ML050330329

Quality Assurance Program (QAP) Topical Report - Millstone Power Station Revision 26, Change 3 (Document No. MP-02-OST-BAP01)

ML050330329
Person / Time
Site:	Millstone
Issue date:	12/30/2004
From:	Bruce D Dominion
To:	Document Control Desk, NRC/FSME
References
000068564, NO-04-0020 MP-02-OST-BAP01, Rev 26
Download: ML050330329 (8)

Text

PASSPORT DOCUMENT T6  : DOCUMENT CONTROL DESK Facility  : MP Department : 806 TRANSMITTAL Address  : NUC REGULATORY COMMISSION (0140)

DOCUMENT CONTROL DESK WASHINGTON, DC 20555 Page: 1 From  : NDS CONT DOCUMENTS Date/Time  : 12/29/04 13:03 Trans No.  : 000068564 Tr ansmittal Group Id: 04363JEP-1 Total Items: 00001 Item Facility Type Sub Document Number / Title Sheet Revision Doc Date Copy # Media Copies

• 0001 MP PROC OST MP-02-OST-BAP01 026 03 P 01 QUALITY ASSURANCE PROGRAM TOPICAL REPORT (NO IMAGE - TOO COMPLEX TO F.)

Please check the appropriate response and return form to NDS Bldg 475/3 Millstone Power Station or Fax to 860-440-2057.

All documents received.

Documents noted above not received (identify those not received).

I no longer require distribution of these documents.

Date: Signature:

I

>  ; Dominion-Memorandum NO-04-0020 December 30, 2004 TO: Quality Assurance Program Topical Report - Controlled Copy Owners FROM: Dorothy BoLce, Millstone QAP Coordinator Nuclear Oversight, Ext. 3185

SUBJECT:

Quality Assurance Program (QAP) Topical Report - Millstone Power Station Revision 26, Change 3 (Document No. MP-02-OST-BAP01)

Enclosed please find Quality Assurance Program (QAP) Topical Report - Millstone Power Station, Revision 26, Change 3. The change is to modify QAP Appendix E, to add an exception for the Quality Assurance audit schedule to allow a 25% extension to the frequency of most QA audits (excluding those mandated by the Code of Federal Regulations). The change adds y> exception number 21 to Appendix E. In addition, this change supersedes QAP Appendix E exception number 16, which will be deleted as noted in QAP Appendix E. The change modifies QAP Appendix E to reflect these changes.

Please note that the effective date of Revision 26, Change 3, is December 30, 2004. Please replace the current section of the Quality Assurance Program with the enclosed section (QAP 1.0 and Appendix E).

If you have any questions, please contact D. Bruce at X3 185.

Attachments: Summary of Changes for Revision 26, Change 3

Enclosure:

Quality Assurance Program Topical Report - Millstone Power Station, Revision 26, Change 3 DSB/dsb

APPENDIX E QUALITY ASSURANCE PROGRAM (QAP)

TOPICAL REPORT - MILLSTONE POWER STATION PROGRAM EXCEPTIONS

1. ANSI N45.2.9, states in part, "structure, doors, frames, and hardware should be Class A fire-related with a recommended four-hour minimum rating." The three record storage vaults onsite have a two-hour rating.

The licensee's vaults are used for storage of documentation that is unsuitable for filming or awaiting filming.

A records organization exists along with written procedures addressing the control of quality assurance records.

2. Deleted

3. ANSI N45.2.9-1974, paragraph 1.4, definition of "Quality Assurance Records" states in part: "For the purposes of this standard, a document is considered a quality assurance record when the document has been completed."

The licensee has developed the following alternative definition to provide guidance during the interim period from the time a document is completed until it is transmitted to the licensee records retention facilities:

"A record is considered a working document until it is transmitted to the licensee records retention facilities at which time it is designated as a Quality Assurance Record. The following maximum time limits are established for the transmittal of working documents to the licensee records retention facilities:

Operations Documents - Documentation generated during plant operations may be maintained, as needed, by operating plant departments, for up to one year.

New Construction or Betterment Documents - Documents which evolve during new construction or betterment projects shall be transmitted to licensee records retention facilities within 90 days of completion of a new construction project or turnover of a betterment project or plant operations.

Procurement Documents - Inspection/Surveillance/Audit Reports generated during vendor oversight activities which are used to maintain vendor status for current and future procurements may be maintained, as needed, by Document Administration for up to three years.

All Other Working Documents - All other working documents shall be transmitted to licensee records retention facilities within 6 months of their receipt or completion."

QAP - Appendix E Rev. 26, chg. 3 Date: 12/30/04 Page 1 of 6

The requirements of ANSI N45.2.9-1974 do not apply to these "working documents" based on paragraph 1.1 of the ANSI standard which states:

"It (ANSI N45.2.9) is not intended to cover the preparation of the records nor to include working documents not yet designated as Quality Assurance Records."

4. Regulatory Guide 1.64 - 6/76, the Regulatory position states, in part, "It should not be construed that such verification constitutes the required independent design verification."

The licensee has developed the following alternative to allow for adequate independent design verification:

This review may be performed by the originator's Supervisor, only if the Supervisor:

Did not specify a singular design approach; Did not establish the design inputs or did not rule out certain Design considerations; Is the only individual in the organization competent to perform the review.

Where the Supervisor performs the design review, the next level of management shall fulfill the Supervisor's responsibilities.

5. ANSI N45.2.13 - 1976, paragraph 10.3.4, states in part: "Post-Installation Test requirements and acceptance documentation (should) shall be mutually established by the purchaser and supplier." Involvement by the supplier in establishing Post-installation Test requirements and acceptance documentation is requested only when it is deemed necessary and proper by the responsible engineering organization.

The licensee no longer has any nuclear plants under construction. As a result, most procurements are made for spare parts from suppliers who are not the original equipment manufacturer. In these cases, the supplier may have little or no understanding or knowledge of either the operation of the system the component is to be installed in, or applicable Post-Installation Test requirements and acceptance documentation. As such, the licensee assumes responsibility for establishing Post Installation Test requirements and acceptance documentation.

6. ANSI N45.2.2 - 1972, paragraph 1.2, states in part that, "The requirements of this standard apply to the work of any individual or organization that participates in the packaging, shipping, receiving, storage, and handling of items to be incorporated into nuclear power plants."

Since a portion of the licensee procurement activities involve commercial suppliers which do not fully comply with the requirements of ANSI N45.2.2, the licensee's Supply Chain Management organization verifies through source inspections, receipt inspection, and/or survey activities that the quality of the materials, items, components or equipment is preserved by those suppliers to the extent that packaging, shipping, storage and handling methods are employed which are commensurate with the nature of the product.

QAP - Appendix E Rev.26, chg.3 Date: 12/30/04 Page 2 of 6

7. ANSI N18.1-1971, paragraph 4.2.2, states in part "The Operations Manager shall hold a Senior Reactor Operator's license". The licensee has developed an alternative to this requirement which has been accepted by the NRC via amendment 132 for the Millstone Power Station Unit No. 3 license which allows that:

If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No. 3, then the Operations Manager shall have held a Senior Reactor Operator license at a pressurized water reactor, and the Assistant Operations Manager (Supervisor

- Nuclear Shift Operations) shall hold a Senior Reactor Operator license for Millstone Unit No. 3 and meet the qualification requirements of Section 4.3.8, "Operations" of ANSI/ANS 3.1-1987, 'American National Standard for Selection, Qualification and Testing of Personnel for Nuclear Power Plants .(in accordance with Section 4.2.2 reference to the Operations Middle Manager).

8. ANSI N18.1-1971, paragraph 4.2.2, states in part "The Operations Manager shall hold a Senior Reactor Operator's license". The licensee has developed an alternative to this requirement which has been accepted by the NRC via amendments 178 and 190 for the Millstone Power Station Unit No. 2 license which allows that:

If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No. 2, then the Operations Manager shall have held a Senior Reactor Operator license at a pressurized water reactor, and an individual serving in the capacity of the Assistant Operations Manager (Supervisor - Nuclear Shift Operations) shall hold a Senior Reactor Operator license for Millstone Unit No. 2 and meet the qualification requirements of Section 4.3.8, 'Operations" of ANSI/ANS 3.1-1987, "American National Standard for Selection, Qualification and Testing of Personnel for Nuclear Power Plants" (in accordance with Section 4.2.2 reference to the Operations Middle Manager).

9. Renulatorv Guide 1.33 - 2/78, regarding audits, states in part:

(a) "The results of actions taken to correct deficiencies...at least once per 6 months."

(b) "...technical specifications and applicable license conditions - at least once per 12 months."

(c) "The performance, training, and qualifications of the facility staff - at least once per 12 months."

The licensee has developed an alternative which modifies these Audit frequencies to at least once per 24 months. This alternative has previously been accepted by the NRC via license amendments 79, 184, and 104 for MPI, MP2, and MP3, respectively.

10. Deleted.

11. ANSI N45.2.13-1976, paragraph 10.3.5., states in part, "in certain cases involving procurement of services only, such as third party inspection; engineering and consulting services, and installation, repair, overhaul or maintenance work; the Purchaser may accept the service by any or all of the following methods:

QAP - Appendix E Rev.26, chg.3 Date: 12/30/04 Page 3 of 6

(a) Technical verification of the data produced (b) Surveillance and/or audit of the activity (c) Review of the objective evidence for conformance to the procurement document requirements such as certifications, stress reports, etc."

In order to maintain the independence requirement of the NRC's August 14, 1996 Order, the licensee will not perform an acceptance review of the work produced by the vendors contracted to conduct the Independent Corrective Action Verification Program. This work will be performed in accordance with the vendor's own approved, 10 CFR 50 Appendix B Quality Assurance Program. Not applicable to Unit 1.

12. Deleted.

13. Regulatory Guide 1.70 Revision 3, November 1978 Section 17.1.2.4 states in part: 'The PSAR should include a listing of QA program procedures or instructions that will be used to implement the QA program for each major activity such as design, procurement, construction, etc. The procedure list should identify which criteria of Appendix B to 10 CFR 50 are implemented by each procedure". Not applicable to Unit 1.

The licensee has developed an alternative to this requirement where procedure indices are maintained which identify the procedures that implement the Quality Assurance Program for Millstone Power Station and which, by title and originating organization, indicate the Appendix B to 10 CFR 50 criterion being implemented.

14. ANSI N18.7-1976, Paragraph 5.2.15, "Review, Approval, and Control of Procedures,"

states in part: "Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable."

The licensee implements administrative and programmatic controls that ensure procedures are maintained current in accordance with 10CFR50, Appendix B, thus meeting the intent of the biennial review.

The licensee implements administrative controls to perform biennial reviews of non-routine procedures such as Emergency Operating Procedures (EOP's), Abnormal Operating Procedures (AOP's), Off Normal Procedures (ONP's), Emergency Plan, Security and other procedures that may be dictated by an event.

Programmatic controls specify conditions when the mandatory review of plant procedures apply, and include a requirement to review applicable procedures following an accident or transient and following any modification to a system.

The licensee utilizes a pre-job briefing practice to ensure that personnel are aware of what is to be accomplished and what procedures will be used prior to beginning a job. In addition, the Procedure Compliance Policy requires that the job be stopped and the procedure be revised or the situation resolved prior to work continuing if procedures cannot be implemented as written.

QAP - Appendix E Rev. 26, chg. 3 Date: 12/30/04 Page 4 of 6

4 Additionally, the licensee's Quality Assurance Program requires the review of a representative sample of plant procedures as part of routine audits and surveillances to ensure that existing administrative controls for procedure verification, review and revision are effective in maintaining the quality of plant procedures. Significant procedural deficiencies are identified and corrected through the Station Corrective Action Program.

The Station Self-Assessment Program also periodically reviews selected procedures and identifies deficiencies and improvements through the Corrective Action Program.

15. Denied NRC approval. Number not reused.

16. Deleted. (Superceded by Exception # 21.)

17. ANSI N18.1-1971, paragraph 4.3.1, states in part, 'A Supervisor (requiring an AEC license) shall have a minimum of a high school diploma or equivalent, and four years of responsible power plant experience, of which a minimum of one year shall be nuclear power plant experience. A maximum of two years of the remaining three years of power plant experience may be fulfilled by academic or related technical training on a one-for-one basis." The licensee has developed an alternative to this requirement which has been accepted by the NRC via amendment 258 for the Millstone Power Station No. 2 which allows that:

Beginning November 1, 2001, applicants for senior reactor qualification shall meet or exceed the education and experience guidelines given in Revision 3 to Regulatory Guide 1.8 (May 2000).

18. ANSI N18.1-1971, paragraph 4.3.1, states in part, "A Supervisor (requiring an AEC license) shall have a minimum of a high school diploma or equivalent, and four years of responsible power plant experience, of which a minimum of one year shall be nuclear power plant experience. A maximum of two years of the remaining three years of power plant experience may be fulfilled by academic or related technical training on a one-for-one basis." The licensee has developed an alternative to this requirement which has been accepted by the NRC via amendment 199 for the Millstone Power Station No. 3 which allows that:

Beginning November 1, 2001, applicants for senior reactor qualification shall meet or exceed the education and experience guidelines given in Revision 3 to Regulatory Guide 1.8 (May 2000).

19. ANSI N18.1-1971, paragraph 4.5.1, states in part, "An operator (to be licensed by the AEC) shall have a minimum of a high school diploma or equivalent, and two years of power plant experience, of which a minimum of one year shall be nuclear power plant experience." The licensee has developed an alternative to this requirement which has been accepted by the NRC via amendment 258 for the Millstone Power Station No. 2 which allows that:

Beginning November 1, 2001, applicants for reactor qualification shall meet or exceed the education and experience guidelines given in Revision 3 to Regulatory Guide 1.8 (May 2000).

QAP - Appendix E Rev. 26, chg. 3 Date: 12/30/04 Page 5 of 6

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20. ANSI N18.1-1971, paragraph 4.5.1, states in part, "An operator (to be licensed by the AEC) shall have a minimum of a high school diploma or equivalent, and two years of power plant experience, of which a minimum of one year shall be nuclear power plant experience." The licensee has developed an alternative to this requirement which has been accepted by the NRC via amendment 199 for the Millstone Power Station No. 3 which allows that:

Beginning November 1, 2001, applicants for reactor qualification shall meet or exceed the education and experience guidelines given in Revision 3 to Regulatory Guide 1.8 (May 2000).

21. ANSI N18.7-1976, paragraph 4.5, states in part, "Audits of selected aspects of operational phase activities shall be performed with a frequency commensurate with their safety significance and in such a manner as to assure that an audit of all safety-related functions is completed within a period of two years."

The licensee has established a 25% extension to the 24-month frequency for most internal audits. This 25% extension will not be applied to those audits which have frequencies specifically delineated by the Code of Federal regulations (i.e. Emergency Preparedness Program which satisfies the requirements of 10CFR50.54(t), or Physical Security Plan which satisfy the requirements of 10CFR50.54(p)(3); 73.56(g)(1) and (g)(2); and 73.55(g)(4), and the Fitness for Duty Program which satisfies 10CFR26.80.

The frequencies of these audits are described in their respective plans and/or programs.

QAP - Appendix E Rev.26, chg.3 Date: 12/30/04 Page 6 of 6