ML18038A506
| ML18038A506 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/31/1992 |
| From: | Firlit J, Jamila Perry, Sylvia B NIAGARA MOHAWK POWER CORP. |
| To: | |
| Shared Package | |
| ML18038A505 | List: |
| References | |
| NMPC-QATR-1, NMPC-QATR-1-R07, NMPC-QATR-1-R7, NUDOCS 9204010199 | |
| Download: ML18038A506 (80) | |
Text
NMPC-QATR-1 REVISION 7 QUALITYASSURANCE PROGRAM TOPICAL REPORT for NINE MILEPOINT NUCLEAR STATION OPERATIONS
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COPY No:
MARCH 1992
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NIAGARAMOHAWKPOWER CORPORATION QUALI'IV TOPICALREPORT NINE MILEPOINT NUCLK4RSTATIONUNITS 1 AND 2 OPERATIONS PHASE Revision 7 of this document is a general update and reflects minor revisions which have been established since the last revision.
There are no basic changes to the Quality Assurance Program.
S/2 s/fM Vice resident Quality A urance 8 4+ g Vi Pr siden Nuclear Generation Vice esi ent Nuclear Engineering ce President Nuclear Support Executi e Vic President Nuclear
e following table reflects the changes made to Niagara Mohawk's Quality Assurance Topical Report (QATR-1) and incorporated into Revision 7. The changes are divided into two categories, Clarifications and Other. Changes have been marked by revision bars.
CLARIFICATIONS PAGE SECTION SUlmARY OF THE CHANGE REASON FOR CHANGE/BASIS 2-1 2.2.2 Deleted "related" and added "most relevant" and "(QAP) or Nuclear Interface Procedure (NIP)."
To reflect the type of procedures listed in Appendix C.
2-3 2.2.7 Added "The application of the 10 CFR Part 50 Appendix B Quality Assurance Program as applied to activities under 10 CFR Part 71 for Nine Mile Point Unit 1 and 2 is limited to procurement and use of packaging for shipment of radioactive materials. Design and fabrication of shipping casks willnot be conducted under this Quality Assurance Program."
To describe the relationship between 10 CFR Part 71 and 10 CFR Part 50 Appendix B in the Topical Report for informational purposes and to reflect what has been approved by the NRC as part of the 10 CFR Part 71 license.
2-3 2.2.9 Deleted "These include:
A. Nuclear Division Directives; and B. Nuclear Division Interface Procedures" Deleted the references to specific.
type Niagara Mohawk procedures in this area of the QATR due to changes being made in the procedural hierarchies.
Note Appendix C does list specific procedures.
Appendix C C-1 Complete Appendix Revised the, appendix to delineate the most relevant NIPs or QAPs that implement the 10 CFR Part 50 Appendix B Program This change is due to internal revisions of procedural hierarchies which caused some previous QAPs to be superseded by NIPs.
The Appendix has been revised to indicate the most relevant NIP or QAP that implements the requirements of the QATR by section.
Page 1
(a:top sum)
PAGE OTHER (organizational title change and typo corrections)
SECTION
SUMMARY
OF THE CHANGE REASON FOR CHANGE/BASIS 1-3 1.2.2.B.1.(e)
Changed Installation Services to "Construction Services" to reflect current organization This was an organizational title change only. Functions performed are unchanged.
1.2.3.A &B Changed Regional Operations Central to "Electric Customer Service," and Senior Vice President, Regional to "Senior Vice President, Electric Customer Service SBV."
Changed Vice President, System Electric Operations to "Director, System Electric Operations."
These are organizational title changes only.
1-6 1-3 1.2.3.C 1.2.2.B.2.(b)
Delete 1.2.3.C in its entirety.
Revised to "Nuclear Fuels (Design, Procurement Specification and Contract Implementation)"
=
The responsibilities for procurement of Nuclear Fuels and administration of Nuclear Fuels contracts has been transferred to Nuclear Engineering.
1-7 Figure 1-1 Added below the title "Figure 1-1" Clarification to be consistent with the text reference.
1-7 Figure 1-1 Revised organization chart to delete Fuel Supply.
Revised to reflect current organization.
1-8 Figure 1-2 Added below the title "Figure 1-2" Clarification to be consistent with the text reference.
1-8 Figure 1-2 Deleted Fuel Supply column and FS Designation The responsibilities for procurement of Nuclear Fuels and administration of Nuclear Fuels contracts has been transferred to Nuclear Engineering.
5-1 5.2.3 Deleted "The procedures used to control activities are listed in Section
- 2. They" Replaced with, "Nuclear Division and departmental procedures" To be consistent with change made to Section 2.2.9, which no longer lists procedure types in Section 2. No change in commitment intended.
7-1 7.2.3 Added to the fourth line "audits or" Correction of typographic error.
Inadvertent deletion between Revision 5 and 6.
17-2 17.2.6 Added "acceptable methods of making corrections to records."
Correction of typographic error.
Inadvertent deletion between Revision 5 and 6.
Appendix B B-10 10.c Para 54 Changed colt to "bolt" Correction of typographic error.
Page 2 (a:top@urn)
NMPC-QATR-1 REV. 7 SECTION INTRODUCTION.
TABLE OF CONTENTS PAGES QUALITYASSURANCE POLICY...
1.0 Organization 2.0 Quality Assurance Program....
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1 1-8 2 2-6 3.0 Design Control
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3 1
3 3 4.0 Procurement Document Control...... ~......... ~.....
4 4-2 5.0 Instructions, Procedures and Drawings...............
6.0 Document Control 7.0 Control of Purchased Material, Equipment and Services 8.0 Identification and Control of Materials, Parts and Components 9.0 Control of Special Processes 10.0 Inspection 11.0 Test Control 5-1 6 6-2 7 7-3 8-1 9 9-2 10 10-3 11 11-2 12.0 Control of Measuring and Test Equipment 13.0 Handling, Storage and Shipping 14.0 Inspection, Test and Operating Status 15.0 Nonconforming Materials, Parts or Components 16.0 Corrective Action..
12-1 13-1 14-1 15 15-2 16-1 17.0 Quality Assurance Records........
18.0 Audits...
17 17-2 18 18-2 Appendix A - Regulatory Commitments..............
A A-2 Appendix B - Interpretations and Exceptions of Appendix A Documents Appendix C - Matrix of 10CFR50 Appendix B...
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Criteria vs. NMPC QATR-1 and QA Procedures B B-11 C-1
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NMPC-QATR-1 PAGE i REV. 7 QUALITYASSURANCE PROGRAM TOPICAL REPORT NINE MILEPOINT NUCLEAR STATION UNITS 1 AND 2 OPERATIONS PHASE INTRODUCTI N This Quality Assurance Program Topical Report fulfillsthe 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/ASMENQA-1 and ANSI/ANS-3.2. This provision permits the preparation and use of a single set of procedures that apply to quality assurance functions at and on behalf of both units.
In the event of a conflict between non-QA programmatic controls contained in this QA Program Topical Report and related commitments contained in Nine Mile Point Units 1 and 2 FSAR's, the latter shall take precedence.
Questions with respect to the content or applicability of the Quality Assurance Program Topical Report should be referred to the Vice President - Quality Assurance.
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QUALITYASS&DACE POLICY NMPC-QATR-1 PAGE ii REV. 7 PURPOSE:
The purpose of this policy is to summarize the Company's position governing Quality Assurance responsibilities and accountabilities.
POTICY:
The Company policy regarding Quality Assurance matters is that:
1.
Organizations ~ith quality-affecting responsibilities shall be structured, managed and operated in compliance with approved Quality Assurance
- Programs, procedures and instructions in direct support of generation>
transmission and distribution projects and operations to achieve the follo~ing objectives:
To strive to perform assigae4 cwork correctly the fi~st time.
To provide facilities ~hich are designed, constructed, tested and oyerated to high standards of ercellence, with high assurance against failure or mal.fuactioal, an4 ~ithout undue risks to the health aa4 safety of the public.
To ensure early and timely identification and resolution of actual and yotential problem areas in design, yrocuremeat, construction, testing, oyerations, maintenance and modificatioa of facilities'o comply effectively ~ith government regulations and established HNPC policiea and procedures, apylying a systematic, disciplined and uniformed approach to Quality Assurance.
2.
Accountability for the quality of generation, transmission and distributioa structures,
- systema, comyonents and services rests with the organizations and persons performing the quality attaining functions of design, construction and opera tioa.
3.
Accountability for determining that the geaeration, transmission an4 distribution structures,
- systems, components and services do, in fact, meet the stated requirements rests with
. the organizations an4 persons performing quality verification functions, such as design reviev, document revie~, inspection, surveillance and audits.
hUTHORIZED:
APPROVED'gn ur Department Pres) dent at 4 ]P
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NMPC-QATR-1 PAGE 1-1 REV.
7 1.0 ORGANIZATION
~P)LAY 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 IMPLKNIENTATI N 1.2.1 R
onsibilit And Auth iit I.
The President Nia ara M hawk Power o
rati n PC, 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.
7 1.2.2 Nuclear Divi ion Res o
ibiliti I.
The Executive Vi Pre iden Nucl, 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 Execu ive taff, 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 Nuclear mmunicati n
nd Pu lic Affair Director reports to the Executive Vice President,
- Nuclear, and is in charge of communications, public affairs and direction of the energy center.
A. The Vi e Pr iden N clear enerati n, 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 Plan Mana er ni 1 and nit 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. 7 2.
Mana er i e ervic reports to the Vice President, Nuclear Generation.
The manager is responsible for:
(a)
Industrial Safety (b)
Environmental Protection (c)
Technical Services (d)
Administrative Services 3.
The Mana er Nuclear Securi 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 President 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 ni I and nit IIEn ineerin report to the Vice President, Nuclear Engineering, and are responsible for providing engineering services for the safe, reliable and economic operation of the Nine MilePoint Nuclear Station Unit I and Unit II, including adherence to applicable regulatory requirements, Responsibilities include:
(a)
(b)
(c)
(d)
(e)
Design Project Management Plant Evaluation Site Engineering Construction Services..
The Mana er Technolo ervices reports to the Vice President, Nuclear Engineering, and is responsible for:
(a)
(b)
(c)
(d)
(e)
Program Development Nuclear Fuels (Design, Procurement Specification and Contract Implementation)
Safety Analysis Health Physics Support Design Basis Reconstitution eneral u ervi r En ineerin Perf rmance Services, 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 PAGE 1-4 REV.
7
- 4. M~EG p
U Vi*P*id,N 1 gi
'g di responsible for providing independent review of plant activities including maintenance, modifications, and operational concerns.
Performing analysis and providing recommendations of the activities reviewed.
C. The Vice President Nuclear Su ort, reports to the Executive Vice President, Nuclear, and has overall responsibilities for:,
- a. Licensing
- b. Information Management
- c. Training
- 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.
2.
Mana er Inf rmation Mana ement reports to the Vice President, Nuclear
- Support, and is responsible for control and administration of Information Systems including Records Management, Document
- Control, computer hardware/software 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 Director Emer enc Pre aredne, reports to the Vice President, Nuclear Support, and is responsible for:
(a) Drills (b) Facilities (c) Technical (d) Procedures 5.
Mana er Human Resource Devel ment 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. 7 Mana er Procurement under the general direction of the Vice President, Nuclear Support, is responsible for:
(a)
Purchasing (b)
Materials Management (c)
Procurement Specialists The Vice President uali As urance, 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 ofresponsibilities, together with proportionate authority for fulfillment, See Figure 1-2 forprimary and supporting Quality Assurance Program element responsibilities.
Responsibilities include:
(a)
(b)
(c)
(d)
(e)
(0 (g)
(h)
(i)
Administering the evaluation and corrective action program for
'eviation/Event Report Audits Su rveillances Inspections Operations Experience Assessments Internal SALP Type Assessments Trend Analysis Stop Work Authority Performance of NDE such as ISI and Erosion/Corrosion The Mana ers uali Assurance erations Unit I and 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.
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.
The u
rvis r uali A
urance Audits, reports to the Vice President, Quality Assurance, and has responsibility, authority, and accountability for QAD functions related to internal and external Quality Assurance Audits.
The u ervi or ualit Service 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. 7 E. The Controller Nuclear Division, 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.
1.2.3 u
ort De artment Res o
ibilities A. The Vice President Electric Customer ervice, reports to the Senior Vice President, Electric Customer Service SBU, and is responsible for formulating, establishing and enforcing Meter and Test activities.
See Figure 1-2 forprimary and supporting Quality Assurance Program element responsibilities.
1.
The eneral Mana er en ral Re ion, reports to the Vice President, Electric Customer Service. The staff includes the Superintendent Regional 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 Director S stem Electric erations, reports to the Senior Vice President, Electric Customer Service SBU, 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 Lab rato Facilities reports to the Director, System Electric Operations.
The staff includes Supervisor, Standards Laboratory, who is responsible for maintaining a facility for calibrating reference standards and for calibration and maintenance of portable measuring and testing equipment (M&TE).
NMPC-QATR-1 PAGE 1-7 REV. 7 R ANIZATI N HART Figure 1-1 NHPC PRESIDENT EXECUTIVE VP NUCLERR-OPERRTIONS SENIOR VP ELEC CUSTOHER SERVICE SBU EXECUTIVE RSSISTRNT PUBLIC RFFRIRS MANRGER EXECUTIVE STRFF DIRECTOR SYSTEM ELEC OPERATIONS VP ELECTRIC CUSTOMER SERVICE VP NUCLERA GENERRTION T ONE PLANT HRNRGER UNIT TWO PLANT HRNRGER VP NUCLERR ENGINEERING VP DUALITY ASSURRNCE VP NUCLERR SUPPORT CONTROLLER NUCLERR DIVISION HRNRGER NUCLERR SECURITY MANAGER UNIT ONE ENGINEERING HRNRGER OR OPERRT IONS UNIT ONE HRNAGER LICENSING DIRECTOR NUCLEAR
~ ACCOUNTING HRNRGER SITE SERVICES HRNRGER UNIT TWO ENGINEERING MRNRGER OA OPERATIONS'NIT TWO HRNAGER INFORHRTION MANAGEMENT DIRECTOR BUDGETS 6 REPORTS NUCL HANRGER TECHNOLOGY SERVICES SUPERVISOA OR AUDITS HRNRGER TRAINING RATE CASE AUDIT/SYS RNRLYST GEN SUP ENGR'ERFORMANCE SERVICES MRNRGER OA ENGINEERING DIRECTOR EMERGENCY PREPRREONESS CERC/WORKING BUDGET RDHINISTRRTOR SUP EA VISOR ISEG SUPERVISOR DUALITY SEAVICES HRNRGER HUMAN RESOURCE DEVELOPEHENT HRNAGER PROCUREMENT
NMPC-QATR-1 PAGE 1-8 REV. 7 QUALITYASSUIUD'CE PROGEVM RESPONSIBILITY MATRIX Figure 1-2 Regulatory Requirements Niagara Mohawk Power Corporation Department I.
Organization I
3.1 3.3 3.4.2
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II.
QA Program 2,2S-I 2$.2 2$-3 3, 3S-I 3.1 3.3 5.1 5.3 3.4.2 3.5 5.2.7.2 P,S P,R R
IV.
Procurement 4, 4S-I 5.2.13.1 R
P V.
Procedures VII. porch. Itans 6,6S-I 7>7S-I
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5.2.13.2 P>S P
P>R P,R R
VIII. Itan Control IX.
Special Proc.
8,8$ -1 9,9S-1 10,10S-1 5.2.133 5.2.18 5.2.12 5.2.17 P
P R
P,R P,R P
P XI.
Testing 11,11$ -1 5.2.19 P
P,S XII. MATE 12, 12S-I 5.2.16 P,S P
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13,13S-1 5.2.13.4 XV.
Nonconformance Status 14 IS,ISS-I 5.2.6 5.2.14 5.2.14 P
P P,S XVL Corrective XVII. Records XVELAudit Action 16 17,17S.I 18,18$ -1 5.2.11 5.2.12 4.5 P
P P,R S,R P
P
. A NO - Nuclear Generation NE - Nuckar Enginccring NSP - Nuckar Support MT - Mctcr & Test ML - Meter & Laboratory QA - Quality Assuranco NS - Nuckar Security P - Primary Responsibility S - Support Responsibility R - Review, Audit and Surveillance Rcsponsil>iTity
NMPC-QATAR-1 PAGE 2-1 REV.
7 2.0 UALITY A S AN E PRO RAM 2.1 POLI( Y 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 fulfillsthe 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 ofthe 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 most relevant Quality Assurance Procedure (QAP) or Nuclear Interfacing Procedure (NIP). 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 willbe 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-QATR-1 PAGE 2-2 REV.
7 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:
~Educati n
Bachelor's degree in engineering or physical science from an accredited institution.
E~xerience 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-QATR-1 PAGE 2-3 REV. 7 E~xerience 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.
The application of the 10 CFR Part 50 Appendix B Quality Assurance Program as applied to activities under 10 CFR Part 71 for Nine Mile Point Unit 1 and 2 is limited to procurement and use ofpackaging for shipment ofradioactive materials.
Design and fabrication of shipping casks willnot be conducted under this Quality Assurance Program.
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.
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.
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.
I NMPC-QATR-1 PAGE 2-4 REV. 7 2.2.11 The scope of the program and the extent to which its controls are applied are established as follows:
A. NMPC uses the criteria specified in Nuclear Engineering Procedures for identifying structures, systems and components to which the Quality Assurance program applies; 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, ifany, 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; GIld 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:
NMPCQATR-1 PAGE 2-5 REV.
7 A. Personnel responsible forperforming 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; I
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 ofqualification 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 ofthe 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 off-site and on-site 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.
NMPCQATR-1 PAGE 2-6 REV.
7 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.
NM PC-QATR-1 PAGE 3-1 REV.
7 3.0 DESIGN 3.1 PQLI~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 requiremen'ts 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 responsibilities include the preparation, review and approval'f 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 3.2.3 Computer programs used in safety-related design and station operation are appropriately documented, verified, certified for use and controlled in accordance with procedures.
3.2.4 Materials parts and processes are selected and specified, based on the requirements of applicable codes and standards or, on known, successful use under simila'r 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.
NMPC-QATR-1 PAGE 3-2 REV.
7 3.2.7 Design drawings and specifications are checked to verify the dimensional accuracy and completeness.
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 ifshown 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.
7 3.2.11 Persons representing applicable technical disciplines are assigned to perform design verifications.
These persons are qualified by appropriate education o'r 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.
7 4.0 PROC REMENT DO UMENT ONTROL 4.1
+)LICY Procurement documents define the characteristics of items or services to be procured, identify applicable regulatory and industry codes or standards requirements, and specify supplier quality assurance program requirements to the extent necessary to assure adequate quality.
4.2 IMPLEMENTATION 4.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
4.2.2 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;
NM PC-QATR-1 PAGE 4-2 REV.
7 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.
NMPC-QATR-1 PAGE 5-1 REV.
7 5.0 IN TR CTIONS PRO ED RES AND DRAWIN S 5.1 PQLT~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 IMPLEMENTATION 5.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION 5.2.2 Instructions, procedures, drawings, or vendor manuals incorporate (1) a description of the activity to be accomplished and (2) appropriate quantitative (such as tolerances and operating limits) and qualitative (such as workmanship standards) acceptance criteria.
5.2.3 Nuclear division and departmental procedures 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.
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NMPC-QATR-1 PAGE 6-1 REV.
7 6.0 DOCUMENT C
NTR L 6.1 PQLI+Y 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.
NMPC-QATR-1 PAGE 6-2 REV.
7 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 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.
NMPC-QATR-1 PAGE 7-1 REV.
7 7.0 NTR L F
P CHA ED MATERIAL E
IPMENT AND ERVI E 7.1 POLLY Activities that implement approved procurement requests for material, equipment, and services are controlled to assure conformance with procurement document requirements.
Controls include a system of supplier evaluation and selection, source inspection, examination and acceptance of items and documents upon delivery, and periodic assessment of supplier performance.
7.2 IMPLEMENTATION 7.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
7.2.2 When contractors perform work under their own quality assurance programs, those programs are reviewed for compliance with the applicable requirements of 10CFR50 Appendix 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 ofevaluating supplier qualification include objective evidence ofsupplier's current quality performance, audits or 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 willverify 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.
NM PC-QATR-1 PAGE 7-2 REV. 7 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 followingprovisions 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 review'ed, 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, depending upon the nature, complexity and importance of the item and amount of source inspection or surveillance, selected characteristics may be examined or tested on a sampling basis to verify conformance to procurement requirements.
Items inspected are identified as to their acceptance status prior to storage or release for installation or use.
NMPC-QATR-1 PAGE 7-3 REV.
7 7.2.8 Suppliers'ertificates of conformance are reviewed for completeness and accuracy and are supplemented by receipt inspection to verify conformance to purchase requirements.
7.2.9 Documentation supporting the conformance of material and equipment with the procurement documents is to be available at the site prior to 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.
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NMPC-QATR-1 PAGE 8-1 REV.
7 8.0 IDENTIFI ATION AND C!L20""
NTROL F
MATERIALS PART AND
- 8. 1 PQLI~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 IMPLEMENTATION 8.2.1 General organizational responsibilities are described in Section 1.0, ORGANIZATION.
8.2.2 Controls provide for the identification and control of materials (including consumables),
parts and components (including partially fabricated assemblies).
8.2.3 Items are identified by physically marking the items, storage
- area, or containers or by maintaining records traceable to the items. The method ofidentification 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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9.0 NTROL F
SPE IAL PROCESSES NMPC-QATR-1 PAGE 9-1 REV.
7 9.1 PQLICY 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 IMP LEMENTATI N 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 ofprotective coatings, and nondestructive examination (NDE).
9.2.3 Requirements for control of special processes involve one or more of the following methods, each of which is approved by qualified personnel:
A. Written instructions on the drawing or specification for the piece or assembly; B. Written procedure(s) including the specific application involved; C.
Reference to a recognized code or standard published by a national society or institute; and D. Combinations of above with addenda, exceptions, or alternates clearly indicated and in terminology familiar to personnel involved in planning, performing the process and evaluating the results.
9.2.4 Special process procedures are prepared by personnel with expertise in the discipline involved.
The procedures are reviewed for technical adequacy by other personnel with the necessary technical competence, and are qualified by testing, as necessary.
9.2.5 Special process personnel qualification is determined by individuals authorized to administer the pertinent examinations.
Certification of qualification is based in part on examination results.
Personnel certification is kept current by performance ofthe 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.
7 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 t'aken, 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.
10.0 INSPECTION NMPC-QATR-1 PAGE 10-1 REV.
7 10.1 ~POLI Y 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,'uel 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; E.
Methods; F.
Provisions for recording objective evidence of inspection results; G. Specify measuring and test equipment ofthe necessary accuracy forperforming inspection.
Inspection is performed on selected operations where it is deemed necessary to verify conformance with specified requirements.
Process monitoring is used where direct inspection alone is impractical or inadequate.
Both inspection and process monitoring are performed when control is inadequate without both.
NMPC-QATR-1 PAGE 10-2 REV.
7 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.
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; NMPC-QATR-1 PAGE 10-3 REV.
7 F.
Reference to information on action taken on nonconformances to resolve any discrepancies noted.
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NM PC-QATR-1 PAGE 11-1 REV.
7 11.0 TEST CONTROL 11.1 PQLI+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 IMPLEMENTATI N 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 ofsystems and equipment; E.
Surveillance tests to assure continuing proper and safe operation of systems and equipment; and F.
NMPC-QATR-1 PAGE 11-2 REV.
7 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.
12.0 NTROL F MEASURING AND TEST E IPMENT NMPC-QATR-1 PAGE 12-1 REV.
7 12.1 PQLICY Measuring and test equipment is identified, controlled, calibrated and adjusted at specified intervals to maintain accuracy within prescribed limits.
12.2 IMPLEMENTATI N 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 12.2.4 Measuring and test equipment is uniquely identified and is traceable to its calibration test data.:.
i 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 if 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.
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NMPC-QATR-1 PAGE 13-1 REV.
7 13.0 HANDLING STORAGE AND SHIPMENT 13.1 PQLI( 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 damage or loss are identified and controlled.
Controls are achieved through the use of appropriate procedures.
13.2 IMPLEMENTATI N 13.2.1 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 atmospher'es, 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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NMPC-QATR-I PAGE 14-1 REV.
7 14.0 INSPE TI N TEST AND OPERATIN STAT 14.1 +P)~LI 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 IMPLEMENTATI N 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.
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NMPC-QATR-1 PAGE 15-1 REV.
7 15.0 N N ONFORMIN MATERIA PARTS R
C M NE T 15.1 ~POLI Y 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, 're 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.
NMPC-QATR-1 PAGE 15-2 REV.
7 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 is determined and corrective action implemented to prevent recurrence in accordance with Section 16.2.3.
NMPC-QATR-1 PAGE 16-1 REV.
7 16.0 ORRECTIVE ACTION 16.1 PQLICY 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, 'efective
- 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.
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NMPC-QATR-1 PAGE 17-1 REV. 7 17.0 ALITY A AN E RE ORDS 17.1 POLICY Quality assurance records are records that furnish documentary evidence ofthe 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 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.
NM PC-QATR-1 PAGE 17-2 REV.
7 17.2.6 Authorized personnel may issue corrections or supplements to records.
Procedures address acceptable methods of making corrections to records.
17.2.7 Traceability between the record and the item 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.
NMPC-QATR-1 PAGE 18-1 REV.
7 18.0 AUDITS 18.1 PQLI~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 perforined 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.
7 18.2.6 Audits include an objective evaluation of quality-related practices, procedures, instructions, activities, items, documents and records to confirm that the quality assurance program is effective and properly implemented.
The following activities are included:
A. Indoctrination and training program; B.
Interface control between NMPC organizational units and between NMPC and its principal contractors; C.
Corrective action; D. M&TEcalibration; E.
Nonconformance control; F.
FSAR commitments; G. Activities associated with computer codes; and H. Activities associated with design verification supervisor.
18.2.7 Audit procedures and the
- scope, plans, checklists documented.
performed by designers'mmediate and results of individual audits are 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 p'erformed 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.
7 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.
2.
10CFR50 Appendix B ANSUANS-3.2
.'.:,'REVXSIONJDA'TK'!;;.;l 1982 Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants 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.
5.
ANSI/ASME NQA-1 ANSI/ASME NQA-2 1983 1983 Addenda 1983 Quality Assurance Program Requirements for Nuclear Facilities Quality Assurance Requirements for Nuclear Power Plants 6.
Reg. Guide 1.37 1973, RO Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (endorses ANSI N45.2.1) 7.
ANSI N45.2. 1 1973 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants A-1
NMPC-QATR-1 REV.
7 O'X ~k +% X
'C%CR'. '.g xXv)":<A,"p~'Y>+~,j~<M; 8.
IEEE 336 1971 Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations.
9.
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) 10.
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.
7 APPENDIX B
INTERPRETATIONS AND EXCEPTIONS OF APPENDIX A
DOCUMENTS i,,:,:::i!i'i!IIC!CCMadT¹ii! ilia!
i'iii':-,'0CFR50 Appendix B None Reg. Guide 1.28 a.
Introduction ECWi
-IN gl Qgld Ppg d
lg and construction of nuclear power plants.
Guidance for operations phase QA programs willbe addressed in separate regulatory guides.
b.
Para. 3.1
- ANPII PMENQA I I I
\\ dNby reference in ANSI/ANS-3.2, which applies to operations phase QA programs.
Therefore, Niagara Mohawk is committing to ANSI/ASMENQA-1 for operations phase activities.
Wg I
-Appg bl I
I g
QA Program should be audited at least annually...
c.
Para 3.2
~Exce tions - During the operations phase, 'applicable elements of the QA program willbe audited at least once every two years, in accordance with ANSI/ANS-3.2 Cgg i Th ppg II h
Id lb audit its supplier's quality assurance program on a triennial basis or arrange for such an audit.
I~i NNPC I I h
WHIR PPE 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-l REV.
7 d.
Section B i!:;::::-':i!i-:::,::::;:::::iiiiii::::,-:'::::::,::::::!IYPRRPRKTAT?ON!.
Requirements
- Discussion, Para.
8 states in part "Personnel performing inspection and testing that are qualified to the guidance contained in Reg. Guide 1.8 need not be qualified in accordance with the requirements of NQA-1. It is not the intent that such personnel be qualified in accordance with both Reg. Guide 1.8 and NQA-1".
ANSI/ANS-3.2 a.
General Interpretation - NMPC has committed to ANS 3.2, which references ANS 3.1 for certification and qualifications of operating plant personnel.
Consistent with the guidance provided in Reg, Guide 1.28 personnel performing inspection and test, who are qualified in accordance with requirements of ANS 3.1, need not be qualified in accordance with NQA-1.
Requirement - ANSI/ASMENQA-1-1979 is referenced throughout ANSI/ANS-3.2, b.
Para.
1.1 Exception - In lieu of the referenced standard NMPC is committed to ANSI/ASMENQA-1-1983 including 1983 addenda.
Requirements - This paragraph refers to "...all activities affecting those functions important to safety..."
c.
Para. 3'.4.2 Exception - NMPC is committed to a program based on controls applied to safety-related systems, components, and services.
Requirement - This paragraph establishes requirements for the qualifications of the On-Site Operations organization.
d.
Para. 4.0 Implementation - In lieu of these controls, NMPC will comply with those contr'ols described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.
Requirements - These paragraphs establish requirements for reviews and audits.
Implementation - In lieu of these controls, NMPC will 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.
7 e.
Section 5 Requirement - Reference is made within this section to the ANSI/ANS-3.2 General Appendix for typical activities which should be covered by written procedures.
- f. Para. 5.2.1.6 Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Unit 1 and 2 FSARs and the related technical specifications.
Requirement - This section provides rules for the maximum number of hours at a duty station.
g.
Para. 5.2.2 Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.
Requirement - Portions of this paragraph specify
'pprovals for temporary procedure changes.
h.
Para. 5.2.7 Implementation In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.
Requirement - This paragraph requires the use of ANSI/IEEE 336-1980.
- i. Para. 5.2.7 Implementation - In lieu of the referenced standard Appendix A of this Topical Report commits to IEEE 336-1971.
Requirement - ANSVANS-3.2-82 references ANSI N45.2.5-1978 concerning design and construction activities associated with modifications.
- j. Para. 5.2.7 Exception - In lieu of the referenced standard NMPC is committed to ANSI N45.2.5-1974 (see Appendix A item 10).
Requirement - This paragraph refers to ANSI N45.2.8-1975.
Exception - In lieu of the reference standard NMPC is committed to ANSVASME NQA-2-1983 part 2.8 for nuclear safety related permanent plant modifications and maintenance activities.
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NMPC-QATR-1 REV.
7 k.
Para. 5.2.7 Requirement - This paragraph refers to ANSI/ASME D3843-80.
- l. Para. 5.2.8 Exception - 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.
Requirement - A surveillance testing and inspection program
~.. shall include the establishment of a master surveillance schedule reflecting the status of all planned inplant surveillance tests and inspections.
Interpretation - Independent master schedules may exist for different programs such as in-service inspection @ST, pump and valve testing, and Technical Specification surveillance testing.
m.
Para. 5.2.9 Implementation - In lieu of these controls, NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related Technical Specifications.
Requirement - Procedure shall be developed to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.
n.
Para. 5.2.10 Implementation - This item is addressed in the Security Plan.
Requirement - This paragraph refers to ANSI/ASME N45.2.1-1980.
Exception - In lieu of this revision of the referenced standard, NMPC is committed to ANSI/ASMEN45.2.1-1973, (Appendix A, Item 7).
r B-4
NMPC-QATR-1 REV.
7
'-".ll'ilia<JKIJ~'2f74!::.-:ii iiiiiii'i-o.
Para. 5.2.13.2 Requirement - Where required by law, regulation or contract requirements, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.
p.
Para. 5.2.13.4 Interpretation - NMPC requires that the required documentary evidence be available at the site prior to use, but not necessarily prior to installation.
This allows installation to proceed under specified conditions while any missing documents are being obtained, but precludes dependence on the item for safety purposes.
Requirement - This paragraph refers to ANSI/ASME N45.2.2-1978.
q.
Para. 5.2.15 Exception - In lieu of the referenced standard NMPC is committed to ANSI/ASMENQA-2-1983 part 2.2 for nuclear safety related permanent plant modifications and maintenance activities.
Requirement - This paragraph established administrative controls for the review, approval and control of procedures.
r.
Para. 5.2.16 Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs 'and the related technical specifications.
Requirement - Records shall be made and equipment suitable marked to indicate calibration status.
s.
Para. 5.2.16 Exception - 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).
Requirement - This paragraph references ANSI/IEEE 336-1980.
Implementation - In lieu of the referenced standard NMPC commits to IEEE 336-1971.
(See Appendix A, item 8).
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NMPC-QATR-1 REV.
7 t.
Para. 5.3 Requirement - This paragraph establishes administrative controls for written procedures.
u.
Para. 5.3.9.3 Implementation - In lieu of these controls NMPC will comply with those controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs and the related technical specifications.
Requirement - This paragraph suggests ANSI/ANS 3.7.1-1979, ANSI/ANS 3.7.2 and ANSUANS 3.7.3-1979 for additional guidance in preparation of Emergency Plan Implementing Procedures.
ANSI/ASMENQA-1 a.
Supplement 2S-1 Exception - In lieu of ANSI/ANS 3.7.1,3.7.2 and 3.7.3 described in ANSI/ANS 3.2, NMPC willcomply with the emergency preparedness controls described in applicable sections of the Nine Mile Point Units 1 and 2 FSARs.
Requirement - Supplement 2-S1 provides requirements for the qualification of personnel performing inspection and test.
b.
Supplement 2S-2 Interpretation - Consistent with guidance founded in Regulatory Guide 1.28, personnel qualified in accordance with requirements of ANS 3.1 need not be qualified in accordance with NQA-1, Requirement - The American Society of Nondestructive
'esting Recommended Practice No. SNT-TC-1A, June 1975 Edition and its applicable supplements shall apply as requirements to NDE personnel covered by this Supplement.
c.
Supplement 2S-3 Exception - In lieu of the referenced standard NMPC is committed to ASNT Recommended Practice No. SNT-TC-1A, June 1980 and its applicable supplements.
Requirement - Personnel who participate in Quality assurance program audits shall be qualified in accordance with ANSUASME NQA-1 supplement 2S-3.
Exception - 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.
7 d.
Supplement 7$-1 Para. 8.1 Requirement - Where required by code, regulation or contract requirements, documentary evidence that items conform to procurement document requirements shall be available a't the nuclear facility site prior to installation or use.
e, Supplement 7S-1
'Para. 8.2.4 Interpretation - NMPC requires that the required documentary evidence be available at the site prior to use, but not necessarily prior to installation.
This allows installation to proceed under specified conditions while any missing documents are being obtained, but precludes dependence on the item for safety purposes.
Requirement -...post-installation test requirements shall be mutually established by the purchaser and supplier.
- f. Supplement 17S-1 Para. 4.4.2 Interpretation - In exercising its ultimate responsibility for its QA program, NMPC establishes post-installation test requirements, giving due consideration to supplier recommendations.
Requirement - The following are acceptable alternatives to the criteria of 4.4.1 above for a single facility...(b) 2 hr. fire rated class B file containers meeting the requirements of NFPA 232-1975;...
Exception - When temporary storage of records (such as for processing, review, or use) is required by an 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 limitfor 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.
7 g.
Supplement 17S-1 Para. 4.4.2 and Footnote Requirement - The following are acceptable alternatives to the criteria of 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 232-1975'; (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'ith 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.
Exception - 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.
ANSI/ASMENQA-2 a.
General b.
Part 2.1
'FPA 232-1986 and NFPA 232AM-1986 are published by the ¹tional Fire Protection Association, Batterymarch Park, Quincy, MA 02269 Applicable parts of this standard willbe 'applied to nuclear safety related activities pertaining directly to permanent plant modifications only, except for items 3o.
and 3j. of this Appendix B.
Requirement - This section gives QA requirements for cleaning of fluid systems and associated components.
c.
Part 2.5 Exception - In lieu of the referenced NQA-2 Section, NMPC is committed to Reg. Guide 1.37 (see Appendix A item 6).
Requirement - This section gives QA requirements for installation, inspection and testing of structural concrete, structural steel, soils and foundations.
Exception - In lieu of the referenced NQA-2 section, NMPC is committed to Reg. Guide 1.94 (see Appendix A item 9).
B-8
NMPC-QATR-1 REV.
7 d.
Part 2.15 Requirement - This section gives QA requirements for hoisting, rigging and transportation of items for nuclear power plants.
e.
Part 2.20 Exception - In lieu of the referenced NQA-2 section, NMPC is committed to the requirements of applicable heavy load reports for Nine MilePoint 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.
Requirement - This section outlines QA requirements for subsurface investigations for nuclear power plants.
General b.
Para. C.3 Exception - In lieu of the referenced NQA-2 section, NMPC willcomply with the subsurface controls described in the applicable sections of the Nine Mile Point Units 1 and 2 FSARs, Applicable parts of this Reg. Guide willbe applied to nuclear safety-related activities pertaining to major plant modifications and maintenance within the scope of paragraph 5.2.10 of ANSUANS 3.2-82 only (i.e., those under the direction of Nuclear Engineering).
Requirement - The water quality for final flushes....
...shall be at least equivalent to the quality of the operating system water.
c.
Para. C.4 Exception - NMPC is committed to the stated requirement except for the oxygen content.
Requirement - This paragraph gives precautions on chemical compounds that could contribute to intergranular cracking or stress corrosion cracking in austenitic stainless steel and nickel based alloys.
Exception - 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 nickel 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.
7 7.
Section 3.1.2
- Thf gf" h I"'" f Class B cleanness.-
b.
Section 3.2 Ence tion - Upgraded piping systems and components constructed of carbon steel materials willmeet Class B cleanness requirements except for final flushing/cleaning which may exhibit rust staining in accordance with Class C cleanness requirements.
-Th' g'g'T requirements for cleaning.
8.
IEEE-336 9.
Reg. Guide 1.94 Ence ti n - Dne to seasonal conditions, freshwater from Lake Ontario willhave an allowable upper pH limitof 8.5.
Applicable parts of this standard willbe 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).
No exceptions 10.
General b.
Para. 5.3 Applicable parts of this standard willbe applied to nuclear safety-related activities pertaining to major plant modifications only (i.e., those under the direction of Nuclear Engineering).
Th p
g phgl P
lf "f assembly,and
- erection, c.
Para. 5.4 Exce~ti
- Bolt holes generally willnot be burned (oxygen cut). Ifholes must be burned, the following criteria willbe followed; a) after cutting, the edges of the cut willbe ground or reamed back a minimum of 1/32 in., and b) the final bolt hole dimensions willnot exceed those given in the Specification for Structural Joints using ASTM A325 or A490 bolts.
-Thl p g
ph hllh P
f determining correct bolt length as at least two threads extending beyond the face of the nut.
~Exce tion - 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.
7 d.
Para. S.5 Requirement - This paragraph gives requirements for welding inspection.
e.
Para. 6.2.2 Exception - Allreinforcing bar splices made by arc welding, except those splices welded to metal embedments, willbe selected on a random basis for radiography and inspected in accordance with AWS D12.1.
Splices welded to metal embedments willbe inspected in accordance with AWS D12.1.
Requirement - This paragraph gives the requirements for evaluating mechanical (Cadweld) splice test results.
Exception - 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.)
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APPENDIX C MATRIXOF 10CFR50 APPENDIX B CRITERIA VS. NMPC QATR-1 AND NMPC PROCEDURES NM PC-QATR-1 REV. 7 10CFR50, Appendix 8 QA Criteria NMPC QA Program Topical Report Section Quality Assurance Procedures (QAPsJ and Nuclear Interface Procedures (NIPs) by Number IV.
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Organization QA Program Design Control Procurement Document Control Instructions, Procedures and Drawings Document Control Control of Purchased Material Identification and Control of Materials and Parts Control of Special Processes Inspection Test Control Calibration of Equipment Handling, Storage and Shipping Inspection, Testing and Operating Status Nonconforming Material Corrective Action QA Records Audits 10 12 13 16 17 C-1 QAP-POL-1.01 QAP-S RE-2.30 QAP-ASU-6.20, QAP-ASU-3.-01 NIP-PES-01, NIP-PES-02 NIP-PRO-02 NIP-DOC-01 NIP-PES-03 NIP-INV-01 QAP-SPR-9.01 QAP-INS-1 0.30 QAP-INS-10.31 QAP-MTE-1 2. 1 0 NIP-INV-01 QAP-INS-10.30 NIP-EGA-01 NIP-EGA-01 NIP-RMG-01 QAP-ASU-1 8. 1 0
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