ML18139B432

Amend 4,Draft 5 to QA Program,Operations Phase

ML18139B432
Person / Time
Site:	Surry, North Anna
Issue date:	07/06/1981
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18139B430	List: ML18139B429 ML18139B432
References
VEP-1-A04-DRFT, VEP-1-A04-DRFT-05, VEP-1-A4-DRFT, VEP-1-A4-DRFT-5, VEP-1-A4-DRFT5, NUDOCS 8107070163
Download: ML18139B432 (48)

Text

A:.~c.:n*: t; AMEND 4 DRAFT 5 to VEP-:-1 QA PROGRA~ OPERATIONS PHASE Rec'd w/lt!r 7/6/81. .. 8107070154 NOTICE THE ATTACHED FILES ARE OFFICIAL RECORDS OF THE DIVISION OF DOCUMENT CONTROL. THEY HAVE BEEN CHARGED TO YOU FOR A LIMITED TIME PERIOD AND MUST BE RETURNED TO THE RECORDS FACILITY BRANCH 016. PLEASE DO NOT SEND DOCUMENTS CHARGED OUT THROUGH THE MAIL. REMOVAL OF ANY PAGE(S) FROM DOCUMENT FOR REPRODUCTION MUST BE REFERRED TO FILE PERSONNEL.

DEADLINE RETURN DATE

_-,, /- J(' / .

",/bjCTt RECORDS FACILITY BRANCH

ABSTRACT

• This topical report describes the Virginia Electric and Power Company's quality assurance program for the operational phase of its nuclear power stations. The report is organized as, and is generically used for, Chapter 17, part 2 - Quality Assurance (Operations) - of Vepco's Safety Analysis Reports. The Vepco quality assurance program conforms to applicable regulatory requirements such as 10CFR50, Appendix B and to approved industry standards such as ANSI N45.2-1977 and ANSI N18. 7-1976 and

• corresponding daughter standards, or to equivalent al~ernatives. The program also follows additional guidance developed by the Nuclear Regulatory Commission. This report describes the quality assurance program beginning with preoperational testing and continuing through all phases of startup and operation. Included are organizational charts and a point-by-point comparison of the program with the 18 criteria of 10CFR50, Appendix B. This topical report is intended to be a comprehensive I

up-to-date description of Vepco's operational quality assurance program for nu(!lear I I

power generating stations .

• -Ef10707bT63 810706.

PDR ADOCK 05000280 p PDR Amendment Four Draft Five

17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.2.0 General It is the policy of the Virginia Electric and Power Company to establish and maintain a formal Quality Assurance Program for the operational phase of nuclear power generat-ing stations. This program is described by written procedures contained in appropriate manuals. The application of th~s program _acco111plishes two important objectives: 1) to

• provide* orderly,. uniform administrative and managerial procedures to assure safe, reliable and economic operation of nuclear power stations, and 2) to assure compliance with regulations promulgated by the U. S. Nuclear Regulatory Commission.

The quality assurance program encompasses such activities as operating, testing, refueling, repairing, in-service inspecting, maintaining and modifying nuclear power stations as related to safe operation. This includes surveillance of training and retraining programs, plant physical security programs, and administrative controls exercised during the operational phase.

17.2.0.1 Topical Report This topical report is written in the format of a Safety Analysis Report (SAR) Chapter 17, part 2, "Quality Assurance During the Operations Phase," in accordance with the' NRC'S "Standard Format and Content of Safety Analysis Reports for. Nuclear Power Plants" (Nov. 1975) and subsequent NRC guidelines. The quality assurance program described herein is applicable to all VEPCO nuclear power plants as ref,erenced by Chapter 17 of the plants' SAR's. Section 17.1 (not included in this report) describes quality assurance. up to and including pre-operational testing (except as noted) *. The applicable provisions of Section 17.2 are formally and gradually implemented during pre-operational testing as deemed necessary by the Station Manager so that the entire .

• program is implemented prior to the issuance of the operating license ..

Subsequent changes to VEPCO's operational quality assurance program will be in-corporated in this topical report. *The topical report is intended to be a comprehensive up-to-date description of VE PC O's operational quality. assurance program for nuclear power stations.

17 .2.0.2 Quality Assurance Standards and Guides The VEPCO operational quality assurance program conforms to Appendix B of 10 CFR 50 as. amended and ANSI N18.7-1976 and complies with the regulatory positions of the Regulatory Guides indicated in table 17.2.0 as modified by the notes to that table.

• 17.2-1 Amendment Four Draft Five

TABLE 17.2.0 CONFORMANCE OF VEPCO OP.ONAL QUALITY ASSURANCE PROGRAM TO QUALITY ASSURANCES ARDS, REQUIREMENTS AND GUIDES Regulatory Guide _A_N_S_I_S_t_a_n_d_ar_d_In_c_o_r..._po_r_a_t_e_d______________ Conformance Status Regulatory Guide 1.8 - Personnel Selection ANSI Nl8.1-i971-Selection and Training of Conforms and Training (Rev. 1-R, 5/77) Nuclear Power Plant Personnel Regulatory Guide 1.29 - Seismic Design None Conforms Classification (Rev. 3, 9/78)

Regulatory Guide 1.30 - Quality Assurance ANSI N45.2.4-1972-Installation, Inspection Alternative Requirements for the Installation, Inspection and Testing Requirements for Instrumenta- As discussed in and Testing of Instrumentation and Electric

• tion and Electrical Equipment during the sections 17. 2.11 Equipment (Rev. O, 8/72) Construction of Nuclear Power Generating and 17.2.12 of Stations this report Regulatory Guide 1.33 - Quality Assurance ANSI Nl8. 7-1976-Administrative Controls Conforms with Program Requirements (Operation) and Quality Assurance for the Operational exception (Rev. 2, 2/78) Phase of Nuclear Power Plants see note (1)

Regulatory Guide 1.37 - Quality Assurance ANSI N45.2.l-1973-Cleaning of Fluid Systems Conforms Requirements for Cleaning of Fluid Systems and Associated Components during the Con-i...;;l and Associated Components* of Water-cooled struction Phase of Nuclear Power Plants I N

Nuclear Power Reactors (Rev. O, 3/73)

Regulatory Guide 1.38 - Quality Assurance ANSI N45.2.2-1972-Packaging, Shipping, Conforms Requirements for Packaging, Shipping, Receiving, Storage, and Handling of See Note (2)

Receiving, Storage, and Handling of Items Items for Nuclear Power Plants during for Water-cooled Nuclear Power Plants the Construction Phase (Rev. 2, 5/77)

Regulatory Guide 1.39 - Housekeeping Require- ANSI N45.2.3-1973-Housekeeping during the Conforms ments for Water-cooled Nuclear Power Plants Construction Phase of Nuclear Power Plants (Rev. 2, 9/77)

Regulatory Guide 1.58 - Qualification of ANSI N45.2.6-1973-Qualification of Inspection Alternative Nuclear Power Plant Inspection, Examination, Examination, and Testing Personnel for the See Note (3) and Testing Personnel (Rev. O, 8/73) Construction Phase of Nuclear Power Plants Regulatory Guide 1.64 - Quality Assurance ANSI N45.2.ll-1974-Quality Assurance Conforms Requirements for the Design of Nuclear Requirements for the Design of Nuclear Power Plants (Rev. 2, 6/76) Power Plants Regulatory Guide 1.74 - Quality Assurance ANSI N45.2.10-1973-Quality Assurance Terms Conforms Terms and Definitions (Rev. O, 2/7 4) and Definitions

• See note (4)

Regula~_u_id_e~~~~~~~~~~~~~ dard Incor orated Confor1 * . Status Regulatory Guide 1.88 - Collection 1 Storage 45.2.9-1974-Requirements for Collection, Alternative and Maintenance of Nuclear Power Plant Storage, and Maintenance of Quality Assurance See Sec.

Quality Assurance Records (Rev. 2, 10/76) Records for Nuclear Power Plants 17.2.17 Hegulatory Guide 1.94 - Installation, Inspec- ANSI N45.2.5-1974-Installation, Inspection Conforms tion and Testing of Structural Concrete and and Testihg of Structural Concrete and See note (5)

Structural Steel (Rev. 1, 4/76) Structural Steel During the Construction Phase of Nuclear Power Plants.

Regulatory Guide 1.116 -Installation, Inspec- ANSI N45.2.8-1975-Supplementary Quality Conforms with tion and Testing of Mechanical Equipment and Assurance Requirements for Installation, Inspec- exception Systems (Rev. 0-R, 6/76) tion, and Testing of Mechanical Equipment and See note (6)

Systems for the Construction Phase of Nuclear Power Plants Regulatory Guide 1.123 - Quality Assurance ANSI N45.2.13-1976-Quality Assurance Require- Conforms Requirements for Control of Procurement of ments for Control of Procurement of Items and Items and Services for Nuclear Power Plants Services for Nuclear Power Plants (Rev. 1, 7/77)

Regulatory Guide 1.144 - Auditing of ANSI N45.2~12-1977-Requirements for Auditing Conforms Quality Assurance Programs for Nuclear of Quality Assurance Programs for Nuclear Power Plants (Rev. O, 1/79) Power Plants Regulatory Guide 1.146 - Qualification ANSI N45.2.23-1978-Qualification of Quality Conforms of Quality Assurance Program Audit Assurance Program Audit Personnel for Personnel for Nuclear Power Plants Nuclear Power Plants (Rev. O, 8/80)

TABLE 17 .2.0 NOTES

• Note (1) Some procedures which are frequently used are considered to be under frequent review and are not formally reviewed every two years. The specific types of procedures to which this applies is delineated, e.g. in station Administrative Procedures.

Note (2) The use or storage of food, drinks, and salt tablet dispensers in office areas within storage areas is permitted. The marking requirements of Appendix A3.9 to ANSI N45a2.2 - 1972 are for general guidance only and not considered to be mandatory by Vepco.

Note (3) Only QA/QC personnel are qualified to ANSI N45.2.6-1973. NDE personnel are qualified to SNT-TC-lA. Operational/functional testing personnel meet the requirements of ANSI N18.1-1971.

Note (4) Some Definitions used by Vepco are worded differently than those in ANSI N45.2.10; however, the general meanings are the same. The definitions of Certificate of Conformance, Certified Test Report, Construction Phase,

• Deviation, Inspection, and Storage are placed in the context of operating power stations and are made more specific.

Note (5) Vepco's program conforms to ANSI N45.2.5 - 1974 as applicable to the operations phase. It is not Vepco's intent to commit to each and every referenced document in this ANSI standard. Balances and volumetric buckets (ANSI N45.2.5, Section 2.5.1) are not calibrated.

Note (6) In some cases, inspections and tests are performed as an integral part of the installation procedure, in which case section 2.3 is not applicable in its entirety.

17 .2-4 Amendment Four Draft Five

17.2.1 ORGANIZATION

• 17.2.1.1 General Description Figures 17.2.1-1, 2, 3, and 4 illustrate the organizational relationships between the various groups which contribute to the power station quality assurance program.

Under the Senior Vice President-Power Operations, the System Power Operations Group is divided into five distinct departments; Quality Assurance, Nuclear Operations, Fossil and Hydro Operations, Fuel Resources and Environmental Services. Collectively, except Fossil and Hydro Operations, these departments are responsible for the licensing and operation of nuclear power stations. The Quality Assurance Department has prime responsibility for the operational quality assurance program. The Fuel Resources Department has prime responsibility for the quality assurance program for nuclear fuel.

17.2.1.2 Management of Operational Quality Assurance Specific responsibilities for operational quality assurance are:

NUCLEAR OPERATIONS A. Vice President - Nuclear Operations Responsible to the Senior Vice President-Power Operations and has corporate responsibility for the operation of nuclear power stations. As such, he has overall responsibility for the implementation of the requirements established by the quality assurance program for the operational phase of nuclear power stations *

• B. Manager-Nuclear Operations and Maintenance Responsible to the Vice President-Nuclear Operations for the operation of nuclear power stations and for the execution of the requirements established by the quality assurance program for the operational phase* of power stations. His approval is required on the establishment of these operational quality assurance program requirements.

C. Director-Operation and Maintenance Services Responsible to the Manager-Nuclear Operations and Maintenance for the day-to-day operation of the company's nuclear power stations. Has responsibility for assuring that the provisions contained in the nuclear operations quality assurance program relating to his area of responsibility are being fallowed.

D. Manager-Nuclear Technical Services Responsible to the Vice President-Nuclear Operations for technical support functions requiring specialization not available at the nuclear power stations.

• E. Station Manager

• Responsible to the Manager-Nuclear Operations and Maintenance for the 17 .2-5 Amendment Four Draft Five

overall safety and efficient operation of the station, and the implementation

• of quality assurance requirements in the areas specified by the Nuclear

• F.

Power Station Quality Assurance Manual.

Superintendent Technical Services Operations/Superintendent Maintenance/Superintendent Responsible to the Station Manager, through the Assistant Station Manager, for the safe and efficient operation and maintenance of the Station within their respective areas of responsibility, including the quality assurance program requirements as specified in the Nuclear Power Station Quality Assurance Manual.

G. Station Supervisory Personnel Responsible to the Station Manager (through their respective superin-tendents) for implementing the power station quality assurance program requirements applicable to their respective areas of responsibility.

H. Station Staff It is the responsibility of each member of the station staff to adhere to the provisions contained in the Nuclear Power Station Quality Assurance Manual when performing their work tasks to assure quality workmanship.

I. Safety Evaluation and Control The Safety Evaluation and Control staff, under the Director-Safety Evaluation and Control, provides an independent review of matters relating to the activities of the Station Nuclear Safety and Operating Committee, the Operating License and Te.chnical Specifications, changes and modifications, Technical Specification departures, investigations, tests, abnormal performance, and incidents reportable as required by 10CFR20 and 50; and to make recommendations on these matters. The Technical Specifications for each station further define their responsibilities.

J. Station Nuclear Safety and Operating Committee The Station Nuclear Safety and Operating Committee serves in an advisory capacity to the Station Manager. It has the responsibility of providing a continuing review of operational safety of the station. The committee reviews all normal, abnormal, operating, maintenance, test and emergency procedures that affect nuclear safety and changes thereto; all proposed changes to the Technical Specifications; and all proposed changes or modifications to systems or equipment. The Technical Specifications for each station further define the responsibilites of this committee.

The Station Nuclear Safety and Operating Committee is separate from operational QA activities in that its authority and responsibilities are not established by the operational quality assurance program. However, since the prime responsibility of this committee is to provide a continuing review of the operational and safety aspects of the station, it does perform a quality assurance function.

17 .2-6 Amendment Four Draft Five

FUEL RESOURCES

• A. Vice President-Fuel Resources Responsible to the Senior Vice President-Power Operations for the design, procurement, and use of nuclear fuel, and to establish policies and guidelines for the Quality Assurance Manual for Nuclear Fuel.

B. Manager-Fuel Resources Responsible to the Vice President-Fuel Resources for the administration of

.the quality assurance program associated with the design, procurement, and.

use of nuclear fuel. He has overall* responsibility for developing and implementing a nuclear fuel quality assurance program.

C. Director-Nuclear Fuel Accountability and Procurement Quality Responsible to the Manager, Fuel Resources for the implementation of the following areas:

1. Auditing of quality assurance activities associated with con-version, enrichment, fabrication, and design of the .nuclear fuel.

2. Inspection and surveillance activities associated with new fuel receipt, new and irradiated fuel movements; spent fuel shipping, and handling of nuclear fuel. *

3.

• Administration of the quality assurance program requirements in the Fuel Resources Department as delineated in the Fuel Resources Department Quality Assurance Manual for Nuclear Fuel. As such, he is responsible for developing and implementing a nuclear fuel manufacturing and design quality assurance audit .

program on current and potential nuclear fuel. vendors. . He is also responsible for nuclear fuel quality assurance liaison at the

• reactor site.

ENVIRONMENTAL SERVICES A. Executive Manager-Environmental Services Responsible to the Senior Vice President-Power Operations for providing

. *services which will fulfill the nonradiological environmental surveillance requirements.

• PURCHASING A. Manager-Purchasing Responsible for implementing the requirements of the Nuclear Power

$tation Quality Assurance Manual as related to the activities conducted by his department.

17.2-7 Amendment Four Draft Five

QUALITY ASSURANCE

• A. Executive Manager-Quality Assurance Responsible to the Senior Vice President-Power Operations for:

1. Es.tablishment and implementation of the quality assurance program for the engineering, construction, and operational phases of nuclear power stations.

2. The direction of the total quality assurance effort encompassing the engineering, construction, and operational phases of nuclear power stations.

3. Corporate emergency response planning and implementation of those plans for nuclear power stations.

The Executive Manager-Quality Assurance may make recommendations to the Vice President-Nuclear Operations or other levels of management. If he disagrees with any action taken by Nuclear Operations, and is unable to obtain resolution, he brings the matter to the attention of the Senior Vice President-Power Operations who will determine the final disposition.

B. Manager-Quality Assurance, Operations Responsible to the Executive Manager-Quality Assurance for:

1. The establishment and implementation of the quality assurance program for the operational phase of the nuclear power stations.

2. The technical support to the quality assurance effort associated with the operation and maintenance of nuclear power stations.

The Manager,...Quality Assurance, Operations may make recommendations to the Manager-Nuclear Operations and Maintenance or other levels *of management. If he disagrees with any quality assurance action taken by Nuclear Operations~ he notifies the Executive Manager-Quality Assurance.

C. Manager-Quality Assurance, Eng-ineering and Construction Projects Responsible to the Executive Manager-Quality Assurance for:

1. Establishment and implementation of the quality assurance program for the engineering and construction phases of nuclear power stations.

2. Surveillance and audit of vendors and contractors. -

3. Preparation and maintenance of the Vepco Quality Assurance Manual and the Vepco Vendors List.

D. Director-Quality Assurance, Nuclear Operations Responsible to the Manager-Quality Assurance, Operations for performing the following activities:

17.2-8 Amendment Four Draft Five

1. Development, maintenance, and implementation of suitable quality assurance auditing and inspection programs for all nuclear power

• 2.

stations in the Vepco System. The scope of these programs covers operating power stations, design changes, operation and maintenance.

Auditing to assure that technical requirements for operating nuclear power stations including the design bases, applicable regulatory requirements, and specified codes and standards, are correctly translated into specifications, drawings, procedures, or instructions.

3. Inspection of operating and maintenance activities at all nuclear power stations including testing, methods of operation, and modifications to systems, components, or structures, where applicable.

4. Development and maintenance of quality assurance training for nuclear operations quality assurance personnel to enable them to more effectively perform quality assurance functions.

5. Initiating action, when quality problems are identified within Nuclear Operations, recommending solutions to correct deficiencies and reinspection to insure that proper dispositioning has been rendered.

6. Formulating; establishing, reviewing and approving QA policies, procedures, and instructions for the activities relative to operation, preventative and corrective maintenance, in-service inspection, repair and modification.

7. Verifying the effectiveness of these procedures and their implementa-tion through a* formal audit program that complies with criterion XVIII, Appendix B to 10 CFR 50.

8. Preparation and maintenance of the Nuclear Power Station Quality Assurance Manual.

The Director-Quality Assurance, Nuclear Operations may make recommendations to the Director Operation and Maintenance Services or other levels of management. If he disagrees with any quality assurance action taken by Nuclear Operations he notifies the Manager-Quality Assurance, Operations.

E. Resident Quality Control Engineer Responsible to the Director-Quality Assurance, Nuclear Operations, and supported by his staff, for perf*,rming the following activities:

1. Assuring compliance with the Nuclear Power Station Quality Assurance Manual.

2. Establishing a comprehensive system of planned and periodic internal audits as the Director-Quality Assurance, Nuclear Operations directs.

3. Inspection of operating and maintenance activities at the power station including testing, methods of operation, and modifications to systems, components, or structures, where* applicable.

17.2-9 Amendment Four Draft Five

4. Performing specific quality assurance functions for the Station Manager (e.g. receipt inspections, procedure review, etc) as specified in the Nuclear Power Station Quality Assurance Manual .

F. Station Quality Control Staff The station Quality Control staff conducts audits and inspections in accord-ance with the Nuclear Power Station Quality Assurance Manual and performs other duties as directed by the Resident QC Engineer.

• Station Quality Control staff representatives have access to all areas of the power station at any time when deemed necessary for inspections, audits, and observations related to quality. They have access to station records as required for in depth auditing of station operations, including confidential personnel records (but only to the extent necessary to verify personnel

• qualifications or other information related to quality).

17 .2.1.3 Authority to Stop Work The Quality Assurance Organization has the authority, and the responsibility, to stop work in progress which is not being done in accordance with approved procedures or where safety or equipment integrity may be jeopardized.

17 .2.1.3.1 Imposition of "Stop Work" Station Quality Control Staff The station Quality Control staff representative advises the cognizant supervis9r or supervisory personnel on the scene to stop work in progress whenever he determines it is not being conducted in accordance with applicable procedures, instructions, guides, or standards or may jeopardize the safe operation of the station. The Station Resident Quality Control Engineer immediately notifies the Station Manager of the decision to stop work because of adverse quality conditions. He also notifies the Director- Quality Assurance, Nuclear Operations.

Station Manager The Station Manager considers the Quality Control staff's determination of the necessity to stop-work.*

1) If he concurs with the decision to stop work he initiates the necessary corrective action. Only after the discrepancy has been corrected and approved by the Quality Control staff does work resume. *

2) In the event the Station Manager does not concur with the Quality Control staff's decision to stop work, he may drder work to resume by notifying the Resident Quality Control Engineer and the appropriate station supervisory personnel of hL decision. He also notifies the Manager-Nuclear Operations and Maintenance of his course of action.

Manager-Nuclear Operations and Maintenance The Manager-Nuclear Operations and Maintenance is responsible for approving or disapproving the Station Manager's decision in those cases where the Station Manager 17.2-10 Amendment Four Draft Five

does not concur and orders work to resume.

Director-Quality Assurance, Nuclear Operations The Director-Quality Assurance, Nuclear Operations may refer any concerns he may have concerning the handling of "stop work" to Nuclear Operations and Maintenance management or Quality Assurance*management personnel. He may direct*imposition of "stop work" whenever he deems such action to be appropriate.

17.2-11 Amendment Four Draft Five

EXECUTIVE VICE PRESIDENT

• Y POWER SENIOR VICE PRESIDENT POWER OPERATIONS I

VICE PRESIDENT V!CE PRESIDEN'l' NUCLEAR OPERATIONS FUEL RESOU1\.CES N

.....I EXECVTI\'E ~lANAGER QUALITY ASSUHANCE EXECUTIVE MANAGER ENVIHON'.lE!'lTAL N

SER\'JCES MANAGER MANAGER Ml\. NAGER QUALITY ASSURANCE NUCLEAR NUCLEAR OPERATIONS OPERATIONS&: MAJNT. TECHNICAL SERVICES I I I I DIRECTOR NUCLEAR DIRECTOR DIRECTOR DIRECTOR QUALITY ASSURANCE* STATION OPERATION AND SAFETY EVALUATION TECHNICAL ANALYSIS NVCLEAR OPERATIONS MANAGERS MAINT. SERVICES AND CONTROL AND CONTROL SYSTEM POWER OPERATIONS

-ORGANIZATION FIGURE l'l.2.1-:1.

• EXECUTIVE MANAGER QUALITY ASSURANCE I

l\IANAGER MANAGER QUALITY ASSURANCE QUALITY ASSURANCE ENGINEERING AND CONSTRUC.PROJECTS I

PnOJECT PEnSONNEL N

I DIRECTOR DIRECTOR

>-'->" QUALITY ASSURANCE QUALITY ASSURANCE

...J FOSSlL OPERATIONS NUCLEAR OPERATIONS I

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.. EXECUTIVE MANAGER PURCHASING AND GENERAL SERVICES MANAGER PURCHASING VEFCO ORGANIZATION SHOWING RELATIONSHIP OP PURCHASING TO POWER OPERATIONS PIG'.qRE 11.2.1-4

17 .2.2 QUALITY ASSURANCE PROGRAM

• 17.2.2.1 General Descriptiori The objective of the Vepco Quality Assurance Program for operating nuclear power stations is to comply with the criteria as expressed in 10 CFR 50, Appendix B, as amended and with the quality assurance program requirements for nuclear power plants as referenced in ANSI N18.7-1976 and NRC Regulatory Guide 1.33, Feb. 1978. This program, its policies and procedures are described in the Vepco Nuclear Power Station Quality Assurance Manual and the station procedures, and it applies to those quality-related activities that involve the functions of safety-related structures, systems and components associated with the operation and maintenance of nuclear power stations and those non safety related components described in the FSAR. The vehicle for transmission of this program to all levels of management is the Nuclear Power Station Quality Assurance Manual. This manual describes the overall operational quality assurance program addressing, in individual subsections, all eighteen criteria of Appendix B, 10 CPR 50.

The goal of this program is to assure that procedures for the safe, reliable and efficient operation of the nuclear power station are specified and used in accordance with sound engineering principles.

The Program provides written policies, procedures, and instructions covering engineer:..

ing, design, procurement, modifications, periodic surveillance, testing, and maintenance after the systems have been installed, checked and turned over to Vepco for operation.

Detailed procedures and. instructions are issued by the station for *administrative, normal operation, periodic testing, abnormal and emergency conditions. An audit and inspection program has been implemented to provide assurance that these procedures are being correctly applied. The role of Vepco QA/QC personnel in this structure is specified in the Vepco Nuclear Power Station Quality Assurance Manual. The station Resident Quality Control Engineer reports to and is under the administrative and supervisory direction of the Director-Quality Assurance, Nuclear Operations. Vepco quality assurance personnel are thus completely divorced from production influences and fulfill a four-part role as follows:

1. Audit and inspect to ensure that the overall operation of the nuclear power station is carried out in accordance with Technical Specifications 5 applic-able codes~ NRC guides and regulations, and company policies.

2. Provide on a continuous basis, objective specified quality assurance and quality control services to the Station Manager as set forth in the Nuclear Power Station Quality Assurance Manual. (Examples~ Receipt inspections 5 procedure reviews, hold point inspections~ etc.)

3.. Serve as a management tool for station and system management personnel, illuminating problem areas, detecting trends, and providing recommenda-tions regarding solution of problem areas when applicable.

4. Provide all levels of management with an independent source of information regarding the quality aspect of station operations and maintenance activities.

Differences of opinion between QA/QC personnel and other departments are resolved 17.2-16 Amendment Four Draft Five

either at the station level by the Station Manager and the station Resident Quality Control Engineer or are forwarded through normal administrative chains of both individuals for resolution at the corporate level~ Final decision-making authority rests with the Senior Vice President-Power Operations.

17 .2.2.2 Quality Assurance Manuals The Vepco Quality A_ssurance Program policies, procedures, and instructions are documented as follows:

(a) Vepco Quality Assurance Manual, which is applicable to the engineering and construction phases of nuclear power stations; (b) Nuclear Power Station* Quality Assurance Manual, which is applicable to the operational phase of nuclear power stations; (c) Fuel Resources Department Quality Assurance Manual for Nuclear Fuel, which is applicable to design, procurement and use of nuclear fuel.

(d) Quality A.ssurance programs written specifically to accomplish major repair, modification and construction projects, when required. These programs .

shall be approved at the same level of management as the above manuais.

These manuals/programs are structured to correspond to. the *18 criteria expressed in Appendix B to 10 CFR 50. .

. The. Quality Assurance Department develops and maintains the Nuclear Power ~tation Quality Assurance .Manual which describes the activities of auditing, reviewing,- and inspecting performed during station operations, modification, refueling, etc. This manual addresses the criteria expressed in Appendix B of 10 CFR 50 and the guidelines of ANSI N18. 7-1976. It also identifies the interface between system organizations and the station as related to the overall operation QA program. This manual was issued in'..

September: 1974 for all operating nuclear power stations.

Listed in Table 17 .2.2 ure the titles and a brief abstract of each section of the Nuclear Power Station Quality Assurance Manual. This manual provides the detailed guidance

. for the operational phase of Vepco's nuclear power stations&

The preparation and continued maintenance of the Vepco and Nuclear Power Station Quality Assurance Manuals is . a responsibility of the Manager-Quality Assurance, Engineering and Construction Projects and the Director-Quality Assurance, Nuclear.

Operations respectively. All manuals are controlled copies unless specifically

• designated uncontrolled. These manuals are authorized by the Executive Vice President-Power and their use made mandatory for all Vepco personnel~

The preparation and continued maintenance of the Fuel Resources Department Quality Assurance Manual is a responsibility of the Fuel Resources Department. All manuals

• are controlled copies unless specifically designated as uncontrolled .

• 17.2-17 Amendment Four Draft Five

TABLE 17.2.2 Appendix B * *.

• Vepc6 10 CFR 50 .NPSQAM Criterion Section Title Abstract

.I I Organization Defin~s the relationship of departments to the quality assurance effort associated with the operation of the

• nuclear power station.

• II II Quality Control Defines the Operations Program *Quality Assurance Program, its overall responsibility and provisions.

III III Design Control Defines the policy, respon-

• sibility and procedures for exercising design change control within the Nuclear Power Station and the Sys-tern Power Department.

IV IV Procurement Establishes policy and pro-Document Control curement document control applicable to plant opera-tion and maintenance.

v v Instructions, Establishes guidelines

• . Procedures, and for preparing instructions, Drawings procedures and drawings *.

VI . VI

• Document Control . Establishes procedures for *.

the control of procedures and instructions *.

VII VII Control of Purchased Establishes methods for Material, Equipment . assuring that purchased and Services items conform.to the speci-

. fied quality requirements.

VIII VITI Identification arid * :Establishes procedures for Control of Material, the identification and con-Parts and Components trol of material, parts and components IX. IX Control of Special

• Establishes procedures which Processes assure that special processes are controlled and accom-plished by qualified personnel.

17.2-18 Arnendment Four Draft Five

• • Appendix B. Vepco 10 CFR 50 NPSQAM Criterion Section Title TABLE 17 .2.2 (cont'd)

Abstract x x Inspection Establishes a program for inspection of activities affecting quality.

XI XI Test*Control Establishes policy and pro-cedures for power stations test programs.

xn xn Control of Measuring Establishes procedures for and Test Equipment control and calibration of test and measuring equip-ment.

XITI XIII Handling, Storage Establishes policy and pro-and Shipping cedures for this function as related to material and equipment.

XIV XIV Inspection, Test Makes reference to appro- ..

and Operating Status priate administrative

• -** procedures which govern ..

this function.

xv xv Non-Conforming Establishes procedures for Material,. Parts, or reporting and controlling Components . non'.""conforming materials, parts, or components.

XVI XVi ..* Corrective Action Assures that conditions adverse to quality are promptly identified and

• corrected.

XVII XVII Quality Assurance Assures maintenance, iden-Records

• tification and retrieva-bility of records.

XVIII XVIII Audits Defines policy and pro-cedures for audit programs.

17.2-19 Amendment Four Draft Five

17 .2.2.3 Identification of Structures, Systems and Components Safety related structures, systems, and components are identified in the FSAR. The portions of these structures, systems, and components that are within the scope of the operational quality assurance program are further identified in the respective nuclear power station Administrative Procedures as required by the Nuclear Power Station Quality Assurance Manual. .

17.2.2.4 Periodic Review of the Operational Quality Assurance Program An audit of the Operational Quality Assurance Program will be conducted at least once per 24 months in accordance with the respective station Technical Specifications.

17 .2.2.5 Personnel Qualification Requirements The Executive Manager-Quality Assurance shall have a four year accredited engineering or science degree or equivalent with a minimum of 1 O years experience related to electric power generating facilities. At least 5 years of overall experience shall have been in a supervisory capacity, 2 years of which should have involved quality assurance related matters.

• The Manager-:-Quality Assurance, Operations shall have a four year accredited engineer-ing or science degree or equivalent with a minimum of 8 years experience related to electric power generation facilities, 2 years of which involve exp.erience in nuclear power stations. At least 4 years of overall experience shall have been fo a supervisory capacity, 2 years of which should have involved quality assurance related matters.

The Director-Quality Assurance; Nuclear Operations shall have a four year accredited engineering or science degree or* equivalent with a minimum of 6 years experience related to electric power generating facilities, 2 years of which inyolve experience in nuclear power stations. At least 2 years of overall experience shall have been in a supervisory capacity, 1 year of which should have involved quality assurance related matters.

The station Resident Quality Control Engineer shall have a four year accredited engineering or science degree or equivalent. A minimum of 2 years overall experience or equivalent training in power plant operations is a prerequisite with at least 1 year of this experience involved in nuclear power station operations.

The* Manager-Fuel Resources shall have a four year accredited engineering or science degree, or equivalent with a minimum of 10 years related experience in quality assurance or electric power generation facilities. At least 5 years of overall experience shall have been in a supervisory capacity, 2 years of which should have involved quality assurance related m*atters.

The Director-Nuclear Fuel Accountability and Procurement Quality shall have a four year accredited engineering or science degree or equivalent with a minimum of 8 years experience related to quality assurance or electric power generation facilities, 2 years of which should involve experience in n11clear quality assurance. At least 4 years of overall experience shall have been in a supervisory capacity, 2 years of which should have involved quality assurance related matters.

17 .2-20 Amendment Four Draft :Five

17 .2.2.6 Qualification and Certification of Q.A./Q.C. Personnel

• The qualification and certification of Q.A./Q.C. personnel is accomplished in accordance with the Quality Assurance, Operations Certification Program. This program provides for the certification and recertification of Level I, Level II, and Level III inspectors and for auditors and lead auditors ..*

The program *outlines the qualification and certification requirements for various

• QA/QC disciplines and requires the individual to be certified in each discipline prior to his performing specified inspection or audit functions associated with those disciplines.

In addition, employees in the Fuel Resources Department receive formal training through job related seminars and courses designed to increase their job proficiency.

The requirements for training are fully documented in procedures maintained by the Director, Nuclear Fuel Accountability and Procurement Quality.

• 17.2.2.7 Training of Other Vepco Employees All licensed Reactor Operators and Senior Reactor Operators are trained and retrained in accordance with the provisions. of 10 CPR 55. . .

Other station personnel engaged in activities affecting quality of structures, systems, equipment, or components are

• indoctrinated in health physics procedures and other appropriate station procedures required in the performance of their respective duti~s.

Training is also provided concerning the quality assurance program at the site, and includes as a minimum (1) overall company policies, procedures, and instructions which establish the quality assurance program, and (2) procedures which implement the quality

• assu~ance program related* to .the specific job-related activity. Off-site personnel

• engaged in activities affecting quality are trained within their depart1J1ent in the specific aspects of the Quality Assurance Program which encompasses their specific activity.

17.2.2.8 Transfer of Quality Assurance Activities from Construction to Operations Phase The management of technical and quality assurance interfaces between the constructor, architect-engineer, nuclear steam system supply (NSSS) vendor and Vepco during the phase out of design and construction is detailed in Section 14 of the Vepco Quality Assurance Manual. This procedure specifies the means of tagging and identifying structures, systems and components in a manner that assures continuity of indicators of the status of inspections and tests; and ensures that the effective transfer, storage, and control of records is accomplished. Formal transfer of the following Quality Assurance

• activities from the Architect-Engineer, NSSS Vendor or Constructor to Vepco is accomplished upon final acceptance of a structures system or component:

Design Control Procurement Document Control Document Control Control of Purchased Material, Equipment, and Services Identification and Control of Material, Parts and Components Control of Special Processes Inspection Test Control Control of Measuring and Test Equipment 17.2-21 Amendment Four Draft Five

Handling, Storage, Shipping, and Preservation Non-conforming Materials, Parts, or Components Corrective Action Quality Assurance Records The Architect-Engineer and NSSS Vendor are delegated the responsibility of developing and implementing a program, approved by Vepco, to assure that structures, systems, and components are so constructed that they will perform satisfactorily in service.

Vepco's surveillance of these programs is accomplished through the quality control inspection of selected vendor's shops and the witnessing of key shop tests on major components, e.g. hydrostatic tests, pump capacity tests, control systems checkouts, core and coil inspections, and final assembly inspections.

Vepco Resident Quality Control Engineers and Operating Staff also check the readiness of installed equipment for initial operation, and check the cleanliness of piping and

• equipment for initial operation of controls and protective devices. At the completion of initial operations and checks, Equipment Conditional Release forms are filled out by the Architect-Engineer Supervisor, Vepco Resident Quality Control Engineers, and Vepco Operating Staff signifying that the equipment is essentially complete and accepted by Vepco for formal Preoperational Testing. From specifications supplied by the A/E and NSSS Vendor, Vepco operating personnel prepare test procedures for the nuclear and safety-related power plant equipment, operate said equipment for the prescribed tests, record the necessary data and prepare summaries of test results.

These test data and results are reviewed _and evaluated by. the Architect-:-E11gineer and/or the NSSS Vendor as applicable, with final approval by the Station Nuclear Safety and Operating Committee.

The status of inspections and test performed on individual items is indicated through the use of stickers, tags, stamps or stampings, or labels, and is documented through the use of equipment record cards, test reports, field quality control preoperational test records, and check-off lists.

The Vepco Resident Quality Control Engineer verifies the readines of items for formal preoperational testing and evaluation through his audit of the specific data package and supporting documents verifying compliance to applicable specifications and codes, and through his audit of the item verifies the implementation of procedures.

Quality assurance records are maintained in the Master Quality Assurance File, which is designated and referred to as the Architect-Engineer Field Quality Control File. The responsibility for maintaining this file is delegated to the Architect-Engineer. The file provides a retrievable quality history for purchased items from their inception through specifications, purchase, manufacturing, shipment, receipt, installation, construction testing and initial operation including revisions and changes. Identification and retrieval of these records is readily facilitated through an established file index. On completion of the project the Master Quality Assurance File becomes a part of the station's permanent files. The responsibility for the maintenance of these files is delegated to the Station Manager. The program for maintenance of quality assurance records requires the periodic auditing of these records to assure implementation of record maintenance requirements as described in the Nuclear Power Station Quality Assurance Manual.

• • 17.2.2.9 Major Contractors Quality Assurance Program The ultimate responsibility for the safety aspects of the stations, including design and 17.2-22 Amendment Four Draft Five

conformance of equipment, and equipment installation to the design, rests with Yepco.

To administer this responsibility, Vepco delegates the establishment* and execution of the Quality Assurance Program during the Design and Construction phases to the Architect-Engineer and to the supplier for the nuclear steam supply system equipment, but in so doing Vepco retains the ultimate responsibility for the overall Quality Assurance.

The Quality Assurance organizations and programs, design and equipment specifica-tions, equipment Vendor qualifications, and quality standards, for both the A/E. and NSSS Vendor are reviewed and approved by Vepco. Conformance to the approved requirements and programs are assured through. close liaison with the project engineers of the three companies and by surveillance and audits conducted throughout the. design and construction phase by Vepco.

The Vepco audit program provides for a system of audits to be made of the A/E, the NSSS Vendor, and Vepco to verify their compliance with and the effectiveness of the respective Quality Assurance Programs. These audits are conducted by Vepco QA staff.

and/or qualified designees as selected by the Manager-Quality Assurance, Engineering and Construction Projects or the Manager-Quality Assurance, Operations.

l'l.2-23 Amendment Four

• Draft Five

17.2.3 DESIGN CONTROL

• Measures are established to assure that applicable regulatory requirements and the nuclear power station design bases are correctly translated into Vepco specifications, drawings, procedures, and instructions applicable to design changes and/or modifica-tions for the operating nuclear power station.

All design changes and/or modifications to safety related structures, equipment, system~ and components and those non safety related components described in the FSAR are reviewed, approved, and acted upon by the Station Nuclear Safety and Operating Committee in accordance with their responsibilities and functions as referenced in the Technical Specifications and the Nuclear Power Station Quality Assurance Manualo Design changes to these structures, equipment, systems and components approved by the Station Nuclear Safety and Operating Committee are forwarded to Safety Evaluation and Control Group of Nuclear Technical Services for an

• independent review. This review may be performed by Safety Evaluation and Control Group personnel, the staff of other company departments, or consultants. The responsibility for the development, identification requirements, monitoring, and implementation of an effective design control progr*am within the station organization is delegated to the Station Manager with input as appropriate from operations personnel.

The Nuclear Power Station Quality Assurance Manual, Section 3, "Design Control,"

delineates procedures that assure design changes, including field changes, are subject to design control measures commensurate with those applied to the orignial design and that applicable specified design requirements, such as design bases, regulatory require-ments, codes and standards are correctly translated into specifications, drawings,

~*. procedures, or instructions for those structures, systems and components classified as safety related or non safety related components described in the FSAR. This section provides for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the .

performance of a suitable testing program. When a testing program is solely used to test the adequacy of a design, the test will be conducted under adverse design conditions. The provisions of this section assure that the verifying or checking process is performed by individuals or groups other than those who performed the original design changeo These individuals or groups are identified and their authority and responsibility is described" Section 3, also indentifies the design documents that are required to be reviewed and the personnel responsible for their review and revision~ to assure that design characteristics can be controlled, inspected and tested and inspection and test criteria are identified. Design documents and revisions thereto are distributed to responsible supervisors to determine whether revisions to controlled documents are necessary. Design documents and reviews~ records and changes thereto are collected, stored and maintained in a systematic and controlled manner.

The Nuclear Power Station Quality Assurance Manual establishes measures for the selection and review for suitability of application of materials, parts, equipment and processes that are essential to the safety-related functions of the systems, structures and components. These measures include the use of valid and applicable industry standards and specifications, materials and prototype hardware testing programs, and design reviews. In the event of a design modification to a system which is safety related, or to non safety related components described in the FSAR, engineering studies are initiated to evaluate parts, equipment, processes, and material suitability for repair of such equipment or components; previously approved items are used without further review. Previously approved material, parts, or components used for a different 17.2-24 Amendment Four Draft Five

application are reviewed for suitability prior to approval for their new application *

• Quality control measures are assured through all levels of the design control program by the Design Control Engineer, Engineering Supervisor, Director-Safety Evaluation and Control and the Station Nuclear Safety and Operating Committee, culminating with a final review by the station Quality Control staff

• to assure quality standards are specified and deviations and changes from such standards are controlled. Any errors or deficiencies noted in the design process are documentated on the design change forms and subsequently corrected.

Procedures for design controls, analysis, and reviews have as their basis the applicable portions of documents referenced in the Nuclear Power Station Quality Assurance Manual, and include ANSI N45.2.ll - 1974.

General *procedures have been established to describe the design* interface between Vepco and the contractors for the review, approval, release, distribution, and revision I

. I of documents involving design interfaces.

Suitable design controls are applied to such disciplines *as reactor* physics; seismic, stress, thermal, hydraulic, radiation, and accident analysis; compatability of materials; and accessibility for in-service inspection, maintenance, and repair. Designs are reviewed to assure that (1) design characteristics can be controlled, inspected, and tested, and (2) inspection and test criteria are identified *

• 17.2-25 Amendment Four Draft Five

17 .2.4 PROCUREMENT DOCUMENT CONTROL The Nuclear Power Station Quality Assurance Manual, section 4 "Procurement Document Control11 describes the program for completing procurement documents including review, approval, document control and change control.

In addition, references to procedures that goverh the actfons of the *Quality Assurance Engineering and Vendor Surveillance staffs are made which include provisions for. access to the suppliers facilities and records, for source inspection and audit by quality assurance personnel, and qualification of vendors prior to the initiation of quality related actions when the need for such inspection or audit has been determined. This manual also provides a program for describing the records to be prepared, maintained, made available for review, or delivered to the purchaser prior to use or installation of the hardware, such as drawings, specifications, procedures, procurement documents, inspection and test records, personnel and procedure qualifications, material, chemical and physical tests results, and the identification of quality assurance requirements

• applicable to the items or services purchased, including sub-tier procurement require-ments when required. * * ** * *

• Procedures are established in the Nuclear Power Station Quality Assurance Manual to ensure that procurement documents reference all actions required by a supplier in accordance with the applicable codes, specifications, and drawings. These documents are reviewed by the Quality Control staff to confirm accuracy and adequacy of the quality references and requirements. The purpose of the review is to determine that 1) quality requirements are correctly. stated, inspectable and .controllable, 2) ther.e are adequate acceptance and rejection criteria,* 3) the documents have been prepared, reviewed and approved in accordance with quality assurance procedures, 4) that changes and revisions to procurement documents affecting the quality assurance program are reviewed and approved at the same scope and depth commensurate with the original document, and 5) the need for source surveillance or audit has been evaluated.

Procurement documents incorpo*rate the design basis technical requirements including the applicable regulatory requirements, component and material identification require-ments, drawings, specifications, codes and industrial standards, test and inspection requirements and special process instructions for such activities as welding, heat treating, non-destructive testing and cleaning as applicable.

Procurement documents for spare or replacement parts of safety related structures, systems and components are subject to controls at least equivalent to those used on the original equipment.

The purchase document, a copy of which is filed and available for review, is prepared by the cognizant supervisor and reviewed by the Quality Control staff for the quality attributes discussed above, and then undergoes the review and approval routing as determined by Vepco procurement policies and procedures. These reviews and approvals are documented .

• 17.2-26 Amendment Four Draft Five

17.2.5 INSTRUCTIONS, PROCEDURES AND DRAWINGS

• As* required by* the

• Technical Specifications, detailed written procedures are established, implemented, and maintained covering the following activities: (1) The procedures recommended in Appendix A of Reg. Guide 1.33, revision 2, Feb. 1978, as determined applicable by the Station Nuclear Safety and Operating Committee. (2)

Refueling operations. (3) Surveillance and test activities. (4) Security Plan implement-ation. (5) Emergency Plan implementation. (6) Fire Protection Program implementa-tion. These procedures are approved by the Station Nuclear Safety and Operating Committee.

Other activities affecting quality of structures, systems and components, within the scope of the 10 CFR 50 Appendix B are prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances. These activities are accomplished in accordance with these instructions, procedures, or drawings.

Applicable instructions, procedures or drawings include for reference appropriate qualitative and/or quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

• The Nuclear Power St.ation Quality Assurance Manual, Section 5, describes the sequence of actions and the requirements for developing, reviewing, approving and controlling procedures used for testing as well as corrective maintenance, operating, administra-tive and other procedures used at the power station. These requirements include references, prerequisites, precautions, limitations, manufacturer 1s specifications, check-off lists, and acceptance criteria. When applicable the acceptance limits and requirements contained in the design and procurement documents constitute a portion of the acceptance criteria referenced and contained in written testing procedures * ..

The station Quality Control staff reviews the documents to ensure revisions are made promptly and that obsolete material is deleted. They specifically review safety related maintenance procedures, design changes and purchase documents and changes thereto for compliance with the 18 criteria of Appendix B to 10 CFR 50 and have the authority to recommend changes to specificaitons, drawings, purchase orders, or manuals.

Through their stop work authority they can prohibit their use if found obsolete until correct documents can be utilized.

In addition to the above references, detailed procedures are included in the appropriate sections of the Nuclear Power Station Quality Assurance Manual .

• 17.2-27 Amendment Four Draft Five

17.2.6 DOCUMENT CONTROL

• Measures are established and documented within the operating nuclear power station describing the control of documents, such as procedures, instructions and drawings, to .

provide for their review, approval and issue, and changes thereto, prior to release and to assure they are adequate and the quality requirements are stated. Provisions call for, among other things, (1) the periodic review of approved nuclear safety-related station procedures~ the review and approval of all new station procedures and design changes prior to release, the review and approval of all changes/revisions to station procedures and design changes by the Station Nuclear Safety and Operating Committee, (2) policy and procedures for issuance of and changes to station drawings and approval of changes by Engineering, and (3) the maintenance and distribution of these procedures. Normally changes to documents are reviewed and approved by the same organizations that performed the original review and approval; however, this respons-ibility may be delegated to other qualified responsible organizations. Approved changes are incorporated into procedures and drawings, and other appropriate documents associated with the change. Procedures and drawings and changes thereto are processed, distributed and controlled. Station Records maintains a record of all holders of procedures and drawings and an index of all procedures, drawings, specifications and*

procurement documents, listing the current revision date. Instructions require that a copy of the appropriate procedure be available at the activity location prior to the commencement of that activity.

These measures are detailed in the Nuclear Power Station Quality Assurance Manual and the Technical Specifications.

The Nuclear Power Station Quality Assurance Manual, Section 6, "Document Control,"

lists and defines certain documents that require strict administrative control for distribution, revision and routing. These documents are categorized as "Controlled Documents." Examples of controlled documents are: Station Procedures, Final Safety Analysis Report, Station Drawings, Technical Specifications, and Precautions Limita-tions and Setpoint Document. Also set forth are the distribution and controlling procedures for design and procurement documents and the Quality Assurance Manuals and changes thereto. The station Quality Control staff makes periodic inspections of station documents to verify their status, using a current master c0py.

17, 2-28 Amendment Four Draft Five

17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES

• Prior to contract award an evaluation of suppliers is performed by one or more of the following: (1) The supplier 1s capability to comply with the elements of 10 CPR 50, Appendix B that are applicable to the type of material, equipment or service being procured, (2) A review of previous records and performances of. suppliers who have provided similar articles of the type being procured, or (3) A survey of the supplier1s facilities and quality assurance program to determine his capability to supply a product or service which meets the design; manufacturing and quality requirements.

Surveillance of* suppliers during fabrication, inspection, testing, and shipment of materials, equipment, and components is planned and performed in accordance with written procedures to assure conformance to the purchase order requirements as applicable. These procedures provide .for:

a. Instructions that specify the characteristics* or processes to be witnessed, inspected or verified, and accepted; the method of surveillance and the extent of documentation required; and those responsible for implementing these instructions. Surveillance may be performed on those items where verification of procurement requirements cannot be determined on receipt.

b. Audits and/or inspections which assure that the supplier complies with all quality requirements.

These evaluations are performed under the superv1s10n of the Manager-Quality Assurance, Engineering and Construction Projects. The results of these actions are documented and filed.

The Nuclear Power Station Quality Assurance Manual, Section 7, describes the require-ments and procedures for controlling purchased material, equipment and services for use on safety related structures, systems, equipment and components. The require-ments and procedures applied to spare and replacement parts are at least equivalent to those applied to the original parts. The manual assigns to the station Quaiity Control .

staff the responsibiiity for assuring that applicable material and equipment received at the station meet the requirements of the specifications, purchase order, code, drawing, or other purchasing documents. This assurance include8 the review of documentation received, physical inspections, cleanliness, packaging 1 marking or functional testing, as required. Purchased items are normally under the control of the "on-site" organization.

This organization is authorized to contact system organizations and NSS Suppliers, A.E.

contractors and subcontractors through the auspices of system representatives for assistance as required.

Perfodic evaluations or monitoring of procurement history of the suppliers are performed to verify continued supplier capability.

Documentation concerning the quality of material, components and equipment received is identified and reviewed by the power station Quality Control staff for conformance with the Purchase Requisition and Purchase Order in accordance with instructions contained in the Nuclear Power Station Quality Assurance Manual. This review must be completed before the receipt inspection can be considered completed and the mat~rial, components and equipment can be released for installation or use. The applicable section of the Receipt Inspection Report is completed by the power station Quality Control staff. The receipt inspection report form, a copy of the purchase order and other pertinent documentation are available prior to release of the material, equipment or component for installation or use and become a part of the station records. If the 17 .2-29 Amendment Four Draft Five

material or equipment conforms to procurement requirements, the power station

• Quality Control staff so indicates by affixing a Power Station Receipt Inspected OK sticker, Power Station Quality Control Accepted tag or other positive indicator.

If the proposed material to be purchased falls into the Fuel Resources area of responsibility, evaluation of suppliers prior to contract awards may be accomplished by Fuel. Resources Department. This is accomplished under the Director, Nuclear Fuel Accountability and Procurement Quality.

In the case of nuclear fuel, documentation concerning the quality is received and maintained by the Fuel Resources Department .

• 17 . 2-:rn Amendment Four Draft Five

"17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS

• Installed components at the Nuclear Power Station are adequately . identified and substantiated with documented records by the Architect-Engineer and the NSSS Vendor during the construction phase of the station. These identifications and records are maintained in the permanent files for the life of the station.

Replacement materials, parts,* and components including partially fabricated subas-semblies, are adequately and properly identified to allow control and traceability to pertinent quality assurance records such as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and chemical mill test reports. The identification system is consistent, as is practical, with that used during the construction of the station, with similar identification used during design change activities. The location and method of identification do not affect the function or quality of the item being identified. Verification of correct identification of safety related materials, parts, and components is required and documented prior to the release for fabrication, assembling, shipping or installation.

Procedures for implementing these controls are contained in the Nuclear Power Station Quality Assurance Manual.

f.*

17.2-31 Amendment Four Draft Five

17.2.9 CONTROL OF SPECIAL PROCESSES

• The control of special processes is maintained and implemented through the use of procedures, technique sheets, travelers and inspection verification reports, and personnel qualified in accordance with the applicable codes, specifications, and standards for the specific work. In instances where Vepco assigns such work to contractors, the contractor must submit their procedures and personnel qualifications to Vepco for approval prior to the start of work.

Special processes include, for example, those involving welding, heat treating, non-destructive and destructive testing, cadwelding, removal of undesirable substances during shop and site cleaning, degreasing and flushing, and verification of wall thickness

' of valves and other cast components important to nuclear safety.

Vepco conducts inspections of work involving special processes to assure that procedures and personnel are properly qualified and their workmanship is in compliance with applicable specifications, codes, and standards. The procedures relating to special processes are documented in the Nuclear Power Station Quality Assurance Manual.

Records of procedures, equipment and personnel qualification are maintained and kept current by the Director-Operations and Maintenance Services or Superintendent-Maintenance, as applicable .

17.?-12 Amendment Four L Draft Five

17 .2.10 INSPECTION Inspection procedures for those activities affecting quality have been established and are included in the Nuclear Power Station Quality Assurance Manual. This manual contains procedures which govern the inspection and documentation of activities relating to repairs, modifications, and changes made to safety related systems, structures and components. Written maintenance procedures are provided which include quality control hold steps for the power station Quality Control staff.

Examinations, measurements or tests of materials or components associated with safety related equipment and systems are performed for each work operation, where necessary, to assure quality. If inspection is impossible or disadvantageous, indirect control by monitoring methods, equipment, and personnel is provided. Both are provided when control is inadequate without both.

The station safety related maintenance procedures (including modification procedures) are reviewed by the station Quality Control staff to determine the need for an independent inspection and the degree and method if such an inspection is required.

Examinations, measurements or tests that require witnessing by Quality Control personnel are identified as "QC Hold" steps in procedures. The inspection performed at a quality control hold step is specific in nature; quality characteristics . and acceptance/rejection criteria are included or qualitative criteria such as operability checks, compliance with a procedural step, or cleanliness instructions are specified, and the inspection is documented by signature or initials on the written procedure form.

The power station Quality Control staff performs physical inspections, not only at hold steps specified in the procedure, but also at random spot intervals to ensure quality requirements are met and a copy of the appropriate procedure is being maintained at

• the work location. These checks are performed as the conditions of the maintenance warrant. These personnel and other inspectors are qualified in accordance with codes and standards as applicable to the Quality Control function they are performing.

The inspection program requires that inspectors be assigned by cognizant supervisory personnel or by the station Resident Quality Control Engineer as appropriate for the activity being inspected. An inspector may be a member of the organization performing the activity but must be a qualified individual other than the person performing the activity or the supervisor directly responsible for the activity. Person-nel so assigned shall become familiar with the procedure being used and other pertinent documents such as technical manuals and drawings prior to performing the inspection.

Personnel responsible solely for the conduct of nondestructive tests are qualified to SNT-TC-lA, 1975. Audits and reviews of their findings and associated corrective actions are periodically conducted by quality control personnel to assure that these procedures are being carried out in a quality manner. The inspectors qualifications are periodically reviewed for recertification.

Inspection procedures for those activities affecting the quality of nuclear fuel have been established by the Vepco Fuel Resources Department Quality Assurance Manual for Nuclear Fuel.

Generally, Rll physical inspections are under the control of the 11 on-site" organization.

However the Station Manager is authorized to request assistance as required through the Manager-Nuclear Operations and Maintenance as does the station Resident Quality Control Engineer via the Director - Quality Assurance, Nuclear Operations.

17.2-33 Amendment Four Draft Five

For inspections conducted which are not specifically required by a procedure, a QUALITY CONTROL INSPECTION REPORT is used. Instructions for preparing this form require various items to be included *which incorporate within their span:

(a) Quality characteristics to be inspected.

(b) Individuals or groups responsible for performing the inspection.

(c) Acceptance and rejection criteria.

(d) Description of the method of inspection.

(e)- Evidence of completion and certification of inspection.

(f) Record of the results of the inspection.

(g) Verification that all inspection operations are complete and acceptable.

The Nuclear Power Station Quality .Assuran~e Manual, Section 3, sets forth measures

.which assure that modifications to safety related equipment (including field changes) are subject to design control measures, including implementation and testing pro-cedures, that are commensurate with original requirements and are approved by the organization that performed the original design or other responsible and qualified organization. Section 4 of the manual requires that the station Quality Control staff review purchase documents applicable to safety related requirements and specifies that material, equipment, or services involving safety related systems shall be purchased to specifications or codes equivalent to those specified for previous purchases of the same item or those specified by a properly reviewed and approved revision. Section 16 of the Nuclear Power Station Quality Assurance Manual requires that the station Quality Control staff review all maintenance procedures on safety related equipment to insure the adequacy of inspection requirements included in these procedures.

• Section 10 and Section 11 of the manual require the documentation of the inspection and *test to include the type of ob$ervation or method of inspection, the evidence of completing and verifying a manufacturing inspection or test operation, and the acceptability of the .

results of the inspection or test. The inspector, or data recorder, dates and affixes his signature* or initials to the maintenance procedure or other procedure, Inspection Report, or the Test Critique form, as appropriate, upon completion of the test. In the event of a nonconforming item or the unacceptability of test results, the Station Manager, the station Resident Quality Control Engineer, or the cognizant supervisor as appropriate will assign corrective action.

Information relating to a nonconformance which is also docume~ted as corrective action by a maintenance report will be included with or referenced on the Inspection .

Report form or Test Critique form and will be forwarded to the Quality Control staff for reinspection or audit and disposition to station records.

17.2-34 Amendment Four Draft Five

17.2.11 TEST CONTROL

• The test program described in the Technical Specifications assures that safety relatect structures, systems, and components will perform satisfactorily when required. Written "Periodic Testn procedures for this program are reviewed and approved by the Station Nuclear Safety and Operating Committee. These test procedures include or reference:

(1) The requirements and acceptance limits contained in applicable design and procurement documents.

(2) Test prerequisites such as the availability of adequate and appropriate equipment and calibrated instrumentation; trained, qualified and licensed or certified personnel; the completeness of the item to be tested; suitable and controlled environmental conditions; provisions for data collection and storage.

(3) Instructions for performing the test.

(4) Mandatory inspection hold steps, as appropriate.

(5) Acceptance and rejection criteria.

(6) Methods of documenting or recording test data and results.

The 11 Periodic Test Program" provides for instrumentation and electrical equipment in the categories of (1) instruments installed as listed in the Technical Specifications, (2) installed instrumentation used to verify Technical Specifications parameters, and (3) installed safety-related instruments and electrical equipment that provide an *active function during operation or during shutdown i.e., vice being designated safety related solely because the instrument is an integral part of a pressure retaining boundary, shall*

be in a calibration program. This program provides, by the use Of equipment history data, status, records, and performance schedules, for the date that calibration is due and indicates the status of calibration. The identity of person(s) performing calibration is provided on the calibration documents.

Testing of modifications is done in accordance with procedures developed within the Design Change program described in section 17 .2.3 of this report.

Testing upon completion of maintenance is done in accordance with Maintenance Procedures developed as described in section 17.2.16 of this report .

• 17.2-35 Amendment Four Draft Five

i 7.2.12 .CONTROL OF MEASURING AND TEST EQUIPMENT A program with applicable procedures has been established and documented in the Nuclear Power Station Quality Assurance Manual that describes the calibration technique and frequency, maintenance, and control of all "Measuring and Test Equip-ment" (instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive test equipment) which are used in the measurement, inspection, and monitoring of safety related components, systems, and structures. Measuring and Test Equipment does not include: measuring equipment used for preliminary checks or utility trouble-shooting where accuracy is not required, e.g. circuit checking multi-meters. There is also no intention to imply a need for special calibration and control measures of rulers, tape measures, levels, and other such devices if normal commercial practices provide adequate accuracy. Controls for measuring and test equipment include the transportation, storage and protection of the equipment; the handling of associated documents, giving the status of all items under the calibration system such as maintenance history, calibration test data, and individual log sheets assigned to each device; and the permanent marking of each device by a unique identifying number assigned by the station Resident Quality Control Engineer.

The maintenance, calibration technique, and frequency of calibration of test and measuring devices utilized in activities affecting quality at the power station are normally performed as* specified in the manufacturer's instruction manual. In some cases the calibration interval may be assigned or changed based on accumulated experience by trained technicians. If standards are not available or there is some special reason that procedures cannot be followed, the modified procedures and/or interval are documented, including justification. In other cases, rather than require calibration at specified intervals, requirements may specify the device be calibrated prior to use, as in the case of torque wrenches or micrometers. Where permitted by the

. state of the art, reference standards are nci more than i the error allowed in the measuring and test equipment calibrated by that standard. All test and measuring devices used on safety related systems or equipment are calibrated utilizing reference standards whose calibration has a known valid relationship to nationally recognized standards or accepted values of natural physical constants. If no national standard exists, the basis for calibration is documented. Whether the device is calibrated at the power station or at a quality assured outside laboratory, one or more stickers are affixed on a conspicuous surface identifying but not limited to, date of calibration and next calibration due date.

When test and measuring devices utilized in activities affecting quality are found to be out of calibration, the station Resident Quality Control Engineer causes an evaluation to be performed and documented concerning the validity of previOus tests and the acceptability of devices previously tested. The station Resident Quality Control Engineer has the responsibility and authority to require that all previous tests and measurements performed during the current or proceeding calibration cycle be redone if the evaluation so indicates.

Implementation of these procedures is assured through routine inspections or audits by the station Quality Control staff.

Administrative controls for measuring and test equipment calibrated using the Periodic Test Program are as described in Section 17.2.11 of this report rather than as described in this section.

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17 .2.13 HANDLING, STORAGE AND SHIPPING

• Measures have been established in the Nuclear Power Station Quality Assurance Manual to provide adequate methods by qualified personnel for the classification, packaging, cleaning, preservation, shipping, storage, and handling of material and equipment received at the station.

These procedures, prepared in accordance with design and specification requirements, define responsibility, levels of essentiality, degree of receipt inspection, tagging, categories of inspection and their definition, and storage levels for categorized items.

The procedures also control cleaning, handling, storage, packaging, shipping and preservation of materials, components and systems to preclude damage, loss, or deterioration by environmental conditions such as temperature or humidity. Implemen-tation of these measures is assured by the quality control inspection function and verified by audits conducted by the QA staff.

In the case of nuclear fuel, measures have been established for the handling, storage, and shipping of such material by the Fuel Resources Department Quality Assurance Manual for Nuclear Fuel.

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17 .2.14 INSPECTION, TEST, AND OPERATING STATUS Measures for the identification and documentation of the inspection and test status for items to prevent inadvertent bypassing of specified inspections and tests are established and documented in the Nuclear Power Station Quality Assurance Manual and in station operating procedures. These measures define the three general categories of inspection and test status for items: Accept, Reject, or Hold. They provide for status identification through the use of stickers, tags, record cards, test *records, and check-off lists or logs. The operating status of items and/or equipment is identified through records, checklists,

• and operational tagging systems that are maintained beginning with the preoperational phase to indicate the status and authority to operate the item and/or equipment. (See also Section 17 .2.2.8 of this report.) Operating status is additionally controlled through the normal station operating procedures. The application and removal of the various status tags, stickers; and other indicators is controlled by procedures in the Nuclear Power Station Quality Assurance Manual.

Implementation of these measures is verified through audits conducted by the power station Quality Control staff. These audits assure that the required inspections, tests and other critical operations are controlled. *

• I Inspection procedures for those activities affecting the quality of nuclear fuel have been established by the Vepco Fuel Resources Department Quality Assurance Manual for Nuclear Fuel.

I l

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17.2.15 NONCONFORMING MATERIALS, PARTS AND COMPONENTS.

A documented system for controlling nonconformances observed during receipt inspec-tion, storage, fabrication and erection, installation, initial and/or acceptance testing, or operation is established and provides for the preparation, issuing, and distribution of Nonconformance Reports in accordance with prescribed procedures. These procedures apply to all nonconforming new or reworked materials, parts, and components. They do not apply to failures in service.

The identification, documentation, segregation, review, disposition and notification to affected organizations of nonconforming material, parts, or components, are described or referenced in the Nuclear Power Station Quality Assurance Manual, the Technical Specifications,. th.e station administrative procedures, and/or the station operating procedures. Non conformance of purchased services are controlled under Section 17 .2. 7 Control of Purchased Material, Equipment, and Services and Section 17.2.10 Inspection.

Specifically, instructions require that the individual discovering a nonconformance identifies, describes and documents the nonconformance on a Nonconformance Report.

This report is routed to the station Resident Quality Control Engineer for review and further distribution to the Station Manager and cognizant supervisor. The Station Manager or the station Resident Quality Control Engineer, when requested by the Station Manager, assigns corrective action to be taken or disposition to be made of the nonconformance including the assignment of the individual or group responsible. This procedure requires the corrective action or disposition of the nonconformance to be documented on the Nonconformance Report and signed by the person completing the corrective action or disposition. Final review or inspection and approval of the f: corrective action* or disposition of the nonconformance is the responsibility of the station Resident Quality Control Engineer who signifies his approval by affixing his signature to the Non conformance Report.

When a nonconforming item is identified, it is placed in the hold area established in the storeroom or other segregated location; if possible, and identified with a Quality Control Hold tag to prevent its inadvertent use. Quality Control Hold tags are affixed or removed only by station Quality Control staff personnel. Items considered totally rejectable are identified by a Quality Control Reject tag and disposed of as determined by the Station Manager.

Only the station Resident Quality Control Engineer may release "hold" material, parts, or components to station personnel on a risk basis following the documented approval of such risk release by the Station Manager on a "Release on a Risk Basis11 form. Each risk release is handled on a case basis and depends on the nature of the hold status. The basis and conditions of the release are described on the form, including the criteria for clearing the original hold status. Rejected material is not risk released.

A nonconformance dispositioned "accept as isn requires an engineering analysis and approval of the Station Nuclear Safety and Operating Committee. The results of this review and approval are documented and become a part of station records.

Should the disposition of a nonconformance require the rework or repair of materials, parts, components, systems, or structures such rework or repair is *reinspected or

• • retested by a method which is at least equal to the orig;inal inspection or test method .

The inspection requirements and the inspection, rework or repair procedures are documented and become a part of station records.

17.2-'.19 Amendment Four

The disposition and approval of nonconformances are the responsibility of the "on-site"

• organization. However, the Station Manager has the authority to request assistance as appropriate* from "off-site" organizations such as Nuclear Operations, other engineering groups, or the Quality Assurance Department. The station Resident Quality Control Engineer also has the authority to request outside assistance through the Director-Quality Assurance, Nuclear Operations.

The Nonconformance Reports are analyzed on an 11 as-occcuring 11 basis by the station Resident Quality Control Engineer and if quality trends are determined they are reported to appropriate levels of management.

In service failures of materials, parts and components are controlled by the use of Deviation Reports and/or Maintenance Reports as described in paragraph 17.2.16 of this report.

Implementation and verification of the procedures for the control of nonconformances are assured through audits by the power station Quality Control staff.

A documented system for the dispostioli. of non-conformances observed during the receipt inspection of nuclear fuel at all Vepco nuclear power stations is established in the Vepco Fuel Resources Department Quality Assurance Manual for Nuclear Fuel.

• 17.2-40 Amendment Four Draft Five

17.2.16 CORRECTIVE ACTION Corrective action measures are established as an integral part of the processing and resolving of nonconformances and failures in service. Through these measures, assurance is confirmed that significant adverse quality conditions are identified, documented, their cause determined, and the corrective actions have been taken that preclude repetition of the adverse quality conditions. Verification of the proper implementation of corrective action. measures and closeout of corrective action documentation is assured through the monitoring and auditing effort of members of the station staff responsible for quality assurance and the follow-up reviews and audits conducted by the station Quality Control staff. Adverse conditions significant to quality, the cause of the conditions, and the corrective action taken are reported to appropriate levels of both offsite and onsite management by use of a Deviation Report and/or Maintenance Report.

The procedures for. processing a Deviation Report require that each adverse condition significant to quality be categorized as either requiring a Licensee Event Report or as a nonreportable deviation. Nonreportable deviation refers to deviations not reportable to the Nuclear Regulatory Commission. The reporting requirements differ for each of the categories of deviation but require that appropriate levels of management be notified in each case. The station. Quality Control staff periodically audits the deviation reporting process.

Procedures require that all corrective maintenance of nuclear safety related material, parts or components be documented on a maintenance report. The Quality Control staff is notified prior to the commencement of safety related maintenance. The QC I* staff may then initiate a surveillance program as necessary. Examples of areas subject to surveillance are 1) the use of approved maintenance procedures, 2) the existence of Radiation Work Permits and proper tagout, if applicable, 3) the existence of required plant conditions, 4) documentation of Technical Specification requirements. If the QC staff elects to inspect the work, the surveillance does not have to be performed prior to commencement of work. Also, the station QC staff monitors completed Maintenance Reports to assure maintenance performed is properly documented, maintenance pro-cedures are properly signed off and check lists are completed if* applicable, Technical Specification limits were met if applicable, tagout records are cleared if applicable, any materials used are documented, and Maintenance Reports are being adequately reviewed by appropriate supervisory personnel.

Section 16 of the Nuclear Power Station Quality Assurance Manual "Correction Action, 11 requires that all rework or repair of nuclear safety-related materials~ parts, components, systems and structures be accomplished in accordance with approved written procedures. The procedures for rework or repair of safety-related equipment are approved by the Station Nuclear Safety and Operating Committee to insure provisions for an adequate inspection of the completed rework or repair and that this inspection is a method at least equal to the method originally used for inspection or an acceptable alternative. The cognizant supervisor reviews the completed procedures to insure the acceptance criteria have been satisfied and for the completeness of the post-maintenance check-out. The power station Quality Control staff monitors completed procedures to assure adequate supervisory reveiw.

The station Resident Quality Control Engineer determines the scope of the required quality assurance effort on the basis of the extent of modifications or repair to safety related equipment, systems or components. When this determination is made, the power station Quality Control staff reviews the proposed procedures to be used for the 17.?-41  :\mendment Four nrnft Pi11i:.>

modification or repair activities to ensure adequate quality control hold steps are included, the procedure complies with the Nuclear Power Station Quality Assurance Manual and ensures that the applicable codes and standards are referenced. For some repair efforts, briefings of quality control personnel by the power station Resident Quality Control Engineer are conducted. For major evolutions, such as refueling, steam generator modifications, etc., a series of seminars covering all aspects of the activity (Examples: radiation control, personnel hazards, stop work procedures, inspection criteria) are held.

i.

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• • 17.2.17 QUALITY ASSURANCE RECORDS The requirements and responsibilities for record transmittals, retention, and maintenance subsequent to completion of work for quality assurance/control records for the power station have been established, and are documented in the Nuclear Power Station Quality Assurance Manual.

Quality Assurance records relating to the operating status of the station and documentary evidence of the quality of items and activities affecting quality are maintained in accordance with the the Technical Specifications and the Nuclear Power Station Quality Assurance Manual. These records include plant history; operating logs; principal maintenance and modification activities; Licensee Event Reports; results of reviews, inspections, tests, audits and material analysis; monitoring of work perform-ance, qualification of personnel, procedures and equipment; and other documentation such as drawings, specifications, procurement documents, calibration procedures and reports, nonconformance reports and corrective action reports.

Identification and retrievability of these records is facilitated through proper indices and an established basic filing system. Record storage facilities are constructed, located and secured to reduce the possibility of destruction of records by fire, flooding, theft, and deterioration through environmental conditions such as temperature and humidity.

The power station Quality Control staff monitors these records to assure their completeness, adequacy, retrievability, and protection. They periodically audit these records to verify implementation of established policies and procedures. The record storage facilities at the nuclear power stations conform to Regulatory Guide 1.88, Rev *

• 2, Oct. 1976, with the following exceptions:

Surry Power Station:

Conforms to ANSI N45.2.9-1974 except that it is rated at approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; concrete floor has no slope; doors, frames, and hardware are three-hour rated; forced-air ducting is not equipped with automatic fire stops; conduit and wiring exist for interior lighting and security alarms. This facility is considered to meet the intent of ANSI N45.2.9 and provides adequate protection for records.

North Anna Power Station meets the intent of Chapter 3 of NFPA No. 232-1975, subject to the following provisions:

a) The file room is constructed with a minimum fire rating of two (2) hours.

b) Heating, cooling, and ventilation for the file room is by means of a forced air system, with all fans, filters, and heating and cooling elements located in an equipment room which is external to the file room. Ducts for this system are located on the ceiling of the file room and are provided with standard fire door dampers with a minimum rating of two (2) hours where they penetrate the file room fire barrier to other areas of the building.

c) The file room is provided with an early warning fire detection system and an automatic fire suppression system. A protective signaling system is provided, with a remote alarm located at a constantly attended station .

• d) Telephone service is provided to the file room, with the wire penetrations constructed and sealed in accordance with NFPA No. 232-1975.

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e) All records stored in the file room are stored in fully closed metal cabinets,

• f)

. which are arranged to provide adequate access and aisleway~. Work not directly related to the storage, retrieval or auditing of records is not allowed in the file room. Smoking, eating, and drinking is prohibited in the file room.

A wall divides the file room into two sections, with one section used as a file room and the other section used for microfilming of records. The dividing wall has a minimum fire rating of two (2) hours, including the fire door dampers in the duct penetrating the wall.

Quality assurance records relating to nuclear fuel are maintained by the Fuel Resources Department .

• 17.2-44 Amendment Four Draft Five

\'

17 .2.18 AUDITS.

The system of audits devised to verify compliance with quality related aspects of the power station is described in the Nuclear Power Station Quality Assurance Manual. The general audit policy specifies that quality assurance audits be conducted in accordance with a formal preplanned and scheduled system to ensure an adequate and meaningful quality assurance/control program is in effect. In addition to the above manual, the station administrative procedures, other station procedures and the Technical Specifi-cations serve as a basis for quality assurance audits.

The Quality Assurance, Operations section is delegated the responsibility for conducting periodic audits to determine the adequacy of the station's programs and procedures that they are meaningful and comply with the overall Quality Assurance Program. An audit includes an objective evaluation of quality related practices, procedures, and instruc-tions; the effectiveness of implementation; and the conformance with policy and directives; and also includes the evaluation of work area, activities, processes, and items, and the review of documents and records. Provisions are established requiring that audits be performed in those areas where the requirements of Appendix B to 10 CFR 50 are being implemented. These areas include as a minimum, but are not limited to, those activities associated with operation, maintenance, modification and repair controls; the preparation, review, approval and control of design changes, procurement documents, instructions, procedures, and drawings; receiving and plant inspections; indoctrination and training programs; the implementation of the operating and test procedures; and the remaining criteria in Appendix B to 10 CFR 50.

The Director.;..Quality Assurance, Nuclear Operations or his designee directs audits to be conducted. The audits are regularly scheduled on a formal preplanned audit schedule; the scope and frequency is determined by the quality status and safety importance of the activities being performed. Additional audits may be performed as deemed necessary by the Director-Quality Assurance, Nuclear Operations or the station Resident Quality Control Engineer, or when requested by the Station Manager as conditions warrant. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with prepared and approved audit plans or check lists.

The results of each audit are reported in writing to the Station Manager, Depart-ment/ Area Supervisor, Manager-Nuclear Operations and Maintenance, and the Director-Quality Assurance, Nuclear Operations. Additional internal distribution is made to other concerned management levels as deemed appropriate by the above offices upon receipt of the audit report.

Management responds to all audits and initiates corrective action where indicated.

Where corrective action measures are indicated, documented followup of the applicable areas through inspections, review or re-audits is conducted to verify implementation of assigned corrective actions.

If the Resident Quality Control Engineer and the Station Manager disagree on the acceptability of the station response to an auditi a response is not received in a timely manner, or corrective action is not accomplished as indicated on the station response, the matter is brought to the attention of the Director-Quality Assurance, Nuclear Operations who notifies the Director-Operation and Maintenance Services for resolu-

• tion. If the Director-Quality Assurance, Nuclear Operations does not agree with the resolution proposed, he notifies the Manager-Quality Assurance, Operations for ref err al to appropriate levels of management in accordance with Section 17.2.1 of this report.

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The responsibility for analyzing audit reports for trends and effectiveness lies with the

• Director-Quality Assurance, Nuclear Operations. As trends are discovered or the effectiveness of the program is in question, the analysis of the Director-Quality Assurance, Nuclear Operations is forwarded to the management level consistent with the seriousness of the problem. The management level attained could be as high as the Senior Vice President-Power Operations .

• 17.2-46 l:'\.mendment Four Draft Five