.4 Reviewing and approving Quality Assurance Procedures; 6 1.3.3.5 Providing for review of and concurrence with documents as specified in Appendix B of this Manual; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 2 of 8 Policy 1 J250QAM.1A - 2 i _ _ L __ _
1.3.3.6 Directing training for quality essurance personnel; providing quality assurance input to the training and indoctrination programs for personnel performing quality-related activities; and providing for the approval of certification for all Quality Assurance Personnel. 1.3.3.7 Maintaining adequate communications with regulatory agencies, suppliers, contractors and other SERI 6 organizations on Quality Assurance matters; 1.3.3.8 This section deleted in Revision 4. 1.3.3.9 Planning and performing supplier evaluations, source inspections, inspections, source quality verification and audits; 1.3.3.10 Developing and carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements; 1.3.3.11 Providing for periodic review and analycis of NRC and SERI Quality Assurance nonconformance documents to detect possible adverse quality trends. 6 The Director, Quality Programs is independent of undue influences and responsibilities for schedules and costs, and has sufficient authority and organizational freedom to identify quality prcblems, recommend solutions and verify implementation , of solutions. If acceptable solutions cannot be reached he has l the responsibility and authority to escalate these matters to the President & Chief Executive Officer. He has the authority, as delineated in the appropriate Quality Assurance Procedure, to initiate action to stop unsatir: <: tory work and control further processing, delivery, or installation of nonconforming items or continuation of nonconforming services pending correction of the nonconforming condition. l6 1.3.4 Manager, Quality Services l6 The Manager, Quality Services reports to the Director, Quality Programs and is located at the plant site. He directs quality 6 assurance staff located at the plant site and the General office l in inspections (except for receipt inspections), nondestructive examination and reviews of plant site activities--including the activities of the plrnt staff and the Nuclear Plant Engineering 6 staff to verify implementation of the Operational Quality Assurance Program at the plant site. He is responsible for coordinating the review of all SERI procedures, as delineated in Appendix B to this manual to assure quality requirements are 6 addressed; development, interpretation and maintenance of the Operational Quality Assurance Program and Procedure Manuals. He is responsible for the control, processing, tracking, disposi-tioning, and verification of nonconformance documents. He has OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 3 of 8 Policy 1 J250QAM.1A - 3 _ _ _ _ __________a
'}>
r k s Ithe authority, as delineated in the appropriate quality
% !- Assurance Procedure, to initiate action to stop unsatisfactory work ata control further processing, delivery or installation of
< < nonconforming items or continuation of nonconforming services pending correction of the nonconforming condition.
1.3.5 CGNS General Manager The GG1-i General Manager reportt!to the Site Director GGNS and is delegated the responsibility and authority for assuring the safe, reliable and efficient, operation of the p1. ant within the constraints of applicable regulatory requirements and the operating license. He supervises 4the operating plant staff; approves Plant Adminidtrativd P,vocedures; authorizes implementa-
,/ tion of design changes and p3 set;s.o' deifications; implements repairs; deporen appropriate matters to management and the 5 )
Safety Review Cormittee; and genqrelly administers plant opera-
,! tions on a day-to-day basis. 4 h has overall responsibility for execution of the Operational-Quality Assurance Program at the
+
- plant site; except for implementation and testing of design h changes and plant modificatider.%nd 'the preoperational testing s ca Unit 2; and has the authdrity to stop work if an activity at the Plant is not in conformance with program requirements. He has overall responsibility for developing systems to manage the c
storage and retrieval of records within SERI and for coordi- l6 nating the turnover of contractor vendor records. It is the t responsibility of the GGNS Seneral Manager to assure that these a functions are perforred in accordance with the requirements of the Operational Quality Ars.rrance Program. I I. The GGNS General s Manager 10, assisted in entrying out his
& responsibilities by the Maw;er, Plant Onerations; the Manager, F Plant Maintenance ond the Manrger, Plant Support as well as the operatinr; plant stuff.J-which includes tarfividuals knowledgeable
..in plant radiation protection, and plant e,ecurity. In 6 additios, the GGNS Generel Manager oversees the activities of the Plant Safety Review Committee and provides for necessary i liaison with the Safety Review Committee cf which he is a member. :
1.3.6 This Section deleted In Revision 4 ( 1.3.7 Director, Nucler.r Licen ingq l6 The Director, Nuclear Licensing reports to the Vice President, l6 Nuclear Operationa and is responsible for directing the ; activities of the Nuclear Licensing Staff. He is assisted by ! 6 the Manager, Nuclear Licenstug and the Manager, Licensing j Support. The Nuclear Libensing Staff is responsible for j securing the licenser and pcmits required to construct and ; operate the plant. Th Nmlear Licensing Staff also provides ,6 l techtical assistance in the < areas of safety analysis and fire ! { protection. This staff provides support to the Vice President, I OPERATIONAL QUALITY ASSURANCE v.ANUAL Rev. 6 ! TITLE: ORGANIZATION Page 4 of 8 Policy 1 J250QAM.1A - 4
i 1 Nuclear' Operations in matters related to Safety Review Committee
.I activities. It ta the responsibility of the Director, Nuclear 6
Licensing to assure that these functions are performed in accordance with the requirements of the Operational Quality a A Assurance Program. 1.3.8 Director, Nuclear Plant Engineering The Director, Nuclear Plant Engineering reports to the Vice President, Nuclear Engineering & Support, and is responsible for directing the activities of the Nuclear Plant Engineering Staff. Nuclear Plant Engineering, consisting of the Manager, Opera-6 tional' Analysis; Manager, Engineering Support; Manager, Nuclear Design and their respective staffs are responsible for plant design, design review, modifications, chemical / environmental 6 analysis, special processes, operational analysis programs, and accident and transient analyses. It is the' responsibility of . the Director, Nuclear Plant Engineering to assure that these l functions are performed in accordance with the requirements of the Operational Quality Assurance Program. The Director,
~ Nuclear Plant Engineering is responsible for reviewing NPE 6 design documents for compliance with the Operational Quality Assurance Program requirements and concurring with the same.
I '. 3. 9 Safety Review Committee (SRC) Committee composition, responsibility and authority, subjects-to be reviewed, administrative controls, and reporting requirements are addressed in Section 6 of the Technical Specifications for the applicable nuclear generating station. 1.3.10 Plant Safety Review Committee (PSRC) l Committee composition, responsibility and authority, subjects to be reviewed, and reporting requirements are addressed in Section 6 of the Technical Specifications for the applicable nuclear generating station. 1.3.11 Manager, Purchasing and Manager, Contract Administration The Manager, Purchasing and Manager, Contract Administration l are responsible for performing procurement activities in ac-cordance with the Operational Quality Assurance Program, as coordinated with the Site Director GGNS; GGNS General Manager; Mcnager, Unit 1 Projects; the Director, Nuclear Licensing; the Director, Nuclear Plant Engineering; the Director, Quality 6 Programs; the Director, Nuclear Support; the Director, Corporate Services and other appropriate SERI personne.l. j l'.3.12 Other Organizations Other organizations, contractors, or consultc.nts may be dele- l gated certain functions which fall under the Operational Quality j OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 5 of 8 Policy 1 J250QAM.1A - 5 l _ - -- _ _ _-- -_ a
Assurance Program. In such cases, SERI shall retain responsibility for the delegated work. 1.3.13 Minimum Qualifications of Quality Assurance Personnel The qualification requirements and experience levels for key quality assurance personnel are such as to assure competence commensurate with the responsibilities of the position and are described in ANSI /ANS.3.1 (Draft 12/79). See Appendix A. Key quality assurance personnel include the Director, Quality Programs, the Manager, Quality Services and the Manager, 6 Quality Sistem:;. 1.3.14 This section deleted in Revision 5
.1.3.15 Unit 2 Construction Superintendent 6
The Unit 2 Construction Superintendent reports directly to the Vice President, Nuclear Engineering & Support and is immediately responsible for administration of all functions associated with the preoperational testing of the Grand Gulf Nuclear Station It is the Unit 2 Construction Superintendent's responsi. 6 Unit 2. b Hity to assure that the requirements of the Operational Quality Assurance Program are implemented by the organizations I under his direction. The Unit 2 Construction Superintendent 6 l maintains a continuing involvement in preoperational phase ! testing, quality assurance matters, and assesses the implement-ation and effectiveness of the program through contact with and reports furnished by the Director, Quality Programs. 6 ( 1.3.16 Director, Nuclear Support l The Director, Nuclear Support reports to the Vice President, Nuclear Engineering & Support and is responsible for directing the activities of the Nuclear Support Department. The Nuclear Support Department, consisting of the Manager, Nuclear Services
& Fuels; Manager, Radiological and Environmental Services; Manager, Contract Administration; and their respective staffs 6 provide technical support in the areas of environmental li-censing and permitting; health physics; environmental pro-tection; chemistry; waste management; fuel cycle management including the control of the design activities associated with nuclear core design (except those activities associated with accident and transient analyses); developing, bidding, awarding 6 and administering contracts; and, departmental administration. l l It is the responsibility of the Director, Nuclear Support to assure that these functions are performed in accordance with the requirements of the Operational Quality Assurance Program.
l 1.3.17 This section deleted in Revision 5 i. i I OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 i TITLE: ORGANIZATION l Page 6 of 8 Policy 1 J250QAM.1A - 6 t __ _ _ _ _ _._ _.______________J
1.3.18 Miniger, Qutlity Systems The Manager, Quality Systems reports directly to the Director, Quality Programs and is located at the General Office. He directs quality assurance staff located at the plant site and the General Office and is responsible for planning, scheduling. coordinating and performing all internal audits and monitoring, source quality verifications, receipt inspections, audits of onsite contractors and consultants and offsite suppliers. He assures performance of the quality review of procurement documents; performs pre-award evaluations of suppliers; and is ' responsible for coordinating source inapection. He is respons-ible for trend analysis and reporting of results to the appro-priate levels of management as required by Quality Assurance Procedures. He plans, schedules and coordinates the training and certification of Quality Assurance personnel. He coordi- 6 nates'and/or implements administrative services for the Quality Assurante Organization. In addition, he coordinates, develops and issues Quality Assurance reports as required by SERI Management and appropriate procedures. He has the authority, as delineated in the appropriate Quality Assurance Procedure, to initiate action to stop unsatisfactory work and control further processing, delivery or installation of nonconforming items or continuation of nonconforming services pending correction of the nonconforming condition. 1.3.19 This section deleted in Revision 6. 1.3.20 Manager, Unit 1 Projects The Manager, Unit 1 Projects reports directly to the Site Director GGNS and is responsible for modification costs and schedules, for project management direction, and for coordina-tion with the Director, Nuclear Plant Engineering; the Manager, Plant Modification and Construction; and the GGNS General Manager. He is also responsible for providing administrative direction to the Manager, Plant Modification and Construction for the implementation and testing of design changes and plant modifications. It is the Manager, Unit 1 Projects responsibility to assure that the requirements of the Operational Quality Assurance Program are implemented by the organizations under his direction. 1.3.21 Vice President, Nuclear Engineering & Support The Vice President, Nuclear Engineering & Support reports directly to the President & Chief Executive Officer and is responsible for the administration of all functions associated with engineering and support of GGNS. He provides guidance with regard to corporate quality assurance goals and objectives to the Director, Quality Programs. He maintains a continuing 6 awareness of quality matters through applicable inspection reports and management audits of the program. He is also responsible for coordination of corporate quality assurance matters, as they relate to procurement. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 7 of 8 Policy 1 J250QAM.1A - 7
1.3.22 Site Director GGNS The Site Director GGNS reports directly to the Vice President, Nuclear Operations and is responsible for training. He also 6 provides management direction to the GGNS General Manager and the Manager, Unit 1 Projects. It is the responsibility of the i Site Director SGNS to assure that these functions are performed in accordance with the requirements of the Operational Qaality Assurance Program. 1.3.23 Manager, Emergency Preparedness The Manager, Emergency Preparedness reports directly to the Vice President, Nuclear Operations and is responsible for'the Emergency Preparedness program and associated activities. It is the responsibility of the Manager, Emergency Preparedness to assure these functions are performed in accordance with the requirements of the Operational Quality Assurance Program. 6 1.3.24 Manager, Operational Analysis The Manager, Operational Analysis is responsible for carrying out the activities of the Independent Safety Engineering Group (ISEG) as described in Technical Specification 6.2.3. a i i i i i l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: ORGANIZATION Page 8 of 8 Policy 1 J250QAM.1A - 8
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2.0 QUALI'TY ASSURANCE PROGRAM 2,1 PURPOSE-This Policy describes the Operational-Quality Assurance Program estab-lish'ed by SERI.for the Grand Gulf Nuclear Station. 6 2.2 SCOPE.' This Policy describes the Operational Quality Assurance Program in termu of the-objectives to be accomplished, the requirements to be met, and the implementation and control mechanisms which have been established. The total progrsm is described throughout this Manual. 2.3 APPLICABILITY The requirements of the Operational Quality Assurance Program apply to all individuals or organizations performing functions during the operational phase which affect the quality of safety-related structures, systems, components or services. Operational phase functions to which the program applies include: design-
.ing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing (including preoperational and j startup), auditing, operating, maintaining, repairing, refueling, and modifying (Except major modifications which may be excepted and covered under an NRC accepted construction QA Program per 0QAM 3.5.18. See Appendix A).
2.4 POLICIES, GOALS'AND OBJECTIVES Corporate quality assurance policies, goals, and objectives are summarized in the statement that all individuals and organizations within SERI wh 6
. perform quality-related activities have personal and corporate responsi-
.bility to assure that the Grand Gulf Nuclear Station is designed, constructed and operated in a manner which protects public health and safety'and promotes reliable and efficient operation.
The Operational Quality Assurance Program is designed to provide the mechanism for assuring that these policies, goals, and objectives are achieved. 2.5 PROGRAM DESCRIPTION The Operational Quality Assurance Program, as described throughout this _ Manual, delineates the measures established by SERI to assure that activities which affect the quality of safety-related structures, systems, l6 components and services are performed in a controlled manner and are sufficiently documented to provide objective evidence of compliance with I established requirements. ]
.The Operational Quality Assurance Program is documented by written l policies, procedures, and instructions; and shall be carried out -
throughout the life.of the plant in accordance with these policies, procedures, and instructions. These documents convey SERI quality l6 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 ' TITLE: QUALITY ASSURANCE PROGRAM Page 1 of 6 Policy 2 J250QAM.2A - 1
essurance philosophy end requirements to all levels of management and to all organizations and individuals involved with program implementation. The applicable Policies of the Operational Quality Assurance Program are mandatory for safety-related activities and functions as described in this Manual. The Operational Quality Assurance Program applies to all activities, ! including the use of expendable and consumable materials, affecting the safety-related functions of those structures, systems and components which prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The program is designed to comply with the requirements of Appendix B to 10CFR50,
" Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and with the Regulatory Position in applicable NRC Regulatory Guides and ANSI Standards as listed in Appendix A to this Manual.
A listing of structures / systems / components designated safety-related is included in the UFSAR for the applicable nuclear generating station. A Q-list which contains as a minimum those structures / systems / components l6 designated as safety related in the UFSAR plus those selected non-safety l6 related structures / systems / components to which the Quality Assurance Program applies is issued and maintained current. Nuclear Plant Engineering is responsible for the development and maintenance of this Q-List in accordance with written procedures which delineate the contents of the Q-List. The procedures will assure that structures / systems / components listed in the UFSAR are contained in the 6 Q-list. The distribution of the Q-List will be procedurally controlled. The positions authorized to approve changes to the Q-List are designated in Appendix B of this Manual. The applicable requirements of the program are also imposed upon con-tractors, suppliers and consultants. ! Development, control, and use of computer programs for design control I activities--as described in Policy 3 for safety-related structures, systems and components--will be conducted in accordance with the Opera-tional QA Program. 2.5.1 Operational Quality Assurance Manual The Operational Quality Assurance Manual consists of SERI l6 quality assurance policies, goals, and objectives and has been developed in accordance with applicable regulations, codes, and standards. It describes the Operational Quality Assurance Program and delineates the responsibilities and requirements i imposed by the program for the performance of safety-related activities. The Director, Quality Programs is responsible for maintaining l6 the Manual and controlling its distribution, including revisions thereto, in accordance with approved Quality Assurance Proce-dures. Revisions to the Manual will be processed per 10CFR50.54(a). l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 ! TITLE: QUALITY ASSURANCE PROGRAM l Page 2 of 6 Policy 2 i J250QAM.2A - 2 4 l l i
2.5.2 Imp 1rmenting Policies, Procedures and Instructions l6 The Operational Quality Assurance Program is implemented through the use of written, approved policies, procedures and instruc- 6 tions generated by the organizadons responsible' for the per-formance of the specific functions as outlined in Appendix B of this Manual.
.The Quality Assurance Procedure Manual contains the implementing procedures for the quality functions performed by the Quality '
Assurance Organization. Quality Assurance Procedures provide measures to assure that quality-related activities are performed in a controlled manner and are documented to provide objective . evidence of compliance with program requirements. The Director, 6 I Quality Programs is responsible for approving Quality Assurance Procedures prior to implementation. Quality-related functions performed by other organizations are controlled and documented in accordance with procedures pre-pared, approved and controlled by the organization performing the function. These procedures assure that the functions are accomplished in a controlled manner, with specified equipment, under suitable environmental conditions, and that prerequisites have been satisfied prior to inspection or testing. Plant Administrative Procedures provide the means whereby quality-related activities at the plant site including those of the Plant Modification and Construction Section are controlled and documented to provide objective evidence ~of compliance with program requirements. The GGNS General Manager reviews and approves all Plant Administrative Procedures with the Man &ger, Unit 1 Projects also reviewing and approving those Plant ! Administrative Procedures controlling the activities of the Plant Modification and Construction Section. Nuclear Support Administrative Procedures provide the means for assuring that the quality-related activities of the Nuclear Support Staff are controlled and documented to provide objective evidence of compliance with program requirements. Nuclear Support Adminis-trative Procedures are reviewed and approved by the Director, Nuclear Support. Nuclear Licensing Administrative Procedures provide the means for assuring that the quality related ) activities of the Nuclear Licensing Staff are controlled and 6 documented to provide objective evidence of compliance with i program requirements.. Nuclear Licensing Administrative Proce- ! dures are reviewed and approved by the Director, Nuclear Licensing. Nuclear Plant Engineering Administrative Procedures provide for assuring that the quality-related activities of Nuclear Plant Engineering are controlled and documented to j provide objective evidence of compliance with program require- i ments. Nuclear Plant Engineering Procedures are reviewed and approved by the Director, Nuclear Plant Engineering. The GGNS General Manager also reviews and approves Nuclear Support Administrative Procedures and Nuclear Licensing Administrative 6 Procedures which provide for effluent and environmental moni-toring and Emergency Plan implementation. Corporate Services l6 l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. o l
- TITLE
- QUALITY ASSURANCE PROGRAM Page 3 of 6 Policy 2 J250QAM.2A - 3 i
l l _ _ _ _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ __-_____-___________a
Administrative Procedures provide the means for assuring that the quality related activities of the Corporate Services Staff are controlled and documented to provide objective evidence of 6 compliance with program requirements. Corporate Services Administrative Procedures are reviewed and approved by the Director, Corporate Services. Required quality reviews and concurrence are performed by the Director, Quality Programs, as described in Appendix B to this Manual. Appendix C to this Manual provides a matrix of Quality Assurance procedures cross-referenced to the criteria of Appendix B to 10CFR50 which they implement. 2.5.3 Indoctrination and Training Indoctrination and training programs are established for both onsite and offsite personnel performing quality-affecting activ-ities by the organizations responsible for the activities. These programs are implemented by appropriate training plans and procedures which assure that: 2.5.3.1 Personnel responsible for performing quality-affecting activities are instructed as to the purpose, scope and implementation of manuals, procedures and instructions; 2.5.3.2 Personnel performing quality-affecting activities are trained and qualified in the principles and techniques of the activity being performed; 2.5.3.3 Proficiency of personnel performing quality-affecting activitics is maintained by retraining, reexamining or decertifying; 2.5.3.4 The scope, method and objective of the training are documented; 2.5.3.5 Records of training sessions are prepared and maintained, including identification of the content, the attendees and the date the training was conducted. 2.5.4 This section deleted in Revision 5. 2.5.5 Resolution of Disputes Disputes arising between SERI organizations on any quality l6 assurance matter which cannot be resolved by management of the involved organizations will be referred to the Vice President, Nuclear Engineering & Support or the Vice President, Nuclear Operations for resolution. l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY. ASSURANCE PROGRAM J250QAM.2A - 4
k _ 2 . 5 . 6 ' Quality Responsibilities i ! Quality responsibilities for the implementation of major activ-ities addressed in this Manual are designated in the individual policies of this Manual. 2.5.7 Preoperational Testing and Plant Turnover _ The Unit 2 Construction Superintendent,-who is responsible for the administration of all Unit 2 construction and preoperational phase activities for the plant, provides the management interface with the principal contractors in planning and j providing-for preoperational testing and plant turnover. The l GGNS General Manager who is responsible for the administration l =of.all startup testing activities for the plant, provides the management interface with the principal contractors in planning and providing for startup testing and plant turnover. The Unit 2 Construction Superintendent is responsible for the performance of preoperational phase testing, and the GGNS General Manager is responsible for the performance of startup testing. Each is also responsible for plant turnover activities (i.e., turnover from construction testing to SERI Plant Staff) with support l6 supplied by the principal contractors. Prior to the actual turnover, written procedures are developed by these organiza-tions for the control of the transfer of all portions of the plant, including documentation. Appropriate Quality Assurance Procedures provide for auditing and inspection of preoperational testing, startup and plant turnover activities to verify conformance with Operational Quality Assurance Program requirements. The GGNS General Manager is responsible for the control of the turnover of construction records and documentation from contractors and suppliers. 2.5.8 Definitions The terms and phrases given in the " Definition" portions of the ANSI Standards endorsed by this Program in Appendix A shall apply as well as those given in pertinent sections of the applicable portions of Title 10, Code of Federal Regulations. As used throughout this Operational Quality Assurance Program ; and its implementing procedures, the following words shall be construed to have the special definitions given: 2.5.8.1 Shall - A requirement considered enforceable by the appropriate regulatory body. 2.5.8.2 Should - A recommendation, but not an enforceable requirement. Management expects each employee using plant directives to carry out any "should" statement unless circumstances prevent or i necessitate a deviation. In those unusual l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 5 of 6 Policy 2 J250QAM.2A - 5 I
. _ _ . _ _ _ _ ____ - _ - _ _ - ____-___-_____-______D
occurrences where deviation'is necessary, the ! employee must justify the exception to the ; responsible Manager. ; 1 2.5.8.3 May - An option, neither a recommendation or a requirement. 2.5.8.4 Must - A requirement normally established by SERI management or may be used to meet regulatory intent. l6 l 2.5.8.5 Additional items are defined in Appendix A (see l under Regulatory Guide 1.74), individual Quality Assurance Procedures and other quality documents. 2.5.8.6 Any words which have not been defined in 1 through 5 above or item 7 below shall be as defined in a contemporary collegiate dictionary by a well known publisher or authority. 2.5.8.7 Will - Is defined the same as Shall. 2.5.9 Quality Assurance Position Statements Quality Assurance Position Statements are issued when considered necessary by the Director, Quality Programs, for use in inter- 6 pretation of certain commitments in the Operational Quality Assurance Manual. These statements are not a part of the NRC accepted Operational Quality Assurance Manual, and are
'being included in the manual binder only for the convenience of the users.
2.5.10 Resolution of Differences Every attempt has been made to include the pertinent require-ments from external documents, included in this' Program by the commitments in Appendix A, within these Policies; no known conflicts exist between those commitments and these Policies. Differences arising during future reviews or implementation of the Program, must be brought to the attention of the Director, 6 Quality Programs who initiates changes to the commitments or the Policies as necessary to resolve the differences. The provi-sions delineated in these Policies shall take precedence over differing requirements given elsewhere until the Director, Quality Programs has evaluated the issue and determined which 6 requirement (s) must be modified. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE PROGRAM Page 6 of 6 Policy 2 J250QAM.2A - 6 l l _ - -__A
3.0 DESIGN CONTROL 3.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to control design activities affecting safety-related 6 structures, systems and components for the Grand Gulf Nuclear Station. 3.2 SCOPE This Policy delineates responsibilities and defines requirements for the development and implementation of design control measures to assure that design activities are carried out in a planned, controlled and orderly manner. 3.3 APPLICABILITY The requirements of this Policy apply to all organizations performing design functions on safety-related structures, systems or components during the operational phase of nuclear power plant activities. 3.4 RESPONSIBILITY 3.4.1 Responsibility and authority for the control of design activities related to modifications or changes to plant safety-related structures, systems or components (including control of 6 accident and transient analyses, but excluding nuclear fuel and nuclear core design--see 3.4.5) during the operational phase are delegated to the Director, Nuclear Plant Engineering. The GGNS l General Manager authorizes the design modification or change to [ be implemented by the Manager, Unit 1 Projects. The Director, 1 l Nuclear Plant Engineering is responsible for assuring that procedures are developed and implemented to control the design activities of Nuclear Plant Engineering in accordance with the requirements of this Policy. 3.4.2 The reviewing of proposed 10CFR50.59 changes is completed as required by the Technical Specifications. This is described in appropriate procedures. When a proposed change is requested, the Director, Nuclear Plant Engineering initiates the design change (except in cases related to nuclear fuel and core design) { and assures submittal of the design change package, including I the safety evaluation per 10CFR50.59, to the Plant Safety Review i Committee (PSRC). The Manager, Nuclear Services & Fuels is 6 responsible for initiating design changes related to nuclear ; fuel and core design and for coordinating with Nuclear Licensing ) and Nuclear Plant Engineering in the development of required ' 10CFR50.59 evaluation (s) and submittal of the design change description and evaluation (s) to the PSRC. The Manager, Plant Modification & Construction is responsible (except in cases related to nuclear fuel) for the coordination of scheduling j and installation of plant modifications, betterments and repairs j once approved by the PSRC. The GGNS General Manager is respon- l sible for the scheduling and installation of nuclear fuel and core related design changes once approved by the PSRC. The OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL Page 1 of 5 Policy 3 J250QAM.3A - 1
Secretary of the Ssfety Review Committze (SRC) assures the review of the safety evalu: tion by the SRC. The Director, 6 Nuclear Licensing is responsible for developing a summary of the safety evaluation and submittal of the summary to the NRC, as required by 10CFR50.59. 3.4.3 Organizations supplying material, equipment or services are responsible for complying with the requirements of this Policy to the extent specified in the applicable procurepient documents, and for imposing them on their contractors and suppliers, as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being j adequately implemented. 3.4.4 The Director, Quality Programs is responsible for reviewing nuclear fuel and nuclear core (excluding accident and transient 6 analyses) design documents for compliance with Operational , Quality Assurance Program requirements and concurring with same; i for monitoring the implementation of design control measures by offsite organizations; and for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy. Those design documents include the type design documents originated, reviewed 6 and approved by the Manager, Nuclear Services & Fuels. 3.4.5 Responsibility and authority for control of design activities related to modification of or changes to nuclear fuel or nuclear core design (excluding control of accident and transient anal- 6 f ysis activities - See 3.4.1) are delegated to the Manager, l Nuclear Services & Fuels. He manages and coordinates the ( activities of nuclear fuel suppliers and other appropriate l' organizations. The Manager, Nuclear Services & Fuels is in-volved in: providing design inputs; providing interface control; reviewing all " accept-as-is" or " repair" dispositions for nuclear fuel or core configuration nonconformances. In addition he may perform design verification. The Director, Nuclear Support is responsible for assuring that procedures are de-veloped and implemented for the above design activities in accordance with the requirements of this Policy. J 3.4.0 Responsibility and authority for control of design activities (including accident and transient analyses, but excluding 6 modification of or changes to nuclear fuel or nuclear core j design) are delegated to the Director, Nuclear Plant Engine- 1 ering. Generally, the Director, Nuclear Plant Engineering l is involved in: providing design inputs, providing interface ) control; controlling design output; and performing design l verification. The Director, Nuclear Plant Engineering is ! responsible for assuring that procedures .are developed and implemented for the above design activities in accordance with the requirements of this Policy and will provide or concur with all " accept-as is" or " repair" dispositions (including accident 6 I and transient analyses, but excluding modification of or changes l to nuclear fuel or nuclear core design) for nonconformances. l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL Page 2 of 5 Policy 3 l
'J250QAM.3A - 2
r j The Director,' Nuclear Plant Engineering is responsible for reviewing NPE design documents for compliance with the 6 Operational Quality Assurance Program requirements and i
. concurring with the same.
3.5 REQUIREMENTS 3.5.1 Organizations having design responsibilities shall develop procedures, consistent with the scope of their responsibilities, j to provide measures for the control of their design activities. J 3.5.2 Procedures shall be developed to assure that applicable design inputs such as design bases, regulatory requirements, codes and-standards are identified and documented, and are correctly translated into design output documents such as specifications, drawings, procedures and instructions. 3.5.3 ' Procedures shall provide for the identification and documen-tation of appropriate quality standards to be specified in the design documents. Deviations and changes from these quality. standards shall be controlled. 3.5.4 Procedures shall include measures for: the control of design analyses such as. reactor physics, seismic, stress, thermal, , hydraulic, radiation, and accident analyses; compatibility of materials; accessibility for inservice inspection, maintenance, and repair. 3.5.5 Provisions shall be made in the procedures for the selection l of suitable materials, parts, equipment, and processes which include the use of valid industry standards and specifications. 3.5.6 Procedures shall require.that designs be reviewed to assure that: design characteristics can be controlled, inspected and tested, as appropriate; and, inspection'and test criteria are identified. Such reviews shall be documented. 3.5.7 Materials, parts and equipment which are standard, commer-cial (off-the-shelf), or which have been previously approved for a different application shall be reviewed for suitability prior ) to selection. Such reviews shall be documented. ! 3.5.8 Procedures shall provide for the control of design inter-faces for managing the flow of design information between organizations. Systematic methods shall be established for communicating needed design information across the interfaces, including changes to the design information as the work progresses. 3.5.9 Procedures shall include requirements to verify that the
' design is adequate and that it meets the specified design inputs. The extent of the design verification required shall be a function of the importance to safety of the item, the complexity of the design, the degree of standardization, the state-of-the-art and the similarity with previously proven OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DESIGN CONTROL Page 3 of 5 Policy 3 J250QAM.3A - 3
-designs'. In each case however, standardized or previously proven designs shall be reviewed' for applicability prior M use.
3.5.10 Acceptable verification methods shall include, but not be
-limited to, design reviews, alternate calculations, or qualification testing.- If a test program is used to verify the adequacy'of a design, qualification testing of.a prototype unit under the most adverse design conditions which are appropriate, shall be used.
3.5.11 Individuals or groups responsible for design reviews or'other
-verification activities shall be identified in the procedures
- and their authority and responsibility shall be defined and controlled. Design verification =shall be performed by any competent individuals or groups other than those who performed the original' design but who may be from the same organization.
i This verification may be performed by the originator's supervisor provided the supervisor is the only technically qualified individual available and the appropriate clarification provisions listed in Appendix A to this Manual are met. 3.5.12 Design and specification changes, including those.. originating onsite, shall be subject to the same degree of control as the original design and approved by the original design organization-unless another qualified, responsible organization is specifically designated. 3.5.13 Errors and deficiencies in the design process, including ; computer irograms, that could adversely affect safety-related i structures, systems or components shall be documented, and corrective e: tion taken to preclude repetition. 3.5.14 Proposed modifications or changes which involve an unre-viewed safety question or a change to the technical speciff-cations shall be handled in accordance with procedures which address the requittements of 10CFR50.59. ! 3.5.15 Design reccrds shall be maintained by the GGNS General. Manager in accordance with Policy 17.0 of this Manual. 3.5.16 This Section Deleted in Revision 4. 3.5.17 Plant Procedures are provided to assure that responsible plant personnel are made aware of design changes / modifications which may directly affect the performance of their duties. 3.5.18 During operational phase activities of a unit and while the A-E/ Constructor or his suppliers are; performing design or construction activities for that unit, another unit, or for shared facilities at GGNS,-SERI may choose to purchase similar services (i.e., design or construction) for the operating l6 unit (s). If such services are purchased: 3.5.18.1 They shall be procured in accordance with the requirements OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
, TITLE: DESIGN CONTROL Page 4 of 5 Policy 3 J250QAM.3A - 4
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j of Policies 4.0 and 7.0 and ANSI N45.2.13 (as modified and' included in Appendix A of the OQAM); - L3.'.18.2 5 They shall be in accordance with;the QA program-(A-E/' f, Constructor's or his suppliers') in effect for'similar 3 activities on other or the same unit (s)'or for shared j facilities; and 3.5.18.3 The QA Program shall be reviewed by SERI Quality l6 j Assurance.to assure that any additional' requirements which. are considered necessary to assure quality have been ! Lincluded. { i l l I OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
. TITLE: DESIGN CONTROL Page 5 of 5 Policy 3
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4.0 PROCUREMENT DOCUMENT CONTROL 4.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to control procurement documents for safety-related l6 material, equipment and services for the Grand Gulf Nuclear Station. 4.2 SCOPE This Policy delineates responsibilities and defines requirements for procurement document preparation, review, approval and change control in order to assure that purchased safety-related items and services will conform to established, specified requirements. 4.3 APPLICABILITY The requirements of this Policy apply to all procurement documents for r safety-related meterial, equipment and services purchased by or for SERI l6 during the operat.ional phase of nuclear power plant activities. 4.4 RESPONSIBILITY 4.4.1 All organizations participating in the preparation of pro-curement documents for safety-related items and services during the operational phase are responsible for developing their own procedures or using generic procedures. In either case procure- 6 ment document control procedures which address the requirements of this Policy, applicable to their scope of activities, shall be implemented. 4.4.2 The GGNS General Manager is responsible for onsite procure-ment document control. He is responsible for assuring l i procurement activities performed by the Plant Staff are l procedurally controlled in accordance with the requirements of this Policy. This includes preparation, review, approval and issue of procurement documents. 4.4.3 The Manager, Quality Systems is responsible for performing l6 quality reviews of procurement documents, prior to issuance, to verify conformance to the requirements of this Policy. The Manager, Quality Services is responsible for reviewing proce- l6 dures for procurement document control to assure that they address the applicable requirements of this Policy. Lower tier instructions may be reviewed by individuals (other than the preparer) of the organization preparing the documents if such individuals have been indoctrinated in the Operational Quality Assurance Program. The Manager, Quality Systems is responsible 6 for indoctrination and certification of these individuals. 4.4.4 The Director, Nuclear Support and Director, Nuclear Licensing 6 are delegated the responsibility for assuring that general office procurement activities performed by the Nuclear Support Staff and Nuclear Licensing Staff respectively, are procedurally 6 controlled in accordance with the requirements of this Policy. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: PROCUREMENT DOCUMENT CONTROL Page 1 of 4 Policy 4 J250QAM.4A - 1
1 This includes preparation, review, approval and issuance of procurement documents. 4.4.5 Organizations supplying material, equipment or services are , responsible for complying with the applicable requirements of ) this Policy, as specified in the appropriate procurement I documents and for imposing them on their contractors and i suppliers, as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 4.4.6 The Director, Quality Programs is responsible for assuring l6 implementation of procurement document control measures and for quality review of procurement documents and procedures. He is also responsible for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy. 4.4.7 The Manager, Purchasing and the Manager, Contract Administration 6 are responsible for performing procurement activities, in accordance with the Operational Quality Assurance Program, as coordinated with the Director, Nuclear Support; the Director, Nuclear Licensing; the Director, Nuclear Plant Engineering; the GGNS General Manager; the Director, Quality Programs; the Manager, Unit 1 Projects; the Director, Corporate 6 Services; and, other appropriate SERI personnel as delineated in appropriate procedures. 4.4.8 The Director, Nuclear Plant Engineering is responsible for assuring procurement activities performed by the Nuclear Plant Engineering Staff are procedurally controlled in accordance with the requirements of this Policy. This includes preparation, review, approval, and issue of procurement documents. 4.4.9 The Unit 2 Construction Superintendent is responsible for assuring procurement activities to support preoperational testing are procedurally controlled in accordance with the requirements of this Policy. This includes preparation, review, approval, and issue of procurement documents. 4.4.10 The Manager, Unit 1 Projects is responsible for assuring procurement activities to support the implementation and testing of design changes and plant modifications are procedurally controlled in accordance with the requirements of this Policy. This includes preparation, review, approval and issue of procurement documents. 4.5 REQUIREMENTS 4.5.1 Procedures shall be established by the responsible organiza-tions to clearly delineate the sequence of actions to be accomplished to control the preparation, review, approval and issuance of procurement documents for safety-related items and services. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: PROCUREMENT DOCUMENT CONTROL Page 2 of 4 Policy 4 J250QAM.4A - 2
4'5.2f
. The procedures shall assure that procurement' documents issued at.
all levels of procurement include provisions for the following, as' applicable: 4.5.2.1 A. statement of the scope of work to be performed by the contractor or supplier; 4.5.2.2 Identification of the design basis-technical requirements by reference to specific drawings, specifications, codes, regulations, industrial j standards or other documentation, including revisions thereto, that describe the items or services to be furnished; 4.5.2.3 Identification of test, inspection and acceptance requirements, and any special instructions and requirements for such activities as design, fabrication, identification, cleaning, erecting, packaging, handling, shipping and extended storage; 4.5.2.4 . Identification of the quality assurance program requirements which must be complied with by the contractor or supplier; 4.5.2.5 Stipulation that the provisions of 10CFR21 apply; 4.5.2.6 Identification of the documentation, such as drawings, specifications, procedures, fabrication and inspections plans, inspection and test records, personnel and procedure qualifications, and chemical and physical test results to be prepared and maintained by the supplier or contractor and
. requirements for submittal to SERI for review and 6 approval; 4.5.2.7 Identification of those records to be retained, controlled and maintained by the supplier or I contractor and those to be delivered to SERI l6 prior to use or installation of the procured item; 4.5.2.8 SERI's right of access to the supplier's facilities 6 and records for source quality verification, inspection and audits, as deemed necessary; 4.5.2.9 Extension of applicable requirements.to lower tier subcontractors and suppliers, including SERI's l6 right of access to facilities and records; 4.5.2.10 Subject to the clarification of ANSI N45.2.13, Section 8.2, given in Appendix A of this program, reporting and approving the " Accept-as-is" or " Repair" dispositions of nonconformances; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: PROCUREMENT DOCUMENT CONTROL Page 3 of 4 Policy 4 J250QAM.4A - 3
7.-_ 4.5.2.11 SERI's right to hold shipment if procurement document 6 L. - requirements, including'those for documentation, have not been fulfilled. 4.5.3 The procedures shall assure that procurement documents are subjected to technical and quality review by qualified personnel.
-and are approved by designated individuals prior to issuance.
The review and approval shall be documented and available for verification. 4.5.4 Review and concurrence with the adequacy of quality require-ments shall include. verification that the requirements are correctly stated, inspectable and controllable; that there are adequate acceptance and rejection criteria; and that the procurement documents have been prepared, reviewed and approved in accordance with.the requirements of this Policy. 4.5.5 Changes or revisions to procurement documents shall be sub-jected to an equivalent review and approval as the original documents, and such review and approval shall be documented. Exceptions to this include. changes in quantity, estimated price, cost codes, taxes, format or editorial changes that do not affect the quality of the item or service 4.5.6 Procurement documents for spare or replacement parts for safety-related structures or systems shall be subject to control at least equivalent to those required for purchase of original s equipment, or those specified by a properly reviewed and approved revision to the original requirements. i l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
. TITLE: PROCUREMENT DOCUMENT CONTROL Page 4 of 4 Policy 4 J250QAM.4A - 4
L5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS
' 5 .1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to assure that all activities affecting the quality or 6 ,
safety of the Grand Gulf Nuclear Scation are prescribed and accomplished !
.in accordance with documented instructions, procedures, drawings or other documents appropriate to the circumstances.
5 . '2 ' SCOPE This Policy delineates responsibilities and defines requirements for the development and implementation of measures designed to assure that safety-related activities are prescribed and accomplished in accordance with documented instructions, procedures or drawings. 5.3 APPLICABILITY The requirements of this Policy apply to all individuals or organizations performing activities which affect the quality of safety-related items during the operational phase of nuclear power plant activities. 5.4 RESPONSIBILITY 5.4.1 All organizations performing activities during the opera-tional phase which affect the quality of safety-related structures, systems and components are responsible for per-forming these activities in accordance with documented instructions, procedures or drawings. It is the responsibility of the managers of these organizaticus to assure the development, review, approval and control of instructions, procedures and drawings necessary to control their safety-related activities in accordance with the requirements of this Manual. It is the responsibility of the Vice President, Nuclear Engineering & Support, the Vice President, Nuclear Operations and the Vice President, Human Resources and Administration to ensure that those instructions, policies, procedures and 6 drawings that cross internal' organizational lines integrate and t function in accordance'with the above. 5.4.2 This sect $on deleted in Revision 3. 5.4.3 During the operational phase, the GGNS General Manager is responsible for assuring that adequate inspection plans; test calibration, special. process, maintenance, and repair procedures; drawings, specifications and other safety-related documents and revisions thereto are used. During the implemen-tation and testing af design changes and plant modifications, the Manager, Unit 1 Projects is responsible for assuring that inspection plans; modification and test procedures; drawings, specifications and other safety-related documents and appropriate revisions thereto are used. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Page 1 of 3 Policy 5 l J250QAM.5A - 1
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'Preoparational phase testing.is the responsibility of.the Unit 2 Construction Superintendent. The Director, Quality Programs is l6 responsible for the performance of nondestructive examinations.
The Manager, Quality Services is responsible for performing the l6 quality review of procedures, and determining that the necessary QA requirements are included. He is responsible for determining 6 the need for inspection requirements in work documents. Documents which contain administrative controls which specify quality assurance requirements will also be reviewed by the Manager, Quality Serrices. Lower tier documents may be reviewed 6 byLindividuals (other than the preparer) of the organization preparing the documents if such individuals have been indoc-trinated in the Operational Quality Assurance Program. The Manager, Quality Systems is responsible for indoctrination and l6
, certification of these individuals.
5.4.4 The Director, Quality Programs is responsible for reviewing and/or approving instructions, procedures or drawings as l6 indicated in Appendix B of this Manual and for carrying out an audit program, as described in Policy 18.0 of'this Manual, to verify conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy. 5.5 -REQUIREMENTS 5.5.1 Written instructions, procedures, drawings, or other docu-ments appropriate to the circumstances shall be used to provide measures for complying with the requirements of the Operational Quality Assurance Program. 5.5.2 Directions commensurate with the nature of the activity shall be prescribed in instructions, procedures and/or drawings for the performance of activities affecting quality. The activities shall then be performed in accordance with the instructions, procedures and/or drawings. 5.5.3 Instructions, procedures or drawings shall include.quantita-tive and/or qualitative acceptance criteria for verifying that the activities have been satisfactorily accomplished. 5.5.4 The responsible organizations shall establish procedures which define responsibilities and clearly delineate the sequence of actions to be accomplished in the preparation, review, approval and control of instructions, procedures, or drawings, and changes thereto. 5.5.5 Safety-related administrative procedures must reference documents used in their preparation. 5.5.6 When the NRC accepts changes to a policy or an appendix which result in more restrictive requirements, affected implementing procedures must be issued or revised within 120 days. If procedures cannot be revised or issued within 120 days, the man-ager of the affected organization (s) must approve a schedule OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Page 2 of 3 Policy 5 J250QAM.5A .2 i
dateiling whtn thz rsquirzd chengss will b2 accomplichtd. If the approved changes are less restrictive, the more restrictive requirements must be complied with until the old procedures are revised or new procedures are issued. When changes to procedures (more restrictive) are required by changes to NRC regulations or by Bulletins or Orders, the required procedures shall be changed within 120 days or as stipulated in SERI's 6 response to the Bulletin or Order or as set forth in the Regulation. The more restrictive time frame shall be met. I a OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Page 3 of 3 Policy 5 J250QAM.5A - 3
6.0. DOCUMENT CONTROL ~ 6.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to control safety-related documents for the Grand l6 j
/
Gulf Nuclear' Station. 6.2 SCOPE i l This Policy delineates responsibilities and defines requirements for the review, approval', issuance and control of documents and changes or , revisions thereto, which prescribe all activities affecting quality or { safety. ] 6.3 APPLICABILITY The requirements of this Policy apply to all individuals or organizations performing functions which affect safety-related structures, systems or components during the operational phase of nuclear power plant activities, i 6.4 RESPONSIBILITY )' , 6.4.1 Responsibility and authority for the control of safety- ' related documents during the operational phase are delegated to the individuals / organizations specified in Appendix B of this Manual. They are responsible for developing and implementing procedures to control the review, approval and issue of documents in accordance with the requirements of this Policy. 6.4.2 Organizations supplying material, equipment or services are responsible for complying with.the applicable requirements of this Policy as specified in the appropriate procurement documents, and for imposing them on their contractors and suppliers, as applicable. They are also responsible .for assuring, through surveillance or audits, that the requirements are being adequately implemented. ( 6.4.3 This section deleted in Revision 4. s
'6.4.4- The Director, Quality Programs is responsible for monitoring 6 document control activities and for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify compliance with Operational Quality Assurance Program requirements, including the requirements of'this Policy.
6.5 REQUIREMENTS 6.5.1 Procedures shall be established and implemented by the responsible organizations to provide for the control of documents, including changes thereto, which prescribe all . activities affecting quality or safety. These procedures are identified in Appendix B to this Manual. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DOCUMENT CONTROL Page 1 of > Policy 6 J250QAM.6A - 1 _ _________-A
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< 6.5.2 Th2 procsduras shall identify thz documsnts to ba con-trolled.. As a minimum, they shall include:
Design Specifications Design, Manufacturing, Construction and Installation Drawings Procurement Documents l Quality Assurance Manuals, Procedures and instructions y
'*' Operating Procedures Operating and Special Orders 3
I' p 3 Maintenance and Modification Procedures Manufacturing, Inspection and Test Procedures Equipment and Material Control Procedures Refueling Procedures Updated Final Safety Analysis Report 6 i Design Change.Requ'ests/ Packages i Design Change Notices Nonconformance Reports Q-List 6.5.3 The procedures shall specify the individuals or organiza-tions responsible for the preparation, review, approval, issuance and control of the documents, and revisions thereto. 6.5.4 Review of documents for adequacy shall be performed by knowledgeable personnel other than the originator. Reviewers shall have access to pertinent background information and shall have adequate understanding.of requirements and intent of the i document. 6.5.5 Documents shall be-approved for issue by authorized person-
'!. ! nel prior to release and shall be distributed in accordance with q current, documented distribution lists.
w 6.515' Master lists or.their equivalents shall be established and maintained to identify the current status of instructions, , procadures, specifications, drawings and procurement documents. The lists shall be available to responsible personnel to
, preclude the use of superseded documents.
6.5.7 Documents required to perform a specific activity shall be OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DOCUMENT CONTROL
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I available at the location where the activity is to be performed prior to commencement of the activity. Cancelled or superseded documents shall be controlled to prevent their inadvertent use. i 6.5,8 Unless delegated to other appropriately qualified organiza- i l tions, changes to documents shall be reviewed and approved by J l the same organizations that performed the original review and l approval. I i 6.5.8.1 Changes shall be included in the documents (i.e., I procedures or instructions) prior to implementation of the change, except in those cases where adequate i procedural controls allow implementation of changes l prior to revision of the original document. These 4 changes, if considered permanent, shall be incorporated into the original document in a timely manner as defined by the Quality Assurance organization. 6.5.8.2 Prior to issuance of an Operating License on Unit 2, l and after the initial use of the procedure on Unit 2, temporary changes shall be incorporated in the next revision of the affected procedure or within six months, whichever occurs first. 6.5.8.3 Unit 1 Preoperational and Startup Test procedures, including temporary changes, shall be evaluated and revised as necessary prior to being utilized on Unit 2. 6.5.8.4 Preoperational and Startup Testing Procedures are one-time-use procedures. Permanent changes are not required to be incorporated in a revision of these procedures until and unless the procedure is used again. 6.5.9 In addition to initial review and approval, procedures for operational phase activities shall be subject to subsequent periodic reviews with a specified frequency dependent on the type and complexity of the activity involved. 6.5.10 Plant procedures (as defined in Technical Specification 6.8.1) shall be reviewed by an individual knowledgeable in the area affected no less frequently than every two years or prior to use if the procedure / instruction is not used routinely to determine 6 if changes are necessary or desirable. A revision of the pro-cedure constitutes a procedure review. The two year cycle began on June 16, 1982 with issuance of the Operating License for Unit 1. 6.5.11 Following any modification to a plant system and prior to initiation of any activity affected by the modification, the applicable procedures shall be reviewed to determine if changes j are required. t OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: DOCUMENT CONTit0L ) Page 3 of 4 Policy 6 l J250QAM.6A - 3 ) - --- )
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6.5.13 Review and, approval of documents, and chan.ges thereto, shall . be documen'ted to the extent necessary to provide evidence'of complianc4 with the requirements of thie Policy'. lv. );
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l 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICEE 7.1 PURPOSE i l ( This Policy describes the Operational Quality Assurance Program measures established by SERI to control the procurement of safety-related material, 6 equipment and services for the Grand Gulf Nuclear Station. 7.2 SCOPE l 1 This Policy delineates responsibilities and defines requirements for the control of activities performed during the procurement of safety-related 1 items and services in order to assure that such items and services conform l to the procurement documents. 7.3 APPLICABILITY The requirements of this Policy apply to all safety-related material, equipment and services procured for the operational phase of nuclear power plant activities, and to all individuals or organizations participating in the procurement of such items or services. 7.4 RESPONSIBILITY 7.4.1 Responsibility and authority for controlling the procurement of safety-related material, equipment and services during the operational phase are delegated to the Director, Nuclear Support; the Director, Nuclear Licensing; the Director, Quality 6 Programs; the Director, Nuclear Plant Engineering; the GGNS General Manager (for startup testing and operations); the Director, Corporate Services; and the Manager, Unit 1 Projects. 6 It is the responsibility of these individuals to assure that the requirements of this Policy, which are applicable to their scope of activities, are implemented in accordance with written approved procedures. These activities include, as appropriate: source evaluation and selection; evaluation of objective evidence of quality furnished by the supplier; source inspection; audit, and/or source quality verification; examina-tion of items upon delivery. 7.4.2 Organizations supplying safety-related material, equipment and services are responsible for complying with the applicable requirements of this Policy, as stipulated in the procurement documents, and for imposing them upon their contractors and suppliers as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 7.4.3 The Director, Quality Programs is delegated the responsibility l6 for assuring implementation of procurement activities at the p]snt site. He is responsible for inspection as necessary to assure compliance with the requirements of this Policy. 7.4.4 The Director, Quality Programs is responsible for assuring the l6 implementation of Operational Quality Assurance Program OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 I TITLE: CONTROL OF PURCHASED MATERIAL, I EQUIPMENT AND SERVICES Page 1 of 5 Policy 7 ! J250QAM.7A - 1 }
g .. requirements relative to procurement activities, including: the quality evaluation of suppliers, source inspections, source quality _ verification and an audit program, as described in i Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements, including l the requirements of this Policy. 7.5 REQUIREMENTS 7.5.1 Heasures shall be established, implemented and documented by the appropriate organizations, consistent with their scope of responsibilities, to assure that p- ,ased material, equipment and services, whether procured directly or through contractors,_ conform to the procurement documents. These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the supplier, inspection, source quality verification and audit-at the source, and/or examination of items upon delivery. 7.5.2 Procedures shall be. established to provide for the selection of suppliers based on one or more of the following: 7.5.2.1 An evaluation of the Supplier's Quality Assurance Program / Manual / Procedures, as appropriate. 7.5.2.2 Review and evaluation of historical quality per-formance data; 7.5.2.3 Source qualification programs; 7.5.2.4 Source quality surveys; 7.5.2.5 Through the Coordinating Agency for Supplie> Evaluation (CASE) using the current revisi n of the CASE Register. When the CASE Register is used for commercial (catalog and off the-shelf) items, reference to the CASE Regieter shall provide adequate documentary evidence of source evaluation. Commercial items are those that do not require unique design or special engineering specifications; or are manufactured to national standards or by processes generally automated or_ highly repetitive; or there is little chance for error during manufacture to affect their safety-related characteristics. For items which are not commercial or which require unique design or special engineering specifications, a copy of the qualifying audit report shall be obtained and reviewed for adequacy and applicability prior to selection; i 7.5.2.6 Through the NRC's " Licensee Contractor and Vendor Inspection Status Report" (white book) for contractors with IE letters confirming Quality Assurance Program implementation; 7.5.2.7 Through documented information received from others l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 2 of 5 Policy 7 J250QAM.7A - 2
l ,? l l (architect-engineer, NSSS supplisr, other utilities,
-ASME, etc.) indicating a program meeting appropriate Quality Assurance Program requirements.
The procedures shall specify the organizations responsible for performing technical and quality evaluations, the methods of evaluation and the criteria for supplier acceptance. To facilitate pre-award supplier evaluation, telephone surveys may be conducted by Quality Assurance as established by Quality ,
' Assurance Procedures. . 0ther means of supplier pre-award j evaluation.are also established by Quality Assurance Procedures. j
- l 7.5.3' . Evaluation and selection of the supplier shall be performed l in accordance with written procedures by qualified quality assurance and technical personnel prior to or concurrent with award of the procurement document.
Items.which have been manufactured or are to be manufactured prior to this concurrence with the contractor or supplier
. Quality Assurance Program will be acceptable, but shall not be relied upon to fulfill any safety-related function until after the item is shown to meet procurement requirements (including QA Program).
7.5.4 Results of supplier evaluations shall be documented and re-tained on file. Any deficiency identified during a supplier evaluation shall be resolved early enough in the procurement cycle to prevent the deficiency from adversely affecting the quality of the purchased product or service. 7.5.5 Procedures shall be established to provide for evaluation and verification activities such as source inspections, source quality verification or audits, as necessary, to assure the quality of the item and to verify supplier conformance to procurement document requirements. 7.5.6 Inspection procedures shall specify the characteristics or processes to be witnessed, inspected or verified, and accepted. The method of verification and the extent of documentation required; and those responsible for implementing the inspection. Source quality verification procedures shall specify the characteristics or processes to Inn witnessed, observed or verified, including the method of verification and the extent of documentation required. Audits shall be performed in accordance with procedures which implement the requirements of Policy 18.0 of this Manual. I 7.5.7 The extent and frequency of evaluation and verification ac-tivities shall be a function of the relative importance, com-plexity and quality of the item procured and the supplier's quality performance. Source inspections, source quality verifications and audits may not be necessary when conformance i of an item to pro;.urement requirements can be verified by I receipt inspection, review of test reports, or other means. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL'0F PURCHASED MATERIAL, EQU1PMENT AND SERVICES Page 3 of 5 Policy 7 J250QAM.7A - 3 j
i f .,' i l 7.5.8 '.Raceipt inspection of supplier-furnishsd items shall be proce-durally controlled to assure: that the iteras are properly identified and correspond with the identification on the receiving documentation; that the. items.and acceptance records are inspected and judged acceptable in accordance with prede-termined instructions prior to installation or use; that in-spection. records or certificates ef conformance are available at the plant site prior to installation or use of the item; and, that. items accepted and released are identified.as to their inspection status prior to storage or use.
. Prior to issuance of an Operating License (OL) for Unit 2,
'Startup may install equipment or parts for which all documen-tation has not yet been. received at the plant site: such installation ed use will be on a " risk basis" such that a failure to subsequently receive all of the required documenta-tion may require the equipment or parts to be removed'and may invalidate any testing which has been accomplished. Startup may operate such installed equipment, but they may not rely on the affected. system to fulfill its safety-related function.
Controls in Plant and Quality Assurance Procedures will cover this conditional release process, and will assure that the applicable procedural and administrative aspects of this Policy (7.5.8) and Policies 8.5.8, 14.5.5 and 15.5.5 of the Operational Quality Assurance Program are fulfilled. 7.5.9 Records required to be furnished by the supplier shall be specified in the procurement documents, as stipulated in Policy 4.0 of this Manual. These records shall be reviewed and accepted by personnel specifically designated to perform this activity. These personnel will be designated in accordance with applicable procedures. Other SERI organizations may be used l. 6 when their areas of exp1ertise provide an adequate basis for such a review. (e.g., Nuclear Services & Fuels could review records from nuclear fuel suppliers.) 7.5.10 The records shall include, as a minimum, documentation that identifies the purchased item and the specific procurement requirements (e.g., codes, standards, specifications) met; and documentation which identifies procurement requirements which have not been met. Subject to the clarification of ANSI N45.2.13, Section 8.2, given in Appendix A of this Manual, such documentation shall include a description of those non-conformances dispositioned " accept-as-is" or " repair." i 7.5.11 Where supplier certificates of conformance are used to j identify the requirements met by the item, the certificates of } conformance shall be periodically evaluated by audits, ' independent inspections or tests to assure that they are valid. 7.5.12 Spare or replacement parts for safety-related systems or components shall be procured, fabricated and controlled in accordance with present QA programmatic controls and technical requirements at least equivalent to those used for the original j i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 ! TITLE: CONTROL OF PURCHASED MATERIAL, l EQUIPMENT AND SERVICES Page 4 of 5 Policy 7 l I J250QAM.7A - 4 1
item, or those specified by a properly reviewzd and approved revision to the original requirements. 7.5.13 When a supplier is removed from the Qualified Suppliers List, procedures shall assure that any outstanding purchase orders for that supplier are reviewed, and appropriate action taken to assure that materials subsequently received.from that supplier are handled and dispositioned as nonconformances. 6 7.5.14 This section deleted in Revision 6. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 5 of 5 Policy 7 J750QAM.7A - 5
l 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS 8.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures 1 established by SERI to provide for the identification and control of l6 j safety-related material, parts and components for the Grand Gulf Nuclear j Station. 8.2 SCOPE This Policy delineates responsibilities and defines requirements for the identification and control of safety-related items in order to assure that only correct and accepted items are used or installed. 8.3 APPLICABILITY The requirements of this Policy apply to all individuals or organizations participating in the procurement, fabrication, receipt, storage, installation, operation, modification or repair of safety-related items during the operational phase of nuclear power plant activities. 8.4 RESPONSIBILITY 8.4.1 Recponsiblity and authority for the identification and control of materials, parts and components during the opera-tional phase are delegated to the GGNS General Manager except, during implementation and testing of design changes and plant modifications, the Manager, Unit 1 Projects is responsible for this activity. They are responsible for assuring that procedures are established to address the applicable requirements of this Policy, and that identification and control of safety-related items is maintained in accordance with the procedures from procurement of the item through fabrication, storage, installation and use. 8.4.2 Organizations supplying safety-related material, equipment and services are responsible for complying with the applicable requirements of this Policy, as stipulated in the procurement documents, and for imposing them on their contractors and suppliers as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 8.4.3 The Manager, Quality Systems and the Manager, Quality Services l6 are delegated the responsibility for assuring implementation of identification and control requirements for items at the plant t site by receipt inspection and other inspections, respectively. The Manager, Quality Fervices is responsible for reviewing 6 procedures and work documents to the extent necessary to verify j conformance to the applicable requirements, of this Policy. l 8.4.4 The Director, Quality Programs has the responsibility for l6 carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with the requirements of the OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: IDENTIFICATION AND CONTROL OF ) MATERIALS, PARTS AND COMPONENTS Page 1 of 2 Policy 8 : l J250QAM.8A - 1 l
Operationsi Quality Assurance Program, including the requirements of this Policy. 8.5 REQUIREMENTS 8.5.1 Procedures shall be established and implemented to provide for the identification and control of safety-related materials, parts and components, including partially fabricated subassem-blies, in order to assure that only correct and accepted items are used and installed. 8.5.2 The procedures shall be developed by the appropriate organ-izations to cover the various stages from procurement of the item through fabrication, receipt, storage, installation, use, modification or repair. 8.5.3 The procedures shall provide assurance that a unique identi-fication of items is maintained, such as by part number, serial number, heat number, drawing identification number or other appropriate means. 8.5.4 The procedures shall assure that identification is maintained either on the item or on records traceable to the item. Physical identification, such as by marking or tagging, shall be used to the maximum extent practical. 8.5.5 When specified by codes, standards, procurement documents, or other requirements; identification shall be such that items are traceable to appropriate documentation (e.g. specifications, drawings, purchase orders, manufacturing and inspection documents, nonconformance reports, physical or chemical mill test reports). 8.5.6 Where identification marking is employed, the marking shall be clear, unambiguous and indelible, and shall be applied in such a manner as not to affect the fit, function or quality of the item. 8.5.7 Markings shall be transferred to each part of an item, if subdivided, and shall not be obliterated or hidden by surface treatment or coatings unless other means of identification are substituted. 8.5.8 Procedures shall provide for the verification and documen-tation of correct identification of items prior to release for fabrication, assembling, shipping, storage or installation. Items may be conditionally released under adequate procedural controls. These controls shall assure that the system, subsystem, or component that receives such items is considered inoperable, no reliance shall be placed on such system, subsystem, or component for fulfilling their intended safety function. The Manager, Quality Services shall review and 6 concur with conditional releases. Applicable procedural and administrative aspects of this Policy (8.5.8) and Policies 7.5.8, 14.5.5 and 15.5.5 of the Operational Quality Assurance Program shall be fulfilled. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS Page 2 of 2 Policy 8 J250QAM.8A - 2 _ _ _-__ a
9.0 CONTROL OF SPECIAL PROCESSESL 9.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to provide for the control of safety-related special l6 processes for the Grand Gulf Nuclear Station. 9.2 SCOPE This Policy delineates responsibilities and defines requirements for the control of special processes including, but not limited to, cleaning, heat treating, welding, nondestructive examination or unique fabricating or testing processes which require interim in-process controls. 9.3 APPLICABILITY The requirements of this Policy apply to all individuals or organizations performing special processes during the operational phase of nuclear power plant activities under this Operational Quality Assurance Program. 9.4 RESPONSIBILITY 9.4.1 Responsibility and authority for the control of special processes, except nondestructive examination, at the plant site during the operational phase are delegated to the GGNS General Manager. During the implementation and testing of design changes and plant modifications, the Manager, Unit 1 Projects is responsible for ensuring that special processes are controlled in accordance with procedures developed by the GGNS General Manager. Responsibility and authority for the control of nondestructive examination are delegated to the Director, 6 Quality Programs. They are responsible for assuring that special processes are performed in accordance with procedures and instructions which implement the requirements of this Policy. They are also responsible for assuring that contractors who are delegated responsibilities for the onsite performance of special processes, impose the applicable requirements of this Policy on their internal operations and on their contractors and _ suppliers. 9.4.2 Offsite organizations responsible for the performance of l special processes shall be subject to the applicable require- j ments of this Policy as specified in the appropriate procurement documents. Individuals or organizations responsible for the preparation of procurement documents shall assure that the applicable requirements of this Policy are included, as stip-ulated in Policy 4.0 of this Manual. 1 l 9.4.3 The Manager, Quality Services is responsible for reviewing Plant Administrative Procedures and Nuclear Plant Engineering l6 Procedures, controlling special processes, and for reviewing 6 work documents and inspection of special process activities, including nondestructive examinations, to the extent necessary to verify conformance to the requirements of this Policy. Lower OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF SPECIAL PROCESSES Page 1 of 2 Policy 9 J250QAM.9A - 1
tier instructions may be reviewed by individuals (other than the preparer) of the organization preparing the documents, if such individuals have been indoctrinated in the Operational Quality Assurance program. The Manager, Quality Systems is responsible 6 for indoctrination and certification of these individuals. 9.4.4 The Director, Quality Programs has the responsibility for 6 monitoring the special process control measures of offsite organizations, and for carrying out an audit program, as described in Policy 18.0 of this Manual; te verify conformance with the requirements of the Operational Quality Acsurance Program, including the requirements of this Policy. 9.4.5 The Director, Nuclear Plant Engineering has the responsibility for assuring that special process standards and specifications are established to address the applicable requirements of this Policy. He is also responsible for reviewing and approving all contractor special process standards prior to use at the Plant Site. 9.5 REQUIREMENTS 9.5.1 Procedures shall be developed and implemented by the respon-sible organizations to assure the control of special processes including, but not limited to, chemical cleaning, heat treating, welding and nondestructive examination. 9.5.2 Special processes shall be accomplished under controlled conditions in accordance with applicable codes, standards, specifications or other special requirements. 9.5.3 Special processes shall be performed by personnel qualified in accordance with applicable codes, standards, specifications, or other special requirements. 9.5.4 Equipment and procedures used in the performance of special processes shall be qualified in accordance with applicable codes, standards, specifications or other special requirements. 9.5.5 Qualification records of personnel, equipment and procedures associated with special processes shall be established, maintained and kept current. 9.5.6 For special processes not covered by existing codes or standards, or where item quality requirements exceed the requirements of existing codes or standards, the necessary qualifications of personnel, procedures and equipment shall be defined and documented. o OPERATIONAL QUALITY ASSURANCE MANUAL Rev 6 3 TITLE: CONTROL OF SPECIAL PROCESSES ! Page 2 of 2 Policy 9 : J250QAM.9A - 2 l l h l
'10.0 INSPECTION 10.1 PURPOSE.
l This, Policy describes the Operational Quality Assurance Program L measures established by SERI to provide for the inspection of activ- 6 ities affecting the safety of the Grand Gulf Nuclear Station.
'10.2 SCOPE This Policy delineates responsibilities and defines requirements for the development and implementation of a program for the inspection of activities affecting safety in order to verify conformance to the documented instructions, procedures and drawings for accomplishing the activity.
10.3 APPLICABILITY The requirements of this Policy apply to.all inspections performed on safety-related structures, systems or components during the opera-tional phase of nuclear power plant activities. 10.4 RESPONSIBILITY 10.4.1 Overall responsibility and authority for establishing and , i implementing an inspection program at the plant site during the operational pha,e are delegated to the Director, 6 Quality Programs and the GGNS General Manager. During the implementation and testing of design changes and plant modifications, the Manager, Unit 1 Projects, in conjunction with the Director, Quality Programs, is responsible for 6 these activities. The Director, Quality Programs is responsible for assuring that procedures / instructions developed for the performance of work operations include appropriate inspection requirements and for assuring that inspections and examinations are performed and documented where necessary to assure quality. The GGNS General Manager { and the Mrnager, Unit 1 Projects (for implementation and ] testing os design changes and plant modifications) are responsible for assuring that measurements and tests of ! materials, products or activities are performed and docu- ) mented for each work operation where necessary to assure i quality. 10.4.2 The Managar, Quality Services is delegated the responsi- l bility for assuring that the onsite inspection program 6 ! (except for receipt inspection) is carried out in i accordance with the requirements of this Policy. The Manager, Quality Systems is delegated the responsibility for assuring that the onsite receipt inspection program is 6 carried out in accordance with the requirements of this ; policy. The Manager, Quality Services is responsible for reviewing Plant Administrative Procedures which control work instructions, modification and repair instructions; preoperational and startup test procedures; and other OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION Page 1 of 5 Policy 10 J250QAM.10A - 1
documents to assure that they contain the appropriate inspection requirements. Lower tier instructions may be reviewed by individuals (other than the preparer) of the organization preparing the documents if such individuals have been indoctrinated in the Operational Quality Assurance Program. The Manager, Quality Systems is 6 E responsible for indoctrination and certification of these L individuals. The Manager, Quality Services is responsible for developing procedures for the performance of all quality inspections. The Manager, Quality Systems and the 6 Manager, Quality Services are responsible for implementing inspection procedures (receipt inspection and other inspections, respectively). The coordination of activities concerning the training and certification of all quality inspectors shall be accomplished by the Manager, Quality 6 Systems; Level III inspectors are appointed. All safety-related work authorizations will be reviewed by the Manager, Quality Services for determination of any quality 6 inspection requirements. Procedures or work authorizing documents which control repetitive tasks are reviewed initially and when revised for inclusion of inspection E requirements. 10.4.3 SERI may delegate the responsibility for implementing l6 certain portions of the inspection program to other organi-zations. However, SERI retains the ultimate responsibility 6 for assuring thet all aspects of the inspection program are carried out. At the plant site, the Manager, Quality Systems and the Manager, Quality Services are responsible 6 for assuring that inspection activities (receipt inspection and other inspection, respectively) assigned to outside organizations are accomplished in accordance with the requirements of this Policy. 10.4.4 Organizations supplying safety-related material, equipment and services are responsible for complying with the appli-cable requirements of this Policy, as stipulated in the procurement documents, and for imposing them upon their contractors and suppliers as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 10.4.5 The Director, Quality Programs is responsible for qualifi- l6 cation of inspectors and has the responsibility for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with the requirements of the Operational Quality Assurance Program, including the requirements of this Policy. 10.5 REQUIREMENTS 10.5.1 Inspection requirements shall be included in applicable specifications, drawings, procedures, instructions or other documents which prescribe and control safety-related activities. OPERATIONAL QUALITY ASSURANCE MANUAL Rev, 6 I TITLE: INSPECTION Page 2 of 5 Policy 10 J250QAM.10A - 2
I 1-10.5.2 These inspection requirements shall be translated into a documented inspection program, to be implemented by the
. responsible organizations in accordance with written pro-cedures, which verifies that the activities are accomplished in accordance with the specifications, drawings, procedures I or instructions.
10.5.3 Inspection procedures, instructions or checklists shall include provisions, as required, for the following: l 10.5.3.1 Identification of characteristics and activities to be inspected; 10.5.3.2 Identification of the individuals or organizations responsible for performing the inspection activities; 10.5.3.3 -Identification of acceptance and rejection criteria; 10.5.3.4 A description of the method of inspection; 10.5.3.5 Recording evidence of the completion and verification of a manufacturing, inspection or test operation; 10.5.3.6 Recording the identity of the inspector or data recorder and the results of the inspection operation; and, 10.5.3.7 Specifying the necessary measuring and test equipment, including the accuracy requirements. Accuracy may be specified by requiring a specific model or type of instrument. 10.5.4 The applicable drawings and specifications shall be avail-able for use with the inspection procedures, instructions or checklists when an inspection operation is being carried out. 10.5.5 Inspections shall be performed by qualified personnel who , are independent of those individuals who performed the activity being inspected. Inspection of operating activ-ities (work functions associated with normal operation of the plant, routine maintenance, and certain technical ser-vices routinely assigned to the onsite operating organiza-tion) may be conducted by second-line supervisory personnel or by other qualified personnel not assigned firsc-line supervisory responsibility for conduct of the work. l When inspections of operating activities are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following controls shall be met: OPERATIONAL QUALITY ASSURANCE MANLAL Rev. 6 TITLE: INSPECTION Page 3 of 5 Policy 10 J250QAM.10A - 3
l L . g 10.5.5.1 Tha' quality of tha~ work can be demonstrated through a functional test when the activity involves breaching of pressure retaining items; I 10.5.5.2 The qualification criteria for inspection personnel ate reviewed and found acceptable by the Quality Assurance organization prior to-initiating the inspection. + . 10.5.6 Personnel performing inspections.which require specialized j i qualifications or skills shall be qualified in accordance with-applicable codes, standards or licensing requirements, I and.their qualifications and certifications shall be'docu- ) mented and kept current. 10.5.7 If. mandatory inspection hold points are required, the spe-cific hold points shall be specified in the appropriate
' drawings,. specifications,' procedures or instructions. The inspection program shall provide assurance that work does, not. progress beyond the hold point until released ~by the designated-authority, and that required. notification and acknowledgement has been satisfied prior to work-continuing.
i 10.5.8 If inspection'is impossible or disadvantageous, indirect control shall be' provided by monitoring processing inethods, equipment, and personnel. Inspection and process monitoring shall be utilized if control is inadequate without both. 10.5.9 Instructions addressing maintenance, modifications, repairs or replacements shall be reviewed by qualified personnel (other than the preparer) who have the knowledge required'to determine the need for inspection, identifica-tion of inspection personnel, and documenting inspection results. Lower tier instructions may be reviewed by individuals (other than the preparer) of the organization preparing tne documents if such individuals have been indoctrinated in the Operational Quality Assum nee Program. The Manager, Quality Systems is responsible fc. ir.doctrina- 6 tion and certification of these individuals. 10.5.10 . Modifications, repairs and replacements shall be inspected ] " in accordance with the original design and inspection requirements or documented engineering approved alternatives. 10.5.11 Inspection data and results shall be evaluated by designated personnel to assure that the inspection objectives have ] been met and that items requiring action or follow-up are l identified and documented. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION Page 4 of 5 Policy 10 J250QAM.10A - 4 _ __. _______________-________a
1 10.5.12 Records shall be kept in sufficient detail to provide adequate confirmation of the inspection program. Records shall be maintained in accordance with Policy 17.0 of this q Manual, j 1 10.5.13 Inspections need not be performed for each specific work l activity. Procedures used for assigning inspections shall j require the following to be evaluated in assignment of i inspections. 10.5.13.1 Complexity, magnitude or criticality of the work. j
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10.5.13.2 Documented engineering inspection requirements. 10.5.13.3 Design organization inspection requirements. 10.5.13.4 Components safety impact. 10.5.14 Inspections shall be performed on repetitive, routine and rework items as determined by the Manager Quality 6 Services. l l l l l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 l TITLE: INSPECTION l Page 5 of 5 Policy 10 J250QAM.10A - 5
11.0 TEST CONTROL 11.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to control testing of safety-related 6 structures, systems and components for the Grand Gulf Nuclear Station. 11.2 SCOPE This Policy delineates responsibilities and defines requirements for the establishment and implementation of a test program to assure that testing required to demonstrate that safety-related items will perform satisfactorily in service is identified, accomplished and l documented. 11.3 APPLICABILITY The requirements of this Policy apply to all testing perfor,ed on safety-related structures, systems and components during the opera-tional phase of nuclear power plant activities and also to required preoperational testing. 11.4 RESPONSIBILITY 11.4.1 The responsibility and authority for the development and implementation of maintenance and surveillance testing programs during the operational phase are delegated to the GGNS General Manager. The responsibility and authority for the development and implementation of testing programs for design changes and plant modifications are delegated to the Manager, Unit 1 Projects. The responsibility and authority for the development and implementation of preoperational phase testing programs are delegated to the Unit 2 Con-struction Superintendent. They are responsible for assuring that the test programs are established and implemented in accordance with procedures and instructions which address the requirements of this Policy. They are also responsible for assuring that contractors who are delegated onsite testing responsibilities impose the applicable requirements of this Policy on their internal operations and on their contractors or suppliers. l 11.4.2 Organizations responsible for conducting offsite testing are subject to the applicable requirements of this Policy as specified in the appropriate procurement documents. Individuals or organizations responsible for the preparation of procurement documents shall assure that the applicable requirements of this Policy are included, as stipulated in Policy 4.0 of this Manual. 11.4.3 This section deleted in Revision 3. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: TEST CONTROL J250QAM.11A - 1
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~11.4.4 The Manager, Quelity Servicas is delegated the responsi- 6 bility for assuring implementation of test activities at the plant site by inspection. . He is responsible for 6 i reviewing test programs and Plant Administrative Procedures which control testing tol verify conformance to the require- ,
ments of this Policy. Lower tier instructions may be J reviewed by individuals (other than the preparer) of the organization preparing the documents if such individuals have been indoctrinated in the Operational Quality Assurance Program. The Manager, Quality Systems is respons- 6 ible for indoctrination and certification of these individuals. i 6 11.4.5. The Director. Quality Programs has the responsibility for
. carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance.with the requirements of.the Operational' Quality Assurance Program, including the requirements of;this Policy.
11.5 REQUIREMENTS 11.5.1 A test program shall be established and implemented to
. assure that testing required to demonstrate that a safety- I
-related structure, system or component will perform satisfactorily in service is identified and documented, and that the testing-is performed in accordance with written, controlled test procedures. .
11.5.2 The test program shall be implemented by the responsible organizations to cover all required testing, including pro-totype tests, preoperational tests, initial start-up tests, surveillance tests, and tests associated with plant maintenance and modifications during the operational phase. 11.5.3 This section deleted in Revision 3. 11.5.4 This-section deleted in Revision 3. 1 11.5.5 Surveillance testing during the operational phase shall be performed to provide assurance that failures or substandard ' performance do not remain undetected and that the required reliability of safety-related systems is maintained. A' l surveillance testing schedule (s) shall be established reflecting the status of all planned in-plant surveillance tests and inspections. Frequency of surveillance tests may be related to the results of reliability analyres, the frequency and type of service, or age of the item, as appropriate. 11.5.6 Tests performed following plant modifications, repairs or replacements shall be conducted in accordance with the original design and testing requirements or engineering approved, documented alternatives. Testing shall be suffi-cient to confirm that the modifications or changes 1 i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: TEST CONTROL Page 2 of 3 Policy 11 J250QAM.11A - 2 i
i 1 reasonably produce expected results and that the change does not reduce safety of operations.
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11.5.7 Written procedures for performing the tests shall incorpo- ) rate or reference the following, as applicable: ! 11.5.7.1 A description of test objectives; I 11.5.7.2 The requirements and acceptance limits contained in applicable design and procurement documents; 11.5.7.3 Instructions for performing the test; 11.5.7.4 Test prerequisites (e.g. calibrated instrumen-tation; adequate and appropriate equipment; trained, qualified, and licensed or certified personnel; assurance of completeness of the item to be. tested; suitable and controlled environ-mental conditions; and provisions for data collection and storage); 11.5.7.5 Hold points or witness points for inspection by designated personnel; 11.5.7.6 Acceptance and rejection criteria; 11.5.7.7 Methods of documenting or recording test data and results. 11.5.8 The documented test results shall be evaluated and their acceptability determined by qualified individuals or organ-izations as designated in the procedures. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: TEST CONTROL Page 3 of 3 Policy 11 J250QAM.11A - 3
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12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 PURPOSE' This Policy describes the Operational Quality Assurance Program measures established by SERI to. provide for the control of measuring 6 and test equipment used in the performance of safety-related activ-ities for the Grand Gulf Nuclear Station. 12.2 SCOPE This Policy delineates re,sponsibilities and defines requirements for the calibration, maintenance and control of measuring and test equip-ment used in safety-related applications in order to assure the re-quired accuracy of such equipment. 12.3 APPLICABILITY The requirements of this Policy apply to all tools, instruments, testing equipment and measuring and control devices used in inspec-tions, measurements, tests or monitoring of safety-related components, systems or structures during the operational phase of nuclear power plant activities. The requirements of this Policy do not apply to rulers, tape measurers, Icvels and other such devices if normal commercial prac-tices provide sufficient accuracy. 12.4 RESPONSIBILITY 12.4.1 Responsibility and authority for the control of measuring and test equipment at the plant site during the operational phase are delegated to the GGNS General Manager. During implementation and testing of design changes and plant i modifications, the Manager, Unit 1 Projects is responsible for ensuring that all M&TE utilized are controlled in accordance with procedures developed by the GGNS General Manager. They are responsible for assuring that procedures are developed to implement the requirements of this Policy. l 12.4.2 Organizations supplying materials, equipment or services are re:ponsible for complying with the applicable require-ments of this Policy, as specified in the appropriate procurement documents and for imposing them on their I contractors and suppliers, as applicable. They are also ] responsible for verifying, through surveillance or audits, ; that the requirements are*being adequately implemented. 12.4.3 The Manager, Quality Systems is delegated the responsi-bility for assuring by audit the control of measuring and test equipment at the plant site. The Manager, Quality 6 Services is delegated the responsibility for assuring by inspection the control of measuring and test equipment at the plant site. The Manager, Quality Services is responsi-ble for reviewing Plant Administrative Procedures which OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF MEASURING AND TEST EQUIPMENT Page 1 of 3 Policy 12 J250QAM.12A - 1
L govern equipm nt control instructions to verify conformance
.to the requirements of this Policy. Lower tier instruc-tions may be reviewed by individuals (other than the i I
preparer) of the organization preparing the documents, if such individuals have been indoctrinated in the Operational Quality Assurance Program. The Manager. Quality Systems is responsible for indoctrination and certification of 6 these individuals. I 12.4.4 The Director, Quality Programs has the responsibility for 6 .! carrying out an audit program, as described in Policy 18.0 I of this Manual, to verify conformance with the requirements of the Operational Quality Assurance Program, including the requirements of this Policy. I 12.5 REQUIREMENTS ; 12.5.1 Organizations parforming safety-related functions which j require the use of measuring and test equipment such as ; instruments, control devices, gages, tools, fixtures, cal- ! ibration standards and nondestructive test equipment shall -) establish and implement procedures to control the calibra- i tion, maintenance-and use of such equipment. ! 12.5.2 ' Procedures shall assure that measuring and test equipment used for measurements, tests or calibrations is of the proper range and type and is controlled, calibrated, adjusted and maintained at specific intervals, or prior to use, to assure necessary accuracy. 12.5.3 The method and interval of calibration shall be established for each device or generic grouping thereof, and shall be based on the type of equipment, stability and reliability characteristics, required accuracies and other conditions affecting calibration. 12.5.4 Procedures shall provide methods for the positive identifi-cation of all measuring and test equipment included under the calibration system, documentation of its calibration status; and traceability to documented calibration test data. 12.5.5 Installed operations measuring and test equipment requiring calibration shall be labeled, tagged or otherwise controlled in accordance with written, approved procedures to assure that approved calibration intervals are not exceeded. Portable measuring and test equipment may be similarly controlled; but shall, as a minimum, be clearly labeled to indicate the date on which the current calibration expires. Portable measuring and test equipment that has exceeded the approved calibration interval shall not be used for measurements or tests. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF MEASURING AND TEST EQUIPMENT Page 2 of 3 Policy 12 J250QAM.12A - 2
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i l 12.5.6 Calibration standards'shall be traceable to nationally j recognized standards; or, where national standards do not ~! exist, provisions shall be established to document the basis for calibration. In order to establish this traceability, calibrating standards should have a greater accuracy than the standard being calibrated and possess , i sufficient range and stability.to assure that.the standard being calibrated is within the required tolerance. f Calibrating standards with the same accuracy as the j standard being calibrated shall be allowed if it can be j shown to be adequate for the requirements and the basis of acceptance is documented and evaluated by a technically knowledgeable individual and authorized by responsible management. l 12.5.7 Measuring and Test Equipment (M&TE) should be calibrated against standards (for the purpose of calibration M&TE is defined as that equipment, whether permanently installed or portable, used to calibrate permanent plant devices) that have an accuracy of at least four times the required accu-racy of the M&TE being calibrated. A standard of lesser accuracy shall be allowed provided that the basis of acceptance is documented, evaluated for adequacy by a technically knowledgeable individual and authorized by responsible management. Calibration of permanent plant devices shall be against M&TE having sufficient accuracy, greater than the device being calibrated, to assure that the system containing the device is within the specified system tolerance. The basis for determining the greater than accuracy of the M&TE used shall be reproducible, either by engineering demonstration or documentation. When an accuracy is specified in the Technical Specifications or bases thereof, this accuracy may be used in lieu of one determined by engineering demonstration or documentation. 12.5.8 Measures shall be established to assure that, if a piece of measuring and test equipment is found to be out of calibra-tion, an evaluation shall be made and documented, in accor- ; dance with Policy 15.0, to verify the validity of previous l tests and the acceptability of devices tested since the time of the last calibration. A permanent plant device i which is found out of calibration, but within the tolerance I given in the Technical Specifications, may be adjusted. l Such actions shall be documented, but they need not be l evaluated or processed as specified in Policy 15.0. 12.5.9 If any calibration, testing or measuring device is consis-tently found to be out of calibration, it shall be repaired or replaced. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CONTROL OF MEASURING AND TES' EQUIPMENT Page 3 of 3 Policy 12 J250QAM.12A - 3
13.0 HANDLING, STORAGE AND SHIPPING 13.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to control the handling, storage and 6 shipping of safety-related materials, components and systems for the Grand Gulf Nuclear Station. 13.2 SCOPE This Policy delineates responsibilities and defines requirements for handling, storage and shipping, including cleaning, packaging and preservation of safety-related items in order to assure that the requisite quality of the items is maintained until they are used or incorporated into the nuclear power plant. 13.3 APPLICABILITY The requirements of this Policy apply to all individuals or organiza-tions participating in the cleaning, handling, packaging, preserva-tion, shipping and storage of safety-related items during the operational phase of nuclear power plant activities. 13.4 RESPONSIBILITY 13.4.1 During the operational phase at the plant site, and excluding preoperational testing, the responsibility and authority for control of handling, storage and shipping, including cleaning and preservation, are delegated to the GGNS General Manager. During the implementation and testing of design changes and plant modifications, the Manager, Unit 1 Projects is responsible for these activities. The responsibility and authority for the control of handling, storage and shipping, including cleaning and preservation, involved with preoperational phase testing programs, are delegated to the Unit 2 Construction Superintendent. They are responsible for assuring that procedures are established to address the applicable requirements of this Policy and that work and inspection activities are accomplished in accordance with the established procedures. 13.4.2 Organizations supplying safety-related material, equipment and services are responsible for complying with the appli-cable requirements of this Policy, as stipulated in the procurement documents, and for imposing them on their con-l tractors and suppliers as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 13.4.3 The Manager, Quality Services is delegated the respons-ibility for inspection of the control of handling and storage at the plant site (excluding the warehouse-related) 6 including during preoperational and startup testing. The Manager, Quality Systems is delegated the responsibility OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: HANDLING, STORAGE AND SHIPPING Page 1 of 3 Policy 13 J250QAM.13A - 1
i for wzrshou:t-reletsd in2psetion (including receipt inspection) of the control of handling, storage and 6 shipping at the plant site including during preoperational and startup testing. The Manager, Quality Services is responsible for reviewing Plant Administrative Procedures to verify conformance to the applicable requirements of this Policy. Lower tier instructions may be reviewed by individuals (other than the preparer) of the organization preparing the documents, if such individuals have been , indoctrinated in the Operational Quality Assurance Program. l The Manager, Quality Systems is responsible for indoctrina- l6 ( tion and certification of these individuals. l 13.4.4 The Director, Quality Programs has the responsibility for 6 I carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with the requirements of the Operational Quality Assurance Program, including the requirements of this Policy. I 13.5 REQUIREMENTS 13.5.1 Procedures shall be established to control handling, storage and shipping, including cleaning, packaging and preservation of safety-related materials, components and systems. The procedures may be developed to cover generic classifications of items which require equivalent levels of protection and control during handling, storage and shipping. Classified items shall be restricted to that level or higher for each of the particular handling, storage and shipping operations; and a change in the classification of an item shall only be made in accordance ; with a written, engineering approved procedure. 13.5.2 The procedures shall be developed by the appropriate organizations to cover the various stages from fabrication , or manufacture of the items to incorporation into the plant. 13.5.3 The procedures shall address the applicable design and regulatory requirements; codes and standards; and manufac-turer's recommendations as approved by SERI engineering 6 personnel for the prevention of danage, deterioration or loss prior to installation or use. Source quality verifi-cation or inspection operations necessary to verify conform ance to the established criteria shall be included in . I proceduren, and documentation of the verification activities shall be required. 13.5.4 Packaging and preservation procedures shall provCde assur-ance of adequate protection against corrosion, contamina-tion, physical damage or any effect which would lower the quality of the item or cause it to deteriorate during ship-ping, handling or storage. Special protective environments, special coverings, inert gas atmosphere, allowable moisture OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: HANDLING, STORAGE AND SHIPPING Page 2 of 3 Policy 13 J250QAM.13A - 2
contznt, and temperature 1sysl chall be epscified as required and'their existence verified and documented. 13.5.5 Cleaning procedures shall provide assurance that necessary cleaning operations are carried out prior to packaging, storage or installation. The level of cleanliness required and verification and documentation requirements shall be specified in the procedures. 13.5.6 Procedures shall be provided to assure that proper marking and labeling of items and containers is accomplished to provide identification and necessary instructions during packaging, shipment and storage. 13.5.7 Measures for receipt inspection of items, disposition of received items and control of nonconforming items shall be addressed in procedures which implement the applicable requirements of Policies 7.0 and 15.0 of this Manual. 13.5.8 Detailed handling procedures shall be provided for all items that require special handling. Special handling tools and equipment shall be provided and controlled to ensure safe and adequate handling. These tools and equip-ment shall be maintained, inspected and tested in accordance with written procedures at established intervals to ensure their reliability and availability for use, j 13.5.9 Storage procedures shall provide for methods of storage and the control of items in storage which will minimize the possibility of damage or deterioration during storage. Periodic inspections of storage areas shall be performed i and documented to verify compliance with storage procedures. Release of items for installation shall also be procedurally controlled. 13.5.10 Until Unit 2 has completed construction and all material has been turned over to SERI, administrative controls l6 shall be established for the transfer of Bechte.1 procured and controlled items to the SERI Operational Quality 6 Assurance Program. I l l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: HANDLING, STORAGE AND SHIPPING Page 3 of 3 Policy 13 J250QAM.13A - 3
14.0 INSPECTION, TEST AND OPERATING STATUS 14.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to identify and control the inspection, j6 test and operating status of safety-related structures, systems and components for the Grand Gulf Nuclear Station. 14.2 SCOPE This Policy delineates responsibilities and defines requirements for identifying and controlling the inspection, test and operating status of sarety-related items in order to assure that required inspections and tests are performed and the acceptability of items is known, and to prevent the inadvertent operation of items which are in a con-trolled status. 14.3 APPLICABILITY The requirements of this Policy apply to all individuals or organiza-tions performing functions on safety-related structures, systems and components during the operational phase of nuclear power plant activities. 14.4 RESPONSIBILITY 14.4.1 During the operational phase, responsibility and authority for identifying and controlling the test and operating status of safety-related items, excluding preoperational testing, are delegated to the GGNS General Manager. The responsibility and authority for identifying and control-ling the test and operating status of safety-related items involved in preoperational phase testing programs are delegated to the Unit 2 Construction Superintendent. The 6 Director, Quality Programs has the responsibility and authority for identifying and controlling the inspection, test, and operating status of safety-related items. They are responsible for assuring that procedures are developed and implemented to address the applicable requirements of this Policy. 14.4.2 Organizations supplying safety-related material, equipment and services are responsible for complying with the appli-cable requirements of this Policy, as stipulated in the procurement documents, and for imposing them on their con-tractors and suppliers as applicable. They are also re-sponsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 14.4.3 The Manager, Quality Services is responsible for reviewing 6 Plant Administrative Procedures to verify conformance to the applicable requirements of this Policy. Lower tier instructions may be reviewed by individuals (other than the preparer) of the organization preparing the documents if OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION, TEST AND OPERATING STATUS Page 1 of 3 Policy 14 J250QAM.14A - 1
cuch individutis have bazn indoctrinated in the 0parationsi , Quality Assurance Program. The Manager, Quality Systems is l6, ,. q responsible for indoctrination and certification of these individuals. ) 14.4.4 The Director, Quality Programs has the responsibility for l6 carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy. 14.5 REQUIREMENTS 14.5.1 Procedures shall be established and implemented by the organizations responsible for the fabrication, storage, installation, test, and operation of safety-related struc-tures, systems and components to assure that the inspection, test and operating status of such items is identified., controlled and made known to affected organizations. 14.5.2 The procedures shall require that the status of inspections and tests be indicated by the use of appropriate status indicators such as stamps, tags, labels, routing cards, shop travelers, or other suitable means. Suitable means may include identification numbers which are traceable to inspection and test records. 14.5.3 The procedures shall identify the status indicator to be used and provide for its control, including responsibility and authority for application and removal. 14.5.4 Bypassing of required inspections, tests or other critical operations shall be procedurally controlled with concurrence by Quality Assurance. Where r.ecessary to preclude inadvertent bypassing of required inspections and tests, the procedures shall prcvide for the identification of items which have passed such inspections and tests. 14.5.5 In cases where documentary evidence is not available.to confirm that an item has passed required inspections and tests, that item shall be considered nonconforming and i i processed in accordance with Policy 15.0. Affected systems shall also be evaluated for operability in accordance with the Technical Specifications and reliance shall not be placed on any such systems (which are evalucted as inoperable) to fulfill their intended safety functions. 4 14.5.6 Procedures shall be provided to require identification of the operating status of systems, components, controls, or support equipment in order to prevent inadvertent or unauthorized operation. These procedures shall require control measures, such as locking or tagging to secure and identify equipment in a centro 11ed status. Independent OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: INSPECTION, TEST AND OPERATING STATUS Page 2 of 3 Policy 14 J250QAM.14A - 2 _ _______________A
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a re . g, bI)b ) verification'shall be. required, where appropriate, to ! t ensure that:necessary measures, such as. tagging equipment, i have been implemented correctly.
" ~L 14.5.7. Temporary. modifications shall be controlled by approved f
.proceduresL which: include a requirement for independent I verification.. A log shall be maintainedHof the current status of such temporary. modifications.
4 i 14.5.8 ' Nonconforming services and nonconforming, inoperative or malfunctioning structures, systems, components or materials shall be identified and controlled in accordance with the requirements of Policy 15.0 of this Manual.
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< q j 15,0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS (Including Items, Services s'nd Activities) 15.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to identify and control safety-related' 6 items, services or activities for the Grand Gulf Nuclear Station which do not conform to established requirements. 15.2 SCOPE l l I This Policy delineates responsibilities and defines requirements for the identification and control of nonconforming safety-related items, services or activities in order to assure that the nonconforming conditions do not compromise quality or safety. 15.3 APPLICABILITY The requirements of this Policy apply to all individuals or organiza-tions performing functions on safety-related structures, systems, materials, parts or components during the operational phase of nuclear power plant activities. 15.4 RESPONSIBILITY 15.4.1 Responsibility and authority for the identification and control of nonconforming items, services and activities during the operational phase are delegated to the Director, Nuclear Plant Engineering (for engineering); the Manager, Unit 1 Projects (for implementation and testing of design changes and plant modifications); the Unit 2 Construction Superintendent (for preoperational phase testing); the Director, Nuclear Support (for nuclear fuel or core items); the GGNS General Manager; the Director, Quality Programs; 6 and the manager of the organization performing the activity. It is the responsib13ity of these individuals to assure that the requirements of this Policy which are applicable to their scope of activities are implemented in accordance with documented procedures. All personnel are responsible for reporting detected nonconformances in accordance with the procedures applicable to their particular organization. 15.4.2 Organizations supplying material, equipment or services are responsible for complying with the applicable requirements of this Policy, as specified in the procurement documents, and for imposing them on their contractors and suppliers, as applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 15.4.3 The Manager, Quality Services is delegated the responsi- 6 bility for assuring implementation of the identification and control of nonconforming icems, services and activities OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 1 of 3 Policy 15 J250QAM.15A - 1
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[bylinspzetion(excludingracsiptin:psetion)ofplictf$ite (I p operations phase activities, including preoperational and E startup testing to verify conformance to the applicable ; requirements of this Policy. The Manager Quality Systems is delegated the responsibility for assuring implementation 1 of the identification and control of nonconforming items, f' , i services and activities by audit or receipt inepection of plant site operations phase activ3!ies, including pre-j'" J operational and startup testhig to verify conformancv to 6
' , the applicable requirements of ghis Policy.
The Manager, Quality Services is dcIcgated the responsi-s bility for control, processing,'trd king, dispositioning, and verification of nonconformance documents for plant sd e j j opertrions phase activities, includ!.ng preoperational ana l startup testing to verify confonaance to the applicable l J requirements of this Policy. 1L4 4 4 The Director, Quality Programs has Ihb responsibility for 6
- i. ; carrying out an audit program, as described in Policy 18.0
- l. of this Manuel, to verify conformance Eith the requirements ,
of the Operational Quality Assurance Program, including the j {' requirements of this Policy. He is also responsible for j
, the periodic review and analysis of NRC and SERI Quality l6 i Assurance nonconformance documents to detect possible adverse quality trends.
15.5 REQUIREMENTS
; 15.5.1 Procedures # hall be established by the responsib3e
} organizations to identify and control nonconforming
> safety-related items, services and activities. The procedures shall include provisions for identification, documentation, segregation, review, disposition and notification to affected organizations, as appropriate.
15.5.2 The procedures shall specify the individuals or organiza-tions responsible for the disposition and approval of non-conforming items, r.,ervices or activities, including an independent review and acceptance by the appropriate quality organization, and shall provide for documentation to identify the item, service or activity; describe the nonconformance; document the disposition and inspection requirements; and provide signature approval of the disposition. Unless evaluated as having no impact on satisfactory performance, nonconformances are corrected or resolved prior to the initiation of the preoperational test program on the item. 15.5.3 Measures shall be established to procedurally control further processing, delivery or installation of a noncon-forming item or continuation of a nonconforming service or activity, pending a decision on its disposition. 4 OPERATIONAL QUM.ITY ASSURANCE MANUAL Rev. 6 TINE: NONCO) MRMING MATERIALS, F4RTS OR COMPONENTS Page 2 of 3 Policy 15
, J250QAM.15A - d I
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15.5.4 In ordsr to prcvsnt its inadvertent us2 or installation, a nonconforming item shall be identified by marking or r,gging and shall be physfcally segregated, where practical. If physical segregation is not practical, identification of the item as nonconforming by marking or ragging shall be acceptable. Where marking or tagging is not feasible, nonconforming items may be controlled by the use of appropriate documentation. Markings or tags used to identify nonconforming items shall be removed after resolution of the nonconforming condition. 15.5.5 Nonconforming items, services or activities shall be ; reviewed and dispositioned in accordance with documented l procedures. Items may be dispositioned in the following ways: 15.5.5.1 Accept-as-is;
, 15.5.5.2 Scrap; 15.5.5.3 Rework'to conform to a drawing or specification; 15.5.5.4 Repair in accordance with an engineering approved procedure.
Items received without the necessary documentation shall be controlled. Acceptance of such items will be withheld pending receipt of required documentation or the items vill be considered nonconforming. 15.5.6 The acceptability of rework shall be verified by reinspecting or retesting the item to the original requirements, or by an equivalent method which has been reviewed and approved. The acceptability of repair shall be verified by reinspection, or retesting the item by an engineering approved method even though the item still may not conform to the original requirements. Inspection, testing, rework and repair shall be documented. 15.5.7 For items dispositioned " accept-as-is" or " repair," a description of the change, waiver or deviation shcIl be documented to record the change and denote the as-built condition. Documentation verifying the acceptability and approval of such items shall also be required. 15.5.8 Nonconformance reports with " accept-as-is" or " repair" dispositions submitted by contractors or suppliers shall be reviewed and concurred with by the designated individuals and shall become a part of the inspection records to be submitted with the item. 15.5.9 Nonconformance reports shall be periodically reviewed and analyzed to detect possible adverse quality trends, and the results shall be reported to management for review and assessment. I OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 3 of 3 Policy 15 J250QAM.15A - 3 F -. _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
l l 16.0 CORRECTIVE ACTION 16 I' PURPOSE' This Policy describes the Operational Quality Assurance Program measures established by SERI.to provide for the correction of g conditions adverse to the quality or safety of the Grand Gulf Nuclear-Station. 16.2 SCOPE This Policy delineates responsibilities and defines requirements for the identification, documentation, reporting, and correction of conditions adverse.to quality or safety, including requirements for the determination of cause and corrective action to preclude the recurrence of significant conditions adverse to quality or safety. 16.3' APPLICABILITY The requit ,ments of this Policy apply to all individuals or organiza- ; tions performing functions which affect safety-related structures, l systems or components during the operational phase of nuclear power ) plant activities. 16.4. ' RESPONSIBILITY 16.4.1 Responsibility and authority for the development and control of measures to assure corrective action during the 1 operational phase are delegated to the Site Director GGNS; Director, Nuclear Plant Engineering; Director, Nuclear-
)
Support; Director, Nuclear Licensing; and the Director, 6 5 Quality Programs. They are responsible for assuring that procedures are established, in accordance with the require-ments of this Policy to provide for the identification, documentation, and correction of conditions adverse to quality or safety. They are also responsible for assuring that corrective action implemented is designed to prevent recurrence of significant adverse conditions. 16.4.2 All organizations performing quality or safety affecting activities are responsible for incorporating into the i appropriate procedures, measures for identifying and 1 reporting conditions which may warrant corrective action. Responsibility for determining and implementing necessary corrective action is delegated to the organization per-forming or controlling the activity. During the opera-tional phase, the responsibility for the determination and implementation of corrective action onsite, excluding preoperational testing acti.ities, is delegated to the GGNS General Manager. During implementation and teeting of design changes and plant modifications, the Manager, L..it 1 Projects l is responsible for this activity. The responsibility for the determination and implementation of corrective action associated with preoperational phase testing programs is delegated to the Unit 2 Construction Superintendent. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CORRECTIVE ACTION Page 1 of 3 Policy 16 J250QAM.16A - 1 l l __ _ _ _ _ 1
J16.4.3 This section deleted in Rsvision'4.- , I l' 6 ; 4'. 4 Organizations supplying matirial, equipment or services are j responsible for complying with the requirements of this :1 Policy'as specified in the' appropriate procurement documents. und for. imposing them'on their contractors and-suppliers as applicable. They are also responsible for-
' verifying, through-surveillance or audits,'that the-requirements are.being: adequately implemented.
16.4.5 The Director, Quality, Programs has the responsibility for 6 carrying out an audit program, as described'in Policy 18.0 of this Manual; to verify conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy; for the periodic review and analysis of NRC and SERI Quality Assurance'nonconformance 6 documents to detect possible adverse quality trends; for reporting such items, if any, to the Vice President, Nuclear Engineering & Support and the Vice President, Nuclear Operations for further action. 16.5 REQUIREMENTS
'16.5.1 Procedures shall be established and implemented by.the 3 responsible organizations, consistent with the scope of-their activities, to provide measures for the identifica-tion, documentation, reporting and correction of conditions adverse to quality or safety.
16.5.2 The procedures shall provide for the evaluation of condi-tions such as nonconformances, failures, malfunctions, deficiencies', violations, deviations, reportable occur-rences, 10CFR21 items, and defective material and equipment to determine the need for corrective action and to identify possible adverse quality trends. 16.5.3 The procedures shall require.that action be promptly initi-ated and adequately documented by the responsible organiza-tion to correct the condition and to determine if. action 19 necessary to preclude its recurrence. 16.5.4 The documentation to be used to report conditions adverse to quality or safety and request corrective action, and the appropriate distribution and control thereof, shall be specified in the procedures. 16.5.5 The procedures shall provide for follow-up reviews by the appropriate organizations to verify proper implementation of the corrective action and to close out the documentation. 16.5.6 For significant conditions adverse to quality or safety, the cause of the conditions, and the corrective action taken which is designed to prevent recurrence of the event OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6
' TITLE: ' CORRECTIVE ACTION Page 2 of 3 Policy 16 J250QAM.16A - 2 b
J y. shall ba docum:ntsd'.>and reported to appropriate levels of-h.; management for review. 16~5.7 Nonconforming materials, partsland components (including j
, items,-services and activities) shall be identified, con . -!
trolled and dispositioned in accordance with procedures l which implement the requirements of Policy 15.0 of thia .
' Manual. !
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I I J0PERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: CORRECTIVE' ACTION Page 3 of 3 Policy 16 J250QAM.16A'- 3 i l
17.0: QUALITY ASSURANCE RECORDS 17.1 PURPOSE L I This Policy describes the Operational Quality Assurance Program-ll measures established by SERI for the collection, storage, and 6 maintenance of quality assurance records for the Grand Gulf Nuclear Station. 1 17.2 SCOPE This Policy delineates responsibilities and defines requirements for the development of a records management system to provide for the collection, storage, and. maintenance of quality' assurance records.
. Quality. assurance records include those records which furnish documentary evidence of the quality of items and of activities affecting quality.
-17.3 APPLICABILITY The requirements of this Policy apply to all individuals or organiza-tions participating in the collection, storage or maintenance of quality assurance records during the operational phase of nuclear power plant activities.
17.4 RESPONSIBILITY 17.4.1 Responsibility and authority for the development of a records management system are delegated to the Vice President, Nuclear Operations. This includes responsi-bility for the collection, storage and maintenance of quality assurance records generated during' design and construction, as well as during the operational phase. He shall' assure that records are collected, stored and main-tained in accordance with procedures which address the requirements of this Policy. Responsibility for the development of the required procedural controls for the collection, storage and maintenance of quality assurance records is delegated to the GGNS General Manager. 17.4.2 The GGNS General Mar.ager is responsible for the collection, storage and maintenance of records generated onsite and y required to be maintained at the site including GGNS j records generated by the Plant Modification and Construc- j tion Section. Such records include those necessary to operate and maintain the facility and meet regulatory requirements. Such records shall be identified in the a appropriate Plant Staff Procedures or the Plant Modification I and Construction Section Procedures developed to meet the requirements of this Policy. 17.4.3 The Manager, Quality Services and the Manager, Quality 6 Systems are delegated the responsibility for assuring implementation of the collection, storage, and maintenance of those quality assurance records onsite which are under OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE RECORDS Page 1 of 3 Policy 17 J250QAM.17A - 1
~ L the control of tha GGNS Gansral Managar. The M:nsgor, 6- [ Quality Services is responsible for reviewing Plant f Administrative procedures and work-documents for and performing inspections to the extent necessary to verify conformance to the requirements of this Policy. Lower tier instructions may be reviewed by individuals (other than preparer) of the organization preparing-the documents lif such individuals have been indoctrinated in the Operational Quality Assurance Program.- The Manager, Quality Systems 6 is responsible for indoctrination and certification of these individuals. 17.4.4 The GGNS General Manager is responsible for the collection, storage and maintenance of records generated by the Nuclear t Support Staff, Nuclear Licensing Staff, Nuclear Plant 6 Engineering Staff, and those records transmitted to the GGNS General Manager. This includes quality assurance records generated by Quality Assurance. Records to be maintained by the GGNS General Manager shall be identified in the appropriate Nuclear Support, Nuclear Licensing, and 6 Nuclear Plant Engineering Administrative Procedures developed to meet the requirements of this Policy. 17.4.5 The Director, Quality Programs is responsible for the 6 collection and storage of quality assurance records gener-ated by Quality Assurance until such time as they are transmitted to the GGNS General Manager. Such records shall be. identified in the appropriate Quality Assurance Procedures developed to meet the requirements of this Policy.- 17.4.6 -Other organizations whose scope of activities require the generation, collection, storage or maintenance of qualfty assurance records shall establish procedures to assure compliance with the applicable requirements of this Policy. Contractors and suppliers are responsible for complying with the requirements of this Policy to the extent specified in the appropriate procurement documents, and for imposing them on their contractors and suppliers, as ; applicable. They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented. 17.4.7 The Director, Quality Programs has the responsibility for l6 carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy, i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE RECORDS ! Page 2 of 3 Policy 17 J250QAM.17A - 2 l 1 l j
17.5' REQUIREMENTS 17.5.1- A system for the collection, storage and maintenance of quality assurance records--including provisions for identi-4 fication, classification, indexing, retention, preserva-tion, safekeeping, retrievability and disposition--shall be established. 17.5.2 The records system shall define requirements and responsi-bilities for records transmittals, retention, and mainte-nance, subsequent to the completion of a work activity, consistent with applicable codes, standards and procurement documents. Measures.to assure that the required records have been received and are acceptable shall be established. 17.5.3 The records system shall provide measures to assure that records are identifiable and retrievable. Retention periods of sufficient duration to assure the ability to reconstruct significant events and satisfy regulatory or statutory requirements shall be specified. Inspection and test records shall contain the following where applicable. 17.5.3.1 A description of the type of observation; L 17.5.3.2 Evidence of completing and verifying a manu-facturing, inspection, or test operation;. 17.5.3.3 The date and results of the inspection or test; 17.5.3.4 Information releted to conditions adverse to quality; 17.5.3.5 Inspector or data recorder identification; 17.5.3.6 Evidence as to-the acceptability of the results. 17.5.4 Storage' facilities for quality assurance records shall be designed to prevent records' damage or loss, to the maximum extent practical; or as a satisfactory alternative, dupli-cate record shall be stored in a separate remote location. 17.5.5 Records and documentation requirements are specified in the other Policies of this Manual. Quality assurance records include, but are not limited to: design records, such as specifications and drawings; procurement documents; operat-ing logs and procedures; principal maintenance and i modification documents; results of reviews, inspections, tests, audits, material analyses; monitoring of work performance; personnel, procedures, and equipment qualification records; nonconformance reports; corrective action documents; and 10CFR evaluations (i.e., 10CFR50.59, 10CFR21). OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: QUALITY ASSURANCE RECORDS Page 3 of 3 Policy 17 J250QAM.17A - 3
18.0 AUDITS 18.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures established by SERI to provide a comprehensive audit program 6 for the Grand Gulf Nuclear Station. 18.2 SCOPE This Policy delineates responsibilities and defines requirements for the development and implementation of a comprehensive program of planned and documented audits designed to verify compliance with, and assess the effectiveness of, the Operational Quality Assurance Program. 18.3 APPLICABILITY The requirements of this Policy apply to all internal and external audits performed by or for SERI during the operational phase of 6 nuclear power plant activities. 18.4 RESPONSIBILITY 18.4.1 Responsibility and authority for the SERI audit program are 6 delegated to the Director, Quality Programs. He is respon-sible for the development and implementation of a program of planned and documented audits to verify ccmpliance with all aspects of the Operational Quality Assurance Program and to assess its effectiveness. He is responsible for assuring that procedures are developed, in accordance with the requirements of this Policy, to provide for both internal and external audits. He is responsible for performance of audits to verify plant conformance to the Technical Specifications; audits of operational phase activities (including activities of the Startup Organiza-tion); and audits of contractors and suppliers performing onsite and offsite activities. He shall also assure that audit results are documented and reported to appropriate management, and that prompt corrective action is taken to eliminate nonconformances detected during the course of i audits. 18.4.2 This section deleted in Revision 3. 18.4.3 Organizations supplying material, equipment or services are responsible for auditing their internal operations and their contractors and suppliers, as stipulated in the appropriate procurement documents, in order to verify compliance with the quality assurance program requirements specified in the procurement documents. ' 18.4.4 The section deleted in Revision 5. q OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: AUDITS Fage 1 of 3 Policy 18 J250QAM.18A - 1
18.5 REQUIREMENTS 18.5.1 A comprehensive program of planned and documented audits shall be established and implemented by the Quality Assur- , ance organization to verify compliance with all aspects of { the Operational Quality Assurance Program. The audit program shall be carried out in accordance with written approved procedures which address the requirements of this Policy. 18.5.2 The audit program shall provide for both internal and j I external audits. Internal audits shall include audits of the procedures and performance of all SERI organizations l6 whose activities affect the quality of safety-related j structures, systems and components. External audits shall i include audits of the practices, procedures and- l instructions of contractors and suppliers who provide safety-related material, equipment or services. 18.5.3 Audits shall provide an objective evaluation of quality-related practices, procedures, instructions, activities, and items; and review of documents and records.
)
18.5.4 Audits of operating plant activities shall include, as a minimum, those specified in the Technical Specifications for the applicable nuclear generating station. 18.5.5 Audits shall be performed by trained, qualified personnel not having direct responsibilities in the areas being audited. Qualification and training requirements for auditors shall be established and documented and records of auditor qualifications shall be maintained and kept current. Personnel selected for quality assurance audit assignments shall have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited. 18.5.6 An audit schedule shall be developed, maintained, reviewed and updated, as necessary. The audit schedule shall address the following minimum requirements: 18.5.6.1 Auditing shall be initiated as early in the life of an activity as practical to assure timely implementation of quality assurance program , requirements. 18.5.6.2 Audits shall be scheduled on the basis of the status and importance of the activities to be audited. 18.5.6.3 Those specified in the Technical Specifications l for the applicable nuclear generating station. l l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 l TITLE: AUDITS l I Page 2 of 3 Policy 18 J250QAM.18A - 2 1
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18.5'.7 Individual audits'shall be parformsd in accordance with documented plans.and checklists which describe the audit and provide for an objective evaluation of the status and adequacy of the areas being1 audited. The " objective evaluation" referenced is not to be confused with the evaluation statement in ANSI N45.2.12 to which SERI has provided a clarification. See Appendix A. 6 18.5.8 Audit lasults, including nonconformances detected during the audit, shall be documented and reviewed with the supervisor or manager having responsibility in the areas audited. Distribution of audit reports shall include management of'the audited organization, and appropriate 6 SERI management. 18.5.9 Management of the. audited organizations shall be respon-sible for correcting nonconformances identified during an audit. They shall assure that corrective action is scheduled, accomplished as scheduled, and documented. The corrective action shall be designed to prevent the recurrence of significant conditions adverse to quality. (See also Appendix A, Regulatory Guide 1.144, Item 11.) 18.5.10 Deficient areas shall be reviewed or reaudited on a timely basis to verify implementation of corrective action. 18.5.11 Audit results shall be analyzed to detect adverse qual 1ty I trends and to evaluate the effectiveness of the Operational Quality Assurance Program. Results of such analyses which indicate adverse quality trends shall be reported to appropriate management for review and assessment. 18.5.12 Records shall be generated and retained for all audits, including individual audit plans, audit reports, written replies, and records of corrective action. (See also Appendix A, Regulatory Guide 1.144, Item 13.) ; i 18.5.13 SERI interprets the requirements of Technical Specification 6 6.5.2.8, which requires that audits shall be performed under the cognizance of the SRC, to be met by the j following: The SRC shall review the results of audits of 6 nuclear activities conducted in accordance with the SERI Operational Quality Assurance Manual. Audits shall be conducted and results shall be reviewed in the areas listed ! in Technical Specification 6.5.2.8. OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 6 TITLE: AUDITS ! Page 3 of 3 Policy 18 J250QAM.18A'- 3
APPENDIX A Conformance of SERI Operational Quality Assurance j Program to NRC Regulatory Guides and ANST Standards f6 l In each of the ANSI standards, other documents (i.e. other standards, codes, regulations, tables, or appendices) required to be included as a part of the standard are either identified at the point of reference or are described in a special section of the standard. The specific applicability or acceptability i of these listed standards, codes, regulations or appendices is either covered l in other specific areas in the Operational QA Program, including appendices, or l such documents are not considered as Quality Assurance Program requirements, although they may be used as guidance. NRC Regulatory Guide 1.8 " Personnel Qualification and Training" (2nd Proposed Revision 2) - Endorses ANSI /ANS 3.1 (Draft 12/79) The Operational Quality Assurance Program complies with those requirements of Sections 1.0, 2.0, 3.0, 3.1, 3.2, 3.2.1, 3.2.2, 3.2.3, 3.3, 4.0, 4.1, and 4.4.5 of ANSI /ANS 3.1 (Draft 12/79) that are applicable to the Quality Assurance organization (both onsite and offsite) with the following clarifications:
- 1) With regard to the term " Bachelor's Degree" as used in the draft Standard, the following qualifications may be considered equivalent to a Bachelor's Degree:
- a. 4 years of formal schooling in science or engineering,
- b. 4 yer.rs of applied experience at a nuclear facility in the area for which qualification is sought,
- c. 4 years of operational or technical experience / training in nuclear power, or
- a. any combination of the above totaling 4 years.
- 2) With regard to Section 4.4.5 of ANSI /ANS 3.1 (Draf-. 12/79) titled Quality Assurance: SERI will comply with Paragraph 4.4.5 as l6 originally stated in ANSI /ANS-3.1 - 1978 which reads as follows:
At the time of initial core loading cr assignment to the active position, the responsible person shall have six years experience in the field of quality assurance, preferably at an operating nuclear plant, or operations supervisory experience. At least one year of this six years experience shall be nuclear power plant experience in the overall implementation of the quality assurance program. (This experience shall be obtained within the quality assurance organization.) A minimum of one year of this six years experience shall be related technical or -- ~ c training. A maximum of four years of this six years expu . . may be fulfilled by related technical or academic training. The applicability of this Guide / Standard to other personnel in the SERI l6 organization is addressed other Sections of the FSAR and the Technical Specifications of the individual nuclear facility. Rev. 6 1 of 33 J250QAMAPPENDIX 1.A - 1
APPENDIX A NRC Regulatory Guide 1.26 " Quality Group Classification, and Standards for Water, Steam, and Radioactive Waste Containing Components of Nuclear Power Plants" (Rev. 3, 2/76) The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarification: SERI may choose not to use the specific A, B, C and D level classification 6 system set forth in this Guide. SERI generally followed the requirements of this Guide in developing the list of structures, systems and components ("Q" List) to which the program will apply. The SERI "Q" List will describe the l6 items to which the Operational Quality Assurance Program will apply in lieu of the guidance contained in this Regulatory Guide. NRC Regulatory Guide 1.28 " Quality Assurance Program Requirements (Design and
-Tstruction)" (6/72) - Endortes ANSI N45.2 - 1971.
This Guide and the Standard it endorses have been superseded for operations activities by Regulatory Guide 1.33 and ANSI N18.7 - 1976 which it endorses. The Operational Quality Assurance Program complies with Regulatory Guide 1.33 and ANSI N18.7 - 1976 as stipulated in Appendix A to that Program; therefore, Regulatory Guide 1.28 (Safety Guide 28) and ANSI N45.2 - 1971 which it endorses are not considered necessary and are not included as part of the Program. NRC Reculatory Guide 1.29 " Seismic Design Classification" (Rev. 3, 9/78) The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarification: For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, SERI shall either control these activities under this Operational QA Program or under an NRC acccpted Construction QA Program (per l6 OQAM 3.5.18). When this Operational QA Program is used, SERI shall comply 6 with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with the maintenance or modification shall be the original requirements or better (e.g., code requirements, material properties, design margins, manufacturing processes , and inspection requirements) . NRC Regulatory Guide 1.30 "Ouality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment" (8/72) - Endorses ANSI N45.2.4 - 1972. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) For operations phase maintenance and modification activicies which are comparable in nature and extent to similar activities conducted during the construction phase, SERI shall either control these 6 Rev. 6 .
l 2 of 33 J250QAMAPPENDIX i.A - 2 ; i
- - _ - - - - - - - - - - - l
APPENDIX A activities under this 0parational QA Progrce or under en NRC acceptsd j Con:truction QA Program (Par OQAM 3.5.18). When this Operational QA = Program is used, SERI shall comply with the Regulatory Position 6 established in this Regulatory Guide in that QA programmatic /adminis-trative requirements included therein (subject to the clarifications in item 2 below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with maintenance and modifications shall be the original requirements or better (e.g.,- code requirements, material properties, design margins, manufacturing processes, and inspection requirements). _ l
- 2) Additional clarifications for ANSI N45.2.4 - 1972 are indicated for !
specific sections below. , Section 1.4 - Definitions in this Standard which are not included in l ANSI N45.2.10 N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in SERI 6 commitment to Regulatory Guide 1.74. Section 2.1 - Planning requirements, when necessary, will be incor-porated into maintenance and modification procedures. Section 2.3 - Procedures and Instructions will be implemented as set forth in Policies 2, 3, 5,10, and 11 of the Operational QA Program and by compliance with the individual nuclear facility Technical Specifications and ANSI N18.7 as set forth in Appendix A to that Program in lieu of the requirements set forth here. Section 2.4 - Results will be implemented as set forth in Policies 10, 11 and 17 of the Operational QA Program and by compliance with ANSI N18.7 as set forth in Appendix A of that Prrgram in lieu of the i requirements set forth here. Section 2.5.2 - Calibration and Control. The third sentence of this section states in part, "... equipment shall be suitably marked to indicate date of next required calibration." SERI will utilize 6 a computerized system to indicate the calibration status of installed operations measuring and test equipment in lieu of marking or tagging the individual item. Section 3 - Preconstruction Verification will be implemented as follows: (1) is raquired only for modifications (2) will be imple-mented with the clarification that " approved instruction manuals" shall be interpreted to mean the manuals provided by the supplier as required by the procurement order--these manuals will not be reviewed and approved, per se, by SERI; (3) no special checks will be made by 6 the person withdrawing a replacement part from the warehouse-- equivalent controls are assured by compliance with ANSI N45.2.2 as set forth in Appendix A to the Operational QA Program; and, (4) will be complied with as stated, by individual technicians as part of the maintenance / modification process. Section 4 - Installation will be implemented by inclusion, as necessary, in the appropriate maintenance or modification procedure, Rev. 6 3 of 33 J250QAMAPPENDIX 1.A - 3 ,
I - fjk ~
- , APPENDIX A' where.such procedures ars used. . Standard SERI maintenance .
6 practices; require that care be exercised in the six' areas listed whether a procedure is required or not. r
.Section 5.1.- Inspections, including subsections 5.1.1, 5.1. 2, and
-the first sentence in 5.1.3, will-be implemented as set forth in Policy 10 of the Operational QA Program, The inspection program will incorporate,.as applicable,'those items listed in these subsections.
The remaining ~ sentence in 5.1.3 is covered in equivalent detail in SERI's commitment to ANSI N18.7, Section 5.2.6; the requirements as 6 set forth in that commitment will be implemented in. lieu of the requirements stated here. Section 5.2.- Tests,. including subsections 5.2.1 through 5.2.3,.will l Lbe implemented as set forth in Policies-3 and 11 of the Operational QA Program. The test program will consider the elements outlined in this-Section, where applicable, when developing test requirements for' inclusion in maintenance and modification procedures. In some cases, testing requirements may be met by post-installation surveillance testing in lieu of a special post installation test. Section 6 - Post-Construction Verification is not generally considered applicable at operating. facilities because of the scope of the work and-the relatively short interval between installation and operation. Where considered applicable, as.in modifications, the elements described'in this'Section will be considered in the development and implementation of inspection and testing programs as
' described in Policies 3, 10 and 11 of the Operational QA Program.
With regard to Section 6.2.1 of ANSI N45.2.4 - 1972 titled Equipment Tests: The last paragraph of this Section deals with tagging and labeling. 'SERI will comply with an alternate last paragraph which' 6' reads: "Each safety-related item of process instrumentation is identified with a unique numbar. -This number is utilized in instrument maintenance records so that current calibration status, including data such as the.date of the' calibration-and identity of person that' performed the calibration, can be.readily determined. Such'information may also be contained on tags or labels which may be attached to installed instrumentation." Section 7 - Data Analysis and Evaluation will be implemented as stated herein after adding the clarifying phrase "Where used" at the beginning of that paragraph. Section 8 - Records will be implemented by conformance with Policy 17 of the Operational QA Program and ANSI N45.2.9 as set forth in Appendix A to that Program.
- NRC Regulatory Guide 1.33 " Quality' Assurance Program Requirements (Operation)" (Rev. 2, 2/78) - Endorses ANSI N16.7 - 1976.
LThe. Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications: Rev. 6 4 of 33 J250QAMAPPENDIX 1.A - 4
j APPENDIX A
- 1) Paragraph C.3 of Regulatory Guide 1.33 (and Section 4.3.4 of ANSI N18.7 which it references) will be implemented as required by the applicable nuclear facility Technical Specifications which define
" Subjects Requiring Independent Review." I
- 2) Paragraph C.4.a of Regulatory Guide 1.33 (and Section 4.5 of ANSI N18.7 which it references) will be implemented as required by the 1 applicable nuclear facility Technical Specifications which define the l
" Audit Program" to be conducted. The audit program is further defined and will be implemented as required by the commitment to ANSI ;
N45.2.12 as stated in Appendix A of the Operational QA Program.
- 3) Paragraph C.S.a of Regulatory Guide 1.33 (and Section 4.4 of ANSI N18.7 which it references) will be implemented with the clarification that the Plant Safety Review Committee shall perform this activity.
- 4) Paragraph C.5.d of Regulatory Guide 1.33 (and Section 5.2.7.1 of ANSI N18.7 which it references) will be implemented by adding the clarifying phrase "Where practical" in front of the fourth sentence of the fifth paragraph. The Regulatory Guides changing of the two uses of the word "should" in this sentence to "shall" unnecessarily restricts SERI's options on repair or replacement parts. It is not 6 always practical to test parts prior to use. For modifications where these requirements are not considered practical, a review in accordance with the provisions of 10CFR50.59 will be conducted and documented.
- 5) Paragraph C.S.e of Regulatory Guide 1.33 (and Section 5.2.13.4 of ANSI N18.7 which it references) will be implemented subject to the same clarifications made for ANSI N45.2.2 elsewhere in Appendix A to the Operational QA Program.
- 6) Paragraph C.S.f of Regulatory Guide 1.33 (and Section 5.2.19(2) of ANSI N18.7 which it references) will be implemented with the substitution of the word " practical" for the word "possible" in the last sentence.
- 7) Paragraph C.S.g of Regulatory Guide 1.33 (and Section 5.2.19.1 of ANSI N18.7 which it references) will be implemented with the addition of the modifier normally" after each of the verbs (should) which the Regulatory Gvide converts to "shall." It is SERI's intent to fully 6 comply with the requirements of this paragraph, and any conditions which do not fully comply will be documented and approved by management personnel. In these cases, the reason for the exception shall also be documented. The documentation shall be retained for the same period of time as the affected preoperational test.
- 8) With regard to Section 3.4.2 of ANSI N18.7 - 1976 titled Requirements for the Onsite Operating Organization: Training standards referenced in this Section will be implemented if such standards are included in Appendix A to the Operational QA Program or in Technical Specifications or are otherwise part of the license of the individual nuclear facility. SERI's method of documenting and 6 otherwise meeting the remainder of the. requirements of this Section Rev. 6 5 of 33 J250QAMAPPENDIX 1.A - 5
s >
, APPENDIX A are . set:forthlin Policies 1- and 1-of the Operational QA Program and'
- in the Technical Specifications of'the~ individual nuclear facility. '
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'9). ;With regard to Section 4.1 of. ANSI N18.7 -L1976 titled General'The SERI audit program will be implemented in accordance with and to meet 6
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the. requirements of: ANSI N45.2.12 as endorsed in Appendix-A; Policies 2, 16'and:18 of the Operational QA Program; and they requirements'of the individual nuclear facility Technical' Specifications.
~10). With. regard to Section 4.2 of ANSI N18.7 - 1976 titled Program
Description:
.Two aspects are addressed in this Section: saudits and independent. reviews. The independent. review program is implemented as required by the Technical Specifications of the . individua1' nuclear f acility and by Policies 1 and 2 of the ! Operational (NL Program.- The SERI audit program will be described in 6
- accordance with' and: to meet the requirements . of ANSI N45.2.12 as endorsed:in Appendix A of the Operational QA Program, the require-ments of the' individual. nuclear facility Technical Specifications, and Policies 16 and 18 of the Operational QA Program.
;11) With regard to Section 4.3 of ANSI N18.7 - 1976 titled Independent Review Process: The requirements of this Section, including all of.Its subparts, shall be met by compliance with the Technical Specifications' requirements'of the individual nuclear facility.
- 12) With regard to Section 4.5 of ANSI N18.7 -'1976. titled Audit Program: 1 The SERI audit. program will be implemented in accordance with and to 6 1 meet the requirements of: ANSI N45.2.12 as endorsed in Appendix A; ;!
Policies 2, 16, 17 and 18 of the Operational QA Program; and the ! requirements of the individual nuclear facility Technical Specifications.
- 13) With regard to Section 5.1.of ANSI N18.7 - 1976 titled Program
Description:
The fourth sentence in this Section required a
" summary document"; SERI has submitted Appendix C to the 6 Operational-QA Program and interprets this Appendix to fulfill the !
requirements'ior.a summary document.
- 14) With regard to Section 5.2.2 of ANSI N18.7 - 1976 titled Procedure Adherence: The temporary change requirements of this Section are delineated in the Technical Specifications for activities occurring after the Operating License (OL) is issued; the requirements of the Technical Specifications shall be used in lieu of the general re-quirements in this Section to control temporary changes. For tem- 2 porary changes which occur under this Program during preoperational and startup testing prior to issuance of an OL, SERI will comply 6 with this Section with the clarification that snother Test Supervisor l or Shift Supervisor or other member of the' Plant Staff (limited to Shift Superintendent, responsible Section Supervisor, Manager Plant Operations, or GGNS General Manager) knowledgeable in the areas affected by the change, may approve changes which require the signer to hold an SR0 license. a L
l i Rev. 6 6 of 33 ; J250QAMAPPENDIX 1.A - 6 i, M&aM_ms __-_a__ _ _ - _ . - _ . - . -- -
L ', . _
^
. . ' APPENDIX'A.
f , Whtn thsre is.a requirement'to:"implemant" or '?addrass".a'procsdura,- L actions prescribsd by. procedures shall be accomplished. 1 This does not.necessarily. imply-that in7all' cases the operator, engineer, or i : technician has a copy of the procedure in-hand and signs-off a (; ' : checklist as each step orLfunction is performed. I: i
- 15) With' regard to'Section 5.2.6 of ANSI.N18,7 - 1976 titled Equipment
! . Control: SERI will comply with the." independent verification"
~
6' re quirements based on the' definition of this phrase as'given under
.o our commitment to Regulatory Guide 1.74, The: third sentence of'the fourth paragraph requires in' dependent verification."when appropriate." Where significant exposure to
, radiation,' which is determined.by the cognizant Health Physics
' '7 ' personnel,;wculd result from such verification, they;shall advise Operations of: current radiological conditions. ' Operations' will then decide whether or not the confidence gained.from.the independent verification is wogth the additional radiation exposure. In all cases, radiation doses will be As. Low As Reasonably Achievable (ALARA). Since'SERI sometimes'uses descriptive names to designate equipment, 6 the sixth paragraph, second sentence is replaced with: " Suitable means include identification numbers or other descriptions which are traceable ~to records of the status of inspections'and tests." i The first' sentence.in the seventh paragraph will be complied with after clarifying " operating. personnel" to mean' trained employees _ _t assigned'to, or under the control'of, SERI-management at an operating 6 nuclear facility.
- 16) With regard to Section 5.2.7 of ANSI N18.7 - 1976 titled Maintenance.
and Modification: Since some emergency situations could arise which might preclude preplanning of all activities, SERI will comply with 6 an alternate to the first-sentence.in the second paragraph which'. reads:
"Except in emergency or abnormal operating conditions where immediate actions-are required to protect the health and safety of the public, to protect equipment or personnel,.or to prevent the deterioration of plant conditions to a possibly. unsafe or unstable level, maintenance or modification'of equipment shall.be preplanned and performed in accordance with written procedures. Where written procedures would be required and are not used, the activities that were accomplished shall be documented after-the-fact and receive the same degree of review as if they had been preplanned."
For those system run-in activities that take place prior to issuance of an Operating License, the Startup Engineer may direct work by E SERI Operations or Maintenance personnel to restore the system to 6 design drawing requirements, provided the work and actions are properly documented and that quality and engineering evaluations are obtained. These evaluations may be obtained after-the-fact. Rev. 6 7 of 33 J250QAMAPPENDIX 1.A - 7 i
APPENDIX A
- 17) 'dith regard to Ssction 5.2.7.1 of ANSI N18.7 - 1976 titled i Maintenance Programs: SERI will comply with the requirements of 6 )
the first sentence of the fifth paragraph, where practical. This 1 clarification is needed since it is not always possible to promptly determine the cause of the malfunction. In all cases, SERI will 6 j initiate proceedings to determine the cause, and will make such determinations promptly, where practical.
- 18) With regard to Section 5.2.8 of ANSI N18.7 - 1976 titled Surveillance ,
Testing and Inspection Schedule: In lieu of a " master surveillance f schedule," the following requirement shall be complied with: "A i surveillance testing schedule (s) shall be established reflecting the status of all in plant surveillance tests and inspections." ; L
- 19) With regard to Section 5.2.9 of ANSI N18.7 - 1976 titled Plant f Security and Visitor Control: The requirements of the individual i nuclear facility Security Plan shall be implemented in lieu of these I general requirements.
- 20) With regard to Section 5.2.10 of ANSI N18.7 - 1976 titled ,
Housekeeping and Cleanliness Control: The requirements of this i' Section, beginning with the last sentence of the first paragraph and continuing through the end of the Section, will be implemented as 6 described in SERI's commitments to ANSI N45.2.3 and N45.2.1 as set forth in Appendix A to the Operational QA Program.
- 21) With regard to Section 5.2.13.1 of ANSI N18.7 - 1976 titled Procurement Document Control: The words "the same" in the last sentence are replaced with the words "an equivalent."
- 22) With regard to Section 5.2.15 of ANSI N18.7-1976 titled Review, Approval and Control of Procedures: The third sentence in Paragraph three is interpreted to mean: Applicable procedures shall be re- '
viewed following an accident, an unexpected transient, significant operator error, or equipment malfunction which results in a report-able occurrence. The first sentence in Paragraph four is interpreted to mean: Routinely used or Administrative type procedures will be 6 reviewed no less frequently than every two years, but procedures which are only used infrequently, i.e., every three to five years, will be reviewed prior to use.
- 23) With regard to Section 5.2.17 of ANSI N18.7-1976 titled Inspections:
Not all inspections will require generation of a separate inspection l report. Inspection requirements may be integrated into appropriate j procedures or other documents with the procedure or document serving i as the record. However, records of inspections will be identifiable j and retrievable. l
- 24) With regard to Section 5.3.9 of ANSI N18.7 - 1976 titled Emergency Procedures: As directed by the NRC, SERI will follow a format for emergency procedures which is " symptom" based as opposed to l6 i
" event" based as stipulated in Section 5.3.9.1. Since SERI will 6 have these " symptom" based procedures, " event" based procedures will not normally be provided.
Rev. 6 l 8 of 33 J250QAMAPPENDIX 1.A - 8 1 i
e V APPENDIX A I 25). With regard to Section 5.3.9.2 of ANSI N18.7 - 1976 titled Events of j Potential Emergency: NRC review of the FSAR has identified all natural occurrences which affect the nuclear facility. Therefore, p 6 SERI will interpret item (11) to mean the natural occu~rences which. have been evaluated in the FSAR for the individual nuclear facility. f
.26) 'With' regard to Section 5.3.9.3 of ANSI N18.7 - 1976 titled Procedures SERI's NRC accepted Emergency 6 for Implementing Emergency Plan:
Plan for each nuclear facility will be implemented in lieu of the re-quirements'in this Section.
- 27) .With Regard to Section 5.2.18 of AFSI N18.7 - 1976 titled Control of 3pecial Processes: The.last four words of the. first sentence are
' clarified by inserting the word " approved" before the word
" procedure": We shall use qualified personnel and approved procedures.
- 28) With regard to Section 5.2.7 of ANSI N18.7 - 1976 titled Maintenance and Modification: The first sentence of the first paragraph could be interpreted to require the same degree of inspection for alJ main-tenance activities as was provided during construction. When viewed in conjunction with Section 5.2.17, the third paragraph, we believe the actual: intent is clear. We shall provide inspections comparable in nature and extent-to that provided during construction if the maintenance / modification work is comparable in nature and extent. I
- 29) With regard to Se'ction 5.3.5(4) of ANSI N18.7 - 1976 titled Supporting Maintenance Documents: SERI may choose to include 6 material from vendor manuals in any of three ways. (1) The applicable section of the manual may be duplicated, referenced in.
and attached to the procedure. (2) The procedure may simply state that'the manual or a specific section is to be followed for l performing a particular function; the manual must then be used in conjunction with the procedure for performing the activity. (3) The pertinent. material from the manual, either as originally written or as modified by the author / reviewers of the procedure, may be written into and become a part of the procedure. In options (1) and (3) above, the material meets the requirement to receive "the same level of review and approval as operating procedures" since the material is reviewed as part of the procedure review process. In option (2), the requirements shall be deemed to have been fulfilled by requiring a copy of the pertinent manual (manual sections) to be available to and considered by persons L conducting the review of the procedure.
- 30) With regard to Section 5.2.16 of ANSI N18.7 - 1976 titled Measuring and Test Equipment: The second sentence of the third paragraph states " Records shall be made and equipment suitably marked to indicate calibration status." SERI will utilize a computerized system l6 to indicate the calibration status of installed operations measuring and test equipment in lieu of marking or tagging the individual item.
Rev. 6 9 of 33 J250QAMAPPENDIX 1.A - 9
L l I APPENDIX A . NRC-Ragulatory Guida 1.37 " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants" (3/73) Endorses ANSI N45.2.1 - 1973.
)
The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) With regard to Paragraph C.3 of Regulatory Guide 1.37: The water quality for final flushing of fluid systems and associated components shall be at least equivalent to the quality of the operating system water except for the oxygen and nitrogen content, but this does not infer that chromates or other additives, normally in.the system water, will be added to the flush water.
, 2) With regard to Paragraph C.4 of Regulatory Guide 1.37: Expendable l materials, such as inks and related products, temperature indicating sticks, tapes, gummed labels, wrapping materials (other than poly-et'.wlene), water soluble dam materials, lubricants, NDT penetrant materials and couplants, which contact stainless steel or nickel alloy surfaces shall not contain lead, zinc, copper, mercury, cadmium and other low melting point metals, their alloys or compounds, as bas ta and essential chemical constituents. Prescribed maximum levels of water leachable chlorides, total halogens, and sulphur and its j compounds < hall be imposed on expendable products.
- 3) With regard to Section 5 of ANSI N45.2.1 - 1973 titled Installation Cleaning: The recommendation that local rusting on corrosion resistant alloys be removed by mechanical methods is interpreted to mean that local rusting may be removed mechanically, but the use of other removal means is not precluded.
- 4) For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted i during the construction phase, SERI shall either control these 6 l
activities under this Operational QA Program or under an NRC accepted Construction QA Program (Per OQAM 3.5.18). When this Operational QA Program is used, SERI shall comply with the Regulatory Position 6 established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (Subject to the stated clarifications) shall apply to these maintenance and modification activities even thcugh such requirements may not have been in effect originally. Technical requirements associated with the maintenance or modification shall be the original requirements or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).
- 5) With regard to Section 1.4 of ANSI N45.2.1 - 1973 titled Definitions:
Definitions in this Standard which are not included in ANSI N45.2.10 chall be used; all definitions which are included in ARSI N45.2.10 shall be used as clarified in SERI's commitment to Regulatory Guide l6 1.74. Rev. 6 10 of 33 J250QAMAPPENDIX 1.A - 10
i APPENDIX A
- 6) With regard to Section 9 of /3SI N45.2.1 - 1973 titled Records:
SERI shall maintain records in accordance with and to mert the l6 requirements of Policy 7 of the 0QAM and ANSI N45.2.9 as specified in Appendix A.
- 7) Throughout this Standard, references are made to cleanness associated with initial installation. When this Standard is used for oper- ,
ations, qualified supervisory maintenance personnel determine what I ~ items within a particular cleanness level are appropriate. As an example, the Reactor Internals are initially classified as Level B. Section 3.1.2 requires this cleanness level to have " metal clean" surfaces and either a visual inspection or dry white-cloth wipe. After use in the reactor coolant system, SERI does not intend to 6 clean a component until it has a bright " metal clean" surface, nor do we (from an ALARA and accessibility considerations) intend to perform a dry white-cloth wipe. Components which have been removed from plant systems of established cleanliness levels may be considered to be of the same cleanliness as the system from which they were removed. Such components need not be recleaned prior to reinstallation provided that measures are taken to Prevent degradation of the previously existing state of cleanliness. NRC Regulatory Guide 1.38 " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" (Rev. 2, 5/77) - Endorses ANSI N45.2.2 - 1972. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) With regard to Section 1.4 of ANSI N45.2.2 - 1972 titled Definitions:
Definitions in this Standard which are not included in ANSI N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in SERI's commitment to Regulatory 6 Guide 1.74.
- 2) With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Planning:
(first sentence) The specific items to be governed by the Standard shall be identified on the Q-List. However, the Standard (as modified by the clarifications in Appendix A) is part of the Operational QA Program and will, therefore, be applied to those structures, systems, and components which are included in that Trogram.
- 3) With regard to Section 2.3 of ANSI N45.2.2 - 1972 titled Results:
The specific methods for performing and documenting tests and inspections are given in Policies 10 and 17 of the Operational QA 1 Program. The requirements in these Policir:s will be implemented in lieu of the general requirements here.
- 4) With regard to Section 2.4 of ANSI N45.2.2 - 1972 titled Personnel Qualifications: Specific requirements for personnel qualifications and training are set forth in Policy 2 and in the Rev. 6 11 of 33 J250QAMAPPENDIX 1.A - 11
AFFENDIX A commitm2nts to training etcndards in App:ndix A of ths Operational QA Program. These requirements will be implemented in lieu of the general requirements stated in this Section.
- 5) With regard to Section 2.7 of ANSI N45.2.2 - 1972 titled t Classification of Items: SERI may choose not to explicitly use l6 the four level classification system. However, the specific require-ments of the Standard that are appropriate to each class will generally be applied to the items suggested in each classification and to similar items.
- 6) With regard to Section 3.2.1 of ANSI N45.2.2 - 1972 titled Level A Items: As an alternate to the requirements for packaging and container 1 zing items in storage to control contaminants (Items (4) and (5)), SERI may choose a storage atmosphere which is free of 6 harmful contaminants in concentrations that could produce damage to stored items. Similarly (for Item (7)) SERI may obviate the need for l6 caps and plugs with an appropriate storage atmosphere, and may choose to protect veld end preparations and threads by controlling the manner in which the items are stored. These clarifications apply whenever items (4), (5) or (7) are subsequently referenced and to Section'3.5.1 titled Caps and Plugs and Section 3.4 titled Methods of Preservation.
- 7) With regard to Section 3.3 of ANSI N45.2.2 - 1972 titled Cleaning: 6 (Third sentence) SERI interprets " documented cleaning methods" to allow generic cleaning procedures to be written which are implemented, as necessary, by trained personnel. Each particular cleaning operation may not have an individual cleaning procedure, but the generic procedures will specify which methods of cleaning or which type (s) of solvent may be used'in a particular application.
- 8) With regard to Section 3.4 of ANSI N45.2.2 - 1972 titled 6 Methods of Preservation: (First sentence) SERI will comply with these requirements subject to the clarifications of Section 3.2.1 (4) and (5) above, and the definition of the phrase " deleterious corrosion" to mean that corrosion which cannot be subsequently
- removed and which adversely affects form, fit, or function.
- 9) With regard to Section 3.6 of ANSI N45.2.2 - 1972 titled Barrict and Wrap Material and Dessicants: This section requires the use of nonhalogenated materials in contact with austenitic stainless steel.
Refer to Regulatory Guide 1.37 above for the SERI position. 6
- 10) With regard to Section 3.7.1 of ANSI N45.2.2-197? t_itled Containers:
Cleated, sheathed boxes may be used up to 1000 lbs. rather than 500 lbs. as specified in 3.7.1(1) . This type of box is safe for, and has been tested for, loads up to 1000 lbs. Other national standards allow this (see Federal Specification PPP-B-601). Special qualification testing may be required for loads above 1000 lbs.
- 11) With regard to Section 3.7.2 of ANSI N45.2.2 - 1972 titled Crates and Skids: Crates or skids will be used on equipment with a gross weight of 500 lbs. or more. Skids or runners will normally be fabricated Rev. 6 12 of 33 J250QAMAPPENDIX 1.A - 12
APPENDIX A from 2 X 4 inch nominal lumbzr ziza, minimum, end laid flet exc:pt where this is impractical because of the small dimensions of the container. If forklift handling is required, minimum floor clearance for forklift tines will be provided.
- 12) With regard to Section 4.2.2 of ANSI N45.2.2. - 1972 titled Closed Carriers: The use of fully enclosed furniture vans, as recommended in (2), of this Section is not considered a requirement. SERI will 6 assure adequate protection from weather or other environmental conditions by a combination of vehicle enclosure and item packaging.
- 13) With regard to Sections 4.3, 4.4 and 4.5 of ANSI N45.2.2-1972 titled, respectively, Precautions During Loading and Transit, Identification and Marking, and Shipment from Countries Outside the United States:
SERI will comply with the requirements of these Sections subject to 6 the clarifications taken to other Sections which are referenced j therein.
- 14) With regard to Section 5.2.1 of ANSI N45.2.2 - 1972 titled Shipping Damage Inspection: Warehouse personnel will normally visually scrutinize incoming shipments for damage of the types listed in this Section, this activity is not necessarily performed prior to !
unloading. Since all required items receive the Item Inspection of Section 5.2.2, separate documentation of the Shipping Damage Inspection is not necessary. Release of 1.he transport agent after j unloading and the signing for receipt of the shipment may be all of the action taken to document completion of the Shipping Damage l Inspection. Any nonconformances noted will be documented and j dispositioned as required by Policy 15 of the Operational QA Program. The person performing the visual scrutiny during unloading ia not considered to be performing an inspection function as defined under i Regulatory Guide 1.74; therefore, while he will be trained to perform this function, he may not be certified (N45.2.6) as an Inspector.
- 15) With regard to Section 5.2.2 of ANSI N45.2.2 - 1972 titled Item Inspection: The second division of this subsection requires six additional inspection activities if an item was not inspected or examined at the source. SERI will consider that a source inspection (6 [
has been conducted if the supplier of the item is required to couply with ANSI N45.2.2 for the purchased item and if the ; supplier's program has been audited and found acceptable in the area (i.e. the supplier performs a source inspection of his supplier or , conducts a receipt inspection that includes, as applicable, the six l additional items listed). j
- 16) With regard to Section 6.1.2 of ANSI N45.2.2 - 1972 titled Levels of j Storage: Subpart (2) is replaced with the following: j (2) Level B items shall be stored within a fire resistant, weathertight, and well ventilated building or equivalent enclosure. This building shall be situated and constructed so that it will not normally be subject to flooding; the floor shall be paved or equal, and well drained. If any outside waters should come in contact with stored equipment, such equipment will be labeled or tagged nonconforming, and then the Rev. 6 l 13 of 33 l J250QAMAPPENDII 1.A - 13 l
l APPENDIX A nonconformance document will be processed and evaluated in accordance wit? Policy 15. Items shall be placed on pallets or shoring or shelves to permit air circulation. The building shall be provided with heating and temperature control or their equivalent to reduce condensation and corrosion. Minimum temperature shall be 40F and maximum temperature shall be 140F or less if so stipulated by a manufacturer.
- 17) With regard to Section 6.2.1 of ANSI N45.2.2 - 1972 titled Access to Storage Areas: Items which fall within the Level D classification of the standard will be stored in an area which may be posted to limit access, but other positive controls such as fencing
.m or guards will not normally be provided.
- 18) With regard to Section 6.2.4 of ANSI N45.2.2 - 1972 titled Storage of Food and Associated Items: The sentence is replaced with the following: "The use or storage of food, drinks, and salt tablet dispensers in any storage area shall be controlled and shall be limited to designated areas where such use or storage is not deleterious to stored items."
- 19) With regard to Section 6.2.5 of ANSI N45.2.2 - 1972 titled Measures to Prevent Entrance of Animals: The sentence is replaced with the following: " Warehouse personnel shall be alert to detect evidence of rodents or small animals in indoor storage areas. If any such evidence is detected, a survey or inspection will be utilized to determine the extent of the damage; exterminators or other appropriate measures shall be used to control these animals to minimize possible contamination and mechanical damage to stored material."
- 20) With regard to Section 6.3.3 of ANSI N45.2.2 - 1972 titled Storage of Hazardous Material: The sentence is replaced with the following:
Hazardous chemicals, paints, solvents, and other materials of a like nature shall be stored in approved cabinets or containers which are not in close proximity to installed systems required for safe shutdown."
- 21) With regard to Section 6.4.2 of ANSI F45.2.2 - 1972 titled Care of Items: The following alternates are provided for indicated subpart:
(5) " Space heaters in electrical equipment shall be energized unless a documented engineering evaluation determines that such space heaters are not required." (6) "Large (greater than or equal to 50 HP) rotating electrical equipment shall be given insulation resistance tests on a scheduled basis unless a documented engineering evaluation determines that such tests are not required." (7) " Prior to being placed in storage, rotating equipment weighing over approximately 50 pounds shall be evaluated by engineering personnel to determine if shaft rotation in storage is required; the resulte of the evaluation shall be documented. If rotation Rev. 6 14 of 33 J250QAMAPPENDIX 1.A - 14
)
APPENDIX A is r quir:d, it shell ba parform:d at epscified intervals, be documented, and be conducted so that parts receive a coating of lubrication where applicable and so that the shaft does not come to rest in the same position occupied prior to rotation. For long shafts or heavy equipment subject to undesirable bowing, shaft orientation after rotation shall be specified and j obtained." l
- 22) With regard to Section 6.5 of ANSI N45.2.2 - 1972 titled Removal of Items from Storage: SERI does not consider the last sentence of this Section to be applicable to the Operations Phase due to the l6 i relatively short period of time between installation and use. The first sentence of the Section is replaced with: "SERI will develop, 6 j issue, and implement a procedure (s) which cover (s) the removal of items from storage. The procedure (s) will assure that the status of all material issued is known, controlled, and appropriately j dispositioned."
- 23) With regard to Section 6.6 of ANSI N45.2.2 - 1972 titled Storage 16 Records: SERI will comply with the requirements of this Section I with the clarification that, for record purposes, only the access of personnel without Key Cards into indoor storage areas shall be !
recorded. Unioading or pick-up of material shall not be considered
" access," nor shall inspection by NRC or other regulatory agents, nor shall tours by non-SERI employees who are accompanied by SERI l6 l employees.
- 24) With regard to Section 7.3 of ANSI N45.2.2 - 1972 titled Hoisting Equipment: Re-rating of hoisting equipment will be considered only when absolutely necessary. Prior to performing any lift above the load rating, the equipment manufacturer must be contacted for his ,
approval and direction. The manufacturer must be requested to supply l a document granting approval for a limited number of lifts at the new rating and any restrictions involved, such as modifications to be made to the equipment, the number of lifts to be made at the new rating, and the test lift lord. At all times, the codes governing re-rating of hoisting equipment must be observed. NRC Regulatory Guide 1.39 " Housekeeping Requirements for Water-Cooled Nuclear Power Plants" (Rev. 2, 9/77) - Endorses ANSI N45.2.3 - 1973. Thu Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, SERI shall either control these {6 f activities under this Operational QA Program or under an NRC accepted l Construction QA Program (Per OQAM 3.5.18). ;
When this Operational QA Program is used, SERI shall comply with the l6 Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (Subject to the l clarifications in item 2 below) shall apply to these maintenance and modifica- 4 i Rev. 6 g i 15 of 33 J250QAMAPPENDIX 1.A - 15
w j APPENDIX A tion activities evsn though such rsquirem:nts may not have been in effect 1 originally. Technical requirements associated with the maintenance or modifi-cation shall be.the original requirements or better (e.g., code requirements, material; properties, design margins, manufacturing processes, and inspection requirements).
- 2) Specific clarifications for ANSI N45.2.3 - 1973 are indicated for specific Sections below.
~Section 1.4 - Definitions: Definitions in this Standard which are not included in ANSI N45.2.10 will be used; all definitions which are Lincluded in ANSI N45.2.10 will be used as clarified in SERI's j6 commitment to Regulatory Guide 1.74.
Section'2.1 - Planning: SERI may choose not to utilize the five- l6 level zone ~ designation system, but will utilize standard janitorial and work practices to maintain a level of cleanliness commensurate ; with Company policy in the areas of housekeeping, plant and personnel safety, and fire protection. Cleanliness will be maintained, consistent with the work being performede so as to prevent the entry of foreign material into safety-related systems. This will include, as a minimum, documented cleanliness inspections which will be performed prior to system closure. As necessary, (e.g., the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies will be established when major portions of the reactor system are opened j for inspection maintenance or repair. Additional housekeeping requirements will be implemented as required for control of radioactive contamination. Section 2.2 - Procedures and Instructions: Appropriate procedures will be written and implemented. Section 3.1 - Control of Site Area: Not applicable to the Operations phase. Section 3.2 _ Control of Facilities: SERI nay choose not to l6 utilize the five-level zone designation system, but will utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with Company policy in the areas of housekeeping, plant and personnel safety, and fire protection. Cleanliness will be maintained, consistent with the work being performed, so as to prevent the entry of foreign material into safety-related systems. This will include, as a minimum, documented cleanliness inspections which will be performed prior to system closure. As necessary (e.g., the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies will , i be established when major portions of the reactor system are opened for inspection, maintenance or repair. Additional housekeeping requirements will be implemented as required for control of radioactive contamination. Rev. 6 } l 16 of 33 f l J250QAMAPPENDIX 1.A - 16 l l
APPENDIX A Sectio'n 3.3 - Materisis and Equipmtnt: The first paragraph in this Section is not applicable to the Operations phase.
.Section 3.4 - Construction Tools, Supplies, and Equipment: Not applicable to the Operations phase.
Section 3.5 - Surveillance, Inspection, and Examination: Subparagraph (1) is not' applicable to the Operations phase; (2), (3) and (4) will be' implemented. Section 4 - Records: The requirements of Policy 17 and ANSI N45.2.9 as set forth in Appendix A of the Operational QA Program shall be implemented in lieu of the requirements of this Section.
'Section 3.2.3 - Fire Protection and Prevention: The accepted Fire Protection Plan shall be used in lieu of the general requirements in this section.
NRC Regulatory Guide 1.58 " Qualifications of Nuclear Power Plant Inspection. Examination, and Testing Personnel" (Rev. 1, 9/80) - Endorses ANSI N45.2.6 - 1978. The Operational-Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) SERI may choose not to apply the requirements of this Guide to those 6 personnel who are involved in day-to-day operations, surveillance, maintenance and certain technical and support services whose qualifications are controlled by Technical Specifications or other
. Operational QA Program commitment requirements. l
- 2) With regard to Section 1.2 of ANSI N45.2.6 - 1978 titled Applicability: The third paragraph requires.that the Standard be used in conjunction with ANSI N45.2; SERI no longer specifically commits (6 to ANSI N45.2.in the Operational QA Program. The fourth paragraph requires that the Standard be imposed on personnel other than SERI l6 i employees, the' applicability of the Standard to suppliers will be documented and applied, as appropriate, in the procurement' documents for such suppliers.
- 3) With regard to Section 1.4 of ANSI N45.2.6 - 1978 titled Definitions:
Definitions in this Standard which are not included in ANSI N45.2.10 I will be used; all definitions which are included in ANSI N45.2.10 vill be used as clarified in SERI's commitment to Regulatory 6 Guide 1.74. l 4) With regard to Section 2.5 of ANSI N4$.2.6 - 1978 titled Physical: l' SERI will. implement the requirements of this Section with the l6 j stipulation that, where no special physical characteristics are required, none will be specified. The converse is-also true: If no special physical requirements are stipulated by SERI, none are 6 considered necessary. l l Rev. 6 17 of 33 J250QAMAPPENDIX 1.A - 17 ! t l
] ;
APPENDIX A 5)- With regtrd to Szction 3.5 of ANSI N45.2.6 - 1978 titled Education ~- and Experience - Recommendations: SERI reserves the right to use l6 { persvnnel who do not meet all the educational and experience re- j quirements of this Section provided: The use of personnel who do not i s meet these requirements shall be the exception rather.than the rule y and each such case shall receive'a documened management evaluation and justification for the exception. An example of a documented management evaluation and justification would be one which includes objective criteria (examination, review of actual work performed) to demonstrate that equivalent competence is possessed by such an individual.
. o ------------------------------------------------------------------------- _
NRC Regulatory Guide 1.64 " Quality Assurance Requirements for the Design of 1 V,j Nuclear Power Plants" (Rev. 2, 6/76) - Endorses ANSI N45.2.11 - 1974. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications: 4 , i" d 1) For operations phase maintenance and modification activities which
/ are comparable in nature and extent to similar activities conducted
' during the construction phase, SERI shall either control these l6 activities under thfe Operational QA Program or under an NRC accepted Construction QA Program (Per OQAM 3.5.18). When this Operational QA Program is uaed, SERI shall comply with the Regulatory Position l6 V established in this Regulatory Guide in that QA programmatic /
,, administrative requirements incidded therein (subject to the ;
clarifications listed below) shall apply to the 2 maintenance and g modification activities even though such requi m ents may not have been in effect originally. Technical requirements associaced with maintenance and modifications shall be the original requirements or better (e.g., code requirements, material properties, design margins, manufacturing processes and inspection requirements).
- 2) With regard to Paragrapn C.2(1) of Regulatory Guide 1.64: If in an exceptional circumstance the designer's immediate Superviser is the only technically qualified individual available, this review c an be conducted by the Supervisor, providing that: (a) the other pro-visions of the Regulatory Guide are satisfied, and (b) the justific-ation is individually documented and approved in advance by the Supervisor's management, and (c) quality assurance audits cover frequency and effectiveness of use of Supervisors as design verifiers to guard against abuse.
With regard to Section 1.4 of ANSI N45.2.11 - 1974 titled l 3) l Definitions: Definitions in this Standard which are not included in ANSI N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in SERI's commitment to l6 Regulatory Guide 1.74.
- 4) With regard to Sections 2.1 (last paragraph), 2.2 (Items 12 and 13), ;
Section 9, and Section 11 (including subsections 11.1 through 11.7) of ANSI N45.2.11 - 1974: The SERI Audit Program will be implemented l6 in accordance with and to meet the requirements of: ANSI N45.2.12 as endorsed in Appendix A; Policies 2, 3, 16 and 18 of the Operational , l Rev. 6 18 of 33 I J250QAMAPPENDIX 1.A - 18 1 L
APPENDIX A
-QA. Program, and the requiramsnts of the individual nuclear facility 1 Technical Specifications'in lieu of the audit requirements stated in=
the' referenced' sections.
.5) JWithl regard to Section 5.2.4 of ANSI N45.2.11 - 1974 titled Documentation: For the documentation of interdisciplinary design reviews...there must be documented evidence of the. acceptability of design documents or portions thereof, prior to release (material, stress, physics, ~ ~hanical, electrical, concrete, etc.). The signature or ini. 41s of those who determine the acceptability of the design relative to their respective' disciplinary area of concern should be on'the document or on a separate form traceable to the document. A document that' indicates the reviewer's comments need not be retained.
'6) SERI does~not require the SAR to be a design document. However' 6 if the SAR contains any design or design input that has not been previously' documented, reviewed and approved in accordance with the !
requirements contained in'the OQAM or.another approved design control QA program and if the SAR is used as a design document during the , design process, that specific information must be controlled and l
. verified in accordance with the commitments here and Policy 3 of the 0QAM. f i
- 7) With regard to Section 6.1 of ANSI N45.2.11 - 1974 titled General:
The third paragraph in this'Section stitulates certain requirements relative to "the results of design verification." SERI may comply l6 with these requirements by having the Reviewer (s) sign and date an appropriate document providing the following conditions are also met: a). Documented engineering / design procedures are established winich cover the extent of design review. b). The procedures identify the duties of the Reviewer and the extent of this responsibility for which he attests with his signature. c) The procedures specify the extent of documentation necessary for the type of design verification applicable to the complexity of the design. d) The signature and date is affixed in accordance with the ! procedures. SERI shall also permit initials to be used in' lieu of the signature h required above IF a file is maintained to correlate characteristic initials versus individuals such that each set of characteristic initials can be traced to sn individual. This correlation must be readily available to NRC inspector whenever the document is being used.
<8) The' timing of design verification is not mentioned in the Standard. J SERI shall perform verification in a timely manner. If other than by l6 l qualifications testing of a prototype or lead production unit, veri-fication should be completed prior to release for procurement, manufacturing or construction or release to another organization for Rev. 6 19 of 33 I
'J250QAMAPPENDIX 1.A -'19
APPENDIX A use in other design activities. In those cases where this timing cannot be met, the design verification may be deferred, providing that the justification for this action is documented and the un-verified portion of the design output document and all design output documents, based on the unverified data, are appropriately identified and controlled. Site activities associated with a design or design change shall not proceed without verification past the point where the installation would become irreversible without extensive de-molition and rework. In all cases, the design verification shall be completed prior to relying upon the component, system, or structure to perform its safety-related function.
- 9) With regard to Section 10 of ANSI N45.2.11 - 1974 titled Records:
SERI shall maintain records in accordance with end to meet the l6 requirements of Policy 17.0 of the OQAM and ANSI N45.2.9 as specified in Appendix A. The additional requirements of the first sentence of the second paragraph in this Section shall also be met. NRC Regulatory Guide 1.74 " Quality Assurance Terms and Definitions" (2/74) - Endorses ANSI N45.2.10 - 1973. g The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) SERI reserves the right to define additional words or phrases which l6 are not included in this Standard. Such additional definitions will be documented in appropriate procedures and/or in attachments /
appendices to the Quality Assurance Procedures Manual, or in Policies of the Operational QA Program. See Policy 2, Paragraph 2.5.8.
- 2) In addition to the Standard's definition of " Inspection," SERI will 6 use the following: " Inspection (When used to refer to activities that are NOT performed by quality organization personnel) -
Examining, viewing closely, scrutinizing, looking over or otherwise checking activities. Personnel performing these functions are not necessarily certified to ANSI N45.2.6." When SERI intends for Inspections to be performed in accordance l6 with the Operational QA Program by personnel certified as required by that Program and for activities defined by " Inspection" in ANSI N45.2.10, appropriate references to the quality assurance organiza-tion which will perform the activity or to Quality Assurance Procedures to be used for performing the activity will be made. If such references are NOT made, inspections are to be considered under the additional definition given above. Inspections to meet the intent of 10CFR50 Appendix B are described in Policy 10 of the OQAM.
- 3) In addition to the Standard's definition of " procurement documents,"
SERI will utilize the definitions given in ANSI N45.2.13 and in l6 Regulatory Guide 1.74. The compound definition is given as follows:
" Procurement documents - Contractually binding docutaents that identify and define the requirements which items or services must Rev. 6 20 of 33 J2500AMAPPENDIX 1.A - 20
APPENDIX A meet in order to be considered acceptable by the purchaser. They include documents which authorize the seller to perform services or supply equipment, material or facilities on behalf of the purchaser (e.g. contracts, letters of intent, work orders, purchase orders, or proposals and their acceptance, drawings, specifications, or instructions which define requirements for purchase)."
- 4) " Program Deficiencies" (Not defined in ANSI N45.2.10, but used and defined differently in ANSI N45.2.12) - Failure to develop, document or implement effectively any applicable element of the Operational QA Program.
- 5) " Quality Assurance Program Requirements" (Not defined in ANSI N45.2.10 but used and defined differently in ANSI N45.2.13) - Those individual requirements of the Operational QA Program which, when invoked in total or in part, establish the requirements of the quality assurance program for the activity being controlled.
Although not specifically.used in the Operational QA Program, ANSI N45.2 may be imposed upon SERI's suppliers. l6
- 6) This section deleted in Revision 4.
- 7) " Independent Verification" - Verification by an individual other than the persca who performed the operation or activity being verified that required actions have been completed. Such verification will not require confirmation of the identical action wher, other indications provide assurance or indication that the prescribed activity is in fact complete. Examples include, but are not limited to: verification of a breaker opening by observing remote breaker indication lights; verification of a set point (made with a voltmeter or ammeter for example) by observing the actuation of status or indicating lights at the required panel-meter indicated value, verification that a valve has been positioned by observing the starting or stopping of flow on meter indications or by remote value positions indicating lights.
- 8) "NRC accepted Construction QA Program" - (1) a program for design or construction which was reviewed by the QA organization of the NRC and accepted for use; (2) the revision of that NRC accepted program which is in effect at the time that SERI authorizes commencement of work; 6
and (3) a program which the SERI Quality Assurance organization reviews and concurs thet the QA Program controls are acceptable for the activity to be perfocmed. (
Reference:
0QAM 3.5.18)
- 9) "Special Processes" - frocesses which are controlled and monitored in accordance with approved procedures where required quality levels cannot be assured by inspection of the processed articles alone, or where it is more effective to control the process than inspect the completed article.
- 10) " Permanent Plant Device" (when used with respect to instrumentation)
- A device, permanently installed, which functions as a part of a system and is used for monitoring a process varinble in the plant.
- 11) " Concurrence" (when used with respect to and in association with a review activity) is defined to mean: (1) a review of a document or Rev. 6 21 of 33 J250QAMAPPENDIX 1.A - 21 C---- _-_ - -__- _-__ --_- _ - _ __ _ - _ _ _ _ __
APPENDIX A portion thereof under consideration; (2) a conclusion that all pertinent and necessary requirements (within the purview of the one performing the review) have been included; and, (3) essential ! agreement and belief that the manner in which the requirements have l been addressed will produce the intended results. l NRC Regulatory Guide 1.88 " Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records"(Rev. 2, 10/76) - Endorses ANSI N45.2.9-1974. The operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) With regard to Section 3.2.1 of ANSI N45.2.9 - 1974 titled Generation of Quality Assurance Records: The phrase " completely filled out" is clarified to mean that sufficient information is recorded to fulfill the intended purpose of the record.
- 2) With regard to Section 3.2.2 of ANSI N45.2.9 - 1974 titled Index:
The phrase "an index" is clarified to mean a collection of documents or indices which, when taken together, supply the information attributed to "an index" in the Standard. The specific location of a record "within a storage area" may not be delineated (e.g., The specific location within a computer record file may not be constant. Further, SERI may utilize a computer assisted l6 random access filing system where such location could not ba readily
" documented." nor would such a location be " relevant.") The storage location will be delineated, but where file locations change with time, the specific location of a record within that file may not always be documented.
- 3) With regard to Section 4.2 of ANSI N45.2.9 - 1974 titled Timeliness:
SERI's contractual agreement with its contractors and suppliers will l6 constitute fulfillment of the requirements of this Section.
- 4) With regard to Section 5.4 of ANSI N45.2.9 - 1974 titled Preservation: The following clarification is substituted for the current subsection 5.4.2 " Records shall not be stored loosely. They shall be secured for storage in file cabinets or on shelving in containers."
The following clarification is substituted for the current subsection 5.4.3 " Provisions shall be made for special processed records (such as radiographs, photographs, negatives, microfilm and magnetic media) to prevent damage from excessive light, stacking, electromagnetic fields, temperature and humidity as appropriate to the record type."
- 5) With regard to Section 5.5 of ANSI N45.2.9 - 1974 titled Safekeeping:
Routine general office and nuclear site security systems and access controls are provided: no special security systems shall be established for record storage areas. Rev. 6 22 of 33 J250QAMAPPENDIX 1.A - 22
l APPENDIX A
, 6) With'rsgard to S2ction 5.6 of ANSI N45.2.9 - 1974 titled Facility: q This Section provides no distinction between temporary and permanent facilities. To cover temporary storage, the following clarification j is added: " Active (in-process) records will be stored in one-hour i fire rated file cabinets. In general, records shall not be maintained l
'in' temporary storage for more than three months after completion. Any exceptions to this requirement must be evaluated and approved by the i Director, Quality Programs; a list;of all such excepted records shall 6 j be maintained and'available'for NRC review. Exceptions may include l records needed on a' continuing basis for an extended period of' time. j (e.g., personne1' qualification and training' records, equipment history records) and records which are' cumulative in nature (e.g.,
nonconforming. item logs)." Paragraph 4, subsection 3 is clarified to require a two-hour minimum fire rating to be consistent with the 1979 version of the Standard and NRC Criteria for Record Storage Facilities (Guidance-ANSI , N45.2.9, Section 5.6) issued.7/1/80. ) Paragraph 4, subsection 9 is clarified to read: "No pipea or ; penetrations except those providing fire protection, lighting, 'I temperature / humidity control, or communications are to .e located f within the. facility. All such penetrations shall be sealed or i dampered to comply with a minimum two-hour fire protection rating." l 7)- With re;;ard to Section 5.3 of ANSI N45.2.9 - 1974 titled Storage: The first sentence is clarified by stating that an individual shall be designated and assigned the responsibility for enforcement of written record storage procedures for each record storage location. The term
" custodian" may or may not be used as part of that designation.
NRC Regulatory Guide 1.94 " Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants" (Rev. 1, 4/76) - Endorses ANSI N45.2.5.1974. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications: ;
- 1) For operations phase maintenance and modification activities which are comparable in nature end extent to similar activities conducted during the construction phase, SERI shall either control these l6 activ$ ties under this Operational QA Program or under an NRC accepted Construction QA Program (Per OQAM 3.5.18). When this Operational QA Program is used, SERI shall' comply with the Regulatory Position 6 established in this Regulatory Guide in that QA programmatic /
administrative requirements included therein shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with maintenance and modifications shall be the original requirements or better (e.g., code requirements, material properties. design margins, manufacturing processes and inspection requirements). Rev. 6 23 of 33 J250QAMAPPENDIX 1.A - 23 _ _ - _ = _ _ _ - _ . _
i APPENDIX A I
- 2) With regard to Section 1.2 of ANSI.N45.2.5 - 1974 titled Applicability: The first sentence in this Section is not applicable SERI shall comply with the third sentence 6 to the operations phase.
in this Section with the clarifications that "importance of the item or service involved" is interpreted to mean those to which~ the OQAM applies, and the extent of coverage shall be defined by supervisory maintenance personnel by the way in which they implement the other requirements of this Standard. . 6 In the second paragraph of this Section, SERI shall substitute the words " maintenance and modification" for the word " construction" as the modifier of " procedures." l
.3) With regard to Section 1.3 of ANSI N45.2.5 - 1974 titled Responsibility: This Section's requirements are met-by the definitions for positions and the organizational responsibilities
' outlined in the Technical Specifications, Policy 1 of the 0QAM and the position descriptions for plant personnel. 4). With regard to Section 1.4 of ANSI N45.2.5 - 1973 titled Definitions: Definitions in this Standard which are not included in ANSI N45.2.10 shall be used: All definitions which are included in ANSI N45.2.10 6 shall be used as clarified in SERI's commitment to Regulatory Guide 1.74.
- 5) With regard to Section 2.1 of ANSI N45.2.5 - 1974 titled Planning:
Planning requirements, when necessary, shall be incorporated into maintenance and modification procedures.
- 6) With regard to Section 2.5.2 of ANSI N45.2.5 - 1974 titled Calibration and Control: The last sentence of this section requires that all .tems inspected with M&TE which is found to be out of calibration shall be considered unacceptable. We will comply with an alternate which will require evaluation to determine the validity of previous measurements. This alternative is consistent with ANSI N45.2.4, Section 2.5.2; ANSI N45.2.1, Section 2.5.2; ANSI N45.2.8, Section 2.8.2;' ANSI N45.2.13, Section 7.4.2, and ANSI N18.7, Section 5.2.16.
- 7) With regard to Section 5.5 of ANSI N45.2.5 - 1974 titled Welding:
SERI will comply with inspection requirements of the applicable l6 welding codes identified in the FSAR and any exceptions thereto. NRC Regulatory Guide 1.116 " Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems" (Rev. 0-R, 6/76) - Endorses ANSI N45.2.8 - 1975. I The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) For operations phase maintenance and modification activities which j are comparable in nature and extent to similar activities conducted 4 during the construction phase, SERI shall either control these l6 activities under this Operational QA Program or under an NRC accepted Rev. 6 -
l 24 of 33 f J250QAMAPPENDIX 1.A - 24 l
APPENDIX A Construction QA Program (Per OQAM 3.5.18). When this Operational QA Program is used, SERI shall comply with the Regulatory Position 6 established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to these maintenance ,aad modification activities even though such requirements may not have been in effect originally. Technical requirements associated with maintenance and modifications shall be the original requirements or bettet (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).
- 2) With regard to Section 1.1 of ANSI N45.2.8 - 1975 titled Scope: The last paragraph of this Section is not applicable to the operations phase. The app 11:able portions of the requirements of this Standard shall also be applied after fuel load; therefore, the last twenty-two words in the last senter.ce of the second paragraph under this Section are also not appropriate to the operations phase.
- 3) With-regard to Section 1.2 of ANSI N45.2.8 - 1975 titled Applicability: The first sentence in this Section is not applicable to the operaticns phase. SERI shall comply with the third sentence l6 in this Section with the clarifications that "important mechanical systems to be covered" is interpreted to mean those to which the 0QAM applies, and "the extent of coverage" shall be defined by supervisory maintenance personnel by the way in which they implement the other requirements of this Standard.
- 4) With regard to Section 1.3 of ANSI N45.2.8 - 1975 titled Responsibility: This Section's requirements are met by the definitions for positions and the organizational responsibilities outlined in the Technical Specifications, Policy 1 of the 0QAM and the position descriptions for plant personnel.
- 5) With regard to Section 1.4 of ANSI N45.2.8 - 1975 titled Definitions:
Definitions in this Standard which are not included in ANSI N45.2.10 shall be used: All definitions which are included in ANSI N45.2.10 shall be used as clarified in SERI's commitment to Regulatory l6 i Guide 1.74.
- 6) With regard to Section 2.1 of ANSI N45.2.8 - 1975 titled Planning:
Planning requirements, when necessary, shall be incorporated into maintenance and modification procedures. 1 ------------------------------- ----------------- ---------------------------- NRC Regulatory Guide 1.123 " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" (Rev. 1, 7/77) - Endorses ANSI N45.2.13 - 1976. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) With regard to Section 1.3 of ANSI N45.2.13 - 1976 titled Definitions: With two exceptions (Procurement Document and Quality Assurance Program Requirements) definitions in this Standard which are not included in ANSI N45.2.10 will be used; all definitions which Rev. 6 25 of 33 J250QAMAPPENDIX 1.A - 25
l APPENDIX A are included in ANSI N45.2.10 vill be used as clarified in SERI's 6 commitment to Regulatory Guide 1.74. The two exceptions are defined in Appendix A under Regulatory Guide 1.74.
- 2) With regard to Section 1.2.2 of ANSI N45.2.13 - 1976 titled Purchaser's Responsibilities: Item c is one of the options which may be used by SERI to assure quality; however, any of the options given l6 in 10CFR50, Appendix B, Criterion VII as deplemented by Policies 4 and 7 of the Operational QA Program may also be used.
- 3) With regard to Section 3.1 of ANSI, N45.2.13 - 1976 titled Procurement Document Preparation, Review and Change Control: The phrase "the same degree of control" is stipulated to mean " equivalent level of review and approval." The changed document may not always be ,
rereviewed by the originator; however, at least an equivalent level of management / supervision shall review and approve any changes.
- 4) With regard to Section 3.4 of ANSI N45.2.13 - 1976 titled Procurement Document Control: SERI will meet the requirements of Policies 4 l6 and 7 of the Operational QA Program in lieu of the requirements specified in this Section.
- 5) With regard to Section 5.3 of ANSI N45.2.13 - 1976 titled Preaward Evaluation: SERI will comply with an alternate paragraph which l6 reads: "Except in unusual circumstances (e.g., replacement parts are needed to preclude the development of some unsafe condition at a nuclear facility), a preaward evaluation of the Supplier shall be performed as required by the Operational QA Program."
- 6) With regard to Section 6.4 of ANSI N45.2.13 - 1976 titled Control of Changes in Items or Services: The phrase "the Operational QA Program" will be inserted in lieu of " ANSI N45.2, Section 7."
- 7) With regard to Section 8.2 of ANSI N45.2.13 - 1976, titled Disposition: The third sentence of item b is revised to read:
Nonconformances to the contractual procurement requirements or Purchaser approved documents which consist of one or more of the following shall be submittad to the Purchaser for approval of the recommended disposition prior to shipment when the noncon-formance could adversely affect the end use of a module or shipable component # relative to safety, interchangeability, operability, reliability, integrity, or maintainability:
- 1) Technical or material requirement is violated;
- 2) Requirement in Supplier documents, which have been approved by the Purchaser, is violated;
- 3) Nonconformance cannet be corrected by continuation of the original manufacturing process or by rework; and/or Rev. 6 26 of 33 J250QAMAPPENDIX 1.A - 26 L_ _ _ _- - - _ - _ _ _ - _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____ _ _ ____
APPENDIX A.
- 4) The itsm does not conform to the original requirement even though the item can be restored to a condition such that the capability of the item to function is unimpaired.
# A module'is an assembled device, instrument, or piece of equipment identified by serial number or other identification code, having been evaluated by inspection and/or test for conformance to procurement l requirements regarding end use. A shippable component is a part or subassembly of a device, instrument, or piece of equipment which is shipped as an individual item and which has been evaluated by in-spection and/or test for conformance to procurement requirements regarding end use.
- 8) With regard tu Section 12 of ANSI N45.2.13 - 1976 titled A_udit of Procurement Program: The SERI audit program will be implemented 6 in accordance with and to meet the requirements of: ANSI N45.2.12 as endorsed in Appendix A; Policies 2, 4 and 18 of the Operational QA ,
Program, and the requirements of the individual nuclear facility ! Technical Specifications.
- 9) Paragraph C.6.e of Regulatory Guide 1.123 (and Section 10.3.4 of ANSI N45.2.13 which it references) shall be implemented as originally written (i.e. with the verb "should" instead of the verb "shall").
This flexibility is necessary because SERI may not always be able 6 ' to obtain agreement with a Supplier. SERI retains the ultimate responsibility for performance of purchased equipment. The appropri-ate SERI engineering discipline w!11 exercise this management / l6 engineering prerogative with respect to the final decision on post I installation test requirements.
- 10) With regard to Section 11 of ANSI N45.2.13 - 1976 titled Quality Assurance Records: SERI shall maintain records in accordance with l6 and to meet the requirements of Policy 17 of the 0QAM at1 ANSI N45.2.9 as specified in Appendix A.
NRC Regulatory Guide 1.144 -
" Auditing of Quality Assurance Programs for Nuclear Power Plants (Rev. 1, 9/80) - Endorses ANSI N45.2.12 - 1977.
The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) With regard to Section 1.4 of ANSI N45.2.12 - 1977 titled Definitions: With two exceptions (Program Deficiencies and audits) the definitions in this Standard which are not included in ANSI J N45.2.10 will be used: All definitions which are included in ANSI ]
N45.2.10 will be used as clarified in SERI's commitment to l 6- l Regulatory Guide 1.74. The excepted definitions are defined in Appendix A under Regulatory Guide 1.74.
- 2) With regard to-Section 2.2 of ANSI N45.2.12 - 1977 titled 1 Personnel Qualification: The qualification of SERI audit personnel l6 will be accomplished as described to meet the requirements of ANSI N45.2.23 - 1978 as endorsed in Appendix A and Policies 2 and 18 of the Operational QA Program.
Rev. 6 J250QAMAPPENDIX 1.A - 27
l APPENDIX A i
- 3) With regard to Section 2.3 (and subsections 2.3.1 through 2.3.3) of !
ANSI N45.2.12 - 1977 titled Training: The training of SERI l6 : audit personnel will be accomplished as described to meet the require- { ments of ANSI N45.2.23 - 1978 as endorsed in Appendix A and Policies 2 i and 18 of the Operational QA Program.
- 4) !"th regerd to Section 2.4 ef ANSI N45.2.12 - 1977 titled Maintenance of Proficiency The maintenance of proficiency of SERI audit 6 j personnel will be accomplished as described to meet the requirements j of ANSI N45.2.23 1978 as endorsed in Appendix A and Policies 2 and 18 j of the Operational QA Program. ;
I
- 5) With regard to Section 3.3 of ANSI N45.2.12 - 1977 titled [
Essential Elements of the Audit System: SERI will comply with l6 l subsection 3.3.5 as it was originally written (subsection 3.2.5) in i ANSI N45.2.12, Draft 3, Revision 4: " Provisions for reporting on the j effectiveness of the quality assurance program to the responsible ! management." For the auditing organization (SERI), effectiveness is l6 ) reported as required by the individual nuclear facility Technical Specifications and paragraphs (currently numbered 1.3.1, 1.3.2 and 1.3.15) in Policy 1 of the Operational QA Program. Other than audit reports, SERI may not directly report on the effectiveness of l6 the quality assurance programs to the audited organization when such I6 organizations are outside of SERI. I Subsection 3.3.6 requirements are considered to be fulfilled by compliance with the organization and reporting measures outlined in the Operational QA Program. Subsection 3.3.7 requires verification of effective corrective action j on a " timely basis." Timely basis is interpreted to mean within the i framework or period of time for completion of corrective action that is accepted by the organization. Each finding requires a response and a corrective action completion date; these dates are subject to revision (with the approval of the quality organization) and must be escalated to higher authority when there is a disagreement between the audited and the auditing organization on what constitutes " timely corrective action."
- 6) With regard to Section 3.5 of ANSI N45.2.12 - 1977 titled Sched-uling: Subsection 3.5.3.1 is interpreted to mean that SERI may l6 procedurally control qualification of a contractor's or supplier's t quality assurance program prior to awarding a contract or purchase l order by means other than audit.
- 7) With regard to Section 4.3.1 of ANSI N45.2.12 - 1977 titled Pre-Audit Conference: SERI will comply with the requirements of this Section by l6 inserting the word "Normally" at the beginning of the first sentence.
This clarification is required because, in the case of certain unannounced audits or audits of a particular operation or work activity, (Monitoring Audit Report) a pre-audit conference might interfere with the spontaneity of the operation or activity being audited. In other cases, persons who should be present ae a pre-audit conference may not always be available: such lack of availability should not be an impediment to beginning an audit. Even in the above Rev. 6 l 28 of 33 J250QAMAPPENDIX 1.A - 28 L__ _ _
APPENDIX A extaples, which'are not intended to be all inclusive, the material
~
set forth in Section 4.3.1 will be covered (if considered necessary or desirable as determined-by the Audit Team Leader by signature on
~
the audit report) during the course of the audit. 8). . With regard to Section 4.3.2 of ANSI N45.2.12-1977 titled Audit 1 Process: l (a) Subsection 4.3.2.2 could be. interpreted to limit auditors to the review of only objective evidence; sometimes and'for some program elements, no objective evidence may be available. SERI 6 ' will comply with an alternate sentence which reads: "When available, objective evidence shall be examined for compliance with quality asssurance program requirements. If subject'ive evidence is used (e.g., personnel interviews) then the audit report must indicate how the evidence was obtained." (b) Subsection 4.3.2.4 is modified as follows to take into account { the fact that some nonconformances are virtually " obvious" with respect to the needed corrective action: "When a nonconformance
~
or quality assurance program deficiency is identified as a result of an audit, unless the apparent cause, extent, and corrective action are readily evident, further investigation shall be conducted by the audited organization in an effort to identify the cause and effect and to determine the extent of the corrective action required." (c) Subsection 4.3.2.5 contains a recommendation wl.eh is clarified with the definition of " acknowledged by a member of the audited organization" to mean that "a member of the audited organization has been informed of the findings;" it does not mean that that person agrees with the findings. Agreement or disagreement with a finding may be expressed in the response from the audited organization. (d) Subsection 4.3.2.7 is not considered applicable as written. SERI will comply with an alternate sentence which reads: l6
" Corrective action taken as a result of the last previous audit of the same area shall be reviewed or reaudited, if necessary, to evaluate the effectiveness of the action to resolve the identified nonconformance."
I 9)' With regard to Section 4.3.3 of ANSI N45.2.12 - 1977 titled Post-Audit Conference: SER1 will substitute and comply with the following l6 paragraph: "For all external audits, a post-audit conference shall be held with management of the audited organization to present audit ' findings and clarify misunderstandings; where no adverse findings exist, this conference may be waived by management of the audited organization: such waiver shall be documented in the audit report. Unless unusual operating or maintenance conditions preclude attendance by appropriate managers / supervisors, a post-audit conference shall be held with managers / supervisors for all internal ; audits for the same reasons as above. Again, if there are no adverse l l Rev. 6 29 of 33 J250QAMAPPENDIX 1.A - 29 c
APPENDIX A findings, mrnagtment of the internal audited organiz tion may waive the post-audit conference: such waiver shall be documented in the audit report."
- 10) With regard to Section 4.4 of ANSI N45.2.12 - 1977 titled Reporting:
(a) This Section requires that the audit report shall be signed by i the audit team leader; this is not always the most expeditious route to take to assure that the audit report is issued as soon as practical. SERI will comply with Section 4.4 as clarified in l6 l the following opening: "An audit report, which shall be signed l by the audit team leader, or his supervisor in his absence, shall provide:" In cases where the audit report is not signed by the Lead Auditor due to his absence, one record copy of the report must be signed by the Lead Auditor upon his return. The report shall not require the Lead Auditor's review / concurrence / signature if the Lead Auditor is no longer employed by SERI.at the time the audit report is issued. l6 (b) SERI will comply with subsection 4.4.3 clarified to read:
" Supervisory level personnel with whom significant discussions were held during the course of pre-audit (where conducted),
audit, and post-audit (where conducted) activities." (c) Audit reports may not necessarily contain an evaluation statement regarding the effectiveness of the quality assurance program elements which were audited, as required by subsection 4.4.4, but they will provide a summary of the audited areas and the results. (d) Subsection 4.4.6 requires audit reports to include recommendations for corrective actions; SERI may choose not 6 to comply with this requirement. Instead, SERI auditors / lead auditors are required to document all adverse audit findings. The procedure for processing nonconformance documents allows the auditor / lead auditor to document actions which are considered necessary to correct the finding, the auditor / lead auditor may also document actions which are considered unacceptable for correcting the finding: the nonconformance document with these
" Auditor Recommendations" is then transmitted to the audited ,
organization. In addition, the auditor / lead auditor or 6 appropriate QA Supervisor is required to review corrective action taken for the nonconformance document and determine if it is acceptable. Any disagreements must be escalated to higher management for resolution. l (e) The last paragraph in Section 4.4 deals with distribution of 1 audit reports. SERI will comply with these requirements after l6 1 ) substituting the following for the last sentence: "The audit i report shall be issued within thirty working days after the last day of the audit." i
- 11) With regard to Section 4.5.1 of ANSI N45.2.12 - 1977 titled i j By Audited Organization: SERI will comply with the following l6 1 clarification of this Section: " Management of the audited organization Rev. 6 1 30 of 33 J250QAMAPPENDIX 1.A - 30
APPENDIX A "or activity shall.rsview and investigate all advarse audit findings, as nscessary, to determine end schsdule appropriate corrective action including action to prevent' recurrence. They shall respond, in writing, within thirty working' days after the date of issuance of the audit report clearly stating the corrective action taken or planned to prevent recurrence and the results of the investigation if conducted. However, written response is not.necessary if corrective action is taken and verified prior to thirty days. The audited organization shall take appropriate action to assure that corrective action is accomplished as scheduled."'The Director, Quality Programs may, at 6 his discretion, waive the requirement for a supplementary response.
- 12) With regard to Sections 3.4 and 4.2.1 of ANSI N45.2.12 - 1977 titled-Audit Planning and Written Plan respectively: In the case of a
. Monitoring Audit Report provisions'for " Written Plan" is met by the overall audit planning documents, which may include the audit plan. :
The audit plan is encompassed by the individual audit report (although may not be identified uniquely as audit plan). In the case of Monitoring Audit Reports the written plan may appear in a different form.
- 13) Paragraph C.3.a of Regulatory Guide 1.144 (and Section 3.5.2 of ANSI N45.2.12 which it references) shall be implemented by meeting the audit requirements of the GGNS Technical Specifications for audits.
under C.3.a(1). Audits under C.3.a(2) fare not covered by this 0QAM.
- 14) Paragraph C.3.b(2) first sentence is replaced with the following: 6 Each Supplier is evaluated initially to determine the acceptability of his quality assurance program. If acceptable, the Supplier is placed on the qualified Supplier list. Audits, when used as the.se- 6 lected method of source verification, shou 3d be conducted as follows:
Paragraph C.3.b(2), second paragraph is replaced with the following: 6 An evaluation of the supplier should be performed annually. This evaluation must be formal, with the results documented and approved by responsible QA management; and it must consider pertinent factors such as the results of other audits, history of performance of product and/or purchased service, s ad effectiveness of implementation of the Supplier's QA program. This aanual evaluation shall consider the complexity of the component concerned and the degree of quality and process control required by the manufacturing effort. As a result of the evaluation, Suppliers requiring a formal reaudit are identified. Regardless of the results of the evaluation, Suppliers 6 shall be re-audited every three years. Paragraph additions to C.3.b(2) are as follows: Previously evcluated and approved active suppliers, for which audit is not the selected method of source verification, should be evaluated concurrent with the award of a contract. Regardless of the.results of the eval-uation, active suppliers (except those excluded under C.3.b(1) above) 6 shall have been source verified (audit, surveillance or inspection) within two years prior to award of a contract or have source ver-ification performed. Rev. 6 { 31 of 33 J250QAMAPPENDIX 1.A - 31
APPENDIX A Inactive Suppliera shall be evaluated prior to supplying safety-related items or services. An audit shall be conducted IF required to determine the acceptability of procured items or services (i.e., acceptability cannot be determined by receipt inspection or one of the other methods allowable under 10CFR50, Appendix B, Criterion VII).
- 15) Paragraph ~C.4.a of Regulatory Guide 1.144 (and Section 3.5.3.3 of ANSI N45.2.12 which it references) shall be implemented with the clarification that the Director, Quality Programs or his designee l6 shall determine which reorganizations or procedure revisions are "significant."
- 16) With regard to Section 5.1 of ANSI N45.2.12 - 1977 titled General:
SERI shall maintain records in accordance with and to meet the 6 requirements of Policy 17.0 of the OQAM and ANSI !.45.2.9 as specified in Appendix A.
- 17) With regard to Section 4.3.2 of ANSI N45.2.12 - 1977 titled Audit Process: Subsection 4.3.2.6 is modified as follows to account for the fact that immediate notification is not always possible: " Conditions requiring immediate corrective action (i.e., those which are so severe that any delay would be undesirable) shall be reported to management of the audited organization. Where responsible management personnel are available (such as at an operating nuclear power plant), these conditions shall be reported immediately. If respon-sible management personnel are not available (such as at a Supplier's shop on a back shift or for items discovered during a review of vendor supplied materials), these conditions shall be reported as soon as practical.
---------- _------------ _ - =------------ _ __ --- ---- ----------
NRC Regulatorv Guide 1.146 " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" (Rev. O, 8/80) - Endorses ANSI N45.2.23 - 1978. The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) With respect to Section 2.2 of ANSI N45.2.23 - 1978 titled Qualification of Auditors: Subsection 2.2.1 references an ANSI B45.2 (presumed to be N45.2); the Operational QA Program does not include a commitment to this. standard; therefore, SERI will comply with an l6 alternate subsection 2.2.1 which reads:
Orientation to provide a working knowledge and understanding of the Operational QA Program, including the ANSI standards and Regulatory Guides included in Appendix A of that Program, and SERI's procedures for implementing audits and reporting results. l6 Rev. 6 32 of 33 J250QAKAPPENDIX 1.A - 32
APPENDIX A
- 2) With respect to Section 4.1 of ANSI N45.2.23 - 1978 titled Organizational Responsibility: SERI will comply with this Section 6 with the substitution of the following sentence in place of the last !
sentence in the Section. l The Director, Quality Programs, Manager, Quality Systems or Lead Auditor shall, prior to commencing the audit, assign personnel who collectively have experience or training commen-surate with the scope, complexity, or special nature of the activities to be audited. Self-initiated Monitoring Audit Reports (MARS) will be performed by qualified auditors, but no 1 assignment is made " prior to commencing the audit" since it is I self-initiated. I
- 3) With respect to Section 3.2 of ANSI N45.2.23 - 1978 titled liaintenance of Proficiency: SERI will comply with the requirements l6 of this Section by defining " annual assessment" as one which takes place at least every twelve (12) months (to a maximum of fifteen
[15]) and which uses either the initial date of certification or the last annual assessment date (not the calendar year) as the starting date for determining when such annual assessment is due.
- 4) With respect to Section 5.3 of ANSI N45.2.23 - 1978 titled Updating of Lead Auditors' Records: SERI will substitute the following l6 sentence for this Section:
Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Section 3.2 (as clarified).
- 5) With respect to Section 5.4 of ANSI N45.2.23 - 1978 titled Record Retention: SERI will substitute the following sentence for this 6 Section.
Qualification records shall be retained as required by the Operational QA Program.
- 6) With regard to Section 2.3.1.3 of ANSI N45.2.23 - 1978 titled Other Credentials of Professional Competence: Add "This includes RO (maximum of 1 credit) and SRO (maximum of 2 credits) licenses" to last sentence of this subsection.
i Rev. 6 33 of 33 J250QAMAPPENDIX 1.A - 33 _ _ ._ __ _____ D
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