ML17055E537

QA Program Topical Rept for Nine Mile Point Nuclear Station Operations.

ML17055E537
Person / Time
Site:	Nine Mile Point
Issue date:	12/31/1988
From:	Palmer D NIAGARA MOHAWK POWER CORP.
To:
Shared Package
ML17055E538	List: ML17055E537 ML18038A451
References
NMPC-QATR-1, NUDOCS 8903020488
Download: ML17055E537 (90)

Text

%PCS%-1 KHQN 4 QUALITY ASSURANCE PROGRAM TOPICAL REPORT FOR NINE MILE POINT NUCLEAR STATION OPERATIONS THIS DOCUMENT IS THE PROPERlY OF NIAGARA MOHAWK POWER CORPORATION AND SHALL BE RETURNED TO THE QUALflY ASSURANCE DEPARIMENT UPON WRIlTEN REQUEST ISSUED TO: COPY No.:

U.S. NRC 20 Document Control Desk Washington, DC 20555 Niagara Mohawk Power Corporatfon Syracuse, New York 85'03020488 890222 PbR ADOCK 05000220 P PDC

NIAGARA MOHAWK POWER CORPORATION QUALITY ASSURANCE PROGRAM TOPICAL REPORT NINE MILE POINT NUCLEAR STATION UNITS 1 AND 2 OPERATIONS PHASE 0

Revision 4 of this document, is a general update and clarification, including changes requested by corporate organizations since the issue of Revision 3. There are no basic changes in the Quality Assurance Program.

Organization changes reflecting the addition of the Executive Vice President have been incorporated as well as general descriptions of the responsibilities of the Vice President of Nuclear Engineering and Licensing.

Other changes are additions of the Manager Nuclear Division Projects, Manager Nuclear Services, Manager of Site Engineering, the Program Director of Nuclear Materials Management, Fuel Supply Director, Director of Regulatory Compliance, and the Manager of Special Projects, and their organizations. Clarification in job descriptions of the Quality Assurance Organization and the new position of NDE Supervisor are included.

Editorial changes were made where necessary.

Approved:

Vice President Quality Assurance Concurrence:

Executive Vice President Nuclear Senator Vice President egional Senio Vice resi ent Technical Services

l I I NMPC-QATR-1 Page Rev.

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TABLE 'OF CONTENTS SECTION PAGES INTRODUCTION QUALITY ASSURANCE POLICY 1.0 Organization 1-1 1-13 2.0 Quality Assurance Program 2-1 2-6 3.0 Design Control 3-1 3-3 4.0 Procurement Docum nt Control 4-1 4-2 5.0 Instructions, Procedures and Drawings 5-1 6.0 Document Control 6-1 6-2 7.0 Control of Purchased Material, Equipment 7-1 7-3 and Services 8.0 Identification and Control of Materials, 8-1 Parts and Components 9.0 Control of Special Processes 9-1 9-3 10.0 Inspection 10-1 10-3 11.0 Test Control 11-1 11-2 12.0 Control of Measuring and Test Equipment 12-1 12-2 13.0 Handling, Storage and Shipping 13-1 14.0 Inspection, Test and Operating Status 14-1'5-1 15.0 Nonconforming Materials, - 15-2 Parts or Components 16.0 Corrective Action 16-1 17.0 Quality Assurance Records 17-1 17-2 18.0 Audits 18-1 18-2 Appendix A Regulatory Commitments A-1 A-2 Appendix B Interpretations and Exceptions B-1 B-10 of Appendix A Documents Appendix C Matrix of 10CFR50 Appendix B C-1 Criteria vs. NMPC QATR-1 and QA Procedures

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NMPC-QATR-1 Page Rev.

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QUALITY ASSURANCE PROGRAM TOPICAL REPORT NINE MILE POINT NUCLEAR STATION UNITS 1 AND 2 OPERATIONS PHASE INTRODUCTION 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 Mohawk 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 modification 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.

In the event of a conflict between non-QA programmatic controls contained in this QA Program Topical Report and related commitments contained in Nine Mile Point Units 1 and 2 FSAR's, the latter shall take precedence.

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

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t)UALITY ASSURANCE POLICY Quality Assurance Po1icy 7. 1. 11 emgs L of pURpOSE: The purpose of this policy is to summarize the Company's position governing Quality Assurance responsibilities and accountabilities.

pOI,'ICY: The Company policy regarding Quality Assurance matters is that:

l. Organizations with quality-affecting responsibilities shall be structured, managed and operated in compliance with approved Quality Assurance Programs, procedures and instructions in direct support of generation, transmission and distribution projects and operations to achieve the following objectives:

To strive to perform assigned work correctly the first time.

To provide facilities which are designed, constructed, tested and operated to high standards of ezcellence, with high assurance against failure or malfunctions, aad without undue risks to the health and safety of the public.

To ensure early and timely identification and resolution oC actual and potential problem areas in design, procuremeat, construction, testing, operations, maintenance and modification of facilities.

To comply effectively with government regulations and established NMPC policies and procedures, applying a systematic, disciplined and uniformed approach to Quali ty Assurance.

2. Accountability for the quality of generation, transmission and distribution structures, systems, components and services rests with the organizations and persons performing the quality attaining functions of design, construction and operation.

3. Accountability for determining that the generation, transmission and distribution structures, systems, components and services do, in tact, meet the stated requirements rests with the organizations and persons performing quality verification functions, such as design revie~,

document review, inspection. surveillance and audits, AUTHORIZED:

ign ur Department at APPROVED: 4 rP Pres) dent

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NMPC-QATR-1 Page 1-1 Rev. 4 1.0 G NjZ 0 1.1 ~O~C 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, NMPC retains overall responsibility.

This section of the Quality Assurance Program Topical Report identifies the NMPC 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, and including Nuclear Operations, Nuclear Engineering Licensing, Purchasing, Materials Management, Meter and Test, Meter and Laboratory Facilities, Nuclear Security, Fuel Supply, 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 various organizational units as wellAssurance as the Quality Assurance Department. The Quality 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 The solutions; and verify implementation of solutions. size of the QA Department is determined by the scope of operations activities and their importance to safety.

NMPC-QATR-3 Page 1-2 Rev. 4 1.2 IMPLEMENTATION 1.2.1 Res onsibilit and Authorit The President of Nia ara Mohawk 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 Corporate Officers, as described herein.

The NMPC organization is shown in Figure 1-1.

Departmental responsibilities are summarized in the Responsibility Matrix, Figure 1-2.

1.2.2 Nuclea Divis'on Res onsibilities I. The Executive Vice esident Nuclea 0 erations reports to the President and is responsible for the overall management of engineering, licensing, operation, maintenance and modification of the Nine Mile Point Nuclear Station.

A. The General Su e intendent Nuclear Generation reports to the Executive Vice President Nuclear 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.

NMPC-QATR-1 Page 1-3 Rev. 4

1. The tat'o Su e report to the General

'e e 't and 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 operating procedures;

d. Maintaining equipment status control;

e. Performing startup and operational testing; and

f. Processing, packaging and disposal of radioactive waste.

2. The u e reports to the General t 'e ce uc e Superintendent Nuclear Generation and is responsible for:

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

b. Supervising the maintenance 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;

f. 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.

h. Instrument and control function calibration and maintenance.

NMPC-QATR-1 Page 1-4 Rev. 4

3. The to the General e

Superintendent t e

- Nuclear reports Generation and is responsible for:

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

b. Operation and maintenance of computer-related services;

c. Technical support services;

d. Fire protection;

e. Surveillance planning and scheduling.

4. The KUIRSESL Superintendent -'uclear Generation and is xesponsible for managing and coordinating programs in the areas of Radiation Protection, Radiological Services and Chemistry.

a e otect'o reports to the Superintendent of Chemistry and Radiation Management and is responsible for radiation protection.

b. The 'o '

to the Superintendent of Chemistry and t reports Radiation Management and directs and coordinates the activities of the radiological support staff providing Technical guidance in the areas of industrial hygiene, respiratory protection, internal and external dosimetry, radiation records and ALARA.

c. The v' 0 Chemistry and Radiation Management and is responsible for monitoring and recommending control action on primary and secondary system chemistry, radioactivity measurements, radioactive gasses and liquid effluents and solid radioactive waste measurement. This includes the preparation, review and approval of procedures for these activities.

NMPC-QATR-1 Page 1-5 Rev. 4

5. The e Co reports to the General Superintendent Nuclear Generation and is responsible to direct and monitor site activities to assure that NRC concerns, commitments and requests are promptly resolved and that the plants are operated in accordance with the License.

B. The V' c Nuclear 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 c a 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 & 2, including adherence to applicable regulatory requirements. Responsibilities include:

a. Engineering services;

b. Modification design and management; c Preparing purchase requisitions; and

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

e. Nonconformance dispositions.

2. The reports to the Vice President Nuclear Engineering and Licensing and is responsible for licensing activities for Nine Mile 1 and Nine Mile 2.

3. The reports to the Vice President Nuclear Engineering and Licensing and is responsible for managing the provision of full time Nuclear Engineering and Licensing Department activities conducted on site. Specific areas of responsibility include:

NMPC-QATR-1'age 1-6 Rev.'4

a. In-Service Inspection/Testing;

b. Material Engineering;

c. Design Engineering;

d. Technical Evaluation;

4. The c ea o reports to the Vice President Nuclear Engineering and Licensing and is responsible for managing and directing activities associated with nuclear fuel management, plant performance improvement, corporate health physics and consulting services.

5. The Co reports to the Vice President Nuclear Engineering and Licensing and is responsible

c for verifying that Nuclear Operations Division commitments are accurately stated and accom-plished within the committed time period.

6. The e reports to the Vice President Nuclear Engineering and Licensing and is responsible for providing administrative and technical services to the Nuclear Engineering and Licensing Department including:

a. Document Control;

b. Procedure development;

c. Non-Process computer administration; and

d. Controlled file maintenance

7. The e t reports to the Vice President Nuclear Engineering and Licensing and is responsible to provide Senior Management attention on selected critical tasks.

C. The e e c ea reports to the Executive Vice President Nuclear, serves as his principal advisor, performs duties assigned by the Executive Vice President Nuclear.

D. The c e Sec 't reports to the Executive Vice President Nuclear and has overall responsibility for Nuclear Security at Nine Mile Point Unit 1 and 2. Reporting to the Manager'f Nuclear Security are managers of Nuclear Security Administration, Nuclear Security Projects and Services, Nuclear Security Operations and the Director of Nuclear Security Compliance.

NMPC-QATR-1 Page 1-7 Rev. 4 E,. The e 'v's'o 'e reports to the Executive Vice President Nuclear and is responsible for outage planning; audits conducted by outside agencies; and development of reports of operations for management review.

The uc e 'ts reports to Manager Nuclear Division Projects and is responsible for management and coordination of INPO and PSC audits of the Nuclear Division, rate case efforts, preparation and issuance of Nuclear Division reports, policies and goals and division liaisons with corporate and outside agencies. This includes responsibility for coordination, planning and maintenance of Division manpower, staffing plans, personnel development and personnel records.

2 The u e t t reports to Manager Nuclear Division Projects and is

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responsible for planning, analyzing, evaluating, and controlling the cost of projects from conception to completion, establishing and controlling Nuclear Capital and Expense budgets. This includes estimating, monitoring, controlling project costs and providing status reports to senior management of the Nuclear Division.

3 The 'e t 0 t reports to the Manager-Nuclear Division Projects and is

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'd responsible for overseeing outage management activities for both units. This includes development of outage control plans, integrated schedules, and execution of approved schedules.

4 ~ The e e reports to the Manager Nuclear Division Projects and is responsible for development of project report schedules, engineering preoutage and outage schedules (including modifications);

monitors project manpower, performance measurement systems, and equipment delivery status. This includes responsibility for coordination of outage and project schedules with site organizations and the long range planning program for the Nuclear Division.

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NMPC-QATR-1'age 1-8 Rev. 4 e Se 'eports to the Executive Vice President Nuclear. This position manages the Nuclear Division activities in the areas of Training, Environmental Protection and Emergency Preparedness. Also, the site Administrative Services which include Records Management, the e '

t Manager Nuclear ats Office Administration Services.

and is responsible for Office Administration, Facilities.

reports to This position Procedure Services, general administrative support, and Records Management Services and Site Document Control. Additional responsibilities include payroll, facilities, telephone, wordprocessing hardware and software, Site Technical Library and Nuclear .

Plant Reliability Data Systems (NPRDS) data entry and retrieval.

2. e t a' ea reports to the Manager Nuclear Services. This position is responsible for the administration and coordination of all nuclear training and retraining programs for all nuclear personnel as well as contracted and non-nuclear support agency personnel. In addition, this position also has prime responsibility for the use and operation of the Unit I and Unit II simulators for operator training.

3 ~ e - S't e ta ct'eports to the Manager Nuclear Services. This position is responsible for administering the Nine Mile Point Nuclear Site Environmental Protection Program to insure regulatory compliance and to minimize'he effect of 4 ~ a 'e effluent release on the environment.

ann'eports to the Manager Nuclear Services. This position is responsible for managing the Emergency Preparedness Program in accordance with local state and federal government and Niagara Mohawk regulatory requirements. Additionally responsible to initiate training and drills for site and corporate staff and coordinate emergency exercises with governmental agencies.

NMPC-QATR-1 Page 1-9 Rev. 4 1 '.3 u t t t e o A. The V' t-Technical Services 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 e S te 'eports Vice President Purchasing and Materials to the Management. The staff includes the 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 Department representative.

2. The ect te Purchasing and Materials Management. Included on the staff and reporting to the Program Director Nuclear through the Manager Nuclear Generation Materials Management, is the Supervisor Materials Requirement Planning (MRP) and the Supervisor Nuclear Generation Storeroom. This organization is responsible for reviews of requests for materials and equipment, preparing purchase requisitions, and the receipt, storage and distribution of materials and equipment. The MRP and warehouse operations are operated in accordance with Nuclear Materials Management procedures, which are in concert with Nine Mile Point Nuclear Station Administrative Procedures and Station Orders.

B. The ct reports to the Senior Vice President Technical Services. The Manager Fuel Procurement and Contract Administration and The Manager Fuel Supply Analysis and Management are responsible for procurement of Nuclear Fuels and the administration of Nuclear Fuel contracts.

NMPC-QATR-1 1-10 V't-Page Rev. 4 C. The t'o C t reports to the Senior Vice President - Regional 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 G C reports to the Vice President Regional Operations Central. 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.

D. The V'

' t 0 t'o reports to the Senior Vice President. Regional and is responsible for formulating, establishing and enforcing off-site Meter and Laboratory Facilities Department activities. See Figure 1-2 for primary and supporting quality assurance program element responsibilities.

1. The to the Vice President System Electric

't'eports Operations. The staff includes Supervisor Standards Laboratory who is responsible for maintaining a facility for calibrating reference standards and for calibration and maintenance of portable measuring and testing equipment (M&TE).

E. The reports to the Senior Vice President Technical Services and has responsibility for formulating, establishing and enforcing policies and procedures for the Nuclear Construction Services unit of the Construction Services Department.

NMPC-QATR-1 Page 1-11 Rev. 4

1. The t I reports to the Manager Construction Services, who reports to the Vice President Engineering, and supports Nuclear Generation with supervision and control of construction contractors as well as Niagara Mohawk construction forces when required at Nine Mile Point Nuclear Station. Responsibilities associated with provision of this support include coordination with plant, engineering and quality assurance organizations, schedule performance, cost performance, administrative procedures and adherence to contractual requirements.

A. The ' 'eports the President and is responsible for formulating, to directing, implementing and controlling policies and procedures related to verifying the overall quality of design, construction, operation, maintenance and modification activities at Nine Mile Point Nuclear Station. The Vice President'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, waste handling, installation, inspection, test, operation, modification, repair and maintenance of (l) safety-related systems, structures, components and services; (2) fire protection systems and (3) radwaste systems;

2. Recommending to appropriate management courses of corrective action, when required, including initiation of stop work orders. This "stop work" authority is delineated in writing;

NMPC-QATR-1.

Page 1-12 Rev. 4

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

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

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

6. Providing for timely identification and correct've action of conditions adverse to quality; and

7. Resolving with other levels of management any escalated disputes involving quality, arising from a difference of opinion between QA personnel and other department personnel.

B. The Mana e ualit First Pro ra reports to the Vice President Quality Assurance and has the responsibility to direct and monitor the Quality First Program (Q1P) including confidential investigations of quality concerns relating to Nine Mile Point Nuclear facilities and performing special assignments for the Vice President Quality Assurance.

C. The Mana er Nuclear ualit Assurance 0 erations reports to the Vice President Quality Assurance and exercises control and direction of the Nuclear Quality Assurance Program.

Responsibilities include:

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

2. Advising the Vice President Quality Assurance, Manager Corporate QA, and Manager Quality and Reliability Engineering of nuclear quality activities;

NMPC-QATR-1 Page 1-13 Rev. 4

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;

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

is delineated in writing;

6. Directing the QA Program Manager in the following activities:

a. Developing QA project budgets/decisions on QA involvement on specific projects (plant outage modifications)

b. Utilizing matrix management concept to secure:

Engineering QA functions Procurement QA functions Installations QA functions

c. Establishing QA project schedules and interfaces

d. Monitoring assigned projects and issuing status reports

e. Coordinating project QA problem resolution

f. Coordinating QA closeout of projects

g. Site Operations Review Committee Quality Assurance Representation/Operations Experience Assessment

h. Review of NRC Correspondence;

i. Site ALARA Committee Representative

j. Special assignments as directed by the Manager NQA Operations

k. Coordinating NQAO consulting services

7. Directing the Quality Engineering/Control Supervisor in the following activities:

o Quality Engineering

a. Corrective action trending

b. CAR Coordination

c. Internal/external reporting

d. Training Coordination

NMPC-QATR-1'age 1-14 Rev. 4 T

e. Site quality engineering in Mechanical, Electrical and I&C disciplines to perform:

- Procedure reviews Procurement document reviews (site generated)

- Modification support Deficiency document disposition acceptance Modification package record review/acceptance/close out

f. Inspection planning for maintenance/material control activities accomplished by site NMPC personnel and modifications installed by site NMPC maintenance personnel.

g. Work request package closeout

h. Management of QC associated with selected outage work

i. Responsibility for reviewing welding procedures internal and external to NMPC.

0 Quality Control

a. Receipt, in-process, and final inspection

b. Maintenance support

c. Assisting in/source inspection

d. Training/certifying inspectors

e. Inspection services contract input

f. Work request initial review;

8. Directing the Operations Surveillance Supervisor in the following QA Surveillance areas:

a Surveillance Testing and Operations Activity

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b. Refueling c Chemistry

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'd 0 Radiation protection

e. Training

f. Emergency preparedness gi Fire Protection

h. Environmental Control

3. ~ Radioactive waste shipment Electrical/Mechanical and I&C Maintenance

k. Materials Management

l. Security I&C m Modification, Installation/Testing and Welding activities; and

n. IST & ISI 0~ Meter & Test p ~ Testing

q. General Surveillance

NMPC-QATR-1 Page 1-15 Rev. 4

9. Directing the NDE Supervisor in the following activities:

a. Schedule coordination for NDE examinations

b. Administer ISI inspection contractors

c. Direct NDE personnel

d. Control and management of NDE equipment

e. ANII Interface

f. NDE procedure development and qualification

g. Reviewing NDE procedures internal and external to NMPC

h. Preparation, processing and disposition of ISI NDE data

i. Performance of NDE required by codes and standards

10. Assuring the representatives of the Nuclear Quality Assurance Operations organization on-site routinely attend and participate in work schedule and status meetings to keep abreast of day-to-day work assignments throughout the station and to adequately cover and carry out QA assignments.

D. The Mana er Co o ate ualit Assurance reports to the Vice President 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 Vice President Quality Manager - Quality & Reliability

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Assurance, Engineering, Manager Quality First 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. This "stop work" authority is delineated in writing.

5. Directing the QA Audits Supervisor and QA Services Supervisor in the performance of their responsibilities.

NMPC-QATR-1 Page 1-16 Rev.4 E. The Mana er ualit & Reliabilit En ineerin reports to the Vice President 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 supporting QA aspects of Modification implementation during plant shutdowns; (This includes Quality input to Installation/Inspection plans controlled by Nuclear Engineering).

2 ~ Providing for control of purchased equipment through the contractor qualification program, source surveillance and the preparation of receiving inspection planning (for implementation by Nuclear QA Operations personnel); and procurement docum'ent review (non-site generated);

3 ~ Providing materials engineering support in the areas of material selection, welding, corrosion prevention, non-destructive examination, and fuels quality assurance; 4 ~ Advising the Vice President Quality Assurance, Manager-Nuclear QA Operations, Manager-Non-Nuclear QA Operations and Manager Corporate QA of nuclear quality activities;

5. Provide reliability engineering services to support the Engineering Department in equipment qualification; performance of studies on equipment life extension; implementing the reliability program for Nine Mile Point;

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. This "stop work" authority is delineated in writing.

NMPC-QATR-1 Page 1-17 Rev. 4 F. e 'upervise Quality Assurance Department staff. Supervisory the 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 examinations, inspections, audits and surveillances to verify quality assurance program implementation within NMPC and by outside suppliers and contractors;

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

5. Recommending "stop work" action when appropriate. This authority is delineated in writing;

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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0 NMPC-QATR-1 Page 1-19 Rev.4 QUALITY ASSURANCE PROGRAM RESPONSIBILITY MATRIX REGULATORY U S N S-, S S I. Organization 1/ 1-S1 1 P P P P P P P P P 3.1 3.3 3.4.2 II. QA Progran 21 2S-1 3.1 S S S S S S P/R S S 2S-2 3.3 2S-3 5.1 5.3 3.4.2 3.5 III. Design 31 3S-1 5.2.7.2 S P S R S S IV. Procurement 4/ 4S-1 5.2.13.1 P P S P R S S V. Procedures 5 5.2.7 P P. P P P P P,R P P 5.3 VI. Doc. Control 6/ 6S-1 5.2.15 P P P P P P P,R P P VII. Purch, Items 7/ 7S-1 5.2,13.2 P P S P R P S' VIII. Iten Control 8/ 8S"1 5.2.13.3 P S R P IX. Special Proc. 9/ 9S-1 5.2.18 P P R 5.2.12 X. Inspection 101 10S-1 5.2.17 P S S S P,R P XI. Testing 111 11S-1 5.2.19 P S S S R XII. H&TE 12, 12S-1 5.2,16 P S P R P XIII. Hand. & Stg. 13/ 13S-1 5.2.13.4 P S R P XIV. Operating Status 14 5.2.6 P R 5.2.14 XV. Nonconformance 15/ 15S-1 5.2.14 P P S S R P S XVI. Corr. Action 16 5.2.11 P P S S S S P,R P S XVII. Records 17/ 17S-1 5.2.12 P P S S S S S,R P S XVIII. Audit 181 18S"1 4.5 P P NG - Nuclear Generation P - Primary Responsibility NE - Nuclear Engineering S - Support Responsibility PUR - Purchasing R - Review, Audit and Surveillance HH - Haterials Management Responsibility HT - Heter and Test HL - Heter and Laboratory Services QA

- Quality Assurance NS - Nuclear Security FS - Fuel Supply FIGURE 1-2

NMPC-QATR-1 Page 2-1 Rev. 4 2.0 UALITY ASSURANCE PROGRAM F 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 B are regularly reviewed by NMPC management through reports, meeting, review of audit results, and documented assessments performed by management teams.

2 ' IMPLEMENTATION 2.2 ' General organizational responsibilities are outlined in Section 1.0, ORGANIZATION.

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 B, states NMPC policy for each of the criteria and describes how the controls pertinent to each are carried out. See Appendix C Matrix for a listing of each of the criteria of 10CFR50 Appendix B vs. corresponding sections of this Topical Report and the related Quality Assurance Procedures. Any changes made to this Topical Report that do not reduce the commitments previously accepted by the

NMPC-QATR-1 Page 2-2 Rev. 4 Nuclear Regulatory Commission (NRC) shall be submitted to the NRC at least annually. Any changes made to this Topical Report that do reduce the commitments 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.

The Corporate Quality Assurance Policy authorized by the Vice President Quality Assurance and approve'd 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.

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

The qualification requirements for the Vice President Quality Assurance are as follows:

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

a. Fifteen (15) years of experience in technical fields 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.

NMPC-QATR-1 Page 2-3 Rev. 4 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:

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

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.

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, and are consistent with the FSAR commitments.

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.

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

a. Audits or surveillances on approximately 104 of radioactive waste shipments.

b. Annual audits of the radioactive waste handling program.

c. Inspection of radwaste shipments by Quality Control.

NMPC-QATR-1 Page 2-4 Rev. 4 Audits identified in a. and b. are performed by Quality Assurance 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. Purchasing Department Purchasing Procedures and Fuel Purchasing Procedures;

d. Materials Management Department Material 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 '0 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 B of this Topical Report.

2.2 '1 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 Nuclear Engineering Procedures for identifying structures, systems and components to which the quality assurance program applies;

NMPC-QATR-1 Page 2-5 Rev. 4

b. This identification process results in a Q-list which identifies safety-xelated items for each unit. The Q-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 oper'ation and shutdown;

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

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. Work 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 conditions or operational mode for the task;

f. Current and approved instructions, procedures, and drawings 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. Pxovisions have been made for special equipment, environmental conditions, skills, controls, processes, tests and verification methods.

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

NMPC-QATR-1 Page 2-6 Rev. 4 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, procedures, and drawings.

b. Proficiency tests a'e utilized where appropriate to determine that individuals can perform their assigned tasks;

c. Personnel who perform inspections, examination, tests, 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; and

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

The management of Niagara Mohawk Power Corporation (NMPC) at the presidential or chief executive officer level assesses the scope, status, adequacy,'nd 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 Vice President 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.

NMPC-QATR-1 Page 2-7 Rev. 4

b. The Vice President Quality Assurance regularly attends corporate staff meetings, board meetings and co-tenant 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.

The Safety Review and Audit Board (SRAB) is a standing committee chaired by the Vice President Nuclear Engineering and Licensing and reporting to the Executive Vice President Nuclear Division regarding designated quality assurance functions at the Nine Mile Point Nuclear Station. The Saftey Review and Audit Board responsibilities are defined in applicable unit Technical Specifications and FSAR.

The Site Operations Review Committee (SORC) is an independent review committee responsible to the General Superintendent, Nuclear Generation and transmits reports to the Safety Review and Audit Board. The Site Operations Review Committee responsibilities are defined in the applicable unit Technical Specifications; FSAR and Niagara Mohawk Power Corporation Administrative Procedures.

The Quality First Program (QlP) provides NMPC 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.

NMPC-QATR-1 Page 3-1 Rev. 4 3.0 3.1 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 0 2 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 ' ' Computer programs used in safety-related design and station operation are appropriately documented, verified, certified for use and controlled in accordance with procedures.

3 ' ' 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.

NMPC-QATR-1 Page 3-2 Rev. 4 Exceptions, waivers to, or deviations from engineering requirements are required by procedure and by contract, when applicable, to be documented and controlled.

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 subject to audit by the Quality Assurance Department to verify 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.

NMPC-QATR-1 .

Page 3-3 Rev. 4 Design reviews are performed by single individual or by interdisciplinary or multi-organizational groups, as appropriate. Unless otherwise stated, the verification o'f 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.

Qualification testing of prototypes, components or features is used 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. Qualification 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 shown to be necessary through testing.

if Following modification, any necessary retesting or other verification is performed. Scaling laws are established and verified, when applicable. Test configurations are documented.

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 that:

1. The supervisor did not specify a singular design approach or rule out certain design considerations, and

2. The supervisor did not establish the design inputs used in the design.

OR

1. The supervisor is the only individual in the organization competent to perform the verification, and

2. The supervisor receives written approval by the appropriate Engineering Manager.

NMPC-QATR-1 Page 3-4 Rev. 4 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.

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.

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

NMPC-QATR-z Page 4-1 Rev. 4 4.0 4.1 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 '

4 ' ' General organizational responsibilities are described in Section 1.0, ORGANIZATION.

4.2.2 Procurement 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 the 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;

r

~ ~ ~ qa NMPC-QATR-1 Page 4-2 Rev. 4

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;

g. Provisions for access to supplier and subtier suppliers'acilities and records for inspections, surveillances and audits;

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

i. of Provisions for documentation and dispositioning nonconformances.

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

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.

4.2.7 The Quality Assurance Department performs and documents reviews of procurement requisition packages to assure that:

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

NMPC-QATR-1 Page 4-3 Rev. 4

b. Acceptance and rejection criteria are included; and

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

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. 4 5.0 5.1 Activities affecting the quality of safety-related structures,'ystems, components and services are accomplished using instructions, procedures and (including vendor manuals) appropriate to'rawings the circumstances. These documents include appropriate acceptance criteria.

ANSI/ASME NQA-1 and ANSI/ANS-3.2 commitments contained in App. A of this QA Topical Report have

,been translated into procedural matrices to assure that implementing procedures cover the QA commitments.

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

5 '.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.

They provide for implementation of the requirements contained in the committed standards.

They describe responsibilities, controls and activities to be accomplished in carrying out commitments. When appropriate, they specify 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.

NMPC-QATR-r Page 6-1 Rev. 4 6.0 0 0 6.1 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 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;

NMPC-QATR-1 Page 6-2 Rev. 4

h. Unit Technical Specifications;

i. Quality Assurance Program Topical Report.

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;

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 Department;

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

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.

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 maintaining current copies of the lists.

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

NMPC-QATR-1.

Page 7-1 Rev. 4 7.0 CONTROL OF PURCHASING 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 ' 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 B and the contract and are accepted by the Quality Assurance Department.

7.2.3 NMPC qualifies suppliers (including selected suppliers of commercial grade items) by performing a documented evaluation of their capability to provide items or services specified by procurement documents. Other means of evaluating supplier qualification include objective evidence of supplier's current quality performance, surveys performed by consultants, other utilities or other organizations such as CASE or ASME survey teams.

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

NMPC-QATR-1 Page 7-2 Rev. 4

b. Adaptable to standard to 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.

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.

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; and

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

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.

NMPC-QATR-1'age 7-3 Rev. 4 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.

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

Documentation supporting the conformance of material and equipment with the procurement documents is to be available at the site prior to the 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. 4 8.0 0 0 0 8.1 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 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.

8.2 ' Items are traceable to applicable dravings, 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. 4 9.0 9.1 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 '

9 '.1 General organizational described in Section responsibilities are 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 ' ' 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 '.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.

NMPC-QATR-1 Page 9;2 Rev. 4 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 re-examination at time intervals specified by applicable codes, specifications and standards.

Unsatisfactory performance or, where applicable, failure to perform within the designated time intervals requires requalification and recertification.

For special processes that require qualified equipment, such equipment is qualified in accordance with applicable codes, standards and specifications.

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

The Quality Assurance Department 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.

NMPC specifies in procurement documents which records are to be kept by vendors and/or forwarded to NMPC. The document retention policy and requirements are stated in Section 17.

Qualifications of procedures, personnel, and equipment will be filed and reviewed periodically, and when required by governing codes or standards, the qualification 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 agnes or standards;

NMPC-QATR-1 Page 9-3 Rev. 4

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.

NMPC-QATR-1 Page 10-1 Rev. 4 10.0 10.1 Z~ZX 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 used as necessary to ensure that inspections are accomplished at the correct points in the sequence of work activities.

10.2 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.

NMPC-QATR-1 Page 10-2 Rev. 4 Training and qualification programs for personnel who perform inspection, including nondestructive examination, are established, implemented and documented'n accordance with Section 2.0. These programs meet the requirements of applicable codes and standards.

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

Hold points are designated as mandatory inspection points 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.

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.

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.

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.

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:

NMPC-QATR-1 Page 10-3 Rev. 4

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

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

Inspection records contain the following where applicable:

'a ~ Item inspected;

b. The date of the inspection;

c. Inspector or data recorder identification;

d. Type of observation;

e. Results or acceptability;

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

NMPC-QATR-1 Page 11-1 Rev. 4 11.0 CO

11. 1 ~O~C 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, startup, surveillance and post-maintenance tests. These parameters, including any prerequisites, instrumentation requirements- and environmental-conditions, are specified and met. Test results are documented and evaluated.

11 '

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 start-up tests or operations;

d. Start-up tests, including precritical, criticality, low-power and power ascension to assure tests performed after fuel loading proper and safe operation of systems and equipment;

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

f. Post Maintenance tests.

NNP C-QATR-1 Page 11-2 Rev. 4 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 data collection and storage;

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.

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

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

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 the acceptability of the results; and

f. Action taken to resolve any deviations noted.

NMPC-QATR-1 Page 12-1 Rev. 4 12.0 C

12. 1 K>~f.

Measuring and test equipment is identified, controlled, calibrated and adjusted at specified intervals to maintain accuracy within prescribed limits.

12.2 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 ' 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 ' 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.

NMPC-QATR-1 Page 12-2 Rev. 4 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. Xn such cases the basis of acceptance is documented and is authorized by responsible management personnel.

II 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.

When measuring and testing equipment used for inspection and test is found to be out of calibration, evaluations are conducted to determj.ne 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. 4 13.0 13 ~ 1 ~OLCC.

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 '

13 '.1 General organizational described in Section 1.0, responsibilities are ORGANIZATION.

13.2.2 Procedures are used to control the cleaning, handling, storage, 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 deterioration. When necessary, these procedures provide for special environments such as inert gas atmospheres, specific moisture content levels and temperature levels;

c. 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.

NMPC-QATR-1 Page 14-1 Rev. 4 14.0 0 ES T G 14.1 ~PO ~C 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 14.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

14.2.2 For modification activities, including item fabrication, construction, installation and test, procurement documents, service contracts and procedures specify the degree of control required for the indication of inspection and test status of items.

14 '.3 Application and removal of status indicators such as tags, markings, labels, etc. are controlled by procedures.

14.2.4 The sequence of inspections, tests and other operations, and changes thereto, are controlled by procedures. Changes in the approved sequence are controlled in accordance with the applicable procedures.

14.2.5 The status of inoperable systems, components, and supporting 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.

NMPC-QATR-1 Page 15-1 Rev. 4 15.0 NO C 0 CO ON NTS 15.1 ~~(~

Materials, 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 organizations are notified of nonconformances.

The term "nonconformances" as used herein refers to those items that fail to conform to specified requirem'ents, at the time of inspection or test to verify initial acceptance of the items. Items or subsequently found in a failed, malfunctioning defective condition during operation would not constitute "nonconformances", but would be considered to be other "conditions adverse to quality" and requiring control of corrective action as described in Section 16.0, Corrective Action.

15 '

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

15.2.2 ~ Nonconformances are documented on Nonconformance Reports, Surveillance Reports, and Inspection Reports, are 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. Documentation describes the nonconformance, the disposition of the non-conformance and the inspection requirements.

It also includes signature approval of the disposition;

b. The Quality Assurance Department reviews nonconformance documents to assure completeness and control over nonconforming items. In addition, QA controls, distributes and closes out nonconformance reports, inspection reports and surveillance reports;

NMPC-QATR-1 Page 15-2 Rev. 4

c. Items that have the disposition of "repair" or "use-as-is" require documentation by Nuclear 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.

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

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

The Quality Assurance Department analyzes nonconformance reports to identify quality trends.

Trend reports, which highlight significant results, are issued periodically to Senior Plant and Corporate management for review and assessment.

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

NMPC-QATR-1 Page 16-1 Rev. 4 16.0 0 C V 16 ~ 1 H)~X Program and hardware conditions adverse to quality are identified promptly and corrected as soon as:.

practical.

16.2 0 16.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

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. QA controls, distributes, verifies and closes out conditions adverse to quality that are documented on Corrective Action Requests (CARs). 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 '.4 Conditions adverse to quality are evaluated for reportability.

NMPC-QATR-1 Page 17-1 Rev. 4 17.0 17 - 1 ZQI~Y 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 17 ' ' General organizational responsibilities are described. in Section 1.0, ORGANIZATION.

17 ';2 Documents items and that furnish evidence of quality of 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;

b. Qualification of personnel, procedures and equipment;

c. Operating Logs;

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.

NMPC-QATR-1'age 17-2 Rev. 4 A document becomes a record when completed. At that time it is designated as a permanent nonpermanent record and is transmitted to file.

or Nonpermanent records have specified retention times. Permanent records are maintained for the life of the item and/or plant as appropriate.

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

Records may be original documents, legible copies, or in various microform formats.

Authorized personnel may issue corrections or supplements to records. Procedures address acceptable methods of making corrections to records.

Traceability between the record and the item or activity to which it applies is provided.

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.

NMPC-QATR-1 Page 18-1 Rev. 4 18.0, hVV:ging

18. 1 ~O~C 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. Audit results are documented and are reviewed by management. Follow-up action is taken where indicated.

18.2 18 '.1 General organizational described in Section 1.0, responsibilities are ORGANIZATION.

18 '.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 '.4 Safety Review and Audit Board audits are performed as specified in the unit Technical Specifications.

18 '.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 adversely affected; or that quality has been

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

NMPC-QATR-1 Page 18-2 Rev. 4 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 program;

b. Interface control between NMPC organizational units and between NMPC and its principal contractors;

c. Corrective action;

d. M&TE calibration;

e. Nonconformance control;

f. FSAR commitments;

g. Activities associated with computer codes; and

h. Activities associated with design verification performed by designers'mmediate supervisor.

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

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

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

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.

Management of the audited organization takes appropriate action to correct observed deficiencies and to identify the cause and prevent recurrence of any significant 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 re-audits when necessary.

NMPC-QATR-1 Rev. 4 APPENDIX A REGULATORY COMMITMENTS 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/

D

1. 10CFR50 Quality Assurance Criteria Appendix B for Nuclear Power Plants and Fuel Reprocessing Plants.

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

3. Reg. Guide 1.28 1985 Quality Assurance Program R3 Requirements (Design and Construction) (endorses ANSI/ASME NQA-1)

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

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

6. Reg. Guide 1.37 1973 RO Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants. (endorses ANSI N45.2.1) 7- ANSI N45.2.1 1973 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants A-1

NMPC-QATR-1 Rev. 4

8. IEEE 336 1971 Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations.

9. Reg. Guide 1.94 1976 R1 Quality Assurance Require-ments for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants.

(endorses ANSI N45.2.5)

10. ANSI N45.2.5 1974 Supplementary QA Require- .

ments for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction'hase of Nuclear Power Plants.

NMPC-QATR-1 Rev. 4 APPENDIX B ON 0

0 E C 0

1. 10CFR50 Appendix B None

2. Reg. Guide 1.28

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

NQA-1 is included

/

by reference in ANSI/ANS-3.2, which applies to operations phase QA programs.

Therefore, Niagara Mohawk is committing to ANSI/ASME NQA-1 for operations phase activities.

b. Para. 3.1 elements of an organization's QA Program should be audited at least annually...

E 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. Section B Para. 8 states in part "Personnel performing inspection and testing that are qualified to the guidance contained in Reg. Guide 1.8 need not be qualified in accordance with the requirements of NQA-l.

not the intent that such It is personnel be qualified in accordance with both Reg.

Guide 1.8 and NQA-l".

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NMPC-QATR-1 Rev. 4

2. c. Section B. (Cont.)

committed to ANS 3.2, which references ANS 3.1 for certification and qualifications of operating plant personnel. Consistent with the guidance provided in Reg. Guide 1.28 personnel performing inspection and test, who are qualified in accordance with requirements of ANS 3.1, need not be qualified in accordance with NQA-l.

3. ANSI/ANS-3. 2

a. General IZQRSllt NQA-1-1979

/

is referenced throughout ANSI/ANS-3.2.

referenced standard NMPC is committed to ANSI/ASME NQA-1-1983 including 1983 addenda.

B-1

e. Section 5 General made within this section to the ANSI/ANS-3.2 Appendix for typical activities which.

should be covered by written procedures.

e t t' In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Unit. 1 and 2 FSARs and the related technical specifications.

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

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NMPC-QATR-1 Rev. 4

f. Para. 5.2.1.6 these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

g. Para. 5.2.2 BI1ZKSl paragraph specify approvals for temporary procedure changes.

these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

h. Para. 5.2.7 E requires the use of ANSI/IEEE 336-1980-the referenced standard Appendix A of this Topical Report commits to IEEE 336-1971.

i. Para. 5.2.7 /

references ANSI N45.2.5-1978 concerning design and construction activities associated with modifications.

referenced standard NMPC is committed to ANSI N45.2.5-1974 (see Appendix A item 10).

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NMPC-QATR-1 Rev. 4

j. Para. 5.2.7 refers to ANSI N45.2.8-1975.

reference standard NMPC is committed to ANSI/ASME NQA-2-1983 part 2.8 for nuclear safety related permanent plant modifications and maintenance activities.

k. Para. 5.2.7 8 refers to ANSI/ASME D3843-80.

referenced standard NMPC will comply with the protective coating controls described in applicable sections of the Nine Mile Point Units 1 and 2 FSARs.

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

t t' Independent master schedules may exist for different programs such as in-service inspection (ISI),

pump and valve testing, and Technical Specification surveillance testing.

these controls, NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

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NMPC-QATR-1 Rev. 4

m. Para. 5.2.9 8 be developed to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.

addressed in the Security Plan.

n. Para. 5.2.13.2 8 by law, 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.

t that t t'o the required NMPC requires 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.

o. Para. 5.2.13.4 Irefers to ANSI/ASME N45.2.2-1978.

Ireferenced standard NMPC is committed to ANSI/ASME NQA-2-1983 part 2.2 for nuclear safety related permanent plant modifications and maintenance activities.

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NMPC-QATR-1 ~

Rev. 4

p. Para. 5.2.15 establishes administrative controls for the review, approval and control of procedures.

these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

q. Para. 5.2.16 Records shall be made and equipment suitably marked to indicate calibration status.

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 also items 3h and 3r).

r. Para. 5.2.16 This paragraph references ANSI/IEEE 336-1980.

the t '

referenced In lieu of standard NMPC commits to IEEE 336-1971.

(See Appendix A, item 8).

s. Para. 5.3 8 establishes administrative controls for written procedures.

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NMPC-QATR-1 Rev. 4

s. Para. 5.3 (Cont.)

these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

t. Para. 5.3.9.3 ESLJI suggests ANSI/ANS 3.7.1-1979, ANSI/ANS 3.7.2 and ANSI/ANS 3.7.3-1979 for additional guidance in preparation of Emergency Plan Implementing Procedures.

ANSI/ANS 3.7.1, .2 and .3 described in ANSI/ANS 3.2, NMPC will comply with the emergency preparedness controls described in applicable sections of the Nine Mile Point Units 1 and 2 FSARs.

4. ANSI/ASME NQA-1

a. Supplement 2S-1 provides requirements for the qualification of personnel performing inspection and test.

te t '

Consistent with guidance founded in Regulatory Guide 1.28, personnel qualified in accordance with requirements of ANS 3.l need not be qualified in accordance with NQA-l.

b. Supplement 2S-2 Society of Nondestructive Testing Recommended Practice No. SNT-TC-1A, June 1975 Edition and its applicable supplements shall apply as requirements to NDE personnel covered by this Supplement.

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NMPC-QATR-1 Rev. 4

b. Supplement 2S-2 Ireferenced standard NMPC is committed to ASNT Recommended Practice No. SNT-TC-1A, June 1980 and its applicable supplements.

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

Iperform audits for the Safety Review and Audit Board (SRAB) are not required to be so qualified, since these audits are outside the scope of the audit. program described in section 18 of this Topical Report.

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

t t NMPC requires that the 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. 4

d. Supplement 7S-1 Para. 8.2.4 UILXRLCL.

...post-installation test requirements shall be mutually established by the purchaser and supplier.

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

e. Supplement 17S-1 Para. 4.4.2 1 are acceptable alternatives to the criteria of 4.4.1 above for a single facility (b) 2 hr. fire rated class B file containers meeting the requirements of NFPA 232-1975; rated file containers may be used for intermediate storage of QA records from the time of completion of the record until the time such record is processed into the permanent plant file.

5. ANSI/ASME NQA-2

a. General Applicable parts of this standard vill be applied to nuclear safety related activities pertaining directly to permanent plant modifications only, except for items 3. o. and 3. j. of this Appendix B.

b. Part 2.1 8 gives QA requirements for cleaning of fluid systems and associated components.

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NMPC-QATR-1'ev.

4

b. Part 2.1 Ireferenced NQA-2 Section, NMPC is committed to Reg. Guide 1.37 (see Appendix A item 6).

c. Part 2.5 gives QA requirements for installation, inspection and testing of structural concrete, structural steel, soils and foundations.

referenced NQA-2 section, NMPC is committed to Reg. Guide 1.94 (see Appendix A item 9).

d. Part 2.15 E gives QA requirements for hoisting, rigging and transportation of items for nuclear power plants.

referenced NQA-2 section, NMPC is committed to the requirements of applicable heavy load reports for Nine Mile Point Units 1 and 2 that have been approved by the NRC.

Unit 2's reports are a part of the FSAR (Question and Answer section). Unit 1's are a separate report.

e. Part 2.20 outlines QA requirements for subsurface investigations for nuclear power plants.

referenced NQA-2 section, NMPC will comply with the subsurface controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs.

NMPC-QATR-1 Rev. 4

6. Reg. Guide 1.37

a. General Applicable parts of this Reg.

Guide will be applied to nuclear safety-related activities pertaining to major plant modifications and maintenance within the scope of paragraph 5.2.10 of ANSI/ANS 3.2-82 only (i.e.,

those under the direction of Nuclear Engineering).

b. Para. C.3 Iquality for final flushes...

...shall be at least equivalent to the quality of the operating system water.

to the stated requirement except for the oxygen content.

c. Para. C.4 gives precautions on chemical compounds that could contribute to intergranular cracking or stress corrosion cracking in austenitic stainless steel and nickel based alloys.

XSRIIUaa-materials, i.e., inks and related products, temperature indicating sticks, tapes, gummed labels, wrapping materials (other than polyethylene), water soluble dam materials, lubricants, NDT penetrant materials, and couplants that contact stainless steel or nickel alloy surfaces are in accordance with the Nine Mile Point Unit 2 FSAR position for Regulatory Guide 1.38, Revision 2.

NMPC-QATR-1'ev.

4

7. ANSI N45.2.1-1973

a. Section 3.1.2 E gives the requirements for Class B cleanness.

systems and components constructed of carbon steel materials will meet Class B cleanness requirements except for final flushing/ cleaning which may exhibit rust staining in accordance with Class C cleanness requirements.

b. Section 3.2 S gives water quality requirements for cleaning.

conditions, freshwater from Lake Ontario will have an allowable upper pH limit of 8.5.

8. IEEE-336 Applicable parts of this standard will be applied to activities as stated in ANSI/ANS-3.2 paragraphs 5.2.7 and 5.2.16 (see item 3h and 3r of this appendix).

9. Reg. Guide 1.94 No exceptions

10. ANSI N45.2.5-1974

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

NMPC-QATR-1 Rev. 4

b. Para. 5.3 gives the requirements for assembly and erection.

F generally will not be burned (oxygen cut). If holes must following be burned, the criteria will be followed: a) after cutting, the edges of the cut will be ground or reamed back a minimum of 1/32 in., and b) the final bolt hole dimensions will not exceed those given in the Specification for Structural Joints Using ASTM A325 or A490 bolts.

c. Para. 5.4 Iestablishes the criterion for determining correct bolt length as at least two threads extending beyond the face of the nut.

E criterion established bolt length is for'orrect one thread extending beyond the face of the nut.

d. Para. 5.5 R gives requirements for welding inspection.

bar splices made by arc welding, except those splices welded to metal embedments, will be selected on a random basis for radiography and inspected in accordance with AWS D12.1. Splices welded to metal embedments will be inspected in accordance with AWS D12.1.

~o NMPC-QATR-1" Rev. 4

e. Para. 6.2.2 8 gives the requirements for evaluating mechanical (Cadweld) splice test results.

Ulaltloa-regarding mechanical splicing of safety-related reinforcing bars are in accordance with the Nine Mile Point Unit 2 FSAR position for Regulatory Guide 1.10. (Superseded by Reg. Guide 1.136.)

B-14

NMPC-QATR-1 Rev. 4 APPENDIX C MATRIX OF 10CFR50 APPENDIX B CRITERIA VS. NMPC QATR-1 AND QA PROCEDURES NMPC QA PROGRAM TOPICAL NMPC QA 10CFR50, APPENDIX B REPORT PROCEDURES BY QA CRITERIA SECTION NUMBERS I Organization QAP 1.01 II QA Program QAP 1 '3/ QAP 2 '1/

QAP 2 ~ 02 / QAP 2 ~ 10 QAP 2 30 / QAP 2 ~ 60 III Design Control QAP 6.20 IV Procurement Document QAP 4.01, QAP 4.10 Control V Instructions, Procedures QAP 5 ~ 01 / QAP 5 ~ 02 and Drawings VI Document Control QAP 6.01, QAP 6.20 VII Control of Purchased QAP 7 ~ 20 / QAP 7 ~ 30 Material QAP 7.22 VIII Identification and QAP 4-10/

10.03, Control of Materials QAP and Parts QAP 10.30 IX Control of Special QAP 9.01 Processes X Inspection 10 QAP 10.03/

QAP 10.30 XI Test Control QAP 10.03/

QAP 10.30 XII Calibration of Equipment QAP 12.10 XIII Handling, Storage 13 QAP 10.03, and Shipping QAP 10.30 C-1

NMPC-QATR-1" Rev. 4 APPENDIX C MATRIX OF 10CFR50 APPENDIX B CRITERIA VS. NMPC QATR-1 AND QA PROCEDURES NMPC QA PROGRAM TOPICAL NMPC QA 1 OCFR50 i APPENDIX B REPORT PROCEDURES BY QA CRITERIA SECTION NUMBERS XIV Inspection, Testing 14 QAP 10.30,

& Operating Status QAP 14 20, QAP 15.01 XV Nonconforming Material 15 QAP 15.01 XVI Corrective Action 16 QAP 16.03, QAP 16.04, QAP 16.20, QAP 16.70 XVII QA Records 17 QAP 17.10 XVIII Audits 18 QAP 18.10 C-2