ML17054B827

Rev 0 to Niagara Mohawk Power Corp QA Program Topical Rept, Nine Mile Point Nuclear Station Units 1 & 2,Operations Phase.

ML17054B827
Person / Time
Site:	Nine Mile Point
Issue date:	08/16/1985
From:	Haynes J, John Miller, Jamila Perry NIAGARA MOHAWK POWER CORP.
To:
Shared Package
ML17054B828	List: ML17054B827 ML18038A044
References
NMPC-QATR-1, NMPC-QATR-1-R, NMPC-QATR-1-R00, NUDOCS 8508210066
Download: ML17054B827 (110)

Text

NMPC-QATR-1 l Revision 0 0 August 1985 NIAGARA MOHAWK POWER CORPORATION QUALITY ASSURANCE PROGRAM TOPICAL REPORT NINE MILE POINT NUCLEAR STATION UNITS 1 AND 2

. ~ OPERATIONS PHASE'pproved:

rector Qualit Assur nce Concurrence:

/'enior Vice esident Senior Vice resident F'DR 85082i0066 8500m16220 PDR ADOCK 05

NMPC-QATR-1 Page i Rev. 0 TABLE OF CONTENTS SECTION PAGES INTRODUCTION QUALITY ASSURANCE POLICY 1.0 Organization l-l to 1-10 2.0 Quality Assurance Program 2-1 to 2-6 3.0 Design Control 3-1 to 3-3 4.0 Procurement Document Control 4-1 to 4-2 5.0 Instructions, Procedures, and Drawings 6.0 Document Control 6-1 to 6-2 7.0 Control of Purchased Material, Equipment and Services 7-1 to 7-2 8.0 Identification and Control of Materials, Parts and Components 9.0 Control of Special Processes 9-1 to 9-2 10.0 Inspection 10-1 to 10-3 11.0 Test Control 11-1 to 11-2 12.0 Control of Measuring and Test Equipment 12-1 to 12-2 13.0 Handling, Storage and Shipping 13-1 14.0 Inspection, Test and Operating Status 14-1 15.0 Nonconforming Materials, Parts, or Components 15-1 to 15-2 16.0 Corrective Action 16-1 17.0 Quality Assurance Records 17-1 to 17-2 18.0 Audits 18-1 to 18-2 Appendix A Regulatory Commitments A-1 Appendix 8 Interpretations and Exceptions of 8-1 to 8-5 Appendix A Documents

I NMPC-QATR-1 Page ii Rev. 0 QUALITY ASSURANCE PROGRAM TOPICAL REPORT NINE HILE POINT NUCLEAR STATION UNITS 1 AND 2 OPERATIONS PHASE INTRODUCTION I

I This Quality Assurance Program Topical Report fulfills the requirement for a description of the quality assurance program for the operations phase of the Nine Mile Point Nuclear Station Units 1 and 2. This Topical Report supersedes the previous Quality Assurance Program for Nine Mile Point Unit 1 and Chapter 17 of the Nine Mile Point Unit 2 FSAR relating to the operating phase.

The Quality Assurance Program Topical Report applies to organizations performing work that affects the operation, maintenance or modification of safety-related structures, systems or components. As stated in Niagara Hohawk Power Corporation s Quality Assurance Policy, accountability for the quality of safety-related work rests with the performer whereas accountability for verifying the quality of that work rests with the verifying organizations.

This Topical Report provides for performing operation, maintenance and modifications of both Units 1 and 2 consistent with ANSI/ASME NQA-1 and ANSI/ANS-3.2. This provision permits the preparation and use of a single set of procedures that apply to quality assurance functions at and on behalf of both units.

Questions with respect to the content or applicability of the Quality Assurance Program Topical Report should be referred to the Director Quality Assurance.

0 NHPC-QATR-1 Page iii Rev. 0 QUALITY ASSURANCE POLICY Quality Assurance POZZm 7.1.11 Page 1 of 1 PURPOSELY The purpose of this policy is to summarixe the Company's position governing Quality Assuxance responsibilities and accountabilities.

The Company policy regarding Quality Assurance matters is thats Z. Organixations with quality-affecting responsibilities shall be structured, managed, and operated in compliance with approved Quality Assurance Programs, procedures, and instructions in direct support of power plant pro)ects and operations to achieve the following objectives:

o To strive to perform assigned wox'k correctly the first time.

o To provide power plants, which axe designed, constructed, tested and operated to high standards of excellence, with high assurance against failure or malfunctions and without, undue risks to the health and safety of the public.

o To ensure early and timely identification and resolution of actual and potential problem areas in design, procurement, construction, testing, operation, main-tenance, and modification of power plants.

o To comply effectively with government regulations and established NNPC policies and procedures, applying a systematic, disciplined and uniform approach to Quality Assurance.

ZZ. Accountability for the quality of powe plant structures, systems, components and services xests with the organixations and persons performing the quality attaining functions of design, construction and operation.

ZZZ. Accountability for determining that the power plant structures, systems, components and services do, in fact. meet the stated requirements rests with the organixations and persons performing quality vex'ification functions, such as design review, document review, inspection, surv llance, and audits.

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NMPC-QATR-1 Page 1-1 Rev. 0 ORGANIZATION POLICY Niagara Mohawk Power Corporation (NMPC) is responsible for establishing and implementing the quality assurance program for the operations phase of the Nine Mile Point Nuclear Station. Although authority for development and execution of specified parts of the program may be delegated to others, such as contractors and consultants, NHPC retains overall responsibility.

This section of the Quality Assurance Program Topical Report identifies the NHPC organizations responsible for activities affecting the operation, maintenance or modification of safety-related structures, systems, or components, and describes the assigned authorities and duties for quality-attaining functions and for quality verification functions. Each organizational unit, including Nuclear Operations, Purchasing, Materials Management, Meter and Test, Meter and Laboratory Services, and the Quality Assurance Department, is responsible For the quality of its own work.

Quality assuring functions include establishing the quality assurance program and verifying that activities affecting the quality of safety-related structures, systems, components, and services are performed in accordance with quality assurance program requirements.

Quality assuring functions are performed by personnel within the Quality Assurance Department and other organizational units. The Quality Assurance Department, independent from impacts of cost and schedule, has direct access to management levels to assure the ability to identify quality problems; initiate, recommend or provide solutions; and verify implementation of solutions.

1.2 IMPLEMENTATION 1.2.1 Res onsibilit and Authorit The President of Nia ara Hohawk Power Cor oration has ultimate responsibility for safe operation of the Nine Mile Point Nuclear Station. Authority and responsibility for establishing and implementing the quality assurance program for station operations, maintenance, and modifications is delegated by the President to the Senior Vice President responsible for Nuclear Operations, the Director Quality Assurance, the Senior Vice President responsible for Purchasing and Materials Management and heads of other participating departments.

The NHPC organization is shown in Figure l-l. Departmental responsibilities are suomarized in the Responsibility Matrix, Figure 1-2.

1.2.2 Nuclear Division Res onsibi lities A. The Senior Vice President res onsible for Nuclear 0 erations reports to the President and is responsible for the overall management of operation, maintenance and modification of the Nine Hile Point Nuclear Station.

NHPC-gATR-1 Page 1-2 Rev. 0 B. The Vice President Nuclear Generation reports to the Senior Vice -.

President responsible for Nuclear Operations and is responsible for safe and efficient operation, maintenance and modification of the Nine Hile Point Nuclear Station. See figure 1-2 for primary and supporting quality assurance program element respons'ibilities.

1. The General Su erintendent-Nuclear Generation reports to the Vice President Nuclear Generation and is responsible for safe and efficient operation, maintenance and modification of the nuclear power station in compliance with station licenses, applicable regulations, and the quality assurance program.

The General Superintendent delegates to the Station Superintendents and other appropriate personnel authority for performance in accordance with the quality assurance program.

Activities performed under the responsibility of the General Superintendent-Nuclear Generation include:

a. Controlling the preparation, review and approval of procedures and instructions;

b. Ensuring that technical, operations and maintenance personnel are appropriately qualified for their duties;

c. Providing the necessary corrective action, evaluation, processing and reporting of nonconforming conditions; and

d. Providing for timely identification and corrective action of conditions adverse to quality.

2. The Station Su erintendents Units 1 and 2 report to the General Superintendent Nuclear Generation. They are responsible for:

a. Safe and efficient station operation;

b. Coordinating station maintenance and modifications;

c. Establishing and enforcing compliance with'perating procedures;

d. Haintaining equipment status control;

e. Performing startup and operational testing; and

f. Processing, packaging and disposal of radioactive waste.

3. The Site Su erintendent Haintenance Nuclear reports to the General Superintendent Nuclear Generation and is responsible for:

a. Originating requests for procurement of maintenance and repair materials and equipment.

NMPC-QATR-1 Page 1-3 Rev. 0

b. Supervising the welding program in accordance with Administrative Procedures.

c. Equipment testing for maintenance (electrical, structural, mechanical), repair, and modification; .

d. Supervision of maintenance, repair, and assigned modifications;

e. Control of Maintenance Department measuring and test equipment; Receipt inspection of nuclear fuel; and

g. Providing for intermediate storage and protection of safety-related equipment awaiting disposition after removal from service, assuring preservation of identification until final disposition.

4. The Technical Su erintendent Nuclear Generation reports to the General Superintendent Nuclear Generation and is responsible for:

a. Reactor engineering, reactor core management, and nuclear fuel accountability, storage, utilization, and disposition;

b. Instrument and control function calibration and maintenance;

c. Operation and maintenance of computer-related services;

d. Technical support services;

e. Coordination of inservice inspection and testing program  ;

f. Fire protection;

g. Administrative services and records management; and

h. Planning and surveillance scheduling.

5. The Su erintendent Chemistr and Radiation Mana ement reports to the General Superintendent Nuclear Generation and is responsible for chemistry, radiochemistry, radiation protection, environmental protection, ALARA program and emergency planning including control of measuring and test equipment for these activities.

6. The Su erintendent Trainin reports to the General Superintendent Nuclear Generation and is responsible for conducting training and maintaining records thereof.

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NHPC-QATR-1 Page 1-4 Rev. 0 C. The Vice President-Nuclear En ineerin and Licensin reports to the ~

Senior Vice President responsible for Nuclear Operations and has overall responsibility for nuclear engineering support and licensing services including 10CFR Part 21 final reportability determinations. See figure 1-2 for primary and supporting quality assurance program element responsibilities.

1. The Hang er Nuclear En ineerin reports to the Vice President-Nuclear Engineering and Licensing and is responsible for providing engineering services for, the safe, reliable ,.and economic operation of the Nine Mile Point Nuclear Station Units 1 5 2, including adherence to applicable regulatory requirements. Responsibilities include:

a. Engineering services;

b. Fuel management;

c. Licensing services in support of operations, safety evaluations and technical specification changes;

d. Modification design and management;

e. Preparing purchase requisitions; Dispositioning nonconformances; and

g. Providing for timely identification and corrective action of conditions adverse to quality.

2. The Mana er Nuclear Com liance and Verification reports to the Vice President-Nuclear Engineering and Licensing and is responsible for verifying that Nuclear Operations Division commitments are accurately stated and accomplished within the committed time period.

3. The Mana er Nuclear Staff Services reports to the Vice.-President Nuclear Engineering and Licensing and is responsible for providing support services to the Nuclear Engineering and Licensing Department including:

a. Records Management;

b. Training; and

c. Procedure development.

NHPC-QATR-1 Page 1-5 Rev. 0 1.2.3

~ ~ Su ort Oe artment Res onsibilities A. The Vice President Purchasin and Materials Mana ement reports to a Senior Vice President and is responsible for formulating, establishing, and enforcing compliance with procurement requirements. See figure 1-2 for primary and supporting quality assurance program element responsibilities.

1. The Mana er-S stem Purchasin reports to the Vice President, Purchasing and Materials Management. The staff includes the Assistant Manager Nuclear Purchasing, Supervisory Buyer and Senior Contract Administrator. This organization is responsible for preparing, issuing and administering purchase orders after verifying that safety-related purchase requisitions are signed by the requester and a Quality Assurance Oepartment representative.

2. The Mana er - S stem Materials Mana ement reports to the Vice President Purchasing and Haterials Management. Included on the staff and reporting to the Manager System Materials Management through the Assistant Manager Nuclear Materials Management is the Supervisor Nuclear Generation Storeroom.

The Supervisor-Nuclear Generation Storeroom is responsible for reviewing site-generated requests for materials and equipment, preparing purchase requisitions, and for receipt and storage of materials and equipment in accordance with Nine Mile Point Nuclear Station Administrative Procedures and Materials Management Procedures.

B. The Vice President Re ional 0 erations reports to a Senior Vice President and is responsible for formulating, establishing.and enforcing Meter and Test activities. See figure 1-2 for primary and supporting quality assurance program element responsibilities.

1. The General Mana er Central Re ion reports to the Vice President Regional Operations. The staff includes the Superintendent Meter and Test who is responsible for the following safety-related functions.

a. Testing and maintaining power systems protective devices and metering equipment;

b. Reviewing and advising on changes to electrical protective logic, metering and associated equipment; and

c. Performing verification testing associated with the above equipment and circuits.

C. The Vice President S stem Electric 0 erations reports to a Senior Vice President and is responsible for formulating, establishing and enforcing Meter and Laboratory Services activities. See Figure 1-2 for primary and supporting quality assurance program element responsibilities.

NMPC-gATR-1 Page 1-6 Rev. 0

1. The Mana er Meter and Lab Services reports to the Vice President System Electric Operations. The staff includes the Supervisor System Standards Lab who is responsible for maintaining the facility for calibrating reference and secondary standards and general usage portable and laboratory measuring and test equipment.

1.2.4 ualit Assurance De artment Res onsibilities A. The Director ualit Assurance reports to the President and is responsible for formulating, directing, implementing and controlling policies and procedures related to verifying the overall quality of station design, construction, operation, maintenance and modification activities. The Director's position may delegate to personnel under its jurisdiction appropriate portions of responsibilities, together with proportionate authority for fulfillment. See figure 1-2 for primary and supporting quality assurance program element responsibilities. Responsibilities include:

1. Reviewing documents and directing the management of investigations, surveys, audits and reports concerning activities related to the quality of design, procurement, fabrication, materials management, installation, inspection, test, operation, modification, repair and maintenance of safety-related systems, structures, components and services;

2. Recommending to appropriate management courses of corrective action, when required, including initiation of stop work orders;

3. Verifying the operations of suppliers, contractors and corporate departments performing safety-related work to ensure compliance with applicable regulations, procedures, specifications, codes or other standards;

4. Directing the supervision of administrative functions within the department, including training, document control and procedures manual development; and

5. Preparing periodic and special reports to keep management informed of the quality assurance program status.

6. Providing for timely identification and corrective action of conditions adverse to quality.

B. The Mana er Nuclear ualit Assurance 0 erations reports to the Director guality Assurance and exercises control and direction of the nuclear quality assurance program. Responsibilities include:

l. Interpretation and implementation of the nuclear quality assurance policy and procedures;

NHPC-QATR-1 Page 1-7 Rev. 0

2. Advising the Director Quality Assurance of nuclear quality activities;

3. Reviewing Quality Assurance Department procedures;

4. Reviewing and concurring with various documents and other department procedures, where applicable, which implement this Quality Assurance Program Topical Report; and

5. Recommending to appropriate management courses of corrective action, when required, including initiation of stop work orders.

C. The Mana er Cor orate ualit Assurance reports to the Director Quality Assurance and provides a support function for the Quality Assurance Department. Responsibilities include:

Preparing, controlling and implementing Quality Assurance Department documents including the Quality Assurance Topical Report and Quality Assurance Department policies and procedures;

2. Advising the Director Quality Assurance and the Manager Nuclear Quality Assurance Operations of nuclear quality activities;

3. Initiating or delegating action in assigned areas oF responsibility including training, supplier evaluation, audit, and trend analysis; and

4. Recommending to appropriate management courses of corrective action, when required, including initiation of stop work orders.

D. The Manager Quality 5 Reliability Engineering reports to the Director Quality Assurance and provides technical support to the Nuclear QA Operations Section. Responsibilities include:

Reviewing plant modification design documents for inspectability; developing quality planning to support installation of plant changes and coordinating the technical aspects of QA Modification package implementation during plant shutdowns.

2. Providing for control of purchased equipment throught the contractor qualification program, source surveillance and the preparation of receiving inspection planning (for implementation by Nuclear QA Operations personnel).

3. Providing materials engineering support in the areas of material selection, welding, corrosion prevention, non-destructive examination, and fuels quality assurance.

Advising the Director Quality Assurance and the Manager, Nuclear QA Operations of nuclear quality activities.

NMPC-QATR-1 Page 1-8 Rev. 0

5. Providing reliability engineering support for the equipment qualification program; establishment of system and equipment availability goals; follow-up with suppliers on achievements of euipment reliability requirements; and performance of studies on extending equipment life.

6. Reviewing and concurring with various documents and other department procedures, where applicable, which implement this Quality Assurance Program Topical Report, and

7. Recommending to appropriate management courses of corrective action, when required, including initiation of stop work orders.

E. ualit Assurance Su ervisors supervise the Quality Assurance Department staff. Supervisory and staff responsibilities include:

1. Supervising, directing, and coordinating the Quality Assurance Department staff within the framework of established policies and Quality Assurance Department procedures;

2. Reporting status of quality activities to the responsible manager;

3. Conducting inspections, audits and survei llances to verify quality assurance program implementation within NMPC and outside suppliers and contractors;

4. Preparing and implementing Quality Assurance Department procedures and instructions;

5. Recommending "stop work" action when appropriate;

6. Reviewing quality-related documents including procedures, purchase requisitions and suppliers'uality assurance programs;

7. Documenting and verifying correction of conditions adverse to quality;

8. Reviewing, preparing and filing quality assurance department records;

9. Conducting training programs; and

10. Maintaining the Nondestructive Examination Procedures Manual.

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NMPC-QATR-1 Page 1-10 Rev. 0 QUALITY ASSURANCE PROGRAM RESPONSIBILITY MATRIX REGULATORY REQUIREMENTS NMPC DEPARTMENTS I. Organi zati on 1,1-Sl 1 P P P P P P P 3.1 3.3 3.4.2 I I. QA Program 2, 2S-1 3.1 S S S S S S P,R 2S-2 3.3 2S-3 5.1 5.3 3.4.2 3.5 III. Design 3, 3S-1 5.2.7.2 S P S IV. Procurement 4,4S-l 5.2.13.1 P P S P V. Procedures 5.2.7 P P P P P P P,R 5.3 VI. Ooc. Control 6, 6S-1 5. 2.15 P, P P P P P P,R VII. Purch. Items 7, 7S-1 5.2.13.2 P P S P VIII. Item Control 8, BS-1 5.2.13.3 P S IX. Special Proc. 9, 9S-1 5. 2.18 P P 5.2.12 X. Inspection 10, 105-1 5.2.17 P S P,R XI. Testing 11, 1 ls-l 5.2.19 P P XI I. M&TE 12) 125-1 5.2.16 P R XIII. Hand. & Stg. 13, 13S-1 5.2.13. 4 P S XIV. Operating 14 5.2.6 Status 5.2.14 XV. Nonconf own. 15, 15S-1 5.2.14 P P S S XVI. Corr. Action 16 5.2.11 P P S S S S P,R XVII. Records 17, 17S-1 5.2.12 P P S S S S S,R XVIII. Audit 18, 185-1 4.5 NMPC DEPARTMENT PROCEDURAL COVERAGE REQUIRED NG - Nuclear Generation P - Primary Responsibility NE - Nuclear Engineering S - Support Responsibility PUR - Purchasing R - Review, Audit or Survelliance MM - Materials Management Responsibility MT - Meter and Test ML - Meter and Laboratory Services QA - Quality Assurance Figure 1-2

NMPC-QATR-1 Page 2-1 Rev. 0 2.0 UALITY ASSURANCE PROGRAM 2.1 POLICY The Niagara Mohawk Power Corporation (NMPC) quality assurance program for the Nine Mile Point Nuclear Station operations phase is established by this Quality Assurance Program Topical Report and applies to safety-related activities, i.e. activities that affect the operation, maintenance or modification of safety-related systems, structures or components. The quality assurance program includes policies, procedures, instructions and other documents that implement the provisions of this Topical Report. The quality assurance program fulfills the requirements of the regulatory documents to which NMPC has committed.

The quality assurance program provides for safety-related activities to be performed under suitably controlled conditions, including the use of appropriate equipment, maintenance of proper environmental conditions, assignment of qualified personnel and assurance that applicable prerequisites have been met.

Quality assurance program status, scope, adequacy and compliance with 10CFR50 Appendix 8 are regularly reviewed by NMPC management through reports, meetings, review of audit results, and documented assessments

,performed by management teams.

2.2.1 General organizational. responsibilities are outlined in Section 1.0, ORGANIZATION.

2.2.2 This Quality Assurance Program Topical Report, organized to present the NMPC quality assurance program in the order of the 18 criteria of 10CFR50 Appendix 8, states NMPC policy for each of the criteria and describes how the controls pertinent to each are carried out. Any changes made to this Topical Report that do not reduce the commitments previously accepted by the Nuclear Regulatory Commission (NRC) shall be submitted to the NRC at least annually. Any changes made to this Topical Report that do reduce the comnitments previously accepted by the NRC will be submitted to the NRC and shall receive NRC approval prior to implementation. The submittal of the changes described above will be made in accordance with the requirements of 10CFR50.54.

2.2.3 The Corporate Quality Assurance Policy authorized by the Director Quality Assurance and approved by the President states, "Organizations with quality-afFecting responsibilities shall be structured, managed, and operated in compliance with approved quality assurance programs, procedures and instructions...". That statement makes the quality assurance program described herein and in the implementing procedures mandatory and requires compliance by participating organizations and individuals.

0

I NNPC-QATR-1 Page 2-2 Rev. 0 2.2e4

~ ~ The quality assurance program is implemented by organizations responsible for attaining quality and by organizations responsible for verifying quality (see Section 1.0, ORGANIZATION).

2.2.5 The qualification requirements for the Director Quality Assurance are as follows:

Edocation Bachelor's degree in engineering or physical science from an accredited institution.

~Ex em)ence

a. Fi fteen (15) years of experi ence in tee hni ca 1 f i el ds such as quality control/assurance, engineering, manufacturing, operations, or construction; and

b. Five (5) years of experience in nuclear quality control/assurance; and

c. Five (5) years of experience in responsible managerial positions.

NOTE: The experience requirements may be met on a concurrent basis.

Quality Assurance Department Managers and Supervisors are required to have demonstrated their management competence through prior assignments.

of increasing responsibility in addition to the following qualifications:

Education Bachelor's degree or equivalent in engineering or physical science.

~Ex eri ence

a. Seven (7) years in quality assurance, design, manufacturing, construction, plant operations, or equivalent activities; and

b. Three (3) years in nuclear quality assurance.

Note: Experience requirements may be met on a concurrent basis.

2.2.7 The operations phase quality assurance program applies to activities affecting the operation and the quality of structures, systems, components, and services during plant operation, maintenance, testing and modifications. Safety-related structures, systems, and components are identified in Q-Lists, which are developed and maintained for each unit.

0

NMPC-QATR-1 Page 2-3 Rev. 0 Appropriate elements of the Quality Assurance Program Topical Report are applied to emergency plans, radiation protection procedures and radioactive waste shipment programs for the nuclear station.

2.2.8 Those elements of the Quality Assurance Program Topical Report which apply to radioactive waste handling activities include:

a. Audits or surveillances on approximately 10$ of radioactive waste shipments.

b. Annual audits of the radioactive waste handling program.

c. Audits identified in a. and b. are performed by Quality As'surance Department personnel who are trained in Department of Transportation (DOT) and Nuclear Regulatory Commission radioactive waste handling requirements.

2.2.9 Departmental procedures specify the methods and controls for implementing operational phase activities. These include:

a. Nuclear Generation Department Nine Mile Point Nuclear Station Administrative Procedures;

b. Nuclear Engineering and Licensing Department Engineering Procedures; c.'urchasing Department Purchasing Procedures;

d. Materials Hanagement Department Materials Management Procedures;

e. Meter and Test Department Measuring and Test Equipment Control Procedures;

f. Meter and Laboratory Facilities Department Calibration Procedures; and

g. Quality Assurance Department Quality Assurance Procedures.

2.2.10 The programmatic Regulatory Guides and ANSI Standards, and their applicable revisions, to which NMPC commits with regard to quality assurance matters and appropriate explanations of interpretations and exceptions are tabulated in Appendices A and 8 of this Topical Report.

2.2.11 The scope of the program and the extent to which its controls are applied are established as follows:

a. NMPC uses the criteria specified in Engineering Procedures for identifying structures, systems and components to which the quality assurance program applies;

NMPC-gATR-1 Page 2-4 Rev. 0

b. This identification process results in a g-list which identifies safety-related items for each unit. The g-list is a controlled document. Safety-related items are determined by engineering analysis of the function(s) of plant structures, systems and components in relation to safe operation and shutdown;

c. The controls specified in the quality assurance program described in this Topical Report are applied to safety-related items.

2.2.12 Safety-related activities are accomplished under controlled conditions.

Preparations for such activities include confirmation that prerequisites have been met, such as:

a. Assigned personnel are qualified;

b. Mork is planned in accordance with the proper revisions of applicable engineering and/or technical specifications;

c. Specified equipment and/or tools, if any, are on hand to be used;

d. Equipment and materials are in an acceptable status;

e. Systems or structures on which work is to be performed are in the proper condition or operational mode for the task;

f. Current and approved instructions or procedures for the work are available for use;

g. Items and facilities that could be damaged by the work, have been protected as required; and h.. Provisions have been made for special equipment, environmental conditions, skills, controls, processes, tests and verification methods.

2.2.13 Oevelopment, control and use of computer programs affecting nuclear power plant safety-related design and operation are subject to appropriate controls.

2.2.14 Responsibility and authority for planning and implementing indoctrination and training programs are delegated to each department.

The training and indoctrination program provides for the following as appropriate:

a. Personnel responsible for performing and verifying activities that affect quality are Familiar with the activities and the requirements identified in applicable quality-related manuals, instructions and procedures.

b. Proficiency tests are utilized where appropriate to assess training effectiveness.

'C NMPC-QATR-1 Page 2-5 Rev. 0

c. Personnel who perform inspection, examination, test, audit and special process activities are trained and qualified in accordance with 'applicable requirements. Certificates of qualification (where required) designate specific areas of qualification and the bases for the qualification.

d. Provisions are included for retraining, re-examination and recertification (where certification is required) to ensure that proficiency is maintained.

e. Training content and attendance records, and required qualification and certification records are maintained.

2.2.15 The management of Niagara Mohawk Power Corporation (NMPC) at the presidential or chief executive officer level assesses the scope, status, adequacy, and compliance of the quality assurance program for the nuclear stations at a predetermined regularity. Management at this level employs the following means to assess the program:

a. The Director Quality Assurance is responsible for annually reporting in writing to the President of NMPC on the status, adequacy and effectiveness of the NMPC quality assurance program.

b. The Oi rector Quality Assurance regularly attends corporate staff meetings, board meetings and cotenant meetings, and makes verbal presentations regarding quality-related matters. Minutes of these meetings are generally documented.

Certain actions of the Safety Review and Audit Board and of the Site Operations Review Committee result in audits and/or reports by which members of these offsite and onsite review committees are made aware, on a regular basis, of the effectiveness of the quality assurance program.

2.2.16 The Safety Review and Audit Board (SRAB) is a standing committee responsible to the Vice President Nuclear Engineering and Licensing and to the Vice President Nuclear Generation regarding designated quality assurance functions at the Nine Mile Point Nuclear Station.

2.2.17 The Site Operations Review Committee (SORC) is an independent review comoittee responsible to the General Superintendent, Nuclear Generation and transmits reports to the Safety Review and Audit Board. The Site Operations Review Cooeittee responsibilities include:

a. Reviewing reportable events;

b. Reviewing facility operations to detect potential safety hazards;

c. Performing special reviews, investigations or analyses and reports thereof as requested by the Chairman of the Safety Review and Audit 0 Board;

NHPC-QATR-1 Page 2-6 Rev. 0 2.2.18 The Quality First Program (QlP) provides NHPC and contractor employees an opportunity to communicate their quality concerns regarding operation, maintenance or modification while keeping their identity confidential, if they desire, and to receive feedback regarding the results of investigations with respect to their concerns. Quality concerns determined to be valid are acted upon by the responsible organization and the actions are verified by Q1P personnel prior to closeout.

NNPC-QATR-1 Page 3-1 Rev. 0 3.0 DESIGN CONTROL 3.1 POLICY Station modifications are accomplished in accordance with approved designs and procedures. The controls apply to preparation, review and revision of design documents, including the correct translation of applicable regulatory requirements and design bases into design, procurement and procedural documents. The controls apply to .design work performed by contractors as well as by NMPC engineering 'and technical organizations.

3.2 IMPLEMENTATION 3.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

3.2.2 Nuclear Engineering and Licensing Department responsibilities include the preparation, review and approval of such things as:

a) system descriptions; b) design input and criteria; c) drawings, specifications, procedures; and d) engineering analyses and associated computer programs.

3.2.3 Computer programs used in safety-related design and station operation are appropriately documented, verified, certified for use and controlled in accordance with procedures.

3.2.4 Materials, parts and processes are selected and specified, based on the requirements of applicable codes and standards or on known, successful use under similar conditions. The adequacy of the selected materials, parts, and processes is assured through the required design verifications or approvals. Alternatively, materials, parts, and processes may be qualified for use through qualification testing.

3.2.5 Exceptions, waivers to, or deviations from engineering requirements are required by procedure and by contract, when applicable, to be documented and controlled.

NMPC-gATR-1 Page 3-2 Rev. 0 When modifications involve design interfaces between internal or external design organizations or across technical disciplines, these interfaces are controlled. Procedures delineate the review, approval, release, distribution and revision of documents involving design interfaces. Controls are provided to ensure that structures, systems and components are compatible geometrically and Functionally with processes and environment. Lines of communication are established for controlling the flow of needed design information across design interfaces, including changes to the information as work progresses.

Decisions and problem resolutions involving design interfaces are made by the Nuclear Engineering organization.

Design drawings and specifications are checked to verify the dimensional accuracy and completeness.

Modification design document packages are audited by the guality Assurance Department to assure that the documents therein have been prepared, reviewed, and approved in accordance with procedures and that they contain the necessary quality assurance requirements. These requirements include any inspection and test requirements, quantitative and/or qualitative acceptance criteria and the requirements for documenting inspection and test results.

The extent of and methods used for design verification are documented.

Methods for design verification include evaluation of the applicability of standardized or previously proven designs, alternate calculations, qualification testing and design reviews. These methods may be used singly or in combination, depending on the needs for the design under consideration.

When design verification is done by evaluating standardized'or previously proven designs, the applicability of such designs is confirmed. Any differences from the proven design are documented and evaluated for the intended application.

Design reviews are performed by single individuals or by interdisciplinary or multi-organizational groups, as appropriate.

Unless otherwise stated, the verification of design addresses the information conveyed by the design document. When the verification is limited to certain areas or features, the scope or extent and any limitations on the verification are documented.

NMPC-gATR-1 Page 3-3 Rev. 0 when the ability of an item to perform an essential safety function cannot otherwise be adequately substantiated. This testing is performed before plant equipment installation where possible, but always before reliance upon the item to perform a safety-related function. gualification testing is performed under conditions that simulate adverse design conditions as determined by analysis, considering relevant operating modes. Test requirements, procedures .

and results are documented. Results are evaluated to assure that test requirements have been satisfied. Modifications are made if shown to be necessary through testing; Following modification, any necessary retesting or other verification is performed. Scaling laws are established and verified, when applicable. Test configurations are documented.

3.2.11 Persons representing applicable technical disciplines are assigned to perform design verifications. These persons are qualified by appropriate education or experience and are not directly responsible for the design being verified. This verification may be performed by the originator's supervisor, provided the supervisor did not specify a singular design approach or rule out certain design considerations and did not establish the design inputs used in the design, or provided the supervisor is the only individual in the organization competent to perform the verification.

3.2.12 When designs must be released for use before they have been completed or before they have been verified, the incomplete or unverified parts of the design and the hold point to which work may proceed are identified, and design output documents based on unverified data are identified and controlled. This hold point occurs before the work becomes irreversible or before the item is relied on to perform a safety-related function. Justification for such early release is documented.

3.2.13 Design output documents, and revisions thereto, are controlled by the design office (architect-engineer, vendor, contractor, consultant or Nuclear Engineering) responsible for the design work. Each design organization controls design documents in accordance with approved procedures that provide for review, approval, distribution and revision.

3.2.14 Changes to design output documents, including field changes, are controlled in a manner coaeensurate with that used for the original design. Information on approved changes is transmitted to affected organizations.

fl I NHPC-QATR-1 Page 4-1 1

Rev. 0

4.0 PROCUREMENT DOCUMENT CONTROL 4.1 POLICY Procurement documents define the characteristics of items or services to be procured, identify applicable regulatory and industry codes or standards requirements, and specify supplier quality assurance program requirements to the extent necessary to assure adequate quality.

4. 2 IMPLEMENTATION 4.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

4.2.2 'rocurement requisition packages are reviewed and. approved prior to submittal to the Purchasing Department. Review includes verification by the Quality Assurance Department that the necessary quality requirements are specified.

4.2.3 The responsible project engineer or requester performs bid evaluations.

4.2.4 Supplier and contractor selection is described in Section 7.0.

4.2.5 The contents of procurement documents vary according to the item(s) being purchased and its function(s) in th'e plant. Procurement documents include the following as applicable:

a. Scope of work to be performed;

b. Technical requirements, with applicable drawings, specifications, codes and standards identified by title, document number and revision and date, with any required procedures such as special process instructions identified in such a way as to indicate source and need;.

c. .Regulatory, administrative and reporting requirements, including 10CFR21 requirements; d.. Quality requirements appropriate to the complexity and scope of the work, including necessary tests and inspections;

e. A requirement for a documented quality assurance program, subject to Quality Assurance Department review and written concurrence;

f. A requirement for the supplier to invoke applicable quality requirements on subtier suppliers;

NHPC-QATR-1 Page 4-2 Rev. 0 0 g. Provisions for access to supplier and subtier suppliers and records for inspections, surveillances and audits; facilities

h. Identification of documentation to be provided by the supplier (see paragraph 4.2.6);

i. Provisions for documentation and dispositioning of nonconformances.

4.2.6 Purchase documents require suppliers to furnish the following records as applicable:

a. Drawings and/or< related engineering documentation that identify the purchased item and the specific procurement requirements (e.g.,

codes, standards, as-built/as-designed drawings and specifications) met by the item;

b. Documentation identifying any procurement requirements that have not been met;

c. A description of those nonconformances from the procurement requirements dispositioned "use as is" or "repair."

The Quality Assurance .Department evaluates the acceptability of these documents during source and/or receipt inspection.

e 4.2.7 The Quality Assurance Department performs and documents reviews of procurement a.

requisition packages to assure that:

Quality requirements (see paragraph 4.2.5) are correctly stated, inspectable, and controllable;

b. Acceptance and rejection criteria are included; and

c. The procurement documents have been prepared, reviewed, and approved in accordance with applicable procedures.

4.2.8 Changes to the technical or quality requirements in procurement documents are controlled in a manner commensurate with that used for the original requirements.

NMPC-QATR-1 Page 5-1 Rev. 0 5.0 INSTRUCTIONS PROCEDURES AND DRAWINGS 5.1 POLICY Activities affecting the quality of safety-related structures, systems, components and services are accomplished using instructions, procedures and drawings (including vendor manuals) appropriate to the circumstances. These documents include appropriate acceptance criteria.

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5.2 IMPLEMENTATION 5.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

5.2.2 Instructions, procedures, drawings, or vendor manuals incorporate (1) a description of the activity to be accomplished and (2) appropriate quantitative (such as tolerances and operating limits) and qualitative (such as workmanship standards) acceptance criteria.

5.2.3 The procedures used to control activities include the departmental procedures listed in Section 2. Those procedures provide requirements and controls pertaining to the conduct of both onsite and offsite safety-related activities to provide affected personnel with a clear understanding of the operating philosophy and management policies as well as methods and techniques for performing required work.

5.2.4 Measures are provided to assure that correct procedures are available and that they are used in the performance of safety-related activities.

l 1 NMPC-QATR-1 Page 6-1 Rev. 0

.0 '.0 DOCUMENT CONTROL 6.1 POLICY Documents are controlled, issued and changed according to established procedures. Documents such as instructions, procedures, and drawings, including changes thereto, are reviewed for adequacy, approved for release by authorized personnel, and are distributed and used at the location where a prescribed activity is performed.

Changes to controlled documents are reviewed and approved by the same organizations that performed, the original review and approval or by the organizations designated in accordance with the procedures governing these documents.

6.2 IMPLEMENTATION 6.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

6.2.2 Procedures are established for review, approval, issue, change and use of documents in the following categories:

a. Design documents (e.g., calculations, drawings, specifications, analyses) including documents related to computer codes;

b. As-built drawings, procedures and related documents;

c. Procurement documents;

d. Instructions and procedures for activities such as fabrication, construction, modification, installation, inspection, test, and station maintenance and operation;

e. Procedures that implement the quality assurance program;

f. Final Safety Analysis Report;

g. Reports of nonconformances;

h. Unit Technical Specifications;

i. Quality Assurance Program Topical Report.

6.2.3 Procedures which govern the review, approval, issue, change and use of documents include as appropriate:

a. Establishment of criteria to ensure that adequate technical and quality requirements are incorporated prior to implementation;

I NHPC-QATR-1 Page 6-2 Rev. 0

0 b. Identification of the organizations responsible for review, approval, issue, and revision;

c. Performance and documentation of a review for concurrence with quality assurance related aspects by the Quality Assurance Oepartment;

d. Review of changes to documents by the same organizations that performed the initial review and approval or by the organizations designat'ed in accordance with the applicable procedures.

6.2.4 Controlled documents, including changes, are issued and distributed so that:

a. The documents are available as required at the work location prior to commencing work; and

b. Obsolete or superseded documents are removed from work areas and replaced by applicable revisions in a timely manner.

6.2.5 Master lists or equivalent means are, used to identify the current revision of controlled documents. When master lists are used, they are updated and distributed to designated personnel who are responsible for 0 6.2.6 maintaining current copies of the l,ists.

As-built drawings and related documents are prepared in consistent with the needs of the user organization.

a timely manner

NMPC-QATR-1 Page 7-1 Rev. 0 7.0 CONTROL OF PURCHASED MATERIAL E UIPMENT AND SERVICES 7.1 POLICY Activities that implement approved procurement requests for material, equipment, and services are controlled to assure conformance with procurement document requirements. Controls include a system of supplier evaluation and selection, source inspection, examination and acceptance of items and documents upon delivery, and periodic assessment of supplier performance.

7.2 IMPLEMENTATION 7.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

7.2.2 When contractors perform work under their own quality assurance programs, those programs are reviewed for compliance with the applicable requirements of 10CFR50 Appendix 8 and the contract and are accepted by the Quality Assurance Oepartment.

7.2.3 NMPC qualifies suppliers (excluding suppliers of commercial grade items) by performing a documented evaluation of their capability to 0 provide items or. services specified by procurement documents. Other means of evaluating supplier qualifications include objective evidence of suppliers! current quality performance, surveys performed by consultants, other ASME survey teams.

utilities or other organizations such as CASE or NMPC qualified suppliers involved in active procurements are surveyed every three years to maintain their qualified status except as follows. Supplier three year surveys are not necessary to maintain qualification when the items or services supplied are determined and documented by Nuclear Engineering and Licensing and Quality Assurance Departments to satisfy each of the following conditions:

a. Relatively simple and standard in design, manufacture and test; and

b. Adaptable to standard or automated inspections or tests of the end product to verify quality characteristics after delivery; and

c. Such that receiving inspection does not require operations that could adversely affect the integrity, function, or cleanness of the item.

In the above cases, source and/or receipt inspection provides the necessary assurance of an acceptable item or service.

7.2.4 Supplier activities that affect quality are verified in accordance with written procedures that provide the method of verifying (such as audit, surveillance, or inspection) and documenting the verification results.

NHPC-QATR-1 Page 7-2 Rev. 0 7.2.5 Spare and replacement parts are procured in accordance with the following provisions to assure that their performance and quality are at least equivalent to those of the parts that will be replaced:

a. Specifications and codes referenced in procurement documents for spare or replacement items are the same or equivalent to those for the original items or to reviewed and approved revisions.

b. Where quality requirements for the original items cannot be determined, requirements and controls are established by engineering evaluation.

c. Any additional or modified design criteria, imposed after previous procurement of the item(s), are identified and incorporated.

7.2.6. Commercial grade items to be used in safety-related applications are purchased in accordance with Nuclear Engineering Procedures that provide controls to assure that the items satisfy design requirements.

7.2.7 Receipt inspections are performed to verify that items are undamaged and properly identified and that required supplier-furnished documentation is available and correct. In addition, depending upon the nature, complexity and importance of the item and amount of source inspection or surveillance, selected characteristics may be examined or tested on a sampling basis to verify conformance to procurement requirements. Items inspected are identified as to their acceptance status prior to storage or release for installation or use.

7.2.8 Suppliers'ertificates of conformance are reviewed for completeness and accuracy and are supplemented by receipt inspection to verify conformance to purchase requirements.

7.2.9 Documentation supporting the conformance of material and equipment with the procurement documents is to be available at the site prior to installation whenever possible. In those instances when equipment and material are received without the required documentation, installation may be accomplished if:

a. The installation is controlled in accordance with the requirements of Sections 15 and 16 of this Quality Assurance Program Topical Report; and

b. The installed items are readily removable or more readily protected by installation than by 'segregated storage; and

c. The supporting documentation is reasonably expected to arrive prior to the use of the equipment or material.

In no case shall material or equipment be relied upon for its safety

~ function without receipt of proper documentation.

NMPC-QATR-1 Page 8-1 Rev. 0 8.0 IDENTIFICATION AND CONTROL OF MATERIALS PARTS AND COMPONENTS 8.1 POLICY Materials, parts, and components (items) are identified and controlled to prevent their inadvertent use. Identification of items is maintained either on the items, their storage areas or containers, or on records traceable to the items.

8.2 IMPLEMENTATION 8.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

8.2.2 Controls provide for the identification and control of materials (including consumables), parts and components (including partially fabricated assemblies) .

8.2.3 Items are identified by physically marking the items, storage area, or containers or by maintaining records traceable to the items. The method of identification is such that the quality of the items is not degraded'.2.4 Items are traceable to applicable drawings, specifications, or other pertinent documents to ensure that only correct and acceptable items are used. Verification of traceability is performed and documented prior to release for fabrication, assembly, or installation except as provided in Section 7.0.

NMPC-QATR-1 Page 9-1 Rev. 0 9.0 CONTROL OF SPECIAL PROCESSES 9.1 POLICY Special processes are controlled and are accomplished by qualified personnel using qualified procedures and equipment in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

9.2 IMPLEMENTATION 9.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

9.2.2 Processes subject to special process controls are those for which the results are highly dependent on the control of the process or the skill of the operators, or both, and in which the specified quality cannot be readily determined by inspection or test of the product. Such processes include welding, heat treating, chemical cleaning, application of protective coatings, and nondestructive examination (NDE).

9.2.3 Requirements for control of special processes involve one or more of the following methods, each of which is approved by qualified personnel:

a) Written instructions on the drawing or specification for the piece or assembly; b) Written procedure(s) including the specific application involved; c) Reference to a recognized code or standard published by a national society or institute; and d) Combinations of above with addenda, exceptions, or alternates clearly indicated and in terminology familiar to personnel involved in planning, performing the process and evaluating the results.

9.2.4 Special process procedures are prepared by personnel with expertise in the discipline involved. The procedures are reviewed for technical adequacy by other personnel with the necessary technical competence, and are qualified by testing, as necessary.

9.2.5 Special process personnel qualification is determined by individuals authorized to administer the pertinent examinations. Certification of qualification is based in part on examination results. Personnel certification is kept current by performance of the special process(es) and/or reexamination at time intervals specified by applicable codes, specifications and standards'nsatisfactory performance or, where applicable, failure to perform within the designated time intervals

. ~ requires requalification and recertification.

NHPC-gATR-1 Page 9-2 Rev. 0 9.2.6 For special processes that require qualified equipment, such equipment is qualified in accordance with applicable codes, standards and speciFications.

9.2.7 gualification records and records of satisfactory special process performance are maintained in accordance with Section 17.

9.2.8 The guality Assurance Oepartment performs audits, inspection and surveillance of special processes to assure they are satisfactorily performed when specified by applicable inspection planning and/or site procedures. Such inspections, surveillances and audits include verification that process data are recorded as required, are within specified limits and are performed in accordance with applicable requirements.

9.2.9 NHPC specifies in procurement documents which records are to be kept by vendors and/or forwarded to NHPC. The document retention policy and requirements are stated in Section 17. gualifications of procedures, personnel, and equipment will be filed and reviewed periodically, and when required by governing codes or standards, the qualification I

records will be updated or revised as appropriate.

Examples of typical records that may be specified are:

a) Procedure, personnel and equipment qualification test results in.

accordance with applicable codes or standards; b) Special process procedures, signed and dated by authorized personnel; c) Results of special inspections with results of tests, any corrective action taken, retest if required, and the dated acceptance signature. The results document must identify the part, assembly, and/or section of the system with its own number or code for future identification and reference. Supporting evidence or documentation such as radiographs, photos, sketches or other descriptive material must bear the same number or code; d) Charts of the heat cycle in heat treating operations showing test equipment numbers, temperatures, and time; or certiFied documents by authorized personnel attesting to test equipment numbers, temperature, and time used in the heat treating cycle.

I NMPC-QATR-1 Page 10-1 Rev. 0

~ 10.0 10.1 INSPECTION POLICY Inspections of items or activities are performed to verify their conformance with specified requirements. The inspections for certifying acceptance are performed by people other than those who perform or supervise the work being inspected. Direct inspection, process monitoring, or both, are used as necessary. Hold points and/or witness points are us'ed as necessary to ensure that inspections are accomplished at the correct points in the sequence of work activities.

10. 2 IMPLEMENTATION 10.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

10.2.2 Inspections are applied to procurement, maintenance, modification, testing, fuel handling, operation and inservice inspection to verify that items and activities conform to specified requirements.

Inspection planning documents are prepared or reviewed by .the Quality Assurance Department .in accordance with procedures. Documentation of inspection planning identifies the following as applicable:

a. Characteristics and activities to be inspected;

b. Inspection organization;

c. Accept/reject criteria;

d. Hold points and/or witness points;

e. Methods;

f. Provisions for recording objective evidence of inspection results;

g. SpeciFy measuring and test equipment of the necessary accuracy for performing inspection.

Inspection is performed on selected operations where it is deemed necessary to verify conformance with specified requirements.

Process monitoring is used where direct inspection alone is impractical or inadequate. Both inspection and process monitoring are performed when control is inadequate without both.

10.2.3 Training and qualification programs for personnel who perform inspection, including nondestructive examination, are established, implemented and documented in accordance with Section 2.0. These programs meet the requirements of applicable codes and standards'

NNPC-QATR-1 Page 10-2 Rev. 0

. ~ Qualifications and certifications of inspection and nondestructive examination (NDE) personnel are maintained as quality records in accordance with Section 17.

10.2.4 Hold points are designated as mandatory inspection point" when confirmation is needed that the work at that point is acceptable before additional work can proceed. Hold point inspections are performed, and work is released for further processing or use, by designated inspection personnel. Hold points may be waived only by designated personnel.

10.2.5 Witness points require notification of the Quality Assurance Department prior to performance of the specified activity. Work may proceed upon sufficient notice to QA of the impending witness point.

10.2.6 Inspections are performed and documented in accordance with written procedures. The results are evaluated and documented by qualified personnel in order to verify the acceptability of the item or work.

10.2.7 Inservice inspection and testing is performed and documented in accordance with a program of examinations, tests, and inspections of plant components and .systems. An Authorized Nuclear Inservice Inspector (ANII) is employed to verify that the program is conducted in accordance with requirements.

10.2.8 Inspections are normally performed by Quality Assurance Department personnel. Inspections associated with normal operations of the plant (such as routine maintenance, surveillance, and test) may be performed by individuals within the same group other than those who performed or directly supervised the work, provided the following requirements are met:

a. The quality of the work can be demonstrated through a functional test when the activity involves breaching a pressure retaining item; and

b. The qualification criteria for inspection personnel are reviewed by the Quality Assurance Department.

10.2.9 Inspection records contain the following where applicable:

a. Item inspected;

b. The date of the inspection;

c. Inspector or data recorder identification;

l NHPC-QATR-I Page 10-3 Rev. 0

d. Type of observation;

e. Results or acceptability;

f. Reference to information on action taken on nonconformances to resolve any discrepancies noted.

t NHPC-QATR-1 Page 11-1 Rev. 0 0 11.0 TEST CONTROL POLICY Testing is performed to demonstrate that items will perform satisfactorily in service. The testing is performed in accordance with written procedures that incorporate specified requirements and acceptance criteria. The test program includes qualification, acceptance, pre-operational, start-up, surveillance and post-maintenance tests. Test parameters, including any prerequisites, instrumentation requirements and environmental conditions, are specified and met. Test results are documented and evaTuated.

11.2 IHPLEHENTATION 11.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

11.2.2 Tests are performed in accordance with procedures and criteria that designate when tests are required and how they are to be performed.

Such testing includes the following:

a. Qualification tests, as applicable, to verify design adequacy in accordance with Section 3.0;

b. Tests of equipment and components to assure their proper operation prior to delivery or pre-operational tests;

c. Pre-operational tests to assure proper and safe operation of systems and equipment prior to s'tart-up tests or operations;

d. Start-up tests, including precritical, criticality, low-power and

'ower ascension tests performed after fuel loading to assure proper and safe operation of systems and equipment;

e. Surveillance tests to assure continuing proper and safe operation of systems and equipment; and

f. Haintenance tests after preventive or corrective maintenance.

11.2.3 Test procedures and instructions include provisions for the following, as applicable:

a. The requirements and acceptance limits contained in applicable design and procurement documents;

b. Test prerequisites such as calibrated instrumentation, required test equipment, degree of completeness of the item to be tested, suitable and controlled environmental conditions and provisions for 0 data collection and storage;

NHPC-QATR-1 Page 11-2 Rev. 0

c. Verifying that test prerequisites have been met;

d. Instructions for performing the test;

e. Any witness and hold points;

f. Acceptance criteria;

g. Documenting or, recording test data and results; ~and

h. Verification of completion.

11.2.4 Test procedures and instructions are reviewed by the applicable organizations for technical content and by the Quality Assurance Department for quality assurance requirements.

11.2.5 The Quality Assurance Department verifies that test results are documented, evaluated and accepted by responsible personnel.

11.2.6 Test records contain the following where applicable:

a. Item tested and type of observation;

b. The date and results of the test;

c. Information related to conditions adverse to quality;

d. Data recorder identification;

e. Evidence as to the acceptability of the results; and

f. Action taken to resolve any deviations noted.

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NHPC-QATR-1 Page 12-1 Rev. 0

~ 12.0 12.1 CONTROL OF MEASURING AND TEST E UIPHENT POLICY Measuring and test equipment is identified, controlled, calibrated and adjusted at specified intervals to maintain accuracy within prescribed limits.

12.2 IMPLEMENTATION 12.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

12.2.2 Procedures are established for calibration, maintenance and control of measuring and test equipment utilized in the operation, measurement, inspection or monitoring of items. These procedures describe calibration technique, frequency, maintenance and control of installed as well as portable equipment.

12.2.3 Measuring and test equipment is uniquely identified and is traceable to its calibration test data.

12.2.4 Labels are attached to measuring and test equipment to display the next calibration due date. Where labels cannot be attached, a control system is used that identifies to potential users any equipment beyond the calibration due date.

12.2.5 Measuring and test equipment is calibrated at specified intervals.

These intervals are based on the amount of use, stability, characteristics and other conditions that could adversely affect the required measurement accuracy. Reference and secondary calibration standards are traceable to nationally recognized standards where they exist. Where national standards do not exist, provisions are established to document'the basis for calibration.

12.2.6 Where practical, reference standards that have at least four times the required accuracy of the item being calibrated are used to calibrate secondary standards. When this accuracy is not possible, these standards shall have an accuracy that assures that the equipment being calibrated will be within required tolerance. In such cases the basis of acceptance is documented and is authorized by responsible management personnel.

12.2.7 Secondary standards normally have a greater accuracy than the equipment or installed plant instrumentation being calibrated.

Standards with the same accuracy may be used when shown to be adequate for specific calibration requirements. The basis for this acceptance is documented and is approved by responsible management.

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0 NMPC-QATR-1 Page 12-2 Rev. 0 12.2.8 When measuring and testing equipment used for inspection and test is found to be out of calibration, evaluations are conducted to determine the validity of the results obtained since the most recent calibration. The results of evaluations are documented. Retests or reinspections are performed on suspect items as necessary.

NMPC-QATR-1 Page 13-1 Rev. 0 0 13.0 13.1 HANDLING POLICY STORAGE AND SHIPPING Activities with the potential for causing contamination or deterioration that could adversely affect the ability of an item to perform its intended function and activities necessary to prevent damage or loss are identified and controlled. Controls are achieved through the use of appropriate procedures.

13. 2 IMPLEMENTATION 13.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

13.2.2 Procedures are used to control the cleaning, handling, storing, packaging, preserving and shipping of materials, components and systems in accordance with design and procurement requirements. These procedures include the following functions:

a. Cleaning, to assure that required cleanliness levels are achieved and maintained;

b. Packaging and preservation, to protect against damage or e c.

deterioration. When necessary, and these procedures provide for special environments such as inert gas atmospheres, specific moisture content levels temperature levels; Handling, to preclude damage or safety hazards. Routine inspection of handling equipment is included;

d. Storing, to minimize the possibility of loss, damage or deterioration of items in storage, including consumables such as chemicals, reagents and lubricants. Storage procedures also provide methods to assure that items having limited shelf life are not used after their expiration date; and

e. Marking'and labeling of items for packaging, shipment, and storage is to be adequate to identify the shipment and to indicate the need for special environments and special control.

1 I NMPC-QATR-1 Page 14-1 Rev. 0 14.0 INSPECTION TEST ANO OPERATING STATUS 14.1 POLICY Systems are established which ensure that the inspection, test and operational status of items is known and controlled. Non-operational status of systems and components for inspection, maintenance and tests is indicated by tagging, marking, logging or other specified means under procedural controls to prevent inadvertent use.

14.2 IMPLEMENTATION 14.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

14.2. 2 For modi f i cat i on installation and acti vi ti es; including i tern fabri cati on, construct test; procurement documents, service contracts and i on, procedures specify the degree of control required for the indication of inspection and test status of items.

t 14.2.3 14.2.4 14.2.5 Application and removal of status indicators such labels, etc. are controlled by procedures.

thereto, are controlled by procedures. Changes in the approved as sequence are controlled in accordance with applicable procedures.

The status of inoperable systems, components, and supporting tags, markings, The sequence of inspections, tests and other operations, and changes structures is known and controlled from the control room in accordance with procedures which are kept up-to-date to preclude unintentional operations.

14.2.6 The status of nonconforming, inoperable or malfunctioning items is identified and documented in accordance with Section 15 to prevent inadvertent use.

NHPC-QATR-1 Page 15-1 Rev. 0 e 15.0 NONCONFORHING HATERIALS PARTS OR COHPONENTS 15.1 POLICY Haterials, parts, components or services as applicable (including computer codes) that do not conform to requirements are controlled in order to prevent their inadvertent use. Nonconforming items are identified, documented, segregated when practical and dispositioned.

Affected. organizatidns are notified of nonconformances.

15.2 IHPLEHENTATION 15.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

15.2.2 Nonconformances are documented and dispositioned, and notification is made to affected organizations. Nonconforming items are reviewed for reportability. Personnel authorized to disposition, conditionally release and close out nonconformances are designated.

a. Nonconforming items. are identified by marking, tagging or segregating or by administrative controls. Oocumentation describes the nonconformance, the disposition of the nonconformance and the 0 .inspection requirements. It also includes signature approval of the disposition;

b. The Quality Assurance Oepartment reviews the disposition of NHPC QA originated nonconformances and documents concurrence with the acceptance, conditional release or repair of a nonconforming item;

c. Items that have the disposition of "repair" or "use-as-is" require documentation- by Engineering justifying acceptability; and

d. Repaired, reworked, and replacement items are inspected and tested in accordance with the original inspection and test requirements or alternatives that have been documented as acceptable by the responsible functional organization.

15.2.3 Dispositions of conditionally released items are closed out before the items are relied upon to perform their safety-related functions.

15.2.4 Prior to the initiation of preoperational testing on an item, nonconformances are corrected or evaluated for possible impact upon the item or the testing program.

I NMPC-QATR-1 Page 15-2 Rev. 0 15.2.5 The Quality Assurance Oepartment analyzes nonconformance reports to identify quality trends. Trend reports, which highlight significant results, are issued periodically to upper management For review and assessment.

15.2.6 When appropriate, cause of nonconforming conditions is determined and corrective action implemented to prevent recurrence.

NHPC-gATR-1 Page 16-1 Rev. 0 16.0 CORRECTIVE ACTION 16.1 POLICY Program and hardware conditions adverse to quality are identified promptly and corrected as soon as practical.

16. 2 IHPLEHENTATION 16.2.1 General organizational responsibilities are described in Section 1.0, ORGANI'ZATION.

16.2.2 Controls are established to assure that conditions adverse to quality such as malfunctions, errors, deficiencies, or nonconformances are identified and documented and that appropriate corrective action is taken. The controls also assure that corrective action is implemented in a timely manner. Verification is required on adequacy and implementation of corrective action.

16.2.3 For significant conditions adverse to quality, corrective action includes determining the cause and extent of the condition and taking appropriate action to minimize similar problems in the future. These identified conditions, their causes and corrective actions taken are reported to appropriate levels of management for review and assessment.

16.2.4 Conditions adverse to quality are evaluated for reportability.

L NNPC-QATR-1 Page 17-1 Rev. 0 17.0 UALITY ASSURANCE RECORDS 17.1 POLICY Quality assurance records are records that furnish documentary evidence of the quality of items and services. Such documents are prepared by the originator and maintained by designated organizations. They are accurate, complete and legible and are protected against damage, deterioration or loss. They are identifiable and retrievable.

17. 2 IMPLEMENTATION 17.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

17.2.2 Documents that furnish evidence of quality of items and services are generated and controlled in accordance with the procedures that govern those activities. Such documents are considered records upon completion. These records include:

a. Results of reviews, inspections, surveillances, tests, audits and material analyses; e b. Qualification of personnel, procedures

c. Operating Logs; and equipment;

d. Maintenance and modification procedures and related inspection results;

e. Reportable occurrences;

f. Records required by the stations'echnical Specifications;

g. Nonconformance reports;

h. Corrective action reports; and

i. Other documentation such as drawings, specifications, procurement documents, calibration procedures and reports.

17.2.3 A document becomes a record when completed. At that time it is designated as a permanent or nonpermanent record and is transmitted to file. Nonpermanent records have specified retention times. Permanent records are maintained for the life of the item and/or plant as appropriate.

17.2.4 In-process documents are controlled by the originator until completed and transmitted to file.

NHPC-QATR-1 Page 17-2 Rev. 0

0 17.2.5 Records may be original documents or legible copies.

17.2.6 Authorized personnel may issue corrections or supplements to records.

Procedures address acceptable methods of making corrections to records.

17.2.7 Traceability between the record and the item applies is provided.

or activi'ty to which it 17.2.8 Except for records that are stored as originals, such as radiographs and certain strip charts, records are stored in remote, dual facilities to prevent damage, deterioration or loss due to natural or unnatural causes. When only the single original can be retained, appropriate fire-rated facilities or features are used.

NHPC-QATR-1 Page 18-1 Rev. 0

18. 0 AUDITS 18.1 POLICY Audits are carried out to provide an independent evaluation of compliance and effectiveness of the quality assurance program, including those elements of the program implemented by suppliers and contractors. Audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibility in the areas audited. Audi,t results are documented and are reviewed by management. Follow-up action is taken where indicated.

18.2 IHPLEHENTATION 18.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

18.2.2 Quality Assurance Department audits are performed:

a. To provide a comprehensive independent verification and evaluation of quality-related procedures and activities; and

b. To verify and evaluate the quality assurance programs, procedures, and activities of suppliers.

18.2.3 Audits are performed in accordance with established schedules.

Applicable QA Program elements are audited at least once every two years.

18.2.4 Safety Review and Audit Board audits are performed as specified in the unit Technical Specifications.

18.2.5 Regularly scheduled audits are supplemented by special audits when appropriate. Conditions which may warrant special audits include:

a. Significant changes are made in the quality assurance program; b When it is suspected that quality has been adversely affected; or

c. When an independent assessment of program effectiveness is considered appropriate.

18.2.6 Audits include an objective evaluation of quality-related practices, procedures, instructions, activities, items, documents and records to confirm that the quality assurance program is effective and properly implemented. The following activities are included:

a.. Indoctrination and training programs;

, ~ b. Interface control between NHPC organizational units NHPC and its principal contractors; and between

NMPC-QATR-1 Page 18-2 Rev. 0

~ c. Corrective action;

d. M&TE calibration;

e. Nonconformance control;

f. FSAR commitments; and

g. Activities associated with computer codes.

18.2.7 Audit procedures and the scope, plans, checklists and results of individual audits are documented.

18.2.8 Personnel selected for auditing assignments have experience or are given training commensurate with the needs of the audit and have no direct responsiblities in the areas audited.

18.2.9 Lead auditors are qualified and certified in accordance with approved procedures.

18.2.10 Audit data are analyzed to identify any quality deficiencies and assess the effectiveness of the quality assurance program. Audit reports are distributed to the responsible management of both the audited and auditing organizations.

18.2.11 Management of the audited organization takes appropriate action to correct observed deficiencies and to identify the cause and prevent recurrence of any conditions adverse to quality. Follow-up is performed by the Quality Assurance Department to ensure that the appropriate corrective action is taken and is effective. Such follow-up includes reaudits when necessary.

0 NHPC-QATR-1 Rev. 0 0 APPENDIX A REGULATORY COMHITHENTS Niagara Mohawk Power Corporation commits to the requirements of the regulations and industry standards identified in Appendix A subject to the stated interpretations and exceptions in Appendix B.

REVISION/

DOCUMENT DATE TITLE

l. 10CFR50 Appendix 8 Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

2. Reg. Guide 1.28 1985 R3 Quality Assurance Program (being issued) Requirements (Design and Construction) (Endorses ANSI/ANS NQA-l).

3. ANSI/ANS-3. 2 1982 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.

4. ANSI/ASME NQA-1 1983 including Quality Assurance Program 83 Addenda Requirements. for Nuclear Facilities.

5. ANSI/ASHE NQA-2 1983 Quality Assurance Requirements for Nuclear Power Plants.

6. ANSI N45.2.4/ 1972/1971 Installation, Inspection IEEE 336 and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations.

NHPC-QATR-1 Rev. 0 APPENOIX 8 INTERPRETATIONS ANO EXCEPTIONS OF APPENOIX A OOCUHENTS

,OOCUHENT INTERPRETATION/EXCEPTION

l. 10CFR50 Appendix 8 None

2. Reg. Guide 1.28

a. Introduction to design and construction of nuclear power plants. Guidance For operations phase QA programs will be addressed in separate regulatory guides.

/ "'l-included by reference in ANSI/ANS-3.2, which applies to operations phase QA programs. Therefore, Niagara Hohawk is committing to ANSI/ASHE NQA-1 for operations phase activities.

b. Para. 3.l.l.a f organization's QA Program should be audited at least annually ...

~Exec tion goring the operations phase, applicable elements of the QA program will be audited at least once every two years, in accordance with ANSI/ANS-3.2.

c. Para. 3.1.1.b the applicant or licensee may determine ...

that external audits are not necessary ...

~Exce tion In addition to the exemptions provided, NHPC considers that Authorized Inspection Agencies, National Bureau of Standards, and. other state or federal agencies that provide services to NHPC are not required to be audited.

3. ANSI/ANS-3.2

a. General M'"

referenced ll-->>

throughout ANSI/ANS-3.2.

~Exec tion NMPC is conmitted to ANSI/ASME NQA-1-1983 including 1983 addenda.

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3. ANSI/ANS-3.2 (Cont'd)

b. General N45.2.2-1978 and N45.2.8-1975 are referenced in ANSI/ANS-3.2.

tion i<<hi

~Exec NHPC is comnitted to ANSI/ASHE NgA-2-1983 for major modifications.

c. Para. 3.4.2 i h requirements for the qual i f i cati ons of the Onsite Operations organization.

O~ h i h i i hi paragraph is covered in section 6 of each station's Technical Specification.

d. Para. 4.0 h requirements for reviews and audits.

h paragraphs are covered in Section 6 of each station's Technical Specification and Section 18.0 of this Topical Report.

e. Section 5 General section to Appendix for typical activities which should be covered by written procedures.

which require written procedures are covered in Section 6 of each station's Technical Specification.

f. Para. 5.2.1.6 for the maximum number of hours at a duty station.

the Technical Specifications, Section 6.

g. Para. 5.2.2 h specify approvals for temporary procedure changes.

approval of temporary changes are covered in Section 6 of each station's Technical Specification.

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3. ANSI/ANS-3.2 (Cont'd)

h. Para. 5.2.7 use of ANSI/IEEE-336-1980.

hh Report commits to ANSI/IEEE-336-1971.

i. Para. 5.2.8 inspection program ... shall include the establishment of a master surveillance schedule reflecting the status of all planned inplant surveillance tests and inspections.

I schedules may exist for different programs such as in-service inspection ( ISI), pump and valve testing, and Technical Specification surveillance testing.

addressed in the Technical Specifications, Section 4.

j. Para. 5.2.9 to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.

d i the Security Plan.

k. Para. 5.2.13.2 regulation or contract requirements, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.

required documentary evidence be available at the site prior to use, but not necessarily prior to installation. This allows installation to proceed under specified conditions while any missing documents are being obtained, but precludes dependence on the item for safety purposes.

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NMPC-QATR-1 Rev. 0 1 3. ANSI/ANS-3.2 (Cont'd)

l. Para. 5.2.15 hi 1 <<1ih administrative control s for the review, approval and control of procedures.

I i <<F paragraph are covered in Section 6 of each station's Technical Specification.

m. Para. 5.2.16 equipment suitably marked to indicate calibration status.

~Exec tion In some instances size or locations of installed plant instrumentation precludes attaching calibration labels directly on the instrument. In such cases, the label may be placed adjacent to the instrument or the instrument shall be uniquely identified and traceable to its calibration records. (See item 3h)

n. Para. 5.3 hi administrative controls for written procedures.

F hh paragraph are covered in Section 6 of each station's Technical Specification.

4. ANSI/ASME NQA-1

a. Supplement 2S-3 quality assurance program audits shall be qualified in accordance with ANSI/ASME NQA-1 supplement 2S-3.

~Exce tion Personnel who perform audits for the Safety Review and Audit Board (SRAB) are not required to be so qualified.

b. Supplement 4S-1 Section 3 documents) shall be performed and documented ... prior to contract award.

~Exce tion Ilocuments may be released for bid or contract award before completing the necessary reviews. However, these reviews are completed before the item or service is relied on for its safety-related function, or before work has progressed to the point where it would be impractical to reverse the action taken.

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4. ANSI/ASME NQA-1 (Cont'd)

c. Supplement 7S-1 Para. 8.1 regulation or contract requirement, documentary evidence that items conform to procurement document requirements shall be available at the nuclear facility site prior to installation or use.

h h required documentary evidence be available at the site prior to use, but not necessarily prior to installation. This allows installation to proceed under specified conditions while any missing documents are being obtained, but precludes dependence on the item for safety purposes.

d. Supplement 7S-1 Para. 8.2.4 requirements shall be mutually established by the purchaser and supplier.

responsibility for its QA program, NMPC establishes post-installation test requirements, giving due consideration to supplier recommendations.

5. ANSI/ASME NQA-2

a. General Applicable parts of this standard will be applied to activities related directly to major plant modifications only (i.e. those under the direction of Nuclear Engineering).

b. Part 2.15 N requirements for hoisting, rigging and transportation of items for nuclear power plants.

~Exec tion NNPC is comnitted to the requirements of applicable heavy load reports for Nine Mile Point Units 1 and 2.

6. ANSI N45.2.4/IEEE-336 Applicable parts of this standard will be applied to activities related directly to major plant modifications only (i.e. those under the direction of Nuclear Engineering).

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