ML18038A352

Forwards Rev 6 to NMPC-QATR-1, QA Topical Rept for Nine Mile Point Nuclear Station Operations.

ML18038A352
Person / Time
Site:	Nine Mile Point
Issue date:	05/08/1991
From:	Jamila Perry NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17058A736	List: ML17058A735 ML18038A352
References
JP91-099-PRO-2, JP91-99-PRO-2, NMP1L-0581, NMP1L-581, NUDOCS 9105140055
Download: ML18038A352 (81)

Text

t ACCELERATED DISTRIBUTION DEMONST$&TION SYSTEM t

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 910514'0055 DOC. DATE: 91/05/08 NOTARIZED: NO DOCKET FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara Powe 05000220 50-410 Nine'.;Mile Point Nuclear Station, Unit 2, Niagara Moha 05000410 AUTH. NAME AUTHOR AFFILIATION PERRY,J.A.

RECIP.NAME Niagara Mohawk Power Corp.

RECIPIENT AFFILIATION

~C/P+

Document Control Branch (Document Control Desk)

SUBJECT:

Forwards Rev 6 to NMPC-QATR-l, "QA Topical Rept for Nine Mile Point Nuclear Station Operations." D DISTRIBUTION CODE: Q004D TITLE:

COPIES RECEIVED:LTR Topical Report, Amendment, Q ENCL Q(Docket/Utz.lz.ty or Correspondence SIZE: ~ 85Speci $

QA NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDl-1 LA 1 1 BRINKMAN,D 1 1 D OUDINOT,D 1 1 D

INTERNAL: ACRS 8 8 4DI4/LPEB1 0 1 1 OC/LFMB 1 1 REG FXEE 01 2 2 RGN1 FILE 1 1 EXTERNAL: IHS 1 1 NRC PDR 1 1 D

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE XVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 18

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JP91-099 PRO-2 NIAGARA MOHAWK POWER CORPORATION NIAGARA

~ MOHAWK 300 CRIC GOUI.CVARO WCST SYRACUSC, M.Y. I3202 JAMES A. PERRY YIaE msISENT-auiI.IIYAssuINMaE May 8, 1991 NMP1L 0581 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D.C. 20555 Re: Nine Mile Point Unit 1 Nine Mile Point Unit 2 Docket No. 50-220 Docket No. 50-410 DPR-63 NPF-69 Gentlemen:

Transmitted herewith is Revision 6 of the Quality Assurance Topical Report for Nine Mile Point Nuclear Station Operations (QATR-1). This revision incorporates changes to the Quality Assurance Program since the issuance of Revision 5. These changes are being submitted in accordance with the requirements of 10CFR50.54(a)(3). The revisions include the organizational changes of the Nuclear Division as well as a general update and a clarification of the accountability of Quality attaining functions. There are no basic changes to the Quality Assurance Program. The revised text has been noted by the application of vertical lines in the outer margins.

These changes can be described as general updates and clarifications that do not reduce previous commitments. If you have any questions, please contact the undersigned.

Sincerely, NIAGARAMOHAWKPOWER CORPORATION ames A. Perry Vice President - Quality Assurance IAP/la (8a7-048)

Attachment xc: Regional Administrator, Region 1 W. A. Cook, Senior Resident Inspector R. A. Capra, Project Directorate No. I-l, NRR D. S. Brinkman, Project Manager, NRR N. Blumberg, Chief, Performance Program Section Records Management 9i05i40055 9i0508 PDR 4DOCK 05000220

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NMPC-QATR-1 REVISION 6 QUALITYASSURANCE PROGRAM TOPICAL REPORT for NINE MILE POINT NUCLEAR STATION OPERATIONS

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9105140055 FEBRUARY 1991

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Niagara Mohawk Power Corporation Syracuse, New York

l 'E NIAGARA MOHAWKPOWER CORPORATION QUALITYASSURANCE PROGRAM TOPICAL REPORT NINE MILE POINT NUCLEAR STATION UNITS I AND 2 OPERATIONS PHASE MARY F H Revision 6 of this document is a general update and reflects the new Nuclear Division organization, which has been established since the last revision. There are no basic changes to the Quality Assurance Program. This reorganization reflects the new management approach of having independent management of each nuclear station, Vice esident - Quality As ance Vice esid t - Nuclear Generation Vice President - N ear Engineering Vice President - Nuclear upport

-z r-Executive 'ce Preside - Nuclear

NMPC-QATR-1 PAGE i REV. 6 TABLE F ONTENT

~SE ~TI N PA ES INTRODUCTION...

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

........ B B-11 Appendix C - Matrix of 10CFR50 Appendix B C-1 Criteria vs. NMPC QATR-1 and QA Procedures

1 l 0

NMPC-QATR-1 PAGE ii REV. 6 QUALITYASSURANCE PROGRAM TOPICAL REPORT NINE MILE POINT NUCLEAR STATION UNITS 1 AND 2 OPERATIONS PHASE INTR D I This Quality Assurance Program Topical Report fulfills the requirement for a description of the quality assurance program for the operations phase of the Nine Mile Point Nuclear Station Units 1 and 2. This Topical Report supersedes the previous Quality Assurance Program for Nine Mile Point Unit 1 and Chapter 17 of the Nine Mile Point Unit 2 FSAR relating to the operating phase.

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

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

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

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

1 1 QUALITYASSURANCE POUCY NMPC-QATR 1 PAGE iii REV. 6

'I pggposm: The purpose of this policy i,s to summarize the Company's position governing Quality Assurance responsibilities and accountabilities.

pot'.ICY: The Company policy regarding Quality Assurance matters is that:-

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

To strive to perform assigned work correctly the first time.

To provide facilities which are designed, constructed. tested and ayerated to high standards of ezcellence, with high assurance against failure or malfunctions, aa4 without undue risks to the health and safety of the public.

~ To insure early an4 timely ideatification and resolution of actual and potential problem areas in design, procurement, construction, testing, oyerations, maintenance and modification of facilities.

~ To comyly effectively with government regulations and established HNPC policies and ycocedures, ayylying a systematic, disciylined aa4 uniformed ayyraach to Quality Assurance.

2. Accountability for the quality of generatian, transmission and distributioa structures, systems, camyonents and services rests with the organisations and persons perfarming the quality attainiag functions of desiga,. construction and operation.

3. Accountability for determining that the generation, transmission and distribution structures, systems, comyonents and services da,

-in, fact, meet the stated requirements rests with the organizations and persans performing quality

'erification functions, such as design review>

document review, insyection, surveillance and audits.

AUTHORIZED! Si d't gn ur Department APPROVED: 4 il President

I 1 l

1 J

NMPC-QATR-1 PAGE 1-1 REV. 6 RGANIZATION 1.1 ~POLT Y Niagara Mohawk Power Corporation (NMPC) is responsible for establishing and implementing the Quality Assurance program for the operations phase of the Nine Mile Point Nuclear Station. Although authority for development and execution of specified parts of the program may be delegated to others, such as contractors and consultants, NMPC retains overall responsibility.

This section of the Quality Assurance Program Topical Report identified the NMPC organizations responsible for activities affecting the operation, maintenance or modification of safety-related structures, systems, or components, and describes the assigned authorities and duties for quality-attaining functions and for quality verification functions. Each organizational unit, including Nuclear Generation, Nuclear Engineering, Nuclear Support, Nuclear Controller, and the Quality Assurance Department, is responsible for the quality of its own work.

Quality assuring functions include establishing the Quality Assurance program and verifying that activities affecting the quality of safety related structures, systems, components, and services are performed in accordance with Quality Assurance program requirements. Quality assuring functions are performed by personnel within various organizational units as well as the Quality Assurance Department. 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 IMPI.KMENTATI N 1.2.1 R n ibili And Au h ri I. The Pre ident Nia ara M hawk Power o ration NMP, has ultimate responsibility for safe operation of the Nine Mile Point Nuclear Station. Authority and responsibility for establishing and implementing the Quality Assurance Program for station operations, maintenance, and modifications is delegated by the President to Corporate Officers, as described herein. The NMPC organization is shown in Figure 1-1. Departmental responsibilities are summarized in the Responsibility Matrix, Figure 1-2,

. NMPC-QATR-1 PAGE 1-2 REV. 6 1.2.2 Nuclear Division Res on ibiliti I. The Exec tive Vice Pr id nt Nucl r, reports to the President, and is responsible for the overall management of engineering, licensing, operation, maintenance and modification of the Nine Mile Point Nuclear Station.

1. The Mana er Executive Staff, is accountable to the Executive Vice President, Nuclear, and provides support for the overall Nuclear Division functions of Independent Assessment, Business Planning and Reporting, Quality First, Organizational Development, and External Interfaces.

2. The Nucl r mm ni i n n li Aff ir Direc or reports to the Executive Vice President, Nuclear, and is in charge of communications, public affairs and direction of the energy center.

A. The Vi Pre iden N le r ner i, reports to the Executive Vice President, Nuclear, and is responsible for safe and efficient operation, maintenance, and modification of the nuclear power station in compliance with station licenses, applicable regulations, and the Quality Assurance Program. The Vice President, Nuclear Generation delegates to the Plant Managers and other appropriate personnel authority for 'performance in accordance with the Quality Assurance Program.

Activities performed under the responsibility of the Vice President, 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,

1. The Plant Mana er ni l and ni 2 report to the Vice President, Nuclear Generation. They are responsible for:

(a) Outage Management (b) Health Physics (c) Operations (d) Maintenance (e) Chemistry (f) Tech Support

NMPC-QATR-1 PAGE 1-3 REV. 6 Mana er i e Servic reports to the Vice President, Nuclear Generation. The manager is responsible for:

(a),Industrial Safety (b) Environmental Protection (c) Technical Services (d) Administrative Services The Mana er Nuclear ecuri reports to the Vice President, Nuclear Generation, and has overall responsibility for Nuclear Security at Nine Mile Point Units 1 and 2.

B. The Vice Pre ident Nuclear En ineerin, reports to the Executive Vice President, Nuclear, and has overall responsibility for Nuclear Engineering support. See Figure 1-2 for primary and supporting Quality Assurance Program element responsibilities.

The Mana er nit I and nit II En ineerin reports to the Vice President, Nuclear Engineering, and are responsible for providing engineering services for the safe, reliable and economic operation of the Nine Mile Point Nuclear Station Unit I and Unit II, including adherence to applicable regulatory requirements.

Responsibilities include:

(a) Design (b) Project Management (c) Plant Evaluation (d) Site Engineering (e) Installation Services The Mana er Techn I ervice reports to the Vice President, Nuclear Engineering, and is responsible for:

(a), Program Development (b) Fuels (c) Safety Analysis (d) Health Physics Support (e) Design Basis Reconstitution

3. eneral u rvi r En ineerin Perf rm nce ervice, reports to the Vice President, Nuclear Engineering, and is responsible for:

(a) Engineering Cost and Scheduling (b) Engineering Training and Assessment (c) Administrative Services

NMPC-QATR-1

4. 'G p U Vi PAGE 1-4 REV. 6 id",N responsible for providing independent review of plant activities including r,

maintenance, modifications, and operational concerns. Performing analysis and providing recommendations of the activities reviewed.

C. The Vi Pre i n N cl reports to the Executive Vice President, Nuclear, and has overall responsibilities for:

a. Licensing

b. Information Management

c. Training

d. Emergency Preparedness

e. Human Resource Development

f. Procurement

1. The Mana er Licen in reports to the Vice President, Nuclear Support, and is responsible for all licensing activities.

A

2. Mana er Inform i n Man m n reports to the Vice President, Nuclear Support, and is responsible for control and administration of Information Systems including Records Management, Document Control, computer hardware/sofbvare and reporting capabilities.

3. The Mana er Trainin reports to the Vice President, Nuclear Support, and is responsible for:

(a) Operations Training (b) Technical/RP/Chemical/Maintenance Training (c) Administration/Records (d) Training Support

4. The Direct r Emer enc Pre re Support, and is responsible for:

n, reports to the Vice President, Nuclear (a) Drills (b) Facilities (c) Technical (d) Procedures

5. Mana er Human Re urce D v 1 m n under the general supervision of the Vice President, Nuclear Support, is responsible for managing and overseeing all Human Resource functions for the Nuclear Division including Employee Relations, Staff Development, and Leadership Development Programs.

NMPC-QATR-1 PAGE 1-5 REV. 6

6. Mana er Pr urement under the general direction of the Vice President, Nuclear Support, is responsible for:

(a) Purchasing (b) Materials Management (c) Procurement Specialists D. The Vice President u li A uranc, reports to the Executive Vice President, Nuclear, and is responsible for formulating, directing, implementing and controlling policies and procedures related to verifying the overall quality of design, operation, maintenance, and modification activities at Nine Mile Point Nuclear Station. The Vice President may delegate 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:

(a) Administering the evaluation and corrective action program for Deviation/Event Report (b) Audits (c) Surveillances (d) Inspections (e) Operations Experience Assessments (0 Internal SALP Type Assessments (g) Trend Analysis (h) Stop Work Authority (i) Performance of NDE such as ISI and Erosion/Corrosion

1. The Mana ers ali As urance eration nit I nd II, report to the Vice President, Quality Assurance and exercise control and direction over the Quality Assurance Program governing operations of their respective unit responsibilities.

2. The Mana er uali Assurance En ineerin, reports to the Vice President, Quality Assurance and provides a technical support function for Procurement, Fuels, Nuclear Engineering, and Licensing Activities.

3. The u ervi or uali Assurance Audit, reports to the Vice President, Quality Assurance, and has responsibility, authority, and accountability for QAD functions related to internal and external Quality Assurance Audits.

4. The Su ervisor uali Services reports to the Vice President, Quality Assurance and provides a support function for the Quality Assurance Department by preparing, controlling and issuing QA documents, report, and coordinating internal and external assessments.

NMPC-QATR-1 PAGE 1-6 REV. 6 E. The ntr lier Nuclear Divi i n, reports to the Executive Vice President, Nuclear, and is responsible for preparation, coordination and evaluation of Nuclear Division budgets, and reports, invoice review and support, and the management of Nuclear .

Division accounting and rate case audit activities and analysis.

A. The Vice Pr id n R i n I r i n n r, reportstotheSenior VicePresident, Regional, and is responsible for formulating, establishing and enforcing Meter and Test activities. See Figure 1-2 for primary and supporting Quality Assurance Program element responsibilities.

1. The eneral Mana er en r l Re i n, reports to the Vice President, Regional Operations Central. The staff includes the Superintendent Meter and Test who is responsible for the following safety-related functions.

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

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

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

B. The Vice President em Ele ri er i n, reports to the Senior Vice President, Regional, and is responsible for formulating, establishing and directing off-site Meter and Laboratory Facilities Department activities. See Figure 1-2 for primary and supporting Quality Assurance Program element responsibilities.

1. The Mana er Me er and La r Facilitie reports to the Vice President, System Electric Operations. The staff includes Supervisor, Standards Laboratory,

~i who is responsible for maintaining a facility for calibrating reference standards and for calibration and maintenance of portable measuring and testing equipment (M&TE).

C.th p U S i Vi P id - hidS The Manager Fuel Procurement and Contract Administration and the Manager Fuel Supply Analysis and Management are responsible for procurement of Nuclear Fuels and the admnistration of Nuclear Fuel contracts.

NMPC-QATR-1 PAGE 1-7 REV. 6 R ANIZATI HART NMPC PRESIDENT EXECUTIVE VP SENIOR VP SENIOA VP NUCLEAR " REGIONAL TECH OPERATIONS SERVICES EXECUTIVE PUBLIC MRNAGER VP SYSTEM VP REGIONAL FUEL SUPPLY ASSISTANT RFFAIRS EXECUTIVE ELEC OPS/CENTRRL DIRECTOR STRFF OPERATIONS VP HUCLEAR GENERATION ONE UNIT TWO VP NUCLERR VP DUALITY VP NUCLERR CONTROLLER LANT PLRNT ENGINEERING ASSURANCE SUPPORT HUCLERR MANAGER MANAGER DI VISIGH MANRGER MRNRGEA MANAGER OA MANAGER DIRECTOR NUCLEAR UNIT ONE OPERATIONS LICENSING HUCLERR SECURITY ENGINEERING UNIT OHE ACCOUNTING MANAGER MANRGEA MANAGER OA MANAGER DIRECTOR SITE UNIT TWO OPERATIONS INFORMATION BUDGETS G SERVICES ENGINEERING UNIT TWO MANAGEMENT REPORTS NUCL ~

MANAGER SUPERVISOR 'ANAGER RATE CRSE TECHNOLOGY OA AUDITS TRAINING AUDIT/SYS SERVICES . RHRLYST GEN SUP ENGR. MANAGER OA DIRECTOR CERC/WORKING PERFORMRHCE ENGINEER IHG EMERGENCY BUDGET SERVICES PREPRREDNESS ADMINISTRATOR SUPERVISOR SUPEA VISOR MANAGER HUMRN ISEG DUALITY RESOURCE SERVICES DEVELOPEMENT MRNAGEA PROCUREMENT

NMPC-QATR-1 PAGE 1-8 REV. 6 QUALITYASSURANCE PROGRAM RESPONSIBILITY MATRIX Regulatory Requirements Niagara Mohawk Power Corporation Department (f/::,:

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$ .3 3.4.2 3.$

HL Design 3, 3$ -1 $ .2.7.2 P R IV. Procurement 4, 4$ -1 $ .2.13.1 P R P V. Procedures $ .2.7 P P P,R P P P Vf. Doc. Control 6,6$ -1 5.2.1$ P P.R P P 7,7$ -1 $ .2.13.2 P P P VHI. Item Control 8,8$ -1 5.2.13.3 P R IX. Special Proc. 9,9$ -1 5.2.18 P P,R 5.2.12 X. Inspection 10,10S-2 $ .2.17 P,R P XI. Testing 11,11$ -1 5.2.19 P P,S 12, 12$ -1 $ .2.16 P P,S P R P XIII. Hand. gs Stg. 13 '38-1 5.2.13.4 P XIV. Operating 14 5.2.6 P R 5.2.14 XV. Nonconformance 15,15$ -1 5.2.14 P P R P,S XVI. Corrcctivo 16 5.2.11 P,R P XVH. Records 17,17$ -1 5.2.12 S,R P XVHI. Audit 18,18$ -1 4.$ P P NhfPC DFPA PROCFDURAI COVFRAGF. RF UIRED NO - Nuclear Generation P - Pirimaty Responsibility NE - Nuclear Engineering S - Support RcsponsibiTity NSP - Nuclear Support R ~ Review, Audit and SutvciUance hrr - hfeter gr, Teat Responsibility ML - Meter dc Laboratory QA - Quabty Asauranco NS ~ Nuclear Security FS Fuel Supply

NMPCQATR-I PAGE 2-1 REV. 6 ALITY ASSURANCE PROGRAM 2.1 ~PL~IY The Niagara Mohawk Power Corporation (NMPC) Quality Assurance program for the Nine Mile Point Nuclear Station operations phase is established by this Quality Assurance Program Topical Report and applies to safety-related activities, i.e., activities that affect the operation, maintenance or modification of safety-related systems, structures or components. The Quality Assurance program includes policies, procedures, instructions and other documents that implement the provisions of this Topical Report. The Quality Assurance program fulfills the requirements of the regulatory documents to which NMPC has committed.

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

Quality Assurance program status, scope, adequacy and compliance with 10CFR50, Appendix B are regularly reviewed by NMPC management through reports, meeting, review of audit results, and documented assessments performed by management teams.

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

2.2.2 This Quality Assurance Program Topical Report, organized to present the NMPC Quality Assurance program in the order of the 18 criteria of 10CFR50 Appendix B, states NMPC policy for each of the criteria and describes how the controls pertinent to each are carried out.

See Appendix C Matrix for a listing of each of the criteria of 10CFR50 Appendix B vs.

corresponding sections of this Topical Report and the related Quality Assurance Procedures.

Any changes made to this Topical Report that do not reduce the commitments previously accepted by the Nuclear Regulatory Commission (NRC) shall be submitted to the NRC at least annually. Any changes made to this Topical Report that do reduce the commitments previously accepted by the NRC will be submitted to the NRC and shall receive NRC approval prior to implementation. The submittal of the changes described above will be made in accordance with the requirements of 10CFR50.54.

NMPC-QA'IR-'1 PAGE 2-2'EV.

6 2.2.3 The Corporate Quality Assurance Policy authorized by the Vice President - Quality Assurance.

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

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 Vice President - Quality Assurance are as follows:

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

~Ex eri nc A. Fifteen (15) years of experience in technical fields such as quality control/assurance,

~

engineering, manufacturing, operations, or construction; and B. Five (5) years of experience in nuclear quality control/ assurance; and C. Five (5) years of experience in responsible managerial positions.

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

2.2.6 Quality Assurance Managers and Supervisors are required to have demonstrated their management competence through prior assignments of increasing responsibility in addition to the following qualifications:

~Educati n Bachelor's degree or equivalent in engineering or physical science.

NMPC-QA'IR-1 PAGE 2-3 REV. 6

~Ex ~ri n g A. Seven (7) years in Quality Assurance, design, manufacturing, construction, plant operations, or equivalent activities; and B. Three (3) years in the implementation of the nuclear Quality Assurance program.

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

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

Appropriate elements of the Quality Assurance Program Topical Report are applied to emergency plans, radiation protection procedures and radioactive waste shipment programs for the nuclear station.

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

A. Audits or surveillances on approximately 10 percent of radioactive waste shipments.

B. QA audits of the radioactive waste handling program.

C. Inspection of radwaste shipments by Quality Control.

s Audits identified in B. are performed by Quality Assurance Department personnel who are trained in Department of Transportation (DOT) and Nuclear Regulatory Commission radioactive waste handling requirements.

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

A. Nuclear Division Directives; and B. Nuclear Division Interface Procedures 2.2.10 The programmatic Regulatory Guides and ANSI Standards, and their applicable revisions, to which NMPC commits with regard to Quality Assurance matters and appropriate explanations of interpretations and exceptions are tabulated in Appendices A and B of this Topical Report.

2.2.11

~ ~

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

A. NMPC uses the criteria specified in Nuclear Engineering Procedures for identifying

~

structures, systems and components to which the Quality Assurance program applies;

t NMPC-QATR-1 PAGE 2-4 REV. 6 B. This identification process results in a Q-list, and Appendix B Determinations which identifies safety-related items for each unit. The Q-list is a controlled document. Safety-related items are determined by an 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, and others as specified by NMPC.

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. Work is planned in accordance with the proper revisions of applicable engineering and/or technical specifications; C. Specified equipment and/or tools, if any, are on hand to be used; D. Equipment and materials are in an acceptable status; E. Systems or structures on which work is to be performed are in the proper conditions or operational mode for the task; F. Current and approved instructions, procedures, and drawings for the work are available for use; G. Items and facilities that could be damaged by the work have been protected as required; and H. Provisions have been made for special equipment, environmental conditions, skills, controls, processes, tests and verification methods.

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

2.2.14 Responsibility and authority for planning and implementing indoctrination and training programs are delegated to each department. The training and indoctrination program provides for the following as appropriate:

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

B, Proficiency tests are utilized where appropriate to determine that individuals can perform their assigned tasks;

NMPC-QATR-1 PAGE 2-5 REV. 6 C. Personnel who perform inspections, examination, tests, audit and special process activities are trained and qualified in accordance with applicable requirements. Certificates of qualification (where required) designate specific areas of qualification and the bases for the qualification; D. Provisions are included for retraining, re-examination and recertification (where certification is required) to ensure that proficiency is maintained; and E. Training content and attendance records, and required qualification and certification records are maintained.

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

A. The Vice President- Quality Assurance is responsible for reporting on the status, adequacy and effectiveness of the NMPC Quality Assurance program, through the Nuclear Division Internal SALP Type Assessment Reports.

B. The Vice President - Quality Assurance regularly attends NMPC Nuclear Oversight Committee Meetings, Chief Executive Officers (CEOs) Meetings, and co-tenant meetings, and makes verbal presentations regarding quality-related matters. Minutes of these meetings are generally documented.

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

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

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

NMPC-QATR-'1 PAGE 2-6 REV. 6 2.2.18 The Quality First Program (Q1P) provides NMPC and contractor employees an opportunity to communicate their quality concerns regarding operation, maintenance or modification while keeping their identity confidential, ifthey desire, and to receive feedback regarding the results of investigations with respect to their concerns. Quality concerns determined to be valid are.

acted upon by the responsible organization and the actions are verified by Q1P personnel prior to closeout.

NMPC-QATR-1 PAGE 3-1 REV. 6 3.0 DEI N 3.1 P~LI ".Y Station modifications are accomplished in accordance with approved designs and procedures.

The .controls apply to preparation, review and revision of design documents, including the correct translation of applicable regulatory requirements and design bases into design, procurement and procedural documents. The controls apply to design work performed by contractors as well as by NMPC engineering and technical organizations.

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

3.2.2 Nuclear Engineering Department r'esponsibilities 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.

E. Material and Service Procurement Specifications

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

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

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

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 communication are established for controlling the flow of needed design information across design interfaces, including changes to the information as work progresses. Decisions and problem resolutions involving design interfaces are made by the Nuclear Engineering organization.

NM PC-QATR-1 3.2.7 PAGE 3-2 REV. 6 Design drawings and specifications are checked to verify the dimensional accuracy and completeness.

0 3.2.8 Modification design document packages are subject to audit by the Quality Assurance, Department to verify that the documents therein have been prepared, reviewed, and approved in accordance with procedures and that they contain the necessary quality assurance requirements. These requirements include any inspection and test requirements, quantitative and/or qualitative acceptance criteria and the requirements for documenting inspection and test results.

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

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

Design reviews are performed by single individual 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.

3.2.10 Qualification testing of prototypes, components or features is used when the ability of an item to perform an essential safety function cannot otherwise be adequately substantiated. This testing is performed before station equipment installation where possible, but always before reliance upon the item to perform a safety-related function. Qualification testing is performed under conditions that simulate adverse design conditions as determined by analysis, considering relevant operating modes. Test requirements, procedures and results are documented. Results are evaluated to assure that test requirements have been satisfied. Modifications are made 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.

NMPC-QATR-1 PAGE 3-3 REV. 6 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:

The supervisor did not specify a singular design approach or rule out certain design considerations, and did not establish the design inputs used in the design.

OR The supervisor is the only individual in the organization competent to perform the verification, and 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 Nuclear Engineering has overall control of design documents. Design output documents, and revisions thereto, are controlled by the design office (architect-engineer, vendor, contractor, consultant or Nuclear Engineering) responsible for the design work. Each design organization controls design documents in accordance with approved procedures that provide for review, approval, distribution and revision.

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

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NMPC-QATR-1 PAGE 4-1 REV. 6 4.0 PR REMENT D ENT C NTR L 4.1 PQL~I'.Y Procurement documents define the characteristics of items or services to be procured, identify applicable regulatory and industry codes or standards requirements, and specify supplier quality assurance program requirements to the extent necessary to assure adequate quality.

4.2 IMPLEMENTATI N 4.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

4.2.2 Procurement documents are reviewed and approved prior to issuance. Review includes verification that the necessary technical and quality requirements are specified.

NOTE: In certain situations, a purchase requisition may be released prior to review, provided proper restrictions are in place.

4.2.3 The responsible project engineer or requester performs bid evaluations in conjunction with Nuclear Purchasing.

4.2.4 Supplier and contractor selection is described in Section 7.0.

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

A. Material description and/or 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 and QA Programmatic requirements of ASME NQA-1 basic requirements and where appropriate or on an exception basis supplemental requirements consistent with the complexity and scope of the work.

D. A requirement for a documented quality assurance program, subject to Quality Assurance Department review and written concurrence; E. A requirement for the supplier to invoke applicable quality requirements on subtier suppliers;

jJ NMPC-QATR-1 PAGE 4-2 REV. 6 F. Provisions for access to supplier and subtier suppliers'acilities and records for inspections, surveillances and audits; G. Identification of documentation to be provided by the supplier (see paragraph 4.2.6);

H. 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."

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

A. Quality requirements 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.

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PAGE 5-1 REV. 6 5.0

~ IN TR TI N PROCED RE AND DRAWIN 5.1 PQLI( Y 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/ASME NQA-1 and ANSI/ANS-3.2 commitments contained in App. A of this QA Topical Report have been translated into procedural matrices to assure that implementing procedures cover the QA commitments.

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

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

5.2.3 The procedures'sed to control activities are listed in Section 2. They provide for implementation of the requirements contained in the committed standards. They describe responsibilities, controls and activities to be accomplished in carrying out commitments. When appropriate, they specify methods and techniques for performing required work.

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

THIS PAGE INTENTIONALLYLEFT BLANK NMPC-QATR-1 PAGE 6-1 REV. 6 6 0 D ME T NTROL 6.1 ~PLATY 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 IMPLEMENTATI N 6.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

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

A. Design documents (e.g., calculations, drawings, specifications, analyses) including documents related to computer codes; B. As-built drawings, procedures and related documents; C. Procurement documents; D. Instructions and procedures for activities such as fabrication, construction, modification, installation, inspection, test and station maintenance and operation; E. Procedures that implement the quality assurance program; F. Final Safety Analysis Report; G. "Reports of nonconformances; H. Unit Technical Specifications; I. Quality Assurance Program Topical Report.

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NMPC-QATR-1 PAGE 6-2 REV. 6 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; B. Identification of the organizations responsible for review, approval, issue, and revision; C. 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.

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

A. The documents are available as required at the work location prior to commencing work; and 'I B. Obsolete or superseded documents are removed from work areas and replaced by applicable revisions in a timely manner.

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

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NMPC-QATR-1 PAGE 7-1 REV. 6 7.0 NTR L F P RCHASED MATERIAL E IPMENT AND ERVI 7.1 PQLT( Y 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 2.2 7.2.1

~A performance.

General organizational responsibilities are described in Section 1.0, ORGANIZATION.

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

7.2.3 NMPC qualifies suppliers (including selected suppliers of commercial grade items) by performing a documented evaluation of their capability to provide items or services specified by procurement documents. Other means of evaluating supplier qualification include objective evidence of supplier's current quality performance, surveys performed by consultants, other utilities or other organizations such as Nuclear Procurement Issues Committee or ASME survey teams. Alternately, items or services may be procured from suppliers and accepted based on appropriate inspection or verification activity.

1. Procurement of safety-related material and equipment from suppliers is permitted when NMPC has performed a documented evaluation of their capability to provide items or services specified by procurement documents. However, such evaluation for items or services specified may not necessarily result in the supplier being placed on the Qualified Contractor List Database (QCLD) as a qualified vendor. In instances where:

A. Supplier is capable of meeting specific procurement document requirements by virtue of his ability to control critical manufacturing and functional processes and characteristics identified by Nuclear Engineering and Quality Assurance; B. Methods have been identified and documented by which QA will verify conformance to these requirements, and; C. The identified supplier is the only practical source; Procurement may be authorized, subject to satisfactory verification of the process and characteristics identified in (A&B) above.

NMPC-QATR-1 PAGE 7-2 REV. 6

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

A. Relatively simple and standard in design, manufacture 'and test; and B. Adaptable to standard or automated inspections or tests of the end product to verify quality characteristics after delivery; and C. Such that receiving inspection does not require operations that could adversely affect the integrity, function, or cleanness of the item.

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

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

7.2.5 Spare and replacement parts are procured in accordance with the following provisions to assure that their performance and quality are at least equivalent to those of the parts that will be replaced:

A. Specifications and codes referenced in procurement documents for spare or replacement items are the same or equivalent to those for the original items or to reviewed and approved revisions; B. Where quality requirements for the original items cannot be determined, requirements and controls are established by an engineering evaluation; and C. Any additional or modified design criteria, imposed after previous procurement of the item(s), are identified and incorporated.

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

7.2.7 Receipt inspections are performed to verify that items are undamaged and properly identified and that required supplier-furnished documentation is available and correct. In addition,

'epending 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.

NM PC-QATR-1 PAGE 7-3 REV. 6

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7.2.8

~ Suppliers'ertificates of conformance are reviewed for completeness and accuracy and are

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supplemented by receipt inspection to verify conformance to purchase requirements.

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

A. The installation is controlled in accordance with the requirements of Sections 15 and 16 of this Quality. Assurance Program Topical Report; and B. The installed items are readily removable or more readily protected by installation than by segregated storage; and C. The supporting documentation is reasonably expected to arrive prior to the use of the equipment or material.

In no case shall material or equipment be relied upon for its safety function without receipt of proper documentation.

THIS PAGE INTENTIONALLYLEFT BLANK NMPC-QATR-1 PAGE 8-1 REV. 6 8.0 IDENTIFI ATION AND CONTROL OF MATERIALS PARTS AND M NENTS 8.1 POLI+Y Materials, parts, and components (items) are identified and controlled to prevent their inadvertent use. Identification of items is maintained either on the items, their storage areas or containers, or on records traceable to the items.

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

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

8.2.3 Items are identified by physically marking the items, storage area, or containers or by maintaining records traceable to the items. The method of identification is such that the quality of the items is not degraded.

8.2.4 Items are traceable to applicable drawings, specifications, or other pertinent documents to ensure that only correct and acceptable items are used. Verification of traceability is performed and documented prior to release for fabrication, assembly, or installation except as provided in Section 7.0.

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~PL~I'.Y L OF PE IAL PRO E SE NMPC-QATR-1 PAGE 9-1 REV. 6 Special processes are controlled and are accomplished by qualified personnel using qualified procedures and equipment in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

9.2 9.2.'1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

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

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

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

9.294 Special process procedures are prepared by personnel with expertise in the discipline involved.

The procedures are reviewed for technical adequacy by other personnel with the necessary technical competence, and are qualified by testing, as necessary.

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

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

NMPC-QATR-1 PAGE 9-2 REV. 6 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 The Quality Assurance Department performs audits, inspection and surveillance of special processes to assure they are satisfactorily performed when specified by applicable inspection planning and/or site procedures. Such inspections, surveillances and audits include verification that process data are recorded as required, are within specified limits and are performed in accordance with applicable requirements.

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

17. Qualifications of procedures, personnel, and equipment will be filed and reviewed periodically, and when required by governing codes or standards, the qualification records will be updated or revised as appropriate.

Examples of typical records that may be specified are:

A. Procedure, personnel and equipment qualification test results in accordance with applicable 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.

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PAGE 10-1 10.0

~ ~0 REV. 6 10.1 ~PLATY Inspections of items or activities are performed to verify their conformance with specified requirements. The inspections for certifying acceptance are performed by people other than those who perform or supervise the work being inspected. Direct inspection, process monitoring, or both, are used as necessary. Hold points and/or witness points are used as necessary to ensure that inspections are accomplished at the correct points in the sequence of work activities.

10.2 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 in accordance with established procedures. Documentation of inspection planning identifies the following as applicable:

A. Characteristics and activities to be inspected; B. Inspection organization; C. Accept/reject criteria; D. Hold points and/or witness points; 0

E. Methods; F. Provisions for recording objective evidence of inspection results; G. Specify measuring and test equipment of the necessary accuracy for performing inspection.

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

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

NMPC-QATR-1 PAGE 10-2 i REV. 6 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.

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

10.2.4 Hold points are designated as mandatory inspection 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 Witness points require sufficient notification of the specifying organization prior to performance of the specified activity.

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

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

10.2.8 Inspections are normally performed by Quality Assurance Department personnel. Inspections

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

A. The quality of the work can be demonstrated through a Post Maintenance test when the activity involves breaching a pressure retaining item; and B. The qualification criteria for inspection personnel are reviewed by the Quality Assurance Department.

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PAGE 10-3 REV. 6 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; D. Type of observation; E. Results or acceptability; F. Reference to information on action taken on nonconformances to.resolve any discrepancies noted.

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11. 1 PQLET,.'Y Testing is performed to demonstrate that items will perform satisfactorily in service. The testing is performed in accordance 'with written procedures that incorporate specified requirements and acceptance criteria. The test program includes qualification, acceptance, pre-operational, startup, surveillance and post-maintenance tests. These parameters, including any prerequisites, instrumentation requirements and environmental conditions, are specified and met. Test results are documented and evaluated.

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

11.2.2 Tests are performed in accordance with procedures and criteria that designate when tests are required and how they are to be performed. Such testing includes the following:

A. Qualification tests, as applicable, to verify design adequacy in accordance with Section 3.0; B, Tests of equipment and components to assure their proper operation prior to delivery or pre-operational tests; C. Special 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. Post Maintenance tests.

NM PC-QATR-1 PAGE 11-2 .

REV. 6 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; C. Verifying that test prerequisites have been met; D. Instructions for performing the test; E. Any witness and hold points; F. Acceptance criteria; G. Documenting or recording test data and results; and H. Verification of completion.

11.2.4 Test procedures and instructions are reviewed by the applicable organizations for technical content. The Quality Assurance Department verifies through surveillance or audits that Quality Assurance program requirements are being met and that test results are documented, evaluated and accepted by responsible personnel.

11.2.5 Test records contain the following where applicable:

A. Item tested and type of observation; B. The date and results of the test; C. Information related to conditions adverse to quality; D. Data recorder identification; E. Evidence as the acceptability of the results; and F. Action taken to resolve any deviations noted.

NMPC-QATR-1 PAGE 12-1',

REV. 6 12.0 NTR L F MEA RIN AND TEST E IPMENT

12. 1 ~PL~IY Measuring and test'equipmerit is identified, controlled, calibrated and adjusted at specified intervals to maintain accuracy within prescribed limits.

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

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

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

12.2.4 Labels are attached to measuring and test equipment to display the next calibration due date.

Where labels cannot be attached, a control system is used that identifies to potential users any equipment beyond the calibration due date.

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

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

12.2.7 Secondary standards normally have a greater accuracy than the equipment or installed plant instrumentation being calibrated. Standards with the same accuracy may be used when shown to be adequate for specific calibration requirements. The basis for this acceptance is documented and is approved by responsible management.

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.

THIS PAGE INTENTIONALLYLEFT BLANK NM PC-QATR-1 PAGE 13-1 REV. 6 13.0 HANDLIN TORAGE AND HIPMENT 13.1 ~PLI( Y 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 13.2 ~N 13.2.1 damage or loss are identified and controlled. Controls are achieved through the use of appropriate procedures.

General organizational responsibilities are described in Section 1.0, ORGANIZATION.

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

A. Cleaning, to assure that required cleanliness levels are achieved and maintained; B. Packaging and preservation, to protect against damage or deterioration. When necessary, these procedures provide for special environments such as inert gas atmospheres, specific moisture content levels and temperature levels;

. C. Handling, to preclude damage or safety hazards. Routine inspection of handling equipment is included; D. Storing, to minimize the possibility of loss, damage or deterioration of items in storage, including consumables such as chemicals, reagents and lubricants. Storage procedures also provide methods to assure that items having limited shelf life are not used. after their expiration date; and E. Marking and labeling of items for packaging, shipment and storage is to be adequate to identify the shipment and to indicate the need for special environments and special control.

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REV. 6 14.0 IN PE TI N TE T AND PERATIN TAT 14.1 ~POLI Y 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.

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

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

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

THIS PAGE INTENTIONALLYLEFT BLANK NMPC-QATR-1 PAGE 15-1, REV. 6 15.0 NON NF RMING MATERIA PART OR M NENT 15.1 ~PLATY 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.

Niagara Mohawk utilizes various systems reflected in departmental procedures to identify, control and disposition nonconforming conditions in materials, parts, components or services.

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

15.2.2 Nonconformances are documented in accordance with departmental procedures, are dispositioned, and notification is made to affected organizations.

15.2.3 Nonconforming items are reviewed for reportability.

15.2.4

~ ~ Personnel authorized to disposition, conditionally release and closeout nonconformances are

~

designated. ~

15.2.5 Nonconforming items are identified by marking, tagging or segregating or by administrative controls which do not adversely affect the end use of the item.

15.2.6 Documentation describes the nonconformance, the disposition of the nonconformance and the inspection requirements. It also includes signature approval of the disposition.

15.2.7 The Quality Assurance Department reviews nonconformance documentation to assure completeness and control over nonconforming conditions.

15.2.8 Items that have the disposition, of "repair" or "use-as-is" require technical justification documented by Nuclear Engineering and as-built records reflecting the accepted deviation.

15.2.9 Repaired, reworked, and replacement items are inspected and tested in accordance with the original inspection and test requirements or alternate acceptance criteria that have been documented as acceptable by the responsible design organization.

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

NM PC-QATR-1 PAGE 15-2, REV. 6 15.2.11 Prior to the initiation of pre-operational testing on an item, nonconformances are corrected or evaluated for possible impact upon the item or the testing program.

15.2.12 Documents that identify nonconformances are evaluated as prescribed in departmental procedures to identify quality trends.

15.2.13 Reports, based on the results/inspection of Quality Assurance activity, and which highlight significant results, are issued periodically to Senior Nuclear division and Corporate Management for review and assessment.

15.2.14 For significant conditions adverse to quality, cause of nonconforming conditions and'corrective action implemented to prevent recurrence in accordance with Section is'etermined 16.2.3.

NMPC-QATR-1 PAGE 16-1 REV. 6 16.0 CORRECTIVE A TION 16.1 ~PLI( Y a

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.

16.2.2 Controls are established and documented in departmental procedures to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, defective items, or nonconformances are identified and documented and that appropriate corrective action is taken.

The controls also assure that corrective action is implemented in a timely manner. Verification is required on adequacy and implementation of corrective action.

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

16.2.4 Conditions adverse to quality are evaluated for reportability.

THIS PAGE INTENTIONALLYLEFT BLANK NMPC-QATR-1 PAGE 17-1 REV. 6 ALITY A AN E RE RD 17.1 PQLI~Y Quality assurance records are records that furnish documentary evidence of the quality of items and services. Such documents are prepared by the originator and maintained by designated organizations. They are accurate, complete and legible and are protected against damage, deterioration or loss. They are identifiable and retrievable.

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

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

A. Results of reviews, inspections, surveillances, tests, audits and material analyses; B. Qualification of personnel, procedures and equipment; C. Operating Logs; D. Maintenance and modification procedures and related inspection results; E. Reportable occurrences; F. Records required by the stations'echnical Specifications; G. Nonconformance reports; H. Corrective action reports; and I. Deviation Event Reports; and J. 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.

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

17.2.6 Authorized personnel may issue corrections or supplements to records. Procedures address

NMPC-QATR-1 PAGE 17-2 >

REV. 6 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.

NM PC-QATR-1

~

PAGE 18-1 REV. 6 18.0 ~AD~IT

~

18.1 ~POLT Y 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 IMPLEMENTATI N 18.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.

18.2.2 Quality Assurance Department audits are performed:

A. To provide a comprehensive independent verification and evaluation of quality-related procedures and activities; and B. To verify and evaluate the quality assurance

~ programs, procedures, and activities of suppliers. ~

~

18.2.3 Audits are performed in accordance with established schedules. Applicable QA Program elements are audited at least once every two years.

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

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

A. Significant changes are made in the quality assurance program; B. When it is suspected that quality has been adversely affected; or C. When an independent assessment of program effectiveness is considered appropriate.

NMPC-QATR-1 PAGE 18-2 ~

REV. 6

~ ~ ~ ~

Audits include an objective evaluation of quality-related practices, procedures, instructions,

~

18.2.6 ~

activities, items, documents and records to confirm that the quality assurance program is effective and properly implemented. The following activities are included:

A. 'Indoctrination and training program; B. Interface control between NMPC organizational units and between NMPC and its principal contractors; C. Corrective action; D. MEcTE 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 responsibilities in the areas audited.

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

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

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

NMPC-QATR-1 REV. 6 APPENDIX A REGULATORY COMMITMENTS Niagara Mohawk Power Corporation commits to the requirements of the regulations and industry standards identified in Appendix A subject to the stated interpretations and exceptions in Appendix B.

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

2. ANSI/ANS-3.2 1982 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants

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

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

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

6. Reg, Guide 1.37 1973, RO Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (endorses ANSI N45.2. 1)

7. ANSI N45.2. 1 1973 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants A-1

NMPC-QATR-1 REV. 6 IEEE 336 1971 Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations.

Reg. Guide 1.94 1976, Rl Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Steel During the Construction Phase of Nuclear Power Plants - (endorses ANSI N45.2.5)

ANSI N45.2.5 1974 Supplementary QA Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants A-2

NMPC-QATR-1 REV. 6 APPENDIX 8 INTERPRETATIONS AND EXCEPTIONS OF APPENDIX A DOCUMENTS

1. 10CFR50 Appendix B None

2. Reg. Guide 1.28

a. Introduction RMIil- Thlof and construction g \ Q g ld PPII d lg nuclear power plants. Guidance for operations phase QA programs will be addressed in separate regulatory guides.

h~i-ANRIIARMRNQAI I I I dMby reference in ANSUANS-3.2, which applies to operations phase QA programs. Therefore, Niagara Mohawk is committing to ANSUASME NQA-1 for operations phase activities.

b. Para. 3.1 Mggil - APPR bl I f g Program should be audited at least annually...

QA

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

c. Para 3.2 - Th ppg ~ h Id ld audit its supplier's quality assurance program on a triennial basis or arrange for such an audit.

NMPQ M I h q NlflM phil involved in active procurements are audited every three years. However, a tolerance of one quarter of a year can be applied. This allows for scheduling flexibilitywhich may be required due to performance considerations to resolve any open items from vendor audits without the removal of the supplier from the Qualified Contractors List.

NMPC-QATR-1 .

REV. 6

d. Section B RM Ill D; P .9 I

"Personnel performing inspection and testing that are qualified to the guidance contained in Reg. Guide 1.8 need not be qualified in accordance with the requirements of NQA-l. It is not the intent that such personnel be qualified in accordance with both Reg. Guide 1.8 and NQA-1".

-NMPCh I M ANSI.I, bib references ANS 3.1 for certification and qualifications of operating plant personnel. Consistent with the guidance provided in Reg. Guide 1.28 personnel performing inspection and test, who are qualified in accordance with requirements of ANS 3.1, need not be qualified in accordance with NQA-1.

ANSI/ANS-3.2 ANSIIASMR NQA-I-1979 I f

a. General throughout ANSI/ANS-3.2.

E~Exce i n - in lieu of the referenced standard NMPC is committed to ANSI/ASME NQA-1-1983 including 1983 addenda.

b. Para. 1.1 -TN p g ph f "...Nl affecting those functions important to safety..."

~Exce i~ti - NMPC is committed to a program based on controls applied to safety-related systems, components aild services.

c. Para. 3.4.2 RMIil-Thl p g ph bg h for the qualifications of the On-Site Operations organization.

I~li comply with

-I those II controls fh described in I, NMPC the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

d. Para. 4.0 RMgig-11 9 g Ph bb' for reviews and audits.

-I II f h I,NMPC RI comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs, the related technical specifications, and Section 18.0 of this Topical Report.

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NMPC-QATR-1 REV. 6

e. Section 5 R~i-2 f I d Ihl pl the ANSUANS-3.2 General Appendix for typical activities which should be covered by written procedures.

3

-I II fd " INMPC M comply with those controls described in the applicable sections of the Nine Mile Point Unit 1 and 2 FSARs and the related technical specifications.

f. Para..5.2.1.6 -Thl Id I f h maximum number of hours at a duty station.

I~li -I II f h I NMPC comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

g. Para. 5.2.2 R~i P fed d phd ff approvals for temporary procedure changes.

I II fh I NMC RI comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

h. Para. 5.2.7 -Thl p 2 ph II h f ANSI/IEEE 336-1980.

I~li -I ~ fh f M d d Appendix A of this Topical Report commits to IEEE 336-1971.

i. Para. 5.2.7 ANSVANS-3.2-S2 f ANSI N45.2.5-1978 concerning design and construction activities associated with modifications.

~Exec ii n - In lieu of the referenced standard NMPC is committed to ANSI N45.2.5-1974 (see Appendix A item 10).

j. Para. 5.2.7 -III p 2 ph f ANSIN4222-1975.

E~xe ~irt - In lieu of the reference standard NMPC is committed to ANSI/ASME NQA-2-1983 part 2.8 for nuclear safety related permanent plant modifications and maintenance activities.

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NMPC-QATR-1 .

REV. 6

k. Para. 5.2.7 yhl p S ph I ANSIIASMN D3 843-80.

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

1. Para. 5.2.8 RMIil-A III IS dl P program ... shall include the establishment of a master surveillance schedule reflecting the status of all planned

-Id p d for different programs such as inplant surveillance tests and inspections.

hM I in-service y

inspection gSI),

pump and valve testing, and Technical Specification surveillance testing.

-I R Ih I,NMPC M comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related Technical Specifications.

m. Para. 5.2.9 -P M hdlh d I Nd supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.

I~li Plan.

-PMI I dd Ml h S 'y

n. Para. 5.2.10 RMNN-IM p 'S ph I ANSI/ASMN N45.2.1-1980.

~Exec tion - In lieu of this revision of the referenced standard, NMPC is committed to ANSI/ASME N45.2.1-1973, (Appendix A, Item 7).

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NMPC-QATR-1 REV. 6

'Et)iii!i'Mii't'NEER'Egag'ATttt'¹EE'Cgpi'gibgft iii'::;-'::ll'i'll-::.";'*':--

o. Para. 5.2.13.2 -Wh M'Mbpl, gl 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.

I~i-NMPC M I g h 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.

p. Para. 5.2.13.4 - Thi p g ph f ANSIIASME N45.2.2-1978.

~Ex e )~in - In lieu of the referenced standard NMPC is committed to ANSUASME NQA-2-1983 part 2.2 for nuclear safety related permanent plant modifications and maintenance activities.

q. Para. 5.2.15 R~i-Thi p g ph blih I d controls for the review, approval and control of procedures.

-I li f h* I NMPC Rl comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

r. Para. 5.2.16 -R d hdlb d dMI~

suitable marked to indicate calibration status.

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

s. Para. 5.2.16 Thi p 'g ph f ANSIIIEEE 336-1980.

I~li -I I'g f M NMPC commits to IEEE 336-1971. (See Appendix A, d d item 8).

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NMPC-QATR-1.

REV. 6

t. Para. 5.3 S~i-TN controls for p g ph written procedures.

hl/h d

-I g IN I NNPC comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.

u. Para. 5.3.9.3 S~i-IN p g ph gg ANSI/ANSSTI-1979, ANSVANS 3.7.2 and ANSVANS 3.7.3-1979 for additional guidance in preparation of Emergency Plan Implementing Procedures.

~Exce i n - In lieu of ANSVANS 3.7.1,3.7.2 and 3.7.3 described in ANSI/ANS 3.2, NMPC will comply with the emergency preparedness controls described in applicable sections of the Nine Mile Point Units 1 and 2 FSARs.

ANSVASME NQA-1 S ppl*

• I-Sl ~ d

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

I~i-C I<< lag ld I SNi Regulatory Guide 1.28, personnel qualified in accordance with requirements of ANS 3.1 need not be qualified in accordance with NQA-1.

b. Supplement 2S-2 S~i-Ih A lip IN Testing Recommended Practice No. SNT-TC-1A, June d

1975 Edition and its applicable supplements shall apply as requirements to NDE personnel covered by this Supplement.

~Ex @~i'll - In lieu of the referenced standard NMPC is committed to ASNT Recommended Practice No. SNT-TC-1A, June 1980 and its applicable supplements.

c. Supplement 2S-3 -P I hp lp N/I assurance program audits shall be qualified in accordance with ANSI/ASME NQA-1 supplement 2S-3.

~Exec ion - 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.

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NMPC-QATR-1 REV. 6

d. Supplement 7S-1 R~i - RR ~' by d, g I Para. 8.1 contract requirements, documentary evidence that items conform to procurement document requirements shall be available at the nuclear facility site prior to installation or

~li use.

'l

"-Rbddd Wi h h Wi d 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.

e. Supplement 7S-1 ...p -I II " hll

~li Para. 8.2.4 be mutually established by the purchaser and supplier.

-I llgl I' lbllly for its QA program, NMPC establishes post-installation test requirements, giving due consideration to supplier recommendations,

f. Supplement 17S-1 R~i ~ -11 Ill I g p bl g Para. 4.4.2 to the criteria of 4.4.1 above for a single facility... (b) 2 hr. fire rated class B file containers meeting the requirements of NFPA 232-1975;...

~Ex ~i' When temporary storage of records (such for processing, review, or use) is required by an as organization's procedures, the records shall be stored in a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rated container. The procedures shall specify the maximum allowable time limit for temporary storage.

The container shall bear a UL label (or equivalent) certifying 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire protection or be certified by a person competent in the technical field of fire protection.

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NMPC-QATR-1.

REV. 6 iistiiiiii:--:,-i!i

g. Supplement 17S-1 -gh ill 1 g 1 hl Para. 4.4.2 and to the criteria of 4.4.1 above for a single facility: (a) 2 Footnote hour fire rated vault meeting NFPA 232-1975', (b) 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire rated Class B file containers meeting the requirements of NFPA 232-1975', or (c) 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire rated file room meeting the requirements of NFPA 232-1975'.

with the following additional provisions:

'FPA 232-1975 is contained in Volume 9 of the National Fire Codes published by the National Fire Protection Association, 470 Atlantic Avenue, Boston, MA 02210.

~Exce ion - The following are acceptable alternatives to the criteria of Para. 4.4.1 above for a single facility: (a) 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire rated vault meeting NFPA 232-1986 or NFPA 232AM-1986 or both (b) 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire rated Class B file containers meeting the requirements of NFPA 232-1986 or NFPA 232AM-1986 or both with the following additional provisions.

'FPA 232-1986 and NFPA 232AM-1986 are published by the National Fire Protection Association, Batterymarch Park, Quincy, MA 02269 ANSI/ASME NQA-2 Applicable parts of this standard will be applied to

a. General nuclear safety related activities pertaining directly to permanent plant modifications only, except for items 3o.

and 3j. of this Appendix B.

b, Part 2.1 R~i"of fiuid -111 'gl QA ll 1 cleaning systems and associated components.

~Ex e i>iin - In lieu of the referenced NQA-2 Section, NMPC is committed to Reg. Guide 1.37 (see Appendix A item 6).

c. Part 2,5 Rhl g'" Q 1"'

installation, inspection and testing of structural concrete, structural steel, soils and foundations.

Ence tion - In lieu of the referenced NQA-2 section, NMPC is committed to Reg. Guide 1.94 (see Appendix A item 9).

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NMPC-QATR-1 REV. 6

d. Part 2.15 ~Ri -Thl 'l QA Wi hoisting, rigging and transportation of items for nuclear power plants.

R

~Exce )~ti i1 - In lieu of the referenced NQA-2 section, NMPC is committed to the requirements of applicable

'l heavy load reports for Nine Mile Point Units 1 and 2 that have been approved by the NRC. Unit 2's reports are a part of the FSAR (Question and Answer section). Unit 1's are a separate report.

e. Part 2.20 -TR QA ll f subsurface investigations for nuclear power plants.

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

Reg. Guide 1.37 Applicable parts of this Reg. Guide will be applied to

a. General nuclear safety-related activities pertaining to major plant modifications and maintenance within the scope of paragraph 5.2.10 of ANSI/ANS 3.2-82 only (i.eh those s under the direction of Nuclear Engineering).

b. Para. C.3 -Th h Ill'f fl lh h

...shall be at least equivalent to the quality of the

~

operating system water.

Excg~il1 - NMPC is committed to the stated

c. Para. CR4 RTh requirement except for the oxygen content.

p g phg chemical compounds that could contribute to p

intergranular cracking or stress corrosion cracking in austenitic stainless steel and nickel based alloys.

Encei n - Expendable materials, i.e., inks and related products, temperature indicating sticks, tapes, gummed labels, wrapping materials (other than polyethylene),

water soluble dam materials, lubricants, NDT penetrant materials, and couplants that contact stainless steel or, nickely alloy surfaces are in accordance with the Nine Mile Point Unit 2 FSAR position for Regulatory Guide 1.38, Revision 2.

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NMPC-QATR-1 REV. 6

7. ANSI N45.2.1-1973 Yh g h l l

a. Section 3.1.2 Class B cleanness.

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

b. Section 3,2 R~i" for.

requirements Yhi cleaning.

" gi" l lilY

~Ex e~ti - Due to seasonal conditions, freshwater from Lake Ontario will have an allowable upper pH limit of 8.5.

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

9. Reg. Guide 1.94 No exceptions

10. ANSI N45.2.5-1974 Applicable parts of this standard will be applied to a, General nuclear safety-related activities pertaining to major plant modifications only (i.e., those under the direction of

b. Para. 5.3 ~-hh' Nuclear Engineering).

assembly and erection.

g Phg" R l"' l Ence tion - Bolt holes generally will not be cut). If holes must be burned, the following burned'oxygen criteria will be followed: a) after cutting, the edges of the cut will be ground or reamed back a minimum of 1/32 in., and b) the final bolt hole dimensions will not exceed those given in the Specification for Structural Joints using ASTM A325 or A490 bolts.

c. Para. 5.4 R~i-Yhi p g ph hlih h determining correct colt length as at least two threads extending beyond the face of the nut.

Ence ti n - For NMPC the criterion established for correct bolt length is one thread extending beyond the face of the nut.

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NMPC-QATR-1 REV. 6

d. Para. 5.5 Th p g phg l " l welding inspection.

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

e. Para. 6.2.2 ~gi -Thl p g phgl h ll evaluating mechanical (Cadweld) splice test results.

k

~Ex giin - 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. (Superseded by Reg. Guide 1.136.)

THIS PAGE INTENTIONALLYLEFT BLANK NMPC-QATR-1 REV. 6 APPENDIX C MATRIX OF 10CFR60 APPENDIX B CRITERIA VS. NMPC QATR-1 AND QA PROCEDURES 10CFR50, Appendix 8 NMPC QA Program NMPC QA Procedures by QA Criteria Topical Report Section Number Organization QAP 1.01 QAP 1.03, QAP 2.01, QAP 2.02, QA Program QAP 2.10, QAP 2.30, QAP 2.60 Design Control QAP 6.20 IV. Procurement QAP 4.01, QAP 4.10 Document Control V. Instructions, Procedures and QAP 5.01, QAP 5.02 Drawings VI. Document Control QAP 6.01, QAP 6.20 VII. Control of QAP 7.20, QAP 7.30, QAP 7.22 Purchased Material VIII. Identificaion and QAP 4.10, QAP 10.03, QAP Control of Materials and Parts 10.30, QAP 10.31 IX. Control of Special QAP 9.01, QAP 10.31 Processes 4

QAP 10.03, QAP 10.30, QAP X. Inspection 10 10.31 QAP 10.03, QAP 10.30, QAP XI. Test Control 10.31 XII. Calibration of QAP 12.10 Equipment XIII. Handling, Storage QAP 10.03, QAP 10.30, QAP 13 and Shipping 10.31 XIV. Inspection, Testing QAP 10.30, QAP 10.31, QAP and Operating 14 1 5.01, QAP 1 5.02 Status XV. Nonconforming 15 QAP 15.01, QAP 15.02 Material QAP 15.02, QAP 16.03, QAP XVI. Corrective Action 16.05, QAP 16.04, QAP 16.20, QAP 16.70 XVII ~ QA Records 17 QAP 17.10 XVIII~ Audits 18 QAP,1 8.10 C-1

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