ML19259A656
| ML19259A656 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/29/1978 |
| From: | Short T OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7901080423 | |
| Download: ML19259A656 (36) | |
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7)'#E8S Omaha Public Power District 1623 HARNEY a O M A H A. NESRASKA 68102 m TELEPHONE 536-4000 AREA CODE 402 Dece=ber 29, 1978 - i ( S.S.s 4 6b,.
b-Director, Office f Iluelear p f/t'fD L I'aterial Safety ad Safeguard 2 - I C Fd,4 /.l ,q O 0 U. S. Iluclear Regulatory Commission q / 7p ;-
Washington, D. C. 20555 '6 g 1
Reference:
Facility Operatin6 License Ilo. DPR h0 'xi N .
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Fort Calhoun Station Unit :To. 1 ,N Quality Assurance Program Gentlemen:
The Omaha Public Power District possesses a general license within the scope of 10 CFR Part 30 for byproduct material. Paragraph 71 51 of 10 CFR Part 71 re; quires the licensee to establish, maintain, and execute a quality a.-surance program satis ^ying each of the applicable criteria specified in Appendix E, " Quality Assurance Criteria for Shipping Packages for Radioactive Material".
Enclosed is a description of that progran applicable to Fort Cal-houn Station Unit 'To.1, Docket Ilo. 50-285, for file in accordance with Section 71.51 of 10 CFR Part 71.
Sincerely, j
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.. E. Sh _t ,j g g'i9 C Assistant General Manager - in m.', >9 -fff TES/ FAT:jcm -
A<t Enclosurc hb cc: LeBeeuf, Lamb, Leiby & MacRae 1757 "II" Street , II. W.
Washingten , D. C. 20036 11623 7901080 9 3
If.0 QUALITY ASSURANCE DURING THE OPERATIONS PHASE This document describes the Omaha PLblic Power District's (OPPD) Quality Assurance Program for the operation of Fort Calhoun Station Unit No.1. The program is based on the criteria of Appendix B to ICCFR Part 50, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants;"
General Design Criterion 3, Appendix A to 10CFR Part 50, " Fire Protection;"
Appendix E to 10CFR Part 71, " Quality Assurance Criteria for Shipping Packages for Radioactive Material;" and the guidance provided in: American National Standard, ANSI N45.2, " Quality Assurance Program Requirements for Nuclear Power Plants," and its associated daughter standards; officially promulgated Regulatory Guides and Standards associated with WASH 1283, WASH 1309, and WASH 1284; and Appendix A to Cranch Technical Position 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants." The program will be applied to:
those structures, systems, components, or items whose satisfactory performance is required to prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public; those fire protection systems and equipment used or installed in all areas housing safety-related equipment, and other areas where an unsuppressed fire could potentially damage safety-related structures, systems or components; and those activities affecting the components of radioactive material packaging for transport which are significant to safety.
17.1 Organization OPPD's organization for carrying out an effective operations phase Quality Assurance program is shown in Figure 17.1. The Division Manager - Environmental and Regulatory Affairs is the upper level off-site management position which has direct management responsibility for formulation, implementation, and assessment of the effectiveness of the Quality Assurance Program. The Division Manager -
Production Operations is the upper level off-site management position which has direct management responsibility for plant operations and for formulation, implementation, and assessment of the effectiveness of the Fire Protection Program and the Packaging of Radioactive Material for Transport. Those positions in Figure 17.1 that have responsibility for Fire Protection Program implementa-tion are indicated by an asterisk (*) and those positions that have responsibility for Radioactive Material Packaging implementation are indicated by a (#). The Division Manager - Engineering is the upper level off-site management position which has direct responsibility for designation of those structures, systems, components or items classified as Critical Quality Elements (CQE's) and covered by the Quality Assurance Program, and for designation of the fire protection systems, equipment, and zones covered by the Fire Protection Program. The Division Manager - Material Management is the upper level off-site management position which has direct management responsibility for fomulation and imple-mentation of the Nuclear Purchasing Procedures.
17.1.1 Manager - Fort Calhoun Station l
The Manager - Fort Calhoun Station shall have direct responsibility for the i safe operation of the nuclear power facility. In all matters pertaining to the nuclear facility, the Manager - Fort Calhoun Station shall report to and I be directly responsible to the Section Manager - Ooerations.
(1)
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17.1.2 Plant Review Committee A comittee composed of plant staff members designated as the Plant Review Committee shall act in an advisory capacity to the Manager - Fort Calhoun l Station. The responsibilities and authority of the Plant Review Committee are delineated in Section 5.5.1 of Fort Calhoun Station Unit No.1 Technical Specifications, Appendix A to Operating License No. DPR-40.
17.1.3 Safety Audit and Review Committee (SARC)
Another comittee composed primarily of off-site, highly qualified and experienced District management personnel and consultants, designated as the Safety Audit and Review Comittee (SARC), shall function to provide the independent review and audit of activities as designated in Section 5.5.2 of Fort Calhoun Station Unit No.1 Technical Specifications, Appendix A to Operating License No. DPR-40. The SARC reports to and advises the Assistant General Manager - Production Operat'.ons on the reviews and audits of the designated activities. -
7.1.4 Manager - Ouality Assurance The Manager - Quality Assurance is responsible for the development and imple-mentation of the Quality Assurance Program for design, construction and operation.
This responsibility extends into all project and operations activities including engineering, design, procurement and construction. He reports on all technical and administrative matters to the Division Manager - Environmental and Regulatory Affairs. This reporting arrangement provides isolation of construction and oper-ational costs and scheduling influences from activities performed by the Manager -
Quality Assurance. He has the duty and authority to identify quality-related problems; to initiate, recommend or provide solutions; and to verify the imple-mentation and effectiveness of corrective action taken. He has authority to "Stop Work" on design, procurement, fabrication, installation, or packaging of safety-related structures, systems or components, fire protection systems, fire protection systems and equipment, and shipping packages for radioactive material.
His principle duties and responsibilities include the following:
(1) Manages the OPPD Quality Assurance Program.
(2) Supervises and coordinates an independent audit, review and
' update of OPPD quality activities to assure compliance with, and offectiveness of, the Quality Assurance Program.
(3) Training and indoctrination of OPPD personnel in Quality Assurance activities.
(4) Prepares Quality Assurance procedures, instructions, and reports. Preparation and maintenance of OPPD's QA Manual.
(5) Reviews draft standards submitted by various standards agencies for review. Coordinates response by District for QA-related draft standards.
(6) Acts as an internal consultant on Quality Assurance and nuclear safety related matters.
(2) -
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(7) Maintains liaison with the NRC and vendors on quality matters.
(8) Maintains a file of quality related codes and standards for the construction and operation of nuclear power plants.
(9) Reviews design data and changes, operating procedures and test reports for quality requirements.
(10) Serves as a member of various cerratttees including the Safety Audit and Review Committee.
(11) Maintains OPPD's list of qualified vendors and suppliers.
Adds and removes names from this list as necessary to pre-serve quality standards within the corporation.
(12) Verifies that the Quality Assurance related requirements of the Fire Protection Program, approved by the NRC, are satisfied.
The qualification requirements of the Manager - Quality Assurance are:
(1) A college degree or equivalent in engineering. Registra-tion as a professional engineer in the state of Nebraska is desirable. Advanced degree in management or work in quality-related discipline is desirable.
(2) Eight (8) or more years in a supervisory or management position related to the operation, maintenance, testing, and construction of nuclear power plants, including quality assurance.
(3) Basic understanding of regulations, standards, and gafdes relating to quality assurance.
(4) Thorough administrative and supervisory skills and technical knowledge of quality assurance requirements for nuclear power plants.
(5) A high degree of initiative, sound judgment and maturity.
Must have the abfif ty to make sound decisions and defend them to top management.
(6) The ability to work closely and in harmony with others.
The ability to coordinate several complex operations simul-taneously.
(71 An excellent degree of emotional stability is a major require-ment of this position.
(8) Must possess skill as a manager and a very high degree of personal integrity.
(3)
The Manager - Quality Assurance has assisting him in the execution of his duties and responsibilities a QA Engineering Staff as necessary, including:
(1) The Coroorate GA Engineer - has primary responsibility for OPPD Quality Assurance activities during design and procure-ment.
(2) The Construction QA Engineer - has primary responsibility for all Quality Assurance activities at the construction site.
(3) The Ooerations QA Engineer - has primary responsiblity for Quality Assurance activities at an operating nuclear power plant.
The Corporate QA Engineer's duties and responsibilities, are:
(1) Plans, schedules, and conducts audits of procurement (including fusi) and design activities to determine ccm-pliance with and effectiveness of the District's QA Program.
(2) Maintains a list of qualified vendors and services to nuclear power plants operating and under construction.
Conducts necessary audits of vendors and suppliers and reviews their QA Manuals and programs in making this determination.
(3) Coordinates source inspection and witnessing of test of components and equipment for nuclear power plants as required.
(4) Maintains file of applicable QA codes and standards for construction and operation of nuclear and fossil power plants, including their ordering and distribution. Fur-nishes interpretation of same on request.
(5) Prepares needed QA Procedures and changes to QA Manual.
Controls distribution of QA Manual.
(6) Assists in conducting QA reviews of procedures, tests, test results, DCR's and other documents requiring QA review.
(7) Maintains District's QA files, including QA training records and qualification files.
The Construction QA Engineer's duties and responsibilities are:
(1) Plans, schedules, and conducts audits of construction activities to determine compliance with and effectiveness of the District's QA Program.
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(2) Assists in conducting QA reviews of procedures, tests, test results, field changes, and other documents requiring QA review during construction.
(3) Provides training for and qualifies OPPD civil, mechanical and electrical QA inspectors for the construction effort.
(4) Maintains liaison between Contractor and Architect-Engineer QA and QC personnel.
(5) Monitors accumulation, active files storage and transfer of QA records to the QA records vault.
(6) Interprets codes and standards involving construction activities. ,
(71 Identification, reporting and followup action on construc-tion deficient items requiring corrective action.
(8) Acts as on-the-scene advisor to the construction management personnel on matters of quality.
(9) Assists in monitoring and auditing of the testing program.
The Operations QA Engineer and his staff of QA inspectors are stationed at the Fort Calhoun Station and are involved only in QA activities. The l
Operations QA Engineer's duties and responsibilities are:
(1) Plans, schedules, and conducts audits of operati.ng plant activities to determine compliance with and effectiveness of the District's QA P ogram.
(2) Maintains permanent QA record vault and other QA files at an r.perational nuclear power plant.
(3) Advises Stores Clerk on Quality Assurance requirements l relating to the maintenance, storage and inspection of spares for the operating plant.
(4) Reviews CQE, fire protection, and radioactive material packaging, work requests, maintenance work orders, requests for quotations, purchase orders, work and installation packets and other documentation for quotations, purchase orders, work and installation packets and other documenta-tion for inclusion of necessary quality related data, adding same as necessary, to ensure complete documentation for an operating plant.
(5) Witnesses inspection of incoming material, as required, to ensure quality and documentation.
(6) Acts as on-the-scene advisor to the Manager - Fort Calhoun i Station on matters and questions related to QA activities.
(5)
(7) Assists the Manager - Quality Assurance in the training of Station and other District personnel in matters relating to QA activities. 1 (8) Assists in monitoring and auditing of the quality assurance related portions of the testing program including testing of fire protection systems and the qualifications of test persSnne?.
(9) Assures the effective implementation of the Fire Protection Program on site by planned inspections and scheduled audits.
He will report the results of these inspections or audits to the Manager - Quality Assurance who will assure and verify that the results are promptly reported to cognizant manage-ment personnel.
17.1.5 QC Staff ~
The QC Staff is responsible for quality control actions as specified in Stand-ing Orcer G-26. The QC Staff reports to the Supervisor - Maintenance, Fort Calhoun Station.
17.1.6 Division Manager - Material Management s The prime QA responsibilit.y of the Division Manager - Material Management is to provide unifonn procedures to be used by other District personnel when procuring Critical Quality Elements for Fort Calhoun Station Unit fio.1.
Other specific duties as prescribed by the fiuclear Purchasing Procedures include:
(1) maintenance of procurement records; and (2) direction of corrective action by suppliers for deficiencies in his documentary evidence of quality, shipping damage, or count discrepancies.
17.i.7 Section Manager - Generating Station Enc _ineerinc_
ine Section Manager - Generating Station Engineering, under the Division Manager -
Engineering, has primary responsibility for maintenance of as-built data; perfor-mance and review of detailed design for the nuclear power plant; development and review of procurement specifications; classification of safety-related structures, systems ar.d components; and the modifications associated with the Fire Protection Plan.
17.1.8 Section Manager - Technical Services The Section Manager - Technical Services, under the Division Manager - Production Operations, has primary responsibility for control of technical support for the nuclear pwc plant staff, including nuclear material management, radiological and cherrical control, plant modifications, environmental sciences, and packaging of low specific activity radioactive material for transport.
(6)
17.2 OA Program 17.2.1 Corporate Policy OPPD's corporate policy is to construct and operate nuclear power plants with due regard for public and plant safety as prescribed by various regulatory requirements. Since there is a close correlation between safety and plant quality, OPPD has as its goal the establishment of a program for quality achievement and assurance in nuclear power station design, construction and operation which assures that the above policy is met. The OPPD OA Manual is the document which states OPPD's corporate quality policies, goals and objec-tives, and defines responsibilities.
OPPD assures transmittal of these quality policies to all concerned by con-trolled distribution of the QA Manual and changes thereto to all levels of management associated with the OPPD QA Program. In addition, specific QA Procedures are authorized and promulgated, further defining detailed objectives for attaining and maintaining high quality in the design, construction, and operation of its nuclear power plants.
OPPD's Quality Assurance Program has the full support of upper management.
The Assistant General Manager. authorizes issuance of the QA Manual and all revisions thereto, which defir.es the general requirements and specifies the l responsibilities for implementing OPPD's Quality Assurance Program. Imple-mentation of the general recuirements documented in the QA Manual is facilitated by specific requirements anc. procedures documented in the Purchasing Manual, Quality Assurance Procedures, Generating Station Engineering Procedures Manual, and the Fort Calhoun Station Operating Manual.
I The Programsafety-related are identifiedstructures, in Appendixsystems, and components C (and Attachment controlled A to Appendix C of theby)the QA QA Manual. Actual identification of the mechanical and electrical systems and components is by means of P&ID flow and electrical diagrams, and by means of listing other major components and systems not covered by P&ID's. The codirig was accomplished based upon guidance from the NSSS supplier and the Architect-Engineer using the 1971 ASME Code,Section III, as modified by ANS-18.2 (January 1973). The ASME Section III code was t. sed as a guideline to establish boundaries shown on P&ID's. Since the majority of the systems at Fort Calhoun Unit 1 were built to USAS 831.1 or B31.7 requirements, the boundaries shown on P&ID's may or may not indicate a real difference in quality recuiremnts. Replacement or addition of components or parts, as allowed by ASME Section XI, should be done using the construction code in effect at the time of installation of the original component or part. If the component or part failed due to inadequate design, then upgrading the design to include ather requirements is warranted. Certain expendable or consumable items necessary for the functional performance of safety-related structures, systems, or components, such as welding rod, dye penetrant examination materf als ar.d boric acid, are received, stored, tested, expended as safety-related. With regard to fire protection, the QA Program is applicable to the fire pumps, main loop firemain piping, fire walls, penetration fire seals, automatic initiated detector systems, automatic initiated independent fire suppression systems, and all piping, valves, sprinklers, and nozzles asso-cf ated with automatically initiated water fire protection systems. The actual fire areas, room numbers, and protected systems are as shown in Appendix D of the QA Manual. The pertinert sections of this program shall be applied to the Fire Protection Program to an extent consistent wtth their importance to safety.
Therefore, Sections 17.6,17.8,17.9,17.12 and 17.13 are not applicable.
(7)
The QA Program shall apply to the procurement and use of packaging for the transsort of radioactive material. This shall include receptacles, wrappers, and tiefr contents excluding fissile material and other radioactive material, but including absorbent material, spacing structures, themal insulation, radiation shielding, devices for cooling and for absorbing mechanical shock, external fittings, neutron moderators, nonff ssile neutron absorbers, and other supplementary equipment which have safety significance. The programs all assure that the package design, fabrication, assembly, testing, maintenance, modification, and repair conform to the approved design of each individual package and that the handling, storing, cleaning, inspecting, assembling and shipping meet the requirements of 10CFR Part 71 and Department of Transporta-tion Regulations.
Any disputes which cannot be resolved to the satisfaction of either the Manager - Quality Assurance or the Division Manager - Environmental and Regulatory Affairs will be brought before the Assistant General Manager. f
. I In addition, periodic training sessions are held to promulgate and explain policies, goals, and objectives including changes thereto. Needed changes to the OPPD QA Program have been identified by means of:
- a. planning, performing and reporting audits
- b. continuing review of NRC Regulatory Guides and ANSI N45.2 standards c, participation in the Edison Electric Institute Task Force on Quality Assurance
- d. response to NRC questions and identified defi-ciencies Changes to the Fort Calhoun Station Unit No. 1 QA Program are accomplished by issuing technical supplements to the QA Program. These changes are not incorporated into the FSAR.
17.2.2 OA Manual The Preface of~the OPPD QA Manual states: l
" Tite QA Manua.C sh1LL be . implemented and applied to nuclea,t pcwet statwns being designed, const. ucted and cpetated bij QPPD. This QA Manual establishes the CPPD Quality Assa,t-ance Pugram and sets for. tit Ste Quality Polic,ies fo,t CPPD.
Compliance teith 6 tis QA Manual as weLL as QA Pucedu,tes developed .the,tefum a,te mandatatu. Vanagemertt shat.l give full support .to ma,intaint.ng an ef fective quality pugram.
Compliance with applicable ,tequitemertts of the QA Manual sha.it be made a condition of conttact for suppo.1t,ing Com-panics."
The OPPD QA Manual requires that OPPD organizations and Companies under contract to supply technical services or products for the plant comply with the following requirements:
(8) .
- a. The authority and duties of individuals and groups perfoming quality assurance functions are clearly established and delineated in writing. They have sufficient authority and organizational freedom to:
(1) identify quality problems (2) initiate, recommend or provide solutions for conditions adverse to quality (3) verify implementation
- b. An individual or group assigned responsibility for QA functions, such as auditing or otherwise verifying that an activity has been correctly- performed, is independent of the individual or group directly responsible for per-foming the specific activity. -
Copies of the QA Manual are issued in a controlled manner. A nailing list is maintained by QA showing recipients of the QA Manual. Personnel signify the receipt of their copy of the QA Manual by signing and returning a receipt card to the Manager - Quality Assurance. Recommended changes to this manual are solicited and all such recommendations are given due consideration by the Manager - Quality Assurance. Necessary revisions are prepared, reviewed for adequacy, approved and issued in a controlled manner similar to the QA Manual.
These revisions are also controlled by means of a receipt card.
Revisions are dated and identified with fomal revision numbers as they are issued and contain a list of effective pages so that individuals in the field have the capability of determining if their QA Manual is complete and up to date.
17.2.3 QA Procedures OPPD assures that the various QA Program Procedures are derived from QA policies, goals and objectives by means of a review of these procedures, both prior to issuance and during audits of the activity prescribed by the procedure. Procedure review is accomplished in accordance with QAP #3, Document Review Procedure. Audits are conducted in accordance with QAP #17, Audit Planning, Performance and Reporting.
I 17.2.4 Training and Indoctrination Personnel responsible for performing quality-affecting activities are instructed as to the purpose, scope, and implementation of the quality-related manuals, instructions, and procedures by participation in the OPPD " Quality Assurance Training Program," the Fort Calhoun Station " Indoctrination Program and Training Program," the Chemical and Radiation Protection Training Program, and the on-the-job training provided by each activity.
(9)
The QA Manual specifies that personnel performing quality-affecting activities are required to possess documented evidence that they are trained and qualified in the principles and techniques of the activity being performed. Quality Assurance Procedures providing for training and qualification in the principles and techniques of the activity being performed are as follows:
(1) QAP #10, Nondestructive Evaluation (NDE) Personnel Administration (2) QAP #18, Auditor Training Qualification (3) QAP #19, QA Indoctrination and Training of Personnel (4) QAP #8, Qualification of Construction Inspectors Fort Calhoun Station standing orders specify the training and qualification requirements for operators, maintenance personnel and chemistry and radiation protection personnel. The QA auditing and surveillance programs provide assurance that the personnel are trained in the activity concerned prior to the event. The Fort Calhoun Station Training Manual specifies the training and qualification requirements for Security and Fire Brigade personnel.
Standing Order G-40 specifies the qualification and certification of Quality Control personnel.
The scope, the objective, and the method of implementing the various indoctri-nation and training programs are prescribed in writing and records are main-tained to verify the progress and success of the programs. This documentation is audited and the programs receive periodic reviews within the applicable divisions to verify their adequacy.
The indoctrination and training programs described above assure that the proficiency of personnel performing quality-affecting activities is maintained by specifying retraining, re-examining, and/or recertifying in accordance with the specified requirements.
The indoctrination and training programs provide for documenting the training sessions, describing the content, the date held, the attendees, and the results of any examinations conducted inherent therewith..
17.3 Design Control The OPPD Quality Assurance Program provides for several levels of design con-trol for mndification of or additions to an operating nuclear power plant.
OPPD design activities meet applicable NRC Regulatory Guide requirements for all safety related activities including Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants." QA audits assure that OPPD's design control measures provide a clear definition of design interfaces, review and approval of initial design, including changes or revi-sions, and that those performing design review activities are independent of those originating the design. The verification of engineering and design adequacy of the contractors' design documents will be performed in accordance with the contractor's approved Quality Assurance Program and Procedures and by OPPD through review by either Generating Station Engineering (GSE) or Tech-nical Services, and the Plant Review Comittee.
(10) .
For the Fire Protection Program, the applicable guidelines of Regulatory Guide 1.120, or approved alternatives, will be included in design and procurement documents prepared by any person initiating design or procurement documents.
New designs and plant modifications, including fire protection systems, will be reviewed by qualified personnel to assure inclusion of appropriate fire protection requirements. These reviews will include items such as:
- a. Reviews to verify adequacy of wiring isolation
- b. Reviews to verify appropriate requirements for room isolation Quality standards will be specified in the design documents such as appropriate fire protection codes and standards. Deviations or changes from these standards will be individually approved.
Procedures for OPPD design development and review are contained within the QA i Manual, Station Operating Manual, GSE Procedures Manual, and the Plant Modifi- I cation Procedure. The GSE and Technical Services design activities are controlled through GSE Procedures Manual. Plant Standing Order No. G-21, " Station Modifica-tion Control," provides the administrative instructions for initiating, controlling and documenting modification of station equipment and facilities. GSE Procedures describe the various relationships of the design development and verification organizations within the design process.
The Manager - Fort Calhoun Station is responsible for reviewing and approving design prior to implementation at Fort Calhoun Station Unit No.1. Utilization l of the Plant Review Committee is governed by the Station Operating Manual and specifically the following Standing Orders for their review function:
G-5 Plant Review Comittee G-21 Station Modification Control If an unreviewed safety question is involved, the design is further reviewed by the Safety Audit and Review Committee as specified in the SARC Charter prior to submittal to the NRC for approval.
GSE Procedures require an independent review of design documents. GSE Proce-dures assure that design characteristics can be controlled, inspected, and tested. Independent design review and verification activities are required by the QA Manual to be performed under the authority of the designer organiza-tion's QA program by appropriately qualified engineers for engineering calcula-tions, specifications, and design drawings for safety-related items.
The QA Manual states: '
"The selected documentts shall be reviexed to detemine tJiat they costtain, as appropr<. ate:
- a. Applicable design ba.ses, tedtrticci requ.iremen,ts, regulatory requitematts, componesti and rutext:L identtification, drawings specificaticuts, codes and .uzdustty standards, tests and Ltspec ticn requiremasts, and special process irtstwctiorts (11)
-_ _ _ . ~ . -. . ..
for such activities as fabrication, cleaning, erection, packaging, handib19, shipping, storage, and inspection;
- b. Requiremen.ts diat identify Dte document: tion to be prepa,ted, mabstained, sabnitted, and made ava.ilabie t.o tJte purchaser for review and coment, such as drawings, specifications, procedu,1es, inspection and
. test records, personnel and procedu.te qualifications, and chenical and plujsicai test results on materials;
- c. Requirements for bte retention, conttal, and rat.n. ten-ance of documents and quality assustance activities records."
GSE Procedures describe how reviews and verifications are conducted l through the use of a design verification checklist. This procedure com-plies with Section 6 (Design Verification) of ANSI 45.2.11 " Quality Assurance Requirements for the Design of Nuclear Power Plants."
The QA Manual raquires:
" Design adequacy shail be verified by systeratic evaluation of tJte elemen.cs of the design with respect .to regtdremeetts for design, safe.ty, funct, ion, and quality. Verification may be accomplished by pe,1fornbtg design reviews, by Bie use of altera11te or simpiified calculational mehtads, or by conducting a suitable test p.togram. The verifying process shali be pe,1 formed by .indi-viduais or groups otJter dian Biose who pc.tfarmed tJte original design, bu.c who may be from die same organi:ation. The ve,tifica.tions shali be Legible and be in a form suitable for reproduction, filing, and rett.ieving. "
Detailed design or design changes involving Critical Quality Elements (CQE) that are performed by Generating Station Engineering (GSE) are performed in accordance with the GSE Procedures Manual. GSE Procedures state that tech-nical calculations and safety analyses must be provided by the design engineer and describe how safety analyses and technical calculations are processed.
GSE Procedures provide design controls for compatibility of materials, and accessibility for inservice inspection, maintenance and repair.
Materials, parts, equipment and processes essential to Critical Quality Elements, the Fire Protection Program, and packaging for shipment of radio-active material are required to be selected and reviewed for suitability of application. The methods of assurance of suitability are required to include independent design verification by individuals or groups competent in the applicable field of design and related nuclear power plant requirements.
(12)
The methods of selection and review are required to provide for (as applicable):
reactor physics, stress, thermal, hydraulic and accident analyses; compatibility of materials; as low as practicable radiation levels; accessibility'for inservice inspection, maintenance and repair; test requirements and delineation of accep-tance criteria for inspections and tests.
Measures shall be established by the Section Manager - Generating Station Engineer-ing, Section Manager - Technical Services, and Manager - Fort Calhoun Station to assure that the applicable guidelines of Regulatory Guide 1.120 or approved alternatives are included in design and procurement documents prepared by their personnel and that deviations therefrom are controlled. Field changes and design deviations will be subject to the same level of controls, reviews, and approvals that were applicable to the original document. Quality standards will be specified in the design documents such as appropriate fire protection codes and standards.
Deviations or changes from these standards will be individually approved. New designs and plant modifications, including fire protection systems, will be reviewed by qualified personnel to assure inclusion of appropriate fire protection require-ments. These reviews will include items such as:
- a. Reviews to verify adequacy of wiring isolation
- b. Reviews to verify appropriate requirements for room isolation Design control measures for packaging for transport of radioactive material shall be applied to items such as: criticality physics, radiation shielding, stress, thermal, hydraulic, and accident analyses; compatibility of materials; features to facilitate decontamination; and delineation of acceptance criteria for inspections anc tests. Design changes, including field changes, shall be subject to design cmtrol measures commensurate with those applied to the original design. Changes in the conditions specified in the package approval require Commission approval.
All materials, parts, and equipment for CQE structures, systems, and components are procured in accordance with the Nuclear Purchasing Procedures regardless
'of comercial or previous approval status. The Nuclear Purchasing Procedures require an engineering and quality review cf all procurement documents for CQE items.
Design changes are originated in accordance with Standing Order G-21. These l requests for changes are processed through a review chain described in that standing order.
GSE Procedures require that all CQE design changes be processed through the design engineer and that an independent reviewer reviews the changes.
All aspects of the process are documented and retained in the master file per GSE Procedures. l Design documents are then transmitted to the station for review and approval in accordance with Standing Order G-21. This standing order delineates the planning, control and documentation of station modificatons at the Station.
(.13 )
Errors and deficiencies in the design process are normally detected during the design verification performed in accordance with GSE Procedures, and the l design reviews of the Plant Review Committee or the Safety Audit and Review Committee. The rejected design is returned to the designer for redesign with their documented comments.
QA audits are another mechanism by which errors and deficiencies in the design process are documented and corrected. An audit of OPPD design activities is performed annually and as ordered by the Manager - Quality Assurance or the Safety Audit and Review Comittee. Audits are performed utilizing ANSI N45.2.11 criteria and are conducted as needed to ensure compliance. Design activities include design initiation, design bases preparation, design scecifications preparation, and design output document preparation and control. Audits are performed using audit checklist (s) prepared by the audit team and approved by the Team Leader prior to commencing the audit. Upon completion of each audit, a formal audit report is prepared. The audit report cont; tins any deficiencies or nonconformances found during the audit, and reconnerided actions to be taken.
If necessary, a re-audit of the area is performed to verify the corrective action taken. Audits are also scheduled and documented to verify compliance with the Fire Protection Program, including design and procurement documents, instruments, procedures and drawings, and inspection and test activities.
The OPPD QA Program requires that OPPD's manufacturers' and contractors' design activities meet applicable NRC Regulatory Guide requirements for all safety related activities including Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants." The OPPD QA Program requires verification that all applicable NRC Regulatory Guide requirements have been incorporated in all activities affecting quality design review, audit and surveillance of manufacturers and contractors. This will assure that design input (applicable regulatory requirements and design bases as specified in the license application for safety-related structures, systems and components) for Fort Calhoun Station Unit No.1 are correctly translated into Design Output Documents (specifications, drawings, procedures, and instructions). QA audits will assure that OPPD's manufacturers' or con-tractors design control measures provide a clear definition of design inter-faces, review and approval of initial design, including changes or revisions, and that those performing design review activities are independent of those originating the. design.
The design activities of contractors for safety-related structures, systems or components are required to comply with the design development and control requirements of ANSI N45.2.ll. The design activities of manufacturers of packaging for transport of radioactive material are required to comply with the applicable regulatory requirements and the approved package design, as specified in the license. This compliance is audited by OPPD Quality Assurance.
OPPD will perform audits of OPPD's and contractors' design activities in accord-ance with QAP No. 2, " Audit Plans."
17.4 Procurement Document Control Appropriate requirvents have been established by the OPPD Quality Assurance Program to assure that procurement documentation is controlled and accurately reflects applicable regulatory requirements, design bases and other appropriate (14) .
requirements, such as industry codes and standards. Procurement documents and specifications require that bidders or suppliers submit for review by OPPD written quality assurance programs consistent with the importance and complexity of the materials, equipment or service procured. Such quality assurance orograms shall be consistent with pertinent provisions of Appendix B to 10CFR, Part 50, or Appendix E to 10CFR Part 71, as appropriate. OPPD satisfies these require- l ments as follows:
(1) Review of procurement documentation for CQE-listed materials, equipment and services will be performed in accordance with Nuclear Purchasing Procedures (NPP) No. I and No. 2, which require OPPD Engineer-ing and QA to review all CQE procurement documents l and document their review on the procurement document.
(2) Procurement documents for fire protection and radio-active material packaging materials, equipment, and services will receive the proper review, concurrence, documentation by qualified personnel for adequacy of fire protection and quality requirements. This review will detennine that fire protection require-ments and quality requirements are correctly stated, inspectable and controllable; that there are adequate acceptance and rejection criteria; and that the pro-curement document has been properly prepared, reviewed, and approved.
(3) Planned, periodic, and documented audits will be performed by responsible OPPD personnel to provide assurance that the procurement activities of OPPD are being carried out in accordance with approved procedures. These audits will be conducted as described in Section 17.18.
Appendix C to the Nuclear Purchasing Procedures requires that quality data be included in or appended to the Procurement Document or engineering data attachments, as appropriate. The quality data prescribes as necessary:
(1). Quality requirements including use of procedures or instructions (2) Requirements for a Supplier Quality Program and docu-mentation (3) Requirements for documentary evidence of quality to be furnished by the Supplier (e.g., test results, certi-fication that specific requirements have been met, or traceability to the source)
(4) Access requirements for QA surveillance, inspection and audits at the Supplier's work site (15) ,
The following is inserted as a special condition on all sealed bid contracts for CQE f tems:
Ouality Assurance "The Contractor shall submit his Quality Assurance Manual or complete details of his Quality Assurance Program for review and approval by the District. The program proposal shall meet the intent of the latest effective provisions of 1CCFR, Part to, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants," as well as all the requirements of ANSI Na5.2 and/or Section III of the ASME Boiler and Pressure Vessel Code.
'The Manual or program shall include sufficient organizational description to indicate the independence of the Quality Assurance Group and establish the authority and organizational freedom to identify and evaluate deficiencies and ensure that corrective actions are taken. Responsibiliites and qualifications of key personnel shall also be shown.
'Further, the program shall make provisions for the District and/or the Engineer to conduct periodic audits of the Con-tractor's Quality Assurance Program as well as that of his subcontractors. The Contractor shall be responsive to requests for corrective actions by the District and/or the Engineer regarding implementation of, or deficiencies in, his program or those of his subcontractors. The Contractor shall cooperate in scheduling of audits or tests, and shall supply with his proposal a schedule of suggested witnesses and/or holdpoints for OPPD and/or Engineer's inspection personnel.
'In addition, unpriced copies of all first tier subcontracts and purchase orders shall be provided to facilitate proper organization of audits.
'The program shall also make provision for establishing the responsibility of the Contractor for the quality of the work performed by his subcontractors and for review and approval of subcontractors' Quality Control programs to the same standards required of the Contractor.
'In addition, the program shall provide that all records attest-ing to the quality of materials and equipment,.such as material certifications, test reports, procedures and qualifications, process records, and radiographs shall be submitted to the District for permanent retention. All such records shall be available for review during shop audits and shall be forwarded prior to or concurrent with material or equipment shipments to which they are related."
The OPPD QA Manual requires that modifications to a Purchase Order or any document forming a part of the order shall be prepared, reviewed, and approved as for new Procurement Documents.
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This requirement is provided by the detailed procedures contained in the fluclear Purchasing Procedures and fulfillment of the requirement is assured by QA files.
fluclear Purchasing Procedures tio.1 and tio. 2 assure that procurement docu-ments for spares or replacement parts are subject to controls meeting all requirements of WASH 1283, Revision 1. The procurerrent process for spares and replacement parts for Fort Calhoun Station Unit tio.1 (FCl), as required by the OPPD QA Manual and further delineated in the OPPD fluclear Purchasing Procedures, is more controlled than the original procurerent process. The procurement process for FCl occurred from 1967 to 1970; the 10CFR, Part 50, Appendix B QA requirements were not invoked until 1971.
17.5 Instructions, Procedures, and Drawincs -
Appropriate requirements have been established in the OPPD Quality Assurance Program to assure that quality-related activities for plant operations are prescribed by documented instructions, procedures, or drawings; be accomplished in accordance with such documents, and are approved only when acceptance cri-teria are met. The responsibility for the development of the instructions, procedures, or drawings is delegated to the organization responsible for the activity (normally the Manager - Fort Calhoun Station); however, the developed l instructions, procedures, and drawings are subject to OPPD QA audit. The Quality Assurance Manual contains the specific requirements pertaining to the instructions, procedures, and drawings associated with activities affecting plant quality.
The QA Department audits measures established to assure that approved changes are promptly included where applicable into instructions, orocedures, and drawing associated with the change. The OPPD QA Program assures that changes are reviewed for their effect on present instructions, procedures and/or draw-ings.
The OPPD QA Program requires that procedures include a description of the sequence of activities or operation for fabrication, processing, assembly, inspection and test. Instructions shall indicate the operations or processes to be performed, type of characteristics to be reasured or observed, the methods of examination, the applicable acceptance criteria and documentation requirements. .The QA Program also requires establishment of those inspections, tests, and holdpoints from raw material through fabrication, processing, and assembly, at which time conformance of parts, components and subsystems to requirements will be verified. Holdpoints identify those inspection points which will be rendered impossible to inspect by subsequent operations, and must be certified complete before start of the next operation by use of check-lists and certifications. Each checklist or certification shall include the date of completion of the operation or test and the signature of the operator or inspector.
The Operations QA Engineer will review such documentation to assure it ade-quately reflects all applicable quality requirements. In review activities the Operations QA Engineer will asstre that instructions, procedures, and drawings contain appropriate quantitMive (such as dimensions, tolerances, and samples) acceptance criteria for deter nining that important activities have been satisfactorily accomplished.
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Inspections, tests, administrative controls, fire drills, and training tnat govern the Fire Protection Program will be prescribed by docr.ented instruction, procedures, or drawings and will be accomplished in accordance with these docu-men ts . Instructions and procedures for design, installation, inspection, test, maintenance, modification and administrative controls will be reviewed in ac-cordance with the Plant Administrative Procedures to assure the proper inclusion of fire protection requirements.
Through its auditing procedures, as der c ;d in Section 17.18, OPPD will detennine that quality activities are tplished in accordance with those approved instructions, procedures, ano orawings.
17.6 Document Control 0 PPD has established requirements to assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.
These requirements provide that contractors include, in their internal pro-grams, measures to assure that changes to documents will be reviewed and approved by the same organization that perfonned the original review and approval. OPPD will verify implementation of these requirements through audi ts. This OPPD QA Program requires that changes to documents that have been reviewed and approved by OPPD organizations will be reviewed and approved by the same OPPD organizations that perfonned the original review and approval.
These requirements also provide that the documents are distributed to and used at the location where the prescribed activity is performed. The scope of these requirements apply to OPPD as well as to contractors and subcontractors.
OPPD employs within its own internal organization a control system that uti-lizes numbering of documents requiring control, predetermined distribution lists, and review and approval procedures. Controlled documents associated with Fort Calhoun Station Unit No. I have been controlled by document change transmittal letters instructing the recipient to remove and destroy obsolete or superseded pages. OPPD requires:
l (1) maintenance of a distribution list (2) use of receipt cards / letters (which indicate that superseded pages/ documents are destroyed or marked
" superseded")
The Quality Assurance Program reouires that design engineering and procure-ment documentation, except for fire protection equipment, which consists of specifications, drawings, FSAR material, instructions, procedures, reports, and changes thereto, and manufacturing and construction documents and records required for traceability, evidence of quality, and substantiation of the as-built configuration, be controlled.
Instruction, procedures, specifications, drawings, and procurement documents are controlled in accordance with QA Manual Section 9, GSE Procedures, and Fort Calhoun Station Unit No.1 Standing Order No. G-3D. l (18)
A " Table of Contents" or "Index" system is used ay OPPD departments to identify the current revision number of instructions, procedures and procure-ment documents. As a new revision or addition is made, a new " Table of Contents" or "Index" is promulgated. The controlled copies are distributed to predeter-mined, responsible personnel, and a distribution list is maintained. Superseded documents are returned to the originator or destroyed as directed in the trans-mittal.
Since Fort Calhoun Station Unit tio.1 was constructed prior to present require-ments, the file of specifications and drawings is not complete. OPPD has a continuing program of updating its specifications and drawings files. A master index is in preparation and is controlled in accordance with GSE Procedures. !
Procedures in the QA Manual identify those individuals or groups responsible for reviewing, approving and issuing documents and revisions thereto. Where deemed necessary, OPPD will require that periodic document summary lists be submitted by an organization to verify the use of the proper document or change.
The effectiveness of document control methods is evaluated through audits.
17.7 Control of Purchased Material, Eouipment, and Services Measures utilized by OPPD to control purchased material, equipment, and services for an operating plant consist of individual comittee reviews, audits, and inspections. These measures are described in the OPPD Quality Assurance Manual and the Purchasing Manual.
Potential manufacturers or contractors who are to be considered by 0 PPD or its prime contractors for the supply of items will normally be evaluated in advance of placing them on the Approved Suppliers List. OPPD's evaluation of potential vendors is performed by QA in accordance with Quality Assurance Procedure (QAP) flo. 5. The evaluation involves the review of available historical data on manu- l facturers' or contractors' performance and capability; review of their quality assurance programs; or results of previous shop surveys and audits. Quality assurance program descriptions are required to be submitted with bids for CQE-listed items. The manufacturer or contractor to supply the material, equipment, or services will be selected from the Approved Suppliers List. If required, a pre-award survey at the supplier's facility will be conducted before award of contract.
Documented, objective evidence such as certifications, chemical and physical analyses, inspection reports, test results, personnel and process qualification results, code stampings and nondestructive test reports are required to be evaluated by 0 PPD and suppliers or contractors. This verification will assure conformance to design requirements, drawings, specifications, codes, standards, regulatory requirements and other applicable criteria. These documents become a part of the quality verification records to be retained as a QA record in accordance with Section 17.17.
Source inspection, when deemed necessary, is required by the applicable procure-ment document. The purchasing organization shall require that holdpoints be detemined as necessary for this activity. Manufacturers are required to give sufficient notice of approaching holdpoints to allow scheduling of personnel.
(19) .
Both in-process and final source inspections cover review of the quality veri-fication documentation. An inspection document is used to establish the inspection sequence and for recording inspection results. This document also becomes part of the quality verification records. Provision is made for report-ing deviations and nonconformances, if any; for recormtending disposition and corrective action; for reinspection, if required; and for release for shipment, if appropriate. OPPD or its contractor may elect to participate in selected source inspections.
The OPPD QA Program requires that procurement documents specify that manufac-turers or contractors provide the quality verification documentation at the plant prior to the scheduled time of installation or use of the subject material and equipment. During the review and approval of procurement documents, OPPD will check to assure that the above requirement is included. Audits will assure that the contractor is implementing a records management system. Installation or use of delivered components will not occur until receipt of objective evidence of the quality verification package.
Receiving inspection of purchased products will be acccmplished by Stores and QA personnel in accordance with Standing Order G-24. These procedures require that shipments delivered to the station be checked by the Stores Clerk for l shipping damage, agreement of actual count with the purchase order and packing slip, and agreement of the individual item identification with the purchase order and packing slip.
Standing Order G-24 requires that one or more receiving inspection packets be l
prepared by the QA Engineer (Operations) for each purchase order requiring delivery of material to the Station. A receiving inspection packet includes a preprinted packet cover, a copy of the purchase order or Requisition on Purchasing, a material inspection packet, and a document retention checklist. Special instructions may be included in the packet for complex inspection requirements and tests to be performed at the plant or the supplier's work site as determined from the purchase order. Drawings and/or specification documents are included as appropriate. The QA inspectors perform the receiving inspection in accord-ance with the above instructions and/or specifications.
The QA Program requires that all inspection records or certificates of confonnance attesting to the quality of materials and equipment be submitted to the District for permanent retention. All such records shall be available for review during shop audits and shall be fonvarded prior to or concurrent with material or equip-ment shipments to which they are related. In addition, prior to acceptance of l
all material, the QA Engineer (Operations) shall be notified to verify that neces-sary documentation has been received. The documentation is maintained within the
" Receiving Inspection Packet."
Products intended for use as Critical Quality Elements are inspected upon receipt in accordance with Standing Order G-24, which requires a " Rejected Material" tag [
to be affixed to rejected material, and the material segregated in the receiving area to prevent inadvertent use. Accepted material is identified, and there are records traceable to the material indicating acceptance. Furthermore, materials classified as Critical Quality Elements are controlled in act rdance with ANSI N45.2.2 and 10 CFR 50, Appendix B.
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17.8 Identification and Control of Materials, Parts, and Components Appropriate requirements have been established by the OPPD Quality Assurance Program to assure continuous and accurate identification and control of materials, parts, and components so that the use of incorrect or defective materials, parts, or components is prevented.
For an operating nuclear power plant, specific procedures t'o comply with this requirement are contained in the Quality Assurance Manual and the Plant Operating Manual . Identification and control of materials is maintained by the use of Standing Order G-25, " Stores Control." All materials received at the storeroom for use as Critical Quality Elements or as packaging for radioactive material for transport are identified to prevent the use of incorrect or defective material.
The identificaticn of the item is maintained by an appropriate code, letter, or number so that the identity of the material is maintained. Items shipped to the plant are normally identified by nameplate or other identification marking on the item. In those instances when it is not practical to provide identification markings on the individual items, identification information will be provided in shipping paperwork that is transmitted with each shipment.
Materials classified as Critical Quality Elements are controlled in accordance with ANSI N45.2.2 and 10 CFR 50, Appendix B.
Material classified as Critical Quality Elements or packaging for radioactive material for transport is released from the storeroom by the Stores Clerk only upon receipt of two copies of an authorized and signed Rcquisition on General Stores, OPPD Form 45.5203.
The " Requisition on General Stores" is initiated by designated District personnel.
It designates each individual item requested, including size, schedule, pressure rating, etc., and the system on which the material is used. Two lines are left blank between each item on the " Requisition" to assure space for the material identification data.
The " Requisition on General Stores" for Critical Quality Elements does not contain noncritical material. This precludes the issuance of noncritical items on the same requisition for Critical Quality Element material.
Each " Requisition on General Stores" for Critical Quality Element material is stamped with the Critical Quality Element stamp. Each " Requisition on General Stores" for packaging for radioactive material for transport will be stamped with a " Radioactive Material Packaging" stamp. When available, the material identi-fication number, material heat number, or code number or letter is noted on the
" Requisition."
The traceability of materials is maintained through the use of Standing Orders G-24 and G-25. The receiving inspection packet contains all of the documentation needed for the traceability of the item. Those documents which are not included are referenced as to their location.
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The method of identf fication to be applied to purchased materials is specified as part of the purchase document. Codes and standards referenced in the purchase document have incorporated the appropriate marking method, such that the fit, function, or quality of the item is not affected. Codes and standards referenced include:
(1) ASTM - American Society for Testing and Materials (2) ASME - American Society of Mechanical Engineers The correct identification of materials is verified and documented prior to release through the use of Standard Orders G-24 and G-25. l Contractors are required to utilize procedures which establish and document a system or method of identifying the material (e.g., physical marking, tagging, labeling, color code). This system shall clearly indicate whether materials are acceptable or unacceptable for further use, as required by the quality program. Material traceability is provided as specifically required by applicable codes; othemise, material identification, either on the item or on records traceable to the item, will be used, as appropriate. Where identification marking of an item is employed, the marking will be clear, understandable, and legible, and applied in such a manner as not to affect the function of the item. The identification and control measures provide for relating the item of production (batch, lot, components, part) at any stage, from materials receipt through fabrication, shipment, and installation to an applicable drawing, specification, or other technical document.
OPPD requires its suppliers to establish and implement a program for inspecting, marking, identifying and documenting material prior to use or storage. This program must be documented.
Holdpoints are required where inspections must be made and certified complete before start of next operation. Inspection of materials include the following:
(1) Verification that identification and markings are in accordance with applicable codes, standards, specifi-cations, drawings, and purchase orders.
(2) Visual examination of materials and components for
. physical damage or contamination.
(3) Examination of quality verification records to assure that the material received was manufactured, tested and inspected prior to shipment in ac']rdance with applicable requirements.
(4) Actual inspection, as required, of workmanship, con-figuration and other characteristics.
These inspections shall be documented by reports and controlled through internal audi ting. OPPD will perform surveillance of vendor facilities to assure imple-mentation of the program.
OPPD will require that contractors establish specific measures to assure compliance with approved procedures for identification and control of materials, parts, and
~
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components, including coatings and partially fabricated assemblies. OPPD will verify confomance by four methods:
(1) Review and approval of contractors' quality assurance programs, including procedures.
(2) Review and approval of Product Control Procedures con-tained in OPPD's Plant Operating Manual.
(3) Surveillance of selected manufacturing, fabrication, construction and installation activities by quality assurance personnel.
(4) Auditing:
(a) of contractors for satisfactory performance of committed quality actions; and (b) of Stores activities for adherence to quality requirements.
17.9 Control of Special Processes OPPD requires for its operating nuclear power plants that written procedures and controls be prepared to assure that special processes, including welding, heat treating, special coating applications, and nondestructive testing are accom-plished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special require-ments. These procedures shall describe the operations to be performed, the sequence of operations, the characteristics involved (e.g., flow temperature, fitup, finish, hardness, and dimensions), the limits of these characteristics, process controls, measuring and testing equipment to be utilized, and documen-tation requirements.
Examination, tests, and inspections shall be conducted to verify conformance to the specified requirements.
Written procedures will also be required to cover training, examination, quali-fication, certification, and verification of personnel as well as the maintenance of all required personnel records.
Compliance with these procedures is required for plant maintenance personnel, contractors, and vendors. Procedures for control of special processes are subject to review and approval by OPPD on an individual basis.
OPPD will assure conformance with these requirements by:
(1) Review of procedures by the Plant Review Committee and Operations QA Engineer for inclusion of special processes requiring control; definition of require-m2nts for training, qualification and certification; conformance to applicable codes, standards, drawings, specifications, or other criteria.
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(2) Audits to verify the adequacy of selected plant and vendor shop acitivites and the effectiveness of the special process procedures being implemented.
Special Process Control activities perfomed by OPPD personnel are presently being performed in accordance with Standard Order G-12.
17.10 Inspection OPPD will establish with its personnel and contractors a division of responsibility which.will determine the seruices, structures, systems, components, and materials for which each is responsible. The organization having the responsibility for maintenance or repair of such items shall also have the primary responsibility to assure that adequate inspection is accomplished. OPPD OA, however, retains the responsibility and authority for review, approval, and surveillance or audit of the inspection procedures utilized by plant maintenance personnel or contractors.I OPPD QA or maintenance inspection (QC) personnel will be responsible for the inspection of all work performed by OPPD maintenance personnel on nuclear safety related structures, systems, or components, and on radioactive material packaging.
Fort Calhoun Quality Control personnel or other personnel who are independent of the individuals performing the activity being inspected and who are qualified in the design and installation requirements for fire protection will inspect activities affecting fire protection to verify conformance with documented installation drawings and test procedures for accomplishing the activities.
The review and approval of a contractor's inspection program and procedures will be ccomplished as an integral part of OPPD's review of the organization's Quality Assurance / Quality Control programs. The Operations QA Engineer and the plant QC personnel will use the following criteria in evaluating inspection methods proposed by plant maintenance personnel or organizations under contract to OPPD:
(1) Inspection procedures for functional groups such as procurement, project engineering, construction, and shop inspectors, must be described including measures to identify inspection and test status.
(2) Duties and responsibilities of personnel performing
. quality activities must be clearly established.
(3) Qualifications of personnel performing quality acti-vities must be commensurate with their duties and responsibilities.
(4) Documentation methods for inspection activities of each group must be established (e.g., inspection forms, reports).
(5) Documentation control systems for identification and distributing inspection documents must be defined.
(6) Review and approval procedures for inspection documen-tation must be provided.
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(7) Surveillance methods must be established to assure proper implementation of inspection procedures.
(8) Planning of inspection sequence activities by plant maintenance personnel or the contractors shall include the type of characteristics to be measured, the methods of examination, and the criteria. OPPD will approve inspection holdpoints in the sequence.
The Manager - Fort Calhoun Station shall assure that the periodic inspections made by his staff members include:
(1) Periodic inspections of fire protection systems, breathing equipment, emergency lighting, and comunication equipment to assure the acceptable conditions of these items.
(2) Periodic inspections of materials subject to degradation such as fire stops, seals, and fire retardant coatings to assure that such items have not been damaged or deteriorated.
Inspection planning shall be utilized to assure conformance to procedures, drawings, specifications, codes, standards, and other documented instructions.
Inspections shall not be performed by those individuals who performed the activity being inspected. Sufficient inspections shall be conducted to verify conformance particularly in areas rendered inaccessible by further processing.
Process monitoring may be utilized in lieu of inspection in those cases where inspection is impossible, disadvantageous or destructive. When required for adequate control, a combination of inspection and process monitoring shall be employed. Holdpoints shall verify (by review of inspection reports, visits to supplier shops, and plant surveillance) that inspections are being performed and documented by personnel in confonnance with approved procedures.
The provisions which assure inspections are performed with the necessary drawings and specifications are covered in Plant Standing Order G-24, " Receipt Control"; l Plant Standing Order G-17, " Maintenance Orders"; and Plant Standing Order G-21,
" Modification Control."
Modifications are inspected in accordance with Fort Calhoun Administrative Procedures Standing Order G-21, "Statien Modification Control." A plan of inspection and monitoring is developed and incorporated in Planning Documents of work segments, including designation of mandatory holdpoints. The inspection and monitoring plan is designed to verify conformance of work and products with the Planning Documents, applicable Design Documents, and specific quality stan-dards and requirements. The plan provides for inspection and monitoring during critical stages in the progression of work and for inspection at the conclusion of each work segment.
Repairs are inspected in accordance with Fort Calhoun Administrative Procedure Standing Order G-17, " Maintenance Orders." Any holdpoints for inspection or witnessing is specified under the QA Requirements section of the. maintenance order. Replacements are inspected during receiving inspection in accordance with Plant Standing Order G-24. l (25) .
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OPPD inspectors are qualified and maintain their qualification by participation in the training and indoctrination delineated in Section 14.2.4 OPPD QA/QC and maintenance personnel performing nondestructive examination are trained and qualified in accordance with QAP #10, "NDE Personnel Administration." Consultant l and Contractor inspectors performing inspection duties for OPPD are required to provide documentary evidence that they are qualified and that the certifications are current in accordance with ANSI N45.2.6.
17.11 Test Control The OPPD Quality Assurance Program requires that plant personnel, contractors, and suppliers designate appropriate tests to be performed at specific stages of manufacturing, fabrication, construction, and operation. Conduct of tests will be governed by written procedures which will incorporate requirements and acceptance limits to assure that the structures, systems, and components tested will perform satisfactorily in service. Tests will be conducted in accordance with these procedures and will be properly documented. - Written test procedures for radioactive material packaging shall incorporate the requirements and accep-tance limits contained in the package approval.
OPPD shall assure that all necessary tests are conducted by contractors perform-ing maintenance or repair service for an oper3 ting plant. Such testing will be performed in accordance with quality assurance and engineering test limits con-tained in applicable design documents. Test requirements and acceptance criteria are provided by the organization responsible for the specification of the item under test, unless otherwise designated. The entire test program will cover all required testing including, as appropriate, performance testing of production equipment, calibration testing of instruments, hydrostatic testing of pressure boundary components and surveillance testing.
Provisions to assure that modifications, repairs, and replacements are tested in accordance with the original design and testing requirements or acceptable alternatives are contained in (1) GSE fianual for preparation of test procedures l as a part of the design package; (2) Standing Order G-21 for execution of modi-fications at the plant; (3) Standing Order G-21 for tests of repairs or replace-ments; (4) Nuclear Purchasing Procedure t'o. 2 for tests to be conducted by the supplier; and (5) Standing Order G-23 for surveillance tests. Documentation of tests conducted is included in the completed design package, with the completed l maintenance order by special procedure, or included in the receiving inspection packet.
Follcwing construction, modification, repair or replacement, sufficient testing will be perfomed to demonstrate that fire protection systems, emergency light-ing and communication equipment will perform sabsfactorily in service and that design criteria are met. Written test procedures for installation tests will be prepared by the responsible engineering group and will incorporate the require-ments and acceptance limits contained in applicable design documents.
Present test control activities are being performed in accordance with Standing Orders G-12 and G-19.
Test procedures as a minimum shall include:
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_ . _ . _ _ _ _ . _ . _. . . . . . . _ _ . . ~ .
(1) Requirements that prerequisites for the test have been met.
Test prerequisites may include, but are not limited to, the following:
(a) calibrated instrumentation (b) adequate and appropriate equipment (c) trained, qualified and, as appropriate, licensed or certified personnel (d) preparation, condition, and completeness of item to be tested (e) suitable and, if required, controlled environmental conditions .
(f) mandatory inspection holdpoints where applicable, for witness by OPPD, contractor, or authorized inspector (g) provisions for data collection and storage (h) acceptance and rejection criteria (1) methods of documenting or recording test data results (2) Designation of specific test methods to adequately assess appropriate parameters.
(3) Designation of measuring and test equipment to be used.
(4) Specific environmental considerations.
(5) Measures to prevent damage to the item or system under test.
(6) Safety considerations.
(7) Documentation requirements.
Test results shall be evaluated to verify as applicable:
(1) Proper functioning of the systen, structure, or component.
(2) Confonnance to design specifications.
(3) Compliance with stated test requirements.
(4) That test results are within allowable limits.
(5) That recording and documentation is complete and accurate.
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Audits by 0 PPD QA, vendor surveillance, and witness of specific tests will serve to assure the f nctional adequacy of, and verify compliance with, the testing program.
17.12 Control of Measure and Test Eouiement The OPPD Quality Assurance Program requires that organizations performing quality activities involving measuring and test equipment have written procedures to govern these actions. OPPD requires that the standards used for calibration and accuracy verification of measuring and test equipment be traceable to the U. S. Bureau of Standards or other appropriate sources. In addition, only properly calibrated measuring and test equipment shall be used. A calibration frequency and method system shall be established to which the tools, instruments, gauges, and other devices shall confom. Records of calibrations shall be main-tained and the calibration equipment appropriately marked to indicate the date and acceptance of the calibration. Calibration activities being performed by OPPD personnel are in accordance with Standing Orders G-19, M-26, M-28, T-13, l and M-7. If standard deviation exceeds the guaranteed accuracy, then the standard shall be replaced. Calibration standards, when not limited by the " state-of-the-art," will have an uncertainty (error) requirement of no more than 1/10th of the uncertainty of the equipment being calibrated.
When inspection and testing equipment is found to be out of calibration due to use or damage, or when out of limits at recalibration, all items inspected, tested, or measured with that equipment since the latest valid calibration shall be considered as being potentially unacceptable. Resolution of these cases shall be detennined on a case basis by treating them as a nonconformance.
OPPD QA shall monitor calibration activity, including evidence of calibration status and the use of calibrated equipment. In addition, OPPD QA will perform periodic audits to ensure that approved calibration control procedures are being implemented.
OPPD's QA Program requires that instructions or guidance for plant handling, preservation, storage, and control of products are prepared and approved prior to arrival of the products at the plant. These procedures will specify, as required, that special environmental facilities, such as inert gas, humidity control, or temperature controlled storage area are established prior to the receipt of the products. Contractors performing naintenance or repair services for an operating plant shall provide procedures for the handling of products to prevent damage or deterioration. The procedures will be reviewed and approved by OPPD. To assure existence of the requirements for procedures in the procure-ment documents, OPPD QA will verify the inclusion during its review prior to authorization for document issuance. OPPD personnel shall procure, receive, store and handle CQE and radioactive material packaging products, material, and components in accordance with the Purchasing Manual and Plant Standing Orders.
OPPD QA will perform periodic surveillance and audits of affected OPPD organi-zations and contractors to assure that specified and approved procedures are being properly implemented.
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17.14 Inspection, Test, and Operating Status OPPD's QA Program requires that procedures be established to identify the inspec-tion, test, and operating status of radioactive material packaging and safety- l related structures, systems, and components. Identification of the inspection, i
test and operating status of structures, systems, and installed components is provided through use of Fort Calhoun Administrative Procedure, Standing Order 0-20, " Equipment Tagging," and the Surveillance Test Program. Identification of the inspection, test, and operating status of components not installed is provided through the use of Plant Standing Order G-24. Schedules and methods j for periodic testing of fire protection systems and components will be developed and documented by the Manager - Fort Calhoun Station. Fire protection equipment, emergency lighting, and communication equipment will be tested periodically to i
assure that the equipment will properly function and continue to meet the design I
cri teria. Test results will be documented, evaluated, and their acceptability I detemined by plant Quality Control personnel. ,
The application and removal of inspection and welding stamps and status indi-l cators are procedurally controlled in accordance with Standing Order 0-20. Non-i conforming, inoperative or malfunctioning structures, systems, or components are identified through the use of: QAP #15, " Adverse Condition Reporting and Correc- l tion"; Standing Order G-2, "Special Orders"; G-17. " Maintenance Orders"; G-18,
" Nonconformity Control"; 0-25, " Electrical Jumpers Control"; 0-28, " Requirements for Bypassing Safety Functions"; G-24, " Receipt Control"; and 0-20, " Equipment Tagging."
There is no provision for formally bypassing required inspections, tests, and other critical operations at the operating plant. System completeness and acceptance at the end of a maintenance or repair phase are detemined by:
(1) reviewing for adequacy, completeness, and conformance to quality assurance requirements for each system or component being accepted; (2) performing surveillance and monitoring of the test activities associated with the approved test program; (3) reviewing the test records to verify that test results comply with QA requirements.
The suppliers' and contractors' inspection and test status of items are required to be maintained through the use of status indicators such as physical location, tags, markings, shop travelers, stamps, or inspection records. These measures provide for assuring that only items that have received the required inspections and tests are used in manufacturing and are released for shipment. The procedures for control of status indicators are released for shipment. The proccdures for control of status indicators, including the authority for application and removal of tags, markings, labels, or stamps will be documented in approved manufacturing or quality assurance procedures. Perfomance of this function will be audited by OPPD QA to assure that effectiv measures are being taken.
17.15 Nonconfamina Materials, Parts, or Comoonents The OPPD Quality Assurance Program requires that measures be taken and documented by OPPD Stores and by Plant and QA personnel to control the identification, (291
documentation, segregation, and disposition of nonconfoming material, parts or components. The implementing instructions which fulfill these requirements are contained in OA Procedure #2, " Reporting of Defects and Noncompliance" and Plant Standing Orders G-17, " Maintenance Orders"; G-18, " Nonconformity Control";
and 0-20, " Equipment Tagging." The QA Manual, Section 10, identifies those individuals or groups delegated the responsibility and authority for the dis-position and approval of nonconforming items. Nonconfomity items are controlled and identified in accordance with written procedures to prevent inadvertent use or installation. Control measures include tagging or marking and segregation when feasible. Nonconforming products are maintained in quarantine whenever possible. Control measures are maintained until the item has been removed from the plant site or corrective work has been completed and accepted.
Plant Standing Orders G-17, " Maintenance Orders," and G-18, " Nonconformity Control,"
set forth requirements for controlling and correcting nonconforming items at Fort Calhoun Station Unit No.1. These procedures cover:
(1) Initiation of the documentation for material rejected at receiving inspection or inplant activities including the affixing of a Rejected Material tag to the noncon-foming item. The nonconfomance report identifies the nonconforming item and describes the nonconfomance.
(2) Assignment of disposition and/or corrective action responsibilities, including the inspection requirements and signature approval of the disposition.
(3) Control of correction work planning and acceptance.
Nonconfomance reports are analyzed during audits of the nanconfomity control system to detect adverse quality trends. These reports go to management for review and assessment.
The OPPD Quality Assurance Program requires that measures be taken and docu-mented by contractors and suppliers to control the identification, documentation, segregation, and disposition of nonconforming material, parts, or components.
These measures will prevent inadvertent use or installation of defective com-ponents and are subject to review and approval by OPPD. Written procedures will be required for investigation of the nonconfoming item, decisions on its dis-position, and preparation of adequate reports. Procedures will also control further processing, fabrication, delivery, or installation of items for which disposition is pending. All reports documenting actions taken on nonconfaming items will be made available to 0 PPD for evaluation. Departures from design specifications and drawings requirements that are dispositioned "use as-is" and
" repair" will fomally be reported to affected organizations and OPPD management.
OPPD will audit contractors to assure compliance with this requirement.
The effective of nonconfor nance control procedures will be assured by:
(1) Contractor quality assurance and manufacturing, fabrication, or construction personnel being involved in processing nonconfoming reports.
(2) OPPD participation in dispositions and approvals.
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(3) Document review at final inspection or shipping release and at receiving inspection by OPPD.
(4) Surveillance by OPPD's and contractors' quality ass vance personnel.
(5) Audits performed by the contractors, suppliers, and OPPD QA.
17.16 Corrective Action OPPD requires measures for an operating nuclear power plant to assure that con-ditions adverse to quality are promptly identified, reported, and corrected.
Responsibility for performing corrective action will be assigned to OPPD personnel and all contractors and suppliers so that each will be alert to those conditions adverse to quality within his own area of responsibility. In the case of signi-ficant conditions adverse to quality which are reportable to the NRC under the provisions of 10CFR, Section 50.55(c), measures shcIl be taken to assure that the cause of the condition is determined and corrective action is implemented to pre-clude repetition. Corrective acticn procedures will require thorough investigation and documentation of significant conditions adverse to quality. The cause and corrective action will be reported in writino to the appropriate levels of manage-ment. The corrective action to be applied will be subject to review and approval by OPPD QA. Corrective action followup and closecut procedures will provide that corrective action commitments are implemented in a systematic and timely manner and are effective.
The instnJctions for implementing these requirements are contained in QAP No. 5,
" Supplier Qualification"; Standing Orders G-18 " Nonconformity Control"; G-24,
" Receipt Control"; G-25, " Stores Control"; and R-4, " Operations Incidents Reports."
The effectiveness of the suppliers' or contractors' corrective action program will be assessed during audits by the supplier, the contractor, and by OPPD.
Stop work authority shall be exercised as required.
The effectiveness of OPPD's corrective action program will be assessed during audits by QA and the SARC.
17.17 Quality Assurance Records OPPD's Quality Assurance Program requires that OPPD and its contractors have a quality records system which will provide documentary evidence of the performance of activities affecting quality. The requirements include that:
(1) Records are to be maintained that show evidence of pe ~ mnance of activities affecting quality. Typical re: 3 to be maintained include quality assurance pros-a...s and plans, design data and studies, design review reports, specification procurement documents, procedures, inspection and test reports, material certifications, personnel certifications, test reports, audit reports, reports of nonconformances and correc-tive actions, as-built drawings, operating logs, cali-bration history, maintenance data, and failure and incident reports.
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(2) Inspection and test records, as a minimum, will identify the date of the inspection or test, the inspector or data recorder, the typa of observation, the results, the acceptability, and the action taken in connection with any nonconformances noted.
(3) Records shall be protected against deterioration and damage.
(4) Criteria shall be established for determining the classification of the record as well as the length of the retention period.
(5) A method of identification and indexing of records for ease of retrievability shall be established.
(6) Responsibility for recordkeeping during _ design, fabri-cation, construction, preoperational testing, and commercial operation shall be documented.
(7) Method of transfer of records between organizations and ultimate transfer to OPPD shall be established.
All requirements and responsibilities for the handling, storage, and retention of records which furnish documentary evidence of quali1.y re prescribed by QAP #7, " Storage and Retention of QA Records"; GSE Procedure A-9, " Filing";
and Fort Calhoun Station Standing Orders C-1, " Office Files"; C-2, "QA Records";
and C-3, "QA Records." The records are accumulated and handled in a controlled manner in accordance with these written instructions. An audit system is estab-lished to assure that the record transmittals, retention, and maintenance are effective and consistent with applicable codes, standards, and procurement documents.
17.18 Audits The OPPD QA Pregram requires that planned and periodic audits be performed to verify compliance with all aspects of the Quality Assurance Program and to determine the effectiveness of the program. OPPD 0A will perform such audits on OPPD internal activities, contractors, suppliers, and others as necessary to provide an objective evaluation of the effectiveness of their programs; to determine that their programs are in compliance with established requirements, methods, and procedures; and to verify impicmentation of recommended corrective action. The Operations QA Engineer is responsible for assuring the effective implementation of the Fire Protection Program onsite by inspections and audits.
The internal audit cycle for Fort Calhoun Station Unit No.1 is promulgated by QA Procedure #16 and is based on the safety importance of the activities being l performed. An internal and external audit schedule is distributed and updated quarterly to ensure coverage of status changes. If, in the opinion of the Manager - Quality Assurance, a given area requires added emphasis, the frequency of audits is increased until the situation is clarified.
The OPPD audits, both internal and external, will be conducted primarily by members of the Quality Assurance staff in accordance with QA Procedure #2, l (32) -
" Audit Plans"; QAP #17, " Audit Planning, Performance, and Reporting"; QAP #5, l
" Supplier Qualification"; and QAP #15. " Adverse Condition Reporting and Correc-ti on . " Consultants will be utilized by 0 PPD on audits as required. OPPD speci-fies that the auditing system used by 0 PPD, its contractors, and suppliers:
(1) utilizes an audit planning document which defines the organizations and activities to be audited and the frequency of audits; (2) requires auditors to be familiar with the type of activities to be audited and have no direct responsi-bilities in the type of activities to be audited; (3) provides auditing checklists or other cbjective guide-lines to identify those activities which affect quality; (4) requires examination of the essential characteristics of the quality activity examined; (5) requires an audit report to be prepared and that it notes the extent of examination and deficiencies found.
QAP #17 " Audit Planning, Performance and Reporting"; QAP #18, " Auditor Training and Qualification"; and QAP #19, " Quality Assurance Indoctrination and Training of Personnel," provide the means which assure that audits are performed in a thorough and professional manner. OPPD audits determine the existence of a system and the deficiencies of that system, personnel awareness of the system, and the actual practice of the system. Audit checklists are used to ensure that audits include the objective evaluation of work areas, activities, processes, and items and the review of documents and records.
OPPD QAP #17 requires that upon completion of each audit, a formal renort shall l be prepared following the guidance of AtlSI ti45.2.12-1974. The audit report shall contain any deficiencies or nonconformances found during the audit, and recommended actions to be taken. Audit reports are distributed as follows:
Standard Distribution:
(1) Applicable Assistant General Manager l (2) Applicable Division Manager (3)' Applicable Section Manager (4) Applicable Department Manager (5) Applicable Supervisor (6) Manager - Quality Assurance (7) Applicable QA Engineer (8) Participating Auditors Special Distribution:
Depending upon the nature of discrepancies noted, or the areas audited, the following are added to the distribution list as required:
(1) Division Manager - Material Management (2) Contract and Specifications Engineer (3) Supervisor of General Stores (33)
(4) Maintenarce Engineer (5) Applicable Contractor (6) SARC Secretary for promu:gation to SARC Members l QA Form #2 is used to identify and monitor corrective actions arising from QA audits conducted in accordance with any of the OA procedures. This form is used by QA personnel (or by non-QA personnel conducting QA audits) to document quality assurance related deficiencies and their corrective action. Items 1 through 7 of l QA Form #2 are completed by the person identifying the deficiency. The form is addressed to the Action Addressee. The Original and two copies are sent to the l Action Addressee for his endorsement of action to be taken, assign investigator (if required), and expected completion date (if known). The Followup Copy is retained by the auditor originating the deficiency report.
The Action Addressee will keep the Action Addressee's Copy, state corrective action to be taken and forward the Original and one copy to the appropriate QA l Engineer. The QA Engineer will send the Audit File Copy to the Manager - Quality Assurance for filing. The Original and Followup Copies are kept by the QA Engineer for followup and corrective action. After receiving the deficiency report with the stated corrective action, the QA Engineer reviews the forms for concurrence. If he does not concur with the corrective action to be taken, he will return the forms to the Action Addressee for further action. Final concur-rence will be decided between the QA Engineer and the Action Addressee. After concurrence by the QA Engineer, he will provide followup on the item until it is complete. When the deficiency is corrected, the QA Engineer updates the Original Copy to agree with the Followup Copy and sends the Original to the Manager -
Quality Assurance. The Manager - Quality Assurance will update the Audit File Copy from the Original and file both copies, thus closing out the deficiency.
A quarterly report of deficiencies that have occurred, including the status of all resolved deficiency reports, is prepared and distributed by the QA Engineer (Corporate). This report is routed to the senior management of the major OPPD organizations participating in the QA program.
The QA Engineer (Operations) is responsible for followup activities at Fort Calhoun Station Unit No.1, He works closely with the Manager - Fort Calhoun Station and plant Staff in this regard, notifying the Manager - Quality Assurance as each deficiency is corrected. The QA Engineer (Corporate) raintains followup on design, procurement, and supplier activities.
The Manager - Quality Assurance maintains a consolidated status summary of all deficiencies.
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