ML18038A108
| ML18038A108 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/31/1985 |
| From: | Haynes J, Mangan C, Jamila Perry NIAGARA MOHAWK POWER CORP. |
| To: | |
| Shared Package | |
| ML17055A971 | List: |
| References | |
| NMPC-QATR-1, NMPC-QATR-1-R01, NMPC-QATR-1-R1, NUDOCS 8512310218 | |
| Download: ML18038A108 (69) | |
Text
NMPC-QATR-1 Revision 1
December 1985 NIAGARA MOHAWK POSER CORPORATION QUALITY ASSURANCE PROGRAH TOPICAL REPORT NINE NILE POINT NUCLEAR STATION UNITS 1
AND 2 OPERATIONS PHASE Approved:
Concurrence:
Director S
o ual it Assu nce Y ce President ior Vice resident Se ior Yic President
/
8512310218 8512 27 PDR ADOCH, 05000220 P
NMPC-QATR-1
~ Page i Rev.
1 TABLE OF CONTENTS SECTION PAGES INTROOUCTION QUALITY ASSURANCE POLICY 1.0 Organization 2.0 Quality Assurance Program 3.0 Oesign Control 4.0 Procurement-Oocument Control V
5.0 Instructions, Procedures, and Orawings 6.0 Oocument Control 7.0 Control of Purchased
- Material, Equipment and Services 8.0 Identification and Control of Materials, Parts and Components 9.0 Control of Special Processes 10.0 Inspection 11.0 Test Control 12.0 Control of Measuring and Test Equipment 13.0 Handling, Storage and Shipping 14.0 Inspection, Test and Operating Status 15.0 Nonconforming Materials,
- Parts, or Components 16.0 Corrective Action 17.0 Quality Assurance Records 18.0 Audits 1-1 to 1-12 2-1 to 2-6 3-1 to 3-3 4-1 to 4-2 5-1 6-1 to 6-2 7-1 to 7-2 8-1 9-1 to 9-2 10-1 to 10-3 ll-l to 11-2 12-1 to 12-2 13-1 14-1 15-1 to 15-2 16-1 17-1 to 17-2 18-1 to 18-2 Appendix A - Regulatory Commitments Appendix 8 - Interpretations and Exceptions of Appendix A Oocuments Appendix C - Matrix of 10CFR50 Appendix 8 Criteria vs NMPC QATR-1 and QA Procedures A-1 to A-2 B-l to 8-9 C-1
NHPC-QATR-1 Page ii Rev.
1 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 Hile Point Nuclear Station Units 1
and 2.
This Topical-Report supersedes the previous Quality Assurance Program for Nine Hile Point Unit 1
and Chapter 17 of the Nine Hile Point Unit 2 FSAR relating to the operating phase.
The Quality Assurance Program Topical Report applies to organizations performing work that affects the operation, maintenance or modification of safety-related structures, systems or components.
As stated in Niagara Hohawk Power Corporation's Quality Assurance Policy, accountability for the quality of safety-related work rests with the performer whereas accountability for verifying the quality of that work rests with the verifying organizations.
This Topical Report provides for performing operation, maintenance and modifications of both Units 1
and 2 consistent with ANSI/ASHE 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 prograomatic controls contained in this QA Program Topical Report and related commitments contained in Nine Hile 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 Director Quality Assurance.
e
NMPC-QATR-i Page iii Rev.
1 QUALETY ASSURANCE POLECY TITLE:
Quality Assurance Policy 7.l.ll Page PIPOSEi The purpose of this policy is to summarize the Company's position governing Quality Assurance responsibilities and accountabilities.
POLICT:
The Company policy regarding Quality Assurance matters is thats I.
Organisations 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~
o To strive to perform assigned work correctly the first time.
o To provide faciliti.es which are
- designed, constructed, tested and operated to high standards of excellence,,
with high assurance against failure or malfunctions, and without undue risks to the health and safety of the public.
o To ensure early and timely identificat'on'and resolution of ac ual and potential problem areas in
- design, procurement, construction,
- testing, operations, main" enance and modification of fac'ities.
o To comply effectively with gove nment regulations and esrablished VMPC policies and procedures, applying a
systematic, disciplined and uniformed approach to Quality Assurance.
ZI.
Accoun"abiLity
.'or the quality of generation, transmission ard distr'but'on structures, sys:ems, components and se vices rests with
=he organizations and persons perfor...ing the quality at=ain ng
~functions of
- design, construct on and opera 1on
~
hccountabil'ty for determining
=hat the generat'on,
=ransn ss'on snd str b '.'on struct
= s,
- systems, con"onen=s and services
'o,
'n fac=,
meet
=he s"aced
."equ'rements rests with
.he organixa ions and persons performing quality ve i 'ca.
on
."nct ons, s 'ch as design
- review, document rev ew,
'.;specs'on, surveil'ance and aud'ts.
I AVTEORIZED:
- uality -'ss.rsrcs bigs ture partment f~/ l/>
ate APPROVED:
)$ 45% Agjp a<'azeo
NHPC-QATR-1 Page l-l Rev.
1 ORGANIZATION POLICY Niagara MOhawk Power Corporation (NHPC) is responsible for establishing and implementing the quality assurance program for the operations phase of the Nine Hile Point Nuclear Station.
Although authority for development and execution of specified parts of the program may be delegated to others, such as contractors and consultants, NHPC retains overall responsibility.
This section of the Quality Assurance Program Topical Report identifies the NHPC organizations responsible for activities affecting the operation, maintenance or modification of safety-related structures,
- systems, or components, and describes the assigned authorities and duties for quality-attaining functions and for quality verification functions.
Each organizational unit, including Nuclear Operations, Purchasing, Materials Hanagement, Meter and Test, Heter and Laboratory
- Services, and the Quality Assurance Department, is responsible for the quality of its own work.
Quality assuring functions include establishing the quality assurance program and verifying that activities affecting the quality of safety-related structures,
- systems, components, and services are performed in accordance with quality assurance program requirements.
Quality assuring functions are performed by personnel within the Quality Assurance Department and other organizational units.
The Quality Assurance Department, independent from impacts of cost and
- schedule, has direct access to management levels to assure the ability to identify quality problems; initiate, recommend or provide solutions; and verify implementation of solutions.
The size of the QA Department is determined by the scope of operations activities and their importance to safety.
1.2 IHPLEHENTATION 1.2,1 Res onsibi lit and Authorit The President of Nia ara Mohawk Power Cor oration has ultimate responsibility for safe operation of the Nine Mile Pojnt Nuclear Station.
Authority and responsibility For establishing and implementing the quality assurance program For station operations, maintenance, and modifications is delegated by the President to the Senior Vice President responsible for Nuclear Operations, the Director Quality Assurance, the Senior Vice President responsible for Purchasing and Materials Management and heads of other participating departments.
The NMPC organization is shown in Figure 1-1.
Departmental responsibilities are summarized in the Responsibility Hatrix, Figure 1-2.
1.2 '
Nuclear Division Res onsibilities A.
The Senior Vice President res onsible for Nuclear 0 erations reports to the President and is responsible for the overall management of operation, maintenance and modification of the Nine Mile Point Nuclear Station.
NHPC-gATR-1 Page 1-2 Aev.
1 The Vice President - Nuclear Generation reports to the Senior Vice President responsible for Nuclear Operations and is responsible for safe and efficient operation, maintenance and modification of the Nine LIIile Point Nuclear Station.
See Figure 1-2 for primary and suppoiting quality assurance program element responsibilities.
1.
The General Su erintendent-Nuclear Generation reports to the Vice President - Nuclear Generation and is responsible for safe and efficient operation, maintenance and modification of the nuclear oower station in compliance with station licenses, applicable regulations, and the quality assurance program.
The General Superintendent delegates to the Station Superintendents and other appropriate personnel authority for performance in accordance with the quality assurance program.
Activities performed. under the responsibility of the General Superintendent-Nuclear Generation include:
a.
Controlling the preparation, review and approval of procedures and instructions; b.
Ensuring that technical, operations and maintenance personnel are appropriately qualified for their duties; c.
Providing the necessary corrective action, evaluation, processing and reporting of nonconforming conditions; and d.
Providing For timely identification and corrective action of conditions adverse to quality.
2.
The Station Su erintendents Onits 1
and 2 report to the General Superintendent
- Nuclear Generation.
They are responsible for:
a.
Safe and ef Ficient station operation; b.
Coordinating station maintenance and modifications; c.
Establishing and enforcing compliance with operating procedures; d.
Haintaining equipment status control; e.
Performing startup and operational testing; and f.
Processing, packaging and disposal oF radioactive waste.
3.
The Site Su erintendent Haintenance
- Nuclear reports to the Genera 1 Superintendent
.- Nuclear Generation and is responsible for:
a.
Originating requests for procurement of maintenance and repair materials and equipment.
NMPC-gATR-1 Page 1-3 Rev.
1 b.
Supervising the welding program in accordance with Administrative Procedures.,
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.
4.
The Technical Su erintendent - Nuclear Generation reports to the General Superintendent
- Nuclear Generation and is responsible for:
a.
Reactor engineering, reactor core management, and nuclear fuel accountability, storage, utilization, and disposition; b.
Instrument and control function - calibration and maintenance; c.
Operation and maintenance oF computer-related services; d.
Technical support services; e.
Coordination of inservice inspection and testing program f.
Fire protection; g.
Administrative services and records management; and h.
Planning and surveillance scheduling.
The Su erintendent
- Chemistr and Radiation Mana ement reports to the Genera1 Superintendent
- Nuclear Generation and is responsible For chemistry, radiochemistry, radiation protection, environmental protection, ALARA program and emergency planning including control of measuring and test equipment for these activities.
6.
The Su erintendent
- Trainin reports to the General Superintendent
- Nuclear Generation and is responsible for conducting training and maintaining records thereof.
NMPC-0ATR-1 Page 1-4 Rev. l C.
The V1ce President-Nuclear En ineerin and Licensin reports to the Senior Vice President responsible for Nuclear Operations and has overall responsibility for nuclear engineering support and licen~ing services including 10CFR Part 2l final reportability detereinations.
See figure 1-2 for primary and supporting quality assurance program element responsibilities.
l.
The Mana er Nuclear En ineerin reports to the Vice President-Nuclear Engineering and Licensing and is responsible for provid1ng eng1neering services for the safe, reliable and economic operation of the Nine Mile Point Nuclear Station Units 1
5 2, including adherence to applicable regulatory requirements.
Responsib1l ities include:
a.
Engineering services; b.
Fuel management; c.
Licensing serv1ces in support of o'perations, safety evaluations and technical specification changes; d.
Modification design and management; e.
Preparing purchase requisitions; f.
Oispositioning nonconformances; and g.
Providing For timely identification and corrective action of conditions adverse to quality.
2.
The Mana er Nuclear Com liance and Verification reports to the Vice President-Nuclear Engineering and Licensing and is responsible for verifying that Nuclear Operations Division commitments are accurately stated and accomplished within the committed time period.
3.
The Mana er Nuclear Staff Services reports to the Vice-President Nuclear Engineering and Licensing and is responsible for providing support services to the Nuclear Engineering and Licensing Department including:
a.
Records Management; b.
Training; and c.
Procedure development.
NMPC-QATR-1 Page 1-5 Rev.
1 1.2.3 Su ort De artment Res onsibi lities A.
The Vice President - Purchasin and Materials Hang ement reports to a Senjor Vice President and is responsible for formulating, establishing, and enforcing compliance with procurement
. requirements.
See figure 1-2 for primary and supporting quality assurance program element responsibilities.
1.
The Hang er-S stem Purchasin reports to the Vice President, Purchasing and Haterials Hanagement.
The staff includes the Assistant Hanager - Nuclear Purchasing, Supervisory Buyer and Senior Contract Administrator.
This organization is responsible for preparing, issuing and administering purchase orders after verifying that safety-related purchase requisitions are signed by the requester and a Quality Assurance Oepartment representative.
2.
The Hang er -
S stem Materials Mana ement reports to the Vice President - Purchasing and Haterials Management.
Included on the staff and reporting to the Manager System Materials Hanagement through the Assistant Manager - Nuclear Haterials Hanagement is the Supervisor - Nuclear Generation Storeroom.
The Supervisor-Nuclear Generation Storeroom is responsible For reviewing site-generated requests for materials and equipment, preparing purchase requisitions, and for receipt and storage of materials and equipment in accordance with Nine Hile Point Nuclear Station Administrative Procedures and Haterials Management Procedures.
B.
The Vice President
- Re ional 0 erations reports to a Senior Vice President and is responsible for formulating, establishing and enforcing Meter and Test activities.
See figure 1-2 for primary and supporting quality assurance program element responsibilities.
1.
The General Mana er - Central Re ion reports to the Vice President
- Regional Operations.
The staff includes the Superintendent Heter and Test who is responsible For the following safety-related functions.
a.
Testing and maintaining power systems protective devices and metering equipment; b.
Reviewing and advising on changes to electrical protective logic, metering and associated equipment; and c.
Performing verification testing associated with the above equipment and circuits.
C.
The Vice President S stem Electric 0 erations reports to a Senior Vice President and is responsible For Formulating, establishing and enforcing Meter and Laboratory Services activities., See figure 1-2 for primary and supporting quality assurance program element responsibilities.
NMPC-gATR-1 Page 1-6 Rev.
1 1.
The Mana er Meter and Lab Services reports to the Vice President - System Electric Operations.
The staff includes the Supervisor System Standards Lab who is responsible for mqintaining the facility for calibrating reference and secondarystandards and general usage portable and laboratory measuring and test equipment.
1.2.4 ualit Assurance Oe artment Res onsibilities d
responsible for formulating, directing, implementing and controlling policies and procedures related to verifying the overall quality of station design, construction, operation, maintenance and modification activities.
The Oirector's position may delegate to personnel under its jurisdiction appropriate portions of responsibilities, together with proportionate authority for fulfillment.
See figure 1-2 for primary and supporting quality assurance program element responsibilities.
Responsibilities include:
1.
Reviewing documents and directing the management of investigations,
- surveys, audits and reports concerning activities related to the quality of design, procurement, fabrication, materials management, installation, inspection,
- test, operation, modification, repair and maintenance of safety-related
- systems, structures, components and services; 2.
Recommending to appropriate management courses of corrective
- action, when required, including initiation of stop work orders.
This "stop work" authority is delineated in writing; 3.
Verifying the operations of suppliers, contractors and corporate departments performing safety-related work to ensure compliance with applicable regulations, procedures, specifications, codes or other standards; 4.
Oirecting the supervision of administrative Functions within the department, including training, document control and procedures manual development; and 5.
Preparing periodic and special =reports to keep management informed of the quality assurance program status.
6.
Providing For timely identiFication and corrective action of conditions adverse to quality.
7.
Resolving with other levels of management any escalated disputes involving quality, arising from a difference of opinion between
(}A personnel and other d'epartment personnel.
Oirector guality Assurance and exercises control and direction of the nuclear quality assurance program.
Responsibilities include:
l.
Interpretation and implementation of the nuc lear quality assurance policy and procedures;
NHPC-QATR-l
~ Page 1-7 Rev. l 2.
Advising the Director Quality Assurance of nuclear quality activities; t
3.
Reviewing Quality Assurance Department procedures; 4.
Rev1ewing 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's del1neated in writ1ng; 6.
Directing the QA Program Hanager in the following activities:
a.
Develop1ng QA project budgets/decisions on QA involvement on specific projects (plant outages-mod1fications) b.
Utilizing matrix management concept to secure:
- Engineering QA functions Procurement QA functions Installation QA functions c.
Establishing QA project schedules and interfaces d.
Honitoring assigned projects and issuing status reports e.
Coordinating project QA problem resolution f.
QA closeout of projects; 7.
Directing the Quality Engineering Supervisor in the following activities:
a.
Site Operations Review Comnittee QA representative b.
Corrective action trending c.
CAR coordination d.
NRC correspondence and comment coordination e.
Internal/external reporting f.
Training coordination g.
Site quality engineering in Mechanical, Electrical, and l&C disc1plines to perform:
- Procedure reviews
- Procurement document reviews
- On-site contractor monitoring Assisting source inspection
- Modification support
- Material Review Board member (NCRs)
Modification package record review; 8.
Directing the Operations Surveillance Supervisor in the following QA Surveillance areas:
a.
Site Operations Review Comaittee QA representative b.
Tech.
Spec.
- Operations c.
Refueling
NHPC-gATR.-1
.Page 1-8 Rev.
1 9.
10.
d.
Chemistry e.
Radiation control f,.
Training g',
Security h.
Fire -Protection j.
Environmental Control; Directing the guality Control Supervisor in the following areas:
a.
Inspection - Mechanical, Electrical, I8C discipline b.'aintenance support c.
Receipt inspection d.
Management of gC associated with selected outage work e.
Work Request processing f.
Assisting in Source Inspection g.
Training/certifying gC inspectors h.
NOE procedure development and qualification i.
Section XI - In-Service Inspection j.
Haintenance procedure review k.
Inspection procedures and checklist development; and Assuring that representatives of the guality Assurance organization on-site routinely attend and participate in work schedule and status meetings to keep abreast of day-to-day work assignments throughout the plant and to adequately cover and carry out gA assignments.
C.
The Mana er Cor orate ualit Assurance reports to the Director guality Assurance and provides a support function for the guality Assurance Department.
Responsibilities include:
Preparing, controlling and implementing guality Assurance Department documents including the guality Assurance Topical Report and guality Assurance Department policies and procedures; 2.
3.
4.
O.
The Advising the Director guality Assurance and the Manager Nuclear guality Assurance Operations of nuclear quality activities; Initiating or delegating action in assigned areas of responsibility including training, supplier evaluation,
- audit, and trend analysis; and Recommending to appropriate management courses of corrective
- action, when requi,red, including initiation of stop work orders.
This "stop-work" authority is delineated in writing.
Mana er ualit
& Reliabilit En ineerin reports to the Director guality Assurance and provides technical support to the Nuclear gA Operations Section.
Responsibilities include:
0
NMPC-gATR-1 Page 1-9 Rev.
1 Reviewing plant modification design documents for inspectability; developing quality planning to support ipstallation of plant changes and coordinating the technical aspects of OA Modification package implementation during plant shutdowns.
2.
3.
Providing for control of purchased equipment throught the contractor qualification program, 'source surveillance and the preparation of receiving inspection planning (for implementation by Nuclear gA Operations personnel).
Providing materials engineering support in the areas of material selection, welding, corrosion prevention, non-destructive examination, and fuels quality assurance.
4.
5.
Advising the Director guality Assurance and the Manager, Nuclear gA Operations of nuclear quality activities.
Providing reliability engineering support for the equipment qualification program; establishment of system and equipment availability goals; follow-up with suppliers on achievements of euipment reliability requirements; and performance of studies on extending equipment life.
6.
7.
Reviewing and concurring with various documents and other department procedures, where applicable, which implement this gua 1 ity Assurance Program Topi ca 1 Repo r t, and Recommending to appropriate management courses of corrective
- action, when required, including initiation oF stop work orders.
This "stop work" authority is delineated in writing.
E.
ualit Assurance Su ervi sors supervise the equality Assurance Department staff.
Supervisory and staff responsibilities include:
Supervising, directing, and coordinating the guality Assurance Department staFF within the framework of established policies and guality Assurance Department procedures; 2.
3.
Reporting status of quality activities to the responsible manager; Conducting inspections, audits and surveillances to verify quality assurance program implementation within NMPC and outside suppliers and contractors; 5.
Preparing and implementing guality Assurance Department procedures and instructions;.,
Recommending "stop work" action when appropriate.
This authority is delineated in writing;
NHPC-0ATR-1 Page 1-10'ev.
1 6.
Reviewing quality-related documents including procedures, purchase requisitions and suppliers'uality assurance programs; 7.
Oocumenting and verifying correction of conditions adverse to quality; 8.
Reviewing, preparing and filing quality assurance department records; 9.
Conducting training programs; and 10.
Haintaining the Nondestructive Examination Procedures Hanual.
TOPICAL QATAR-1, REV. 1 IONS UALI ASS CE PROG TOPICAL ORT FOR MILKPOINT NUC S
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NMPC-gATR-1 Page 1-12 Revision 1
REGULATORY REOUIREMENTS
~
t QJALITY ASSURANCE PROGRAM RESPONSIBILITY MATRIX NMPC OEPARTMENTS 1
I.
Organization 1,1-Sl II.
OA Program 2,
2S-1 25-2 25-3 III.
Oes ign 3,
35-1 IY.
Procurement 4,4S-l V.
Procedures 5
Yl.
Ooc. Control 6,
65-1 VII.
Purch.
Items 7,
7S-1 VIII.
Item Control 8,
8S-1 IX.
Special Proc.
9, 95-1 1
3.1 3.3 3.4.2 3.1 3.3 5.1 5.3 3.4. 2 3.5 5.2.7.2 5.2.13.1 5.2.7 5.3 5.2.15
- 5. 2.13. 2
- 5. 2.13. 3
- 5. 2.18
- 5. 2.12 P
P P
P P
P P
5 5
5 5
5 5
P,R 5
P 5
P P
5 P
P P
P P
P P
P,R P
P P
P P
P P,R P
P 5
P P
5 P
P X.
Inspection 10, 105-1 XI.
Testing 11, 11S-1 XII.
MhTE 12, 125-1 XIII.
Hand.
4 Stg.
13, 135-1
- 5. 2.17
- 5. 2.19
- 5. 2.16
- 5. 2.13. 4 P
5 P
P P
5 5
5 5
5 P,R XIV.
Operating Status 14 5.2.6
- 5. 2.14 XY.
Nonconform.
15, 15S-1 XYII.
Records XVI II. Audit 17, 175-1 18, 185-1 XVI.
Corr. Action 16
- 5. 2.1'4 5.2. 11
- 5. 2.12
- 4. 5 P
P 5
5 R
P
'P
- 5 5
5 5
P R
P P
S S
5 S
S,R NMPC OEPARTMENT NG-NE PUR i"Pl-MT-ML-OA-Nuclear Generation Nuclear Fngineering
- Purchasing Materials Management Meter and
- Test, Meter and Laboratory Services equality Assurance PROCEOURAL COVERAGE REQUIREO P - Primary Responsibility S - Support Responsibility R - Review, Audit or Survelliance Responsibility Figure 1-2
NMPC-QATR-1
.Page 2-1 Rev.
1 2.0 UALITY ASSURANCE PROGRAH 2.1 POLICY The Niagira Hohawk Power Corporation (NMPC) quality assurance program for the Nine Mile Point Nuclear Station operations phase is established by this Quality Assurance Program Topical Report and applies to safety-related activities, i.e. activities that affect the operation, maintenance or modification of safety-related
- systems, structures or components.
The quality assurance program includes policies, procedures, instructions and other documents that implement the provisions of this Topical Report.
The quality assurance program fulfills the requirements of the regulatory documents to which NMPC has committed.
The quality assurance program provides for safety-related activities to be performed under suitably controlled conditions, including the use of appropriate equipment, maintenance of proper environmental conditions, assignment of qualified personnel and assurance that applicable prerequisites have been met.
Quality assurance program status,
- scope, adequacy and compliance with 10CFR50 Appendix 8 are regularly reviewed by NHPC management through
- reports, meetings, review of audit results, and documented assessments performed by management teams.
2.2 IMPLEMENTATION 2.2.1 General organizational responsibilities are outlined in Section 1.0, ORGANIZATION.
2,2.2 This Quality Assurance Program Topical Report, organized to present the NHPC quality assurance program in the order of the 18 criteria of 10CFR50 Appendix 8, states NHPC 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 8 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 coomitments previously accepted by the Nuclear Regulatory Commission (NRC) shall be submitted to the KRC at least annually.
Any changes made to this Topical Report that do reduce the coomitments 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 wi 11 be made in accordance with the requirements of 10CFR50.54.
2.2.3 The Corporate Quality Assurance Policy authorized by the Oirector Quality Assurance and approved by the President
- states, "Organizations with quality-affecting responsibilities shall be structured,
- managed,
NIPC-gATR-.l Page 2-2 Rev.
1 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.
2.2.4 The quality assurance program is implemented by organizations responsible for attaining quality and by organizations responsible for verifying quality (see Section 1.0, ORGANIZATION).
2.2.5 The qualification requirements for the Director guality Assurance are as follows:
Education Bachelor's degree in engineering or physical science from an accredited institution.
~Ex er3ence
- 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 ons.
- c. Five (5) years of experience in responsible managerial positi NOTE:
The experience requirements may be met on a concurrent basis.
2.2e6 guality Assurance Department Managers and Supervisors are required to have demonstrated their management competence through prior assignments of increasing responsibility in addition to the following qualifications:
Education Bachelor's degree or equivalent in engineering or physical science
~
~Ex essence 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.
NMPC-QATR-1
.Page 2-3 Rev.
1 2.2.7 The operations phase quality assurance program applies to activities affecting the operation and the quality of structures,
- systems, components, and services during plant operation, maintenance, testing and modifications.
Safety-related structures,
- systems, and components are identified in Q-Lists, which are developed and maintained for each unit, and are consisent with the FSAR coranitments.
Appropriate elements of the Quality Assurance Program Topical Report are applied to emergency plans, radiation protection procedures and radioactive waste shipment programs for the nuclear station.
2.2.8 Those elements of the Quality Assurance Program Topical Report which apply to radioactive waste handling activities include:
a.
Audits or survei llances on approximately 10$ of radioactive waste shipments.
b.
Annual audits of the radioactive waste handling program.
c.
Audits identified in a.
and b. are performed by Quality Assurance Department personnel who are trained in Department of Transportation (OOT) and Nuclear Regulatory Comnission 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 Hi le Point Nuclear Station Administrative Procedures; b.
Nuclear Engineering and Licensing Department Engineering Procedures; c.
Purchasing Department - Purchasing Procedures; d.
Materials Management Department - Haterials Management Procedures; e.
Meter and Test Department - Measuring and Test Equipment Control Procedures; f.
Meter and Laboratory Facilities Department - Calibration Procedures; and g.
Quality Assurance Department - Quality Assurance Procedures.
2.2.10 The programmatic Regulatory Guides and ANSI Standards, and their applicable revisions, to which NHPC coomits with regard to quality assurance matters and appropriate explanations of interpretations and exceptions are tabulated in Appendices A and B of this Topical Report.
NHPC-QATR-1 Page 2-4 Rev.
1 2.2.11 The scope of the program and the extent to which its controls are applied are established as follows:
a.
NHPC uses the criteria specified in Engineering Procedures for identifying structures, systems and components to which the quality
~
assurance program applies; b.
This identification process results in a 9-list which identifies safety-related items for each unit.
The g-list is a controlled document.
Safety-related items are determined by engineering analysis of the function(s) of plant structures, systems and components in relation to safe operation and shutdown; c.
The controls specified in the quality assurance program described in this Topical Report are applied to safety-related items.
2.2.12 Safety-related activities are accomplished under controlled conditions.
Preparations for such activities include confirmation that prerequisites have been met, such as:
a.
Assigned personnel are qualified; b.
Mork is planned in accordance with the proper revisions of applicable engineering and/or technical specifications; c.
Specified equipment and/or tools, if any, are on hand to be used; d.
Equipment and materials are in an acceptable status;'.
Systems or structures on which work is to be performed are in the proper condition or operational mode for the task; f.
Current and approved instructions or procedures for the work are available for use; g.
Items and facilities that could be damaged by the work have been protected as required; and h.
Provisions have been made For special equipment, environmental conditions, skills, controls, processes, tests and verification methods.
2.2.13 2.2.14 Development, control and use of computer programs affecting nuclear power plant safety-related design and operation are subject to appropriate contra)s.
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:
NMPC-gATR-1
.Page 2-5 Rev.
1 a.
Personnel responsible for performing and verifying activities that affect quality are familiar with the activities and the requirements identified in applicable quality'-related
- manuals, instructions and procedures.
b.
Proficiency tests are utilized where appropriate to determine that individuals can perform their assigned tasks.
c.
Personnel who perform inspection, examination, test, audit and special process activities are trained and qualified in accordance with applicable requirements.
Certificates of qualiFication (where required) designate specific areas of qualification and the bases for the qualification.
d.
Provisions are included for retraining, re-examination and recertification (where certification is required) to ensure that proficiency is maintained.
e.
Training content and attendance
- records, and required qualification and certification records are maintained.
2.2.15 The management of Niagara Mohawk Power Corporation (NMPC) at the presidential or chief executive officer level assesses the scope,'tatus,
- adequacy, and compliance of the quality assurance program for the nuclear stations at a predetermined regularity.
Management at this level employs the following means to assess the program:
a.
The Director guality Assurance is responsible For annually reporting in writing to the President of NMPC on the status, adequacy and efFectiveness.
of the NMPC quality assurance program.
b.
The Director ()uality Assurance regularly attends corporate staff
- meetings, board meetings and cotenant
- meetings, and makes verbal presentations regarding quality-related matters.
Minutes of these meetings are generally documented.
Certain actions of the Safety Review and Audit Board and of the Site Operations Review Conmittee result in audits and/or reports 'by,which members of these offsite and onsite review committees -are made aware, on a regular basis, o'f the effectiveness of the quality assurance program.
2.2.16 The Safety Review and Audit Board (SRAB) is a standing corrmittee
-responsible to the Vice President Nuclear Engineering and Licensing and to the Vice President Nuclear Generation regarding designated quality assurance functions at the Nine Mile Point Nuclear Station.
NNPC-QATR-l
,Page 2-6 Rev. l 2.2.17 The Site Operations Rev1ew Cooeittee (SORC) is an independent review comnittee responsible to the General Superintendent, Nuclear Generation and transmits reports to the Safety Rev1ew and Audit Board.
The Site Operatioqs Review Comnittee responsibilities include:
a.
Reviewing reportable events; b.
Reviewing facility operations to detect potential safety hazards; c.
Performing special
- rev1ews, 1nvestigations or analyses and reports thereof as requested by the Chairman of the Safety Review and Audit Board; 2.2.l8 The Quality First Program (QlP). prov1des NHPC and contractor employees an opportunity to coneunicate their quality concerns regarding operation, maintenance or modification wh1le keeping their 1dentity confidential, 1f they desire, and to rece1ve feedback regarding the results of investigations w1th respect to their concerns.
Quality concerns determined to be valid are acted upon by the responsible organization and the actions are verif1ed by QlP personnel prior to closeout.
NHPC-gATR-1 Page 3-1 Rev.
1 3.0 DESIGN CONTROL 3.1 3.2 t
POLICY I
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 NHPC engineering and technical organizations.
IMPLEMENTATION 3.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
3.2.2 Nuclear Engineering and Licensing Department responsibilities include the preparation, review and approval of such things as:
a) system descriptions; b) design input and criteria; c) drawings, specifications, procedures; and d) engineering analyses and associated computer programs.
3.2.3 Computer programs used in safety-related design and station operation are appropriately documented, verified, certified for use and controlled in accordance with procedures.
3.2.4
,3.2.:5 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.
,Exceptions, waivers to, or deviations from engineering requirements are required by procedure and by contract, when applicable, to be documented and controlled.
3.2.6 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 conmunication 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.
NMPC-gATR-1
.Page 3-2 Rev.
1 3.2.7 Oesign drawings and specifications are checked to verify the dimensional accuracy and completeness.
3.2.8 3.2.9 Modificat/on design document packages are audited by the guality Assurance Oepartment to assure'that the documents therein have been
- prepared, reviewed, and approved in accordance with procedures and that they contain the necessary quality assurance requirements.
These requirements include any inspection and test requirements, quantitative and/or qualitative acceptance criteria and the requirements for documenting inspection and test results.
The extent of and methods used for design verification are documented.
Methods for design verification include evaluation of the applicability of standardized or previously proven designs, alternate calculations, qualification testing and design reviews.
These methods may be used singly or in combination, depending on the needs for the design under consideration.
3.2.10 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.
Oesign reviews are performed by single individuals or by interdisciplinary or multi-organizational
- groups, as appropriate.
Unless otherwise stated, the verification of design addresses the information conveyed by the design document.
When the verification is limited to certain areas or features, the scope or extent and any limitations on the verification are documented.
gualification 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.
gualification testing is performed under conditions that simulate adverse design conditions as determined by analysis, considering relevant operating modes.
Test requirements, procedures and results are documented.
Results are evaluated to-assure that test requirements have been satisfied.
Modifications are made if shown to be necessary through testing.
Following modification, any necessary retesting or other verification is performed.
Scaling laws are established and veriFied, when applicable.
Test configurations are documented.
3.2.11 Persons representing applicable technical disciplines. are assigned to perform design verifications.
These persons are qualified by appropriate education or experience and are not directly responsible for the design being verified.
This verification may be performed by the originator's supervisor, provided that:
NNPC-gATR-1
. Page 3-3 Rev.
1 l.
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.
3.2.12 When designs must be released for use before they have been completed or before they have been verified, the incomplete or unverified parts of the design and the hold point to which work may proceed are identified, and design output documents based on unverified data are identified and controlled.
This hold point occurs before the work becomes irreversible or before the item is relied on to perform a safety-related function.
Justification for such early release is documented.
3.2.13 Oesign output documents, and revisions thereto, are controlled by the design office (architect-engineer, vendor, contractor, consultant or Nuclear Engineering) responsible for the design work.
Each design organization controls design documents in accordance with approved procedures that provide for review, approval, distribution and revision.
3.2.14 Changes to design output documents, including field changes, are controlled in a manner commensurate with that used for the original design.
information on approved changes is transmitted to affected organizations.
NHPC-QATR-1 Page 4-1 Rev.
1 4.0 PROCUREHENT OOCUHENT CONTROL 4.1 t
POLICY Procurement documents define the characteristics of items or services to be procured, identify applicable regulatory and industry codes or standards requ1rements, and specify supplier quality assurance program requirements to the extent necessary to assure adequate quality.
4.2 IHPLEHENTATION 4.2.1 General organizational respons1bilities are described in Section 1.0, ORGANIZATION.
4.2.2 4.2.3 4.2.4 Procurement requisition packages are reviewed and approved prior to submittal to the Purchasing Oepartment.
Review includes ver1f1cation by the Quality Assurance Oepartment that the necessary quality requ1rements are specified.
The responsible project engineer or requester performs bid evaluations.
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; e.
A requirement For a documented quality assurance
- program, subject to Quality Assurance Oepartment review and written concurrence; f.
A requirement for the supplier to invoke applicable quality requirements on subtier suppliers;
NHPC-gATR-1 Page 4-2 Rev.
1 g.
Provisions for access to supplier and subtier suppliers'acilities and records for inspections, survei llances and audits; h.
?dentification of documentation to be provided by the supplier (see paragraph 4.2.6);
i.
Provisions for documentation and dispositioning of nonconformances.
4.2.6 Purchase documents require suppliers to furnish the following records as applicable:
a.
Drawings and/or related engineering documentation that identify the purchased item and the specific procurement requirements (e.g.,
- codes, standards, as-built/as-designed drawings and specifications) met by the item; b.
Documentation identifying any procurement requirements that have not been met; c.
A description of those nonconformances from the procurement requirements dispositioned "use as is" or "repair.'he guality Assurance Department evaluates the acceptability of these documents during source and/or receipt inspection.
4.2.7 The guality Assurance Department performs and documents reviews of procurement requisition packages to assure that:
a.
guality requirements (see paragraph 4.2.5) are correctly stated, inspectable, and controllable; b.
Acceptance and rejection criteria are included; and c.
The procurement documents have been prepared,
- reviewed, and approved in accordance with applicable procedures.
4.2,8 Changes to the technical or quality requirements in procurement documents are controlled in a manner commensurate with that used for the original requirements.
5.0 5.1 INSTRUCTIONS 'ROCEDURES AND DRAWINGS t
POLICY NNPC-QATR-1 Page 5-1 Rev.
1 Activities affecting the quality of safety-related structures,
- systems, components and services are accomplished using instructions, procedures and drawings (including vendor manuals) appropriate to the circumstances.
These documents include appropriate acceptance criteria.
ANSI/ASIDE NQA-1 and ANSI/ANS-3.2 comitments contained in Appendix A of this QA Topical Report have been translated into procedural matrices to assure that implementing procedures cover the QA comaitments.
5.2 IMPLEMENTATION 5.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
5.2.2 5.2.3'nstructions, 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.
The procedures used to control activities include the departmental procedures listed in Section 2.
Those procedures provide requirements and controls pertaining to the conduct of both onsite and offsite safety-related activities to provide affected personnel with a clear understanding of the operating philosophy and management policies as well as methods and techniques for performing required work.
5.2.4 Measures are provided to assure that correct procedures are available and that they are used in the performance of safety-related activities.
NMPC-QATR-1 Page 6-1 Rev.
1 6.0 DOCUMENT CONTROL 6.1 POLICY Documents are controlled, issued and changed according to established procedures.
Documents such as instructions, procedures, and drawings, including changes
- thereto, are reviewed for adequacy, approved for release by authorized personnel, and are distributed and used at the location where a prescribed activity is performed.
Changes to controlled documents are reviewed and approved by the same organizations that performed the original review and approval or by the organizations designated in accordance with the procedures governing these documents.
6.2 IMPLEMENTATION 6.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
6.2.2 Procedures are established for review, approval,
- issue, change and use of documents in the following categories:
a.
Design documents (e.g., calculations, drawings, specifications, analyses) including documents related to computer codes; b.
As-built drawings, procedures and related documents; c.
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.
F'ina'1 'Safety Analysis Report; g.
Reports of nonconformances; h.
Unit Technical Specifications; i.
Quality Assurance Program Topical Report.
6.2.3 Procedures which govern the review, approval.,
- issue, change and use of documents include as appropriate:
a.
Establishment of criteria to ensure that adequate technical and quality requirements are incorporated prior to implementation;
6.2.4 NHPC-gATR-1 Page 6-2 Rev.
1 b.
Identification of the organizations responsible for review,
- approval, issue, and revision; I
c.
Performance and documentation of a review for concurrence with quality assurance related aspects by the guality Assurance Oepartment; 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 6.2.5 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.
Nhen master lists are used, they are updated and distributed to designated personnel who are responsible for maintaining current copies of the lists.
6.2.6 As-built drawings and related documents are prepared in a timely manner consistent with the needs of the user organization.
NHPC-QATR-1 Page 7-1 Rev.
1 7.0 CONTROL OF PURCHASED HATERIAL E UIPHENT AND SERVICES 7.1 POLICY Activities that implement approved procurement requests for material, equipment, and services are controlled to assure conformance with procurement document requirements.
Controls include a system of supplier evaluation and selection, source inspection, examination and acceptance of items and documents upon delivery, and periodic assessment of supplier performance.
7.2 IHPLEMENTATION 7.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
7.2.2 7.2.3 When contractors perform work under their own quality assurance
- programs, those programs are reviewed for compliance with the applicable requirements of 10CFR50 Appendix 8 and the contract and are accepted by the Quality Assurance Department.
NHPC qualifies suppliers (excluding suppliers of comnercial grade items) by performing a documented evaluation of their capability to provide items or services specified by procurement documents.
Other means of evaluating supplier qualifications include objective evidence of suppliers'urrent quality performance, surveys performed by consultants, other utilities or other organizations such as CASE or ASHE survey teams, NMPC qualified suppliers invplved,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
~
b.
Relatively simple and standard in design, manufacture and test; and Adaptable to standard or automated inspections or tests of the end product to verify quality characteristics after delivery; and c.
Such that receiving inspection does not require operations that could adversely affect the integrity, function, or cleanness of the item.
In the above cases, source and/or receipt inspection provides the necessary assurance of an acceptable.,item or service.
7.2.4 Supplier activities that affect quality are verified in accordance with written procedures that provide the method of verifying (such as audit, surveillance, or inspection) and documenting the verification results.
NHPC-gATR-1 Page 7-2 Rev.
1 7.2.5 Spare and replacement parts are procured in accordance with the following, provisions to assure that their performance and quality are at least 8quivalent 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 orig1nal items or to rev1ewed and approved rev1sions.
b.
Where quality requ1rements for the orig1nal items cannot be determ1ned, requirements and controls are established by eng1neer1ng evaluat1on.
c.
Any add1t1onal or modified des1gn cr1ter1a, 1mposed after previous procurement of the item(s), are identified and incorporated.
7.2.6.
Comnercial 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 sat1sfy design requirements.
7.2.7 Receipt inspections are performed to verify that items are undamaged and properly identified and that required supplier-furnished documentation is available and correct.
In addition, depending upon the nature, complexity and importance of the item and amount of source inspection or surveillance, selected characteristics may be examined or tested on a sampling basis to verify conformance to procurement requirements.
Items inspected are identified as to their acceptance status prior to storage or release for installation or use.
7.2.8 Suppliers'ertificates of conformance are reviewed for completeness and accuracy and are supplemented by receipt inspection to verify conformance to purchase requirements.
7.2.9 Oocumentation supporting the conformance of material and equipment with the procurement documents is to be available at the site prior to installation whenever possible.
In those instances when equipment and material are received without the required documentation, installation may be accomplished if:
a.
The installation is controlled in accordance with the requirements of Sections 15 and 16 of this guality Assurance Program Topical Report; and b.
The 1nstalled items are read) ly 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.
NHPC-QATR 1
Page 8-1 Rev.
1 8.0 IOENTIFXCATION ANO CONTROL OF HATERIALS PARTS AND COHPONENTS 8.1 POLICY Haterials, 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 IHPLEHENTATION 8.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
8.2.2 8.2.3 8.2.4 Controls provide for the identification and control of materials (including consumables),
parts and components (including partially fabricated assemblies)
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.
Items are traceable to applicable drawings, specifications, or other pertinent documents to ensure that only correct and acceptable items are used.
Verification of traceabi lity is performed and documented prior to release for fabrication,
- assembly, or installation except as provided in Section 7.0.
N4PC-QATR-1 Page 9-1 Rev.
1 9.0 CONTROL OF SPECIAL PROCESSES 9.1 POLICY 9.2 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.
IMPLEHENTATION 9.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
9.2.2 Processes sub]ect 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 whichthe 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 (NOE).
9.2.3 Requirements for control of special processes involve one or more of the following methods, each of which is approved by qualified personnel:
a)
Written instructions on the drawing or specification for the piece or assembly; 9.2.4 9.2.5 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.-
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.
Special process personnel qualification is determined by individuals authorized to administer the pertinent examinations.
Certification of qualification is based in part on examination results.
Personnel certification is kept current by performance of the special process(es) and/or reexamination at time intervals specified by applicable
- codes, specifications and standards.
Unsatisfactory performance or, where applicable, failure to perform within the designated time intervals requires requalification and recertification.
NNPC-QATR-1 Page 9-2 Rev.
1 9.2.6 For special processes that require qualified equipment, such equipment is qualified in accordance with applicable
- codes, standards and specifications.
9.2.7 Qualification records and records of satisfactory special process performance are maintained in accordance with Section 17.
9.2.8 9.2.9 The Quality Assurance Oepartment performs audits, inspection and surveillance of special processes to assure they are satisfactorily performed when specified by applicable inspection planning and/or site procedures.
Such inspections, surveillances and audits include verification that process data are recorded as required, are within specified limits and are performed in accordance with applicable requirements.
NHPC specifies in procurement documents which records are to be kept by vendors and/or forwarded to NHPC.
The document retention policy and requirements are stated in Section 17.
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 codes or standards; b)
Special process procedures, signed and dated by authorized personnel; c)
Results of special inspections with results of tests, any corrective action taken, retest if required, and the dated acceptance signature.
The results document must identify the part,
- assembly, and/or section of the system with its own number or code for future identification and reference.
Supporting evidence or documentation such as radiographs,
- photos, sketches or other descriptive. material must bear the same number or code; d)
Charts of 'the heat cycle in heat treating -operations showing test equipment
- numbers, temperatures, and time; or certified documents by authorized personnel attesting to test equipment
- numbers,
'temperature, and time used in the heat treating cycle.
NMPC-gATR-1 Page 10-1 Rev.
1
- 10. 0 INSPECTION 10 ~ 1 POLICY t
1 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.
Oirect 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 IMPLEMENTATION 10.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
10.2.2 Inspections are applied to procurement, maintenance, modification,
- testing, fuel handling, operation and inservice inspection to verify that items and activities conform to specified requirements.
Inspection planning documents are prepared or reviewed by the guality Assurance Oepartment in accordance with procedures.
Oocumentation of inspection planning identifies the following as applicable:
a.
Characteristics and activities to be inspected; b.
Inspection organization; c.
Accept/reject criteria; d.
Hold points and/or witness points; e.
Methods; f.
Provisions for recording objective evidence of inspection results; g.
Specify measuring and test equipment of the necessary accuracy for performing inspection.
Inspection is performed on selected operations where it is deemed necessary to verify conformance with specified
'requirements.
Process monitoring is used where direct inspection alone is impractical or inadequate.
Both inspection and process monitoring are performed when control is inadequate without both.
10.2.3 Training and qualification programs.for personnel who perform inspection, including nondestructive examination, are established, implemented and documented in accordance with Section 2.0.
These programs meet the requirements oF applicable codes and standards.
NNPC-QATR-1 Page 10-2 Rev.
1 gualifications and certifications of inspection and nondestructive examination (NOR) personnel are maintained as qUality records in accordance with Section 17.
10.2.4 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.
10.2.5 Nitness points require notification of the guality Assurance Oepartment prior to performance of the specified activity.
Work may proceed upon sufficient notice to gA of the impending witness point.
10.2.6 Inspections are performed and documented in accordance with written procedures.
The results are evaluated and documented by qualified personnel in order to verify the acceptability of the item or work.
10.2.7 Inservice inspection and testing is performed and documented in accordance with a program of examinations,
- tests, and inspections of plant components and systems.
An Authorized Nuclear Inservice Inspector (ANII) is employed to verify that the program is conducted in accordance with requirements.
10.2.8 Inspections are normally performed by guality Assurance Oepartment personnel.
Inspections associated with normal operations of the plant (such as routine maintenance, surveillance, and test) may be performed by individuals within the same group other than those who performed or directly supervised the work, provided the following requirements are met:
a.
The quality of the work can be demonstrated through a Functional test when the activity involves breaching a pressure retaining item; and b.
The qualification criteria for inspection personnel are reviewed by the guality Assurance Oepartment.
10.2.9 Inspection records contain the following where applicable:
a.
Item inspected; b.
The date of the inspection; c.
Inspector or data recorder identification;
NHPC-qATR-1 Page 10-3 Rev.
1 d.
Type of observation; t
e.
Resu'its or acceptability; f.
Reference to information on action taken on nonconformances to resolve any discrepancies noted.
NHPC"gATR-1
.Page ll-'1 Rev.
1 11.0 TEST CONTROL POLICY Testing is performed to demonstrate that items will perform satisfactorily in service.
The testing is performed in accordance with written procedures that incorporate specified requirements and acceptance criteria.
The test program includes qualification, acceptance, pre-operational, start-up, surveillance and post-maintenance tests.
Test parameters, including any prerequisites, instrumentation requirements and environmental conditions, are specified and met.
Test results are documented and evaluated.
- 11. 2 IHPLEHENTATION 11.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
11.2.2 Tests are performed in accordance with procedures and criteria that designate when tests are required and how they are to be performed.
Such testing includes the following:
- a. gualification 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 tests performed after Fuel loading to assure proper and safe operation of systems and equipment;
- e. Surveillance tests to assure continuing proper and safe operation of systems and equipment; and
- f. Haintenance tests after preventive or corrective maintenance.
11.2.3 Test procedures and instructions include provisions For the Following, as applicable:
a.
The requirements and acceptance limits contained in applicable design and procurement documents; b, Test prerequisites such as calibrated instrumentation, required test equipment, degree of completeness of the item to be tested, suitable and controlled environmental conditions and provisions For data collection and storage;
NMPC-gATR-1 Page 11-2 Rev.
1
- c. Verifying that test prerequisites have been met; t
- d. Instructions for. performing the test; e.
Any witness and hold points;
- f. Acceptance criteria; g.
Oocumenting or recording test data and results; and
- h. Verification of completion.
11.2.4 Test procedures and instructions are reviewed by the applicable organizations for technical content and by the guality Assurance Oepartment for quality assurance requirements.
11.2.5 The guality Assurance Oepartment verifies that test results are documented, evaluated and accepted by responsible personnel.
11.2.6 Test records contain the following where applicable:
a.
Item tested and type of observation; b.
The date and results of the test;
- c. Information related to conditions adverse to quality; d.
Oata recorder identification; e.
Evidence as to the acceptability of the results; and
- f. Action taken to resolve any deviations noted.
NMPC-gATR-1 Page 12-1 Rev.
1 12.0 CONTROL OF MEASURING AND TEST E UIPHENT 12.1 POLICY Heasuring and test equipment is identified, controlled, calibrated and adjusted at specified intervals to maintain accuracy within prescribed limits.
- 12. 2 IHPLEHENTATION 12.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
12.2.2 Procedures are established for calibration, maintenance and control of measuring and test equipment utilized in the operation, measurement, inspection or monitoring of items.
These procedures describe calibration technique, frequency, maintenance and control of installed as well as portable equipment.
12.2.3 Measuring and test equipment is uniquely identified and is traceable to its calibration test data.
12.2.4 Labels are attached to measuring and test equipment to display the next calibration due date.
Where labels cannot be attached, a control system is used that identifies to potential users any equipment beyond the calibration due date.
12.2.5 Measuring and test equipment is calibrated at specified intervals.
These intervals are based on the amount of use, stability, characteristics and other conditions that could adversely affect the required measurement accuracy.
Reference and secondary calibration standards are traceable to nationally recognized standards where they exist.
Where national standards do not exist, provisions are established to document the basis for calibration.
12.2.6 12.2.7 Where practical, reference standards that have at, least Four times the required accuracy of the 'item being calibrated are used to calibrate secondary standards.
'When this accuracy is not possible, these standards shall have an accuracy that assures that the equipment being calibrated will be.within required tolerance.
In such cases the basis of acceptance is documented and is authorized by responsible management personnel'econdary standards normally have a greater accuracy than the equipment or installed plant instrumentation being calibrated.
Standards with %he 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.
'HPC-gATR-1 Page 12-2 Rev.
1 12.2.8 When measuring and testing equipment used for inspection and test is found to be out of calibration, evaluations are conducted to determine the validity of the results obtained since the most recent calibration.
The results of evaluations are documented.
Retests or reinspections are performed on suspect items as necessary.
0
NMPC-gATR-1
.Page 13-1 Rev.
1 13.0 HANOLING STORAGE AND SHIPPING 13.1 POLICY Activities with the potential for causing contamination or deterioration that could adversely affect the ability of an item to perform its intended function and activities necessary to prevent damage or loss are identified and controlled.
Controls are achieved through the use of appropriate procedures.
- 13. 2 IMPLEMENTATION 13.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
13.2.2 Procedures are used to control the cleaning, handling, storing, packaging, preserving and shipping of materials, components and systems in accordance with design and procurement requirements.
These procedures include the following functions:
a.
- Cleaning, to assure that required cleanliness levels are achieved and maintained; b.
Packaging and preservation, to protect against damage or 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 shel'f 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-OATR-.1.
.Page 14-1 Rev.
1 14.0 INSPECTION TEST ANO OPERATING STATUS 14.1 P
POLICY Systems are established which ensure that the inspection, test and operational status of items is known and controlled.
Non-operational status of systems and components for inspection, maintenance and tests is indicated by tagging, marking, logging or other specified means under procedural controls to prevent inadvertent use.
- 14. 2 IMPLEMENTATION 14.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
14.2.2 For 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.
14.2.3 Application and removal of status indicators such as tags,
- markings, labels, etc.
are controlled by procedures.
14,2.4 14.2.5 14.2.6 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 applicable procedures.
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.
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.
1 15.0 NONCONFORMING MATERIALS PARTS OR COMPONENTS 15.1 POLICY 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.
15.2 15.2.1 IMPLEMENTATION 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.
Oocumentation describes the nonconformance, the disposition of the nonconformance and the inspection requirements.
It also includes signature approval of the disposition; b.
The (}uality Assurance Oepartment reviews nonconformance documents to assure completeness and control over nonconforming items.
In
- addition, gA controls, distributes and closes out nonconformance
- reports, inspection reports and surveillance reports.
c.
Items that have the disposition of "repair" or "use-as-is" require documentation by Engineering justifying acceptability; and 15.2.3 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.
Oispositions of conditionally released items are closed out before the items are relied upon to perform their safety-related functions.
15,2.4 Prior to the initiation of preoperational testing on an item, nonconformances are corrected or evaluated. for possible impact upon the item or the testing program.
NHPC-QATR-1 Page 15-2 Rev.
1 15.2.5 The Quality Assurance Oepartment analyzes nonconformance reports to identify,quality trends.
Trend reports, which highlight significant results,',are issued periodically to upper management for review and assessment.
15.2.6 When appropriate, cause of nonconforming conditions is determined and corrective action implemented to prevent recurrence.
NHPC-gATR"1 Page 16-1 Rev.
1 16.0 CORRECTIVE ACTION 16.1 POLICY Program and hardware conditions adverse to quality are identified promptly and corrected as soon as practical.
- 16. 2 IMPLEMENTATION 16.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
1&.2.2 16.2.3 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.
gA 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.
For significant conditions adverse to quality, corrective action includes determining the cause and extent of the condition and taking appropriate action to minimize similar problems in the future.
These identified conditions, their causes and corrective actions taken are reported to appropriate levels of management for review and assessment.
16.2.4 Conditions adverse to quality are evaluated For reportabi lity.
NHPC-gATR-1 Page 17-1 Rev.
1 17.0 UALITY ASSURANCE RECOROS 17.1 POLICY Quality assurance records are records that furnish documentary evidence of the quality of items and services.
Such documents are prepared by the originator and maintained by designated organizations.
They are accurate, complete and legible and are protected against
- damage, deterioration or loss.
They are identifiable and retrievable.
17.2 IHPLEMENTATION 17.2.1 17.2.2 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
Documents that furnish evidence of quality of items and services are generated and controlled in accordance with the procedures that govern those activities.
Such documents are considered records upon completion.
These records include:
- a. Results of reviews, inspections, surveillances,
- tests, audits and material analyses;
- b. gualification 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.
17.2.3 A document becomes a record when completed.
At that time it is designated as a permanent or nonpermanent record and is transmitted to file
~
Nonpermanent records have specified retention times.
Permanent records are maintained For the life of the item and/or plant as appropriate.
17.2.4 In-process documents are controlled by the originator until completed and transmitted to file.
NHPC-gATR-1 Page 17-2 Rev.
1 17.2.5 Records may be original documents or legible copies.
17.2.6 Authoriied personnel may issue corrections or supplements to records.
Procedures address acceptable methods of making corrections to records.
17.2.7 Traceability between the record and the item or activity to which it applies is provided.
17.2.8 Except for records that are stored as originals, such as radiographs and certain strip charts, records are stored in remote, dual facilities to prevent
- damage, deterioration or loss due to natural or unnatural causes.
When only the single original can be retained, appropriate fire-rated facilities or features are used.
NHPC-gATR-1 Page 18-1 Rev.
1 18.0 18.1 AUDITS D
POLICY
'i 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 IHPLEHENTATION 18.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
18.2.2 guality Assurance Oepartment 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 gA Program elements are audited at least once every two years.
18.2.4 Safety Review and Audit Board audits are performed as specified in the unit Technical Specifications.
18.2.5 Regularly scheduled audits are supplemented by special audits when appropriate.
Conditions which may warrant special audits include:
a.
Significant changes are made in the quality assurance program; b
When it is suspected that quality has been adversely affected; or c.
When an independent assessment of program effectiveness is considered appropriate.
18.2.6 Audits include an objective evaluation of quality-related practices, procedures, instructions, activities,
- items, documents and records to confirm that the quality assurance program is effective and properly implemented.
The following activities are included:
a.
Indoctrination and training programs; b.
Interface control between NMPC organizational units and between NMPC and its principal contractors;
NHPC+ATR-1
.Page 18-2 Rev.
1 c.
Corrective action; d.
MIITE 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.
18.2.7 Audit procedures and the scope, plans, checklists and results of individual audits are documented.,
18.2.8 Personnel selected for auditing assignments have experience or are given training commensurate with the needs of the audit and have no direct responsiblities in the areas audited.
18.2.9 Lead auditors are qualified and certified in accordance with approved procedures.
18.2.10 18.2.11 Audit data are analyzed to identify any quality deficiencies and assess the effectiveness of the quality assurance program.'udit 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 conditions adverse to quality.
Follow-up is performed by the guality Assurance Department to ensure that the appropriate corrective action is taken and is effective.
Such follow-up includes reaudits when necessary.
NHPC-QATR-1
~ Rev.
1 APPENDIX A REGULATORY COHHITHENTS Niagara Hohawk 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.
OOCUHENT REVISION/
DATE TITLE l.
10CFR50 Appendix 8
- 2. 'NSI/ANS-3.2 1982 Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
Administrati ve Control s and Quality Assurance for the Operational Phase of Nuclear Power Plants.
3.
Reg.
Guide 1.28 4.
ANSI/ASME NQA-1 5.
ANSI/ASHE NQA-2 6.
Reg.
Guide 1.37 7.
IEEE 336 1985 R3 1983 including 83 Addenda 1983 1973 RO 1973 1971 A-1 Quality Assurance Program Requirements (Design and Construction)
(Endorses ANSI/ANS NQA-1).
Quality Assurance Program Requirements for Nuclear Facilities.
Quality Assurance Requirements for Nuclear Power Plants.
Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants'endorses ANSI N45.2.1)
Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants Installation, Inspection and Testing Requirements For Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations.
e
NHPC-gATR-1
. Rev.
1 9.
Reg.
Guide 1.94 10.
ANSI N45.2.5 1976 Rl 1974 equality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete'nd Structural Steel Ouring the Construction Phase of Nuclear Power Plants.
(endorses ANSI N45.2.5)
Supplementary gA Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel Ouring the Construction Phase of Nuclear Power Plants.
APPENDIX 8 INTERPRETATIONS AND EXCEPTIONS OF APPENDIX A DOCUHENTS NHPC-0ATR-1
. Rev.
1 DOCUMENT INTERPRETATION/EXCEPTION
- l. 10CFR50 Appendix 8
2.
Reg.
Guide 1.28 a.
Introduction b.
Para.
3.1 None to design and construction of nuclear power plants..
Guidance for operations phase gA programs will be addressed in separate regulatory guides.
/ <<Il-n included by reference in ANSI/ANS-3.2, which applies to operations phase gA programs.
Therefore, Niagara Hohawk is committing to ANSI/ASHE NgA-1 for operations phase activities.
organization's gA Program should be audited at least annually
~..
~Exce tion guring the operations
- phase, applicable elements of the OA program will be audited at least once every two years, in accordance with ANSI/ANS-3.2.
- 3. ANSI/ANS-3.2 a.
General b.
Para.
1.1 0
referenced throughout ANSI/ANS-3'.
~Exec tion - tn lieu of the referenced standard NHPC is committed to ANSI/ASHE NOA-1-1983 including 1983 addenda.
"...all activities affecting those functions important to safety..."
~Exce tion -
NMPC is comnitted to a program based on controls applied to safety-related
- systems, components and services.
8-1
c.
Para.
3.4-.&
NHPC-QATR-1
. Rev.
1 hl >>h hl1 h
requirements For the qualifications of the Onsite Operations organization.
d.
Para.
4.0
~u-11 1
h NHPC will comply with those controls described in the applicable sections of the Nine Hile Point Units 1'nd 2
FSARs and the related technical specifications.
~
h h
hll h
requirements for reviews and audits.
e.
Section 5
General h
NHPC will comply with those controls described in the applicable sections of the Nine Hile Point Units 1
and 2 FSARs, the related technical specifications and Section 18.0 of this Topical Report.
h 1
1 ~"
section to the ANSI/ANS-3.2 Appendix for typical activities which should be covered by written procedures.
1 NHPC will comply with those controls described in the applicable sections of the Nine Hile Point Units 1 and 2
FSARs and the related technical specifications.
f.
Para.
5.2.116 for the maximum number of hours at a duty station.
g.
Para.
5.2.2 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.
specify approvals for temporary procedure changes.~
~
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.
8-2
NMPC-QATR-1 Rev.
1 h.
Para.
5.2-.7 Para.
5.2.16
>>h use of ANSI/IEEE-336-1980.
l standard Appendix A of this Topical Report commits to IEEE-336-1971.
i.
Para.
5.2.8 inspection program... shall include the establishment of a master surveillance schedule reflecting the status of all planned inplant surveillance tests and inspections.
schedules may exist for different programs such as in-service inspection
( ISI), pump and valve testing, and Technical Specification surveillance testing.
NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Onits 1
and 2
FSARs and the related technical specifications.
j.
Para.
5.2.9 to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.
the Security Plan.
k.
Para.
5.2.13.2 regulation or contract requirements, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.
required documentary evidence be available at the site prior to use, but not necessarily prior to installation.
This allows installation to proceed under specified conditions while any missing documents are being obtained, but prec ludes dependence.
on the item For safety purposes.
8-3
NHPC-QATR-1
.Rev.
1 l.
Para.
5.2:7 Para.
5.2.13.4 ANSI N45.2.8-1975, and ANSI/ASHY N45.2.2-1978.
m.
Para.
5.2.7
~Exec tion In lieu of the referenced standards NHPC is committed to ANSI/ASHY NQA-2-1983 parts 2.2 and 2.8 for nuclear safety related permanent plant modifica-tions and maintenance activities.
F ANSI/ASHY 03843-80.
~Exce tion In lieu of this referenced
- standard, NHPC will comply with the protective coating controls described in applicable sections of the Nine Hile Point Units 1
and 2 FSARs.
n.
Para.
5.2.15 h
administrative controls for the review, approval and control of procedures.
NHPC will comply with those controls described in the applicable sections of the Nine Hile Point Units 1
and 2
FSARs and the related technical specifications.
o.
Para.
5.2.16 equipment suitably marked to indicate calibration status.
~Exce tion In some instances size or locations of installed plant instrumentqtion 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 calibrati.on records.
(See also item 3h) p.
Para.
5.3 administrative controls for written procedures.
NHPC will comply with those controls described
-in the applicable sections of the Nine Hile Point Units 1
and 2
FSARs and. the related technica1 specifications.
8-4
q.
Para.
5.3;9.3 NHPC-OATR-1 Rev.
1 ANSI/ANS 3.7.1-1979, ANSI/ASME 3.7.2 and ANSI/ANS 3.7.3-1979 for additional guidance in preparation of Emergency Plan Implementing Procedures.
~Exce tion In lieu of ANSI/ANS 3.7.1,
.2, and
.3 described in ANSI/ANS 3.2, NHPC will comply with the emergency preparedness controls described in applicable sections of the Nine Hile Point Units 1
and 2 FSARs.
4.
ANSI/ASHE NQA-1 a.
Supplement 2S-2 f
Nondestructive Testing Recommended Practice No. SNT-TC-1A, June 1975 Edition and its applicable supplements shall apply as requirements to NOE personnel covered by this Supplement.
~Exce tion In lieu of the referenced standard NHPC is committed to ASNT Recommended Practice No.
SNT-TC-1A, June 1980 and its applicable supplements.
b.
Supplement 2S-3 quality assurance program audits shall be qualified in accordance with ANSI/ASME NgA-1. supplement 2S-3.
~Exec tion Personnel who perform 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 regulation or contract requirement, documentary evidence that items conform to procurement document requirements shall be available at the nuclear facility site prior to installation or use.
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.
8-5
~ d.
Supplement 7S-1 Para.
8.2.4 NHPC-QATR-1
. Rev.
1 requirements shall be mutually established by the purchaser and supplier.
5.
ANSIIt'ASHE NQA-2 a.
General b.
Part 2.1 responsibility for its gA program, NHPC establishes post-installation test requirements, giving due consideration to supplier recommendations.
Applicable parts of this standard will be applied to nuclear safety related activities pertaining directly to permanent plant modifications only, except for item
- 3. l. of this Appendix B.
I requirements for cleaning of fluid systems and associated components.
c.
Part 2.5 Epee tion - In lieu of the referenced NNA-2
- Section, NHPC is coomitted to Reg.
Guide 1.37 (see Appendix A item 6)
Il requirements For installation, inspection and testing of structural
- concrete, structural steel, soils and foundations.
d.
Part 2.15
~Exce tion - In lieu of the reFerenced NNA-2
- section, NHPC is comnitted to Reg.
Guide 1.94 (see Appendix A item 9) requirements for hoisting, rigging and transportation of items For nuclear power plants.
E~xce tion - In lieu oF the referenced NIEA-2
- section, NHPC is coamitted,to the requirements of applicable heavy load reports for Nine Hile Point Units 1
and 2
that have been approved by the NRC.
Unit 2's reports are a part of the FSAR (guestion and Answer section),
Unit 1's are a separate report.
B.6
NHPC-QATR-1
.Rev.
1 e.
Part 2.20 th <<i g
requirements for subsurface investigations for nuclear power plants.
~Exce tion - In lieu of the referenced NUA-2
- section, NHPC will comply with the subsurface controls described in the applicable sections of the Nine Nile Point Units 1
and 2 FSARs.
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 only (i.e. those under the direction of Nuclear Engineering).
b.
Para.
CD 3 flushes...
...shall be at least equivalent to the quality of the operating system water.
~Exce tion NNPC is comnitted to the stated requirement except for the oxygen content.
c.
Para.
C.4 precautions on chemical compounds that could contribute to intergranular cracking or stress corrosion cracking in austenitic stainless steel and nickel, based alloys.
~Exce tion Expendable materials, i.e.,
inks and related
- products, temperature indicating sticks,
- tapes, gurgled labels, wrapping materials (other than polyethylene),
water soluble dam materials, lubricants, NOT penetrant materials, and couplants that contact stainless steel or nickel alloy surFaces are in accordance with the Nine Hi le Point Unit 2
FSAR position For Regulatory Guide 1.38, Revision 2.
7.
Section 3.1.2 requirements For Class 8 cleanness.
~Exce tion - Upgraded piping systems and components. constructed of carbon steel materials will meet Class 8 cleanness requirements except for Final flushing/cleaning which may exhibit rust staining in accordance with Class C
cleanness requirements.
8-7
b.
Section 3.2 8.
IEEE-336 NHPC-gATR-1 Rev.
1 quality requirements for cleaning.
~Exce tion - Bue to seasonal conditions.
freshwater from Lake Ontario will have an allowable upper pH limit of 8.5.
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 of this appendix).
9.
Reg.
Guide 1.94 No Exceptions 10.
General Applicable parts of this standard wi 1 1 be applied to nuclear safety-related activities pertaining to major plant modifications only (i.e. those under the direction of Nuclear Engineering).
b.
Para.
5.3 v
requirements for assembly and erection.
~Exce tion - Bolt holes generally will not be burned (oxygen cut).
If holes must be
- burned, the following 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 ASTH A325 or'A490 bolts.
c.
Para.
5.4 the criterion For determining correct bolt length as at least two threads extending beyond the Face of the nut.
d.
Para'.5 Ence tion - For NMPC the criterion established For correct balt length is one thread extending beyond the Face of the nut.
R~euirement This paragraph gives requirements For welding inspection.
Ex~ca tion All reinforcing har 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 12.1.
8-8
NMPC-QATR-1
.Rev.
1 e.
Para.
6.2.2 requirements for evaluating mechanical (Cadweld) splice test results.
~Exce tion Exceptions 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.
8-9
TOPICAL QATAR-1, REV. 1 IONS UALI ASS CE PROG TOPICAL ORT FOR MILKPOINT NUC S
ION OPE December, 1985 NIAGARAMOHAN POWER CORPORATION Syncuse, N.Y.
T NIAGARA U MOHAWK
COPY 411