AECM-90-0173, Requests Approval for Proposed Change to Plant Supplier QA Organization
| ML20059N144 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/25/1990 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AECM-90-0173, AECM-90-173, NUDOCS 9010100151 | |
| Download: ML20059N144 (261) | |
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. September 25 -1990 Ih,,s U.S. Nuclear Regulatory Commission Mail Station P1-137 t Washingtoa,'D.C. 20555-t Attention: Document Control lesk L Gentlemen: .;
SUBJECT:
. Grand Gulf Nuclear Station-
)
Unit 1 Docket No. 50-416 -
License No. NPF-29 Supplier Quali_ty Assurance i Consolidation and Operational-Quality Assurance Manual (0QAM)
Revision 9a
- By this' letter, Entergy Operations, Inc. is submitting-a proposed l organization change to the Grand Gulf supplier quality. assurance organization. l 1 This change will result in nuclear site supplier quality assarance l organizations reporting to a centralized manager, rather than the site quality l- assurance organization.
Although the change is acceptable under 10CFR50.54, we are requesting .
your approval prior to implementation in accordance Lwith our commitment to do L so contained in the approved August 15, 1989' license amendment request which established Entergy Operations as a licensee for the Grand Gulf Euclear-i Station. Similar proposals are being submitted by Entergy Operations - -
Arkansas Nuclear One and Entergy Operations - Waterford 3.
l Because the original submittals were largely identical, the NRC named a lead Project Manager to coordinate the Staff review. Entergy Operations feels ,
that such an approach was effective and efficient for both the Staff and the J licensees. Consequently, we request that the Waterford 3 Project Manager (the lead Project Manager on the previous review) again lead the review effort for -_ ;
the present submittal. Since the Waterford 3 Project Manager remains familiar with the reasons behind the original commitment which led to this submittal, >
and since the three nuclear site submittals are again-largely identical, we feel that a consolidated review would best serve the Staff and Entergy- '
Operations.
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.i AECM-90/0173 ;
Page 2 To aid in your review, we have submitted the 0perational Quality ~
j Assurance' Manual ;
- to the previously(0QAM), acceptedGGNS-TOP-1A, version in a format to clearly The material which show has allbeen-changes, '
deleted is- shown hyphenated-through(Revision- ( cu,iA ); the new 9).material has been snown in light. italics:( e.mnple). This format is used in. Attachment C.
Attachment 0 is the identical Manual with the overstrike material deleted and- (
the light italics material incorporated. (his format is'the actual record. <
' copy of our submittal. A revision bar and the number "9a" in the right-hand margin identifies each change.
.Yours truly,.
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WMG/MJM/WTC:mtc .
Attachments: A.- Discussion of Proposed Changes B.- 10CFR50.54 Evaluation C. 00AM,- Revision 9a, Highlight Fonnat' .
D. 00AM, Revision 9a, Official Submittal per 10CFR50.54(a)(3) ,
.E. Organization Chart for the Planning ~& Assurance Department- l cc: Mr. D. C. Hintz (w/o) 1 Mr. T. H. Cloninger (w/o)
Mr. R. B. McGahee (w/o) .
Mr. N. S. Reynolds.(w/o)
Mr. H. L. Thomas (w/o)
Mr.H.O.Christensen(w/a)
Mr. Stewart D. Ebneter (w/a)~
Regional Administrator U.S. Nuclear Regulatory Commission Region II-101 Marietca St., N.W., Suite 2900 Atlanta, Geiorgia 30323 l l
Mr. L. L. Kintner, Projwt Manager (w/a)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 11021 Washington, D.C. 20555- 1 1
Mr. D. L. Wigginton, Project Manager (w/a)
Division of Reactor Projects III, IV, and V and Special Projects Office of Nuclear Reactor Regulation l U.S.- Nuclear Regulatory Commission Mail Stop 13D18 Washington, D.C. 20555 A9009171/SNLICFLR - 2 l ;
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l AECM-90/0173i P gs 3- J bec: .Mr._R.' W.'Byrd (w/E)
L Mr._M.lA. Dietrich-(w/a)
Mr. W. E. Edge (w/a)
Mr. W. M. Garner (w/2) '
.Mr. C. R. Hutchinson (w/o)
'Ms.:/F. K. Mangan (w/o) p lir. M. 'J. Meisner (w/a) ;
Mr. G. W. Muench (w/a)
Mr. T. E. Reaves (w/o)
Mr. F. W. Titus (w/o)
- Mr.1G. A. Zinke (w/o) '
File-(LCTS) (w/2)
File (RPTS) (w/a)
File (NL) (w/a) i File (Central) (w/a) ( 140 - ) 'i e
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II Attachment A to AECM-90/0173 Page 1.
DISCUSSION OF PROPOSED CHANGES A. BACKGROUND In requests to the Nuclear Regulatory Commission on August 15, 1989, AP&L, LP&L, and System Energy committed that following issuance of the license amendments approving Entergy Operations as the operator of Arkansas Nuclear One (ANO), Grand Gulf Nuclear Station (GGNS) 1 and Waterford 3, Entergy Operations would inforn the NRC in advance and obtain prior NRC approval of the first planned change i.ivolving centralization / consolidation to organizations which are governed by formal plans subject to NRC regulations. The Quality Assurance Program, the Emergency Plan, and the Security Plan are examples of plans / programs that would be subject to this commitment.
B. DESCRIPTION OF C'HANGE Supplier quality assurance functions including performance of supplier audits, surveys, assessments, product inspections, evaluations, reviews and surveillaaces, and maintenance of the Qualified Vendors List (QVL) or.
Qualified Supplier List (QSL) ee now provided by the Quality Assurance ;
or Quality Programs organizations of ANO, GGNS, and Waterford 3. The .i proposed change transfers the responsibilities and performance of these I activities.to the Entergy Operations Supplier QA Manager in the Planning
& Assurance Department (Attachment E). The quality assurance personnel now performing the above functions for ANO, GGNS ar.o Waterford 3 will '
continue to perform these functions to site specific procedures which.
implement their applicable Quality Assurance Program.
In this initial phase of QA consolidation, the only change.is in responsibility and reporting relationships for Su) plier QA activities as described in revised quality assurance programs w1ich are submitted for review and approval. Later phases of QA consolidation will study subjects such as consolidating procedures and the need for a combined or consolidated QA Program.
C.
SUMMARY
OF 10CFR50.54 EVALVATION Attachment B contains the 10CFR50.54 evaluation for the proposed change. i In summary, baseri on a review and evaluation by the Quality Programs Department, the 0QAM continues to satisfy the requirements of 10CFR50, i Appendix B and the Regulatory Guides and ANSI Standards referenced in !
Appendix A of the 0QAM. There will continue to be a path for resolution of problems, use of the appropriate Quality Program, the appropriate procedures and an effective line of communication.
Specifically, the appropriate site organization will continue to have.the responsibility to follow-up on supplier problems or concerns which are identified by Supplier Quality Assurance. The interfaces and communication paths for concerns and for the resolution of Supplier Quality A n urance identified problems will continue to be through the appropricte site organization. The Supplier Quality tssurance organization will continue to use the ap3ropriate site quality program and procedures. There will continue to )e the same strong communications with plant organizations to support plant operations.
A9009171/SNLICFLR - 4 w . . . . ___ -_ )
t Attachment A to AECM-90/0173 ,
Page 2- ;
Therefore, the changes described above do r.ot reduce commitments as !
described in 10CFR50.54(a)(3).
D. PURPOSE FOR CHANGE The changes in reporting relationships and responsitilities will enable ;
Entergy Operations' to consolidate identical or similar supplier quality r assurance functions into one organization. Supplier Quality Assurance {
" lessons learned" will be shared promptly, efficiently and consistently -l among Entergy Operations' nuclear sites. Consolidation of talents will result in a merger of expertise and experience for company-wide supplier ,
QA activities. The technical qualifications of a consolidated Supplier Quality Assu'/&nce organization will be the same as those of the existing organizations performing supplier quality assurance. activities. Finally, one Supplier Quality Assurance management-reporting relationship will I result in improved management control and more effective lines of authority and communication.
E. REQUESTED APPROVAL SCHEDULE Entergy Operations' requests NRC approval of,the proposed change by November 26, 1990. This schedule is consistent with the 60-day period allowed under 10CFR50.54 for changes to the quality assurance program l
which do not involve a reduction of commitment.
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i Attachment B to AECM-90/0173 ;
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10CFR50.54 EVALUATION
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POLICY SECTION ACTION CERTIFYING ORGANIZATION COfetITMENT VERIFICATION
- 1. 1.3 Adda communicc. tion ManLger, Cucle2r SSfety Aa a result of the change in path on Supplier quality Oversight responsibilities for Supplier matters. QA activities, the effective lines of communication to the President and CEO on quality matters for the Supplier QA Manager are maintained; therefore, there is no reduction in commitments.
- 2. 1 through 18 Adds Senior Vice President, Manager, Nuclear Safety The Senior Vice President, Appendix A, B Planning and Assurance Oversight Planning and Assurance, as a and C Manager Nuclear Safety result of the reorganization /
Oversight, supplier Quality consolidation, is responsible Assurance Manager as for Supplier Quality Assurance responsible for OQAM activities. He is assisted by requirements. the Manager, Nuclear Safety Oversight; and the Supplier QA Deletes Director, Quality Director, Quality Programs Manager in implementing the Programs responsibilities applicable requirements of the for Supplier Quality Operational Quality Assurance Assurance activities. Program. The level of organizational responsibility and reporting functions are maintained at an equivalent level; therefore, there is no reduction of commitments.
- 3. 1.3.3 Delete reference to staff Director, Quality Programs Due to reorganization /
1.3.3.2 at plant site and general consolidation of supplier QA 1.3.4 office. activities identified in (2) above, the Quality Programs staff remains located at the Plant Site. The Supplier QA activities and effective lines of comsunication are maintained at an equivalent organizational level and commitments are not reduced.
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POLICY SECTION ACTION CERTIFYING ORGANIZATION COP 9f1TMENT VERIFICATION
- 4. I through 18 Replace Manager, Quality Director, Quslity Programs The transfer of responsibil-Appendix A, B Systems with Manager, ities for procurement document and C Quality Services for reviews and receipt inspections procedure document review to the Manager, Quality and receipt inspections. Services was made for consistency in the
- _ administration of the activities. This change also facilitates the reorganization /
consolidation identified in (2) 3 above. These activities are maintained under the Director Quality Programs; therefore, there is no reduction in commitments.
- 5. 1.3.3 Deletes " corporate" Director, Quality Programs Designation as " corporate" ,
l quality assurance no .onger i necessary. This change is ,
t editorial in nature to reflect the consolidation of supplier QA. activities.
- 6. 1.3.2 Deletes the responsibility Director, Quality T ograms See justification for (2) for coordination of above.
corporate quality matters Manager, Nuclear Safety as they relate to Oversight
, procurement.
- 7. 1.3.13 Delete specific reference Manager, Nuclear Safety To allow addition of Manager, to Quality Programs Oversight Nuclear Safety Oversight and -
personnel. Supplier Quality Assurance Manager as key " Quality" Personnel. The minimum qualifications of key Quality personnel are maintained and extended to the Supplier QA organization; therefore, there is no teduction in commitments.
OQAM.ACT/SQPFLR - 2
POLICY SECTION ACTION CERTIFYING ORGANIZATION COMMITMENT VERIFICATION O. 1.3.18.1 Delete reference to Manager, Nuclear Safety The audit activities are external and internal Oversight maintained either by Supplier audits. QA or Quality Programs; at an Director, Quality Programs equivalent level; therefore, there is no reduction in commitments.
- 9. 2.4 Adde directives as a means Director, Corporate Services Corporate " directives" are used 2.5 to carry out OQAM as a means to disseminate 2.5.2 requirements. Information to licensee 5.4.1 individuals and organizations.
This is an editorial change in nature to provide consistency with the document nomenclature used within Entergy Operations.
- 10. 8.5.8 Deletes the shall Director, Quality Programs This change is unrelated to requirement for the Supplier QA consolidation.
Manager, Quality Services. The change clarifies without reducing the responsibility of the Manager, Quality Services.
- 11. 3.5.18.3 Change Quality Programs to Manager, Nuclear Safety The change reflects Supplier QA 7.5.2 Supplier QA as applicable. Oversight as the new oganization perform-ing supplier quality assurance activities. The offective lines of comununications and responsibilities remain at an equivalent level.
OQAM.ACT/SQPFLR - 3
4 POLICY SECTION ACTION CERTIFYING ORGANIZATION C009f1TMENT VERIFICATION
- 12. 7.5.2.5 Ccse regieter to NUPIC Director, Qunlity Programs Thio change 10~t.nreic.ted to
, audit. Supplier QA consolidation.
The change reflects current
, -industry and Entergy Operations' practices of utilizing NUPIC which is an l enhancement in the data gathering and sharing process; therefore, there is no i reduction in comunitments.
A review and evaluation was performed of the above changes by the Quality Programs Department. Based on the review, the Operational Quality Assurance Program continues to satisfy the requirements of IOCFR50 Appendix 5 and the Regulatory Guides and ANSI Standards referenced in Appendix A of the OQAM. The changes identified do not reduce the commitments of the approved Revision 9 of the OQAM.
Policy sections indicated are certified jointly by the Director, Quality Programs and the Manager, Nuclear Sefety oversight. Joint certification of these policies / sections is necessary due to reorganization /
consolidation of Supplier QA activities.
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5 Attachment C to AECM-90/0173 l
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l 0QAM, REVISION 9a, HIGHLIGHT FORMAT I
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A9009171/SNLICFLR - 7 1
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e INTRODUCTION This Manual describes the Operational Quality Assurance Program established .
to assure that 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 ruel 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-0800, formerly NUREG-75/087). '
The Quality Assurance Program described herein is applicable to the Grand Gulf Nuclear Station (GGNS), and is referenced in Section 17.2 of the Updated Final Safety Analysis Report. The program applies to a11' operational phase activities (including pre-operational and startup testing) that affect the safety-related functions of those structures, systems and components te .
prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
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! OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a INTRODUCTION Page 1 of 1 INTRODUCTION OQAM.R9A/SQPFLR - 1 i
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FOREWORD This Manual prescribes the Operational Quality Assurance Program Policies '
to cont rol 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 Negulatory 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 issuance of revisions, as necessary. The Director. Quality 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. "
T. H. Cloninger W. T. Cottle
! Vice President, Nuclear Engineering Vice President, Nuclear Operations 6 Support I
R. J. Landy G. M. Muench Vice President, Human Resources and Vice President, Operations Support Administration I
J. G. Dewease Senior Y1ce President, Planning &
l Assurance OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a FOREWORD Page 1 of i FOREWORD 00AM.R9A/SQPFLR - 2
D BLE OF CONTENTS POLICY TITLE REL !
- DATE Policy 1 Organization 9a l
Policy 2 Quality' Assurance Program 9a Policy 3 Design Control 9a Policy 4 Procurement Document Control 9a Policy 5 Instructions, Procedures and Drawings 9a Policy 6 Document Control 9a Policy 7 Control of Purchased Material, Equipment and Services 9a Policy 8 Identification and Control of Material, Parts and Components 9a Policy 9 Control of Special Processes 9a Policy 10 Inspection 9a Policy 11 Test Control 9a Policy 12 Control of Measuring and Test Equipment 9a Policy 13 Ilandling Storage and Shipping 9a Policy 14 Inspection, Test and Operating Status 9a y
Policy 15 Nonconforming Materials, Parts or Components 9a Policy 16 Corrective Action 9a l
Policy 17 Quality Assurance Records 9a Policy 18 Audits 9a 1
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: TABLE OF CONTENTS TABLE OF Page 1 of 2 CONTENTS l
l 0QAM.R9A/SQPFLR - 3 ;
TABLE OF CONTENTS POLICY TITLE REY. DAIE Appendix A Conformance of GGNS Operational 9a -
Quality Assurance Program to NRC Regulatory Guides and ANSI Standards Appendix B Document Control Responsibility- 9a For Quality Related Documents Appendix C Operational Quality Assurance 9a Program Implementing Procedures r
Record of Revisions Entered 2 6/1/81 P
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l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: TABLE OF CONTENTS TABLE OF Page 2 of 2 CONTENTS DQAM.R9A/SQPFLR - 4
1.0 ORGANIZATION 3
1.1 PURPOSE This Policy describes the organizations and key personnel responsible for developing, implementing and verifying the effectiveness' of the Operational Quality Assurance Program for the Grand Gulf Nuclear Station. I 1.2 SCOPE i This Policy defines the organizational structure and delineates the '
authority, responsibility and lines of communication for organizations .'
performing functions covered by the Operational Quality Assurance _
Program.
Certain of these functions may be delegated to other qualified organizations, but responsibility for the program is retained and exercised by the ;
licensee.
1.3 QRGAM1ZATION AND RESPONSIBILITY >>
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Plear and definitive lines of authority, responsibility and communication f are established for all licensee 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 functional responsibility assignments are i
such that attainment of program objectives is accomplished by those who have been assigned responsibility for performing the work, and verification of l
conformance to established requirements is accomplished by 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 and the President & Chief Executive Officer indicates guidance on Quality Assurance policy matters and a direct escalation path.' The dashed line from the Supplier Quality Assurance Manager to-the Senior Vice President, Planning & Assurance and the President and Chief Executive Office indicates guidance on matters related to quality.
l 1.3.1 President & Chief Executive OfficgI ;
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. lie delegates authority and responsibility for '
the development, implementation and verification of the Operational Quality Assurance Program to the appropriate organizations through the Executive Vice President and Chief Operating officer., the Senior Vice President, Planning & Assurance and OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 1 of 13 Policy 1 OQAM.R9A/SQPFLR - 5
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th3 Vic3 Prcsid:nt, Human R:scurc:s & Administratien. H3 '
i maintains o c:ntinuing c Crcn:ss ef. qu lity casurcnca catters.
and monitors effectiveness of the program through status !
reports prepared by the Director, Quality Programs and the ,
Manager, Nuclear Safety Oversight.
1.3.2 Vice President. Nuclear Ooerations [
The Vice' President, Nuclear Operations reports directly to the' Executive Vice President and Chief Operating Officer and is responsible for the administration of all functions associated with the operation of the Grand Gulf Nuclear Station, except ,
those delegated to the Vice President, Nuclear Engineering &
Support and the Senior Vice President, Planning & Assurance. ,
He is also responsible for training. He provides guidance with !
regard to quality assurance goals and objectives to the !
Director, Quality Programs. He maintains a continuing -
awareness of quality matters through applicable reports and I management audits of the program. He is aise responsible fer eeerdination of cerperate quaisty assuranee matterst as they relate te preenrements- 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 Pronrams The Director, Quality Programs reports directly to the Vice )
President, Nuclear Operations 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 eerperate quality assurance policies, goals and objectives. He is assisted by the Manager, Quality Services and thet Manager, Quality Systems j and a staff in residence both in the General Office and at the
! plant site.
The primary duties and responsibilities of the Director, Quality Programs include:
1.3.3.1 Developing and controlling the Operational Quality Assurance Program and the content of this Manual, including the approval of changes thereto and providing for interpretations thereof; 1.3.3.2 Directing the activities of the Quality Programs' Staf f at the General Office and at the piant site in verifying the implementation of the Operational Quality Assurance Program; .
i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 2 of 13 Policy 1-l OQAM.R9A/SQPFLR - 6
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'1.3.3.3 R: porting to tha Vico Prcsid:nt, Nuc12:r Op;rationa cnd tha Prc:id::t & Chicf.Ex:cutiva Officar en'th2 status and adequacy of the Operational Quality Assurance Program; ;
1.3.3.4 Reviewing and approving Quality Assurr_nce Procedures; 1.3.3.5 Providing for review of and concurrence with documents as specified in Appendix B of this Manual; l
1.3.3.6 Providing for the planning, scheduling and coordinating I l of training for the Quality Programs' Staff; providing quality assurance input to the training and '
indoctrination programs for personnel performing quality-related activities; and providing for the approval of all Quality Programs Staff certifications.
l 1.3.3.7 Maintaining adequate communict.tlons with regulatory agencies, suppliers, contractors and other licensen organizations on quality assurance matters; 1.3.3.8 This section deleted in' Revision 4.
1.3.3.9 Planning and performing supplier evainatienst senree ;
inspections; receipt inspectionst_seuree gnality ,
veriffeatfens and audits;
- 1.3.3.10 Developing and carrying out an audit program, as T
l 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 enalysis 'of NRC and licensee quality deficiency documents to detect possible adverse quality trends.
1.3.3.12 Providing for inspections and nondestructive !
examinations.
1.3.3.13 Providing for the coordination, development and fasuance of quality assurance reports as required by ,
Management and appropriate procedures.- '
1.3.3.14 Providing for the coordination and/or implementation of administrative services for Quality Programs.
The Director,-Quality Programs is independent of undue influences and responsibilities for schedules and costs, and has sufficient authority and organizational freedom to identity quality problems, recommend solutions and verify implementation of solutions. If acceptable solutions cannot be reached he has-the responsibility :
and authority co escalate these matters to the President & Chief Executive Of ficer, lie has the authority, as delineated in the cppropriate Quality Assurance Procedure, to initiate action to stop unsatisfactory work and control further processing, l OPERATIONAL 1UALITY ASSURANCE MANUAL Rev. 9a- ,
TITLE: ORGAh7ZATION Page 3 of 13 Policy 1 OQAM.R9A/SQPFLR - 7
1 daliv ry, or is t:11ation cf n:nconferning items er c ntinu; tion cf c:ncinf:raing cervis:s pending correction cf the nonconforming condition.
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1.3.4 Mannear. Quality Servican I l
The Manager, Quality Services reports directly to the Director.
Quality Programs and'is leested at the plant site. He directs Quality Prograns' staff located at the plant site in '
inspections (except for receipt inspeettens), nondestructive ,
examination, receipt inspections, procurenent document revleus,
- l and reviews of activities to verify implementation of the !
Operational Quality Assurance Program.
The Manager, Quality Services has the authority 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.
The primary duties and responsibilities of the Manager, Quality Services include:
1.3.4.1 Coordinating the review of procedures, as delineated in Appendix B to this manual to assure quality requirements are addressed.
1.3.4.2 Developing, interpreting and maintaining the Operational Quality Assurance Program and Procedure .
Manuals.
1.3.4.3 Controlling, processing, tracking, disposition concurrence, and verification of site quality deficiency documents. ;
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- 1. ' t . 4. 4 Analyzing NRC and licensee quality deficiency accuments for trends and reporting results to the 3 appropriate levels of management.
l 1.3. Providing for inspections and nondestructive examinations, i 1.3.4.6 Serving as a primary member of the Plant Safety Review Committee.
1.3.4.7 Reviewing and approving Quality Assurance Instructions, as applicable.
1.3.4.8 Providing for the quality review of procurement documents;
- 1.3.4.9 Providing for the performance of 'i receipt inspection activities.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 4 of 13 Policy 1 OQAM.F9A/SQPFLR - 8
4 1.3.5 GGNS General Maammer i 1 -
The GGNS General Manager reports to the Vice President, Nuclear Operations 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 implementation of design changes and.
plant modifications; implements repairs; reports appropriate -
matters to management and the Safety Review Committee; and generally administers plant operations on a day-to-day basis, f He has overall responsibility for execution of the Operational Quality Assurance Program at the plant site; except for implementation of design changes and plant modifications and the preoperational testing on Unit 2; and has'the authority to '
stop work ir an activity. at the Plant is not in conformance with program requirements. He has overall responsibility for developing systems to manage the storage and retrieval of records and for coordinating the ternover of contractor vendor records. It is the responsibility of the GGNS General Manager.
to assure that these. functions are performed in accordance with the requirements of the Operational Quality Assurance Program.
The GGNS General Manager is assisted in carrying out his responsibilities by the Manager, Plant Operations; the Manager, Plant Maintenance; the Manager, Plant Support; and, Manager, ;
Performance & System Engineering as well as the operating plant staff--which includes individuals knowledgeable in plant radiation protection, 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 Licensinn The Director, Nuclear Licensing reports to the Vice President, Nuclear Operations and is responsible for directing the activitiet ,
l of the Nuclear Licensing Staff. He is assisted by the Manager, Nuclear Licensing and the Plant Licensing Superintendent. The Nuclear Licensing Staff is responsible for securing the i licenses and permits required to construct and operate the i plant. The Nuclear Licensing Staff also provides technical L assistance in the areas of safety analysis and fire protection. ,
This staff provides support to the Vice President, Nuclear '
Operations in matters related to Safety Review Committee i
activities. It is the responsibility of the Director, Nuclear Licensing to assure that these functions are performed in accordance with the requirements of the Operational Quality Assurance Program.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Fage 5 of 13 Policy i OQAM.R9A/SQPPLR - 9 '
i 1.3.8 Director. Nuclear Plant En.ineerine Tha Dircctcr, Nucitar Plcnt Engineering reports to the Vice l President, Nuclear Engineering & Support, and is responsible 1 for directing the activities of the Nuclear Plant Engineering Staff. Nuclear Plant Engineering, consisting of the Manager, ,
Operational Analyris; Manager, Engineering Support; Manager.
Nuclear Design; Quality Engineering Section; and, their j respective staffs are responsible for plant design, design i review, modifications, chemical / environmental 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 functions are !
performed in accordance with the requirements of the i Operational Quality Assurance Program. The Director, Nuclear Plant Engineering is responsible for reviewing NPE design documents for compliance with the Operational Quality Assurance i Program requirements and concurring with the same. l i
1.3.9 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 and "
Section 13 of the UFSAR for the applicable nuclear generating station.
1.3.10 Plant Safety Review Committee (PSRC) '
Committee composition, responsibility and authority sjects to be reviewed, and reporting requirements are addresaS9 in Section 6 -
of the Technical Specifications and Section 13 of the UFSAR for the applicable nuclear generating station.
1.3.11 Mananer. Purchasinn and Manager. Contracia The Manager, Purchasing and Manager, Contracts are responsible for performing procurement activities in accordance with the Operational Quality Assurance Program, as coordinated with l the GGNS General Manager; the Manager, Project Management; the Director, Nuclear Licensing; the Director, Nuclear Plant Engineering; the Director, Quality Programs; the Director, Nuclear Support; the Director, Corporate Services; the #anager, Nuclear Safety Overs /ght; and other appropriate licensee personnel.
1 1.3.12 Qther Ornanizations Other organizations, contractors, or consultants may be delegated certain functions which fall under the Operational Quality !
Assurance Program. In such cases, the licensee shall retain responsibility for the delegated work.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 6 of 13 Policy 1 OQAM.R9A/SQPFLR - 10
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1.3.13- Minimum Oualifications of Ouality Premrama Personnel !
Tha qualification requirements.and experiAnce-levels for key i of Quality Programs personnel are such'as te assure competence. ;
commensurate with the responsibilities of .ne. position and are t described in ANSI /ANS 3.1 (Draft 12/79). .See Appendix A. Key I Quality Programs personnel include the Director, Quality '
Programs; the Manager, Quality Services; and the Manager, Quality Systems; the Manager, Nuclear Safety Oversight; and the Supplier QA Hanager. '
1.3.14 This section deleted in Revision 5 ,
1.3.15 Unit 2 Construction Superintendent 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 Unit 2. It is the Unit 2 Construction Superintendent's responsibility to assure that the requirements '
of the Operational Quality Assurance Program are implemented by the organizations under his direction. The Unit 2 Construction Superintendent maintains a continuing involvement in >
preoperational phase testing, quality assurance matters, and assesses the implementation and effectiveness of the program through contact with and reports furnished by the Director, Quality Programs.
1.3.16 Director. Nuclear Suonort The Director, Nuclear Support reports to the Vice President, Operations Support and is responsible for directing the activities of the Nuclear Support Department. The Nuclear .
Support Department, consisting of the Manager, Radiological and Environmental Services and Manager, Contracts and their respective staf fs provide technical support in the areas of environmental licensing and permitting; health physics; environmental protection;. chemistry; waste management; and, developing, bidding, awarding and administering contracts. It is the responsibility of the Director, Nuc1 car Support to ;
assure that these functions are performed in accordance with the requirements of the Operational Quality Assurance Program.
1.3.17 This section deleted in Revision 5 1 a 1.3.18 tignaner. Quality Systems The Manager, Quality Systems reports directly to the Director, Quality Programs and is seented at the Generai Office, lie directs Quality Programs' staff.leested at the plant site and the General Office in audits and monitoringt seuree quaifty veriffentions; receipt inspections; preenrement doenment reviewt vender evaination; and seuree inspection activities to
, verify the adequacy and implementation of quality assurance i programs established and implemented by the licenses and the vendors.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 7 of 13 Policy 1 0QAM.R9A/SQPFLR - 11
Th3 M:nagor, Quality Systers h:a th3 cuthority to initicts cction -!
to otop uncatisfcctery w:rk cnd ctntrol furth r prccc sing, delivery or installation'of nonconforming items or. continuation of nonconforming services pending correction of the nonconforming '
condition.
The primary duties and responsibilities of the Itanager, Quality
- Systems include:- -
?.3.18.1 Providing for the planning, scheduling, coordinating, performing and reporting of audit activitiest heth internal and external.
1.3.18.2- Providing for the planning, scheduling, coordinating, performing and documenting of seuree quaisty veriffeatient seuree inspection and monitoring-activities.
i 1.3.18.3 This section deleted in Revision 9a.
Providing fer the quality review of preenrement doenments 1.3.18.4 This section deleted in Revision 9a. ?
Previding fer the eserdinatient performance and -!
documentation of receipt inspection aetivitient-1.3.18.5 This section deleted in Revision 9a. ,
Previding for the performance of pre-award evaientien of supplierst 1.3.18.6 Reviewing and approving Quality Assurance' Instructions, as applicable.
1.3.19 This section deleted in Revision 6.
1.3.20 This Section deleted in Revision 6A.
1.3.21 Vice President. Nuclear Ennineerinn & Suncort The Vice President, Nuclear Engineering & Support reports directly to the Executive Vice President and Chief Operating Officer and is responsible for the administration of all functions associated with engineering and fuel cycle management including the control of- the design activities associated with nuclear core design of GGNS. lie maintains a continuing involvement in quality assurance matters and assesses the i scope, status, implementation and effectiveness of the program through contact with and review of reports issued by the Director, Quality Programs.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 8 of 13 Policy 1 OQAM.R9A/SQPFLR - 12 i
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1.3.22 This s:ctirn dolcted in R: vision 9 1.3.23 Hangger. Emermancy Prenaradnang The Manager, Emergency Preparedness reports to the Director, [
Plant Projects and Support and is responsible for the Emergency ;
Preparedness program and associated activities. It is the.
responsibility of the Manager, Emergency Preparedness to assure i these functions are performed in accordance with the requirements of the Operational Quality Assurance Program.
1.3.24 Mananer. Ooerational Analysis-The Manager, Operational Analysis reports to the Director, Nuclear Plant Engineering. He is responsible for directing nuclear safety / thermal performance analyses, reliability reviews and safety evaluations and for making independent recommendations to- !
-improve both plant safety and reliability as delineated in the ,
Operational Assessment Review Policy and Nuclear Regulatory requirements. 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 and in accordance with.the Operational QA -
Program, t 1.3.25 Manager. Proiect Mananement '
r The Manager, Project Management reports directly to the Director, .
Plant Projects and Support. He is responsible for managing.the
, implementation of various major special projects and programs as ,
! may be periodically assigned. These projects' involve hardware '
! snd software implementations and planning functions which l
involve multiple departments. He assists the Director, Plant Projects and Support as assigned, in technical and l administrative matters associatmd with the Grand Gulf Nuclear -
Station. It is the responsibility of the Manager, Project Management to assure these functions are performed in accordance with the requirements of the Operational Quality Assurance Program.
1.3.26 Mananer. Plant Modification & Construction The Manager, Plant Modification & Construction reports directly .
to the Director, Plant Projects and Support. -He is responsible for planning, scheduling..and implementing design changes and plant modifications. He is also responsible for the implementation of assigned major maintenance. It is the responsibility of the Manager, Plant Modification &
Construction to assure these functions are performed in accordance with the requirements of the Operational Quality Assurance Program.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION l Page 9 of 13 Policy 1 l
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1.3.27 Mrnaner. Nuclear Dasien The Manager, Nuclear Design reports to the Director, Nuclear Plant- ,
Engineering and is responsible for managing the activities of the l Civil, Electrical'and Mechanical Engineering disciplines of.the !
Nuclear Plant. Engineering Staff to ensure that design control;and '
technical assistance i provided in the areas of plant design, design review, modifications and chemical / metallurgical /
environmental analyses at Grand Gulf Nuclear Station. It is the responsibility of the Manager, Nuclear. Design to assure these ,
functions are performed in accordance with the requirements of the Operational QA Program,-
l 1.3.28 Mananer. Eneineerine Suonort f
The Manager, Engineering Support reports to the Director, Nuclear Plant Engineering and is responsible for managing the activities of the Configuration Management,' Administrative Support, Drafting / Computer Aided Drafting and Engineering Planning and Control disciplines of the Nuclear Plant ,
Engineering Staff to ensure-that adequate support is given to the Civil, Electrical, Mechanical and Operational Analysis '
disciplines for all phases of_their engineering activities at' Grand Gulf. Nuclear Station. It is the responsibility of the Manager, Engineering Support to assure these functions are performed in accordance with the requirements of the Operational QA Program.
1.3.29 Vice President. Human Resources & Administration -
The Vice President, ilumen Resour:as & AdministraEion reports directly to the President & Chief Executive Officer and is -
responsible for the administration of all functions associated with Corporate Services, lie delegates authority and responsibility for the accomplishment cf the above activitiec through the <
Director, Co.rpersta Services. It is the responsibility of the Vice President, iluman Resources & Administration, to assure these functions ar3 performed in accordance with the Operational Quality l Assurance Program.
1.3.30 Director. Corocrate Services I
The Director, Corporate Services reports directly to the Vice President,liuman Resources & Administration and is responsible for control and maintenance of corporate directives, policies and procedures; risk management coordination; procurement of safety and non-safety related items; and, administrative' services. lie delegates authority and responsibility through the Manager, Administrative Services and the Manager, Purchasing. It is the responsibility of the Director, Corporate Services to assure these' functions are performed in accordance with the requirements of the Operational Quality l Assurance Program.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 10 of 13 Policy 1 !
OQAM.R9A/SQPFLR - 14
1.3.31 Executive Vice President and Chief Ooeratine Officer ] i The Executive Vice President and Chief Operating Officer :
reports directly to the President and Chief Executive Officer.
He is~ responsible for administration of all functions associated with the operating and engineering of GGNS and is ;
assisted by~the Vice Presifent Nuclear Operations; the Vice '
President, Nuclear Engineering & Support; and the Vice President, Operations Support. It is the responsibility of the Executive Vice President and Chief Operating Officer _to assure i requirements of the Operational Quality Assurance Program are '
implemented by the organizations under his direction.
1.3.32 Vice President. Ooerations Suonort The Vice President, Operations Support reports directly to the.
Executive Vice President and Chief Operating Officer, and is responsible.for'the administration of all-functions associated with radiological and environrental services, and-contracts.
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 ,
reports issued by the Director, Quality Programs. It is the responsibility of the Vice President, Operations Support to: ,
assure that these functions are performed-in accordance with the requirements of the Operational Quality' Assurance Program.
1.3.33 Director. Plant Proiects and Suonort i i
e The Director, Plant Projects and Support reports to the Vice President, Nuclear Operations and is responsible'for planning, scheduling and implementing major maintenance; managing implementation of major special projects and programs; cad emergency preparedness. She Provides management direction to ,
the Manager, Plant Modification and Construction; the hanager.
Emergency Preparedness; and the Manager, Project Manage ;nt.
It is the responsibility of the Director, Plant Projects rnd Support to assure that these functions are performed in accordance with the requirements of the Operational Quality Assurance Program.
1.3.34 Senior Vice President, Planning & Assurance The Senior Vice President, Planning & Assurance reports directly to the President and Chief Executive Officer and is responsible for directing Supplier Quality Assurance activities. He delegates =hvough the Manager, Nuclear Safety Oversight and his staff to assure that these activities are ;
performed in accordance with the Operational Quality Assurance -:
Program. He maintains a continuing awareness of quality matters through appilcable reports and management audits of the program. It is the Senior Vice President, Planning &
l Assurance's responsibility to assure that the requirements of l the Operational Quality Assurance Program are implemented by
\ the organizations under his direction.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. oa TITLE: ORGANIZATION Page 11 of 13 Policy'1 !
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1.3.35 M*-"s r, Nuclear Safety Ov rmight The Manager, Nuclear Safety' Oversight reports directly to the Senior Vice President, Planning & Assurance and is delegated the authority and responsibility ~for assuring the 7erformance .
of supplier audits and evaluations;'and developneest and '
nalntenance of inplementing procidure covering S:tpplier Quality. '
Assurance activities. E2 assures safety related " activities are performed in accordance with the Operational Quality Assurance Progran.
The primary duties and responsibl))tles of the Manager, Nuclear Safety Oversight include:
t 1.3.35.1 Reviewing and approving Supplier Quality Assurance Procedures; ,
1 1.3.35.2 Maintaining adequate communciations with suppliers, I
contractors and Entersy Operations' organizations; 1.3.35.3 Planning and performing supplier evaluations, source ,
quality verifications, source inspections and external audits; 2.3.35.4 Developing and carrying out an audit progran
- as described in Policy 18.0 of_this Manual, to verify conformance with the lperational Quality Assurance Program requirement l
2.3.35.3 Reporting to the Sonics Vice President, Planning &
l Assurance and the President & Chief Executive Officer l on the status and adequacy of the Operational Quality Assurance Progran as applicable to Supplier Quality Assurance activities.
1.3.36 Supplier Quality Assurance Manager l
The Supplier Quality Assurance Manager reports directly to the Manager, Nuclear Safety oversight. He assures the performance of supplier audits, surveys, assessments, product source inspections, evaluations and surveillances to verify the adequacy and implementation of quality assurance programs established an? laplemented by suppliers. .Re is also responsible for the development, maintenance and control of procedures that govern the supplier quality assurance activities.
l The primary duties and responsibilities of the Supplier Quality Assurance Manager include:
1.3.36.1 Providing for the planning, scheduling, coordinating, performing and reporting of audit activities; OPERATIONAL QUALITY ASSURANrE MANUAL Rev. 9a TITLE: ORGANIZATION Page 12 of 13 Policy 1 OQAM.R9A/SQPFLR - 16
)
.1.3.36.2 Providing fcr th2 picnning, ccheduling, coordinating, perfor:1:g cnd docune: ting cf courco qu:lity verifications and source inspections. ,
1.3.36.3 Providing for the performance of pre-award evaluation of suppliers.
1.3.36.4 providing for the controlling, processing tracking, disposition concurrence, and verification of Supplier Quality Assurance deficiency documents. ;
1.3.36.S Providing for analyzing Supplier Quality Assurance d'ficiency documents for_ trends and reporting results co the appropriate levels of nanagement.
l The Supplier Quality Assurance Manager ls independent of undue influencas and responsibilities for schedules and. '
costs, and has sufficient authority a.-1 organizational freedon.
to identify quality problems, reconnend solutions and verify implementation of solutions. If acceptable solutions cannot'be reached he has the responsibility and authority to escalate these matters to the Senior Vice President, Planning &
Assurance and the President & Chief Executive Officer. He has the authority, as delineated in the appropriate Supplier quality Assurance Procedures,-to initiate action to stop- '
unsatisfactory work and control further processing, delivery, :
or installation of nonconforming itens or continuation of nonconforming services pending correction of the nonconforming condition. .
t l
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OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 13 of 13 Policy 1 OQAM.R9A/SQPFLR - 17
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2.0 OUALITY ASSURANCE PROGRAM 2.1 PURPOSE This Policy describes the Operational Quality Assurance Program for the Grand Gulf Nuclear Station.
2.2 SCOPE I This Policy. describes the Operational Quality Assurance Program in terms- (
oflthe1 objectives to be accomplished, the requirements to be met, end the implementation and control mechanisms which have been established. The ;
totsi program is described throughout this Manual.
2.3 APPLICABILITY The requirements of the Operational Quality Assurance Program apply to'al' l 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:
designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting. . testing (including preoperationalfand 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 DQAM 3.5.18. See Appendix A).
2.4 POLICIES. DIEECTIVES. GOALS AND OBJECTIVES Corporate quality assurance policies,_ directives, goals, and objectives are summarized in the statement that all licensee individuals and :
- organizations who perform quality-related activities have personal and g corporate responsibility to assure that the Grand Gulf Nuclear Station is l designed, constructed and operated in a manner which protects public health and safety, and promotes reliabic 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 1
The Operational Quality Assurance Program, as drucribed-throughout this Manual, delineates the measures that assures activities which affect the quality of safety-related structures, systems, components and services are performed in a controlled manner and a;e sufficiently documented to provide objective evidence of compliance with established requirements.
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, 1 directives, procedures, and instructions. These documents convey the
'JPFxATIONAL QUALITY ASSURANCE MANUAL Rev. 9a T;rLE: QUALITY ASSURANCE PROGRAM Page 1 of 7 Policy 2 OQAM.R9A/SQPFLR - 18 1
,. l
. lic nics qu ,11ty'anurancs philtsophy and requirennts to 'all lovals of l t: nag: cent cnd to c11' organizations cnd individuals involved with prrgrz:a
'implerentation.-The: applicable ~ Policies of.the Operational-Quality Assurance Program are mandatory for safety-related~ activities and 2 functions as described in t"r,Is Manual. . .
The Operational. Quality Assurance Program' applies to a11' activities. i
. including the use of expendable and consumable materials, affecting the - ,
safety-related3 functions.of those structures, systems and components which ;
prevent .or mitigate the. consequences 'of postulated accidents that could l 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, ;
'l Quality Assurance Criteria for! Nuclear Power Plants and Fuel Reprocessing j 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 i ,
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 nonsafety-related structures / systems / components to which the Quality Assurance Program applies is issued and. maintained current.
Nuclear Plant. Engineering is responsible for the development at ' '
maintenance of this Q-List in accordance-with written procedur s delineate the contents of the Q-List. The procedures will ,
structures / systems / components. listed in the UFSAR are conta,., .y 1:.u.
Q-list. The distribution of the.Q List will be procedura1h ontrc11%1 The positions authorized to approve changes to the Q-List sr. designet- -
in Appendix B of this Manual'.
L The_ applicable requirements of the program are also' imposed upon contractors, suppliers and consultants.
Development, control, . and use of computer programs for design : Arol j activities as described in Policy 3 for safety-related stru-tute ,
systems and components will be conducted in accordance wit' the Operational QA Program. . .
2.5.1 Operational Ouality Assurance Manual The Operational Quality Assurance Manual consis t #
assurance policies, goals, and objectives and ha ,
~
developed in accordance with applicable regulatious, cs a . and :
standards. 'It describes the Operational Quality Assuranse- ~
Program and delineates the responsibilities and requiremee s imposed by the program for the performance of safety-relate i activities.
The Director, Quality Programs is responsible for maintaining the Manual and controlling >ts distribution, including revisions thereto, in accordance with approved Quality Assurance Procedures.
Revisions to the.ManuaI will be processed per 10CFR50.54(a). ,
OPERATIONAL-QUALITY ASSURANCE MANUAL Rev 9a TITLE: . QUALITY ASSURANCE PROGRAM Page 2 of 7 Policy 2 .;
0QAM.R9A/SQPFLR - 19
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J2.S o 2' Imolementine Policies. Directives. Procedures and' Instructions 3m p
The Operational Quality Assurance. Program.is' implemented through'
~
the use of. written,' approved policies ~, directives, procedures and. instructions generated by the' organizations responsible for- !
the performance of the specific functions as. outlined in-1 Appendix B=of.this Manual. .
The Quality Assurance Procedure Manual'centains the. .
implementing procedures / instructions lfor the quality functionsi- 4 l . performed by Quality' Programs. Quality' Assurance Procedures / Instructions provide l measures to; assure that= r quality-related . activities are. performed in a; controlled emnn^rc i and are documented to provide' objective evidence cffc w p wence d t with program requirements. L The Director, Quality .Myramt; e- i responsible for approving Quality Assurance 1PrcMuns p~1or. to !
implementation. The Manager, Quality Servicee rnd thefianager, 'l Quality Systems are responsible for ~ approving Quality Assurance '
Instructions ~ prior.to implementation. !
Quality-related. functions performed byfother organizations are controlled and documented =in accordance:with-procedures :
prepared, approved and controlled by the organization: . t 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 and Training) 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 Manager, Plant Modification & Construction '
also reviewing and approving those Plant Administrative L Procedures controlling the activities of the Plant Modification L and Construction Section. Nuclear Support Administrative L Procedures provide the means for assuring that the
! quality-related activities of the Nuclear: Support Staf f are i g
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 Administrative Procedures- provide the means for assuring that the quality related activities of -the Nuclear Licensing Staff are controlled and documented to provide objective evidence of compliance with Program requirements. Nuclear Licensing'.
Administrative Procedures are reviewed and approved'by the Director, Nuclear Licensing. Nuclear Plant Eng'ineering Administrat.ive Procedures provide for assuring that the t quality-related activities of Nuclear Plant Engineering are controlled and documented to provide objective evidence of C
compliance with program requirements.. Nuclear Plant Engineering Procedures are reviewed and approved by the OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: QUALITY ASSURANCE PROGRAM Page 3 of 7 Policy 2 OQAM.R9A/SQPFLR - 20 7'
4 g
- l Director, Nuclear Plent Engin nring. Ths GGNS G:narsl_ Man g2r It ,
' alto) rsviiws 'cnd approvn Nuclear Support Ad*:Inistrctiva Procedures.and Emergency Preparedness Administrative Procedures which provide-for effluent and' environmental monitoring _and-
, Emergency Plan implementation. Corporate Services
, Administrative Procedures provide _the means for assuring that the . quality related activities of _ the Corporate Services Staf f :i are controlled and documented lto provide objective evidence of ,
l complian.e with program requirements. Corporate Services ;
Administrative Procedures are reviewed.ani approved by the p Director, Corporate Services.- Emergency Preparedness Administrative Procedures provide the means for assuring that .,
the, quality related' activities of the Emergency Preparedness 4 L ' Staff are controlled and_ documented to provide objective- '[
evidence of compliance with program requirements. - Emergency,
>Preppedness /dministrative procedures are reviewed and . '.
approved by the Manager, Emergency Prepare @ ess. Nuclear Fuels- ,
4 Administrative Procedures provide the means for assuring -
quality related activities of fuel cycle management are :
controlled and documented to provide objective evidence of l l
compliance with program requirements. ' Nuclear Fuels Administrative' Procedures are reviewed and approved by the Manager, Nuclear Fuels. Supplier Quality Assurance Procedures provide for assuring quality-related activities are performed '
'in a controlled nanner'and are documented to provide objective 'l evidence of compliance with progran requirements. Supplier '
Quality Assurance Procedures are reviewed and approved by the
. Manager, Nuclent Safety Oversight.- 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. 4 2.5.3 Indoctrination and Traininn 1 Indoctrination and training programs are established for both ?
onsite and offsite personnel performing quality-affecting activities by the organizations responsible for the activities. -
These programs are implemented by appropriate training plans and g 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 i are trained and quallflad in the principles and '
techniques of the act ivity being performed; 2.5.3.3 Proficiency of persorsnel_ performing quality-affecting activities is maintained by retraining,
- reexamining or recertifying; OPERATIONAL QUALITY ASSURANCE MANUAL 'Rev. 9a TITLE: QUALITY ASSURANCE PROGRAM Page 4 of 7 Policy 2 OQAM.R9A/SQPFLR - 21 i
2.5.3.4 'Thr scopa, asthod cnd objectiva of tha. training cro docunnted; 2.5.3.5; Records of training session's are prepared _and' -
maintained,' including identification of the-content, l3
.the attendeesiand/the date the training was ^
conducted.
2.5.4~ This section deleted in Revision'5.-
2.5.5 Resolution of Discutes ,
Disputes arising between ifcensee organizations on any quality assurance matter which cannot be~ resolved by management of the :
involved organizations will be. referred to the Vice Prasident,
- Nuclear Engineering & Support; the-Vice' President, Nuclear Operations; .the-Senior Vice P:esident, Planning &
Assurance or, the Vice President, Operations Support for resolution.-.
2.5.6 Ouality Resoonsibilities Quality.responuibilities for'thellmplementation of major activities 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 Su'perintendent, who.is responsible for ,
the administration of all Unit 2 construction'and
~
preoperational phase activities for the phnt, provides the management interface with~the principal contractors in-planning l and providing for preoperational testing and plant turnover.
L The GGNS General Manager who is responsible for th'e L administration of all startup testing ' activities for the plant,-
l provides the management interface'with the principal contractors in planning and providing :for startup testingt and '
plant turnover. The Unit 2 Construction' Superintendent is .i responsible for the performance of preoperational phase !
testing, and The GGNS General Manager is, responsible for the performance of startup testing.. .Each and is also responsibic for plant' turnover activities (i.e.,Lturnover from construction testing to Plant Staf f) with' support supplied by the principal. .
contractors. Prior to the actual turnover, written procedures i
are developed by.these organizations 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.
3 The GGNS General Manager is responsible for the control of the turnover of construction records and documentation from contractors and suppliers, i
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: QUALITY ASSURANCE PROGRAM Page 5 of 7 Policy 2 0QAM.R9A/SQPFLR - 22 i
- 2. 5. 8 - Definitions s
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 s' actions-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-l' construed to have.the npecialEdefinitions given:
t 2.5.8.1 Shall - A requirement considered enforceable' by. the ' ;
appropriate regulatory body. ;
2.5.8.2 Should .A recommend'atifon, but not an enforceable requirement. Management exp;.es each employee using plant directives to carry'out any "should" -
statement unless circumstances prevent or ,
necessitate a deviation. '
2.5.8.3 'May - An option, neither a recommendation or at i requirement.
2.5.8.4 Must - A requirement normally established.by;1icensee 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.
l 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.
l 2.5.8.7 Will - Is defined the same;as Shall.
l 2.5.9 Ouality Assurance Position Statements Quality Assurance Position' Statements are issued when considered necessary by the Director, Quality Programs,.for use-in interpretation 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 t the users.
2.5.10 Resolution of Differences r Every attempt has been made to include the partinent requirements 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 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: QUALITY ASSURANCE PROGRAM Page 6 of 7 Policy 2 OQAM.R9A/SQPFLR - 23
'1::ple:rntation of ths Progrea, cust bs brought to tha attcntion of tha-Directer, QualityL Progrecs who initistss ch2ngte: to tha ,
commitmentsLor the Policies as.necessary to resolve the dif ferences.- 1The provisions delineated 11n these Policies shall take precedence over -differing requirements given, elsewhere until the Director? Quality Programs.has evaluated the issue and determined which requirement (s) must be modified.
l 4
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i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: QUALITY ASSURANCE PROGRAM Page 7 of 7 Policy 2 j
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! OQAM.R9A/SQPFLR - 24
'l 3.0 DESIGN CONTROL'
'3.1' PURPOSE I This Policy describes the Operational Quality: Assurance Program measures-to' control design' activities affecting/ safety-related structures, systems and components'for the Grand' Gulf Nuclear Station.-
'3.2- SCOPE This Policy delineates respons'ibilities 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 i
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 accident-and transient' analyses, but excluding nuclear fuel and nuclear
, core design see 3.4.5) during=the operational phase are ;
L . delegated to the Director, Nuclear Plant Engineering. _The GGNS .
i General Manager authorizes the design modification or change to
! be implemented by the Manager, Plant . Modification &
Construction. 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 initiates the design change (except in cases talated to nuclear fuel and core design) and assures submittal of the design change package, including the safety evaluation per 10CFR50.59, to the= Plant Safety Review Committee (PSRC). The Manager, Nuclear Fuels is' 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 requ' ired 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 and installation 1of Plant modifications, betterments and repairs once reviewed by the PSRC as required by Technical Specifications. The GGNS General Manager is responsible for the scheduling and installation OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DESIGN CONTROL Page 1 of 5 Policy 3 0QAM.R9A/SQPFLR - 25
J 4
- of nucicar fu21Lcnd cora related d sign chtngta ones rsv1:wid by ths PSRC as rtquired by Technical'Sp1cific tiens.3;Tha:
- Secretary of the Safety Review Committee ~(SRC) assuresLthe<
review of the safety evaluation by the SRC.; The Director, Nuclear' Licensing is responsible for developing' a summary of the safety' evaluation and submittal of the' summary to.the_NRC, L
as required by 10CFR50.59.
i 13.4.3 . Organizations supplying material,tequipment'or servicesLate
-responsible for complying with the requirements of.this Policy.
to-the extent-specifled in the applicable procurement documents,- 1
-and,for imposing them on their contractors and suppliers, as iapplicable. They'are also responsible for, verifying,Lthrough ,
surveillance or audits, that the requirements are being. '
l ' adequately implemented.
J
'3. 4. 4 The Director, Quality Programs is responsible fortreviewing nucicar fuel and nuclear core (excluding-accident and transient = 1; analyses) design documents.for compliance with Operational' Quality Assurance Program requirements'and concurring with' t name; 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 Assutance Program.
- requirements, including the requirementsLof this-Policy. Those i design documents include the type design documents. originated, reviewed and approved by the Manager, Nuclear Fusls.;
3.4.5 Responsibility and authority for control;of design activities j i
related to modification of or changes to nuclear fuel'or nuclear core design (excluding control of accident and transient analysis -
activities - See 3 4.1) are delegated' to the- Manager,: Nuclear Fuels. He manages and coordinates the activities of~ nuclear p fuel suppliers.and other appropriate organizations. The Manager, ,
1 Nuclear Fuels is involved in: providing design inputs; providing i interface control; reviewing all accept-as-is" or " repair" 4
dispositions for nuclear fuel or core configuration nonconformances. In addition he may perform design verification.
The Manager, Nuclear ~ Fuels is responsible ~ for assuring that procedures are developed and implemented for the above design activities in accordance with the requirements of.this Policy.
3.4.6 Responsibility and authority for control of design activities (including accident and transient' analyses, but excluding.
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 implemented for the OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DESIGN CONTROL Page 2 of 5 Policy 3 0QAM.R9A/SQPFLR - 26
cbove dccign cctivitissiin'accordancs with ths requirsecnts of_- i this Policy cnd'williprovids or concur'with all "ccc:pt-Es-is" or "rspair" dicpositien2: (including accident and transient analyses, but excluding modification' of or changes - to nuclear ,!
fuel or nuclear coreidesigu),forenonconformances. The <
- Director, Nuclear Plant. Engineering is responsible for reviewing-NPE. design documents for compliance'with-the !
10perational Quality Assurance. Program requirements and' {
concurring with the samo. :
3.4.7 .The Manager, Nuclear SafstyIOversight;has:the responsibility
'for carrying out'an=auditIprogran as described in-Policy 18.0-of this manual,:ta verify conformance with the requirementsLof h the Operational-Quality Assurance Program, including-the-requirements'of this' Policy.
3.5 REOUIREMENTS 3.5.1 Organizations having design responsibilities-shall develop procedures, consistent with the scope. of .their responsibilities, to provide measures for thel control of their design activities.-
3.5.2 ' Procedures shall be developed to assure that applicable design !
inputs such as design bases,' regulatory requirements, codes and stac4ards'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 documentation I 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,
~
R '
hydraulic, radiation, and accident analyses; compatibility of I
materials; accessibility for inservice-inspection, maintenance, .
and repair. -
3.5.5 Provisions shall be made in the procedures for the selection ;
2 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 arc identified. Such reviews-shall be' documented.
-t 3.5.7 Materials, parts and equipment lwhich are standard, commercial' (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.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DESIGN CONTROL Page 3 of 5 Policy 3 OQAM.R9A/SQPFLR - 27
13.5.8
. , h"'
Procedurso ch:11 provids- for tha control of, d: sign interfacss ,
for t ntging ths. flow cf design'infor23 tion batwaen .
- organizations. Systematic _ methods shall be established for.
y communicating :needed design informarion across the interfaces, including _ changes to'the design'information'as the worko progresses.
3.5.9 Procedures shall include ~ requirements 'to'verifylthatLthe design is. adequate and that it meets-theLspecified designfinputs. The extent of the design verification required shall-be:a function ~ ~
of rhe'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 i however, standardized or previously proven designs shall:be reviewed ~for applicability. prior to use. ,
3.5.10 Acceptable verification methods shall include, but notibe- e limited to, design reviews,_ alternate calculations, Tor -
, qualification. testing. If a test program is used tonverify the l'
-adequacy of a design, qualification testing of'a _ prototype unit under the most adverse design conditions which are: appropriate,3 shall be used.. ,
L
- 3.5.11 Individuals or groups responsible for design reviews.or;other verification activities shall be. identified in theLprocedures E 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.
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 specifict. tion changes, including >those originating onsite, shall' be seoject t-o the same degree of ' control as the original design anj approved by the origina1' design organization unless another qualified, responsible organization 1s-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 unroviewed safety question or a change to the technical specifications shall be handled in accordance with procedures which address the requirements of 10CFR50.59.
3.5.15 Design records shall be maintained by the GGNS General Manager in accordance with Policy 17.0 of this Manual.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DESIGN CONTROL Page 4 of 5 Policy 3 0QAM.R9A/SQPFLR - 28
3.5.16 This S:ction Dalsted in. Revision A.:
3.5.17l Plant Procedures are!provided to' assure that responsible plant personnel are made aware of. design, changes / modifications which; may directly affect the;performancefof-their: duties.
- 1 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,ianother unit, or.for: ,
shared-facilities ~at GGNS..the' licensee may choose to purchase .;
similar services l(1.e.,. design or. construction) for.the '
operating unit (s). ..If'such services'ake pu'rchased: '
3.5.18.1 They shall lus procured in accordance w'ith the requirements of Policies'4.0 Land 7.0.and ANSI ..
-N45.2.13 (as modified and' included in-Appendix.A of-the OQAM);- f
~
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- 3. 5.'18. 2 They shall be in accordance=with thelQA-program !
! -(A-E/ Constructor's-or his suppliers') in effect for similar activities on other ornthe same unit (s) or r for shared facilities; and 3.5.18.'3 The A-E/ Constructor!A QA P ogram shall be-reviewed by-the licensee's: Supplier Quality Programs Assurance to assure that any additional. requirements which are considered necessary to assure quality have been included.
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OPERATIONAL' QUALITY ASSURANCE MANUAL 'Rev. 9a TITLE: DESIGN CONTROL Page 5 of 5 Policy 3 0QAM.R9A/SQPFLR - 29
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. > 4.0 PROCUREMENT DOCUMENT CONTROL j ss , y
!- 4 .1. PURPOSE This Policy describes the Operational: Quality Assurance Program measures to' control' procurement documents for. safety-related1 material, equipment. .
y and services for the Grand Gulf Nuclear Station.
~
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- 4.2 SCOPE This' Policy delineates responsibilities and-defines' requirements for-l Procurement document preparation, review, approval and change control-in g order to assure that purchased- safety-related . items and sordcas will
. conform to established, specified requirements.
s i 4.3 APPLICABILITY i
~
The requirements of this Policy apply-to all procurement documents lfor ;
safety-related material, equipment and servicesipurchasedlby.or for the
11censee during the operational phase of' nuclear. power. plant; activities. . 3
-4.4 RESPONSIBILITY 4.4.1 -All organizations participating in the preparation of- . _ .
procurement. documents. for safety-related;itemst andl services j during the operational phase are responsible fori developing, their own procedures or-using generic procedures. .-In either.
case procurement document control procedures which address'the-requirements of this Policy, applicable to their scope of; activities, shall be implemented. .!
, 4.4.2 The GGNS Genera 1 Manager is responsible for onsite. procurement L 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, approva11and issue of-procurement documents.
l 4.4.3 The Manager, Quality Systems Services'is responsible for !
performing 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 procedures for procurement document, control to assure
~
that they address the applicable requirements of:this Policy. ,
4.4.4 The Director, Nuclear Support and Director, Nuclear Licensing are delegated the responsibility for assuring that general '
office procurement activities performed by the Nuclear : Support Staff and Nuclear Licensing Staff respectively, are procedurally controlled in accordance with the- requirements .of this Policy.
This includes preparation, review, approval and issuance of procurement documents.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: PROCUREMENT DOCUMENT CONTROL Page~1 of 4 Policy 4 i 0QAM.R9A/SQPFLR - 30
14.4.5 - Orgrnizztions. supplying catorial,14 quip; int or servicas ars rssponsibis for co: plying with - tha spp11 cable rcquirsosnta of L ,
this Policy, as specified in the, appropriate procurement l
documents and for imposing ~them on their. contractors,and a 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 implementation of procurement document control measures and for !
quality review of procurement ~ documents and procedures; He'The '
Ofrector, Quality Progransland;the Manager, Nuclear Safety Oversight is are also responsible for carryingLout an audit-program, as described in Policy 18.0 cf this Manual,ito verify I
' conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy.s ;
1 4.4.7 The Manager, Purchasing and tne Manager, Contracts are responsible
- for performing procurement activities,Ein.accordance with the l
Operational Quality Assurance. Program,'as coordinated with tho' q Director, Nuclear Support;-thegDirector,-. Nuclear Licenalng;;the. ~
Director, Nuclear Plant Engineering; .the GGNS General Manager;3 <
the Director, Quality Programs; the Manager,-Plant.Modificat' ion ,
& Construction;1the Director, Corporate Services; the Nanager,- '
Nuclear Safety oversight; and,Lother. appropriate personnel as ' ;
delineated.in appropriate procedures.
/
14.4.8 The Director, Nuclent Plant Engineering-is responsible for 'f assuring procurement activities performed tar the Nuclear Plant: .i l Engineering Staff are procedurally ~ controlled.in.accordance with i I the requirements of this Policy. This includes preparation, .
j 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.
A 4.4.10 The Manager, Plant Modification &' Construction.is responsible for assuring procurement activities to support the implementation 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.
4.4.11 the Manager, Nuclear Safety Oversight is responsible 'or .
assuring procurement activities performed by Supplier Quality Assurance staff are procedurally controlled in accordance with.
the requirements of this Policy. This includes preparation, review, approval, and issue of procuremont documents.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ~ PROCUREMENT DOCUMENT CONTROL ,
Page 2 of 4 Policy 4 o
'OQAM.R9A/SQPFLR - 31
Di 4.5. REOUlxEMENTS'
- 4. 5. '1 Proeddurcsisha111be established byi the responsible .
organizations to clearly delineate ' the- sequence of actions tof .
be accomplishedito control.the preparation,Jreview, approval
and issuance of procuroment documents for safety-related items' :
and services'.-
'425.2 -The' procedures shall: assure that procurement documents issued '
at all . levels 'of procurement -include provisions for the following, as applicable:'
4.5'.24 1 [A statement of the scope of work to be performed byl
~.the contractor or supplier; 4.5.2.2 Identification:of:the dest r basis. technical' I
requirements by reference to specific drawings, specifications, codes,. regulations, industrial i standards or' other documentation, including = revisions !
! .thereto, that. describe the' Items or services to be i
> furnished;. ;
4.5.2.3 . Identification of test., inspection'~andJacceptance- 'I requirements, and any special. instructions and requirements: for such activities as design, .
fabricationk identification, cleaning, erecting, packaging, handling, shipping and extended-storage; I 4.5.2.4 Identification of the quality assurance program .
. requirements which must be complied.with by.the- '
l contractor or supplier; 4.5.2.5. Stipulation =that-the provisions of 10CFR211 apply; 4.5.2.6 Identification of the documentation, such as drawings, specifications, procedures, fabrication and-inspections plans, inspection and: test records, personne1 Land procedure qualifications,.and chemical and physical test results.to be. prepared'and maintained by the supplier or contractor-and' requirements for-submittel to the licensee for review and 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 licensen-prior to use or installation of. the procured item; 4.5.2.8 The licensee's right.of access-to the supplier's
- facilities and records for source quality '
verification, inspection and audits, as deemed.
necessary; i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a '
TITLE: PROCUREMENT DOCUMENT CONTROL Page 3 of 4 . Policy 4 3 0QAM.R9A/SQPFLR - 32
i 4.5.2.9- Ext:nsion of cpplic2blo'r;quirc Ints'~tollowar tist {
cubc:ntrsetors cnd cupplista,. including tha '
licensee's 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. p'rogram, reporting.and' approving.th's " Accept-as.is or '
" Repair" dispositions' of. nonconformances ;-
c 4.5.2.'11 The 11censee's right to hold shipment'if. .
s procurement document requirer.ents.: including'those i
for documentation have not.been fulfilled.
-4.5.3 The procedures shall assure that procurement documents are +
l subjectad to technical and quality review by, qualified > .,
j l personnel-and are' approved by designated-Individuals' prior to issuance. The reviewJand approval shall be documented- and i available for verification. t 4.5.4 Review and ' concurrence-with the adequacy of quality. requirements 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.subjec't'ed 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 uot affect-the: quality '
of the item or service.
4.5.6 Procurement documents for spare or replacement ' parts ' for i safety-related structures or systems. shall be subject to control-at Icast equivalent to those-required:for purchase of original =
equipment, or those specified by~a properly reviewed and ,
approved revision to the original requirements- . i 1
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'4 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: PROCUREMENT DOCUMENT CONTROL 4
Page 4 of 4' Policy 4 0QAM.R9A/SQPFLR - 33
=,
5.0 INSTPUCTIONS PROCEDURES AND DRAW 1 HGS I 5.1 PURPOSE This Policy describes.the Operational QualityLAssurance Program measures. I to assure that all activities affecting the quality or safety of the+
Grand Gulf. Nuclear' Station are prescribed and accomplished in accordance !
with documented' instructions , procedures, drawings orl other documentsL '
appropriate to the circumstances.
5.2 SCOPE This Policy delineates responsibilit1As 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 JPolicy 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 '
J5.4.1 All organizations performing activities during the operational !'
phase which. affect the quality of safety-related structures, systems and components are responsible for. performing these !
activities in accordance with direceives, documented instructions, procedures or drawings. It is the responsibility of the managers of these organizations to assure-the development, review, enpra-el and control of directives,-
J instructions, procedu. .. drawings necessary to control y 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, the Vice President, Operations Support; Senior Vice President; Planning & Assurance; and, the Vico. President,'lluman Resources
& Administration to ensure that-those' instructions, policies,
! procedures and drawings that cross internal organizational j lines integrate and function in accordance with ~ the above.
5.4.2 This section deleted in Revision 3.
t 5.4.3 During the operational phase, the GGNS General Manager is ;
responsible for assuring that adequate inspection plans; test ;
calibration, special process, maintenance,.tast and repair ;
procedures; drawings, specifications and other safety-rele.ted i documents and revisions thereto are used. During the implementation of design changes and plant modifications, the Manager, Plant Modification & Construction is responsible for assuring that. inspection plans: modification procedures; drawings, specifications and other safety-related documents and l appropriate revisions thereto are used.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Page 1 of 3 Policy 5
'OQAM.R9A/SQPFLR - 34
,, - , -, +-
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Pr optration:1 ph:co tssting lo ' ths rssponsibility of tha Unit ;
2 C:natruction Sup2rintend:nt. Tha Dirteter, Quality Progr u a !
is responsible;forthe performance of-nondestructive
.. examina tions .1 i l
=The Manager, Quality Services is responsible for performing theE quality review of procedures / instructions, and determining that-the necessary QA requirements are includedL He is responsible
' for determining the need for: inspection ' requirements 'in work l documents. Documents which contain administrative controls i which specify quality assurance requirements will also be-reviewed by the Managor, Quality Services.- Lower' tier
~ documents (section procedures / 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 Director, Quality- Programs is responsible for '
l indoctrination and certification of'theselindividuals.
5'.4.4 ,TheDirector,QualityProgramsisiandthe[#anager, Nuclear .
Safety Overs /ght. are responsible. for- reviewing and/or approving . t 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 thisLManual, to verify conformance with Operational Quality' Assurance Program requirements, '
including the requirements of this Policy.
5.5 REOUIREMEhTS 5.5.1 Writ ten instructions, procedures, drawings, or other documents 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 commensurat'e with the nature.of.the activity shall be l 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.
1 5.5.3 Instructions, procedures or drawings shall include quantitative 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 l used in their preparation.
OPERATIONAL QUALITY ASSURANCE MANUAL . Rev. 9a TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Page 2 of 3 Policy 5 OQAM.R9A/SQPFLR - 35
i 5.5,6 Wh2n tha1NRC G L ec2 pts chang:c to a policy or in appindix which L
recult in c:rai rcstrictiva requirtcInts,- cffceted ispis::nting Procedures must be issued or revised within 120 days. If--
procedures cannotLbe revised or issued within 120 days. the; manager of the affected organization (s) must. approve a schedule i detailing when the required; changes will.be accomplished. 11 f i l- theLapproved changes are less restrictive, the'more restrictive: !
L requirements-must be complied with.until tha old procedures are revised or new procedures are issued. When changes to-procedures (more restrictive) are required by' changes to NRC c regulations or by Bulletins or Orders, the' required procedures '
shall be changed within 120 days.or as stipulated in the
. licensee's response-to the Bulletin or Order or as-set-forth in'
- the Regulation. The wore restrictive time frame shall be met. !
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OPERATIONAL QUALITY ASSURANCE MANUAL Rev.'9a TITLE: INSTRUCTIONS, PROCEDURES AND DRAWINGS Page 3 of 3 Policy 5 0QAM.R9A/SQPFLR - 36
s f.0i DQCglENT CONTROL 6.1 PURPOSEL 1
This Policy describes the ' Operational Quality Assurance Program measures to control safety-rclated. documents for the Grand Gulf:Nucirtr Station.
't 6.2 SCOPE This Policy'de11neates' responsibilities;and. defines requirements for the review, approval, issuance and control of documents and. changes or revisions thereto, which prescribe :all activities af fecting quality ior ;
safety.-
6.3 APPLICABILITY The requirements of this Policy apply to al1 individuals or orgatilzations
~
1 performing functions which affect safety-related structures, systems orL '
components during the operational phase of nuclear power: plant activities, t 6.4 RESPONSIBILITY- i 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 orfservices are S
responsible for complying with the. applicable-requirements of this Policy as specified in the appropriate precurement documents, and for imposing-them on the1r 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 Programs is and the #anager, Nuclear Safety Oversight are responsible ~for monitoring.
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.
L 6.5 REOUIREMENTS i
6.5.1 Procedures shall be established and~1mplemented 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. 9a TITLE: DOCUMENT CONTROL Page 1 of 4 Policy 6
-q OQAM.R9A/SQPFLR - 37
-6.5.2 -Thn proceduras chall idsntify tha docu:cnts to'bs' controlled. .;
-As a cinicua, thsy r. hall'includs:
Design Specificaticens -
Design, Manufactur: ng, Construction and InstN11ation Drawings. l Procurement Documents Quality Assurance Manuals, Procedures'and Instructions 1
Operating Procedures Operating and Special Orders' '
(
Maintenance and Modification Procedures Manufacturing, Inspection and Test Procedures <
Equipment and Material Control Procedu'res Refueling Procedures Updated Final Safety Analysis Report Design Change Requests / Packages 7
Design Change Notices Quality Deficiency Documents T Q-List c
6.5.3 The procedures shall specify the individuals or organizations 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 document.
6.5.5 Documents shall be approved for issue by authorized personnel 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 status of instructions, procedures, specifications, drawings and procurement documents.
The lists shall be available to responsible personnel to preclude the use of superseded documents.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DOCUMENT CONTROL Page 2 of 4 Policy 6 0QAM.R9A/SQPFLR - 38 i
4 I
6.5.7 Docu:::cnts riquired ! to .parfora a ap;cific .r;ctivity chall ba sv 11chle.ct ths locction_whara thi cctivity-is to b2 -)
performedprior to commencement.of.the' activity. Cancelled . l deactivated or superseded documents shall be controlled-to- i prevent their inadvertent 7:se.
6.5,8_ Unless delegated to other appropriately qualified' organizations,' -
changes to documents shall,be reviewed and approved'by the same organizations that performed the original review and approval. j t'
6.5.8.1 Changes shall-be included in-the documents-(1.e.,.
_ procedures: or instructions) prior _ to implementation of
]
- }
the change, except in those cases where adequate' t procedural! controls allow implementation.of changes l prior to revision of the original document.- These .:
changes, if considered: permanent, shall be incorporated' L!
into the origina1' document.in a timely manner as a defined by. Quality Programs. ' ' '
i i
6.5.8.2 Prior to-issuance of an Operating' License on'. Unit _2,- )
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 r months, whichever occurs first.-
6.5.8.3 Unit 1 Preoperational and Startup Test procedures,- M including temporary changes, shall be evaluated and ,
revised as necessary prior to being utilizedLon Unit-2.
l .
6.5.8.4 Preoperationalland_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 uand- :
again, i 6.5.9 In addition to initial' review and approval, procedures for operational phase activities shall be subjec to subsequent l
Periodic reviews with a specified frequency t apendent-on the ,
type and complexity of,the' activity involved.
6.5.10 Subject to the clarification of ANSI N18.7-1976/ANS-3.2',
Section 5.2.15 given in Appendix.A of this program, 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 usedr 'outinely.to . ,
determine if changes are necessary or desirable. A revision of I the procedure constitutes a procedure review. The two. year
-cycle began on June 16, 1982 with issuance of the Operating >
License for Unit 1. '
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DOCUMENT CONTROL Page 3 of 4 Policy 6 i
0QAM.R9A/SQPFLR - 39
6.5.11 Following any'todification to a plcnt.cystaa'and prior to- '
initiction of any .cctivity af fseted by, ths' todificttion, ths
'spplicabic prccedurcs'shall:bs_ reviewed tofdstermine if changes are-required.
6.5.12 A documented. review ofiapplicable procedures ~shall be~ performed following an accident, an unexpected transient l, significant i operator error, or equipment malfunction.whicheresults in'a l reportable event, to determine'If changes are; required to' j l prevent recurrence.
l '6.5.13 . Review and approval of documents, and changestthereto, shall be:
documented to the extent necessary to provide l evidence of s compliance with the requirements of this Policy.';
4
- L
.f i
l 1
i l'
1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev 9a TITLE: DOCUMENT CONTR0T-Page 4 of 4 Policy 6
.0QAM.R9A/SQPFLR - 40
_,(
7.0 CONTROL'OF PURCHASED MATERIAL. EOUIPMENT AND SERVICES j 7.1 PURPOSE j
~
This Policy; describes _the_ Operational Quality' Assurance Program. measures to controltthe procurement of safety-related_ material,-equipment ~and-services for the Grand Gulf Nuclear Station.
i l- 7.2 SCOPE l This Policy delineates responsibilities 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 ,
i to tho' procurement documents. '
j
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 l activities, and to all-Individuals or organizations. participating in- '
the procurement of such items or. services. -
7.4 BESPONSIBILITI t
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 4 Support;: the Director, Nuclear Licensing; tho' Director, Quality Programs; the Director, Nuclear Plant Engineering; the GGNS ,
General. Manager (for post-modification, startup testing and operations); the Director, Corporate-Services; the Manager, Plant Modification &. Construction; the Nanager, Nuclear Safety ,
oversight; and the Manager,. Project Management.. It is the -
responsibility of these individuals to assure that the 9 requirements of this Policy, which are applicable to their ec. ape of activities, are implemented.In-accordance with written approved procedures. These activities . include', as appropriate: .
source evaluation and selection; evaluation of' objective a evidence of quality; furnished :hy the supplier; source l
inspection; audit, and/or source quality verification; examination of items upon delivery.
- l l
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 4 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 for assuring implementation of procurement activities at the ,
j Plant site. He is responsible for inspection as necessary to. l assure compliance with the requirements of this Policy. '
t OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CONTROL OF PURCHASED MATERIAL, I EQUIPMENT AND SERVICES Page 1 of 5 Policy 7 -
OQAM.R9A/SQPFLR - 41 -
I-
7 . 4 ~. 4 ' : Ths 'Dirdctor, Quality: ProgrcNULis reaptnsibis for;essuring ths? 3 1:plessntation'of Oparztionti Qurulity=l.souranca Prograa !
requirements relative to procurement activities; ineindinar s the quality evaluation of sappiters; seuree inspectionsi soures.
-l quality veriffeatfen and an audit-program,.as described ins Policy'18'.0-of this) Manual...to verify conformance with?
f Operational = Quality Assurance Program, requirements,, including l b ; the requirements of this Policy.; '
i 7.4.S The Manager, Nuclear Safety Oversight:1s responsible for 1 assuring the implementation of Operational QualityJAssurance Program requirements relative to procurement activities,.
~
-including: the quality evaluationlof suppliers, source. i inspection,. source quality verification, and an audit program,; i as-described in Policy 18.0 of this manual to verify conformance'with the Operational Quality Assurance ~ Program 'i requirements, including the requirements of this Policy. '
7.5 REQUIREMENTS 7.5.1 Neasuresshallbeestablished,implementedanddocumentedby.
the appropriate organizations,,conristent with their~ scope of responsibilities, to assure that-purchased material,. equipment ;
and services, whether1 procured directly or through' contractors, conform to the procurement documents. These measures shall l
. 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 tpon delivery..
.j 7.5.2 '
Procedures shall be established to provid e' for the< selection ~
of suppliers based on one or more of the following-7.5.2.1 An evaluation o'f the Supplier'.s Quality Assurance ;
Program / Manual / Procedures, as'appropriste. f i
7.5.2.2 Review and evalu~ation of historical quality performance.
data; j
i 7.5.2.3 Source qualification programs; i 7.5.2.4 Source quality surveys; i 7.5.2.5 Through the 6eerdinating Agency for Suppifer Evaluation (BASE) using the current revisien of the 6ABE Register use of Nuclear Procurement issues Committee (NUPIC) audits indicating a program meeting appropriate requirements. When the GABE Register is l used fer eemmercial (estalog and off the-shelf 3 l- '
items; reference to the 6ABE Register shall.previde.
adequate documentary evidence of sonree evaluatient-OPERATIONAL QUALITY ASSURANCE MANUAL -Rev. 9a TITLE: CONTROL OF PURCllASED MATERIAL, EQUIPMENT AND SERVICES Page 2 of 5 Policy 7 0QAM.R9A/SQPFLR - 42
Gr:23raf21 itsco cro ihace that do.nat'requira uniquaq 2
d2 sign.cr sp2sisi- cnginscring opteffistticast er era manufactured'te nattenal standardster.by; precesses
. generally automated er highly repetitivet er.there is-little chance for errer during manufacture.to affeet_
their safety-related,characteristiest: Fer items .;
~w hfeh-are not eemmerefal er whfeh-require-unique-
-design er speefal engineering specificatiens; a A; copy:of-.the qualifying. audit report shal1~be-obtained and reviewed for' adequacy and: applicability prior to [
selectlon._
l 7.5.2.6 Through~'the NRC's." Licensee Contractor and Vendor-
- Inspection' Status Report".(white book) for' i
- contractors with IE letters confirming Quality-Assurance Program implementation;= !
7.5.2.7 Through documented information received from oth'ers "
(architect-engineer ~, NSSS supplie'r, 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 methodsTof evaluation and the criteria for supplier acceptan'ce.
l To facilitate pre-award supplier evaluation','t_elephone-surveys ,
may be conducted by Supplier QualityiPrograms Assurance as.
established by Supplier Quality: Assurance Procedures. Other> ,.
means of -supplier pre-award evaluation are:also established by :
l Supplier Quality Assurance Procedures.
7.5.3 Evaluation and selection of the supplier.shall be" performed-
.~ In accordance with written procedures by qua11flid quality _
assurance and technical personnel prior to:or concurrent with' '
l award of the procurement document. ,
L 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 shs11 not be i relied upon to fulfill any safety-related function until after the item -is shown n meet procurement requirements (including
- QA -
Program).
7.5.4 Results of supplier evaluations shall be documented and retained on file. Any deficiency identified during a supplier evaluation-shall se resolved early enough in the procure' ment cycle to
~
prevent the deficiency from-adversely affecting the quality of .4
!. the purchased product or service.
1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev'. 9a l . TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 3 of 5 Policy.7 ti 0QAM.R9A/SQPFLR - 43
_ .. _ _ _ J
I
! .t
. 7 . 5 ~. 5 Procidursa shall .ba satchlished to provida- for. sycluation cnd' i verification activitiss auch'as sourcs'inspactions', courc2 quality verification or audits,~as necessary, to assure the:
_ quality of the. Item and to verify supplier.conformance:to
~
3 . procurement document requirements.:
! '7.5.6: Inspection' procedures shall specify the characteristics or' .
,I-L processes to be witnessed,Linspected or verified, and' accepted. '
The' method of verification'and the extent of-documentation-L required; and those responsible'for. Implementing the D inspection.. Source quality verification procedures shall-l specify the characteristics or processesito be witnessed, . ,
l observed or verified, including the method of verification and the extent of documentation. required.- Audits ~ shall be: i l performed in accordance with procedures which implement the ;
requirements of Policy 18.0 of:this Manual.
j 7.5.7
~
The extent and frequency of evaluation and; verification !
activities.shall be a function of the relative,importance,- .
complexity and anality of-the item procured and-the supplier's' quality pe:Iormance. Source inspections, source l quality; verificaciens and auolts may.not be necessary when conformance i of an item to procuremeat: requirements can be verified. by
~
receipt inspection, review-of. test reports,:or other means. :
7 . 5.' 8 Receipt inspection of. cupplier-furnished items .sha11 bet -i procedurally-controlled to assure: lthat the' items are properly-identified and correspond with ' the -identification on the- 1 receiving documentation; that the items and acceptance records are inspected and judged acceptable-in accordance with predetermined instructions prior to installation or-use; that I inspection records or certificates of conformance are.available at-the plant site prior to installation or use of the item; and, that items accepted and released are identified *ascto their inspection status prior to storage or:use.
Prior to issuance of an Operat'ing License (GL) for Unit 2, Startup may install equipment or parts'for which'all ,
i documentation has not yet been received at the' plant. site:
such installation and use will be on a " risk basissuch that a i
failure'to subsequent 1y' receive all of'the required documentation may require the equipment or parts to be removed l
I 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 ,f the conditional release process, and will assure that the '
l applicable procedural and administrative aspects of this. Policy l
(7.5.8) and Policies. 8.5.8, 14.5.'5 and 15.5.5 of the L Operational Quality Assurance Program are fulfilled.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a 1 TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 4 of 5 Po11cy.7 P
OQAM.R9A/SQPFLR - 44
7.5.9 .
~Racords required to ba furnishsd by ths supplier shalle b .
4.0 of this Manual.<-These records shall be, review
- accepted by personnelt
, .t
' activity.- specifically' designated to perform this; These1 personnel will'be' designated in accordance !
with applicable' procedures. :Other licensee organizations may .
t {
be useda when.
for tech review'-their areas of expertise provide 'an adequate
. s basi from r.ncF tr fuelisuppliers.)'(e.g., Nuclear Fuels.could review records-7.5.10 The recorda sh identilfar tus411Riaclude,.as a minimum,-documentation that J requires mts'ie ;.. 3ased item ~ and the ' specific procurement documentation whi codes, standards, specifications) met; and;
.have nct bens t;ot..ch identifies procurement 1 requirements which Subject to the clarification of ANSI documentation shall= include a-description .
_.-such of ,'thoseN45 nonconformances dispositioned " accept-as-is"'or " repair".
7.5.11 Where supplier certificates of-conformance'are used to identify the requirements met by-the item,_the certificates of- -
s 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 item, at least equivalent to those used for the original revision or tothose the specified by: a properly reviewed and-approved original requirements. -
7.5.13 When a -supplier is removed from;the Qualified- Suppliers Li t s
procedures shall assure that any outstanding purchase orders for ,
that supplier are reviewed,- and appropriate action taken o t
are handled and dispositioned as nonconformances. assu 7.5.14 This section deleted in Revision'6.
OPERATIONAL QUALITY ASSURANCE MANUAL TITLE:
CONTROL OF PURCHASED MATERIAL, Rev. 9a EQUIPMENT AND SERVICES '
Page 5 of 5- Policy 7 0QAM.R9A/SQPFLR - 45
.= '- , , , , . . . . . .--
n
" .8.0-IDENTIFICATION AND CONTROL OF MATERIALS.' PARTS'AND COMPONENTS ;
8.1 PURPOSE
'This Policy describes the Operational =Q ality' Assurance: Program measures -f to provide for thefidentification'and conbrol-of safety-related. material,; 't
- parts.and components for the Grand Gulf Nuclear Station.. ,
4 8.2 SCOPE y , i This Policy delinentes;responsibilitiesiand defines' requirements for'the l identification- and control: of safety-related items in order to assure that. 1 i'
c 'y cirrect and accepted' items.are used_or; installed.
8.3 APPLICABILITYL' W-The requirements of4this Po11cy-apply to-allL. individuals or organizations d participating in the~ procurement, fabrication, receipt,-~ storage,.
installation,. operation,; modification or repair-_of. safety-relatedtitemsi :'
during the operational phase of nuclear power plant activities. ,
8.4 RESPONSIBILITY ~
8.4.1 Responsibility and authority.for the-Identification, control; and testing of materials, parts;and' components during the i
4 operational phase are delegated ~ to the GGNS General . Manager:
l except, during implementation of design changes and plant: '
modifications,: the Manager, Plant Modification & Construction is responsible'for this activity. They'are responsible forl assuring m 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-
documenta, and for imposing them on their contractors and=
suppliers as applicable. .They are a 60 responsible for verifying, through surveillance or audits, that the requirements y are being adequately implemented.
8.4.3 The Manager; Quaifty Systems and the Manager,' Quality Services are is delegated the responsibility. for assuring implementation of identification and. control requirements ~for' items at the plant site by receipt inspection and other inspections;_ _.
respectively. The Manager, . Quality Services .is responsible for reviewing-procedures and work documents to-the extent necessary >
to verify conformance to the applicable requirements.of this Policy. '
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8.4.4 Th3 Direct:r, Quality Pregra:s has ccd tha g:nts:r, Nuclocr.
S fcty Overa/ght h:v3 tha rc:ponsibility fcr c rrying cut cn 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 i Policy.-
8.5 REOUIREMENTS [
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 subassemblies, in order.to assure that only correcc and accepted ;
items are used and installed. !
8.5.2 Tha procedures shall be developed by the appropriate .i orga'ifzations to cover the various stages from procurement of the item through fabrication, receipt, storage, installation, !
use, sodification or repair. ;
I 8.5.3 .The procedures shall provide assurance that a unique identification of items is maintained..such as by part number, >
serial number, heat number, drawing identification number or .
other appropriate means. i 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, i 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 i l
treatment or coatings unless other means of-identification are ;
substituted. !
8.5.8 Procedures shall provide for the verification and documentation '
. of correct identification of items prior to release for ,
l fabrication, assembling, shipping, storage or installation, j 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, ;
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS Page 2 of 3 Policy 8 l
OQAM.R9A/SQPFLR - 47 i
I(
cubsy tra, cr compon:nt far fulfilling th fr intcnded cafety l function. Th M: nag ^r, Quality S;rvices chali review cad
}L eeneur with is responsible for reviewing and concuring 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.
F l
l r
r OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS Page 3 of 3 folicy 8 0QAM.R9A/SQPFLR - 48
900 CONTROL OF SPECIAL PROCEEEEE 9.1 PURPOSE.
This Policy describes the Operational Quality Assurance Program measures (
to. provide for the control of safety-related special processes for the ~
Grand Gulf Nuclear Station. '
9.2 SCOPE 1
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 a. , to all individuals or organizations l performing special processes during the operational phase of nuclear power t plant activities under this Operational Quality Assurance Program.
l 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 i Manager. During the implementation of design changes and plant modifications,.the Manager, Plant Modification & Construction 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, Quality i 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 specini l
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 special procesaes shall be subject to the applicable requirements of this Policy as specified in the appropriate procurement documents. Individuals or organizations responsible for the i preparation of procurement documents shall assure that the !
applicable requirements'of this Policy are included, as l stipulated in Policy 4.0 of this Manual. '
t-I OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CONTROL OF SPECIAL PROCESSES Page 1 of 2 Policy 9 i OQAM.R9A/SQPFLR - 49
P 9.4.3 Th3 M:nas r, Q:ality S:rvicts is rcsp:nsiblo f:r rcviewing Plant >
Ad inictrativa Pr:ceduria Crd Nuclear Plcnt Engin:Crinh !
Procedures, controlling special processes, and for reviewing .
work documents and inspection of special process activities, I including nondestructive examinations, to the extent necessary .
to verify conformance to the requirements of this Policy. !
9.4.4 The Director, Quality Programs has and the Nanager, Nuclear I Safety Oversight have the responsibility for ,
monitoring the special process control measures of offsite '
organizations, and for carrying out an audit paogram, 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' 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. lie is also responsible for reviewing and approving all ;
~
contractor special process standards prior to use at the Plant Site.
t 9.5 REQUIREMENTS 9.5.1 Procedures shall be developed and implemented by the responsiblo 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 applicabic 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.
^
+
r 9.5.5 Qualification records of personnel, equipment and procedures associated with special processes shall be established, l
1 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.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CONTROL OF SPECIAL PROCESSES .
Page 2 of 2 Policy 9 OQAM.R9A/SQPFLR - 50
10.0 INSPECTION 10.1 PURPOSE This Policy describes the Operational Quality Assurance Program I measures to provide for the inspection of activities affecting the safety of the Grand Gulf Nuclear Station.
10.2 SCOPE l This Policy delineates responsibilities and defines requirements for the development and implementation of a program for the inspection of activities affec+1og safety in order to verify conformance to the documented instructions, procedures and drawings for accomplishing the activity.
i 10.3 APPLICABILITY '
The requirements' of this Policy apply to all inspections performed on i safety-related structures, systems or components during the operational phase of nuclear power plant activities.
10.4 RESPONSIBILITY r
10.4.1 Overall responsibility and authority for establishing and r impicmenting an inspection program at the plant site during '
the operational phase'are delegated to the Director.
Quality Programs and the GGNS General Manager. During the implementation of design changes and plant modifications, -
the Manager, Plant Modification & Construction, in conjunction with the Director, Quality Programs, is responsible for these activitiesa The Director, Quality '
Programs is responsible for assuring that procedures /
instructions developed for the performance of work operations include appropriate inspection requirements and ;
for ansuring that inspections and examinations are performed '
and documented where necessary to assure quality. The GGNS General Manager and the Manager, Plant Modification & i Construction (for implementation of design changes and plant modifications) are responsible for assuring that measurements 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, Quality Services is delegated the-responsibility for assuring that the onsite inspection program (except for including receipt inspection) is carried out in accordance with the requirements of this >
Policy. The Managert Quaifty Systems is delegated the i
' responsibility fer assuring that the ensite receipt inspection pregram is carried out in aceerdance with the requirements of this Policyv The Manager, Quality ,
l 1
Services is responsible for reviewing Plant Administrative Procedures which control work instructions, modification .
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a -
TITLE: INSPECTION Page 1 of 5 Policy 10 1
_0QAM.R9A/SQPFLR - 51 s
cud repair instructions; pro:p3r: tion:1 cnd ctortup tcst precedur:s; and cth r drcurents to casuro that th y contain the appropriate inspection requirements. The -
Manager, Quality Services is. responsible for ' developing procedures for the performance of all quality inspections. ,
The Managert Quaifty Systems and the Manager, Quality
- Services are is responsible for implementing inspection procedures (receipt inspectden and other inspectionst ;
respectively). The coordination of activities-concerning :
the training and certification of a11' quality _ inspectors '
shall be accomplished by the Director, Quality Programs; !
Level III inspectors are appointed. All safety-related work authorizations will be reviewed, as defined by the appropriate implementing Administrative Procedures, by the !
Manager, Quality Services for determination of any quality inspection requirements. Procedures or work authorizing i documents which control repetitive tasks are reviewed initially and when revised for inclusion of inspection requirements. The-Manager, Nuc13ar Safety Oversight is delegated the responsibility for assuring that the source -
inspection program is carried.out in accordance with the requirements of this policy.
I 10.4.3 The licensee may delegate the responsibility for ,
implementing certain portions of the inspection program to other organizations. However, the licensee retains the ultimate responsibility for assuring.that all aspects of the inspection program are carried out. At the plant site, the Manager; Quality Systems and the Manager. >
Quality Services are is responsible for assuring that inspection activities (receipt inspection and ether inspectionst respectively3 assigned _to outside organizations are accomplished in accordance with the requirements of this Policy. r 10.4.4 Organizations supplying safety-related material, equipment ;
and services are responsible for complying with the :
j applicable requirements of this Policy, as stipulated in l the procurement documents, and for imposing them upon their t 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 and the #anager, Nuclear l Safety Oversight are 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.
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10.5 REOUIREMENTS 10.5.1 Inspection requirements shall be included in applicable specifications,-drawings, procedures, instructions or other documents which prescribe and control safety-related activities. '
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 procedures, which verifles that the activities are accomplished in accordance with the specifications, drawings, procedures or instructions.
10.5.3 Inspection procedur2s,' instructions or checklists shall include provisions, as required, for the following:
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 1 criteria; '
10.5.3.4 A description of the method of inspection; 10.5.3.5 Recording evidence of the completion and i 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 available 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 activities (work functions associated with normal operation of the plant, routine maintenance, and certain technical services routinely assigned to the onsite operating organization)
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: INSPECTION Page 3 of 5 policy 10 OQAM.R9A/SQPFLR - 53
c:y be conducted by corond-lins supervis:ry perc nn31 cr !
by cth:r qualified p;rsonn31 n:t c: signed first-lina supervisory responsibility for conduct of the work.
When inspections of operating activities are performed by itidividuals other than those who performed or directly ;
supervised the work, but are within the same group, the- .
l .following controls shall be met:
10.5.5.1 The quality of the work can be demonstrated i through a functional test when the activity ;
involves breaching of pressure retaining items; '
10.5.5.2 The qualification criteria for inspection . ,
personnel are reviewed and found acceptable by ,
Quality Programs prior to initiating the ;
inspection.
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10.5.6 Personnel performing inspections which require specialized ;
qualifications or skills shall be qualified in accordance.
- with ap,,11 cable codes, standards or licensing requirements, and their qualifications and certifications shall be documented and kept current. !
10.5.7 If mandatory -aspection hold points are required, the f specific ho) points shall be specified in the appropriate- i drawings, s}.ecifications, procedures or instructions. The-inspection program shall provide assurance that' work does ;
not progress beyond the hold point until released by th'e' ;
designated authority, and that required notification and-acknowledgement has been satisfied prior to work i continuing. ,
10.5.8 If inspection is impossible or disadvantageous, indirect d
control shall be provided by monitoring processing methods, equipment, and personnel. Inspection and process '
monitoring shall be utilized if control is inadequate without both.
l 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, identification of inspection personnel, and documenting inspection results.
10.5.10 Modifications, repairs and replacements shall be inspected in accordance with the original design *nspection t requirements or documented engineering - ived 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.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: INSPECTION Page 4 of 5 Policy 10 OQAM.R9A/SQPFLR - 54
i 10.5.12 R:c:rds chall b3 k pt in cufficient d tell to provida q' cdequ to c:nfir:Stica cf. tha inspe2tiin progrcr. R;ctrd3 '
shall be maintained in accordance with Policy 17.0 of this Manual.
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
' inspections.
- 10.5.13.1 Complexity, magnitude or criticality of the work. ,
10.5.13.2 Documented engineering inspection requirements, j 10.5.13.3 Design organization inspection requirements.
10.5.13.4 Components safety impact.
t 10.5.14 Inspections shall be performed on repetitive, routine and rework items as determined by the Manager, Quality Services.
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11.0 TEST CONTROL
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11.1 fURp0SE '
This Policy describes the Operational Quality Assurance. Program l menstres to control testing of safety-related structures, systems and components for the Grand Gulf Nuclear Station.
t 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 '
documented.
11.3 APPLICABILITY The requirements of this Policy apply to_all testing performed on safety-related structures, systems and components during the operational 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 GGNS General Manager is also
- responsible for the development and implementation of testing programs for design changes and plant-modifications. The responsibility and authority for the development and implementation of preoperational phase testing programs are delegated to the Unit 2 Construction ,
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 j delegated onsite testing responsibilities impose the l applicable requirements of this Policy on their internal l operations and on their contractors or suppliers.
11.4.2 Organizations responsible for conducting offsite testing are subject to the applicable requiremencs of this Policy as specified in the appropriate procurement documents. .
Individuals or organizations responsible for the preparation-l, of procurement documents shall assure that the applicable L requirements of this Policy are included, as stipulated in j Policy 4.0 of this Manual.
11.4.3 This section deleted in Revision 3.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: TEST CONTROL )
Page 1 of 3 Policy 11 t 0QAM.R9A/SQPFLk
11.4.4 Tha M:n:g:r, Quality S;rvices is d31eg0ted tha rc:pon31b111ty fcr cocuring impicarnt0tiin cf test !
activities at the plant site by inspection. He is responsible for reviewing test programs and Plant i Administrative Procedures which control testing to verify conformance to the requirements of this Policy. !
11.4.5 The Director, Quality Programs has and the #anager, Nuclear Safety Oversight have the responsibility for 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.
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11.5 REQUIREMENTS 11.5.1 A test program shall be established and implemented to assure that testing required to demonstrate that a safety- t related structure, system or' component will perform
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satisfactorily-in service is identified and documented, and
- that the testing is performed in uccordance with written, controlled test procedures. i 11.5.2 The test program shall be implemented by the responsible organizations to cover all required testing, including .;
pretotype tests, preoperLtional tests, initial start-up l ter ts, surveillance tests, and tests associated with plant '
ma.ntenance and modifications during the operational phase.
11.5.3 Th.'s 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 tasts and inspections. Frequency of surveillance tests may be related to the results of reliability analyses, 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 '
sufficient to confirm that the modifications or changes reasonably produce expected results and that the change does not reduce safety of operations, j
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TITLE: TEST CONTROL Page 2 of 3 Policy 11 0QAM.R9A/SQPFLR - 57 t
11.5.7 Writt:n procedur:s f:r perfcrains tha tests chall inc:rpor;to cr rofercnco tha following, ca cpplic blo:
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 instrumentation; adequate and appropriate equipment; trained, qualified,'and licensed or certified personnel; assurance of completeness of the item to be tested; suitable and controlled environmental conditions; and provisions for data collection and storage);
11.5.7.5 -Hold points or witness points for inspection by designated personnel; j 11.5.7.6 Acceptance and rejection criteria; 11.5.7.7 Methods of documenting or reccrding test data' and results.
11.5.8 The documented test results shall be evaluated and their acceptability determined by qualified individuals or +
organizations as designated in the procedures. ..
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12.0 CONTROL OF MEASURING AND TEST EOUIpMENT 12.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures to provide for the control of measuring and test equipment used in the performance of safety-related activities 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 equipment used in safety-related applications in order to assure the .
required 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 inspections, 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, levels and other such devices if normal commercial practices provide sufficient accuracy.
12.4 RESP 0NSIBILIII
- 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 of design changes and plant modifications, the Manager, Plant Modification & Construction is responsible for ensuring that all M&TE utilized are i controlled in accordance with procedures developed by the -
GGNS General Manager. They are responsthie for assuring that procedures 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 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.
l 12.4.3 The Manager, Quality Systems is delegated the responsibility I for assuring by audit ti.e .ontrol of measuring and test equipment at the plant sjce. 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, Quality Services is responsible for OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a-TITLE: CONTROL OF MEASURING AND TEST l EQUIPMENT Page 1 of 3 Policy 12 t
OQAM.R9A/SQPFLR - 59
r viewing Plant Ad Inictrativa Pr:cedurca which gov;rn -
equipm:nt c ntr:1 in:tructirns to verify etnicrc:nca to 1 the requirements of this Policy.
12.4.4 The Director, Quality Programs has and the Nanager, Nuclear Safety Oversight have 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.
12.5 RIOUIREMENTS I 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, i calibration standards and nondestructive test equipment ,
shall establish and implement procedures to control the calibration, 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.
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12.5.4 Procedures shall provide methods for the positive identification of all measuring and test equipment included -
undur the calibration system, documentation of its l 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 I controlled; but shall, as a minimum _be clearly labeled to indicate the date on which the current calibration expires.
l 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 traceability, _
calibrating standards should have a greater accuracy _than the standard being calibrated and possess sufficient range and stability to assure'that the standard being calibrated OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CONTROL OF MEASURING AND TEST EQUIPMENT Page 2 of 3 Policy 12 OQAM.R9A/SQPFLR - 60
is within th) required t;loranca. Calibrating st:ndards with tha cOra accur cy c3 tha etcnd0rd being calibrated .
shall be allowed if it can be 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. I 12.5.7 Measuring and Test Equipment (M&TE)'should be calibrated- l 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 '
accuracy 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 i' 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 specifieu n. ths-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 calibration, an evaluation shall be made and' documented, in accordance 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 actions 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 consistently found to be out of calibration. It shall be.
repaired or replaced. ,
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OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CONTROL OF MEASURING AND TEST l EQUIPMENT Page 3 of 3 Policy 12 OQAM.R9A/SQPFLR - 61
13.0- HANDLING. STORAGE AND SHIPPING 13.1 PURPOSE This Policy describes the Operational Quality Assurance Program i measures to control the handling, storage and 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 i preservation of safety-related items in order to assure that the I 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 organizations participating in the cleaning, handling, packaging, preservation, shipping and storage ol' safety-ralated 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 of design l
changes and plant modifications, the Manager, Plant l Modification & Construction is responsible for these j activities. The responsibility and authority for the
' control of handling, storage and shipping, including cleaning and preservation, involved witL preoperational phase testing programs, are delegated to the Unit 2 '
l 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 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.
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OQAM.R9A/SQPFLR - 62 t
13.4.3 Tho M:n g:r, Qu2lity S:rviccs is dalcgated tha !
r:cponsibility for in:p;ctirn cf tha c:ntral of h:ndling and storage at the plant site (exeloding the warehouse-related inspecties) including during preoperational and startup testing. .The Manager, Quality Systems Services is delegated the responsibility for warehouse-related inspection (including receipt inspection) of the control of handling, storage and 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.
13.4.4 The Director, Quality Programs han.and the #anager, Nuclear Safety Oversight have 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,- t including the requirements of this Policy. .
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 i
, control during handling, storage.and shipping. Classified l
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 '
.aade in accordance with a written, engineering approved procedure.
t 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 applicaole design and regulatory requirements; codes and standards; and manufacturer's recommendations as approved by the licensee engineering personnel for the provention of damage, deterioration or loss prior to installation or use.
Source quality verification or inspection operations t
necessary to verify conformance to the established criteria shall be included in procedures, and documentation of the verification activities shall be required.
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il OQAM.R9A/SQPFLR - 63
13.5.4 Pack: sing cnd prcs:rvation prrcedur:s chall przvida I c:surcnco cf cdequ:to pr tection cg2 inst c:rrcoitn, contamination, physical damage or any effect which would-
' lower the quality of the item or cause it to deteriorate during shipping, handling or storage. Special protective environments, special coverings, inert gas atmosphere, allowable moisture content, and temperature level shall be ,
j specified as required and their existence verified and documented.
l 13.5.5 Cleaning proceduresshall f rovide 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- i provide identification and necessary; instructions during.
packaging, shipment and storage.
13.5.7 Heasures for receipt inspection of items, disposition of '
received items and control of nonconforming items shall be i
' addressed in procedures which implement the' applicable requirements of Policies 7.0 and 15.0 of this Manual.
I 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 sa'fe -[
and adequate handling. These tools and equipment shall be- .
maintained, inspected and tested in accordance with written procedures at established intervals to ensure their ro11 ability 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 procedures.
Release of items for installation shall also be procedurally controlled.
v 13.5.10 Until Unit 2 has completed construction and all material l has been turned over to the licenue, administrative controls shall be established for the transfer of Bechtel-procured and controlled items to the GGNS Operational Quality Assurance Program. '
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: HANDLING, STORAGE AND SHIPPING Page 3 of 3 Policy 13 OQAM.R9A/SQPFLR - 64
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,14.0 INSPECTION. TEST AND OPERATING STATUS i
14.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures to identify and control the inspection, test and operating status of safety-related structures, systems and components for the Grand Gulf Nuclear Station.
14.2 SCOPE t 1
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 i to prevent the inadvertent operation of items which are in.a controlled status.
I 14.3 APPLICABILITY i
The requirements of this Policy apply.to all individuals or I organizations performing functions on, safety-related. structures, systems and components during the operational phase of nuclear power ;
plant activities. '
I 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 controlling the test and operating status of safety-related items involved in preoperational phase t testing programs are delegated to the Unit 2 Construction Superintendent. The 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 I
the applicable requirements of this-Policy.
14.4.2 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 suppliersgas applicable. -They are also responsible for verifying, through surveillance or audits, that the requirements are being adequately implemented.
14.4.3 The Manager, Quality Services is responsible for reviewing Plant Administrative Procedures to verify conformance to l the applicable requirements of this Policy. l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: INSPECTION, TEST AND OPERATING STATUS Page 1 of 3 Policy 14 l
l OQAM.R9A/SQPFLR - 65
14.4.4 The Directcr, Quality Prrgrczs h:3 cnd tha #2 cgsr, Nucicar S:fcty Orcrsight h:v3 th2 rCCponsibility 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. l 14.5 REOUIREMENTS
- 14.5.1 Procedures shall be established and implemented by the.
organizations responsible for the fabrication, storage, installation, test, and operation of: safety-related structures, 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. j inspection and test records.
14.5.3 The procedures shall identify the status indicator to_be ysed 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 Programs. Where necessary to preclude inadvertent bypassing of required inspections and tests, the procedures shall provide for the identification of items I
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 -i inoperable) to fulfill their~ intended safety functions.
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' controlled statas. Independent verification shall be required, where appropriate, to ensure that necessary measures, such as tagging equipment, have been implemented correctly.
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i 14.5.7 Temporary. codificatfrns ch311 b) c:ntrolled by cpproved i prrcedurcs which includa o requircment frr ind:p:nd:nt 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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15.0 NONCONFORMING MATERIALS. PARTS OR COMPONERIS; (Including ltt:3, S rvicts cnd Activitico) 15.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures to identify and control safety-related items, services or ,
activities for the Grand Gulf Nuclear Station which do not conform to established requirements.
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 AEELICABILITY The requirements of this Policy apply to all individuals or '
organizations 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,.
control and disposition of nonconforming items, services and activities during the operational phase are delegated -
to the Director, Nuclear Plant Engineering (for engineering);
the Manager, Plant Modification & Construction (for implementation of design changes and plant modifications); i the Unit 2 Construction Superintendent (for preoperational phase testing); the Manager, Nuclear Fuels (for nuclear 4 fuel or core items); the GGNS General Manager; the '
Director, Quality Programs;'the Manager, Nuclear Safety ,
Oversight; and the manager-of the' organization performing 1 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 nonconformances in accordance with the procedures applicable tc 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 responsibility for assuring implementation of the identification and ,
control of nonconforming items, services and activities by OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 1 of 4 Policy 15 OQAM.R9A/SQPFLR - 68 i
revitw or rcc:1pt inspectio:s cctivitts during pl nt cito ,
op;r:,tions ph:s3 activitics, including prz perational cnd !
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 identification and control of nonconforming items, services and activities by audit er 9 receipt inspection of plant site operations phase activities, including preoperational and startup testing ,;
to verify conformance to the applicable requirements of ;
this Policy.
The Manager, Quality Services'is delegated the ,
responsibility for control, processing, tracking, !
dr.sposition, concurrence verification and closure'of ronconformance documents for Plant site operations phase octivities, including praoperational and startup testing to verify conformance to the applicable requirements of this Policy.
15.4.4- The Director, Quality Programs has and the #4 nager, Nuclear Safety Oversight have the responsibility for 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. He They is are also responsible for the periodic review and analysis <
of NRC and licensee quality deficiency documents to detect
- possible adverse quality trends. -
.s 15.5 REOUIREMENTS 15.5.1 Procedures shall be established by the responsible ,
organizations to identify and control nonconforming safety-rnlated 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: I 15.5.2.1 specify the individuals or organizations I responsible for the disposition and approval of- "
nonconforming items, services or activities, 6 (including an independent review and acceptance by the appropriate quality organization),
t' 15.5.2.2 provide for documentation to identify the item, service or activity; describe the nonconformance; document the disposition and inspection l 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 tho'preoperational test program on the item.
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15.5.3 M :surcs!chall be catablich:d to precedurally control furth:r prrcoccing, d31ivery cr inttc11ati:n cf o ,
nonconforming item or continuation of a nonconforming .
service or activity, pending_a decision on its disposition.
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 tagging shall be ,
acceptable. Where marking or tagging is not feasible, i 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 procedures. Items may be dispositioned in the following ways:
15.5.5.1 Accept-as-is; 15.5.5.2 Scrap; 1 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 Le_ withheld pending receipt of. required documentation or the items'will 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 l
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," c 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.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 3 of 4 Policy 15 OQAM.R9A/SQPFLR - 70
15.5.8' N:nctnfert:nca r ports with "ccc pt-ca-is" er "rspair"
' di po2f tions cub;1tted by c ntrccters cr .cupplicra ch311 ba .
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.
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i 16.0 CORRECTIVE ACTION-16.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures to provide for the correction of conditions adverse to the quality or safety of the Grand Gulf Nuclear Station.
I 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- j 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 16.4 RESPONSIBILITY 16.4.1 Responsibility and authority for the development and.
control of measures to assure corrective action during the- .i operational phase are delegatrd to the GGNS General i Manager; Director, Nuclear Plant Engineering; Director. -
Nuclear Support; Director Nuclear Licensing; #anager, Nuclear Safety Oversight; and the Director,: Quality i Programs. They are responsible for assuring that procedurea 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 l
l' responsible for assuring that corrective action t 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
I appropriate procedures, measures for identifying and reporting conditions which may warrant corrective action.
, Responsibility for determining and implementing necessary 1
l corrective action is delegated to the organization performing or controlling the activity. During the operational 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 of design changes and plant modifications, l the Manager, Plant Modification & Construction is responsible for this activity. The responsibility for the determination and implementation of corrective action OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CORRECTIVE ACTION Page 1 of 3 Policy 16 OQAM.R9A/SQPFLR - 72
c:ccciated with preoperctional phnso tseting progra a la d21cgated to tha Unit 2'C1:nstructisn Sup;rintend:nt. ~'
l 16.4.3 This section deleted in Revision 4.
b 16.4.4 Organizations supplying material, equipment or services are l responsible for complying with the requirements of this Policy as specified in the appropriate procurement
( documents, and for imposing them on their contractors and L suppliers as applicable. They are also responsible for l verifying, through surveillance or audits, that the l requirements are being adequately implemented, i
16.4.5 The Director, Quality Programs has and the.#anager, i L Nuclear Safety Oversight have the responsibility for carrying out an audit program, as described in Policy 18.0 ,
j of this Manual; to verify conformance with Operational y Quality Assurance Program requirements, including the .i requirements of this Policy; for-the periodic review and. s (
analysis of NRC and licensee quality deficiency documents; '
te detect possible adverse quality trends; for reporting' ,
sut.) items, if any, to'the Vice President, Nuclear ,
Engineering & Support; the Vice President, Nuclear Operations; the Senior Vice President, Planning &
Assurance; and the Vice President, Operations Support for further action.
16.5 RE0VIREMENTS 16.5.1 Pro::edures shall be established and implemented by the t responsible organizations, consistent with the scope of their activities, to provide measures for the identification, *
- j. documentation, reporting and correction of conditions ;
adverse to quality or safety.
16.5.2 The procedures shall provida for the evaluation-of >
conditions such as nonconformances, failures, malfunctionsi 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.
16.5.3 The procedures shall require that action be promptly initiated and adequately documented by the responsible organization 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 quality or safety and request corrective action, and the appropriate distribution and control thereof, shall be specified in the procedures.
l 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.
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16.5.6 For significant conditirns cdv:rsa to quality er safcty, tha c u3o cf tha'conditirns, cnd tha corr:ctivo cctirn taken which is designed to prevent recurrence of the event shall be documented and-reported to appropriate levels af management for review. .
I6.5.7 Nonconforming' materials, parts and components (including items, services and activities) shall be identified, controlled and dispositioned in accordance with procedures
-which implement the requirements of Policy-15.0 of this Manual.
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- 17. 0:~ OUALITY ASS"RANCE RECORDS-1 17,1_ PURPOSE This Policy describes the' Operational-Quality Assurance Program measures for- the collection, storage,:and maintenance of quality ;
assurance records' for the Grand Gulf Nuclear Station .
'17.2 SCOPE ~i i
This Policy delineates responsibilities and defines requirements for. i the development of a records; management system to provide for the collection, storage, and maintenance of; quality assurance records.
Qua11ty' assurance' records include those records which furnish ,
documentary ' evidence of _ the quality of: items and of activities -
affecting quality.
- 17.3 APPLICABILITY l
The requirements of1 this' Policy apply to all individuals or ;
organizations participating'in the collection, storage or' maintenance l
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 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- a that records are collected,1atored and maintained in accordance with procedures which address the-requirements of this Policy.- Responsibility- for the development of, the g 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 Manager'is responsible for the collection, storage and maintenance,of records generated onsite and required to be maintained at the site including GGNS records generated by the Plant Modification and Construction-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 Hodification andJConstruction -
Section-Procedures. developed to meet the requirements of ;
this Policy.
17.4'.3 The Manager, Quality Services and the Manager, Quality.
e Systems are delegated the responsibility for assuring implementation of the collection, storage, and maintena.
of those quality assurance records onsite which are under 1 OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a i TITLE: QUALITY ASSURANCE RECORDS !
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4 OQAM.R9A/SQPFLR - 75
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tha centrol of tha GGNS.Gtnsral'Munigsr.' Tha M:nagsr,v l Qu211ty S3rvicts is ra:ponsibloLfor rsviewing' Plant' Administrative procedures and work' documents for,and l performing: inspections:to the extent necessary;to verify l c
conformance.to'the'requirementsJof.this Policy.
I17.4.4- The GGNS General Manager is responsible'for the- '
collection,' storage.and. maintenance.of' records generated ,
by the Nuclear Support Staff, Nuci ar Licensing Staff,- }
Nuclear Plant Engineering Staff, Supplier Quality l' Assurance Staff and those records transmitted to the GGNS General. Manager.-'This includes qualityLassurance records. !
-generated by Quality Programs. Records:to be maintained
'by.-the GGNS General Manager shall be identified!in~the 'I appropriate Nuclear Support, Nuclear Licensing, and:
- Nuclear Plant Engineering Administrative Procedures and J Supplier; Quality Assurance Procedures; developed'to meet-the requirements or this~ Policy.- ,
17.4.5 The Director, Quality Programs is responsible for-the. 1 collection and storage of quality assurance records generated by Quality Programs,until such time.as they are. .
transmitted to the-GGNS General Manager. . SuchLrecords- J sha11Lbe identified in the appropriate Quality Assurance Procedures developed to meet;the requirements of this. -
Policy. !
17.4.6 Otherlor'ganizations whose scope of activ'ities require ~the '
generation, collection, storage or maintenance of. quality- o assurance records.shall establish procedures to assure compliance with the applicable requirements of 'this Policy.
Contractors and suppliers are responsible for complying 1 with the requirements of this Policy to the extent.specified- '
in the appropriate procurement = documents,Jand~for imposing. l 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 D? rector, Quality Programs has and,the #anager, Nuclea Safety Oversight have'the responsibility,for carrying out an audit program, as described in Policy 18.0 of thia Manual, to ve:1fy conformance-with Operational Qualit,CAssurance Program requirements, including the requirecants of thia Policy. .;
17.5 REQUIREMENTS 17.5.1 A system for the collection, storage'and maintenance of quality assurance records--including provisions for identification, classification, indexing, retention, preservation, safekeeping, retrievability and disposition--shall be established.
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17.5.2: Tha rec rda 'syst:a chall dsfina r; quire:cnts and '
raaponsibilitics for r: cords.trrn2;ittalo, ratcntien,_cnd:
maintenance, subsequent to.the completion of a work l activity, consistent with applicable codes, standards and-
. procurement documents. Measures to assure that the -i 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 i
periods.of sufficient: duration to assure the ability..to~ '
reconstruct significant events and satisfy regulatory oro '
statutory requirements shall be'specified. Inspectiontand ,
-test records shall contain the following where applicable. 1 17.5.3.1 A description of the type of observation; ?
17.5.3'.2 Evidence of completing and verifying aL manufacturing, inspection, or test operation;- c 17.5.3.3 The date andl results' of the inspection or_= test;-
17.5.3.4 Information related'to conditions: adverse to
- quality; 17.5.3.5 Inspector or data recorder Identification;-
17.5.3.6 Evidenceass 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 I
' extent practical; or as a satisfactory alternative, duplicate record shall be stored in a separate remote '
. location. '
17.5.5 Records and documentation requirements are-specified in thel other Policies of this Manual. . Quality assurance records :!
In-lude, but are not limited- to: -design records, such as '
specifications and drawings; procurement documents;-
operating logs and procedures; principal maintenance and modification documents; results of reviews, inspections, tests, audits, material analyses; monitoring;of work performance; personnel, procedures, and equipment qualification records; quality deficiency documents; corrective action documents; and 10CFR evaluations (i.e.,
10CFR50.59, 10CFR21).
.t 1
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: QUALITY ASSURANCE RECORDS Page 3 of 3 Policy 17 OQAM.R9A/SQPFLR - 77 r
18.0 AUDITS !
h 1
l 18.1 PURPOSE
~
This Policy describes the 0perationall Quality Assurance Programu
[ measures to provide a comprehensive audit program for the Grand Gulf-L Nuclear Station.
18.2 SCOPE This Pol' icy delineates. responsibilities and' defines requirements for- 1 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 l: audits ~ performed by or for_the licensee _during the operational phase ,
of nuclear power plant activities.
18.4 RESPONSIBILITY 18.4.1 Responsibility'and authority for'the licensee's audit-
. program are delegated to the Director, Quality Programs" and the Manager, Nuclear Safety Oversight. He is They are responsible for.the development and, implementation of a program of planned and documented -
audits to verif 11ance with all aspects of the Operational Qt surance Program:and=to assess its effectivenesc. ' hey are responsible for assuring' thac procedurus .veloped, in accordance with the requirements of t' ; colicy, to provi6e-for_both internal 1
'and external audits. He The Director Quality Programs is responsible for performance of audits to verify plant-conformance to the Technical Specifications; audits-of-operational phase activities (including activities of the-Startup Organization); and audits of contractors and L suppliers performing onsite and effsite activities. The Manager, Nuclear Safety Oversight is responsible for the ,
1- performance of audits of; contractors and suppliers performing offsite activities. He They shall also assure ;
that audit results are documented and reported'to appropriate' management, and that prompt corrective action is taken to eliminate conditions adverse to quality detected during the course Lof audits.
~
i 18.4.2 This section deleted in Revision 3.
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a 18.4.3 'Orgtniz2tiens cupplying c tsrlal~, cquip Int oricarvics01 il tra rsipon21 bis'for auditing th2ir int 2rn21 cparations and their contractors.and suppliers,Las stipulated.in the-appropriate procurement documents, in order to verify -
compliance with the quality assurance ~ program requirements specified in'the procurement' documents. ,
1 18.4.4- The section deleted in Revision 5..
18.5 REQUIREMENTS = i 18.5.1 A comprehensive' program of p1a'nned'and documented audits-
.shall be established and implemented by Quality Programs. ,
and Supplier Quality Assurance-to verify' compliance with
.I all aspects of the Operational Quality Assurance Program. 1 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 ~ -
externalfaudits. Internal audits shall; include audits of ' - t the procedures and performance of all' licensee organizations'whose activities affect the quality:of, '-
safety-related structures, systems and-components.
External audits sha11' include. audits of theJpractices, procedures.and instructions of contractors and suppliers- i who provide safety-related material,: equipment'or ;
-services. t 1
18.5.3 . Audits shall provJde an objective evaluation of quality-related practices, procedures, instructions, activities, and items; and review of documents and records. .
v 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.
+
1 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 i auditors shall lui 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 to1 be audited =. '
i L
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. ,
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: AUDITS Page 2'of 3 Policy 18 0QAM.R9A/SQPFLR - 79
18.5.6.2 " Audits chall ba acheduled on-tha basis oft tha
' statua cnd icport:ncr of tha e,ctivities to bat .;
audited. ;
l, .s '
1 18.5.6.3 Those specified in the' Technical-Specifications.
for the applicable nuclear generating station'.- 1 i
- .18.5.7 -Individua17 audits shall be performed,in accordance with-l documented plans.and checklists which describe the audit .l l .and provide for'an objective' evaluation of.the status'and' l' -. adequacy of'the. areas-being audited. ')
The " objective' evaluation" referenced is'not to be confused j with the evaluation statement in ANSI N45.2.12 to which !
the~ licensee has'provided'a clarification.- See Appendix ;
A. i 18.5.8 Audit results, including-conditions a'dverse to quality detected during the audit, shall be documented and reviewed with the supervisor or manager having.
responsib City:In'.the areas audited.- Distribution of i audit. reports shall include; management of the audited i organization and appropriate licensee management.- <
t 18.5.9- Management of the audited organizations shall be responsib1'e 3 for- correcting' conditions adverse to= quality identifled-
~during an audit.- They shall assure that. corrective action is scheduled, accomplished as scheduled,'and documented.
The ccirective 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 quality trends and-to evaluate theieffectiveness of the Operationni ,'
Quality Assurance' Program. .Results .of such . analyses which indicate adverse quality trendsLshall be reported to ,
appropriate management for review,and assessment. 't 18.5.12 Records shall be generated and retained for all audits, ;
including individual audit plans, audit. reports, written !
replies, and records ofl corrective action. (See also 1F Appendix A, Regulatory-Guide 1.144,; Item 13.) j 18.5.13 The licensee 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 SRC'shall review the results of audits
~
the following: ~
of nuclear activities conducted in accordance with the GGNS Operational Quality Assurance Program. 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. 9a TITLE: AUDITS Page 3 of 3 Policy 18 j 0QAM.R9A/SQPFLR - 80
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APPENDIX A, Conformance of GGNS Onarational Quality Assuranca Pronram to NRC Ranulatorv Guidas and ANSI Standards
- l. In each of the ANSI standards, other documents . (i.e. , other standards, codes, i
' . regulations, tables, oriappendices) required to be included as.a'part of the standard are either identified at the point'of reference or are describedLin a special section-of theLatandard. 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; I such documents are'not considered as Quality Assurance Program requirements, i.
j; although they may be used as guidance.- ~
NRC Ranulatorv 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,w'ithithose requiremen.ts 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 Quality Programs-(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: t
- a. 4 years of formal schooling in science or engineering,
- b. 4 years 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
- d. any combination of the above totaling'4 years.
l- 2) With regard to Section. 4.4.5 of ANSI /ANS 3.1 (Draft 12/79) titled Ouality Assurance: The licensee will comply with Paragraph 4.4.5 as ,
ll originally stated in ANSI /ANS-3.1 - 1978 which reads asifollows:
At the time of initial core loading or: 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 h
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. '
The applicability of this Guide / Standard to other personnel in the licensee's organization is addressed in other Sections of the FSAR and the Technical
' Specifications of the individual nuclear facility. ;
Rev. 9a 1 of 33 ;
0QAM.R9A/SQPFLR - 81
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{ APPENDIX A:
~
NFC Renulatory Guide 1.26--f" Quality Group Classification, and Standards'for [
Water, Steam, and Radioactive Waste Containing. Components of Nuclear Power ' -j Plants:(Rev. 3, 2/76) ;
L The Operational Quality' Assurance Program" complies uith the requirements of this Guide with the following clarification: !
The licensee mayl choose not'to use'the specific A, B, C and D level.
classification system set forth in-this Guide.' The licensee 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 '
licensee."Q" List will-describe the-items to which the OperationalIQuality
. Assurance' Program will' apply in lieu of the= guidance contained-in this.
Regulatory Guide.
NRC Renulatorv Guide 1.28 --[' Quality' Assurance Program Requirements (Design and' s l- Construction)" (6/72) - Endorses 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.Regulatorv Guide l.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 endsrses-
- - als not considered necessary and are not included. as part of the Program'.
[
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.................................................................................. c NRC Renulatory Guide 1.29 s- " 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, The licensee shall either control-these activities under this Operational QA Program or.under an NRC accepted Construction QA' Program 4 (per OQAM 3.5.18)'. When-this Operational QA Program is used, the licensee shall comply with the Renulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to.those maintenance and modification activities even.though such requirements may not have beencin 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 Renulatory Guide 1.30 " Quality Assurance Requirements forlthe Installation, Inspection, and. Testing of Instrumentation and Electric !
Equipment" (8/72) - Endorses ANSI N45.2'.4 - 1972. 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 are comparable in nature and extent to similar activities conducted Rev. 9a [
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' APPENDIX'A! I during thi construction pha3o,. tha liceness -ch311 sithsr controll l
.these activities under this Operational _QA Program or'under an NRC l accepted Construction QA' Program(Per 0QAM 3.5.18)._ When this -[
Operational QA Program is used,Lthe licenses shall comply with the- i Ranulatorv Position established in this~ Regulatory Guide in'that'QAE <
prohrammatic/ administrative requirements-included therein (subject' '
to the clarifications in item 2-below)_shall apply to-these. I maintenance and modification activities even though:such requirements may not haveLbeen 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)., i 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' ;
ANSI N45.2.10 will:be used; all-definitions' which are included'in ANSI-N45.2.10 will be used'as clarified'in'the licensee commitment- J to Regulatory Guide l.74. !
Section 2.1 'Plannine' requirements, when necessary, will be incorporated into maintenence and modification procedures'. ,
Section 2.3~ - Procedares and Instructions will be implemented as set '
forth in Policies 2, 3, 5, ;10', and '11_ of. the' Operational QA Program [
j and by compliance with the individual nuclear facility Technical q Specifications and ANSI N18.7 as set forth:in Appendix A to that..
(- Program in lieu of the requirements set forth here.
3 1
Section 2.4 - Results will be implemented as set forthLin: 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 l requirements set forth here.
[
Section 2.5.2 - Calibration and Control. The third sentence of.this l section states in part, "... equipment shall be suitably marked to indicate date of next required calibration." . The license'e 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_ j follows: (1) is required only for modifications;- (2) will be '
implemented 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 wi11 not be reviewed and approved, per se, by the licensee; (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 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.
Rev. 9a 3 of 33 0QAM.R9A/SQPFLR - 83
, 1 APPENDIX A-t S2cticn 4 - Installation will bs icpleatnttd by. Inclusion,.as.
necessary, In the appropri.i/e. maintenance or modification procedure,- ,
where such procedures'are used. Standard licensee maintenance l practices require that care'heiexercised-in the six areas listed whether~a procedure is required or not.
Section 5 1 - Inaneetions, ln'cluding subsectionsL5.1'.1, 5.1.2, and
. M the first sentence in 5.1.3, will be implemented:as set forth in
~
Po11cy.10 of the Operational QA Program. - The-inspection program will -
incorporate, as applicable,1 those items.. listed:in these subsections.- ,
The remaining sentence in 5.1.3-is covered in equivalent' detail:in> .
.the licensen's commitment to ANSI N18.7,:Section 5.2.6; the requirements as set forth in that= commitment' will'be implemented in' n11eu;of the requirements stated.here. .
-Section 5.2 - Tests, including subsections 5.2.1 through 5.2.3,:will-be cimplemented as set forth 'in Policies 3. and - 11 oflthe 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.surve~111ance: .
testing in lieu of a special post installation. test. '
Section 6 - Post-Construction Verification is not generally' t considered' applicable at operating facilities because of the scope of
, ~i the work and the relatively short -interval: between installation and l
! operation.- Where considered applicable,~as'in modifications,-the j l: elements described in this Section will be considered in the -
.t 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'Eauinment- -
Tests: The'last paragraph of this Section deals with-tagging and: ;
labeling. The licensee 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 tho'. calibration'and;1dentity of person th, t performed the calibration, can bc readily ' determined.
Such infor,ation 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 (fter-adding the clarifying phrase "where.used" at the i beginning of that paragraph. ,
Section 8 - Records will be implemented by conformance with Policy 17 lI of the Operational QA Prc; ram and ANSI N45.2.9 as set forth in- ?
i Appendix A to that Program.
4 i
Rev. 9a
<i 4 of 33 OQAM.R9A/SQPFLR - 84 ;
u
- APPENDIX A
~
NRC Ranulatorv Guide 1.33 - " Quality' Assurance Program Requirements (Operation)" (Rev. 2, 2/78) - Endorses! ANSI N18.7 '1976. . (
i The Operational Quality Assurance Program' complies with:the1 requirements ofn 4 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 Sp'ecifications which define i
" Subjects Requiring-Independent Review. >
- 2) Paragraph C.4.a -of Regulatory Guide 1.33 (and Section 4.5: of ANSI f N18.7 which it references) will be implemented as required.by the . ]
applicable nuclear facility Technical Specifications which define the j
" 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.5.a of Regulatory Guide 1.33 (and Section 4.4 of; ANSI !
N18.7 which it references) will-be impletented with the clarification that. the Plant Safety Review Committee shall perform this activity.'
x
- 4) Paragraph C.5.d'of Regulatory Guide 1.33 (and SectionLS.2.7-.1-of ANSI' i N18.7 which it references) will be implemented by adding the i 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 the licensee's options-on repair or replacement parts; 'It is not 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 a conducted and documented. ,
- 5) Paragraph C.5.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 mado .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 h
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 -l' ANSI N18.7 which it references) willibe implemented with the addition) of the modifier normally" af ter each of the verbs (should) which the '
Regulatory Guide converts to "shall." It is the' licensee's -intent ' to fully comply with the requirements of this paragraph, and any conditions which do not fully comply will be documented and approved J 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. 9a i 5 of 33 0QAM.R9A/SQPFLR - 85
o ;
. APPENDIX AU ,
8)- With ragtrd_to Stction 3.4.2 of ANSI N18.7 ,1976 - titled Requirements 3 for the Onnite Ooeratine Greanization: -Training, standards referenced- '
.in:this Section will'be implemented if such-standards are included in Appendix A to the. Operational QA. Program;oriin< Technical .
.Specif1 cations or are otherwise partLof.the'llcense:of the individual' ,
nuclear facility.c ' The licensee's method of documenting and. .i
.otherwise meeting'the remainder of the requirements of this Section are set forth'in Policies 1 and12 of the Operational-QA Program-and- '
l- in the Technical' Specifications of the individual nuclear facility.-- !
9)- With regard to Seci; ion'4.1 of ANSI N18.7
- 1976 - titled General: The licensee. audit program will be implemented in:accordance with and to L - meet the requirements of: LANSI N45.2.12 as endorsed:in Appendix'A; l- -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-Pronram:
Descriotion:- 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 individua1Lnuclear: q' facility and_ by Policies 1- and 2 of the . Operational QA Program. : The licensee audit program will be ' described in accordance with and to .
meet the requirements of ANSI'N45.2.12 'as; endorsed in. Appendix A of i the Operational 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'Indeoendent Review Process: The' requirements of.this;Section, including all of its subparts, shall be met-by; compliance with the-_ Technical Specifications' requirenehts of the Iridividual nuclear ' facility.
1 #
- l. 12) With regard-to Section'4.5 of ANSI N18'.7 - 1976 titled Audit Prontam*
The licensen audit program will be : Implemented in'accordance with '
l-l and to meet the requirements of: ANSI N45.2.12 as' endorsed in l Appendix A; Policies 2,16,'17 and 18 'of the Operational QA Program; i and the requirements of the individual nuclear facility. Technical Specifications.
.i
- 13) With regard to Section 5.1 of ANSI N18.7 - 1976 titled;Pronram :(
Descriotion: The fourth sentence-in this Section required a " summary document";Lthe licensee has submitted Appendix C to the Operational _,
QA Program and interprets this Appendix to fulfill the requirements- k 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 Technical Specifications shall be used in lieu of the general requirements in this Section to control temporary changes. For temporary changes which occur under this Program during preoperational and startup testing prior to issuance of an OL,-
.the licensee will comply with this Section with the clarification >
that another Rev. 9a p 6 of 33 0QAM.R9A/SQPFLR . --
t ,
APPENDI' X A Tsst Suparviccr or Shift Sup;rvicer.or othsr en bsr cf ths Plant- ~
y l Staff (limitedsto Shift Superintendent, responsible Se'ction- t l
Supervisor, Manager . Plant ' Operations, or GGNS General: Manager) ,;
- knowledgeable.in
- the areas affected by the change, may approve l c
i changes which require the signe'r to hold an SRO license. ,
i- When>there fs a requirement to " implement"'or " address" a procedure,.
d actions prescribed by procedures shall be accomplished. This'does. j not necessarily' imply that in all. cases _the operator, engineer, or technician has a copy.of the procedure in-hand and signs-off a' -(
checklist as'each step or funct' ion is performed.
i 15). With~ regard;to Section 5.2.6;of ANSI N18.7E- . 1976' titled Eauioment.
control: The licensee will comply with the " independent
- verification" requirements based'on the definition of this' phrase as._- s givenlunder 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,Lthey shall" advise:
Operations-of currerit radiological-conditions. . Operations will then decide whether or not the confidence gained from the independente verification'is-worth the additional radiation exposure. In ally cases, radiation doses will be As. Low As Reasonably. Achievable (ALARA). ;
Since the licensee 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."
l The first sentence in the. seventh paragraph will be complied with after clarifying " operating personnel" to.mean trained employees assigned to, or under the control of, licensee > management at an j operating 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, the licensee will :j 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 ,
or modification of equipment'shall be preplannedt 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 af ter-the-fact and receive the same degree of ,
review as:if they had been preplanned." '
L For those system run-in activities that take place prior to-issuance !
of. an Operating License, the Startup Engineer may direct work by the licensee. 4 Rev. 9a 7 of 33 OQAM.R9A/SQPFLR - 87
' APPENDIX A Oparcticns or ~Maintcntncs personnsl: to :rcstort thCsyste:n- to dssign i drawing requirements,'provided the work and'actionsLare properly- '
= documentedf and. that qualityj and, engineering evaluations are .
obtained. These evaluations may be obtained after-the-fact. ;
- 17) With regard to Section 5.2.7.1 of ANSI N18,71- 1976 titled-
~
~
i Maintanance'Pronrams:- ThellicenseeLwilll comply with'the requirements of the first sentence 'of t the fif th paragraph,' where y practical = This clarification is needed since :lt is.not Lalways '
possible to'promptly determine;the cause of the malfunction..~ In all cases,~the licensee will. 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 .
Testine and Inspection Schedule: In ~ 11eti 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."- t
- 19) With regard - to 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.
j o
- 20) With regard!to Section 5.2.10:of ANSI N18.7:--1976' titled = 5 Housekeenine and Cleanliness-Control: The requirements of this .
Section, beginning with the last sentence ~of the first paragraph and' l'
continuing through the end of the Section,1w111, beiimplemented as - "
described in-the licensee's commitments-to ANSI N45.2.3 and N45.2.1~
l as set forth:In Appendix A to the Operational QA Program.
l 21) With regard to Section 5.2.13.1 of ANSI N18.7 - 1976 titled 1 Procurement Document Control: The words "the same" in the last l sentence are replaced with the wordsf"an equivalent"..
- 22) With regard - to Section 5.2.15 of ' ANSI N18.7. '1976 titled Review, i Anoroval and Control of Procedures: The third sentence in Paragraph three is interpreted to mean: Applicable procedures shall be reviewed following an- accident, an unexpected transient, significant operator error, or . equipment malfunction which results in a
-reportable occurrence. The first's'entence in' Paragraph four is interpreted to mean: This requirement for routine followup review can be accomplished in several ways,.includinge(but not.necessarily t
limited to): documented step-by-step use of tha procedure (such as occurs when the procedure has a step-by-step checkoff associated with it), or detailed scrutiny ,of the procedure as part of a-documented training program,- drill', simulator exercise,- or other such activity. Routinely used or. Administrative type procedures i
will be 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. A revision of a procedure constitutes a procedure review.
- 23) With regard to Section 5.2.17 of ANSI N18.7 - 1976 titled Insoections: Not all inspections will require generation of a [
separate inspection report. . Inspection requirements may be Rev. 9a 8 of 33 0QAM.R9A/SQPFLR - 88 i
-o,
=
, _ ~ APPENDIX:A integrated into cppropristo procedurts or othar docu nnta'with ths
. procedure or: document serving as.the record. l However ; records'of' inspections will be identifiable and retrievable. ~ '
[ -24)- With regsrd to Section 5.3.9 of ANSI N18.7.- 1976 titled Emergency
' Procedures: - As directed by' the NRC,'the licensee w111 follow a 1
{. format for emergency procedures which is '_' symptom" based as ' opposed'- t I! to " event" basedTas stipulated intSection.5.3.9.1. Since the 'I licensee will have these "symptor/' based proceduras; " event" based ' '
~
L o
procedures will not normally be provided, f
- 25) With regard. to Section 5.3.9.2 of ANSI N18.7 - 1976 t'itledl Events of.
- Potential Emernency: NRC' review'of'the FSAR has identified all- l natural occurrences which affect'the nuclear facility..LTherefore,. i the licensee will interpret item (11);-to mean the natural-occurrences which have been evaluated in the FSAR fori the'individualu !
nuclear-facility.
26).'With regard to Section:5.3.9.3 of ANSI.N18.7-- 1976 titled ^
i
" Procedures for Imolementini Emernancy Plan: The licensee's NRC~ '
accepted Emergency Plan forjeach nuclear facility wJ1l be ;
implemented in lieu of the' requirements in this Section.- -
27)' With Regard to Section 5.2.18 of ANSI N18.7 --1976 titled Control of
~
Soecial Processes: The last.four words:of the first sentence are:
clarified by inserting the word " approved"'before the word'. a
" procedure": _ We shall uae qualified personnel andJapproved:
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-p interpreted to= require ' the same degree .of. Inspection for. all ~!
maintenance 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 _extentito that provided during construction a if the maintenance / modification-work is comparable in nature and !
extent. I
- 29) With regard to Section 5-3.5(4) of~ ANSI N18.7 - 1976 titled-Suonortine Maintenance Documents: The licensee may choose to -i
{
includo 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-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
.l as modified by the author / reviewers of the procedure,.- may be written into and become a Part of the procedure.c
(
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 procedtire review process. In option-(2), the requirements.shall be deemed to Rev. 9a l
9 of 33 0QAM.R9A/SQPFLR - 89
\
APPENDIX A d
havs bisn' fulfilled by?riquiring a copylof tha partinsnt cenunl- '
i (manual sections)'to be'available to and considered by persons conducting the review of=the procedure.
! (
- 30) With regard'to Section 5.2.16 of ANSI N18.7l- 1976 titl'ed Measuring and Test Eauinment: The second sentence of)the third paragraph L states " Records sha111be made and equipment suitably ~ marked to 3 l= indicate calibration status." : The licensee will utilize'~a l computerized system to: indicate'the calibration status of installed.
l operations measuring and. test equipment in lieu of marking or
-tagging the individual item.
~
l NRC Renulatorv Guide 1.'37 " Quality Assurance Requirements; for Cleaning of
, _ Fluid Systems and' Associated Components of Water-Cooled Nuclear Power Plants" 1
- 1. (3/73) Endorses ANSI N45.2.1 - 1973. ] 1 l
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 l quality for~ final flushing of fluid = systems and associated components t,
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
.Polyethelene), water soluble; dam. materials, lubricants, NDTfpenetrant '
materials and couplants, which contact stainless steel.or nickel alloy surfaces shall not contain lead, zinc, copper,' mercury,. cadmium and other low molting point metals, their alloys.or compounds, as- )
basic and essentini chemical constituents..-Prescribed maximum levels of water leachable chlorides, total h'alogens, 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 Cleaninn: 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 theruse of other removal means is not precluded.
l 4) For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, the licensee 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' 1 Operational QA Program is used, the licenses shall comply with the ,;
Renulatorv 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 criginally. Technical requirements associated with a
Rev. 9a 10 of 33 OQAM.R9A/SQPFLR - 90
APPENDIX A
- tha c:Intenanca or codification (shall b: the original requirca nts or better (e.g. , code' requirements, material properties, t design margins, manufacturing processes .and inspection requirements).-
5)' With regard to Section 1.4 cf ANSI N45.2.1 1973 titled Definitions:
Definitions in this Standard which are not included in ANSI N45.2'.10- i shall be used; all definitions which are included in ANSI N45.2.10 i shall be used as clarified in the' licensee's commitment to Regulatory Guide 1.74.
- 6) With regard to Section.9 of ANSI N45.2.1'- 1973 titled Records: The licensee'shall maintain-records in accordance with and to meet the requirements lof 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 isjused.forl operations, [i qualified supervisory maintenance personnel determine what 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,; the licensee does not intend to clean a component until it has a bright " metal clean" surface,:nor do wer a
(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 sam'e: cleanliness as the system from which they were removed. Such components needinot'be recleaned prior to reinstallation provided that measures are taken ti prevent degradation of the previously existing state of, cleanliness.<
l .. ............................................................ ...................
l NRC Renulatory Guide 1.38 " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and llandling of Items for Water-Cooled Nuclear Power Plants" (Rev. 2, 5/77) - Endorses ANSI N45.2.2'-'1972.
l 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: ,
l Definitions-in this Standard which are not included in ANSI N45.2.10 l will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in the licensee's commitment to Reguintory Guide 1.74.
l 2) With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Planning:
t (first sentence) The soecific items to be governed by the Standard-nall be identified on the Q List, flowever, the . Standard' (as modified -
sy 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.
l 3) With regard to Section 2.3 of ANSI N45.2.2 - 1972 titled Enaglis:
The specific methods for performing and documenting-tests and Rev. 9a 11 of 33 0QAM.R9A/SQPFLR - 91
k APPENDIX-A.
Inspretions:ars'givsn in Policies 10:cnd 111of tha Oparational QA1 j
' Program'.,~The requirements in these Policies will be implemented in- ;
lieu of;thefgeneral. requirements here. 3 t
- 4) With regard to Section- 2' 4 'of ANSI N45~.2.2:- 1972 titled-Personnel Oualifications: .SpecificLrequirements 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 titledi Classification ~of Items: -The' licensee may' choose not to explicitly useithe four. level classification system. However,1the specific !
requirements 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 . .
containerizin. items in storage-to1 control. contaminants'(Items (4) and-(5)),.tho licensee may choose.a storage atmosphere which<is free. !
of harmful contaminants in' concentrations'that could produce. damage to stored items. . Similarly (for: Item (7)) the licensee may obviate ,
the need for caps and' plugs withfan appropriate storage-atmosphere',-
and may choose to protect weld 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 d
referenced and to Section 3.5.'1 titled Caos and Plues and Section 3&4 titled Methods of Preservation, sl
- 7) With regard to Section 3.3 of. ANSI N45.2.2 - 1972 titled Cleanine:
(Third sentence) The licensee Interprets " documented cleaning; 1
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' individua1 ' cleaning procedure, l but the generic procedures will specify: which methods of cleaning.or
.which type (s) of solvent may be used in a particular application..
l
- 8) With regard to Section 3.4 of ANSI N45.2.2 -11972 titled Methods of 'l Preservation: (First sentence) The licensee will comply with these l requirements subject to the clarifications of SectionJ3.2.1 (4) and i (5) above, and the definition of the phrase " deleterious corrosion" l I to mean that corrosion which cannot be subsequently removed and 1 which adversely affects form, fit, or function. l
- 9) With regard to Section 3.6 of ANSI N45.2.2 - 1972 titled Barrier and-Wran Material and Dessicania: This section requires the use of I nonhalogenated materials in contact with austenitic: stainless steel.
Refer to Regulatory Guide 1.37 above for the licensee's position.
- 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 specified in 3.7.1(1). This type of box is safe for, and has been tested for, loads up to 1000'lbs. Other Rev. 9a 12 of 33 0QAM.R9A/SQPFLR - 92
F 4 APPENDIX A' ,
nztional' otIndsrdanc110w this (oss Federal Sptcification PPP-B-601)'.
'Special' qualification _ testing'may be required-for loads above71000; lbs. )
l
- 11) - With regard to LSection 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-
~
i of.500 lbs. or more. _ Skids or runners;will normally be fabricated
.from 2 X 4 inch nominal lumber; size, minimum, and:lald; flat except where this Is-impractical because of the!small dimensions'of the ,
container. If forklift.handlinglis required,. minimum floorEclearance i for forklift tiw.a'will be.provided.
- 12) _ With regard to Section 4.2.2 of ANSI N45.2.2 - 1972 titled C16 sed I
' Carriers: The useLof-fully cnclosed furniture vans, as recommended, in (2), of this.Section is not' considered a requirement.;:The:
licensee will' assure cdequate 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 -c1972 [
titled. respectively, Precautions Durina Loadine and Transit, Identification and Markine, and Shloment from Countries-Outside'the United States: 'The licensee will. comply with the requirements,of:
these Sections subject to the clarifications taken to'other! Sections- '
which are referenced therein .
i 14)' With regard to Section 5.2.1 of ANSI N45.2.2- -1972 titled Shinoina :
Damane Insoection: Warehouse ~ personnel will normally-visually scrutinize incoming shipmente for damage off the= types listed in this -
.l' Section,'this. activity is not necessarily performed prior to unloading. .Since all required'Itemstre'ceive the? Item. Inspection of Section 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 shipmentL mayLb~
e all of the action taken to document completion of theEShipping Damage' 1 Inspection. Any nonconformances-noted will be: documented and o (
dispositioned as required by Policy 15 aof _the Operational' QA' Program. i The person performing the. visual scrutiny during unloa'dingils not1 i considered to be performing an inspection function-as defined under l Regulatory Guide 1.74; therefore, while he wil11xt trained to perform 1 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 -E1972. titled 11am '
Insoection: The second division of this subsection' requires six additional inspection activities if an;1 tem was not' inspected or examined at the source. The licensee will consider that a source inspection has been conducted if the supplier.of the-item is required 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 thatJincludes, as applicable, the six additional items-listed).
- 16) With regard to Section 6.1.2 of ANSI N45.2.2 - 1972 titled Levels of Storane: Subpart (2) is replaced with the, following:
Rev. 9a
.t
'13 of 33 OQAM.R9A/SQPFLR - 93 s
(2) ~ Lsval B itera shall b2 stored within a - fira rsaistant.
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 he paved or: equal,;and well drained. It;any outside '
waters should come'in contact with stored' equipment,,such' '
equipment will be labeled or, tagged nonconforming,.and then the' t 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 buildingi ,
shall be provided with heatingEand.. temperature control.or their: ;
equivalent to reduce condensation and corrosion.. Minimum i temperature shall:bel40'F and maximum-temperature shall be 140*F- l or less if;so' stipulated by-a' manufacturer. !
17)- With regard to Section 6.2.1 of ANSI N45.2.2'-:1972 titled Access toc -
Storane Areas: Items which fall within'the Level D classification of' ;
the standard will be stored in.an area which.may be posted to. limit t access, but other- positive -controls such. as, fencing or guards will not normally be provided. ,
s
- 18) With regard to Section' 6.2.4 of ANSI N45.2.2 - .'1972 titled Storane of - j Eqod and' Associated Items: The sentence:Is replaced with the; following': "The use or. storage of food, drinks, and salt tablet dispensers in any storage areafshall 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 ,
i 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." "
i
- 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:
1 4
" Hazardous. chemicals, paints, solvents, and other materials of a like:
nature shall be stored in approved cabinets or containers which are J not in close proximity to. installed systems-required for safe 1 shutdown." .
- 21) With regard to Section 6.4.2 of ANSI N45.2.2 - 1972. titled Care of. .
Items: The following alternates are provided for indicated subpart:
(1) " Items in storage shall'have all covers, caps, plugs or other l closures intact, or shall be elevated to allow for proper' 'I drainage. Methods used to seal openings shall be in'accordance with Section 3 of this standard. Covers removed for internal access at any time for any reason shall be'immediately replaced and resealed after comp?etion of the purpose for removal."
Rev. 9a 14 of 33 ,
OQAM.R9A/SQPFLR - 94
s j I
APPENDIX A' .
(5). "Sp2ca haztsra in slactrical 4q dpunt chtlli bs snstgind unless a nocumented engineering evaluation determines that such space heaters are not: required."' i (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.'?
~
- a. (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;= l the results of the evaluation shall be documented.- If. rotation is required, it'shall be performed at.specified intervals,:be. i documented, and 'be conducted so' that partc receive, a coating of" lubrication where appli' cable and -so that the shaf t does not come 3 to rest 11n the same position occupied prior torrotation.. For, ;
long shafts or= heavy. equipment subject to undesireaule-bowing,- =t shaft-orientation aft'er rotation'shall be specified and j obta ined . " ' j
- 22) With regard to Section 6.5 of ANSI N45;2.2 - 1972- titled' Removal of '
Items from Storane: The ' licensee does not consider-the last ;
eentence of this Section to be-applicable to the Operations Phase '
due to the relatively short. period of time between installation'and-use. The first. sentence of the-Section~'is-replaced'with:- " The licensee will develop, -issue, and implement a procedure (s) which cover (s) the removal of items from storage. The procedure (s)-will~ J
, assure that the status of all ~ material issued is known,; controlled, and appropriately dispositioned."'
- 23) With regard to Section 6.6 of ANSI N45.2.2 - 1972 titled Storane 1 Records: The licensee-will comply 'with ti,a requirements of this j Section with the clarification that, for iecord purposes,-only the~ ;
access of personnel without Key CardsLinto indoor storage areas 1 shall be recorded. Unloading or pick-up.of material shall'not be o considered " access,"'nor'shall inspection _by NRC or other regulatory ,
agents, nor shall tours by non-licensee employees who are '
accompanied by licensee employees.
- 24) With regard to Section 7.3 of ANSI:N45.2.2 -'1972 titled dpistinn -
1 Eauloment: Re-rating of hoisting equipment will be Lconsidered .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 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 i
rating, and the test lift load. At all times, the codes governing re-rating of hoisting equipment must be observed.
Rev.' 9a 15 of 33 OQAM.R9A/SQPFLR - 95
+>
APPENDIX A:
'NRC-Ranulatory Guide 1.39 - "Houcekeeping 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'
~this Guide with the following clarifications:
- 1) For operations phase maintenance and.modificat' ion activities which are comparable in nature and extent to similar activities conducted during the construction phase, the licensee shall 3 either control these activities under this Operationair QAs !
Program or under an NRC' accepted. Construction QA_ Program'(Per-OQAM 3.5.18).
When this Operational QA Program -is used' the licensee shall comply;with the Renulato'rv Position established in this Regulatory Guide in that-QA programmatic / administrative requirements included therein-(SubjectJto 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 the mainte' nance or !
modification =shall be the original requirements or better (e.g., code ,
-requirements, material properties, design margins, manufacturing processes, !
and inspection requirements). j
-2) Specific clarifications for ANSI N45.2.3 --1973 are indicated for i 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 *)
i included in ANSI N45.2.10 will be used as clarified in the- '
licensee's commitment to Regulatory Guide 1.74.
Section 2.1 - Plannine: The, licensee may choose not to utilize the- :
fivelevel zone designation system, but will utilize standard j janitorial and work practices to maintain a level of- cleanliness 1 cc mensurate with Company policy' in the areas: of. housekeeping, plant '
and personnel safety, and fire protection, j Cleanliness will be maintained, consistent with the work being performed, so as to prevent the entry of foreign material into safety-related systems. Thic will include, as'a minimum,'_documentedi 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,.ands 'upplies 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 2.2 - Procedures and Instructions: Appropriate procedures will be written and implemer ted. 1 Section 3.1 - Control of Site Arna: -Not applicable to the Operations Phase.
Rev. 9a 16 of 33 0QAM.R9A/SQPFLR - 96
APPENDIX'A
[S2ctionI 3.2 - Control of Facilities: _Ths licansas ar.y chooss nm to "
utilize the' five-level zone-designation system, but will utilize:
standard janitorial and work practices to maintain a level of:
cleanliness commensurate with r .any policy in the area's of-housekeeping',: plant and persom.ai ~ safety, - and fire protection.
Cleanliness will be maintained, censistent with the' work being i performed,'so as to prevent the entry of foreignimaterial'into l
safety-related systems. This will include, as a' minimum, documented- !
cleanliness inspections which_will be, performed: prior t_o system. i closure. As necessary, (e.g'., the opening is larger than the tools; being used) control of personnel, tools, equipment, and supplies will:
t be established when major portions of the reactor-system:are opened-for inspection, maintenance or repair. j Additional housekeeping-requirements will be implemented as required' ,
for control of radioactive contamination. ' ~
1
't Section 3.3 - Materials and Eauinment: The first' paragraph in this; Section is not applicable to the Operations phase.
\
Section 3.4 - Construction Tools. Sucolies. and Eaufnannt:
Not-applicable to the Operations phase. J Section 3.5 - Surveillance.-Insnection. and Examination:
Subparagraph (1) is not applicable to the Operations 3 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 gen ral requirements in this section. .
i NRC Renulatorv 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:
l
- 1) The licensee may choose not to apply the requirements of.this Guide ;
to those personnel who are involved-in day-to-dayloperations, surveillance, maintenance and certain technical and, support _ services ,
whose qualifications are controlled by Technical: Specifications = or other Operational QA Program commitment requirements.
r
- 2) With regard to Section 1.2 of ANSI N45.2.6 - 1978 titled Aeolicability: The third paragraph requires that the Standard be j used in conjunction with ANSI N45.2; the licensee no longer-I specifically commits to ANSI N45.2 in the Operational QA Program.
The fourth paragraph requires that the Standard be imposed on i Rev. 9a 17 of 33 1 0QAM.R9A/SQPFLR - 97
,y APPENDIX A. !
.p2r;tonnsi othar.thrn lictnsss caployoss; the cpplicability of'tha.- ,
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'-'i978 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~clarifiediin the licensee's commitment to Regulatory- !
Guide-1.74.
~
q
- 4) .
With regard to Section 2.5 of ANSIiN45.2.6~ 1978 titled Physical:
-The licensee'will' implement the requ'irements of this Section with -
the stipulation that, where no.special physical characteristics'are- ,
required, none will be~specified.e'The; converse is also true:'-If no , :!
'special physical requirements are stipulated by'the. licensee, none !
- are considered necessary. 3
- 5) With regard: to Section 3.5 of ANSI. N45.2.6 .1978 titled Education and Ernerience - Recommendations: -The licensee reserves'the right:
to use personnel who do not moet.all the; educational and experience- ,
requirements of this Section provided: The:use.of personnel who do not meet these requirements shall be the: exception rather than the ;;
rule and~each such case shall receive a documented management evaluation and justification for the exception. An example of a
- documented management evaluation and justification would be one- #
which includes objective criteria (examination',-retiew of actual .
work Performed) to demonstrate that equivalent. competence is ';
possessed by such an individual.-
~
................................................................................ r NRC Renulatorv Guide 1.64 " Quality Assurance Requirements for the Design of 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: ?
o 1) For operations phase maintenance and. modification-l activities which are comparable in nature and extent to similar activities conducted ~during.the construction phase, the licensee shall either. control these activities :s under this Operational ~QA Program o'r:underian NRC accepted Construction QA Program (Per 0QAM 3.5.18). When this . ;
Operational QA Program is .used, the' 11censee shall comply - j with the Renulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included.therein (subject to the- e clarifications listed below)'shall apply to these 7 maintenance and modification activities ~ even though such l requirements may not have been:in effectLoriginally.
Technical requirements associated with maintenance and modifications shall be the original requirements or better l (e.g., code requirements, material properties, design '
margins, manufacturing processes and Inspection requirements).
- 2) With regard to 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 provisions Rev. 9a
.18 of 33
-h_cm
I APPENDIX 1A' of.tha Regulstory.Guids ars catisfied, and-(b) tha justificstion is; individually documented:and approved in advance by.the Supervisor's '
management, and (c) quality assurance audits' cover frequency and. i effectiveness of use of Supervisors'as design verifiers to guard against abus'e.
l
'3) With ; regard to Section 1.4 of' ANSI L N45.2.11)-11974 titled-
~
, Definitions: Definitions in this Standard' which are not includedin ANSI N45.2.10 will be used;:all' definitions-which are included in j
ANSI'N45.2.10 will be'used as: clarified =in the licensee's-commitment '
to Regulatory Guide l'.74.- ,
I i
- 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 Licensee's Audit Program ~will'be; i o implemented in accordance with and to meet the requirements of: . '
ANSI N45.2.12 as' endorsed in Somndix A;_ Policies 2, 3, 16 and 18 of '
the Operational QA Progrom; ai._ the: requirements of the individual l nuclear facility Technical fpecifications in-lieu of the audit-- :t requirements stated in the referenced sections.
- 5) With regard to v ion-5.2.4 of ANSI N45.2.11 - 1974 titled '
Documentation: m .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, mechanical, electrical, concrete, etc.). The l signature or initials of those who determine the acceptability of the design relative to their respective disciplinary area of Jconcern
- 7 should be on the document or on a separate. form traceable to the !
document. A document that indicates the reviewer's comments need not I be retained.
- 6) The licensee does not require the SAR to be a design document.
Ilowever, if the SAR contains any design'or design ine t that has not been previously documented, reviewed and approved ! accordance with. '
the requirements contained in the OQAM'or another ' proved design control QA program and if the SAR is used as a des an. document- -i during the design process, that specific information must be controlled and verified-in accordance with tho' commitments here and- q Policy 3 of the 0QAM.
l
- 7) With regard to Section 6.1 of ANSI N45.2.11 - 1974= titled General: '
The third paragraph in this Section stipulates certain requirements relative to "the results 'of design verification". The 11censeo may comply with these requirements by having the Reviewer (s) sign and date an appropriate dacument-providing the following conditions are also met:
a) Documented engineering / design proces stablished which cover the extent of design review.
b) The procedures identify the duties viewer and the extent of this responsibility for which he eith his signature.
Rev. 9a 19 of 33 0QAM.R9A/SQPFLR - 99 I
a
. APPENDIX Ar '
c). Tht: procedurss cpacify ths. extent of docuuntation:nsesssaryf for' i the type of design verification applicable to the1 complexity of' the design, '
i d) Thre. signature and date is. affixed.in accordance with the procedures. '
The licensee shall also permit initials to be used'in' lieu of the j signature required above IF a flie is maintained.to. correlate. il characteristic initials versus individuals such that each : set of, characteristic initials can be traced to en individual. This' correlation must be readily available to.NRC inspector whenever the' document'is being used. )
.+ i
- 8) The timing of design. verification is not; mentioned in the' Standard, j The licensee shall perform verification In a timely; manner. If- i other,than by qualifications testing of a' prototype or. lead, :(
production unit, verification should be completed prior to:releasei for procurement, manufacturing or construction or-release to another :
organization:for 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 unverified 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 changa sha11Enot proceed without .
verification past the point where the installation'would become 4 irreversible without extensive demolition and' rework. In all. cases, .;
the design. verification shall be completed prior to relying.upon-the l component, system, or structure to perform its safety-related '
function. ,
- 9) With regard to Section 10 of ANSI N45.2.11 - 1974 titled Records:
The licensee shall maintain records in-accordance with<and to meet the requirements of Policy 17.0 of the 0QAM and ANSI N45.2.9 as- a specified in Appendix A. The additional requirements of the first sentence-of the second paragraph in this Section<shall also be met.
NRC Renulatory Guide 1.74 " Quality Assurance Terms and Definitions" (2/74) - i Endorses ANSI N45.2.10 - 1973. '
The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications:
- 1) The licensee reserves the right'to 'd efine 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", the ,
licensee will use the following: - " Inspection (When used to refer to ;
activities that are NOT performed by Quality Programs' personnel) - !
Examining, viewing closely, scrutinizing, looking over or otherwise checking activities. Personnel performing these functions are not' necessarily certified to ANSI N45.2.6."
Rev. 9a 20 of 33 OQAM.R9A/SQPFLR -100
l l
[ .
. APPENDIX.A L Whrn tha:11cinssa:intdnds for In2ptctions to ba parforardLin-accordance with the Operational QA Program by' personnel certifiedLas required:by that Program and for-activities defined.by." Inspect _lon" '!
In ANSI N45.2.10,. appropriate references to Quality.D ..ams'which will perform the activity;or to Quality . Assurance: Procuures/:
Instructions to be used for performing the- activity; will, be made.
- If such references are NOT made, inspections are to' be' consideredt under the additional definition given above. !
Inspections to' meet the' intent of 10CFR50 Appendix B'are described 11n- l Policy'10 of the 0QAM..
- 3) ~In addition to the Standard's definition of " procurement' >
documents", the licensee will. utilize the definitions given in ANSI N45.2.13 and in Regulatory Guide 1.74.- The' compound definition'~is i given as follows: " Procurement documents'- Contractually binding documents that identify and define the requirements whict items or- l services must meet in' order:to be' considered acceptable by the l purchaser. They include documents which authorize-the seller to perform services or supplytequipment, material or facilities on-
, behalf of the purchaser (e.g. , contracts, letters of intent, workf i orders, purchase orders, or proposals:and their acceptance, . l drawings,' specifications, or instructions which' define requirements
~
for purchase)."
- 4) " Program Deficiencies" (Not defined in ANSI N45.2.10, but used-and: 1 defined differently in ANSI N45.2.12) - Failure to develop, documenti '
or implement effectively any, applicable element of the Operational QA -
Program.
, t
- 5) " Quality Assurance Program Requirements" (Not defined in ANSIJN45.2.10 1 but used and defined differently in ANSI N45.2.13) Those -individual: '
' requirements of the.0perational QA Program which, when invoked .in-total or in part, establish the requirements of the quality- as'surance program for the activity being controlled. Although not specifically-used in the Operational QA Program,. ANSI N45;2 may be' imposed upon
~
the licensee'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 require confirmation of the -identical action when other indications provide assurance or indication that the prescribed activity = 1s 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
, Rev. 9a J
21 of 33 ,
OQAM.R9A/SQPFLR - 101 '!
I L
l' . . .
APPENDIX A.
4 L,
and 4cccpted for ussi (2) ths rsvision of th2t NRC accspted progrca i I <
whichsis in effect'at'the time that the.11censee'~authorizesi
-commencement of work; and',--(3) a program which Quality' Programs- [
the' licensee's quality assurance organization: reviews and; concurs that.the QA Program controls are acceptable.for the. activity to be: l performed. (
Reference:
.0QAM 3.5.18)
- 4
- 9) "Special Processes" - Processes which are controlled and m'onitored.In accordance with approved-procedures where required'qualityJ1evels' cannot'be essured by inspection of the processed articles alone, or- ,
where it is more effective to control the process than inspect'the- <,
l completed, article. 1;
- 10) " Permanent Plant Device"'(when used with respect to instrumentation)' '
l L - A. device', permanently installed,1which functions.as a part of.a :
system and is used for monitoring a process variable in the' plant.-- l
- 11) " Concurrence" (when used with respect to and in association with a -
r-"lew activity) is defined'to mean: -(1) a review of a document or ..
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. g
...................................................................................- 4 NRC Renulatory Guide 1.88 " Collection, Stotage and Maintenance of Nuclear .
Power Plant Quality Assurance Records" (Rev. 2, 10/76) -Endorses ANSI N45.2.9' -
- 1974.
l t
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 Ouality Assurance Records: The phrase " completely filled out ,is clarified to mean that suf ficient- information is recorded to fulfill the intended purpose of the record. o
?!
! 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 mn not be delineated (e.g., The specific location within a computer-record file
- ' may not be constant. Further, the
- licensee may' utilize a computer l assisted random access, filing system where such location could not -t be readily " documented, nor would such a location be " relevant.") I 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.
l .) With regard to Section 4.2 of ANSI N45.2.9 - 1974 titled Timeliness:
The licensee's contractual agreement with its contractors and suppliers will constitute fulfillment of the requirements of this Section.
Rev. 9a OQAM.'R9A/SQPFLR - 102 t
i i i APPENDIX A R
- 4) Wita' reg 2rd to S:cticn 5.4 cf ANSI N45.2.9 - 1974 titled preservations The following clarification is substituted for the current subsection ,
5.4.2: " Records shall'not be stored loosely. They shall be secured j i for storage-in file cabinets or on shelving in containers." i The following clarification is substituted for the current subsection 5.4.3: " Provision shall be made for special processed records (such !
as radiographs, photographs, negaelves, microfilm and magnetic media) !
to prevent damage from excessive light, stacking, electremagnetic ,
fields, temperature and humidity as appropriate to the record type. }
- 5) With resard to Section 5.5 of ANSI N45.2.9 - 1974 titled Safekeenine:
Routine general office and nuclear site security systems and access '
controls are provided; no special security systems shall be ,
established for record storage araas, r
\
- 6) With regard to Section 5.6 of ANSI N45.2.9 - 1974 titled Facility: ;
This Section provides no distinction between temporary and permanent i facilities. To cover. temporary storage, the following clarification ;
is added: " Active (in process) records will be stored in one-hour
~
j fire rated file cabinets. In general, records shall not be maintained in temporary storage for more than three months after completion. :
Any exceptions to this requirement must be evaluated and approved by ,
the Director, Quality Programs; a list of all such excepted records !
shall 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 re, cords 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 i and NRC Criterta for Record Storane Facilities (Guidance-ANSI N45.2.9, Section 5.6) issued 7/1/80.
Paragraph 4, subsection 9 is clarified to read: "No pipes or i penetrations except those providing fire protection, lighting, t t % erature/ 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 lating."
- 7) With regard to Section 5.3 of ANSI N45.2.9 - 1974 titled Storane 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 l " custodian" may or may not be used as part of that designation..
NRC Renulatory 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 Progras complies with the requirements of this Guide with the following clarifications:
Rev.-9a t
23 of 33 OQAM.R9A/SQPFLR - 103 1
1)
APPENDIX A Fcr eperctions phaso maint n nco cnd modification cctivitics
'[ I which are comptrable.in nature and extent to similar activities !
conducted duritg the construction phase, the licensee shall l either control these activities under this Operational QA i Program or under an NRC accepted Construction QA Program (Per OQAM 3.5.18).- (hen this Operational QA Program is used, the . '
licensee shall :omply with the Remulatorv Position established in this Regulatory Guide in that QA programmatic / '
administrative 2equirements included therein shall apply to :
these maintenanca and. modification activities even though sw n requirements may not have been in effect originally. . Technical l requirements associated with maintenance and modifications j 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 1.2 of ANSI.N45.2.5 - 1974 titled Anolicability:
The first sentence in this Section' is not ' applicable to the operations-phase. The licensee 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.the OQAM applies, and the extent of coverage shall be defined by supervisory i maintenance personnel by the way.in'which they implement the other requirements of this Standard.
h of this Section, the licenses shall In the second substitute paragrap' maintenance and modification" for the word the words ,
" construction" as the modifier of " procedures". *
- 3) With regard to Section 1.3 of ANSI N45.2.5 - 1974 titled Resoonsib111tv: This Section s requirements are met by the a definitions for positions and the organizational responsibilities -
outlined in the Technical Specif1 cations, Policy 1 of the 0QAM and -
the nosition descriptions for plant personnel. ,
- 4) Wit- agard to Section 1.4 of ANSI N45.2.5 - 1973 titled Definitions:
Defn.itions 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 the licensee's commitment to ',
- 5) With regard to Section 2:1 of ANSI N45.2.5 - 1974 titled Planninn:
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 items inspected with M&TE which is found to be out of calibration shall be considered unacceptable. The licensee will comply with an alternate which m i 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 ox ANSI N45.2.5 - 1974 titled Welding:
The licensen will comply with inspection requirements of the applicable welding codes identified in the UFSAR and any exceptions
- thereto.
Rev. 9a
._m_ _
24 of 33
d i
APPEND 1X A !
NRC Ranulatorv 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, the licensee shall ,
either control these activities under this Operational QA :
Program or under an NRC accepted Construction QA Program (Per i 00AM 3.5.18). When this Operational QA Program is used, the {
licensee shall comply with the Ranulatorv 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 l 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). .!,
- 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 >
are also not appropriate to the operations phase.
+
- 3) With regard to Section 1.2 of ANSI N45.2.8 - 1975 titled Anolicability: The first sentence in this Section is not applicable to the operations phase. The licenses 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 th: extent of coverage" shall he defined by supervisory maintenance personnel by the way'in which they -
impicment the other requirements of this Standard.
- 4) With regard to Section 1:3 of ANSI N45.2.8 - 1975 titled Resoonsib111tv: This Section's requirements are met by,the definitions for positions and the organizational responsibilities outlined in the Technics 1 Specifications, Policy 1 of the DQAM 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 .acluded in ANSI N45.2.10 shall be used as clarified in the licensee's commitment to Regulatory Guide 1.74.
- 6) With regard to Section 2.1 of ANSI N45.2.8 - 1975 titled Plannine:
Planning requirements, when necessary, shall be incorporated into maintenance and modification procedures.
Rev. 9a 25 of 33 OQAM.R9A/SQPFLR - 105
APPENDIX A-NRC Ranulatorv Guida 1.123 . " Quality Assurance Requirements for Control of .
l' Procurement of Items and Services for Nuclear Power Plants" (Rev. 1, 7/77) !
Endorses ANSI N45.2.13 - 1976. ,
l The Operational Quality Assurance Program complies with the requirements of . ,
j this Guide with the following clarifications- '
1 1 l
- 1) With regard to Section 1.3 of ANSI N45.2.13 -- 1976. titled ,
Definitions: With two exceprions (Procurement Document and Quality Assurance Program Requirements) definitions in this Standard which- I are not included in ANSI N45.2.10 will be used;-all definitions which '
l are included in ANSI N45.2.10 will'be.used as clarified in the ,
l licensee's commitment to Regulatory Guide 1.74. The two exceptions l are defined in Appendix A under Regulatory Guide'1.74. ,
f 2) With regard to Section 1.2.2 of ANSI N45.2.13 1976 titled '
I Purchaser's Ramoonalbilitlaat Item e is one of_the options which ;
may be used by the licensee to assure qualityt however, any of the options given in 1GCTR50, Appendix B, Criterion VII as implemented by Policies 4 and 7 of the Operational.QA' Program may also be_used.
- 3) With rogard to 'Section 3.1'of ANSI N45.2.13 - 1976 titled Procurament Document Prenaration. Review and Chanee Contro1: 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: The licensee will meet the requirements of f Policies 4 and 7 of the Operational QA Program in lieu of the requirements specified in this Sectior.. '
- 5) With regard to Section 5.3 of ANSI N45.2.13 - 1976 titled Preaward Evaluation: The licensee will comp'.3 with an alternate paragraph which reads: "Except in unusual circumstances (e.g., replacement parts are needed to preclude the development of some unsafe condition at a nuclea: facility), a preawarc. 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 Channes in Items or Services: The phrase "the Operational QA Pr, 9" will be inserted in lieu of " ANSI N45.2, Section 7."
- 7) Vith regard to Section 8.2 of ANSI N45.2.13 - 1976, titled 91soosition: 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 submitted to the Purchaser for approval of the recommended disposition prior to shipment when the nonconformance could adversely affect the end use of a module or shipeblo component # relative to safety, interchancsability, operability, reliability, integrity, or maintainability:
Rev. 9a ;
26 of 33 OQAM.R9A/SQPFLR - 106
t APPENDIX A ty Tcchnical er catorial requirc:cnt is violct:d;
- 2) Requiremeut 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
- 4) The item 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 !
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 inspection and/or test for conformance to procurement requirements ,
regarding end use. ,
- 8) With regard to Section 12 of ANSI N45.2.13 - 1976 titled Audit of Procurement Pronram: The licensee audit program will be implemented in accordance with and to meet the requirements of t- 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 the licensee may not'always be ,
able to obtain agreement with a Supplier. The licensee retains.the ultimate responsibility for performance of purchased equipment. The appropriate engineering discipline will exercise this management / engineering prerogative with respect to the . final decision on post installation test requirements.
- 10) With regard to Section II of ANSI N45.2.13 - 1976- titled Ouality Assurance Records: The licensee shall maintain records in accordance with and to meet the requirements of Policy.17 of the OQAM and ANSI N45.2.9 as specified in Appendix A.
NRC Remulatory Guide lills Nuclear Power Plants" (Rev. 1",9/80)
Auditing of Quality
- Endorses ANSIAssurance N45.2.12 - Programs 1977. for L
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) i the definitions in this Standard which are not included in ANSI I
l N45.2.10 will be used: All definitions which are included in ANSI N45.2.10 will be used as clarified in the licensee's i Rev. 9a 27 of 33 DQAM.R9A/SQPFLR - 107 L _ ~.. - -
F p APPEND 1X A commitatat to Regulattry Gulds 1.74. Tho cxecpted d finitirn3 cro defined in Appendix A under Regulatory Guide 1.74.
- 2) With regard to Section 2.2 of ANSI N45.2.12 - 1977 titled Personnel Oualification: The qualification of licensee audit personnel wi).1 be accomplished as described to meet _the requirements of ANSI N45.2.23 1978 as endorsed in Appendix A and Po11cies 2 and 18 of the Operational QA Program.
- 3) With regard to Section 1.3 (and subsections 2.3.1 through 2.3.3) of ANSI N45.2.12 - 1977 titled Train 4ne: The training of licensee 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.
- 4) With regard to Section 2.4 of ANSI N45.2.12 - 1977 titled Maintenance of Proficiancv:' The maintenance of proficiency of licensen 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 Operation &1 QA Program.
- 5) With regard to Section 3.3 of ANSI N45.2.12 - 1977 titled Essential Elements of the Audit Sv.glan: The licensee will comply with subsection 3.3.5 as it was originally written (subsection 3.2.5) in ANSI N45.2.12. Draft 3, Revision 4: " Provisions for reporting on the effectiveness of the quality assurance program to the responsible management." For the auditing organization (licensee), L effectiveness is reported us. 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. 1 Other than audit reports, the licensee may not directly report on '
the effectiveness of the quality assurance programs to the audited organization when such organizations are outside of the licensee.
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 on a " timely basis." Timely basis is interpreted to mean j within the framework or period of time for completion of corrective action that is accepted by the organization. Each finding requires ,
1 a response and a corrective action completion date; these dates are subject to revision (with the approval of Quality Programs or Supplier Quality Assurance) 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 Schedu11ne:
Subsection 3.5.3.1 is interpreted to mean that the licensee 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.
Rev. 9a 28 of 33 CQAL 39A/SQPFLR - 108 l
.)
APPENDIX A
- 7) With reg 0rd to S:cti n o.3.1 cf ANSI N45.2.12 - 1977 titled Eta-Audit Conference: The licensee will comply withithe requirements of-this Section by 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) 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 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 Process:
(a) Subsection 4.3.2.2 could be interpreted to limit auditors to the review of only objeccive evidence; sometimes and for some program elements, no objective evidence may be available.
The licennee will comply with an alternate sentence which reads: "When available, objective evidence shall be examined for compliance with quality assurance program requirements.- If arbjective evidence is used (e.g., personnel interviews) then the auilt 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 conditions adverse to quality are. virtually
" obvious" with respect to the needed corrective action: ."When a condition adverse to quality is identified as a result of an audit, unless the apparant 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 t recommendation which is clarified with the definitica of " acknowledged by a member of the audited organization" to mean that "a member" of the audited organizacion 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. I The licensee will comply with an alternate sentence which reads: " Corrective action taken as a result of the lect previous audit of the same area shall be reviewed or reaudited, if necessary, to evaluate the effectiveness of the action to resolve the identified condition adverse to quality."
- 9) With regard to Section 4.3.3 of ANSI N45.2.12 - 1977 titled Engi- 1 Audit Conference: The licensee will substitute and comply with !
Rev. 9a !
29 of 33 -
l OQAM.R9A/SQPFLR - 109 1
i
APPENDIX A tha following paragrcph: "Fcr c11 cxt0rnti cudits, a pos.t-audit -
conference shall be held with management of the audited organization -
to present audit findings and clarify misunderstand 1ngs; where no adverse findings exist, this conference may be waived by management t of the audited organization: such waiver shall be documented in the a audit report. Unless unvanal operating or maintenance conditions i preclude attendance by appropriate managers / supervisors, a f l
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 findings, management of the internal audited l
organization may waive the post-audit conference: such waiver shall be documented in the audit report."
r
- 10) With regard to Section 4.4'of ANSI N45.2.12 - 1977 titled Renortine: !
(a) This.Section requires that the audit report shall be signed by
-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. The licensee will comply with Section 4.4 as '
clarified in the following opening:- "An audit report, which l shall be signed by the audit team leader, or his supervisor in 1 his absence, shall provide:" In cases where the audit report is ;
not signed by the Lead Auditor due to his absence, one record ,
4 copy of the report must be signed by the Lead Auditor upon his j return. The report shall not require the Lead Auditor's review / concurrence / signature if the Lead Auditor is no longer employed by the licensee at the time the audit report is '
issued.
- l l (b) The licensee will' comply with subsection 4.4.3 clarified to l 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; the licenseo may choose .
( not to comply with this requirement. Instead, licensee auditors /1 cad auditors are required to document all adverse :
l au .t findings. The procedure for processing quality I
dericiency 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 (~rrecting the finding:
the quality deficiency document with these " Auditor- ,f Recommendations" is then transmitted to the audited I organization. In addition, appropriate Quality Programs or Supplier Quality Assurance personnel are required to review i corrective action taken for the condition adverse to quality document and determine if it is acceptable. Any disagreements must be escalated to higher management for resolution. .
Rev. 9a OQAM.R9A/SQPFLR - 110 i
f APPEND 1X A l (o) Tha Icst parrgr:ph in S:ctirn 4.4 d als eith distribution of- i audit reports. The licensee'will comply with these j requirements after substituting the following for the last '
sentence: "The audit report shall be issued within thirty working days after the last day of the audit." t
- 11) With regard to Section 4.5.1 of ANSI N45.2.12 - 1977 titled By Audited Ormanizatlon: The licensee will comply with the following clarification of this Section: " Management of the audited [
l organization or activity.shall review and investigate all adverse- ;
l audit findings, as necessary, to determine and schedule appropriate ;
corrective action including action to prevent recurrence. They '
shall respond, in writing, within thirty working _ days after the date g
! of issuance of quality deficiency documents _ generated as a result of '
l the audit 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 teken and verified prior to issuance of the audit' report.
The audited organization shall take appropriate action:to assure that corrective action is accomplished as scheduled." The Director, Quality Programs or the Manager, Nuclear Safety Oversight, as applicable, may, at his their discretion, waive the requirement for a supplementary response.
P
- 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 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 audits 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) are not covered by this OQAM.
- 14) Paragraph C.3.b(2) first sentence is replaced with the following:
Each Supplier is evaluated initially to determine the acceptability of his quality aanurance program. If acceptable, the Supplier is placed on the Qual, % d Supplier List. Audits, when used as the-selected method of mource verification, should be conducted as follows:
Paragraph C.3.b(2), second paragraph is replaced with the following:
An evaluation of the supplier should be performed annually. This t evaluation must be' formal, with the results documented and approved by responsible Supplier Quality Programs! Assurance management; and it must consider pertinent factors such as the results of other ,
l
' 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, Suppliers shall be re-audited every three years.
Rev. 9a 31 of 33
_0QAM.R9A/SQPFLR 111
APPENDIX A Paragrcph cdditions to C.3.b(2) cro cs follows: Provicuoly_cvaluated and approved active suppliers, for which audit is anL the selected method of source. verification, should be evaluated concurrent with the award of a contract. Regardless of the results of the i evaluation, active Suppliers (except those excluded under C.S.b(1) above) shall have been source verified (audit, surveillance or
. inspection) within two years prior to award of a contract or have source verification' 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
'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 Prohrses, the Nanager, Nuclear Safety Oversight or their 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:
The licensee 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 i Ergnata: 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 4 are so severe that any delay would be undesirable) shall be reported to management of the audited organization. Where responsible y management personnel are available (such as at an operating nuclear ;
power plant), these conditions shall be reported immediately.- If-responsible management personnel are not available-(such as at a .
Supplier's shop on a back shif t or for items discovered during a review of vendor supplied materials), theo2 conditions shall be !
reported as soon as practical."
l 1 -
L NRC Regulatorv Guide 1.lld " 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 - 1976 titled Oualification of Auditert: 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, the licensee will comply L
with an alternate subsection 2.2.1 which reads:
Rev. 9a 32 of 33 0QAM.R9A/SQPFLR - 112
umnui'us e APPENDIX A Orie:t tion ~ to pr;vido o w:rking knowledg2 cnd und: rot:nding cf the Operational QA Program, including the ANSI standards and Regulatory Guides included in Appendix A of that Program, and the licensee's procedures for implementing audits and reporting results.
2)- With respect to'Section 4.1 of ANSI N45.2.23 - 1978 titled Ormanfrational kesoonsibility: The licensee will' comply with this Section with the substitution of the following sentence in place of the last sentence in the Section.
The Director, Quality Programs; Manager, Quality Systems; the Supplier quality Assurance Manager or Lead Auditor shall, prior to commencing the audit, assign personnel who collectively have experience or training commensurate with the scope, complexity, or special nature of the activities te,be audited.
Self-initiated monitoring audits will be performed by qualified auditors, but no assignment is made "ptfor to commencing the audit" since it is self-initisted.
- 3) With respect to Section 3.2 of ANSI N45.2.25 - 1978 titled Maintenance of Proficiencv: The licensee will comply with the requirements of this Section by defining " annual assessment" as one which takes place at lee' avery twelve (12) months (to a maximum of-fif teen [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 Uodattne !
of Lead Auditors' Records: The licenses will substitute the following 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 i Retention: The licensee 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 Comoetence: Add "This includes RO (maximum of I credit) and SRO (maximum of 2 credits) licenses" to last sentence of this subsection.
Rev. 9a 1
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APPENDIX B
/JPENDIX B DOCUMENT CONTROL RESPONSIBILITY FOR OUALITY- W LATED DOC',NENTS DOCUMENT PREPARED BY REVIEWED E APPROVED BY ISSUED BY A. Operational Quality Programs Director, Vice President, Director, Quality Assurance Quality Programs (5) Nuclear Engineering Quality Programs Manual (Topical) & Support Director, Nuclear Vice President, Support Nuclear Operations Director, Nuclear Vice President, Plant Engineering Human Resources
& Administration GGNS G eeral Manager Vice President, Manager, Plant Operations Support Modification &
Construction Director, Nuclear Senior Vice. President, Licensing Planning & Assurance Director, Corporate Services
-Manager, Nuclear Safety Oversight B.I.' Quality Assurance Quality- Quality Director. Director, Procedures Programs Programs Quality Programs Quality Programs
- 2. Quality Assurance -Quality Quality .Desponsible Manager, Manager, Instructions Programs Programs Quality Quality. Services Programs Rev. 9a
'Page 1 of 5 APPB.R9A/SQPFLR - 1
_ _ _ _ . ~
APPENDIX B DOCUMENT PREPARED BY REVIEWED BY APPROVED'BY ISSUED BY B. (Cont'd)
- 3. Supplier quality Supplier Supplier Banager, Nucinar Banager, Nuclear Assurance Qualicy Assurance Quality Assurance Safety Oversight Safety Oversight Procedures Director, Quallty Programs C. Plant Staff and Plant Modification and Construction Procedures
- 1. This Section deleted in Revision'4
- 2. Administrative Plant Staff and GGNS General Manager GGNS General Manager GGNS General Manager Procedures Plant Modification (Safety-Related) & Construction Manager, Plant Manager,: Plant
, Modification & Modification &
Construction (9) Construction (10)
Director, Quality Programs (5)
Plant Safety Review Committee (8)
- 3. This section deleted in Revision 3.
- 4. Plant Section Plant Staff and See Note (15)- See Note (15)
Procedures See Note (15)
Plant Modification
& Construction /ssigned Reviewer See Note-(3)
- 5. Plant Section Plant Staff and See Note (15) See Note- (15)
Instructions See Note (15)
Plant Modification
& Construction Assigned Reviewer (See Note 3)
Rev. 9a Page 2 of 5 APPB.R9A/SQPFLR - 2
.. . .;- _, ._ . ._,u . _ , - _ ..- . . . 2 _.
APPENDIX B DOCUMENT PREPARED BY REVIEWED BY APPROVED BY ISSUED BY D. This section deleted in Revision 4 E.1. Entergy Responsible Director, Quality Responsible Administrative Operations Staffs Programs (14) Vice President Services Management Manual Responsible Director / Manager
- 2. Nuclear Nuclear Support Section Manager Director, Nuclear Director, Nuclear Eupport Staff Support. Support-Administrative Director, Quality Procedr.res Programs (O GGNS General Manager (11)
- a. Environmental Nuclear Support Manager, Radiological Director, Nuclear Director, Nuclear Surveillance Staff & Environmental Support Support Program Services Section Procedures Assigned Reviewer See Note (3)
- 3. Nuclear Nuclear Licensing ~Section Manager Director, Nuclear Director, Nuclear.-
Licensing Staff Licensing Licensing.
Administrative Director, Quality Procedures Programs (5)
- 4. Emergency Emergency Preparedness Supervisor, Emergency GGNS General. Manager, Emergency Preparedness Staff Preparedness Manager (12) Preparedness Administrative Procedures Director, Quality Manager, Emergency Programs (5) Preparedness Rev.~9a Page 3 of 5 APPB.R9A/SQPFLR - 3
ISSUED BY APPENDIX B APPROVED BY REVIEWED BY PREPAPED BY Director, DOCUMENT Director,-
Nuclear Plant Nuclear Plant Nuclear Plant Engineering Nuclear Plant Engineering F. Nuclear Plant Engineering Staff Engineering Engineering Principal Engineer Administrative or Senior Staff Procedures Engineer or Quality
} Engineering J
Director, Quality Programs (5)
G. This section deleted in Revision 5.
Director, Director , .
Director, Nuclear Plant Nuclear Plant Nuclear Plant Engineering H. Q-List Engineer'ng Staff Nuclear Plant Engineering Engineering Manager,' Nuclear Fuels (7)
Director, Quality Programs (5)
Manager, Purchasing Director, Corporate Section Manager Corporate Services Services I. Corporate Services Staff Director, Quality Administrative Programs (5)
Procedures Vice President, Manager, Nuclear Manager, Nuclear Nuclear Engineering Fuels uclear Fuels Fuels J. Nuclear Fuels & Support Administrative Staff Director, Quality -
Procedures Programs (5)
Rev. 9a Page 4 of 5~
APPB.R9A/SQPFLR - 4
APPENDIX B NOTE: 1) Ra2pon:sible individuals licted chove may b:va d:signated alternates the era cuthorized to perfers function.
- 2) Designated support organization (other licensee organizations, contractors, censultants, etc.)
also be authorized to perform certain of the functions.
I
- 3) See Paragraph 5.4.3 of this Manual.
! 4) Sections 6.5.3, 6.5.4, 6.5.5, 6.5.6, 6.5.8, and 6.5.13 apply to this Appendix.
- 5) The Director, Quality Programs reviews these documents to assuie quality requirements are addressed and l provides concurrence. Concurrence indicated by the actual signature may be provided by any Manager QP, the Dire . tor, Quality Programs, or designee.
- 6) Review for comment not concurrence on matters relative to procurement.
- 7) On matters relating to nuclear fuel and nuclear core design.
- 8) As required by the Technical Specifications.
- 9) For those procedures implemented by Plant Modification and Construction.
- 10) Those procedures addressing responsibilities and authorities of. the Plant Modification and Construction Section are approved by both the GGNS General Manager and the Manager, Plant Modification & Construction.
- 11) Environmental Surveillance Program Administrative Procedures Oniv.
- 12) For those procedures directly interfacing with Plant Emergency Procedures.
- 13) SRC Procedures Oniv.
- 14) Safety Related QnlI.
- 15) Plant section procedures / instructions are reviewed and approved in accordance with the guidelines as stated in Technical Specification section 6.5.3.1.
1 Rev.'9a Page 5 of 5 APPB.R9A/SQPFLR - 5
_ _ _ - _ _ _ - _ _ _ _ _ _ _ -_ _ = _ = _ . . _ _ _ _ - _ . _ .. . .- -- - - ._ . . _- _- - _ _ _ _ - . -. . . - .
y APPENDIX C OPERATIONAL OUALITY ASSURANCE PROGRAM IMPLEMENTING PROCEDURES Implementing Document '
by Organization 10CFR50, Appendix B, Criteria Summary 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 16 A. Quality Programs
- 1. Operational QA Manual X X X X X X X X X X X X X X X X X X QA Manuals describe the licensee's QA Program Policies
- 2. QA Procedure Manual X X X X X X X X X X X X X X X X X X for all 10CFR50, Appendix B Criteria, and provide appro-
- 3. QA Instruction Manual X X X X X X X X X X X X X X X X X X priate implementation procedures / instructions. (QA Procedures are numbered by Appendix B Criteria).
B. Nuclear Licensing Nuclear Licensing X X X X X X X X X X Emphasis of Nuclear Licensing -
Administrative is on construction licenses Procedures and permits; safety analysis;-
fire protection; and, SRC support.
C. Nuclear Engineerine
& Sucoort
- 1. NPE Administrative X X X X X X X X X X X X Emphasis of Nuclear Plant Procedures Engineering is on design, independent review, evaluation and technical support.
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APPENDIX C OPERATIONAL OUALITY ASSURANCE PROGRAM IMPLEMENTING PROCEDURES C. Nuclear Engineerine
& Sucoort (cont'd)
Implementing Document by Organization 10CFR50, Appendix B, Criteria Summary 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
- 2. Nuclear Fuels Administrative Procedures X X X X X X X X X X X Emphasis on nuclear fuel cycle management.
D. Plant Staff and Plant Modification &
Construction
- 1. Operations Manual
- a. Safety Related ,X X X X X X X X X X X X X X XX X The Operations' Manual con-Administrative tains implementing procedures Procedures for. a11 10CFR50, Appendix B .
Criteria.
E. Emergencv Preoaredness Emergency Preparedness X X X X X X X X X Emphasis of Emergency Administrative Preparedness is on Readiness Procedures for Emergency Response.
Rev. 9a
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. INTRODUCTION This Manual describes ~the Operational Quality Assurance Program established to assure that 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 i obtained from the NRC's " Standard Review Plan" (NUREG-0800, formerly NUREG-75/087).
The Quality Assurance Program described herein is applicable to.the Grand Gulf Nuclear Station (GGNS), and is referenced in Section 17.2 of the Updated Final Safety Analysis Report. The program applies to all. operational phase activities (including pre-operational and startup testing) that affect the safety-related functions of those structures, systems and components to. e prevent or mitigate the consequences of postulated accidents that coul_ cause ,
undue risk to the health and safety of the public. ,
I l
l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a '
INTRODUCTION Page 1 of 1. INTRODUCTION 1
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OQAMR9A.1/SQPFLR - 1 l t
FOREWORD ;
This Manual prescribes the' Operational Quality Assurance Program Policies' e 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 ci 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-dato.
by the issuance of revisions, as necessary. The Director, Quality 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. ;
i T. H. Cloninger W. T. Cottle i Vice President, Nuclear Engineering Vice President, Nuclear Operations. <
& Support '
i R. J. Landy G. M. Muench I
Vice President, iluman Resources and Vice President, Operations Support.
Administration J. G. Dewcase
. Senior Vice President, Planning & 9ai Assurance l
l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a FOREWORD Page 1 of 1 FOREWORD OQAMR9A.1/SQPFLR - 2 r
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TABLE OF CONTENTS E0LICY TITLE REL DAIE Policy 1 Organization 9a Policy 2 Quality Assurance Program 9a Policy 3 Design Control 9a Poldcy 4 Procurement Document Control 9a Policy 5 Instructions, Procedures and Drawings 9a Policy 6 Document Control- 9a Pciicy 7 Control of Purchased Material, Equipment and Services 9a Policy 8 Identification and Centrol of Material, Parts and Components 9a Policy 9 Control of Special Processes 9a Policy 10 Inspection 9a Policy 11 Test Control 9a Policy 12 Control of Measuring and Test Equipment 9a Policy 13 Ilandling, Storage and Shipping 9a Policy 14 Inspection, Test and Operating :
Status 9a_ l Policy 15 Nonconforming Materials, Part.s or Components 9a Policy 16 Corrective Action 9a ]
Policy 17 Quality Assurance Records 9a Policy 18 Audits 9a i
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OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a l TITLE: TABLE OF CONTENTS TABLE OF !
Page 1 of 2 CONTENTS j
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OQAMR9A.1/S.QPFLR - 3
IABLE OF CONTENTS POLICY TITLE REY. DAIE Appendix A Conformance of t1GNS Operational 9a Quality Assurance Program to NRC ,
Regulatory Guides and ANSI '
Standards ,
Appendix B Document Control Responsibility 9a For Quality Related Documents Appendix C Operational Quality. Assurance 9a .
Program Implementing Procedures -
Record of Revisions Entered 2 6/1/81 .
l i
i OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: TABLE OF CONTENTS TABLE OF Page 2 of 2 CONTENTS '
OQAMR9A.1/SQPFLR - 4 ,
m 1.0 ORGANIZATION 1.1 PURPOSE i 4
This Policy describes the organizations and key personnel responsible _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 orgsnizational structure and delineates the authority, respont1bility and lines of communication for organizations performing functions covered by the Operational Quality Assurance Program.
Certain of these functions may be delegated to other qualified organizations, but responsibility for the program is retained and exercised by the r licensee.
1.3 ORGANIZATION AND RESPONSIBILITY Clear and definitive lines of authority, responsibility and communication are established for all licensee 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 functional responsibility assignments are such that attainment of program objectives is accomplished by those who have 9 boon assigned responsibility for performing the work, and verification of conformance to established requirements is accomplished by qualified !
personnel who do not have responsibility for performing or directly supervising the work. ;
1 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 and the President & Chief Executive Officer indicates guidance on Quality Assurance policy matters and a direct escalation path. The dashed line
! from the Supplier Quality Assurance Manager to the Senior Vice President, Planning & Assurance and the President and Chief Executive Office Indicates guidance on matters related to quality. 9a l 1.3.1 President & Chief Executive Officer
! Ultimate responsibility for providing top level direction of all '
i r.ctivities 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 l Officer provides guidance with regard to corporate quality assurance policy. He delegates authority and responsibility'for l
the development, implementation and verification of the Operational L Quality Assurance Program to the appropriate organizations through the Executive Vice President and Chief Operating Officer, the Senior Vice President, Planning & Assurance and 9a OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION L
l Page 1 of 13 Policy 1 OQAMR9A,l/SQPFLR - 5 l_
tho Vico Presid:nt, Hunan Recture:3 & Adminictr;tirn. 'H3 -
caint2 ins a continuing c Orcn::s cf quality at:urtnes tattors and monitors effectiveness of the program throagh status ;
reports prepared by the Director, Quality Programs and tt ;
Manager, Nuclear Safety Oversight. i 1.3.2 Vice President. Nuclear Ooerations .
The Vice President, Nuclear Operations reports directly to the t Executive Vice President and Chief Operating Officer and is -
responsible for the administration of all functions associated wit'a the operation of the Grand Gulf' Nuclear Station, except 1 those delegated to the Vice President, Nuclear Engineering 6 Support and the Senior Vice President, Planning & Assurance.
He is also responsible for. training. He providee guidance with. 9a-regard to quality assurance goals and objectives to the Director, Quality' Programs. He maintains a continuing i awareness of quality matters through applicable reports and management audits of the program. 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 Pronrams The Director, Quality Programs reports directly to the Vice ,
President, Nuclear Operations and is delegated the overall authority and responsibility for establishing, controlling.and verifying the implementation and adequacy of the Oparational.
9a. .
Quality Assurance Program (including preoperational and startup '
testing). This includes the establishment of quality assurance policies, goals and objectives. He is assisted by the Manager, ,
Quality Services and the Manager, Quality Systems The primary duties and responsibilities of the Director, Quality !
Programs include:
1.3.3.1 Developing and controlling the Operational Quality Assurance Program and the content of this Manual, including the approval of changes thereto and providing for interpretations thereof; l 1.3.3.2 Directing the activities of the Quality Programs' Staff r in verifying the implementation of the Operational 9a Quality Assurance Program.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 2 of 13 Policy 1 I'
0QAMR9A.1/SQPFLR - 6 '
1.3.3.3 RIporting to tha Vic2 President, Nuclear Op3ratirn2 cnd ths Prosid:nt & Chicf Ex:cutivo Of fic0r en tha status and adequacy of the Operational Quality Assurance Program; 1.3.3.4 Reviewing and approving Quality Assurance Procedures; 1.3.3.5 Providing for review of and concurrence with documents as specified in Appendix B of this Manual; 1.3.3.6 Providing for the planning, scheduling and coordinating of training for the Quality Programs' Staff; providing quality assurance input to the training and indoctrination programs for personnel. performing quality-related activities; and providing for the approval of all Quality Programs Staff certifications.
1.3.3.7 Maintaining adequate communications with regulatory agencies, suppliers, contractors and other licensee organizations on quality assurance matters;. i 1.3.3.8 This section deleted in Revision 4 J
1.3.3.9' Planning and performing receipt: inspections; 9a '
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 Qua,ity. Assurance Program requirements; -
1.3.3.11 Providing for periodic review and analysis of NRC and licensee quality deficiency documents to detect po*sible adverse quality trends.
1.3.3.12 Providing for inspections and nondestructive ,
examinations, i
1.3.3.13 Providing for the coordination, development and issuance of quality assurance reports as required by Management and apprcpriate procedures.
1.3.3.14 Providing for the coordination and/or implementation of administrative services for Quality Progr6ms.
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 problems, !
recommend solutions and verify implementation of solutions. If i acceptable solutions cannot be reached he has the responsibility and authority to escalate these matters to the President & Chief' Executive Officer, lie has the authority, as delineated in the appropriate Quality Assurance Procedure, to initiate action to stop unsatisfactory work and control further processing, OPERATIONAL QUALITY ASSURANCE MANUAL Rev 9a TITLE: ORGANIZATION Page 3 of 13 Policy 1 i OQAMR9A.1/SQPFLR - 7 t
1 1
d311vsry, er installation cf.ntnconferring it :a or '
continu tita cf nrnc:nfs; ming a rvicts pending corrsctirn of 1 the nonconforming condition.
l 1.3.4 Mana.er. Quality Services '
The Manager, Quality Services reports directly to the' Director, Quality Programs. He directs Quality Programs' staff in.
inspections, nondestructive examination, receipt inspections, 9as procurement document reviews.c and reviews of activities to - '
verify implementation of the Operational Quality Assurance Program.
f-l The Manager, Quality' Services has the authority.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.
The primary duties and responsibilities of the Manager, Quality Services include: ,
1.3.4.1 Coordinating the review of procedures, as delineated-in Appendix B'to this manual-to assure quality ,
requirements are addressed.
1.3.4.2 Developing, interpreting and maintaining the-Operational Quality Assurance Program and Procedure Manuals.
-l 1.3.4.3 Controlling, processing, tracking,, disposition c.oncurrence, and verification of site quality deficiency documents.
R.
1.3.4.4 Analyzing NRC and licensee quality deficiency 9a documents for trends and reporting results to the ,
appropriate levels of management.
-1,3.4.5 Providing for inspections and nondestructive i examinations.
1.3.4.6 Serving as a primary member of the Plant Safety Review Commit' gee.
1.3.4.7 Reviewing and approving Quality Assurance Instructions, as applicable.
1.3.4.8 Providing for the quality review of trocurement documents; 9a 1.3.4.9 Providing for the performance of '
receipt inspection activities.
OPERATIONAL QUALITY ASSURANCE MANUAL -Rev. 9a :
TITLE: ORGANIZATION Page 4 of 13 Policy 1 DQAMR9A.1/SQPFLR - 8 i 4
1.3.5 GGNS Genernl Mananer
.The GGNS; General Manager reports to the Vice President,_ Nuclear' Operationsfand isLdelegated the responsibility'and authority-for assuring the: safe, reliable _and efficient operation of the'
- plant within :theLeonstraints of; applicable regulatory requirements and the operating license.1 He supervises the-
= operating plant' staff; approves Plant Administrative Procedu'res; authorizes implementation of design changes and plant modifications; implements repairs; . reports appropriate matters to. management and the Safety Review Committee;'and, generally administers plant operations on a day-to-day. basis. j
.He'has overall, responsibility for execution of the Operational _ '
Quality Assurance _ Program at-the7 plant site;_except for implementation of dasign changes and_ plant modifications and the preoperational testing on Unit 2; and has the authority-to stop. work if an-activity at the Plant is-not in conformance 1 with'programiroquirements. He-has ovarall responsibility-for developing ; systems to manage the storage and rotrieval of z
records and for coordinating the turnover of' contractor-vendor ,
records. 'It isfthe responsibility of the GGNS General Managerf '
to assure'that these functions are performed in accordance with the' requirements of the Operational' Quality' Assurance Program.1 The GGNS. General Manager.is assisted:In carrying cut-his responsibilities by the Manager, Plant Operations; the Manager, O Plant Maintenance; the Manager, Plant _ Support; and, Manager,'
Performance;& System Engineering as well as the operating plant, staff which, includes individuals knowledgeable _in plant. <
radiation protection,.and plant security. In acdition,;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. 7 o
1.3.6 This Section deleted in Revision 4 1.3.7 Hirsctor. Nuclear Licensin.g j
-s The Director, Nuclear Licensing reports to the Vice President, !
Nuclear Operations ar4 Jr responsible for directing the activities of the Nuclear Licensing Staff. He is assisted by the Manager, q Nuclear Licensing and the Plant Licensing Superintendent. The "
Nuclear Licensing Staff is responsible for securing the licenses and permits required to construct;and operate the plant. The Nuclear Licensing Staff also provides technical _ l~
assistance in the areas 13f safety analysis and fire protection. 1 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, Nuc1 car Licensing to assure that these functions iro performed in accordance_with the requirementslaf the Operational Quality' Assurance Program.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev 9a TITLE: ORGANIZATION ,
Page 5 of 13 Policy 1 0QAMR9A.1/SQPFLR - 9 1
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1.3.8 Director. Nuclear Plant Eneineerine.
The Director, Nuclear, Plant Engineering reports to the.Vice-- ~
President, Nuclear Engineering & Support, and' is responsible for directing: th activities of the Nuclear Plant Engineering
~
Staff.. Nuclear Plant ~ Engineering,2 consisting of _ the Manager, Operational; belys h ; Manep ;, Engineering Support; _ Manager, ,
Nuclear ~ Design. Mu)u.y Enu neering Section; and,'their-respective sa fa m- responsible _for-plant-design, design rettew,'moditi m ss . chemical / environmental-analysis,=specialt processes,~ opera bru11 analysis programs, and accident and; transient analyses. lit e.s:the responsibility of the Director, Nuclear Plant-Enginsering to assure that these' functions are: 4 performed _in accordarce.with.the requirements of the--
Operational Quality Assurance: Program.; The' Director,. Nuclear Plant' Engineering is responsible forl reviewing NPE design; documents for compliance with the Operational Quality. Assurance
. Program requirements and'soncurring;with'the same.
]
'i 1.3.9 Safety Review Committee (SRC): !
Committee composition,Jresponsibility and authority, subjects;to: 'I be reviewed, administrative controls,=and, reporting requirements .!
are addressed in Section 6'of.the Technical Specifications and
,Section 13 of the UFSAR for.the applicable nuclear generating station. ^1 1;3.10 Plant Safety Review Committee (PSRC)
Committee composition, responsitiility and authority, subjects._to be reviewed,-and reporting requirements are addressed in Section 6 of the Technical Specifications and Section 13 of the UFSAR-for ;
the applicable nuclear generating station.
1.3.11 Mananer. Purchasine and Manannr. Contracts The Manager, Purchasing'and= Manager, Contracts are responsible' for performing' procurement activities in"accordance-with the Operational Quality Assurance Program,-as4 coordinated with !
the GGNS General Manager; the Manager, Project Management; the- 1 Director, Nuclear Licensing; the Director, ; Nuclear: Plant s Engineering; the Director, Quality Programs; the Director,. '
Nuclear Support; the Director, Corporate Services; the Manager; 9a ;
Nuclear Safaty Oversight; and other appropriate licensen personnel.
i 1.3.12 Other Ornanizations Other organizations, contractors, or consultants may be delegated 1 certain functions which fall under the Operational Quality Assurance Program. In such cases, the licensee shall retain responsibility for the delegated work.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 6 of 13_ Policy 1 0QAMR9A.1/SQPFLR - 10
1.3.15' Minimum"Oua11fications of Ouality personnel-The qualification requirements and experience levels-of Quality-personnel are such asito assure competence commensurate with the~ responsibilities of:the position ~and are described-in 9a
-ANS1/ANS 3.1 (Draft 12/79).- See Appendix A.
Key Quality personnel include the Director, Quality Progrant; the Manager, Quality Services; the Manager, Quality Systems; the Manager, Nuclear Safety Oversight; and the Supplier QA Manager.,
1.3.14 This section deleted in Revision 5 1.3.15 Unit 2 Construction Superintendent 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 4 Nuclear ~ Station Unit'2.- It is the Unit'2-Construction- !
Superintendent's responsibility to assure that the requiremental !
of the Operational Quality, Assurance Program are implemented by [
the organizations under'his direction. The Unit 2 Construction =
l Superintendent maintains a. continuing-involvement-in [
preoperational phase testing, quality assurance matters, andi j
assesses the implementation and effectiveness of the program ?
through contact with'and reports furnished by the Director, '
Quality. Programs. -;
1.3.16 Director. Nuclear Sunnort -
The Director, Nuclear Support reports to the Vice. President, Operations Support and is responsible for directing the activities of the Nuclear Support Department. The Nuclear '
Support Department, consisting of-the' Manager, Radiological and-Environmental Services and Manager, Contracts and their respective staffs provide technical support in the areas-of
- environmental licensing and permitting; health physics; j{
environmental protection; chemistry; waste. management; and,- 4 developing, bidding, awarding and administering contracts. 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.
1.3.17 This seation deleted in Revision 5 1.3.18 'Manneer. Quality Systems The Manager, Quality Systems reports directly to the Director, Quality Programs. Ile-directs Quality Programs' staff in' audits and monitoring activities to verify the adequacy-and 9a implementation of quality assurance programs established and implemented by the licensee and the vendors. ,
OPERATIONAL QUALITY ASSURANCE MANUAL Rev '9a k TITLE: ORGANIZATION Page 7 of 13 Policy 1 0QAMR9A.1/SQPFLR - 11
The Manager, Quality Systens"hasLths authority 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.
The primary duties and= responsibilities _of the Manager,. Quality-Systems include:~
1.3.18.1 Providing for the planning, scheduling,l coordinating, performing and reporting of audit activities.
1.3.18.2 Providing for_the planning,: scheduling,; coordinating, 9a performing and documenting'of' monitoring activities.
1.3.18.3 This section deleted in Revision 9a.
1.3.18.4 'this section' deleted.in Revision'9a.
.1.3.18.5 This section deleted in Revision 9a.
-1.3.18.6 ' Reviewing and approving Quality hosurance Instructions,;as applicable.
1.3.19 This sectiva deleted'in Revision 6.
1.3.20 This Section deleted in Revision 6A.
1.3.21 Vice President. Nuclear Ennineerinn & Suonort -
The Vice President, Nuclear Engineering & Support reports directly to the Executive Vice President and Chief Operating Officer and is responsible for the administration of all-functions associated with engineering:and fusincycle management including the control of_the design activities associated with nuclear core design of GGNS. - 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 reports-issued by the Director, Quality Programs.
1.3.22 This section deleted in Revision 9 1.3.23 Mananer. Emernency Preoaredness The Manager, Emergency Preparednoss reports to the~ Director, Plant Projects and Support 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.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 8 of 13 Policy 1 0QAMR9A.1/SQPFLR - 12 ;
=
_ ~- ' '
'- - " ~ ^ ^ ~ ~ ^ ^ ^ ~ ^ '
- 1. 3.' 2 4 ~ .Mananer. Doerational Analvs[g- '
The Manager, Operational Analysis reports lto the Director, Nuclear'
~
' Plant : Engineering. He- is responsible for ' directing nuclear- (
safety / thermal performance analyses, reliability, reviews.and-safety. evaluations and for making independent recommendations to
' improve both plant safety and reliability as delineated in-the. !
Operational Assessment' Review Policy and Nuclear Regv1'a tory- '
requirements. .The Manager,;0perational Analysisnis responsible Lfor carrying out the activities of the'Independen't' Safety.
' Engineering Group (ISEG) as described in Technical ,
Specification 6.2.3 and in accordance with'the Operational QA' Program.
1.3.25 Manamer-. Project Mananement t
. The. Mano"er, Project Management reports directlylto' theLDirector,,
Plant P: 'ects and Support. He'is responsible.forJmanaging the
' implement ' dan of various major special projects ~andl programs as ;
may be~ port diy assigned.' These projects-involve hardware and software'impis stations and planning functions;which.
involve multiple depa -tments. He assists the: Director, Plant
. Projects and Support as assigned, in-technical-andL
< administrative matters associated with the~ Grt.,d Gulf Nuclear Station. It is the responsibility of the' Manager,' Project - i Management to assure these functions are performed in accordance with the requirements of the Operational Quality Assurance Program, s 1.3.26 Mananer. Plant Modification & Construct 3QD ,
The Manager, Plant Modification & Construction reports directly-to the Director, Plant Projects and Support. .He Is responsible for planning, scheduling, and . implemerding- design changes and-plant modifications. He is also responsible for the implementation of assigned major maintenance. lit.is the responsibility of the Manager, Plant Modification 6.
Construction to assure these functions are performed in .i accordance with the requirements of the Operational Quality Assurance Program.
p 1.3.27 Mananer. Nuclear Desinn
- The Manager, Nuclear Design reports to tho' Director, Nuclear i Plant Engineering and is responsible for managing the <
activities of the Civil, Electrical and Mechanical Engineering ;
' disciplines of the Nuclear Plant Engineering Staff to-ensure- '
that design control and technical assistance is provided in the.
areas of plant design, design review, modifications and.
chemical / metallurgical / environmental analyses.at Grand Gulf Nuclear Station. It is the responsibility of the'Hanager, Nuclear Design to assure these functions are performed in accordance with the requirements of the Operational QA Program.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev 9a 4
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1.3.28 Mannesr. YnelheeEina'Suonort J q
The Manager, Engineering . Support reports to _ the Director,- _
Nuclear Plant; Engineering and.is responsible for. managing the- .l activities.of'the Configuration Management, Administrative ~ 9 Support,~ Drafting / Computer Aided Drafting and Engineering !
Planning _and Control disciplines of the Nuclear Plant a Engineering Staff to ensure that adequate support is given'to- ;
the Civil, Electrical,LMechanical and Operational Analysis' l disciplines for'a11Lphases of their engineering activities at- l Grand Gulf-Nuclear Station. It is-the responsibility.of the- ;
Manager,: Engineering: Support to assure these functions'are performediin-accordance with the requirements of the Operational QA Program..
.c 1.3.29 Vice President. Human Resources & Administraiinn; 2
'The Vice President,_ Human Resources & Admi.41stration reports directly to the President 6. Chief Execu+.ve Of ficer and is !
responsible for the administration o# all functions associated.
with Corporate: Services. He dela;;tes authority _and responsibility for the accomplishment of tt,above activities through'the Director, Corporate Services. It is the' responsibility.of the ,
Vice President, Human Resources & Administration, to assure these functions are' performed in accordance with the Operational Quality ..
Assurance Program.. <
1 1.3.30 Director. Cornorate Servf.nga The Director, Corporate Services reports directly to the Vice
- President, Human Resources & Administration and is responsible ,
for control and; maintenance of corporate direcLives, policios and procedures;' risk' management coordination; procurement of -'
safety and non-safety related items;.and, administrative '
services. He' delegates authority and responsibility through the Manager, Administrative Services and the Managcr, Purchasing. It is the responsibility'of the Director,- .
-i Corporate Services to1 assure these functions are performed in 3
accordance with the requirements of the Operational Quality Assurance Program. -
1.3.31 Executive Vice-President and Chief Ooeratine Officer The Executive Vice President and Chief Operating Officer.
reports directly to the ' President and Chief Executive Officer.
He is responsibic for administration of a funct*,ns associated with the operating and engineering ofi NS and is [
assisted by the Vice President, Nuclear OperationL, the Vice President, Nuclear Engineering & Support; and the Vice i President, Operations Support. It is the responsibility of the Executive Vice President and Chief Operating Officer to. assure requirements:of the Operational Quality Assurance Program are implemented by the organizations under his direction.
Rev. 9a OPERATIONAL QUALITY ASSURANCE. MANUAL l TITLE: ORGANIZATION I
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1.3.32; Vice President. Opgations Suonort I
, .. i The Vice President, Operations Support' reports directly.to the: '
Executive Vice President and Chief Operating;0fficer, and' is ';
responsible for the administration of~all functions associated; l l . with radiological and environmental services,land. contracts.
l He maintains a continuing; involvement in quality. assurance ;
matters and: assesses the scope, status.fimplementation'and '
o . effectiveness of the pregram through contact-with!and-review of~ ['
reports' issued by the Director, Quality Programs., It is_the ;
. responsibility of the Vica President, Operations: Support; to-
~
,}
. assure that these = functions are :performediin accordance with - ,
the requirements of the Operational Quality 1 Assurance Program.
1.3.33, Director. Plant Proiects and Suncort L The~. Director, Plant Projects and Support' reports to the-_Vice; President; Nuclear Operations:and 1siresponsible'for planning, scheduling and implementing major maintenance; managingl implementation of major special projects % d programs; and emergency preparedness. Provides' management direction;to the- 9a Manager, Plant Modification and Construction;?the Manager, Emergency. Preparedness; and the_ Manager, Project Management..
'It is-the responsibility of the Director, Plant: Projectsnd= a
- Support to assure that these functions.are performedfin.. :
accordance with the requirements.'of the Operational-Quality j Assurance Program. '
1.3.34- Senior Vice President. Planning &' Assurance.
The Senior Vice President, Planning & Assurance. reports directly to the President and Chief Executive: Officer and is responsible for directing Supplier. Quality Assurance }
l activities. He delegates through the Manager,tNuclea~r~ Safety Oversight.and his staff to assure that these activities are performed in accordance with the Operational' Quality Assurance Program. He maintains a continuing awareness of; quality '
matters through applicable reports and management: audits of the prog ram. It is the Senior Vice President, Planning'&c 98 Assurance's responsibility to assure.that the requirements of (
the Operationel Quality Assurance Program are Implemented by the organizations under his direction.
1.3.35 Manager. Nuclear Safety Oversight The Manager, Nuclear Safet> Oversight reports directly to the i Senior Vice President, Planning & Assurance andLis delegated the authority and responsibility -for assuring the performance of supplier audits and evaluations; and-development and maintenance of implementing procedure covering Supplier Quality Assurance activities. He assures safety related activities are performed in accordance with the Operational' Quality Assurance !
Program.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION .!
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h
. 'Thd priddry 'dutics tnd: rasponsibilitiss cf ths Man:gsr. Nucisar Stfsty'Ovirsight includo:
,1.3.35.1. Reviewing and approving Supplier Quality' Assurance Procedures;
~
1.3.35.'2;' Maintaining adequate ~communciations with_ suppliers L
~
j contractors and Entergy 0perations' organizations;; ;
1.3.35.3. Planning and performing supplier evaluations,' source. /
quality verifications,. source inspections and ,
external audits; -
=1.3.35.4' Developing'and carrying ~out an' audit program. ..
as' described,in Policy.18.0 of this Manual',:to verify
't conformancewiththeOperationalQuality(Assurance Program requirements. '
1.3.35.5; Reporting'to:the Senior Vice President,-Planning &. '
Assurance and the President'& Chief Executive-Officer. J on the statustand adequacy of the Operations 1 Quality.
{
. Assurance Program as applicable to Supplier.. Quality =
Assurance activities. ,
1.3.36 Supplier-Quality Assurance Mansaer 9a I The Supplier Quality Assurance Manager reports'directly to the ;
l Manager,. Nuclear Safety Oversight.. He assures the performance 1
of supplier audits, surveys, assessments, product source . i inspections, evaluations and surveillances to verify lthe adequacy and implementation of quality assurance programs established and implemented by suppliers. He is also- -
responsible:for the: development, maintenas ' and contro1~of procedures that govern the supplier qual.' , -lurance 4 activities.
The primary duties and responsibilities of the Supplier Quality Assurance Manager include:
1.3.36.1 Providing for the planning, scheduling,: coordinating, performing and reporting of audit. activities; ,j l
1.3.'36.2 Providing for the planning, scheduling, coordinating, performing and- documenting of source quality verifications and source inspections, j 1.3.36.3 Providing for the performance of pre-award evaluation l1 of suppliers.
l L
1.3.36.4 Providing for the controlling, processing, tracking, disposition concurrence, and; verification of Supplier Quality Assurance deficiency documents. q OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a 'i TITLE: ORGANIZATION Page 12.of 13 Policy 1 1
0QAMR9A.1/SQPFLR - 16
1 1.3.36.5 'Providing'.for'an21yzing-Supplier Qutlity Assuranca )
d2ficisney- docursnts for trinds cnd raporting rstulto -
~
~to the appropriate levels of management.
s The Supplier Quality ' Assurance Manager is independent of. undue {
influences'and responsibilities for schedules'and costs, and. '
has sufficient authority and organizational.fr'eedom to,1dentify L quality problems,. recommend solutions and verify' implementation
~
! of solutions. .
If acceptable solutions cannot be reached he:has - _;
I the respor.sibility and authority to' escalate these' matters to- .;-
the Senior Vice President, Planning & Assurance andothe 9a: -
, President &' Chief, Executive Officer.' He hastthe authority,Eas-p delineated in the appropriate-Supplier. Quality Assurance Procedures, to initiate action.to stop. unsatisfactory, work.and' t control further processing', delivery, or installation of- j nonconforming: items or continuation of nonconforming services :l pending correction of the nonconforming condition. -
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OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: ORGANIZATION Page 13 of 13 Policy 1 OQAMR9A.1/SQPFLR - 17
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-2.0l 00ALITY ASSURANCE PROGRAM i
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' 'l
, 2.1. PURPOSE '
.. g This Policy describes the Operational _ Quality Assurance Program-
- forf the Grand Gulf Nuclear Station. '
r t 2.2. SCOPE w . , .
' This Policy describes the Operational-QualityLAssurance Program in' terms of the objectives- to be accomplished, the, requirements to 'be met, a'nd the
. implementation and control mechanisms;which have been established. The- f total program'is described throughoutLthis_ Manual.. d 2.3 APPLICABILITY i
, i
~ The requirements of the Operational QualityLAssurance Program apply _to all; individuals or organizations performing functions'during the operational 1 Phase which affect the quality 'of ' safety-related structures, systems, 4 components or services.
Operational phase functions to which the program applies l include: ._
i designing, purchasing, fabricating, handling,; shipping,Jstoring,;clea'ning, ='
erecting, installing, inspecting,:testingi(including preoperational'and' a startup), auditing, operating,_ maintaining,l repairing,Jrefueling; 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).
l .
2.4 POLICIES. DIRECTIVES. GOALS AND OBJECTIVES. l fa Corporate quality assurance policies , directives,; goals, and' objectives . .
)a-are summarized in the statement that all licensee individuals.and-organizations who perform quality-relatediactivities have personal and! .i corporate responsibility to' assure that;the Grand Gulf Nuclear Station is' designed, constructed and operated in a manner which protects.public p health.and safety, and promotes reliable and efficient operation.-
'%e Operationa1 Quality Assurance Program 'is designed .to provide the n:hanism for assuring that these policies, goals, and. objectives _.are !
achieved.
2.5 ERQGRAM DESCRIPTION i
The Operational Quality Assurance' Program, as described throughout this '
Manual, delineates the measures that assures activities which affect the l-
" quality of safety-related structures, systems, components and_ services are performed in a ce h ed manner:and_are sufficiently documented to provide objective evidence of comp 11nnce with established, requirements. j 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, directives, procedures, and instructions. These documents convey the 9a OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: QUALITY ASSURANCE PROGRAM Page 1 of 7 Policy 2 0QAMR9A.1/SQPFLR - 18
~
b ,
H licences quality ocsurancs~ philesophy cnd riquirsaants to all icvols of:
canIg20snt and to ell orstnizctions andiindividuals involvsd with.progrei implementation. The-applicable Policies of the Operational-Quality
. 'l
. Assurance, Program are mandatory for safety-related activities and'
' functions as described in this Manualb d
. 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 1of. 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 toTthis Manual' .
1 A listing of. structures / systems / components designated safety-related Isi
' 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 nonsafety M l related structures / systems / components to which the-Quality Assurance Program applies.la issued and maintained current.- 'l Nuclear Plant Engineering Iis. 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 lthat' t structures / systems / components listed ~1n the UFSAR are contained'in the- A 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 contractors, suppliers and consultants. -
l<
Development, control, and use of computer programs ~for design: controls activities as described in Policy 3 for safety irelated structures, l systems and components will be conducted-in accordance with the 4 l
Operational QA Program.
2.5.1 Ooerational Quality Assurance Manual The Operational Quality Assurance Manual: consists of quality-assurance policies, goals, and objectivesland.has b'een.
developed in accordance with applicableLregulations,. codes,.and-. i standards. It describes the Operational Quality Assurance Program and delineates tho' responsibilities and requirements
~1mposed by the program for the-performance of safety-related-activities.
The Director, Quality Programs is responsible for maintaining '
the Manual and controlling .its distribution, including revisions
.thereto, in accordance with approved Quality Assurance-Procedures.
Revisions to the Manual will be processed per 10CFR50.54(a).
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: QUALITY ASSURANCE PROGRAM i Page 2 of 7 Policy 2-0QAMR9A.1/SQPFLR - 19
<j x 255.2 Innlementine Po1 Nies O Directives.~ Procedures uct i ons. - and Instr
.The OpsrationalLQuality, the'use.of written, approved policies- Assurance ProgramLis imple
, directives, and-instructions ~generatedLby the organizations res. procedures 9a- l
~the-performance ofitheispecific functionsponsible as outlined in-for Appendix B'of this Manual'.:
The Quality Assurance. Procedure Manuale contains th implementing procedures / instructions for the performed by, Quality l Programs.:
- qualit y functions-Quality Assurance Procedures / Instructions provide measures to assure that quality-related acti.vities:are performed in a controll d' rad are documented: to; provide objective evid M th program requirements.
s e manner ence of compliance The Director, Quality Programs is responsible for implementation. approving Quality Assurance Procedures prior to-The Manager,. Quality Services and the Manager Quality Instructions;Systems are-responsiL prior; to implementation. . %-for approving_
e; Quality Assu Quality-related func'tions performed by' other; organizations a contro11ed'and' documented <in accordance with -
es procedur re prepared, approved land; controlled by the organization performing the cfun' tion.;1These procedures assure th t functions.are secomplisheu in;a controlled man. a the ner, with-specified equipment, under. suitable environmental and or. that prerequisites testing. have been-' satisfied conditions, prior to i
. nspection-whereby quality related activities at the plant _ ns- sitPlant-A those of the Plant Modification and Const e (including Training) are controlled and documented ruction Section p and toobjective evidence of compliance with program requirement rovide General Managerireviews and approvess.'allThe Plant GGNS-Ad Procedures also with the Manager, Plant Modification reviewing an'. ministrative~ &C Procedures controlang the activities' u the Pl'pproving those Plan and Construction Section. ant ' Modification Procedures provide the means; for- assuring e'.
that th-Nuclear Supp quality-related activities-of the Nuclear Support a are St ff controlled and documented to provide objective' compliance with program requirements. evidence of Director, Nuclear Support. Administrative pproved by the Procedures are rt. vi Procedures provide the means for= assuring e quality that thNuclear Licensi related activities of the Nuclear Licensing Staff are controlled and documented compliance with Program requirements.
to provide objective e id v ence of Director, Nuclear Licensing. Administrative roved by the Procedures ar Administrative Procedures provide for assuring a the th tNuclear Plant En quality-related activities of Nuclear Plant'Engin eering are controlled and documented to. provide objective e id compliance with program requirements. v ence of Engineering Procedures-are reviewedoved andbyapprNuclear the Plant.
OPERATIONAL TITLE: QUALITY ASSURANCE MANUAL QUALITY ASSURANCE PROGRAM .Rev. 9a Page 3 of 7 Policy 2 0QAMR9A.1/SQPFLR - 20
Director, Nuclear Plant Engineering. - - Th3 GGNS Gsneral' Manageri also reviews-and approves Nuclear Support Adainistrative-Procedures and-Emergency Preparedness Administrative Procedures
.which provide for effluent and environmental monitoring and, -;
Emergency Plan implementation ^.- Corporate Services:
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-compliance with program requirements. Corporate Services.
Administrative Procedures are reviewed and approved by the Director, Corporate Services. Emergency Preparedness Administrative Procedures provide the means for, assuringL that=
the quality related activities of the Emergency Preparedness Staff,are controlled and documented'to' provide objective;
~
evidence.of compliance with program requirements..-._ Emergency-Preparedness Administrative procedures are reviewed and ..
approved by the Manager, Emergency Preparedness. . Nuclear Fuels.
Administrative Procedures provide the means for assuring quality'related activities of fuel; cycle management are; controlled and documented to provide objective evidenceLof j compliance with program requirements. Nuclear Fuels = '
Administrative Procedures are reviewed and approved by;the Manager,-Nuclear Fuels. . Supplier Quality Assurance Procedures provide for assuring quality-related activities are performed:
In a contro11ed' manner ~and are documented to provide objectivel 9a' ,
evidence of compliance: with program requirements. .Supp11eri Quality: Assurance Procedures are-reviewed and approved by-the; Manager, Nuclear Safety-Oversight. _ Required quality. reviews and concurrence are performed by the Director,-Quality !
Programs,,as described in Appendix B to this Manual, j Appendix C to this Manual provides a matrix of QualityL Assurance Procedures cross-referenced to the criteria .of: Appendix .B : to s 10CFR50 which they implement.
q 2.5.5 Indoctrination and Traininn Indoctrination and training programs are established for both onsite and: offsite personnel performing' quality-af fecting activities by the organizations responsible for the accivities.. j These programs are implemented by appropriate training plans and procedures which assure that:
j 2.5.3.1 Personnel responsible for performing quality- 8 affecting activities are instructed as to the M purpose, scope and implementation of manuals, procedures and instructions; 1
2.5.3.2 Personnel performing quality-affecting activities ;
m e trained and qualified in the principles and ,'
techniques of the activity being performed;
(
2.5.3.3 Proficiency of personnel performing qual'ity- '
affecting activities is maintained by retraining, '
reexamining or recertifying; ;
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: QUALITY ASSURANCE PROGRAM l Page 4 of 7 Policy-2 q
0QAMR9A.1/SQPFLR --21 i
E R p 2.5.3.4 Tha ecopa, cathod cnd objectivs of tha training cra p- documnted;-
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. '
h 2.5.4 This section deleted in Revision 5.
2.5.5 Resolution of Discutes 3
Disputes arising _betwe_en licensee organizations on any quality.
~
j assurance matter which cannot be: resolved by management af the L involved organizations;willibe referred to the Vice' President, .
Nuclear Engineering &~ Support; the.Vice President,-Nuclear 9a Operations; the Senior Vice~ President, Planning & Assurance or. i the Vice President,' Operations' Support for resolution.
2.5.6 .Ouality Resoonsibilities Quality. responsibilities for.-the implementation of major j activities addressed in this Manual are designated in-the individual policies ~of this Manual.
2.5.7 Preoperational Testina 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 providing for preoperational testing and' plant turnover. <
The GGNS General Manager who is responsible for the administration 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 j testing, and The GGNS General Manager is responsible for the performance of startup testing,. Each and is also responsible
~
for plant turnover activities (i.e., turnover from construction testing to Plant Staff) with support supplied by the_ principal-contractors. Prior to the actual turnover, written: procedures are developed by these organizations for the control of the .I l
transfer of all portions of the plant, including documentation.
1 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 6anager is responsible for the control of the j turnover of construction records and documentation from H contractors and suppliers. L U
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a f TITLE: QUALITY ASSURANCE PROGRAM Page 5 of 7 Policy 2 l r
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2.5.8- Definitions-f Theterms~andphrases'given--in'the"Definiti6n"[ portions-ofthe g ANSI Standards endorsed by this. Program .in Appendix A 'shall
- apply as well as those'given in pertinent ^sectionsLof the ',
applicable portions of - Tit'le 10, Code of EFederal, Regulations.- '
As used throughout this Operational Quality: Assurance Program.
and its 11mplementing procedures, the followingiwords shall be ,
construed to have' the special . definitions giveni L
2.5.8.1 Shall - A; requirement considered enforceable by th(
_ . appropriate regulatory body.
u 2.5.8.2 Should - A recommendation,'but not an enforceable '
Is requirement. Management expects each employee using plant directives to carry out any "shorld" y
statement unless circumstances prevent-or:
necessitate a deviation. ;
2.5.8.3 May - An option, neither a recommendation or a requirement.
2.5.8.42 Must - A1 requirement normally established by licenseo ?
management or'may be used to meet regulatory intent, ,
2.5.8.5 Additional items are defined in' Appendib A (see under ;
-Regulatory: Guide'1.74), individual Quality: Assurance ~ i Procedures and .other quality documents.
2.5.8.6 Any words which have not been defined Lin 1 through 5 l
above or item 7 below shall.b'e as' defined:in a contemporary collegiate dictionary by atwell known
- publisher or. authority, 1
2.5.8.7 Will - Is defined the same as Shall.:
2.5.9 Ouality Assurance Position Statements Quality Assurance Position Statements are issued-when considered necessary by the- Director, Quality 1 Programs,- for use ,
l in interpretation of certain commitmentsLin.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 ,
requirements from external documents,. included inLthis Program '
by the commitments in Appendix A, within these Policies; no- ;
known conflicts exist between those commitments and these Policien. Differences arising during future' reviews or OPERATIONAL QUALITY. ASSURANCE MANUAL Rev 9a TITLE: QUALITY ASSURANCE PROGRAM l
Page 6 of 7 Policy 2 ;
l-l OQAMR9A.1/SQPFLR - 23
4 0 f
.t itplcaintetion of~ths.Progrca, cust bs brought to tha et'tention. I
.of ths' Dir:ctor, Quality Prograta who initists3 chtng23 'tice ths' , l commitments or the-Policies as necessary to" resolve the t li differences.1 The provisions delineated in these Policies shall' q take precedence over differing. requirements given elsewhere ;at until the Director, Quality Programs has evaluated theLissue '
and' determined which requirement (s) must be modified.
1
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t OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a- ;
TITLE: QUAI.ITY ASSURANCE PROGRAM Page 7 of 7 Policy'2
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?r-3.0 DESIGN CONTROL 3 '.1 PURPOSE 1
This Policy describesi he t Operational Quality Assurance Program measures-to control design activities affecting; safety-related st.ructurc , 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 ace carried out in a planned,-controlled and orderly- a manner. o i
3.3 APPLICABILITY '
i' The requirements of this Policyrapply to all organizations perform' Lng 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 accident and transient. analyses, but excluding nuclear fuel and nuclear
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core design see 3.4.5) during the. operational ~ phase'are' j delegated to the Director, Nuclear Plant Engineering. 'The GGNS. .
l General Manager authorizes the design modification.or change to- ,
l be implemented by the Manager, Plant Hodification-& ,
l Construction'. The Director, Nuclear Plant Engineering is i l responsible'for assuring that procedures are developed;and-implemented to' control the design activities of Nuclear' Plant i
Engineering in accordance with the requirements of thisiPolicy.
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) 1 and assures submittal of the design change package, including-the safety evaluation por 10CFR50.59, to the Plant Safety Review ,
Committee (PSRC). The Manager, Nuclear Fuels is 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 6 Construction is responsible (except in-cases related to nuclear fuel) for the coordination of scheduling andrinstallation of <
Plant modifications,-betterments and repairs once reviewed by i the PSRC as required by Technical Specifications. The GGNS General Manager is responsible for the scheduling and installation -i 4
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DESIGN CONTROL Page 1 of 5 Policy 3-0QAMR9A.1/SQPFLR - 25
of nuclast fhal and coro related design chtngssionca reviewid li
- by-tha,PSRC as' required by,Tcchnical Sp2cifications., Tha l Secretary of the Safety. Review-Committee (SRC) assures the-review oflthe safety evaluation by the SRC. . The Director,-
Nucle'ar 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 . '
M ponsible for complying with the requirements of.this Policy..
to'the extent'specified in the applicable procurement documents,;,
andLfor imposing them on their contractors and suppliers, as applicable. _They are also responsible for verifying, through
surveillance or audits, that the requirements are:being<
._ adequa tely : implemented.
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/ 3. 4.'4 The' Director,-Quality Programs:is responsibleifor reviewing ' ,
nuclear fuel and nuclear core (excluding accident and transient; e analyses); design. documents for compliance with Operational Quality Assurance Program; requirements and concurring.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 m verify conformance with Operational Quality _ Assurance Program requirements, including the requirements of-this Policy. mThose
' design documents include the. type design documents originated',
reviewed and approved by'the Manager, Nuclear 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 analysis activities - See 3.4.1) are delegated _to the Manager, Nuclear.
Fuels. He manages and coordinates the activities of nuclear fuel suppliers and other appropriate organizations. The Manager, Nuclear Fuels is involved.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 Manager, Nuclear Fuels is responsible for assuring that procedures are developed and implemented for.-the above design activities -in accordance with the requirements of this Policy.
3.4.6 Responsibility and authority for control of ' design -activities (including accident.and transient analyses, but_ excluding-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 implemented forLthe OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DESIGN CONTROL Page 2 of 5 Policy 3 0QAMR9A.1/SQPFLR - 26 l
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aboys'dssign setivitids in cccordance withLths' require =sntojof ;
=thioJPolicy and,will provids or concur with all "accspt-co-is"[
or " repair" dispositions (including accident and transient' l analyses, but excluding' modification'of!or; changes toinuclear- !
fuel.or. nuclear core design) for nonconformances. The '
Director,l Nuclear Plant' Engineering is responsible for: ,
reviewing'NPE> design documents for compliance with the 1 Operational ~ Quality: Assurance Program requirements andt , ;
concurring with the'same.. '
3.4.7 The Manager,; Nuclear , Safety Oversight has .the responsibility::
for carrying out an audit program as describedf ir.' Policy:18.0;.
of this manual',~to verify;conformance with the requirementsfof. 9a the. Operational-Quality Assurance Program, including the ',
requirements,of this' Policy. ,
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3.5 REQUIREHENTS L
3.5.1 ' Organizations having design responsibilities shall develop.
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procedures, consistent;with the. scope of their responsibilities,;
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to provide measures for.the control of their,designfactivities.-
1 3.5.2 Procedures shall be developed to assure that applicable des'ign:
i- inputs such as' design bases, regulatory requiren'ents,. codes-ande standards are= identified.and documented, and'are correctly; 3 translated-into design output documents.such:as' specifications, 1 drawings, procedures and instructions.
n 3.5.3 Procedures shall provide for the identification and documentation -
- of appropriate quality standards to be specified ln the design ,
documents. Deviations and changes from these. quality standards 'l l shall be controlled. !
3.5.4 Procedures shall include measures for: the control- of. design .t 4
analyses such as reactor physics, seismic, stress, thermal, j o
hydraulic, radiation, and accident analyses; compatibilitylof~ J materials; accessibility for inservice l inspection, maintenance, <j and repair. i l
3.5.5 Provisions shall be made in the'proceduresffor 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.
3.5.7 Materials, parts and equipment which are standard,' commercial (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.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DESIGN CONTROL Page 3 of 5 Policy 3 l
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- 3 .~ 5 . 8 - Procedures. cha11' provida fer; ths control of design interfscss s ij for cen ging ths flow of_drsign infor22 tion bstwasn*
p; , . organizations. Systematic' methods shall be' established for-l'
communicating;needed design information across the interfaces, including' changes to the design-information;as-the work i progresses.'
3.5.9; Procedures = shall-include requirements to verify that the designi is adequate and that it meets'the-specified design inputs.=;The extent:of the ' design verification required shall be a ffunction.
~of the ieportance.to. safety of the11 ten, the complexity of the a design, the' degree of standardization, the st' ate-of-the-artland- l the similarity with previously proven. designs. In;eachEcase' }
- however, standardized or!previously proven designs"shall be '
. reviewed Lfor applicability prior; to usek t
c 3.5.10 Acceptableverificationmethodsishallincludekbut'notbk
' limited'to, design reviews,-alternate. calculations, Lor
- qualification testing. . If a testfprogram
- isLused to: verify the L adequacy of a. design,: qualification testing'of's prototype unitz L under- the -most adverse design conditions' which are appropriate, shallibe used, i.
Individuals or groups responsible for design _ reviews orlother
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'3.5.11 verification activities'shall be identified:In:the procedures' and their authority and responsibilityishall bel 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 belfrom the same organization. ,
This verification may be performed by the originator's supervisor provided the supervisor is the only technically qualified. individual available and the appropriate clarification l- provisions listed in Appendix A to this Manual ~are met. '
L L 3.5.12 Design'and specification changes, including'.those originating 1 onsite, shall be subject to the same degree of controliasithe, original design and approved by the1 original design' organization. '
unless _ another qualified, responsible organization is: "'
specifically designated.
3.5.13 Errors and deficiencies in the design process, includingDcomputer programs, that could adversely affect safety-related structures, systems or components shall be documented, and co~rrective action taken to preclude repetition.
3.5.14 Proposed modifications or changes which involve an unreviewed safety question or a change to the technicalispecifications: 1 shall be handled in accordance with procedures which address the; requirements of 10CFR50.59.
3.5.15 Design records shall be maintained by_ the GGNS General Manager in accordance with Policy 17.0 of this Manual.
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3.5.16 This-Ssctirn Dalsted in.Rsvision.4.
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Plant' Procedures are provided to assure that responsible plant; j
!. ~ personnel are made aware of design changes / modifications-which may directly~ affect the' performance of their duties. ;
315.18 During operational phase activities lof.a. unitf and while the '
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A-E/ Constructor or his suppliers are performing. design cut j construction activities-for that unit, another unit, or1for ]
. shared facilities;at GGNS, the'11censee may choosc'-to purchase. l similar services (i.e'. ' design or~ construction)-for the operating' unit (s). If such services are purchased- ~r
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' 3. 5.18.~1 They'shall be procuredjin accordance with'the. "
(requirements.of> Policies.4.0 and:7.0 and ANSI , i N45.2.13 (as modified and included'in Appendix A-of
.the OQAM); '
i 3.5.18.2 ' They 'shall be in 'accordance with the QA program (A-E/ Constructor's or his-suppliers') in-effect for similar activities on other-or.the same' unit (s).or for shared facilities; and
+ 1 L 3.5.18.3 The A-E/ Constructor's QA Program shall be reviewed byr
.the licensee's Supplier. Quality Assurance to assure ,
that any. additional requirements'which are. considered- !"
-necessary to assure quality' have -been included..
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4.0- PROCUREMENT DOCUMENT CONTROL
'4.1 PURPOSE This Policy describes the Operational Qtiality' Assurance Program measures -
to control procurement documents' for: safety-related material. equipment-and services for the Grand Gulf Nuclear Station.1 4.2 SCOPE This Policy. delineates responsibilities and defines. requirements for
= Procurement document preparation, review,': approval and-change'controlxin' order to assure that purchased safety-related. items and services will- i conform to established, specified. requirements.
4.3- APPLICABILITY
.The requirements of this. Policy apply to all procurement documents. for -
safety-related material', equipment 1and services! purchased by;or-for the 1 licensee during the operational- phase of. nuclear power plant' activities. . 1 4.4 ESPONSIRILITY l
4.4.1 All' organizations' participating in the preparation of .j :
procurement documents for safety-related items and services
'j during the operational. phase are responsible for developing' i their own procedures or using generic procedures. In either- ;j case procurement 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' Mar.ager is responsible for ons'te i procurement document control. He is responsible for assuring. procurement ,
activities performed by the Plant-Staff are procedurally .j controlled in accordance with the requirements of this Policy.-
This includes preparation, review, approval'and' issue of-procurement documents, j
i 4.4.3 The Manager, Quality Services is responsible:for 9a-
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performing 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 procedures for procurement document control to assure ]
that-they addtess the applicable. requirements of this Policy.. '
4.4.4 1 The Director, Nuclear Support and' Director, Nuclear Licensing j are delegated the responsibility -for. assuring that general i office procurement activities performed by_the. Nuclear Support !
Staff and Nuclear Licensing Staff respectively, are procedurally controlled in accordance with the requirements of this Policy. {
-1 This includes preparation, review, approval and Issuance of '
procurement documents.
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T 4.4'.5 . Orgtnizitlona. supplying catsrlal, equ'ipasnti orssrvicts 'srs responsibis for co: plying with the cpplicablo requirteento 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.
4.4.6 The Director, Quality; Programs is responsible for a'ssurl'ng implementation of procurement document control measuresLand;for, quality review-of procurement documents and procedures,.,!The-Director,-Quality ProgramsLand'the Manager, Nuclear Safety. 9a Oversight are'also responsible for carrying out.an audit' program, as described in Policy 18.0 of.this-Manual', toiverify conformance with- Operational Quality Assurance Program-requirements, . including the requirements of this Policy.
4.4.7 The Manager, Purchasing and.the Manager, Contracts.are responsible for performing procurement activities,Lin 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; '
-l the Director, Quality Programs; the Manager,-Plant Modification; l
& Construction; the Director, Corporate Services; the! Manager, 9a d Nuclear Safety Oversight;.and .other appropriate personnel as' delineated in appropriate procedures.
4.4.8 The Director, Nuclear Plant Engineering is responsible.Lfor !
essuring procurement activ'it'ies. performed ~by the Nuclear Plant 5 i.ngineering Staff _are procedurally controlled -in laccordance with ;
the requirements of this Policy. This includes preparation, '
l 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, Plant Modification & Construction is responsible for assuring procurement activities to support.the implementation 1 of design changes and plant . modifications are procedurally i controlled in accordance with the requirements of this. Policy.
This includes preparation, review, approval and Issue of' L procurement documents. ' ,
- 4.4.11 The Manager, Nuclear Safety.0versight is responsible l for
assuring procurement activities performed by. Supplier Quality
' Assurance staff are procedurally controlled in accordance with the requirements of this. Policy. This includes; preparation, 9a review, approval, and issue of procurement documents..
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4.L REOUIREMENTS 4.5.1 Procedu'rasehh11basatiblichedbythareaponsible t
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organizations to clearly' delineate:the sequence of actions to .
L be accomplished to control the preparation, review, approval =
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l l and' issuance ~of procurement-documents for safety-related items p .and services.~ 1 4.5.2: The' proceduresshall assure that procurement' documents issued' l'
at all levels of procurement include provisions;for the j following,las applicable:
a' 4.5.2.1 'A statement of the' scope ~ofJwork to'be. performed by the contractor or' supplier;. l l
4.5.2.2- Identification of the design'basisi echnical t
' requirements.by reference to specific drawings,; '
specifications, codes, regulations, indust;ial' _
sta'ndards or other documentation,? including revisions- i thereto,- that describe the items or services- to be .
- furnished; 4.5.2.3' -. Identification.of test, inspection.and: acceptance -3
' requirements, and any special instructions and 1
, requirements for such activities as design,- '
fabrication , ' identification, . cleaning,'- erecting,
- packaging, handling, shipping and. extended storage; J 4.5.2.4- Identification of the. quality assurance program ,
requirements which must be complied with by the i contractor or supplier;
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l 4.5.2.5 Stipulation that the provis' ions of 10CFR21 apply; I
4.5.2.6- Identification of the documentation, such as! drawings, l specifications,-procedures', fabrica. ion 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 the licensee:for review and-approval; l- 4.5.2.7 Identification of those. records to b'e retained, !
i controlled and maintained.by the supplier or contractor and.those t'o be delivered to.llcensee prior to use or installation of the procured item; 4.5.2.8 The licensee's right'of access to the supplier's facilities and records for source quality verification, inspection -and audits, as . deemed-necessary; 1 3
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'4.5.2.9 Extinsinn of cpplicabla requirtesnts' to lowar ' tier
-aubcontrccters cnd'eupplisro,: including tha .
licensee's right of access to facilities and records;;
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4.5.2.'10. Subject to the clarification of'ANSILN45.2.13,.
if" '
Section 8.2,- given in Appendix A of .this1 p'rogram, 7
reporting and approving the " Accept-as-is or. 1
'" Repair" dispositions' of;nonconformances';.
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4~.5.2.11' The licensee's right to hold shipmentLif-
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procurement document requirements', including.those.
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for documentation, have not beenl fulfilled.
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4.5.3 1The procedures shall assure thatLprocurement documents are y subjected to technical:and quality reviewfby qualified / , ,
y personnel and are-approved by. designated individuals prior ~to 3 Issuance. The. review and approval shall be documented 1and '
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( , available for verification.
4.5.4 Review and concurrence with the adequacy of quality requirements- ,
shall include verification that the: requirements-are correctly.
! . stated, inspectable and controllable; that.there are adequateV acceptance and rejection criteria;:and.that:the procurement ,
documents have been prepared, reviewed and' approved;in accordance>
with the requirements of this, Policy.
l 4.5.5' Changes or revisions to procurement. documents shall be subjected' to an equivalent review and approval as the o'riginal documents, J and such review and approva1Esha11~be. documented.: Exceptions.to~ ,
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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 systessinhall be subject'to control at 1. ast equivalent to those! required for purchase of original .
equipment, or those specified by a properly reviewed and-approved revision to the original: requirements.~ :
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5.0 -INSTRUCTIONS 2 PROCEDURES AND DRAWINGS' I I
, 5;1' EVEEDSE'- :
- r This Policy describes lthe: Operational Quality Assurance Program measures to assure that allfactivities affecting the quality or safety of the
' Grand Gulf Nuclear. Station are prescribed and accomplished ~in accordance with documented : instructions, procedures, drawingsL or other documents appropriate to the circumstances. '
5.2 SCOPE '
This Policy. delineates responsibilities and definesfrequirements for'the: I
. development and implementation of measures designed to assure that safety-related activities are prescribed and accomplished in -accordance j with documented -instructions, procedures or drawings. .'l 5.3 APPLICABILITY '
The requirements of this Policy apply to all individuals.or organizadions; l performing activities which affect the quality of safety-related items =
during the operational phase of nuclear power.. plant activities.E ' '
i 5.4 RESPONSIBILITY '
f 5.4.1 'A11' organizations performing activities during the operational.
phase which affect the quality of safety-related structures,-
systems and components are responsible for performing'these oa activities in accordance with directives,_ documented: 9a : 'g instructions, procedures or drawings. It is-the' responsibility:
of the _ managers of these. organizations to assure the development, review, approval .and' control of directives, - 9a instructions, procedures and drawingsinacessary to control their safety-related activities in accordance with the ';
requirements of this Manual.
I It is the responsibility of'th'e Vice President, Nuclear 1 Engineering & Support; the Vice President, Nuclear Operstions,.
the Vice President, Operations Support;iSenior Vice President,:
Planning & Assurance; and, the Vice President,. Human Resources' 9a'
& Administration to ensure that those instructions', policies, procedures and drawings that cross internal-organizational lines integrate and function in accordance with the above.
[ 5.4.2 This section deleted in Revision 3.- S 5.4.3 During the operational phase, the GGNS General Manager is responsible for assuring that adequate inspection plans; test.
[ calibration, special process, maintenance, test and repair -
t procedures; drawings, specifications and other safety-related j documents and revisions thereto are ised. During the implementation of design changes and plant modifications, the Manager, Plant Modification &' Construction is responsible for '
P suring that inspection plans; modification procedures; '
drawings, specifications and other safety-related documents and appropriate revisions thereto are used.
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Prc p3rotirn31 phnso tcsting is.tha rc:ponsibility of tha Unit 2 Construction Sup3rintendant. Tha Dirict:r, Quality Progrc s !
is responsible for the performance of neudestructive examinations.
The Matager, Quality Eervices m. responsible for performing the h
quality review of procabrea/iastructions, and determining that >
the necessary QA requis ;ts are included. He is responsible ;
for determining the nee / for inspection requirements in work .
documents. Documents w ich contain administrative controls i which specify quality a.tsurance requirements will also be (
reviewed by the Manager. Quality Services. Lower tier !
docueents (section procedures / instructions) may be reviewed by ;
individuals (other then the preparer) of:the organization '
preparing the documents if such individuals have been irJoctrinated in the Operational Quality Assurance Program. ;
h e Director Quality Programs is responsible for ;
indoctrination and certification of these individuals. >
0 . ': . 4 The Director, Quality Programs and the Manager, Nuclear Safety Oversight are responsible for reviewing and/or approving 9a in tructions, procedures or drawings as indicated in Appendix B.
of t61s Mar.ual ano for' carrying out an audit program, as j described in Policy 18.0 of this Manual, to verify confor. nance -
with Operational Quality Assurance Program requiresents, including the requirements of this Policy.
5.5 REOUIREMENTS S
5.5.1 Written instructions, procedures, drawings, or other documents '
appropriate to the circumstances shall be used to provide [
measures for complying with the requirements of the Operational ;
Quality Assurance Program. '
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, 5.5.2 Directdens commensurate with the nature of the activity shall be [
l prescribed in instructions, procedures and/or drawings for the
' performarce of activities affecting quality. The activities ,
shall then be performed in cccordance with the instructions, '
procedures and/or drawings.
5.S.3 Instructions, procedures or drawings shall include quantitative !
and/or qualitative acceptance criteria for verifying that the i activities have been satisfactorily accomplished. l 5.5.4 Thw tesponsible organizations shall establish procedures which deflue responsibilities and c1carly delineate the sequence of ,
actions to be accomplished in the preparation, review, approval !
)- and control of instructions, procedures, or drawings, and i l changes thereto. :
l: 5.3.5 Safety-related administrative procedures must reference documents i i used in their preparation. ;
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r 5.5.6 Wh:n tha NRC ace: pts ch:ng s to o 'poliby cr' cn -cpp:ndix which rcsult in mora rcstrictiva requirements, affceted icplem:nting Procedurcs cust be issued cr r; viced within 120 days. If i procedures cannot be revised or issued within 120 days, the manager of the affected organization (s) must' approve a schedule i detailing when the required changes will be accomplished. 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 the licensee's response to the Bulletin or Order or as set forth in tie Regulation. The more restrictive time frame shall be met.
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6.0 I DOCUKENT CONTROL' 6.1. PURPOSE i This Policy describes the Operational Quality Assurance Program measures to control safety-related documents for the Grand Gulf Nuclear Station.
6.2 SCOPE I This Policy delineates responsibilities.and defines requirements for the review, approval, issuance and control of documents and changer revisions thereto, which prescribe all activities affecting gi iHi ;
safety.
6.3 APPLICABILITX !
The requirements of this Policy apply to all individuals or orgar.izations a performing functions which affect safety-related structures, systems or' i components during the operational phase of nuclear power plant activities. l e
6.4 RESPONSIBILIII $
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 j 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 procurer.ent :
documents, and fcr imposing them on their contractors and '
supplice s, as applicable. They are also responsible for assuring, through surveillance or audits, that the requirements '
are being adequately implemented.
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6.4.3 This section deleted in Revision 4.
6.4.4 The Director, Quality Programs and the Manager, Nuclear
- 3a Safety Oversight are responsible for monitoring document .
control activities and for carry ngj 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. 1 6.5 REOUIREMENTS -
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.
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6.5.2 Tho procedur:0 chall identify tho decur:nt3~to be c:ntrolled.
As a cini:um..th:y shall includa: ,
Design Specifications Design. Manufacturing, Construction and Installation Drawings ,
L Procurement Documents Quality Assurance Manuals, Procedures and Instructions Operatint, Procedures t
Operating and Specisi Orders !
Maintenance and Modification Procedures '
Manufacturing, inspection and. Test Procedures >
Equipment and Material Control Procedures i
Refueling Procedures i Updated Final Safety Analysis Report Design Change Requests / Packages Design Change Notices Quality Deficiency Documents !
Q-List 6.5.3 The procedures shall specify the indiv Juals or organizations 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
- document.
6.5.5 Documents shall be approved for issue by authorized personnel 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 status of instructions, procedures, specifications, drawings and procurement documents.
The lists shall be available to tes>onsible personnel to preclude the use of superseded docutents.
l OPERATIONAL QU/.LITY ASSURANCE MANUAL Rev. 9a TITLE: DOCUMENT CONTROL Page 2 of 4 Policy 6 DQAMR9A.1/SQPFLR - 38
6.5.7 Docurnts required to p;rform a cp:cific activity chall bo !
cvallcblo at the location whsro the cctivity is to b3 ,
performedprior to commencement of the activity. Cancelled, -
deactivated or superseded documents shall be controlled to }
prevent their inadvertent use.
5.5.8 Unless t'.elegated to other appropriately qualified organizations.
changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval. 5 6.5.8.1 Changes shall be included in the documents (i.e. , !
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 o iginal document in a timely manner as defined 'oy Quality Programs. '
6.5.8.2 Prior to issuance of-an Operating License on Unit 2, 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 un1 w 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 dependant on the type and complexity of the activity involved, l
6.5.10 Subject to the clarificat un of ANSI N18.7-1976/ANS 3.2, Section 5.2.15 given in Appsndix A of this program, 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. LA revision of the procedure constitutes a procedure review. The two year cycle began on June 16, 1982 with issuance of the Operating License for Unit 1.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: DOCUMENT CONTROL Page 3 of.4 Policy 6 +
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6.5.11 Fa11owing any.dodification to e pla:t.cystco cnd prirr to )
. initicti:n of ' azy cctivity cf fccted by tha modific; tion, the ,
applicable procedures shall be reviewed to determine if changes- l are required.'
6.5.12 A documented review of applicable procedures shall be performed !
following an. accident, an unoxpected transient, significant operator error, or equipment malfunction which results in a reportable event, to determine if changes are required.to prevent recurrence.
6.5.13 Review and approval of documents, and changes thereto, shall be documented to the extent necessary to provide evidence of compliance with the requirements of this Policy.
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r 7.0 CONTROL OF PURCHAEED MATERIAL. EOUIPMENT AND SERVICES 7.1 PURPOSE r
This Policy describes the Operational Quality Assurance Program measures i to control the procurement of safety-related' material, equipment and services for the Grand Gulf Nuclear Station.
7.2 SCOPE 3
This Policy delineates responsibilities and. defines reqtirements 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 i plant activities, and to all individuals or organizations participating in ',
the procurement of such items or services.
t 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 3 Programs; the Director, Nuclear Plant Engineering; the GGNS "
General Manager (for pont modification, startup testing and operstions); the Director,. Corporate Services; the Manager, Plant Modification & Construction; the Manager Nuclear Safety 9a Oversight; and the Manager, Project Management. 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 l evidence of quality furnished by the supplier; source l
' Inspection; audit, and/or source quality verification; examination of items upon delivery.
l l 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 l
verifying, through surveillance or audits, that the requirements are being adequately implemented. e 7.4.3 The Director, Quality Programs is delegated the responsibility for assuring implementation of procurement activities at the Plant site. lie is responsible for inspection as necessary to l
assure compliance with the requirements of this Policy.
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OQAMR9A.1/SQPFLR - 41 i
7.4.4 Th3 Directsr, Quality Progrc s is rcsponsiblo fcr casuring tha
~
icplcc r.tation ef Operati:nal Quality Asturcnco Progr:2 ;
requirements relative to procurement activities and an audit 9a l 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.
7.4.5 The Manager, Nuclear' Safety Oversight is responsible for l assuring the implementation of Operational Quality Assurance
]
Program requirements relative to procurement activities, 9a i including: the quality evaluation of suppliers', source inspection, source quality verification, and an audit program, ;
as described in Policy 18.0 of this manual to verify ,
conformance with the Operational Quality Assurance Program' 1 requirements, including the requirements of this Policy.
7.5 REQUIREMENTS l
7.5.1 Measures shall'be established, implemented and documented by the appropriate organizations,-consistent with their scope of 7 responsibilities, to assure that purchased material, equipment and services, whether procured dirr tly or through contractors, conform to the procurement documer, ,. 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, i
7.b.2.2 Review and evaluation of historical quality performance data; 7.5.2.3 Source qualification programs; 7.5.2.4 Source quality surveys; 7.5.2.5 Through the use of Nuclear Procurement Issues Committee (NUPIC) audits indicating a program meeting appropriate requirements. A copy of.the qualifying 9a audit report shall be obtained and reviewed for adnquacy and applicability prior to selection.
7.5.2.6 Through the NRC's " Licensee Contractor anc! Vendor :
Inspection Status Report" (white book) for i contractors with IE Ictters confirming' Quality Assurance Program implementation; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CONTROL OF PURCHASED MATERIAL, 2 EQUIPMENT AND SERVICES Page 2 of 5 Policy 7 !
OQAMR;A.1/SQPFLR - 42 !
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a 7.5.2.7 Thrn gh docuzented inf:rmatirn rcc 1ved from cthers (archittet- ngincor, NSSS supplier, eth;r utilitics, 4 ASME, etc.) indicating a. program meeting appropriate !
Quality Assurance Program requirements. l
':he procedures shall specify the organizations responsible for !
performing technical and quality evaluations, the metnods of evaluation and the criteria for supplier acceptanc9. j To facilitate pre-award supplier evaluation, t'elephone surveys may be conducted by Supplier Quality Assurance as-established by Supplier Quality Assurance Procedures. Other means of 98 supplier pre-award evaluation are also established by Supplier 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).
I 7.5.4 Results of supplier evaluations shall be' documented and retained '
on file. Any deficiency identified during a supplier evaluation ,
shall be resolved early enough in thu procurement cycle to
( prevent _the deficiency from adversely affecting the quality of l the purchased product or service.
7.5.5 Procedures shall be established to provide for evaluation and verification activities such as source inspections, source l quality verification or audits, as necessary, to assure the i
quality of the item and to verify supplier conformance to l pt>curement document requirements. j 7.5.6 Inspsetion procedures shall specify the characteristics or processes to be witnessed, inspected or verified,_ and accepted.
The mathod of verification and the extent of documentation rec;uired; 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.
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7.5.7 Th3 cxtent tnd frequ:ncy cf cvaluaticn cnd v rificatitn activitica shall b3 a functi:n cf tha rcictiva 1 port:nca,-
complexity 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 of an item to procurement requirements can be verified by receipt inspection, review of test reports, or other means.'
7.5.8 Receipt inspection of supplier-furnished items shall be !
procedurally 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!
predetermined instructions prior to installation or use;1thati l inspection records or certificates of conformance are available i at the plant site prior to installation or use of the item; and, that items accepted and released are identified as to their i inspection status prior to storage or use, i Prior to issuance of an Operating License (OL) for Unit 2, Startup may install equipment or parts for which_all documentation has not yet been received at the plant sitet such installation and use will be on a " risk basis" such that a failure to subsequently receive all of the required documentation 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 L
function.
- Controls in Plant and Quality Assurance Procedures will' cover the conditional release process,-and will assure that the applicable procedural and administrative aspects of this Policy (7.5.8) and Policles 8.5.8,14.5.5 and 15.5.5 of ~ the Operational Quality Assurance Program are fulf.111ed.
l 7.5.9 Records required to be furnished by the supplier shall be l 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 licensee organizations may be used when their areas of expertise provide an adequate basis for such a review. (e.g., Nuclear Fuels could review records i 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 nonconformances dispositioned " accept-as-is" or " repair".
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7.5.11 Wh:ro cupplior cartificatcs cf c:nferscnc3 cra used to id:ntify 5 tha requirectnts c:t by tha it:2, tha cortific0tts 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 tie original item, or those specified by a properly reviewed and a pproved revision to the original requirements'.
7.5.13 When a supplier is removed'from the Qualified Suppliers List, procedures shall assure that any outstanding purchare orders for that supplier are. reviewed, and appropriate action :aken to assure that materials subsequently received from that supplier are handled and dispositioned as nonconformances.
7.5.14 This section deleted in Revision 6.
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OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Page 5 of 5 Policy 7-OQAMR9A.1/SQPFLR - 45
4 t 8.0 IDENTIFICATION AND CONTROL OF MATERIALE; PARTS AND COMPONENTS I I
8.1 PURPOSE :
This Policy describes the Operational Quality Assurance Progrem measures !
to provide for the identification and control of safety-related material, '
parts and components for the Grand Gulf Nuclear Station.' i 8.2 SCOPE l
This Policy delineates responsibilities and defines requirements for the identification and control of safety-related items in order to. assure that j only correct and accepted items are used or installed.
t 8.3 APPLICABILITY '
t The requirements of this Policy apply to all individuals or organizations '
participating in the procurement, fabrication, receipt, storage, t installation,. operation, modification er repair of safety-related items during the operational phase of nuclear power plant activities. ,;
8.4 RESPONSIBILITY I i
8.4.1 Responsibility and authority for the identification, control- i and testing of materials, parts and components during the.
- operatinnal phase are delegated to the GGNS General Manager -
except, during implementation of. design changes and plant- -
modifications, the Manager, Plant Modification & Construction is responsible for this activity. Theylare. 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 responsibic 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 Services is delegated the responsibility 9a for assuring implementation of identification and control =
requirements for items at the plant site by receipt inspection and other inspections. The Manager, Quality Services is 9a responsible for reviewing procedures and work documents to the extent necessary to verify conformance to the applicable requirements of this Policy.
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8.4.4 Tha Directcr, Quality Prt:grc:s cnd tho Man g:r, Nuclser 9a Safety Ovaraight h:va tha responsibility fer c rrying cut cn 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 I
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 subassemblies, in order to assure that only correct and-accepted items are used and installed.
- 8. P. 2 The procedures shall be developed by the appropriate-organizations 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
-identification'of items is maintained, such as by part number, serial number, heat number, drawing identification number or i 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. -
l 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, unembiguous 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 r.re substituted.
8.5.8 Procedures shall provide for the verification and documentation 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, OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS Page 2 of 3 Policy 8 0QAMR9A.1/SQPFLR - 47
cub ystca, cr' compon:nt fer~ fulfilling thoir int:nded cafoty function. ,Tho.M: nag r, Quality S rvic:s 13 rt ponsiblo f:r 9a I rcvicwing cud cincurring with conditional r: leases. 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. i l
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9.0 CONTROL OF SPECIAL PROCESSES '
9.1 PURPOSE '
This Policy describes the Operationr. luality Assurance Program measures to provide for the control of safety related special processes for the - 'i Grand Gulf Nuclear Station. '
9.2 SEQfE 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 contral of special !
processes, except nondestructive examination, at the-plant site during the operational phase are delegated to the GGNS General ,
s Manager. During the implementation of design changes and plant modifications, the Manager, Plant' Modification & Construction 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. 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 special processes shall be subject to the applicable requirements i 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 1 stipulated in Policy 4.0 of this Manual.
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l 9.4.3: Tho M:nrgor, Quality S rvices is rcsp nsiblo fcr rcvicwing'Plcnt Adainistrativo Procedurco cnd Nucle:r Plant Engineering Procedures, controlling special processes, and for. reviewing work documents and inspection of special process activities, including nondestructive examinations, to the extent necessary to verify'conformance to the requirements of.this Policy. H 9.4.4 The Director, Quality Programs and the. Manager, Nuclear 9a Safety Oversight have 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 with 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. lie is also responsible for reviewing and approving all contractor special process standards prior to use at the Plant Site.
9.5 REOUIREMENTS 9.5.1 Procedures shall be d sveloped and implemented by the responsible l organizations to assure the control of special processes including, but not limited to, chemical cleaning,' heat treating, welding and nondestructive examination. ]! ;
9 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 j
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.
i 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.
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10.0 INSPECTION f
10.1 PURPOSE '
This Policy describes the Operational Quality' Assurance Program .
measures to provide for the inspection of activities 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 operational 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 '
i the operational phase are delegated to the Director, '
Quality Programs and the GGNS General Manager. D7 ting the implementation of design changes and plant _ modifications,
- the Manager, Plant Modification & Construction, in conjunction with the Director, Quality Programs, is responsible for 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 Ccneral Manager and the Manager, Plant Modification &
Construction (for implementation of design chsnges and plant modifications) are responsible.for assuring that measurements and tests of materials, products or activittas are performed and documented for each work operation where necessary to assure quality.
10.4.2 The Manager, Quality Services is delegated the responsibility for assuring that the onsite inspection pr') gram (including rnceipt inspection) is carried out in accordance with the requirements of this Policy. The Manager, Quality Services is responsible for reviewing l9a Plant Administrative Procedures which control work instructions, modification and repair instructions; OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: INSPECTION Page 1 of 5 Policy 10 OQAMR9A.1/SQPFLR - 51 '
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prc:perational cnd startup test precedurcs; cnd cth0r
- nocu :nts to c cura th;t thry contcin tha cpprcpriato inspection requirements. The Manager, Quality Services is ;
responsible for developing procedures for the performance '
of all quality inspections. The Manager,' Quality Services 9, is responsible.for implementing inspection procedures.
The coordination of activities concerning the training and i
certification of all quality inspectors shall be accomplished by.the Director, Quality Programs; Level III !
inspectors are-appointed. All safety-related work :
authorizat ions will be reviewed, as defined by the '
appropriate implementing Administrative Procedures, by the Manager, Quality Services for determination of any. quality 1 inspection requirements. . Procedures or work authoriaing
. documents which control repetitive tasks are reviewe6- l
-initially and when revised for inclusion of inspection r requirements. The Manager, Nuclear. Safety Oversight la !
delegated the responsibility for assuring that the sourcs 9a inspection program is carried out in accordance with the requirements of this policy. I 10.4.3 The licensee may delegate the. responsibility'for implementing certain portions of the inspection program to other organizations.
j However, the 11cansee retains the-ultimate responsibility for assuring'that all aspects of the inspection program are~ carried out. At the plant site, the Manager, Quality Services is responsible for assuring that inspection activities assigned to outside 96
! organizations are accomplished in accordance with the '
requirements of this Policy.
- l 10.4.4 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 l
contractors and suppliers as applicable. They are also responsible for verifying, through surveillance or audits, ,
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that the requirements are being adequaiely implemented. '
10.4.5 The Director, Quality Programs and the Manager, Nuclear 9a Safety Oversight are 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.
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OQAMR9A.1/SQPFLR - 52 -
20.5' REQUIREMENTS t 10.5.1 Inspection requirements shall be included in applicable specifications, drawings, procedures, instructions or i
other documents which prescribe and control safety-related l activities.
l l 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 Procedures, which verifles that the activities are accomplished in accordance with the. specifications, drawings,. procedures or instructions.
10.5.3 Inspection procedures, instructions or checklists shall include provisions, as required, for the following:
10.5.3.1 Identification of characteristics and activities to be inspected; l 10.5.3.2 Identification of the individuals or organizations t
responsible for performing the inspection
- activities; 4
l 10.5.3.3 Identification.of acceptance and rejection j criterja; i
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.-
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Accuracy may be specified by. requiring a specific model or type of instrument.
. i 10.5.4 The applicable drawings and specifications shall be available for use with the inspection procedures, instructions or checklists when an inspection operation is being carried out. f 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 activities (work functions associated with normal operation of the Plant, routine maintenance', and certain technical services routinely assigned to the onsite operating organization)
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: INSPECTION 3
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cry be conducted by cocInd-lin sup;rvictry parstnn21 or by eth r qualified per;tnn31 n:t cssigned firot-lina 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:
1 10.5.5.1 The quality 1of the work can be demonstrated through a functional test when the activity involves breaching of pressure retaining items; ;
r 10.5.5.2 The qualification criteria for inspection
. personnel are reviewed and found: acceptable by Quality Programs 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, l and their qualifications and certifications shall be documented and kept current. .
10.5.7 If mandatory inspection hold points are required, the [
specific hold points shall be specified.in the appropriate drawings,. specifications, procedures or instructions.= The ;
inspection program shall provide assurance that work doer. a not progress beyond the hold point until released by the -
designated authority, and that required notification apj -
acknowledgement has been satisfied prior to work 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 I without both, l
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, identification of ,
I inspection personnel, and documenting inspection results.
1 l 10.5.10 Modifications, repairs and replacements shall be inspected in accordance with the original desiga and inspection requirements or documented engineecing approved alternatives.
l 10.5.11 Inspection data and results sbill be evaluated by designated i Personnel to assure that the inspection objectives have been met and that items requiring action or follow up are l 3dentified and documented.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: INSPECTION Page 4 of 5 Policy 10 OQAMR9A.1/SQPFLR - 54
10.5.12 R:ctrd shall b) kept in sufficiant d:t"il ;to provida t cdequata confir:3 tion cf tha in:p;ctirn progrca. R:ccrds shall be maintained in accordance with Policy 17.0 of this Manual. ,
10.5.13 Inspection: need not be performed for each specific work-activity. Procedures used for assigning inspections shall ,
roquire the_following to be evaluated in assignment of inspections.
.i 10.5.13.1 Complexity, magnitude or criticality of the work.
- 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 ,
Services.
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11.0 TEST CONTROL 1141- PURPOSE I This Policy describes the Operational Quality Assurance Program; measures to control testing of safety-related' structures, systems and components for the Grand Gulf Nuclear Station. '
11.2 SCOPE This Policy delineates responsibilities and defines requirements for l thie 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 a11' testing performed on safety-related structures, systems and components during the "
operational phase of nuclear power plant activities and also to ;
required preoperational testing..
11.4 RESPONSIBILITY 4 11.4.1 The responsibility and authority for the development and ;
I implementation of maintenance and surveillance testing ,
programs during the operational phase are ' delegated to the GGNS General Manager. The GGNS General Manager is.also
- responsible for the development and implementation of testing programs for design changes and plant modif'. cations. ' The responsibility' and- authority for the I development and implementation of preoperational phase testing programs are delegated to the Unit 2 Construction Superintendent. They are responsible for assuring that -
the test programs.are established and implemented in
- accordance with procedures and instrdctions which address the requirements of this Policy. .They are'also responsible for assuring that contractors who are <
delegated onsite testing responsibilities' impose the applicatie requirements of-this Policy on their internal operations and on their contractors or. suppliers. ,
i 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. 9a TITLE: TEST CONTROL Page 1 of 3 Policy 11 OQAMR9A.1/SQPFLR - 56
N 11.4.4 Th3 M:nagor, Quality Ssrvic:3'is d 1cg ted thi r:cponsibility'ftr cs:uring 1:plcc:ntatiIn of test activities at the plant site by inspection.
He is !
responsible for' reviewing test programs and Plant Administrative Procedures which control testing to verify !
conformance to the requirements of this Policy.
11.4.5
.\
The Director, Quality Programs and the Manager, Nuclear '
Safety Oversight have the responsibility for carrying out 9a 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 REOUIREMENTS 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 .
satisfactorily in service is' identified and documented,'and- 'I that the tesr.g is performed in accordance with written,-
controlled test procedures.
11.5.2 The test program shall be implemented by the responsible. k organizations to cover all required testing, including. 't prototype 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 ;
ro11 ability of safety-related systems is, maintained. A' surveillance testing schedule (s) shall be established reflecting the status of all planned:in plant eurveillance tests and 'nspections. Trequency of surveillance tests may be related to the results of reliability analyses, 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 !
sufficient to confirm that the modifications or changes reasonably produce expected results and that the change does not reduce safety of operations.
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11.5.7 Writt:a prteedurcs f:r parfcr ing tha'tcsts shall incirporsto er rOfercnca tha following, cc cpplicablo:
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
' instrumentation; adequate and appropriate equipment; trained, qualified, and licensed or certified personnel; assurance of completeness of the-item to be tested; suitable and controlled !
environmental conditions;'and provisions for data collection and storage);
11.5.7.5 lloid 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 ani their 'I acceptability determined by qualified. individuals or-organizations as designated in the procedures.
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12.0' CONTROL OF MF.AKURING AND TEST EOUIPMENT 12.1 PURPOSE This Policy describes the Operational Quality Assurance Program measures to provide for the control of measuring and test equipment used in the performance of safety-related activities 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 equipment used in safety-related applications in order to assure the required 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 inspections, measurements, tests or monitoring of safety-related t 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, 1cvels and other such devices if normal commercial practices 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 GGNf, General Manager. During implementation of design changes and plant modifications,
- the Manager, Plant Modification & Construction 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 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 verifying, through surveillance or audits, that the requirements are being adequately implemented.
12.4.3 The Manager, Quality Systems is delegated the responsibility for assuring by audit the control of measuring and test equipment et the plant site._ The Manager, Quality Services g is delegated the responsibility for assuring by-inspection l the control of measuring and test equipment at the plant site. The Manager, Quality Services is responsible for 1
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CONTROL OF '.EASURING AND TEST EQUIPMENT Page 1 of 3 Policy 12
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revicaing Plant Ad inictr0tiva Pr:cedurcs which gov 2rn cquipm:nt centrol instructions to verify ctnferecnca to -
the. requirements of this Policy.
12.4.4 The Director, Quality Programs and the Manager, Nuclear j Safety Oversight have the responsibility for carrying out 9a ,
an audit program, as described in Policy 18.0 of this l
Manual, to verify conformance with the requirements of the
- Operational Quality Assurance Program,. including the l requirements of this Policy.
12.5 REOUIREMENTS l
12.5.1 Organizations performing safety-related functions which l
require the use of measuring and test equipment such as, instruments,. control devices,' gages, tools, fixtures,.
.I calibration ^ standards and nondestructive test equipment !
shall establish and implement procedures to control the - -
l calibration, maintenance and use of such equipment.
12.5.2 Procedures shall assure that measuring and test equ,ipment ;
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 theLpositive identification of all measuring and test equiptent included !
under the calibration system, documentation of its calibration status; and traceability to documented calibration test data.
L 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 .est 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 traceability, calibrating standards should have a greater accuracy than the standard being calibrated and possess sufficient range and stability to assure that the standard being calibrated OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CONTROL OF MEASURING AND TEST EQUIPMENT Page 2 of 3 Policy 12 ,
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q 10 within tha requirca toldr6nco. Calibr ting ctend:rds '
with tha sono cccurccy cs tho st nd:rd b31ng calibratcd i shall be allowed if it can be 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.
12.5.7 Measuring and Test Equipment-(M&TE) should be calibrated against standards (for tiie purpose of calibration M&TE is defined as thatLequipment. whether permanently installed or portable, used to calibrate permanent plant devices) that have an accuracy of at least four times the required accuracy 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 calibration, an evaluation shall be made-and documented, in accordance 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 ,i tolerance given in the Technical Specifications, may be adjusted. Such actions 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 consistently found to be out of calibration,'it shall be repaired or replaced, o l l i
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13.0 HANDLING. STORAGE AND SHIPPJg 13.1 PURPOSE This Policy describes _the Operational Quality Assurance Program measures to control.the handling, storage and 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 an. shipping, including cleaning, packaging'and. '
preservation of safety-related items in order to assure that the a
requisite quality of the items is 'maintal'aed t.ntil they are-used or ,
incorporated into the nuclear _ power pisn'..
13.3 APPLICABILITY '
The requirements of this Policy apply to all' individuals or.
organizations participating in the cleaning, handling, packaging, . 3
- preservation, 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,
- l including cleaning and preservation, are delegated to the GGNS General Manager. During the implementation of design changes and plant modifications, the Manager, Plant Modification & Construction is responsible for these activities. The responsibility and authority-for tho' l control of handling, itorage and shipping, including cleaning and preservati,n, 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 act3vities are accomplished in accordance with the established procedures.
l 13.4.2 Organizations supplying safety-related material, equipment and services are responsible for complying with the applicable requirements of this Policy, ss stipulated in 1 l the procurement documents, and for imposing them on their contractors and suppliers as applicable. They are also-responsible for verifying, through su veillance or audits, .1 that the requirements are being aderjately implemented. !
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: HANDLING, STORAGE AND SHIPPING Page 1 of 3 Policy 13 0QAMR9A.1/SQPFLR - 62
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13.4.3' Tha M:n:ger, Quality;SIrvic:s is dolcanted th2L ;
rn:pon:ibility.for'in:piction'of:th2 cnntral of h:ndling, and storage at-the plant. site' including during '
9a-preoperational and startup testing. TheLManager, Quality.'
Services is delegated the responsibility'for .
warehouse-related Inspection (including receipt- !
g inspect /*n) of the control.of handling; storage land-shippfn at-the plant site including during pre gerational and startup testing. The Manager, Quality, Services da L responsible. for: reviewing' Plant Administrative Procedures-l to verify conformance to the. applicable requirements of-this Policy.-
-13.4.4 The Director, Quality Programs'and the Manager, Nuclear
! Safety Oversight have the responsibility,for carrying out, 9a l an audit program,(as' described in Policy 18.0 of this Manual, to verify.conformance'with the requiraments of the- ;
Operational Quality Assurance Program, _ncluding the- ;
-requirements-of this Policy.
-s 13.5 REOUIREMENTS
.)
13.5.1. Procedures shall be established to control handling.' storage -;
and shipping,' including cleaning, packaging and preservation of safety-related materials,; components- and syctems. .The Procedures may be developed to cover generic-classifications i of items which require equivalent' levels of protection 1and' t control during handling, storage and shipping. Classified
- items shall-be restricted.to that'leveltor higher for:each' 5 of the particular handling, storage and shippingoperatiopsi; j' and a' change in the classification -of an item shall only no made in accordance with a. written, engineering approved' procedure.- ,
13.5.2 The procedures shall be developed by the: appropriate 4 organizations to cover -the various = stages from; fabrication-or manufacture of the items to~incorpocation'into-the plant.- j l
13.5.3 The procedures shall address the.applicsble design and ;
regulatory requirements;. codes and standre P and . ;
manufacturer's reoommendations'as approveu by.phe licensee '
engineering personnel for the prevention of damege, p deterioration or loss prior to installation or use..
Source quality verification or inspection operations 4
, necessary to verify conformance to the established ~
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criteria shall be included in. procedures, and. .
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.r 13.5.4- . Pickaging and pr232rvation' procedursoL chall provida socurcnes of cdequ ta protectiun ag:inct corro:fon.,
contamination, physical damage or-any effect which would; lower the quality of-the item or~cause-it to deteriorate during shipping, handling or storage.- Special protective
-environments, special coverings, inert gas _ atmosphere, allowable moisture content, and-temperature level shall be specified-as required and their existence verified and
' documented..
13.5.5 Cleaning procedhres shall provide assurance that necessary cleaning. operations 6.3 carried'out prior to. packaging, stor' ge or installation. The level of cleanliness required
-and verification and-documentation requirements lshall be l 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.. I m ,;
13.5.7 Measures.for receipt inspection of.it' ens, disposition of I received: items and control of nonconferming. Items shall-be-addressed in procedures which implement.the applicable requirements of Polictos 7.0 and 15.0 of this-Manual, j 13.5.8 Detailed handling procedures shall be provided for all items that require special handling. Special handling tools.andL equipment shall be provided and w ntrolled to ensure safe and adequate-handling. These' tools and equipment shall L-maintained,.; inspected and tested in accordance with written ,
procedures _at established intervals 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 crL deterioration.during storage.
Periodic ing ections of storage areas shall be performed ;
and documented to verify compliance with storage procedures. l Release of items for installation shall.also be procedurally controlled.
13.5.10 Until Unit 2 has completed construction'and a11' material i hcs been turned over to the licensee, administrative controls shall be established for the transfer ot' Bechtel-procured and controlled items to the GGNS Operational Quality Assurance Program.
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16.0, ,1NSPECTION. TEST AND OPERATING STATUS.
14.1 PURPOSE '
a
.This. Policy. describes the Operational Qua41ty Assurance-Program' measures to identify and control the' inspection,.-test and operating
~
status of safety-related structures,Lsystems and; components for thel ;
Grand Gulf Nuclear Station.
14.2 SCOPE t 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 ar.d tests are. performed)and-the acceptability of items:is known, and !
to prevent the inadvertent operation of-items which are in a:
~
controlled status. '
14.3 APPLICABILITY The requirements of this Policy apply-to all'indivicuals'or.
organizations performing-functions on safety-related structures.. ~;
systems and components during the operational phase of nuc~ lear power; '
plant activities. . c 14.4 RESPONSIBILITY 14.4.1 Duringtheoperationalphase,-responsibil1Nyandauthority-for identifying and controlling;the ~ test. and operating.
- status of safety-related items, excluding preoperational:
~
testing,'are dt.egated to the GGNS General'_ Manager. The responsibility and authorJty 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-Programs has the l responsibility and authority for identifying.andi 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 f 3 applicable requirements of this Policy:, as stipulated in, i the procurement documents, and for imposingLthem.on their
,, contractors-and suppliers as applicable. They are also'
- l. responsible for verifying, through surveillancesor audits.
l that the. requirements are being adequately Implemented.
l 14.4.3 The Manager, Quality Services is responsible for reviewing' Plant Administrative Procedures to verify conformance-to the applicable requirements of this Policy.
OPERATION.\L QUAh1TY ASSURANCE MANUAL Rev. 9a TITLE: INSPECTION, TEST AND OPERATING STATUS i
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-14.4.4 Tha Dircctor, Quslity. Prograc3 ' cnd- tha MInagsr,ENuclest .I Safcty Ovarsight'h;va tha r20ponsibility for carrying'out. 9a -
an audit program, as described.in' Policy 18.0 of this-Manual, to verify.conformance with-Operational Quality' );
Assurance-Program requirements, including th'airequirementsi of this-Policy. .
14.5 REOUIREMENTS 14.5.1 Procedures shall be estab1'ished an'd implemented by the:
organizations responsible for the fabrication, storage, 3 installation.. test, and operation of_ safety-related '
structures, systems and components to assure that the' 4
. inspection,. test and:operatina . 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-s indicators such-as stamps tags, labels, routing: cards, shop travelers, or-other suitable means.- Sultable meansl -;
may include identificationinumbers which are traceable to. i inspection and. test records. ,
14.5.3 The procedures shalll identify.the' status indicatorLto be used and provide for its control,1 including responsibility 1
.and authority for application and' removal.- 'l 14.5.4 Bypassing of required inspections, tests or other critical .
operations-shall be procedurally controlled with concurrence by Quality Programs. Where necessary-to preclude inadvertent bypassing of required inspections and tests, the procedures shall provide for the-identification of -ms' which have passed such-inspections and tests. ,,
14.5.5 In cases where documentary evidence-iscnot-available to confirm that an item has passed required; inspections and -
]'
tests, that item shall be considered. nonconforming and: :,
. processed in accordance with Po11cy,15.0. 'Affected' systems ;
shall also be evaluated for operability in'accordance with a' the Technical Specifications and reliance shall not be placed on any such systems-(whirh are evaluated =as
]~
. inoperable) to fulfill their intended safety functions.. ;
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 phall require ;
control measures, such as locking or tagging to se' cure and. ,'
identify equipment la a controlled status. Independent verification.shall'be required, where' appropriate,.to ensure- -
that necessary measures,.such as tagging equipment, have =!
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I 14' . 5. 7. Tceporary/codificatiens ch::11 b2 centro 11dd by.Lcpprovsd prccedurss which includ -c requircasnt for indsp2ndant.
verification.- A log shall be maintained of the current status of such temporary modifications.-
~
14.5.8 Nonconforming services and' nonconforming.-inoperative or1 malfunctioning st:uctures,-systems',1 components or materials shallibe identiflad'and controlled in accordance with the-requirements of P311cy 15.0' of this Manual'.
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15.0f NONCONFORMING'M'A TERIALS. PARTS OR COMPONENTS
-(Including Its 3, S3rvicc2 cndLActivitiss)'
1511 PURPOSE This Policy describes the Operational Quality Assurance, Program-measures _to idet,tify'and control-safety-relatedLitems services or activities for:the Grand Gulf _ Nuclear Stationiwhich do not conform to established requirements.~
15.2 SCOPE q
This Policy delineates responsibilities and_ defines requirements for 2 the identification _ and control of nonconforming _ safety-related.: items, services or activities in order to assure that the nonconforming conditions do-not cons _ mise quality.or' safety.
15.3 APPLICABILITY The requirements of this Policy' apply to all-individuals or organizations performing functions on safety-related structures, systems, materials, parts or components during the. operational = phase t of nuclear power 91 ant activities.
15.4 RESPONSIBILITY 4 -1 1
15.4.1 Responsibility and authority for.the identification', :l l
control and disposition of nonconforming items, > services !
and activities during the operational phase are delegat'ed
- to the Director, Nuclear Plant Engineering (for engineering);
the Manager, Plant Modification & Construction > (forL implementation of design changes and. plant modifications);
the Unit 2 Construction Superintendent (for preoperational phase testing); the Manager, Nuclear Fuels (for nuclear :
fuel or core items); the GGNS General Manager;.the !
Director,, Quality Programs;;the Manager, Nuclear Safetyg 3a Oversight; and the manager of the organization performing j the activity. It is the responsibility of,these individuals to assure that the requirements of this Policy 3 which are applicable to their scope of activities are implemented in accordance with documented procedures. All q personnel are responsible for. reporting detected !
nonconformances in accordance. with the procedures-applicable to their particular organization. I 15.4.2 Organizations supplying material, equipment or services are' i 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. 1 15.4.3 The Manager, Quality Services is delegated the responsibility for assuring implementation of the identification and-control of nonconforming items, services and activities by OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 1.of 4 Policy 15 OQAMR9A.1/SQPFLR - 68 .$
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review or receipt inspections'activitica during plant' site' 9a oparations phase activitics, including preoparational and startup. testing _to' verify _.conformance to the applicable requirements _of-this-Policy._-The Manager, Quality =SystemsL is delegated'the-responsibility for assuring ._
implementation of:the identification and control of-nonconforming items,. services and' activities by audit of. 9a-plant site operations. phase activities, including preoperational and startup testing to verify conformance to the applicable'requ tements of this' Policy.
The Manager, Quality Services-is delegated the responsibility for control, processing, tracking, disposition, concurrence verification and closure:of-nonconformance documents' for Plant s.ite operatf ons phase -
activities, including preoperational and startup testing to. verify conformance to the applicable-requirements-of this Policy.
15.4.4 The Director, Quality Programs and the Manager, Nuclear Safety Oversight have the responsibility for carrying out 9a an audit program, as' descriced 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. Theyfare also responsible 9a for the periodic review and analysis;of NRC and licensee:
quality deficiency 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' affocted organizations .as appropriate.
15.5.2 The procedures shall:
15.5.2.1 'specify the individuals _or organizations-responsible for the disposition and approval of
~
- nonconforming items, services or activities, (including an' independent review and acceptance by the appropriate quality organization).
15.5.2.2 provide for documentation to identify the item, service or activity; describe'the nonconformaice; 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. i OPERATIONAL QUALITY ASSURANCE MANUAL Rev 9a TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 2 of 4 Policy 15 l 0QAMR9A.1/SQPFI.R - 69
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- 15.5.3. Mncsurcs'shall ba istcbliched to-procedurally control ^
further proc 2saing,_dr,11 vary or in2tallction of a nonconforming item or continuation of a nonconforming
, service-or activity...pending a decision on its disposition.1 15.5.4 - In order to prevent its inadvertent use or finstallation,Ja : >
nonconforming'iten 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 tagging shall be' t.cceptable.- Where marking or tagging is~not feasible, nonconforming items may be controlled byJthe.use of appropriate. documentation.. Markings or tags used-to:
Identify nonconforming l items _'shall-be removed after, resolution of the nonconforming _ condition.
15.5.5 Nonconforming items, servicestor_ 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; 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 will.
be considered-nonconforming. 1 li 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.
1.
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 i
For items dispositioned " accept-as-is" or," repair," a 1 description of the change, waiver or deviation, shall bei documented to record the change and denote'the as-built condition. Documentation verifying the_ acceptability and
.l approval of such items shall also be required.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a j TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 3 of 4 Policy 15 0QAMR9A.1/SQPFLR - 70
4 15.5.8 Nonconfer0:nca:rcportsLwith "ccespt-se-is" or "rspali" diepositi n3 cubmitted byferntracters or cupplists shall br ->
reviewedLand concurred with by-the designated' individuals and_shall become a-part.of'the inspection records to be- j submitted'with the item.' -
15.5.9 Nonconformance. reports shall be periodically reviewed and analyzed to detect possible. adverse quality _ trends,1and the-results shall be reported to management'for review and'-
assessment.--
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L 16.0 GQERECTIVE= ACTION ,
\
16.1- PURPOSE ,
This Policy describes-the Operational-Quality Assurance Program ;
measures to provide for the correction ~of conditions adverse to the '
quality or safety of the.Giand Gulf Nuclear Station.
16.2 SCOPE
'This Policy delineates.responsibilitiesiand_definestrequiremonts[for the identification, documentation',sreporting, and'correctior.~of ,
conditions adverse to quality or safety,; including requirements'for the ' determination of .cause and corrective action to praclude the. :
recurrence of significant' conditions adverse _to quality or safety.
16.3 APPLICABILITY 4
The requirements of this Policy apply-to all individuals or organizations 'performingi functions which affect sr fety-related structures, systems or: components during the operational phase of nuclear power plant activities.
16.4 RESPONSIBILITY.
16.4.1 Responsibility. and authority ;fori he_
t development and i control of measures to assure corrective action during the 1 operational phase are delegated to the GGNS General-Manager; Director, Nuclear Plant Engineering; Director,-
Nuclear Support; Director, Nuclear Licensing;< Manager _, 9a Nuclear Safety Oversight;.and the Director, Quality Proere== They are responsible for assuring that
! procedures 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 la designed to prevent recurrence of-significant adverse conditions.
l 16.4.2 All organizations performing qun11ty or safety affecting activities are responsible for incorporatinglinto 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 l' performing or controlling the: activity. During the operational phase, the responsibility-for the determination and implementation of corrective action ,
onsite, excluding preoperatlonal testing activities, is delegated to the GGNS General Manager. During implementation of design changes and plant; modificar1ons,-
the Manager, Plant Modification & Construction is responsible for this activity. The responsibility for the determination and implementation of corrective action OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: CORRECTIVE ACTION Page'1 of 3 Policy 16 0QAMR9A.1/SQPFLR - 72 Yr
l aesociated with praopar:tional phtes tuting progrc:s ic -
dsleg2ted'to tho Unitn2 Construction Sup2rintsndrnt. -
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 procurementi
' documents, and for. Imposing them on iheir contractors and= ?
suppliers as applicable', 'They ate i b responsible-for verifying, through surveillance orjofits, that the ,
requirements are being adequately impfemented. ,
16.4~. 5 : The Director, Quality. Programs and the_ Manager, Nuclear 9a_
Safety' Oversight have the_ responsibility for carrying'out
=
an audit program, as described in Policy- 18.0 of this 't 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 licensee quality deficiercy documents to detect ,
possible adverse quality trends; for reporting'such: items, i if any, to the Vice President', Nuclear Engineering &
Support; the Vice Prerident,. Nuclear Operations; the .
i Senior Vice President," Planning & Assurance; and the _Vice 9a '
President, Operations Support for further action.-
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 near,ures 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, violaticas, deviations,~ reportable occurrences, 10CFR21 items, and: defective meterial and equipment to determine the need,for. corrective action.and 7 to identify possible adverse quality trends.
16.5.3 The procedures shall require that: action be 3romptly.
initiated and adequately documented.by.the't mponsible -
organization to correct the condition and te determine if action is necessary to preclude its recurrence.
16.5.4 The documentation to be used to report conditions adverse r
- to quality or safety and request corrective action,_and'tho
- appropriate distribution and control thereof,. shall .be
-specified in the procedures.
16.5.5 The procedures shall provide for follow-up resiews by the-appropriate organizations to verify proper implementation' R of the corrective action and to close'out the' documentation.
OPERATIONAL QUALITY ASSURANCE MANUAL .Rev. 9a TITLE: CORRECTIVE ACTION Page 2 of 3 Policy 16 OQAMR9A.1/SQPFLR - 73
2 16.5.6 For cignifier.nt conditions .cdvoram to qurlity'or stfaty, - ;
'ths cru:o of.-ths c:nditiona,-cndLths corrsctiva cction a taken which11s designed to prevent. recurrence of the event- -i shall- be documented and Lreported to appropriate levels' of-management 1for review.: s
~
'16.5.7 Nonconforming' materials,Lparts and' components-(including items,. services and activities):shall be identified, controlled and dispositioned in accordance with proceduresz which implement the-requirements of Policy 15.0'of.this Manual.
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. o 17.0- OUALITY ASSURANCE RECORDSi V
- 17.1 PURPOSE '
1 This Policy describes the Operational' Quality Assurance l Program:
c measures for .the collection, storage,1and maintenance of quality ; !
assurance records for the Grand Gulf Nuclear' Station.
17.2 SCOPE '
This Policy delineates responsibilities and. defines requirements >for. '
U 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 a f fecting quality. i 17.3 APPLICABILITY
,The requirements of this Policy apply to all individuals.or organizations' participating in the collection, storage or maintenance of quality assurance records during the' operational phase of nuclear
~ '
power plant activities. >
17.4 2 RESPONSIBILITY 17.4.1 Responsibi'11ty 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 controls for the collection, storage ;
and maintenance of quality assurance records is delegated ;
to the GGNS General Manager. t 17.4.2 The GGNS General Manager is responsible for the collection, storage and maintenance of records generated onsite and required to be maintained at the site including GGNS records generated by the Plant Modification and Construction 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 Hodification and Construction Section Procedures developed"to meet.the requirements of this Policy.
17.4.3 The Manager, Quality Services and the Manager, Quality Systems are delegated the responsibility for assuring implementation of the collection, storage, and maintenance l
of those quality assurance records onsite which'are under l OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: QUALITY ASSURANCE RECORDS Page 1 of 3 Policy 17 0QAMR9A.1/SQPFLR - 75 i
V ths control of ths GGNS Gantral MInag,r. Tha Inagar,.
Quality Sarvicts 12 rc ponsiblo for.rsviswing"Plcnt'
~
. Administrative.proceduresiand work documents for.and-performing inspections to the. extent necessary to verify; ,
conformant,e_to the' requirements oflthis Policy. .,
17.4.4 The: GGNS General ' Manager -is responsible - for the
' collection,-. storage and maintenanceD of records generatedL '
by the Nuclear Support:Staf f,LNuclear I.icensing Staf f ?
Nuclear: Plant Engineering: Staff, Supplier Quality gm Assurance Staff and those records transmitted to-the GGNS ;
-General Manager. This includes quality' assurance records -
generated'by Quality Programs.: Records to be maintained c
r bt the GGNS General Manager shall be : Identified inL the ,
appropriate Nuclear Support,~ Nuclear Licensing ~, Nuclear-Plant Engineering Administrative Procedures and Supplier 9a l Quality Assurance Procedures developed'to. meet thel ,.
requirements lof.this' Policy.
'17.4.5) The Director, -Quality Programs is - responsible for the' ? - ,
collection _and storage of-quality assurance records < , q generated by Quality. Programs.until such timeas they are transmitted;to the'GGNS General. Manager._;Such' records shall be identified?in the. appropriate Quality Assurancei Procedures developed to meet.the requirements of.this-Policy.
17.4.6 Other organizations whosa_ scope-.of activities require the generation, collection, storage or . maintenance of _ quality j 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 . i adequately implemented.
17.4.7 The Director, Quality _ Programs, and the Manager, Nuclear 9a Safety Oversight have thetresponsibility for carrying out an audit program, .as described in~ Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance: Program requirements, l including 1 the requirements
-of this Policy .
I 17.5 REQUIREMENTS 17.5.1 A system for the collection, storage and: maintenance of '
quality assurance records including provisions'for l
identification, classification, indexing, retention, ;
preservation, safekeeping, retrievability and disposition shall be established.-
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE:- QUALITY ASSURANCE RECORDS Page.2 of 3 Policy 17 OQAMR9A.1/SQPFLR - 76
17.5.2 Th2 rccorda-cystoa ch:111dsfin2 requirtsnts_dnd-ra:ponsibilitits.fer_ttcordsitrancoittels', rotantion,:cnda maintenance,~ subsequent to'the completion _ofla: work:
activity, consistent with.applic'able' codes,; standards:and' procurement documents.'_ MeasuresLto 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'.identifial e and ret.rievable. __. Retention -
~
periods of sufficient duration to assure the ability to -
reconstruct significant events'and satisfy regulatory ors ,
statutory requirements'shall be'speciffed. -Inspection and: -l test records shall contain the following where applicable.~.
t 17.5.3.1 A description of the' type of_ observation ~;
17.5.3.2 Evidence of completing and: verifying a-manufacturing, inspection, or test operation;: +
17.5.3.3 The date and'results of the inspectionLorl test; 17.5.3.4 Information telated to conditions adverse to quality;
- 1 17.5.3.5 Inspector 'or data recorde_r_ identification; _
17.5.3.6 Evidence as to the t.cceptability of the results.
17.5.4 _ Storage facilities for quality assurance records'shall be I designed to prevent' records' damage or loss, to the maximum j extent. practical; 'or as a satisfactory alternative, duplicate record shall1be stored :in a separate remote- i
. -i location.
, ]q 17.5.5 Records and documentation' requirements are specified in the h other policies of this Manual. Quality assurance' records ;i include, but are not~ limited to: design-records',,such-as d specifications and drawings; procurement documents; J operating logs and procedures; principal maintenance and J modification documents; results of reviews, inspections.
tests, audits, material analyses; monitoring of work l performance; personnel, proceduresf and equipment (
qualification records; quality deficiency documents-corrective action documents; and'10CFR evaluations j
(i.e.,. ,
10CFR50.59, 10CFR21).
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18.01 AUDITS' 18.1' PURPOSE This Policy' describes the Operational' Quality Assurance Program measures to provide a comprehensive audit program _for the Grand Gulf 1 Nuclear _ Station.
18.2- SCOPE This-Policy delineates responsibilities land 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.-
1 18.3 APPLICABILITY The~ requirements of this Policy apply to all_ internal,and external audits performed by'or for the licensee during the operational phase of nuclear power ~ plant activities.
18.4- RESPONSIBILITY 18.4.1 Responsibility and authority;for.the;11censee's audit .
program are delegated <to the Director Quality Programs- l and the Manager, Nuclear Safety.0versight..-;They~are 9a 1 responsible for thefdevelopment and implementation ~of a '
. program of planned and documented audits-;to verify 1 4 compliance with all' aspects of the. Operational Quality 1 Assurance' Program and to assess its-effectiveness.. They' are responsible for. assuring that procedures?are1 _ ,
q developed, in accordance with the requirements of this '
Policy, to provide for both internal and external audits. '!
The Director-Quality Programs is responsible for 9a . j performance of audits to. verify plant conformance to the 'l Technical " Specifications ;: audits of; operational = pha'se : j activities (including activities of the Startup j Organization); and audits of contractorstandssuppliers performing onsite activities. The' Manager? Nuclear Safety
^~ersight is responsible for the-performance of. audits of mtractors 'and suppliers performing offsite activities.
- ey shall also assure that audit results 'are documented 9a d
d reported to appropriate management,)end that prompt '!
corrective action is taken to eliminate conditions adverse'
~
j to quality detected during the' course of audits.- 1l 18.4.2 This section deleted in Revision 3.
OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: AUDITS '
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.18.4.3 .Org:nizatiens'cupplying'caterial,; equip 22nt or cervicca :(
cre responsibis for cuditing thair internal operations and! ;
their contractors.and suppliers,-as stipulated in'the-appropriate procurement documents, tin order to verify- 1
' compliance with the quality assurance program requirements specified'in the procurement documents. ' ~
-18.4.4 .The . section deleted in Revision 5. :
18.5- REQUIREMENTS 18.5.1 A' comprehensive program of planned and documented audits.
shall be established'and implemented by. Quality; Programs' and Supplier Quality Assurance to. verify compliance withi 9a.
l all aspects of the'0perational Quality Assurance Program'- "
The audit program shall be carried out-iniaccordance with. '
written approved procedures which address the' requirements of this Policy. '
18.5.2 .The audit program' shall provide for both. internal and-external audits. Internal audits shall, include audits of<
the procedures ~ and. performance of allilicenseo-organizations whose activitiesraffect.the quality;of safety-related' structures, systems andl components. '
External audits shall include audits of'the practices, '
procedures and instructionstof _ contractors and suppliers ?
who provide, safety-related material',' equipment'or J services.;
18.5.3 Audits shall provide an objective evaluation of quality-related practices,' procedures,Dinstructions', 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 4 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:
l auditors shall.be established and documented and records of q auditor qualifications shall be maintained Land kept current.
Personnel selected'for ;:qslity assurance audit' assignments
! shall have experience or. training commensurate with the ;
l 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: ;
'i 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 4
requirements, r
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)
=18.5.6.2- Audite.ch211 b) och duled cniths b$sia of tha l
-otetus:end'i: port:nce of tho activit120 to be 1 audited.
18.5.6.3 Those specified -in the Technical Specifications 1
=for;the applicable nuclear 1 generating' station.; j 18.5.7 Individual audits shall be performed in accordance with: j documented plans:and checklists which describe the audit 1
- and provide for an~ objective evaluation of the status and i edequacy_of the areas being audited.1 i The
- " objective! evaluation" referenced is not to be confused with the' evaluation statement'in ANSI N45.2.12 to which-
- the licensee has provided a clarification.- See' Appendix A.
18.5.6 Audit.results, includingLconditions adverse'to quality detected:during the audit, shall be documentedjand' reviewed with the~ supervisor or. manager having .
responsibility in the areas'. audited.- Distribution of, audit reportsishall include management ofi the audited organization and appropriate' licensee, manage ant.
18.5.9 Management of-the au'ited d organizations shall be responsible i
for correcting conditions adverse to quality identified i during an audit. -They shall assure that corrective: action l
.Is scheduled, accomplished'as scheduled, and documented.
i The corrective action shall be designed to prevent' the ;
! recurrence of significant conditions adverse"to qualityO !
- (See also Appendix A. Regulatory Guide . l.144, ~ Item 11. ) -
18.5.10 Deficient areas shall be reviewed or reauditedfon a timely- .i basis to verify-implementation of' corrective action.
i 18.5.11 Audit results shal1~be analyzed to detect < adverse.' quality j}
> ~
trends and to evaluate the effectiveness of tho' Operational Quality Assurance Program. Results'of such. analyses which 1 Indicate adverse quality trends shall beEreported to I appropriate management for review and' assessment. j 18.5.12 Records shall be generated and retained for al11 audits, a including individual audit plans, audit reports, written I replies, and records of corrective action. . (See also. j Appendix A, Regulatory Guide 1.144, Item 13.')
18.5.13 The licensee interprets the. requirements of Technical Specification 6.5.2.8, which requires that audits shall be .
i performed under the cognizance of the SRC, to be met by the following: The SRC shall review the results offaudits i of nuclear. activities conducted in accordance with the a GGNS Operational Quality Assurance Program. Audits shall.
be conducted and results shall be reviewed in the areas '!
listed in Technical' Specification 6.5.2.8. I OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 9a TITLE: AUDITS Page 3 of 3 Policy '18 0QAMR9A.1/SQPFLR - 80 '
I
APPENDIX A Conformance of GGNS Onarational Ouality Assurance:
~Pronram to NRC Raoulatory Guides and ANSI Standards:
IneachoftbeANSIstandards,otherdocuments(i.e.,otherstandards, codes, i 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.
~
of these listed standards, codes, regulations or appendices is either covered !
In other specific areas in the Operational QA Program, including appendices, or such documents'are not considered as Quality Assurance Program requirements, although they may be used as guidance. '
NRC Ranulatorv Guide 1.8 , " Personnel Qualification and Training"'(2nd' Proposed' ,
. Revision 2) . Endorses ANSI /ANS 3.1 (Draft'12/79). ,
1 The Operational Quality- Assurance Program complies with those require:nents of I Sections 1.0, 2.0,13.0, 3.1, 3.2, 3.2.1, 3.2.2, 3.2.3, 3.3, 4.0,- 4.1, and 4.4.5. j j of ANSI /ANS 3.1 (Draft 12/79) that are applicable to Quality Programs (both' l onsite and offsite) with the following clarifications: s
- 1) With regard to the . term " Bachelor's ' Degree" as used in. the draf t .
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 years of applied experience at a nuclear facility in the area J for which qualification is sought,.
- c. 4 years of operational or technical experience / training In. 't nuclear power, or 4 t
- d. any combination of the above totaling 4 years.
- 2) With regard to Section 4.4.5 of ' ANSI /ANS 3.1 (Draf t 12/79)' titled .
Quality Assurance: The licensee will comply with Paragraph 4.4.5 as originally stated in ANSI /ANS-3.1 - 1978 which reads as'follows:
At the time'of initial core loading or assignment to'the active position, the responsible person shall have six ycEnrs 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 itplementation of the quality ,
assurance program. '(This experience shall be obtained within- .i the quality assurance organization.) A' minimum of one year of. ;
- is six years experience shall be related'technica12or academic aining. A maximum of four-years of this six. years experience
.ay be fulfilled by related technical or academic training.
l The applicability of this Guide / Standard to other personnel in the licensee's organization is addressed in other Sections of the FSAR and the Technical l Specifications of the individual nuclear facility. l l
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9 OQAMR9A.1/SQPFLR - 81
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~ APPENDIX A
=NRC Ranulatory Guide 1.26 "Queilty Group Classification, and Standards for Water', Steam, and Radioactive Laste Containing Components of Nuclear-Power. '
Plants (Rev. 3, 2/76)
The Operational Quality Assurance Program complies 1with=the requirements of -[
this Guide with the following clarification:
The.llcensee may chooseLnot to use the specific A, B, C and D level classification-system set forth in this Guide. The licens e generally )
followed the requirements of this Guide in developing the list Lof structures, systems and components ("Q" List) to which the program will apply.- The licensee "Q" List will describe the -items. to which the Operational Quality - !
Assurance Program will apply in lieu of the guidance contained in this 1 Regulatory Guide. "
..............................................................................m....
NBC Renulatory 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 activities by Regulatory Guide' l.33 and ANSI ~ N18.7 11976 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 Renulatorv 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, The licensee shall eithnr control these activitle- 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, the-licensee shall comply with the Rerulatorv 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 i margins, manufacturing processes, and' inspection requirements).
- NRC Renulatorv Guide'1.30 " Quality Assurance Requirements;for the Installation, Inspection, and Testing of Instrumentation and Electric I
Equipment" (8/72) - Endorses ANSI N45.2.4 - 1972. .
l The Operational Quality Assurance Program complies with the equirements 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 Rev. 9a 2 of 33 i 0QAMR9A.1/SQPFLR - 82 ,
APPENDIXLA during_ths1 construction phaso, ths licanoss obs11=oithat control th:2o cctivities und0r this Oparational QA Prrgrca or under an NRC- >
accepted Construction.QA Program (Per 0QAM 3.5.18).. When this
' Operational QA. Program.is used, the' licensee shall comply with the Remulatorv Position. established inlthis: Regulatory-Guide in.that QA' programmatic / administrativeLrequirements included therein.(subject.
j 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 b,e -
the original requirements or,better (e.g., code requirements, '
material properties, design' margins,: manufacturing processes and:
inspection requirements).
- 2) Additional clarifications for ANSI N45.2.4 ;1972 are indicated'for '
specific sections below..
Section 1.4 - Definitions inLthis St'andard which ar'e not included in' ANSI N45.2.10 will be used; a11' definitions which are included?in.
ANSI N45.2.10 will be used as clarified in the' licensee-commitment to Regulatory' Guide 1.74.
Section 2.1 - Plannine requirements,.when necessary, will be incorporated-into maintenance and modification procedures.
Section 2.3 - Procedures and Instructions will'be implemented as set- -
forth in Policies 2, 3, 5, l' , and 0 11'of,the'0perational.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'fortti 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 thex Program;in lieu of the: 1 l
requirements set'forth here.
Section 2.5.2 - Calibration and Control. The third sen'tence of.this section states in part, "... equipmentnshall be' suitably marked to indicate date of next required calibration." The licensee will utilize a computerized system to indicate the calibration status of l
' Installed operations measuring and test. equipment irr lieu of marking-or tagging the individual item.
Section 3 - Preconstruction Verification will be implemented'as follows: (1) is required only for modifications;-(2):will be implemented with the clarification that " approved instruction manuals" shall be-interpreted to mean the manuals provided by the l supplier as re quired- by the procurement ' order--these manuals will not be reviewed and approved, per.se, by the licensee; (3) no special '
checks will be made by the person withdrawing.a replacement;part' l from the warehouse--equivalent controls-are assured by compliance 1 J with ANSI N45.2.2 as set forth in Appendix A to the Operational QA' I Program; and, (4) will be complied with as stated, by individual. >
technicians as part.of the maintenance / modification process.
Rev. 9a
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' APPENDIX lAl Saction 4 - Installation w111 b3 irpls:snted-by inclusicn, csy i necessary, fin the appropriate maintenance or- modification procedure,. '
where such procedures are used. Standard IIcensee maintenance. -
practicesfrequirelthat care:be exercised in the'six areas' listed whether a procedurefis required or not. '
Section.5.1 - Insoections, including subsections 5.1.1,15.1.2, and' theiffrat. sentence in 5.1.3, will be11mplemented as' set - forth in Policy 10 of the Operational QA Program. 'The inspection program will:
incorporate, as applicable, those~ items 111sted in these subsections.
~
The remaining sentence in 5.1.3-is ' covered in equivalent detail:in i the licensee's commitment: to!ANSIfN18.7,-Section 5.2.6; ther !
requirements as set forthiin.that commitment will be_ implemented in. l lieu of the requirements stated here.
Section 5.2. Tests,_ including subsections 5.2.1 through'5.2.3,,will-be f rolemented 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 forf '
inclusion in. maintenance and modification procedures. _.In some cases,:
testing tequirements~may be met by post-installation surveillance testing in lieu of-a special post installation test. l Section 6' - Post-Construction Verification 1s- not generally '
considered: applicable at operating facilities because of.the scope of a the work and the relatively=short. interval'between. installation'and operatien. 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: The11ast paragraph of; this Section deals with tagging and l-labeling.- The licensee 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 1
instrument maintenance records so that -currentfcalibration status, including data such as theldate of the calibration and identity of !
person that performed the calibratior , can- be readily determined. '
Such information may also be contain3d on tags-or labels which may.
be attached to installed instrument 4 tion." >
Section 7 - Data Analysis'nad Fraluation 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 cnd ANSI N45.2.9 as set forth in Appendix A to that Program.
Rev. 9a #
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L 0QAMR9A.1/SQPFLR - 84
n , -i
' APPENDIX ~A: ;
NRC Regulatory Guide'1.33 " Quality Assurance Program Requirements-
-(Operstit j" (Rev. 2, 2/78) - Endorssa ANSI N18.7 - 115 .'6. j The Operational Quality Assurance. Program complies with :the ~ requirements of [
.- this Guide with the following clarifications:- Ti
- 1) IParagraph C.3 of ' Regulatory Guide 1.33'(and Section 4.3.4 of eNSI J N18.7 which it references) will'beJizplemented:as required t 'ae applicable nuclear facility Technical Specifications'which du. !
" Subjects' Requiring Independent Review."
~'i
- 2) Paragraph C.4.a of Regulatory Guide 1.33 (and Section 4.5Lof ANSI N18.7 which it refe'rences) will be istsemented as required by the
' applicable nuclear, facility Technical! Specifier +.fons whichLdefine the e
" Audit Program" to be conducted.~ .The audit program is further.
defined and will be implemented asErequired 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 Plaat : Safety Review . Committee shall: perform this1 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 Guidesichanging of the two uses of.the word "should" in.this sentence to "shall"? unnecessarily. ,
restricts the licensee's options on repair or replacement parts. It r is not 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.5.e of Regulatory Guide 1.33- (and 5 ction 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 elsewherejin Appendix.A to the Operational QA Program.
4
- 6) Paragraph C.S f of Regulatory Guide.l.33 (and SectionL5.2119(2)-of ANSI. N18.7 which it references) will bel 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 Guido converts to "shall." It is the licensee's intent to fully comply with the requirements of this paragraph,.and any conditiens 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. 9a 5 of 33 0QAMR9A.1/SQPFLR - 85
J
~ APPENDIX A.
- 8) l With reg:rd to S ction 3.4.2 of ANSI' N18.7 -- 1976 tit 1ed Requirements
~
for the Onsite Ooeratine Dreaniutlon: TrainingTstandards; referenced ,
in this Section will'.be implemented -if such standards arelinc" luded'in_
Appendix A to'the Operational.QA Program or'in Technical- .
Specifications or are otherwise'partf of. the' licensy of the' individual
-nuclear facility. . The licensee's method lof documenting ~and .
otherwise meeting: the _ remainder 'of the' requirements- of. this Section i
"are set forth in Policies 1 and 2 of the' Operational QA Program and:
-in the' Technical. Specifications of the individual nuclear facility.
- 9) With regard to Section"4.1.of ANSI N18.7. .1976' titled G.eneral: The licensee audit program will-be implemented.in accordance with:and'to
- ]
meet lthe requirements of: . ANSI N45.2.12 as; endorsed;in Appendix A;. ;
l' Policies 2,.16 and.18.of the,0perational QA Program;'and the' ~*
l requirements'of the individual' nuclear facility Technical:
- L Specifications. ,
10)- With regard to Section'4.2 of ANSI N18.7 1976 titled ErngTAB .
Descriotion: Two' aspects are addressed in'this Section: audits'and independent reviews. The independent, review program isilmplemented as required by the Technical Specifications.of the~ individual:nuclea'r.
facility and-by Policies I'and 2 of'the Operational QA Program. 'The licensee audit program will be described in accordance with and tot meet the requirements of-ANSI N45.2.12 as endorsed in' Appendix'AJof the Operational 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 Indeoendent Review Process: -The-requirements of this.Section, including.all of j i
l' its subparts, shall be met by compliance with the Technical Specifications' requirements of the individual nuclear facility, a
- 12) With regard to Section 4.5 of ANSI N18.7 - 1976 titled Audit Pronram:
The-licensen audit. program will be' implemented'in accordance'with and to meet the requirements ofi . ANSI N45.2.12 'as endorsed in'-
! Appendix A; Policies 2,'16, 17'andJ18'of the Operational 1QA Program;' q and the requirements of: the -individual nuclear- facility Technical Specifications.
.i
- 13) With regard to Section 5.1 of ANSI,N18.7 - 1976 titled Proiram l Descrintion: The fourth sentence in this Section required a " summary I document"; the licensee has submitted Appendix.C-to the Operational QA Program and interprets this Appendix to fulfill the requirements for a summary document.
i
- 14) With regard to Section 5.2.2 of ANSI N18.7 - 1976 titled Procedure Adherence: The temporary change requirements of this. Section are l delineated in the Technical Specifications'for activities occurring after the Operating License (OL) is issued; the requirements of the i Technical Specifications shall be: Used in lieu of the general requirements in this Section to control temporary changes. For ;
temporary changes which' occur'under this Program during l
preoperational and startup testing prior to _ issuance of an OL,. I the licensee will comply with this Section with the clarification that another Rev. 9a 6 of 33 OQAMR9A.1/SQPFLR - 86 ,
. we+q N w
APPENDIX A~
Tsot Sup:rvitor or Shift Sus rvicor_or'cthi canbar of ths P10nt Staff (limited, to Shif t, 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 '!1mplement" or " address" a procedure, actions' prescribed by procedures ehall be' accomplished. . This-.does not necessarily imply that'in all cases-the operator,_ engineer, or technician has a copy 'of the procedure in-band and. signs-off 'a checklist as each step or function'is_ performed.
- 15) With regard to Section 5.2.6lof ANSI N18.7~- 1976 titled Equipment control: The licensee will-comply with the " independent-verification" requirements 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.sha11' advise Operations of current radiological conditions. Operations will then decide whether or notithe confidence gained'from the independent? i verification is worth the additional radiation = exposure.' In all.
1 1
cases, radiation doses will be As Lo.t As Reasonably.~ Achievable j (ALARA). j Since the licensee sometimes uses descriptive names to designate f equipment, the sixth paragraph, second sentence is replaced with: 1
" Suitable means include' identification numbers or other' descriptions l which are traceable to records of the status of inspections and -
tests."
The first sentence in the seventh paragraph will be complied with-af ter clarifying " operating personnel" to mean trained employ'ees - j assigned to, or under the control of, licensee. management at an operating nuclear facility.:
- 16) With regard to Section 5.2.7-of ANSI N18.7 - 1976 titled Maintenance _ a and Modification: Since some emergency situations could arise--which d might preclude preplanning of all activities, the licensee will comply with an alternate to the first sentence in the second paragraph which reads: .;
i "Except in emergency or abnormal operating conditions where immediate 'j 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 af ter-the-fact and receive the same degree'of review as if they had been preplanned." 1 1
For those system run-in activities that take place prior to issuance of an Operating License, the Startup Engineer may direct work by the licensee.
Rev. 9a 7 of 33 OQAMR9A.1/SQPFLR - 87
i 1
- APPENDIX A l OparstionsoriM51ntsn:nce'parconnsi.torsatorsLthasyst:3 to dssign drawing requirements, provided1the work and -actions are properly-
' documented and1that quality and' engineering; evaluations are-
~
obtained. These evaluations may be.obtained after-the-fact. ,
- 17) ' With regard l to Section 5.2.7.1 of ANSI N18.7 - L1976> titled
~
Maintenance Pronrams : The licensee will comply.with the ,
requirements of the first sentence of-the"fifth' paragraph, where> .}
practical. .This clarification.is neededLsince it is not,always: l possible:to promptly determine the cause of the malfunction.) In all:
cases, the licensee will initiate proceedings;to determine the'- l 3
cause, and will make'such determinations promptly, where practica1'.
- 18) .With = regard to SectionL5.2.8 of' ANSI N18.7. - 1976 titled Surveillance ._ ;
Testine and Insnection Schedule:- In-lieu of a " master' surveillance !
schedule," the.following'requirementishall be complied with: "A surveillance testing schedule (s) shall be established reflecting the
[ status of all' in-plant surveillance tests and Inspections."
- 19) With regard to Section 5.2.9 of ANSIfN18.7 -11976. 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 Housekeenine and Clean 11 ness' 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 asi ,
described.in the licensee'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, t- Acoroval and Control of Procedurga: The third sentencefin' Paragraph three is interpreted to mean: cpplicable procedures shall;be-t l
reviewed following an accident, an-unexpected, transient,.significant' operator error or equipment malfunction which results in'a reportable occurrence. The first. sentence in Paragraph,four.is interpreted to mean: This requirement for routine. followup review can be accomplished in several ways, including;(but not n' ecessarily limited to): documented step-by-step use of the procedure (such.as ,
occurs when the procedure has=a step-by-step checkoff associated with it), or detailed scrutiny of the procedure as' part of a documanted training program, drill, simulator exercise, or other such activity. Routinely used or Administrative type procedures will be reviewed no less frequently than every two years, but a procedures which are only used Infrequently,11.e., every three to '
five years, wilJ be reviewed prior to use. A revision of a procedure constitutes a procedure review.
- 2. ) With regard to Section 5.2.17 of ANSI N18.7 - 1976 titled Insoections: Not all inspections will require generation ,. ,
separate inspection report. Inspection. requirements may be i
Rev. 9a 8 of 33
.OQAMR9A.1/SQPFLR - 88
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I)
APPENDIX A' intsgrsted into cppropricts procedursa er othar docunnts with tha. 1 procedure or document serving -as 'the record. However, records-of _
inspections will be; identifiable.and retrievable.- '
-24) With regard to Section 5.3.9 of ANSI N18.?' J1976 titled Emernancv i !
Procedures: .As directed by-the NRC,'the' licensee willJfollow a format for emergency procedures which is " symptom". based:as' opposed, f to . ',' event"- based' as stipulated in Section - 5.3;9.1. Since the i licensee 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 TEyents:of .
Potential Emernancv: :NRCt. review of the~FSAR has identified all natural'occu; ices which affect the nuclear facility.= Therefore, the licensee will interpret ites (11) to mean the" natural
~
g 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 I a"
Procedures for Imolementina Emermancy Plan: Thel 11censee's NRC-accepted Emergency plan for each nuclear facility will-be: ,
implemented in lieu of the requirements in.this'Section.
- 27) With Regard to Section 5.2.18 of ANSI N18.7 - 1976- titled Control of
~
Soecial Processes: The last four.words of the first' sentence are- j 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 -1976Ititled Maintenance p and Modification: The first sentence'of the first paragraph could be
- . interpreted to require the same degree of inspection?for. all !
l- maintenance activities as was provided during construction. When l~ viewed in conjunction with Section 5.2.17,7 the third paragraph,.we'
! believe the actual ~1ntent is clear. We shall provide-inspections! '
comparable-in nature,and. extent to that provided during: construction if the maintenance / modification work is comparableiin nature and:
extent.
t
- 29) With regard to Section 5-3.5(4) of ANSI N18.7 - 1976 titled -
i Supogrtina Maintenance Documents: The licensee may choose to include ma6erial~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) E praedure may, simply state. i that the manual or a specific sect;on is to be tollowea for performing a particular function;.the manual must then be used-in conjunction with the. procedure for performing the activity. '(3)l The I j portinent material from the manual, either as originally written..or as modified by the author / reviewers of the procedure, may bi written
- l. Into and become a Part of-the procedure. '
In options',.(1) and (3) above, the material meets the requirement to receive "the sae level of-review and approval as operating procedures" since N material is reviewed as part of the procedure review process. I' otion (2), the requirements shall be deemed to ;
Rev. 9a L ~
9 of 33 0QAMR9A.1/SQPFLR - 89 a we -w*s e A
'f APPENDIX'A' d have bun'fulfilledTby: requiring W copyfof tha partinsnt s nual (manual sections) to be available to and~ considered by. persons-conducting the review of'the procedure. ' '
q 30)'. With! regard to Section 5.2.16 of ANSI N18.7?- 1976. titled Measurine:
and Test Eautoment: .The second~ sentence'of the third paragraph states " Records shall be.made and equipment ' suitably marked to indicate calibration status." The licensee willl utilize a- 3 computerized system to indicate the calibration-status'of installed-operations measuring and-test equipment in lieu offmarking or- .
tagging the individual item.. -
a j
NRC Regulatorv Guide 1.37 . " Quality Assurance Requirements fcr Cleaning .of.- .
Fluid Systems and- Associated Components of Water-Cooled Nuclear Power l Plants"' ,
(3/73)' Endorses ANSI N45~.2.1 - 1973.
x 't -
The Operational Quality Assurance Program complies'with the requirements of1 this.-Guide with the following clarifications: -
- 1) With regard to Paragraph C.3'of Regulatory Guide 1.37: - TheLwater 4 quality for final flushing of fluid. systems.and associated' components-shall be at least equivalent to the quality'of the,operatingJsystem water except for the oxygen;and nitrogen content, but;thisidoes 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, wrappfr.g caterials (other than Polyethelene), water soluble dam materials, lubricants,.NDT< penetrant ~
materials ant. couplants, wh!Jh contact stainless. steel'or nickel alloy surfaces shall not contain' lead, zinc, copper,{ mercury, cadmium '
and other low molting point metals, their alloys -or compounds :as basic and essential chemical constituents. Prescribed maximum levels -
o of water leachable chlorides, total halogens,-and sulphur and its compounds shall be . imposed on* expendable' products.
~
j
- 3) With regard to Section 5 of- ANSI N45.2.1;- 1973 titled-Installation
, Cleaninn: 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 operationr hase mainten;:nce,and modification activities which are comparabla .
'ture and extent to similar activities conducted during the or. . . tion phase, the licensee shall either control these activ. e,. Ier this ' Operational-QA Program or under an NRC t accepted Construction QA Program (Per OQAM 3.5.18). When thic Operational QA Prog-am is used, the licensee shall comply with the- i e Renulatorv Position established in this Regulatory Guide in that QA - ~
programmatic / adcinistrative requirements included therein (Subject
! to the stated clarifications) sha11' apply to these maintenance and ;
l modification activities even though such requirements may not have been in effect originally. Technicci requirements associated with "
Rev. 9a l
l 10 of. 33
! 0QAMR9A.1/SQPFLR - 90 l l
L t
__h_ s r y +
t APPENDIX A l ths mainten:nca er codification chall b3 tha criginal requirc= nts L 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 :
s'all be used; all definitions which are included in ANSI N45.2.10 '
s all be used as clarified in the licensee's commitment to
- Re e Latory Guide 1.74. !
'6) With regard to Section 9 of ANSI N45.2.1 - 1973 titled Records: The
- licensee 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 operations, qualified supervisory maintenance personnel determine.what items within a particular cleanness level.are appropriate. As an example. l the Raactor 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, the licensee 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 censidered to be of the same cleanliness as the system from which they were removed-Such components not4 not bc ;
recleaned prior to reinstallation provioed that measures are u ken to prevent degradation of the previously existing state of clean 11ners. !
NRC Regulatorv Guide 1.38 " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water Cooled Nuclear ,
Power Plants" (Rev. 2, S/77) - Endorien ANSI N45.2.2 - 1972.
The Operational Quality Assurance Program complies with the requirements of i this Guide with the following clarifications: l
- 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 i will be w.ed; all definitions which are included in ANSI N45.2.10 will be used as clarified in the licensee's commitment to Regulatory ,
Guide 1.74.
[i
- 2) With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled planning: l (first sentence) The soecific items to be governed by the Standard l shall be identified on the Q List. However, the Standard (as modified l by the clarificar8.ons 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 Result.g: [
The specific methods for performing and documenting tests and j Rev. 9a 11 of 33 ;
0QAMR9A.1/SQPFLR - 91
- l APPENDIX A inspectitns cro given in Palicica 10 cnd il cf tha Op;rctirnal QA Program. The requireaents in these Pol 2cies 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 Oualifications: 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 Itat=:- The licensee,may choose not to explicitly use the four level classification system. However, the specific.
requirements of the Standard that are agn:cretate to each class will generally be applied to the items suggest$d 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 containerizing items in storagefto control contaminants (Items (4) and (5)), the licensee may choose a storage atmosphere which is free of harmful contaminants in concentrations that could produce damage to stored items. Similarly (for Item-(7)) the licensee 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 clarifications apply whenever items (4),'(5) or (7) are subsequently .
referenced and to Section 3.5.1 titlad Caos and Pluem and Section 3&4 titled Methods of Preservation.
- 7) With ragard to Section 3.3 of ANSI N45.2.2 - 1972 titled Claaning:
(Third sentence) The licensee 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 (n) 9! solvent siay be used in a particular application.
l 8? With ruga ri to Section 3.4 of ANSI N45.2.2 - 1972 titlod Methods of Preservntion: (First f.entence) The licensee will comply with these ,
requirements subject to the clarifications of Section 3.2.1 (4) and (5) sbove, and the definition of the phrase " deleterious corrosion" -!
to mean thet corrosion which cannot be subsequently removed and which adeersely affects form, fit, or function.
- 9) With regard to Section 3.6 of ANSI N45.2.2 - 1972 titled Barrier and Wran Material and 3canicants: This section requires the use of
.,onhalogenated materials in cordoct with austenitic stainless steel.
Refer to Hegulatory Guide 1.37 above for the licensee's position.
- 10) With regccd to Section 3.7.1 of ANSI N45.2.2 - '1972 titled ;
Containers: Cleated, sheathed boxeo may he used up to 1000 lbs. '
rather than 500 lbs. as specified in 3.7.t(1). This type of box is !
safe for, and has been tu ted for, Icads up to 1000 lbs. Other !
Rev. 9a 12 of 33 OQAMR9A.1/SQPFLR - 92 !
x 1
APPENDIX A' national stcnd:rds allow this (cos redoral Sp:cific ticn PPP-B-601).
Special qualification testing may be required for loads above 1000 lbs.
3') 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.
- 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. The licensee will 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 Durine Loadine Snd Transit, '
j Identification and Markine, and Shinment from Countries Outside the United Statsa: The licensee will comply with the requirements of these Sections subject to the clarifications'taken to other Sections-which are referenced therein.
- 14) With regard to Section 5.2.1 of ANSI N45.2.2 - 1972 titlod $hionine Damana Insoection: Warehouse personnel will normally visually
- scrutinize incoming shipments for damage of the types ' listed. ia 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 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 documtnted and dispositioned as required by Policy 15 of the Operational QA Program.
The person performing the visual scrutiny during unloading is not censidered to be performing an inspection function as-defined under 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 itan Insoection: The second division of this subsection requires six additional inspection activities if an item was not inspected or examined at the source. The licensee will consider that a source inspection has been conducted if the supplier of the item is required to comply with ANSI N45.2.2 for the purchased item and if the supplier's program has been audited and found receptable in tho area (i.e. , the supplier performs a source inspection of his supplier or conducts a receipt inspection that includes, as applicable, the six additional items listed). i
- 16) With regard to Section 6.1.2 of ANSI N45.2.2 - 1972 titled Levels of Eintags: Subpart (2) is replaced with the following:
Rev. 9a 13 of 33 0QAMR9A.1/SQPFLR - 93 l q
APPENDIX A (2) L;vol B itets ch311 ba etered within a firo rcsictcnt, 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 -
o a 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 chall be provided with heating and temperature control or their equivalent to reduce condensation and corrosion. Minimum temperature shall be 40'F and maximum temperature shall be 140*F 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-Storane 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 or guards will not normally be provided.
g
- 18) With regard to Section 6.2.4 of ANSI N45.2.2 - 1972 titled Storane of lood 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 odents 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 pos 1ble contamination and mechanical damage to stored material."
- 20) With regard to Section 6.3.3 of ANSI N45.2.2 - 1972 titled Storane 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 N45.2.2 - 1972 titled Care of Iteas: The following alternates are provided for indicated subpart:
(1) " Items in storage shall have all covers, caps, plugs or other closures intact, or shall be elevated to allow for proper drainage. Methods used to seal openings shall be in accordance with Section 3 of this standard. Covers removed for internal access at any time for any reason shall be immediately rep' laced and resealed after completion of the purpose for removal.
Rev. 9a 14 of 33 0QAMR9A.1/SQPFI.R - 94
1 APPEND 1X A (5) "Sp;co h:3 tors in olectrien1 equipmant chall ba ensrgined un10:o a documented engineering evaluation determines that such space-heaters are not required."
(6) "Large (greater than or equal to 50 llP) 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 results of the evr'.uation 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 shaf t does r.ot coen to rese fu the same position occupied prior to rotation. For long shafts or heavy equipment subject to undesireable bowing, shaft orientation after. rotation shall be specified and obta in ed . "
- 22) With regard to Section 6.5 of ANSI N45.2.2 - 1972 titled Removal of Iteam from storama: The licensen 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 se* ince of the.Section is replaced with: " The -
licensee will deveL f, 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 dispositioned."
- 23) With regard to Section 6.6 of ANSI N45.2.2' - 1972 title'd Storage Records: The licensee will comply with the requirements of this Section with the 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-licensee employees who are accompanied by licensee employees.
- 24) With regard to Section 7.3 of ANSI N45.2.2 - 1972 titled Holsting 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 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 load. At all times, the codes governing re-rating of hoisting equipment must be observed.
Rev. 9a r
15 of 33 l
l OQAMR9A.1/SQPFLR - 95
i APPENDIX A .
NRC Ranulatory Guide 1.39 "HousckO: ping Requirc::nts fer Water-Cooled Nuclear I Power Plants" (Rev. 2, 9/77) - Endorses ANSI N45.2.3 - 1973.
l The Operational Quality Assurance Program complies with the requirements of i this Guide with the following clarifications:
- 1) For operations chase maintenance and modification activities' s which are comparable in nature and extent to similar activities conducted during the construction phase, the licensee shall ;
either control these activities under this Operational QA '
Program or under an NRC accepted Construction QA Program (Per OQAM 3.5.18),
s When this Operational QA Program is used, the licensee shall comply with the. ,
Remulatory 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 modification activities even though such requirements may not have been in ;
effect originally.- Technical requirements associated with the maintenancs-or .
modification shall be the original requirements or better (e.g., code !
requirements, material properties, design margins, manufacturing processes, l 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 *~
Included in ANSI N45.2.10 will be used as clarified in the licensee's commitment to Regulatory Guide 1.74.
Section 2.1 - Plannine: The licensee may choose not to utilize the fivelevel 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: ?
i safety-related systems. This will include, as a minisum, 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 resecor system are opened i
for inspection, maintenance or repair.
Additional housekeeping requirements will be implemented as required for control of radioactivo contamination, t
1 Section 2.2 - Procedures and Instructions: Appropriate procedures l will be written and implemented.
Section 3.1 - Control of Site Area: Not applicable to the Operations Phase.
Rev. 9a-16 of 33 OQAMR9A.1/SQPFLR - 96
msm, < ,' 1 1
APPENDIX A S ctitn 3.2 -' Control of Facilitima: Tho~11 con ca cay choosa nst 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 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, maintenance or repair.
Additional housekeepin a raquirements will be implemented as required for control of radioactive contamination.
Section 3.3 - Materials and Eauinment: The first paragraph-in this-Section is not' applicable to the Operations phase.
Section 3.4 - Construction Tools. Sunn11as. and Eouinment: Not applicable to the Operations phase.
Section 3.5 - Surveillance. Innnection-. and Examination:
Subparagraph (1) is not applicable to the Operations phcse; (2), (3) and (4) will be implemented.
Section 4 - Recorda: 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 PIotection and Prevention: The accepted Fire Protection Plan shall be used in lieu of the general. requirements in this section. .
1 NRC Ranulatory Guide 1.58
" Qualifications of NuclearL 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) The licensee may choose not to apply the requirements of this Guide to those personnel who are involved in day-to-day operations, surveillancs, maintenance and certain technical and support services.
whose qualifications are controlled by Technical Specifications or other Ope.ational QA Program commitment requirements.
- 2) With regard to Section 1.2 of ANSI N45.2.6 - 1978 titled Aeolicability: The third paragraph requires that the Standard be ;
used in conjunction with ANSI N45.2; the licensee no longer specifically commits to ANSI N45.2 in the~0perational QA Program.
The fourth paragraph requires that the Standard be imposed on Rev.-9a OQAMR9A.1/SQPFLR - 97
}/
- j. ,
APPENDIX A~
persenn01 oth r th:n 11c:n co c:ployc:s; tha cpplicability of ths-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 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in the licensee's commitment to Regulatory Guide 1.74.
- 4) With regard to Section 2.5 of ANSI N45.2.6-- 1978 titled Physical:
The licensee will implement the requirements of.this Section with the stipulation that, where no spenial physical characteristics are required, none will be specified. The converse is also true: If no special physical requirements are stipuisted by the licensee, none are considered necessary.
- 5) With regard to Section 3.5 of ANSI N45.2.6 - 1978 titled Education and Ernerience - Recommendations: The licensee reserves-the right to use personnel who do not meet is11 the coucational and experience requirements of this Section provided: The use of personne1'who do not meet these requirements shall be the exception rather than the rule and each such case shall receive a documented management evaluation and justification for the exception.- An example of a documented management evaluation and @:tification would be one 1 which includes objective criteria (exa ination, review of actual work Perfo:med) to demonstrate that equivalent competence is-possessed by such an individual. -
l NRC Remulatory Guide 1.64 " Quality Assurance Requirements'for the Design of Nuclear Power Plants" (Rev. 2, 6/76) - Endorses ANSI N45.2.11'-'1974.
The Operational Quality Assurance Program complies with the requirements of I this Guide with the following clarifications:
- 1) For operations phase maintenance and modification j activities which are comparable in nature and extent to similar activities conducted during the construction ] !
phase, the licensee shall either control these activities under this Operational QA Program or under an NRC accepted l Construction QA Program (Per OQAtt 3.5.18). When this i Operatione' QA Program is used, the licensee shall comply i with the Renulatorv Position established in.this Regulatory Guide in that QA programmatic / administrat.1ve j r requirements included therein (subject to tta clarifications listed below) shall apply to these maintenance and modificatiori activities even though such i requirements may not have been in effect eriginally.
Technical requirements associated with c.aintenance'and modifications shall be the origina1' requirements or better (e.g., code requirements, material properties, design margins, manufacturing processes and inspection requirements).
- 2) With regard to 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 provisions Rev. 9a reayY:TYv1Ju2mratrtn_m 18 of 33 '.
APPENDIX A ef th3 Regulot:ry Guid] cro 00ticfied, cnd (b) tho justification is individually documented and approved in advance by the Supervisor's management, and (c) qvelf t;' naurance audits cover frequency and effectiveness of use of Supervisore as design verifiers to guard against abuse.
- 3) With regard to Section 1.4 of ANSI N45.2.11 - 1974 titled DAfinitions: 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 clariffel in the licensee's commitment.
- 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 Licensee's Audit Program will be implemented in accordance with' and to meet the requirements of:
ANSI .N4',.2.12 as endorsed in Appendix A; Policies 2, 3,16 and 18 of the P,serational QA Program, and the requirements of the individual nutuear facility Technical. Specifiestions 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, design documents or portions 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 /
should be on the document or on a separa'te form traceable to the-document. A document that indicates the reviewer's comments need not be retained.
- 6) The licensee does not require the SAR to be a design document. l However, if the SAR contains any design or design input that has not- -l been previously documented, reviewed end approved in accordance with i the requirements contained in the OQAM or another approved design control QA program and if the SAR is used as a design document I
during the design process, that specific information must be controlled and verified in accordance with the commitments here and Policy 3 of the 0QAM.
l l 7) With regard to Section 6.1 of ANSI N45.2.11 - 1974 titled General:
The third paragraph in this Section stipulates certain requirements relative to "the results of design verification". The licensee may comply with these requirements by having the Reviewer (s) sign and date an appropriate document providing the following conditions are also met:
i l a) Documented engineering / design procedures are established which 1
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.
Rev. 9a 19 of 33 l
OQAMR9A.1/SQPFLR - 99
, . - - ~
APPEND 1X A .
c) Tho procedur:s cpecify th3 cxt:nt, cf dtcur ntation n2c00:ary L for the type of design verification applicable to the complexity of ;
the design. >
i d) The signature and date f.s affixed in accordance with the '
l procedures .
.The licensee 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' used.
- 8) The timing of design verification is not mentioned in the Standard.
The licensee shall perform verification in= a timely manner. If
- other than by qualifications testing of a prototype or lead i production unit, verification should be completed prior to release for procurement, manufacturing or construction or release to another ;
organization for 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. unverified 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 .i irreversible without extensive demolition 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: i The licensee shall maintain records -in accordance with and .to meet '
the 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 Renulatorv Guide 1.74 " Quality Assurance Terms and Definitions" (2/74) -
Endorses ANSI N45.2.10 - 1973.
' The Operational Quality Assurance-Program complies with the requirements of this Guide with the following clarifications: '
- 1) The licensen 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", the licensee will use the following: " Inspection (When used to refer to activities that are NOT performed by Quality Programs' personnel) -
Examining, viewing closely, scrutinizing, looking over or otherwise ,
checking activities. Personnel performing these functions are not
~
necessarily certified to ANSI N45.2.6." l Rev. 9a >
20 of 33 !
OQAMR9A.1/SQPFLR - 100
APPENDIX'A Wh2n ths licen:co intenda for In:pections to b2 perferoid in -
accoriance with the Operational-QA Program by personnel certiflei as requi ed by that Program and for activities defined by " Inspection" in AN:11 N45.2.10, appropriate references.to Quality Programs which will perform the activity or to Quality Assurance Procedt.res/
Instructions to be used for performing the activity will be made.
If suel; 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", the licensee will utilize the definitions given in ANSI-N45.2.13.and in Regulatory Guide.l.74 The compound definition is given as follows: " Procurement documents - Contractually binding documents that identify and define the requirements which items or services must maet in order to be considered acceptable by the purchaser. Ther include documents which authorize the seller to perform services or_ supply equipment,' material or facilities,on behalf of the purchaser (e.g. , contr. acts, letters of intent, work orders, purchest orders, or proposals and their acceptance,_
drawings, speciftestions, or irst-uctions which define requirements for purchase)."
- 4) " Program Deficionales" (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 3 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 the licensee's suppliers.
- 6) This section deleted in Revision 4.
- 7) " Independent Verification" - Verification by antindividual other than i the person who performed the operation or activity being verified that required actions have been completed. Such verification will ;
not require confirmation of the identical' action when other indications provide assurance or indication that the prescribed j activity is in fact complete. Examples include, buc 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 remoteLyalue 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 Rev. 9a 21 of 33' i OQAMR9A.1/SQPFLR - 101 l
1 2
-- .. ~
4 APPENDIX A cnd ccccpted for use; (2) tha.rsvision cf th2t NRC ccc:pted progrca ,
which is in.effect at the time that the licensee authorizes 'i commencement of work; and,.(3) a program which the licensee's ,
quality assurance organization reviews and concurs that the QA 98_
Program controls are acceptable for the activity,to be performed.
Ikeference: OQAM 3.5.18) ' {
- 9) "Special Processes" - Processes which are controlled and monitored in l
,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)- l
- A device, permanent 1y' installed, which functions as a part of a 7 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 j 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 been addressed will produce the intended results. ;
NRC Ranulatory Guide 1.88 " Collection, Storage and Maintenance of Nucler.r 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: ,j
- 1) With regard to Section 3.2.1 of ANSI N45.2.9 - 1974 titled Generation -
of Ouality Assurance Records: The phrase " completely filled out" is clarified to mean that sufficient information is ' recorded to fulfill the intended purpose of the record.
- 7) 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, the licensee may utilize a computer ,
assisted random access, filing system where such location could not be readily "dacumented, not would such a location be " relevant.")
The storage location will te delineated, but where file locations change with time, the_specit!c 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:
The licensen's contractual agreement with its contractors and suppliers will constitute fulfillment of the requirements of this l Section.
Rev. 9a 22 of 33
'OQAMR9A.1/SQPFLR - 102
APPENDIX A 4)- With ragsad to S:ction 5.4 cf 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 Safekeeoinn:
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 exceptions to this requirement must be evaluated and approved:by the Director, Quality Programs; a list of all such excepted records shall 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 cualification and. training records, equipme,nt 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 Stornne 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- 1 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 Storame: The first sentence is clarified by stating that an individuni 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. i NRC Renulatorv Guide 1.94 " Quality Assurance Requirements for Installation, I 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. '
s The Operational Quality Assurance Program complies with the requirements of this Guide with the following clarifications: l Rev. 9a 23 of 33 OQAMR9A.1/SQPFLR - 103 !
i
~
1 d
.. APPEND 1X A ;
1), .F~ op: rations phaso caintsn:ncs cnd codificaticn ac*.ivitiss l which are comparable in nature and extent-to similar activities I
- l. conducted during the construction phase,.the licensee shall L either control these accivities under this Operational QA ;
l Program or under an NRC accepted Construction.QA Program (Per- 1 i OQAM 3.5.18).. When this Operational QA Program is used, the 4
- 1. licensee shall comply with the Renulatory position established in this Regulatory Guide in that QA programmatic / j administrative requirements included therein shall apply to '
these maintenance and modification activities even though such l requirements may not have been in effect originally. Technical' requirements associated with maintenance and modifications ,
i shall be'the original requirements or better (e.g., code i l requirements, material properties, design margins, L manufacturing processes and inspection requirements).
- 2) . With regard to Section.1.2 of ANSI N45.2.5 - 1974 titled Ano11 cab 111tv:
The 'first sentence in this Section is not applicable to the operations.
~
phase. The licensee 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 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, i In the second paragrap'h of this Section, the licensee 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 Resnonsibility: This Section a n,quirements are met by the '
definitions for position and the organizational responsibilities !
outlined in the Technical Specifications, Policy 1 of the OQAM and the position descriptions for plant personnel.
- 4) With regard to Section 14 of ANSI N45.2.5 - 1973 titled Definit 1 Sna:
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 l shall be used as clarified in the licensee's commitment to '
- 5) With regard to Section 2:1 of ANSI N45.2.5 - 1974 titled Planninn: '
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 items inspected with M&TE which is found to be out of calibration shall be considered unacceptable. The licensee 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 i
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. i
- 7) With regard to Section 5.5 of ANSI N45.2.5 - 1974 titled Weldine:
The licensee will comply with inspection requirements of the l
applicable welding codes identified in the UFSAR and any exceptions thereto.-
- Rev. 9a '
24 of 33 dqAMR9A.USRF&G - 1% . _ , . ~ -
APPENDIX A ,
NRC Remulatory Guide 1.116 .'" Quality Assurance Requirements for Installation, I Inspection and Testing of Mechanical Equipment and Systems" (Rev. 0-R, 6/76) -
' 1 Endorses ANSI N45.2.8 - 1975. '
i The Operational Quality Assurance Program complies with the requiremen+s of ,
this Guide with the following clarifications- '
- 1) For operations phase maintenance and_ modification activities t which are comparable in nature and extent to siellar activ' ties i conducted during the construction phase,'the licensee shall ;
either control these activities under this Operational QA Program or under an NRC accepted Construction QA Program (Por-OQAM 3.5.18).- When this-Operational QA Program is used, the l licensee shall comply with the Ranulatory 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).
- 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 Stande d i shall also be applied after fuel load; therefore, the last twenty-two ,
words in the last sentence 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 Ano11 cab 111tv: The first sentence in this Section is not applicable to the operations phase. The licensee shall comply with the third' sentence in this Section with the clarifications that "important i
mechanical systems to be, covered" is interpreted to mean those to which the DQAM applies, and the extent of coverage" shall be defined l
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 Resoonsibility: This Section's-requirements are met by the definitions for positions and the organizational responsibilities outlined'in the Technical Specifications, Policy 1 of the OQAM 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 the licensee's commitment to r i Regulatory 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 l maintenance and modification procedures.
( Rev. 9a t
25 of 33.
OQAMR9A.1/SQPFLR - 105
[
APPENDIX A NRC Reaulatorv Guide'1.123 " Quality Assurance Recluirements for Control of Procarement 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 wJth 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 i 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 the licensee's commitment to Regulatory Guide'1.74. The'two exceptions are defined in Appendix A under Regulatory Guide 1.74.
- 2) With regahd to Section 1.2.2 of ANSI N45.2.13 1976 titled.
Purchamer's Resnonsibilities: Item c is one of the options which may be used by the licensee 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 Program may also be used.
- 3) .4 regard to Section 3.1 of ANSI N45.2.13 - 1976 titled Procurement' Document Prenaration. Review and Channe 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 j 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 1 Document control: The licensee will meet the requirements of l 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: The licensee will comply with an alternate paragraph '
which 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 Channes in Items or Services: f The phrase "the Operational QA Program" will be inserted in lieu of " ANSI N45.2,.Section 7."
4
- 7) With regard to Section 8.2 of ANSI N45.2.13 - 1976, titled Disoosition: 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 submitted to the Purchaser for ' approval of the recommended disposition prior to shipment when the nonconf - .nce could adversely affect the end use of a module or shipable component # relative to safety, interchangeability, operability, reliability, integrity, or maintainability:
Rev. 9a 26 of 33 l OQAMR9A.1/SQPFLR - 106 i 1
l
r i
APPENDIX A
- 1) Technics 1 or ::tsrici requisc::nt is violated; 2)- Requirement in Supplier documents,' "hich have been approved by the Purchaser, is violated;
- 3) Nonconformance cannot' be corrected by cont inuation. of the original manufacturing process or-by rework; and/oc.
- 4) The item does not conform to theLoriginal requirement even tnvugh 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 requirener.ts regarding end use. A shippable component is a part or 1 subassembly of.a device, instrument, or' piece of equipment which is~
shipped as an individual item and which has been evaluated by' inspection and/or test for conformance to procurement . 4uirements regarding end usc.
~
f
- 8) With regard to Section 12 of ANSI N45.2.13;- 1976 titled Audit of I 4
Procurement Pronram: The licensee audit program will be implemented in accordance with and to meet the requirements of:- ANSI N45.2.12- u as endorsed in Appendix A;. Policies 2, 4 and 18 of the Operational- )
QA Program, and the requirements of.the individual nuclear' facility 4 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 the. licensee may not always be
~
able to obtain agreement with a Supplier. _The licensee retains the ultimate responsibility for performance of purchased equipment. 'The appropriate angineering discipline will exercise this management / engineering prerocative with respect to the final decision on post installation testLrequirements. ,
i
- 10) With regard to Section II o'. ANSI N45.2.13 - 1976 titled Ouality L
Assurance Records: The licensee shall maintain records in '
accordance with and to e.eet the requirements ef Policy 17 of the- ;
OQAM and ANSI N45.2.9 as specified in Appendix A..
NRC Renulatorv Guide 1.144 " Auditing of Quality Assurance I rograms 'ior Nuclear Power Plants" (Rev. 1, 9/80) - Endorses ANSI N45.2.11 - 1977.
The Operational Quality Assurance Program complies with the requirements of !
this Guide with the following clarifications:
- 1) With regard to Sectiot 1.4 of ANSI N45.2.12 - 1977 titled De finit i.2na : With two exceptions (Program Deficiencies and audits) the de'initions in thia Standard which are not included in ANSI N45.". 10 will be used: All definitions which are included in ANSI N45.2.10 will be used as clarified in the licensee's Rev. 9a 0QAMR9A.1/SQPFLR - 107
- -Eel-t 1
APPENDIX A {
comait:2nt to R:gulctery Guido 1.74. Th3 excepted dsfinitions' cro . )
defined in Appendix A under Regulatory Guide 1.74. I 2). With regard to Section 2i2 of ANSI.N43.2.12 - 1977 titled Personnel Oualification: The qualification of licensee audit personnel will be accomplished as described to meet the requirements of ANSI i N45.2.23 1978 as endorsed in Appendix A and Policies 2 and 18 of the j
Operational QA Program, a
- 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 licensee i audit personnel will,be accomplished as described to meet the requirements of ANSI N45.2.23 - 1978 as endorsed in Appendii A and- .:
Policies 2 and 18 of the Operational QA Program. -'
- 4) .With regard to Section 2.4 of ANSI N45.2.12 - 1977' titled Maintenance of Proficianev: .The maintenance of proficiency of licensee 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.
- 5) With regard to Section 3.3 of ANSI N45.2.12 - 1977 titled Essential Elements of the Audit' System: The licensee will. comply with subsection.3.3.5 as it-was originally written (subsection 3.2.5) in ANSI N45.2.12, Draft 3, Revision 4: " Provisions.for reporting on the effectiveness of the quality assurance program to the ,
responsible management." For the auditing organization (licensee),
effectiveness is 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, the licensee.may not directly report on the effectiveness of the quality assurance programs to the audited i organization when such organizations are outside of the licensee. .
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 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 and a corrective action completion date; these dates are subject to revision (with the approval of Quality Programs or Supplier Quality Assurance) and must be escalated to higher 9a 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 Schedu11ne:
Subsection 3.5.3.1 is interpreted to mean that the licensee 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.
Rev. 9a 28 of 33 0QAMR9A.1/SQPFLR - 108
- - , , - - - . -w,, n b
APPEND 1X A:
- 7) With rcgard'to Saction'4.3.1 ef ANSI N45.2.12 - 1977 titled Erg '
Audit Conference: .The licensee will comply with the requirements of this Section by 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) 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 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'Andit 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.
The licensee will comply with an alternate sentence which reads: "When available, objective evidence shall be examined ;
for compliance with quality assurance program requirements. If subjective evidence is used (e.g., personnel interviews) then the audit report must indicate how the evidence was obtained."
(b) Suosection 4.3.2.4 la modified as follows to take into account the fact that some conditions adverse to quality are virtually
" obvious" with respect to the needed corrective action: "When a condition adverse to quality 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."
I (c) Sibsection 4.3.2.5 contains a recommendation which.is clarified with the definition of " acknowledged by a member of the audited j organization" to mean that "a member" of the audited orgtnization 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.
The licensee will comply with an alternate sentence which reads: " Corrective action taken as a result of the last previous audit of the same area shall be reviewed or reaudited, j if necessary, to evaluate the effectiveness of the action to j resolve the identified condition adverse to quality."
i
- 9) With regard to Section 4.3.3 of ANSI N45.2.12 - 1977 titled Egit-Audit Conference: The licensee will substituts and comply with ,
Rev. 9a l OQAMR9A.1/SQPFLR - 109
j APPENDIX'A 1 tho following paragrcph: '"Fcr all cxtern21 cudito, a post-cudit ,
conference shall be held with management of the audited organizatici y
to present audit findings and clarify misunderstandings; where no. ;
adverse findings exist, this conference may be waived by management j of the audited organization: such waiver shall be docuwenited 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. 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 Renortine:
(a) inis Section requires that the audit report shall be signed by 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. The licensee will comp"ly with Section 4.4 as clarified in the following opening: An= audit report, which shall be signed 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' l 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 the licensee at the time the audit report is- ;
issued. ,
(b) The licensee 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 t;111 provide a summary of the audited areas and the results.
(d) Subsection 4.4.6 requires audit reports to include recommendations for corrective actions; the licensee may choose
- not to comply with this requirement. Instead, licensee auditors / lead auditors are required to document all adverse audit findings. The procedure for processing quality deficiency 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 quality deficiency document with these " Auditor Recommendations" is then transmitted to'the audited organization. In addition, appropriate Quality Programs or Supplier Quality Assurance personnel are required to review 9a corrective action taken for the condition adverse to quality document and determine if it is acceptable. Any disagreements must be escalated to higher management for resolution. ,
Rev. 9a i 30 of 33 0QAMR9A.1/SQPFLR - 110
i
' APPENDIX A (e) Th3102t paragraph ~ 1n Section 4.4 d:als with diotribution of audit reports. .The licensee will comply with these
~
requirements after. substituting the followir's for the last sentence: "The audit 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 By Audited Dreanization: The licensee will comply with the i following clarification of this Section: " Management of the audited i organization or activity shall review and investigate all adverse audit findings, as necessary, to determine and schedule appropriate- i corrective ection including action to prevent recurrence. They shall respond, in writing, within thirty working days after the date '
of issuance of quality deficiency documents generated as a result of the audit clearly stating the corrective action taken or planned to prevent recurrence and the results of the investigation.if 1 conducted, liowever, written response is not necessary if correcttve
- action is taken and verified prior to issuance of the audit repop,.
The audited organization shall take appropriate action to issu%
that corrective action is-accomplished as scheduled." The Director, Quality Programs or the Manager, Nuclear Safety Oversight, as applicable, may, at their discretion, waive the requirement for a 9a :
supplementary response. 4
- 12) With regard to Sections 3.4 and 4.2.1 of ANSI N45.2.12 - 1977 titled' Audit plannine and Written plan respectively: In the case of a moni+- & c audit previsions for " Written Plan" is met by the overall audit pt.nni.'s domments, 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 audits 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 referencas) 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~0QAM.
- 14) Paragraph C.3.b(2) first sentence is replaced with the following:
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 selected method of source verification, should.be conducted as follows:
Paragraph C.3.b(2), second paragraph is replaced with the following:
An evaluation of the supplier should be performed annually. This evaluation must be formal, with the results document.ed and approved ,
by responsible Supplier Quality Assurance management; and it must 9a 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, Suppliers shall be re-audited every three years. '
Rev. 9a i
31 of 33 '
OQAMR9A.1/SQPFLR - 111 1
APPENDIX A .I Parcgr ph cdditicns to C.3.b(2) cro co follows: Provicualy cvolust:d i and approved active suppliers, for which audit is nel the selected l method of source verification, should be evaluated concurrent with the award of a contract. Regardless of the results of the evaluation, active Suppliers (except'those. excluded under C.3.b(1) l above) shall have been source verified (audit, surveillance or i
inspection) within' two years prior' to award of a contract or have ,
j source verification 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 !
the other methods allowable under 10CFR50, Appendix B, i Criterion VII)'. '
- 15) Paragraph C 4.a of Regulatory Guide 1.144 (and Section 3.5.3.3 of i ANSI N45.2.12 which it references) shall be Implemented with the clarification.that the Director, Quality Programs, the Manager, Nuclear Safety Oversight or their designee shall determine which 9a reorganizations or procedure revisions are "significant."
- 16) With regard to Section 5.1 of ANSI N45.2.12 - 1977 titled General:
The licensee 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.
l 17) With regard to Section 4.3.2 of ANSI-N45.2.12 -1977 titled Audit i
Process: Subsection 4.3.2.6 is modified as follows to account for the fact that !amadiate notification is not always possible:
" Conditions requiring immediate corrective action (i.e., those which t
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 responsible 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 Renulatory Guide 1.146 " Qualification of Quality Assurance Program l
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 ,
l B45.2 (presumed to be N45.2); the Operational QA Program does not include a commitment to this standard; therefore, the licensee will comply with an alternate subsection 2.2.1 which reads:
Rev. 9a '
32-of 33 ,
^
OQAMR9A.1/SQP1LR - 112 i
APPENDIX A Orientstion to provids a werking knowltdgo cnd undcrstanding of the Operational QA Program, including the ANSI standards and Regulatory Guides included in Appendix A of that Program, and the licensee's procedures for implementing audits and reporting results.
- 2) With respect to Section 4.1 of ANSI N45.2.23 - 1978 titled Ormanimational Resoonsibilitv: Le licensee will comply with this Section with the substitution of the following sentence in place of the last sentence in the Section.
The Director,-Quality Programs; Manager, Quality Systems; the Supplier Quality Assurance Manager or Lead Auditor.shall, prior 9a to commencing.the audit, assign personnel who. collectively have experience or. training commensurate with the scope, complexity, or special nature of the activities to be audited.
Self-initiated monitoring audits 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 Proficiencv: The licensee will comply with,the requirements 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 Updatinn of Lead Auditors' Recorda: The licensee will substitute the-following 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: The licensee 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 Comoetence: Add "This includes R0 (maximum of 1 credit) and SRO (maximum of -2 credits) licenses" to ,
last sentence of this subsection. !
l i
Rev. 9a 33 of 33 ;
j 0QAMR9A.1/SQPFLR - 113 '
APPENDIX B APPENDIX B DOCUMENT CONTROL RESPONSIBILITY FOR OUALITY-RELATED DOCUMENTS DOCUMENT PREPARED BY REVIEWED BY APPROVED BY ISSUED BY A. Onerational Quality Programs Director, Vice President, Director, Quality Assurance Quality Programs (5) Nuclear Engineering Quality Programs Manual (Topical) & Support Director, Nuclear Vice President, Support Nuclear Operations Director, Nuclear .Vice President,
. Plant Engineering Human Resources
& Administration GGNS General Manager Vice President, Manager,. Plant Operations Support Modification &
Construction Director, Nuclear Senior Vice President, Licensing Planning & Assurance 9a Director, Corporate Services Manager, Nuclear g
Safety Oversight B.I. Quality Assurance Quality Quality . Director, Director, Procedures Programs Programs Quality-Programs -Quality Programs .
- 2. Quality Assurance Quality Quality Responsible Manager, Manager, Instructions Programs Programs ' Quality Quality Services Programs Rev. 9a Page 1 of 5 APPBR9A.1/SQPFLR - 1
ATPENDIX B DOCUMENT PREPARED BY REVIEWED BY APPROVED BY ISSUED BY B. (Cont'd)
'3. Supplier Quality Supplier Supplier Manager, Nuclear Manager, Nuclear Assurance Quality Assurance Quality Assurance Safety Oversight Safety Oversight Procedures 9a Director, Quality Programs C. Plant Staff and Plant Modification and Construction Procedures
- 1. This'Section deleted in Revision 4
- 2. Administrative Plant Staff and GGNS General Manager GGNS General Manager. GGNS General Manager Procedures Plant Modification (Safety-Related) & Construction Manager, Plant Manager, Plant Modification & Modification &
Construction (9) Construction (10)
Director, Quality Programs (5)
Plant Safety Review Committee (8)
- 3. This section deleted in Revision 3.
- 4. Plant Section Plant Staff and See Note (15) See Note (15)
Procedures See Note (15)
Plant Modification
& Construction Assigned Reviewer See Note (3)
- 5. Plant Section Plant Staff and See Note (15) See Note (15) See Note (15)
Instructions Plant Modification
& Construction Assigned Reviewer (See Note 3)
Eev. 9a Page 2 of S APPBR9A.1/SQPFI.R - 2
APPENDIX B DOCUMENT FREPARED BY REVIEWED BY APPROVED BY ISSUED BY D. This section deleted in Revision 4 E.1. Entergy Responsible Director, Quality Responsible Administrative Operations Staffs Programs (14) Vice President Services Management Manual Responsible Director / Manager-
- 2. Nuclear Nuclear Support Section Manager Director, Nuclear Director, Nuclear.
Support Staff' Support Support Administrative Director, Quality Procedures Programs (5) GGNS General Manager (11)
, n. Environmental Nuclear Support Manager, Radiological Director, Nuclear Director, Nuclear Surveillance Staff & Environmental Support. . Support Program Services Section Procedures Assigned Reviewer i
See Note (3)
- 3. Nuclear Nuclear Licensing Section Manager Director, Nuclear Director, Nuclear Licensing Staff Licensing- Licensing Administrative Director, Quality Procedures Programs (5) 93
- 4. Emergency Emergency Preparedness Supervisor, Emergency GGNS General Manager, Emergency Preparedness Staff Preparedness- . Manager (12) Preparedness Administrative Procedures Director, Quality Manager, Emergency Programs (5) Preparedness:
Rev. 9a Page 3 of 5
-APPBR9A.1/SQPFLR - 3
-. - . . _ - , - a
APPENDIX B DOCUMENT PREPARED BY REVIEWED BY APPROVED BY ISSUED 21.
F. Nuclear Plant Nuclear Plant Nuclear Plant Director, Director, Engineering Engineering Staff Engineering Nuclear Plant Nuclear Plant-Administrative Principal Engineer Engineering Engineering i Procedures or Senior Staff Engineer or Quality Engineering Director, Quality Programs (5)
G. This section deleted in Revision 5.
H. Q-List Nuclear Plant Director, Director, Director, Engineering Staff Nuclear Plant Nuclear Plant Nuclear Plant Engineering Engineering Engineering Manager, Nuclear Fuels (7)
Director, Quality Programs (5)
I. Corporate Corporate Services Section Manager Director, Corporate Manager, Purchasing Services Staff Services Administrative Director, Quality Procedures Programs (5)
J. Nuclear Fuels Nuclear Fuels Manager,~ Nuclear- Vice President, Manager, Nuclear Administrative Staff Fuels Nuclear. Engineering Fuels Procedures Director, Quality & Support Programs (5)
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APPENDIX B NOTE: 1) Responsible individuals listed above csy have designated alternstes who are cuthorized to perfora function.
- 2) Designated support organization (other licensee organizations, contractors, consultants, etc.)
also be authorized to perform certain of the functions.
- 3) See Paragraph 5.4.3 of this Manual.
- 4) Sections 6. 5.3, 6.5.4, 6.5.5, 6.5.6, 6.5.8, and 6.5.13 apply to this Appendix.
- 5) The Director, Quality Programs reviews these documents to assu e quality requirerents are addressed and provides concurrence. Concurrence indicated by the actual signature may be provided by t.ny Manager QP, the Director, Quality Programs, or designee.
- 6) Review for comment not concurrence on matters relative to procurement.
- 7) On matters relating to nuclear fuel and nuclear core design.
- 8) As required by the Technical Specifications.
- 9) For those procedures implemented by Plant Modification and Construction.
- 10) Those procedures ' addressing responsibilities and authorities of the Plant Modification and Construction
, Section are approved by both the GGNS General Manager and the Manager, Plant Modification & Construction.
- 11) Environmental Surveillance Program Administrative Procedures Oniv.
- 12) For those procedures directly interfacing with Plant Emergency Procedures.
- 13) SRC Procedures OnIV.
- 14) Safety Related Oniv.
- 15) Plant section procedures / instructions are reviewed and approved in accordance with the guidelines as stated in Technical Specification section 6.5.3.1.
Rev. 9a 'l
[ APPBR9A.1/SQPP,R - 5 l
- APPENDIX C OPERATIONAL OUALITY ASSURAhi;-
PROGRAM IMPLEMENTING PROCE" M Implementing Document by Organization. 10CFR50, Appendix B, Criteria .
- Summary 1 2 3 4 5 6 7. 89 10 11 12 13 14 15 16 17 18' A. Ouality Pronrams
- licensee's QA Program Policies
- 2. QA Procedure Manual X X 'X X X X X X X^ XX X X X X X X ' 'X -for all 10CFR50, Appendix BL
. Criteria,'and. provide appro-~-
- 3. QA Instruction Manual X X X X X X X X X X X X- X X X X X X priate .:implementatior.
procedures / instructions. (QA-Procedures are numbered by; Appendix B Criteria).
B. Nuclea- Licensine Nuclear Licensing X X X X 'X XX .XX X. Emphasis of Nuclear Licensing Administrative. is on construction licenses -
Procedures and permits; safety analysis;.
fire protectfan; and, SRC support.
C. Nuclear Enrineering
& Sucoort
- 1. NPE Administrative X X X'X .X X~X X: X X X X Emphasis of Nuclear. Plant Procedures Engineering.is on design, independent review, evaluation '
and technical support.
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. 3 ._ - . . - . . . ._
7,. -
.m APPENDIX C-OPERATIONAL OUALITY ASSURANCE PROGRAM IMPLEMENTING PROCEDURES C.. Nuclear Enrineerine h_Sucoort (cont'd)
Implementing Document by Organization- 10CFR50, Appendix B, Criteria Summary 1 2 3 4 5 6 7 8 9 10 21 12 13 14 15 16 17 18
- 2. Nuclear Fuels Administrative Procedures X X X X X X X X X.X~X Emphasis on nuclear fuel cycle management..
D. Plant Staff and Plant Modification &
Construction
.-l. Operations Manual
- a. Safety Related X XX X X XX X X X X X. X X X X -X- The Operations Manual con-Administrative -tains implementing procedures Procedures .for all'10CFR50, Appendix B Criteria.
E. Esercency Preparedness Emergency Preparedness X- X X ': X X X XX X Emphasis of Emergency 1 Administrative Preparedness.is on Readiness Procedures for Emergency Response.
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= - - = - :- - :- - - - --- - - - - '--- -
Attachment E to AECM-90/0173 ENTERGY OPERATIONS. INC.
PRESIDENT S CHIEF EXECUTIVE OFFICER I
I SENIOR VICE PHESIDENT I
PLANNING G ASSURANCE ig___I -
I DIRECTCR NAMBER NANAGER l
TOTAL NUCLEAR SAFETY R.ANNINS 8 g
00ALITY Ov8 BIGHT PROFESSIONALISM i
r - " -" n SUPPLIG '
M EAR SERVICES
!90R AND ges gggg.3 SWPLIER }
- i i i
i AND SENERAL 9 tits W8ES-3 NANAGER MANAGER O!NECTM NUCLEAR QUAL A ""
__E
- - Indicates that Supplier Quality Assurance and Servicae Quality Assurance on Preeldent have accessrelated settees to the f5eeldent and CEO and Senior Vice te quality.
Indicates that these three site surlier GA cesenizatione communicate with conce S N *rese ut$ Es kkerS!a!b )
A9009171/SNLICFLR - 9 l
'. APPENDIX C:
OPERATIC?.AL OUALITY ASSURANCE _
. PROGRAM IMPLEMENTING PROCEDURES l.
Implementing Doc 9 ment by Organization 10CFR50, Appendix B, Criteria
. Summary-1 2 3 4 5 6 -7' 8 9 10 11 12 13'14 15 16 17.18 F. Corocrate Services Corporate Ser7 ices X X X X X X X X X X. X Emphasis of. Corporate Services Administrative is on procurement-and admin -
Procedures 1strative services..
G. Nuclear Sucoort Nuclear Support X X X X X .X X X X. Emphasis of Nuclear Support is:
Administrative on environmental'11 censes and.
Procedures permits and contract' management.
H. Supplier QA Emphas.is of Supp1'ier QA'is on 9 Supplier QA X X X ' X X X X X X' X' -
- Procedures .. supplier activities.-.
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- Page 3 of'3.
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APPCR9A.1/SQPFLR m.
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~'
, , , 3 CONCURRENCE' REVIEW > FORM = '
. SECTION I _
AECM-90/0173 Rev. O
-RESPONSE'DUE: 09/25/90
_( NRC Required or Target)
SUBJECT:
Supplier QA Consolidation
_{0perational Quality Assurance Manual (GGNS-TOP-1A), Revision 9a) l W.'M. Garner M f/Xf 4 / #'
=- f
- IO NRC Document Preparer 'Date. /' Reg'%sible Section Date MMger/Superintenden t
~~^
Commitment Concurrence Responsible
. Organization Locations Commitment Primary / Secondary Due Date NONE 1
i l
i l
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i 1
l I
n
-A9009211/SN ICFLR - 1 W
1 1 d
SECTf0N=III Concurrence
- Review Required. Comments' I 'd
-( ) (/)
VP, Engineering /Date-()() ( -) Co - _ P/24~/fY VP, Operations GGNS/DaWe- '
( )- (X)-
Director, Nuclear Plant:
Engineering /Date
(-) (
GG General Manager /Date __
/
(b
() (/ * -
- 9fES To .
Dit'ct6r, Nuclear ~
i ensing/Date
() (X) '
't Director, Quality Program -
(- ) (r)
- Manager, Nuclear. Safety Oversight w
M l l f
A9009211/SNLICFLR - 2