Text

QA Manual Operations, Revision 5
	ML19261D439
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/11/1979
From:	Cavanaugh W; ARKANSAS POWER & LIGHT CO.
To:	;
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ML19261D438	List: ML19261D437; ML19261D439;
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	APL-TOP-1A, NUDOCS 7906190245
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Copy No.

QUALITY ASSURANCE MANUAL OPERATIONS

/lRKANSAS POWER LIG H T HELPING Bull.D ARKANSAS 2307 005 7906190Ay5 Ei ON 5

TABLE OF CONTENTS 4EL;..iAS POWER & LIGHT COMPANY SECTION SUBJECT TAB PAGE POLICY STATEMENT FORWARD TERMS AND DEFINITIONS 1.

ORGANIZATION 1

1 1.1 SCOPE 1

1.2 ARKANSAS POWER & LIGHT COMPANY I

1.3 SUPPORTIVE SERVICES 1

1.3.1 MANAGER OF SAFETY 1

1.3.2 SUPERVISOR OF PURCHASING 1

1.4 GENERATION AND CONSTRUCTION 2

1.4.1 DIRECTOR, TECHNICAL & ENVIRONMENTAL SERVICES 2

1.4.1.1 QUALITY ASSURANCE ORGANIZATION (QAO) 3 1.4.2 DIRECTOR, PROJECTS MANAGEMENT 6

1.4.3 DIRECTOR, GENERATION OPERATIONS 6

1.4.4 DIRECTOR, GENERATION ENGINEERING 7

1.4.5 DIRECTOR, ADMINISTRATIVE SERVICES & PROJECT SUPPORT 7

1.5 ARKANSAS NUCLEAR ONE ORGANIZATION g

1.5.1 GENERAL MANAGER 8

1.5.2 OPERATIONS & MAINTENANCE MANAGER 8

1.5.3 ENGINEER & TECHNICAL SUPPORT MANAGER 10 1.5.4 PLANT ADMINISTRATION MANAGER 12 1.5.5 QUALITY CONTROL SUPERVISOR 12 1.6 QUALITY PROGRAM COMMITTEES 13 1.6.1 SAFETY REVIEW COMMITTEE 13 1.6.2 PLANT SAFETY COMMITTEE 16 1.7 ORGANIZATIONAL INTERFACES AND RESPONSIBILITIES 18 2.

QUALITY ASSURANCE PROGRAM 2

1 2.1 SCOPE 1

2.2 PURPOSE 1

2.3 APPLICABILITY 1

2.4

'iROCEDURES 3

2.5 PROGRAM REVISION AND CONTROL 4

2.6 SYSTEM STRUCTURE AND COMPONENT CLASSIFICATION 4

2.7 TRAINING AND PERSONNEL 5

2307 0066 2.8 PROGRAM REVIEW A

REV.

QUALITY ASSURANCE MANUAL 5

TITLE: TABLE OF CONTENTS 5

IABLE OF PAGE 1 of CONTENTS

SECTION SUBJECT TAB PAGE 3.

DESIGN CONTROL 3

1 3.1 SCOPE I

3.2 GENERAL I

3.3 DESIGN PROCESS /VF2.IFICATION I

3.4 DESIGN RECORDS 3

4.

PROCUREMENT DOCUMENT CONTROL 4

4.1 SCOPE 4.2 GENERAL i

4.3 REQUISITIONS 2

4.4 SPECIFICATIONS 3

4.5 PURCHASE ORDERS 3

5.

INSTRUCTIONS, PROCEDURES AND DRAWINGS 5

1 5.1 SCOPE 1

5.2 GENERAL 1

5.3 TEMPORARY CHANGES 3

5.4 CHANGES TO PROCEDURES 3

5.5 REVIEW OF PROCEDURES, INSTRUCTIONS AND DRAWINGS I

6.

DOCUMENT CONTROL 6

1 6.1 SCOPE I

6.2 GENERAL 1

6.3 DOCUMENT IDENTIFICATION 2

6.4 STORAGE AND FILING REQUIREMENTS 7.

CONTROL OF PURCHASED MATERIAL, EQUIPMENT & SERVICES I

7 7.1 SCOPE 7.2 SOURCE EVALUATION y

7.3 DOCUMENTATION OF QUALITY y

7.4 SOURCE INSPECTION 2

7.5 RECEIPT INSPECTION 3

7.6 STORAGE 3

8.

IDENTIFICATION & CONTROL OF MATERIAIS, PARTS &

8 1

COMPONENTS 8.1 SCOPE 1

8.2 IDENTIFICATION AND MARKING 1

8.3 TAGGING 1

8.4 DOCUMENTATION 2

8.5 DEFECTIVE OR INCORRECT ITEMS 2

9.

CONTROL OF SPECIAL PROCESSES 9

1 9.1 SCOPE 1

9.2 RESPONSIBILITY l

9.3 GENERAL I

9.4 QUALIFICATION 2

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TITLE: TABLE OF CONTENTS TABLE OF PAGE 2 Of 5

CONTENTS

SECTION SUBJECT TAB PAGE 10.

INSPECTION 10 1

10.1 SCOPE 1

10.2 RESPCNSIBILITY 1

10.3 INSPECTION PROCEDURES 2

10.4 INSPECTOR QUALIFICATION 2

10.5 DOCUMENTATION 3

11.

TEST CONTROL 11 1

11.1 SCOPE 1

11.2 Surveillance Testing 1

11.3 PROCEDURE APPROVAL 2

11.4 DOCUMENTATION AND REVIEW OF TEST RESULTS 2

11.5 PREOPERATIONAL TESTING 3

12.

CONTROL OF MEASURENENT AND TEST EQUIPMENT 12 1

12.1 SCOPE I

12.2 GENERAL 1

12.3 RESPONSIBILITIES 1

12.4 EQUIPMENT IDENTIFICATION 2

12.5 DOCUMENTATION 2

13.

ggryLING. STORAGE AND SHIPPING 13 1

13.1 SCOPE I

13.2 SPECIAL REQUIREFENTS I

13.3 RECEIVING INSPECTION 1

13.4 STORAGE AND PRESERVATION I

13.5 RADI0 ACTIVE MATERIALS 2

13.6 RECORDS 2

14.

INSPECTION, TEST AND OPERATING STATUS 14 1

14.1 SCOPE 14.2 DETERMINING OPERATIONAL SIATUS 14.3 IDENTIFICATION OF OPERATIONAL STATUS I

15.

NONCONFORMING MATERIAL. PARTS OR COMPONENTS 15 15.1 SCOPE

)

15.2 GENERAL 15.3 TAGGING AND STORAGE 2

15.4 DOCUMENTATION 2

16.

CORRECTIVE ACTION 16 16.1 SCOPE 1

16.2 GENERAL 1

16.')

SIGNIFICANT NONCONFORMANCES 17, QUALITY ASSURANCE RECORDS 17 1

17.1 SCOPE 1

17.2 RESPONSIBILITY l

2307 008 17.3 DOCUMENT RETENTION 1

17.4 GENERATION AND CONSTRUCTION 2

p DATE t

QUALITY ASSURANCE MANUAL REV.

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TITLE: TABLE OF CONTENTS TABLE OF PAGE 3 of 5 CONTENTS

SECTION SUBJECT TAB PAGE 17.

QUALITY ASSURANCE RECORDS (Continued) 17 17.5 STORACE 3

17.6 RECORDS INDEXING AND RECEIPT CONTROL 4

17.7 FINAL DISPOSITION 4

18.

AUDITS 18 1

18.1 SCOPE I

18.2 GENERAL I

18.3 IN-P1 ANT REVIEW AND SURVEILLANCE I

18.4 AUDIT PERSONNEL 18.5 DOCUMENTATION 18.6 AUDIT ACTIVITIES 3

APPENDIX A INTERPRETATIONS OF REGULATORY GUIDE 4 A

1-29 ANSI STANDARDS APPENDIX B QUALITY ASSURANCE PRODECURES MATRIX B

1 2307 009 QUALITY ASSURANCE MANUAL REV.

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T TITLE: TABLE OF CONTENTS uusu:, ur PAGE 4 of 5 CONTENTS

FIGURES AND TABLES FIGURES NUMBER TITLE TAB 1-1 Arkansas Power 6 Light Company 1

Corporate Organization 1-2 Arkansas Power G Light Company 1

Administrative Services-Purchasing 1-3 Arkansas Power 6 Light Company 1

Generation 6 Construction

5 1-3A Arkansas Power G Light Company 1

Quality Assurance Organization 1-4, A, B, C Arkansas Power 6 Light Company 1

ANO Organization TABLES NUMBER TITLE TAB PAGE 2-1 Quality Assurance Procedures 2

2-2 Plant Quality Procedures 2

2-3 Generation 6 Construction 2

5 2307 010 REV. 5 QUALITY ASSURANCE MANUAL TITLE: TABLE OF CONTENTS PAGE Of 5

5 o

y

ARK \\NSAS POWER G LIGIIT COMPANY POLICY STATEMENT QUALITY ASSURANCE PROGRAM FOR OPERATION It is the pol :y of the Arkansas Power S Light Company (AP6L), from the high-est level of corporate management, that its Quality Assurance Program for Operation shall meet the requirements of the Code of Federal Regulations, 10 CFR 50, Appendix B, with respect to operation, maintenance, refueling, repair and modifications, and inservice inspection of APSL Nuclear Plants.

Under the Program, the Vice President, Generation and Construction, is the

5 final nanagement authority responsible for assuring that this policy statement and the Quality Assurance Program are implemented within APGL. The General Manager is responsible for the daily implementation of the Program's procedural requirements at the plant.

Each Generation and Construction Director (Director, 5

Technical 4 Environmental Services, Director, Generation Engineering, Director,

"-nera t ion Opera t ions, Director, Project Management, etc.), is responsible for the procedural implementation of the program within his assigned area.

The Manager of Quality Assurance shall be responsible for establishing the Progran. The Manager of Quality Assurance, Director, Technical 6 Environmental 5

Services, and the Executive Director of Generation and Construction shall be responsible for approval of the program.

Quality Assurance personnel reporting to the Manager of Quality Assurance shall be responsible for auditing the Program as necessary and monitoring

5 activities required by the Program to assure compliance with its requirements.

The Plant Quality Control Supervisor shall have the authority and organizational

5 freedom necessary to meet the requirements of 10 CFR 50, Appendix B.

The Manager of Quality Assurance dall provide for annual review of the adequacy and overall effectiveness of the Program. Any defects in the implementation of either this policy or the Program that are revealed during the review, and that require action for correction, will be reported to appropriate Icvels of ma nagement together with appropriate recomnenda : ions.

Implementation of this policy is necessary in order to achieve the reliability and safety re,uired at our Nuclear Plants.

Each person involved in activities concerning our Nuclear Plants shall be responsible for assuring quality in his own work, and for compliance with the requirements of the Program. The Quality Assurance Program policies, manuals, and procedures are mandatory requirements which must be implemented and enforced by all responsible organizations and individuals.

2307 011

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WY Y

11. Cavanaugh III

/j Vice President, Gene' ration 6 Construction

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Dated:

FOREWORD Quality assurance requirements have been established for the design and construction of AP&L Nuclear Plants to assure that regulatory require-ments and licensing comminments, codes and standards are correctly translated into the as-built plant. It is the objective of this program to establish quality assurance requirements to ensure that activities such as operating, testing, refueling, repairing, maintaining and modifying the Plant are conducted in occordance with good engineering practices. To meet this objective, a Quality Assurance Program for Operation applicable to AP&L Nuclear Plants has been established by Arkansas Power & Light Company. The Program, ide '

'2d as the Quality Assurance Program for Operations, provides criteria to be s plied to the operational phase of the plant. The Program e

controls those phases, as applicable, for the design, procurement, manufact-uring and fabrication, installation, repair, maintenence or changes made to existing plant structures, components and systems that prevent or mitigate the consequences of a postulated accident which may cause undue risk to the health and safety of the public. It assures that the necessary operational safeguards are applied in accordance with the criteria for safe, efficient, and reliable operation. The Program is an outgrowth of the principle that quality assurance emanates from each individual contributor, and that manage-is responsible for creating an awareness of quality.

5 ment AP&L's initial Qualitf Assurance Program was formalized on March 10, 1971, with the initial issue of AP&L's Quality Assurance Manual. The program was revised and upgraded seven times (12/17/71, 4/5/72, 8/22/72, 2/6/73, 6/5/73,12/4/73, 3/26/74), and on 6/11/74, the Quality Assurance Program for Operations was described in a manual separate from the construction program.

Quality Assurance Program changes are made as required by the Manager of Quality Assurance to implement additional or changed requirements.

The Quality Program is implemented through quality assurance procedures contained in the following manuals.

Quality Assurance Procedures Manual Quality Assurance Administrative Procedures Manual Generation & Construction Procedures Manual

5 ANO Master Plant Manual - Quality Control Procedures All procedures contained in these manuals which are identified in this program are reviewed and approved as described in paragraph 2.4.3.

The procedures are developed and revised as necessary by the cognizant group.

The procedures and revisions are examined by the Manager of Quality Assurance to assure that Quality Assurance Program commitments are met.

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QUALITY ASSURANCE MANUAL REV.

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TITLE: FOREWORD PAGE 1 of 1

FOREWORD

TERMS AND LEFINITIONS Approval - An act of endorsing or adding positive authorization, or both.

Appurtenance - A part that is attached to a component which has been completed.

As-Built Data - Documented data that describes the condition actually achieved in a product.

Assembiv - A combination of subassemblies or components, or both, fitted together to form a unit.

Audit - An activity to determine through investigation, the adequacy of, and adherence to, established procedures, instructions, specifications, codes, and standards or other applicable contractual and licensing requirements, and the effectiveness of implementation.

Bid Eve ~ ation - A formal evaluation of all proposals received in response to an inqu.ry to determine the vendor to whom the purchase order will be awarded.

Certificate of Conformance - A written statement, signed by a qualified party, certifying that items or services comply with specific require nts.

Certificate of Compliance - A written statement, signed by a qualified party, attesting that the items or services are in accordance with specified require-ments and accompanied by additional information to substantiate the statement.

Certified Test Report - A written and signed document, approved by a qualified party, that contains sufficient data and information to verify the actual prop-erties of items and the actual results of all required tests.

Certification - The action of determining, verifying and attesting, in writing, to the qualifications of personnel or material.

Characteristic - Any property or attribute of an item, process, or service that is distinct, describable, and measurable, as conforming or nonconforming to specified quality requirements. Quality characteristics are generally identified in specifications and drawings which describe the item, process, or service.

Checks - The tests, measurements, verifications or controls placed on an activity by means of investigations, comparisons, or examinations, to deter-mine satisfactory conditions, accuracy, safety or performance.

2307 013

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i QUALITY ASSURANCE MANUAL REV.

DATE 5

TITLE: TERMS AND DEFINITIONS PAGE 1 of 6 TERMS

s Package - A wrapping or container including its contents of material or equipment.

Packaged Unit - An assembly of items and parts which can be disassembled without destroying the integrity of the individual parts.

Part - An item which has work performed on it ans which is attached to and becomes part of a component before completion of the component.

Plant - The ewuipment, piping, structures, buildings and property that comprise an installation or facility.

Procedure - A document that specifies or describes how an activity is to be performed. It may include methods to be employed, equipment or materials to be used and sequence of operations.

Procurement Documents - Contractually binding documents that identify and define the requirements which items or services must meet in order to be considered acceptable by the purchaser.

Proiect - A planned series of activities including all actions necessary to provide, utilize, and maintain a facility or portion thereof.

Proposal - A bid, usually written by a vendor in response to an inquiry, which provides the issuing party with the vendor's proposed compliance to the inquiry and the cost.

Purchase Order (or Contract,) - A document authorizing a vendor to provide equipment, material or services in accordance with stated terms and conditions.

Purchaser - The organization or organizations responsible for issuance and administration of a contract, subcontract, or purchase order.

Q-List - A list which specifically identified those structures, systems and components whose failure could cause an uncontrolled release of radioactivity, or those essential for the safe shutdown and immediate and long-term operation following a Loss of Coolant Accident.

Qualification (Personnel) - The characteristics or abilities gained through training or experience or both that enable an individual to perform a rc-quired function.

Qualified Party - A person or organization competent and recognized as know-legeable to perform certain functions.

Qualified Procedure - A procedure which incorporates all abblicable codes and standards, manufacturer's parameters, and engineering specifications and has been proven adequate for its intended purpose.

Qualified Vendor List - A listing of vendors having quality assurance programs consistent with the requirements of applicable portions of 10CFR50, Appendix B.

5 2307 014 QUALITY ASSURA1. s MANUAL REV.

5 i

TITLE: TERMS AND DEFINITIONS PAGE 4 of 6 TERMS

RECORD OF REVISIONS REVISION NUMBER DESCRIPTION DATE O

Initial Issue 6/11/74 1

Response to AEC Questions Submitted 12/13/74 11/21/74. Revisions to Section 2, 4, and 7 as indicated.

2 Response to NRC Wuestions Submitted 3/4/75 2/7/75. Procedure Numbers 1005.xx changes to 1004.xx (Number Change Only) 3 General revision to change AEC to NRC, 9/8/76 update organization, reflect NSP revisions, minor program implementation changes.

4 Eliminate Quality Assurance Committee 9/8/77 Changes to Procurement Control - Qualifi-cation of Vendors. Organizational Changes.

Incorporate Technical Specification Changes.

5 Incorporate Organizational Changes and responses to subsequent NRC Questions.

2307 015 QUALITY ASSURANCE MANUAL REV.

DATE 5

e TITLE: RECORD OF REVISION RECORD OF PAGE 1 of 1 REVISIONS

ARKANSAS POWER f, LIC!!T COMPANY QUALITY ASSURANCE PROCPuut FOR OPERATIONS TOP-1A-Rev.

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ORGANIZATION 1.1 SCOPE This section defines lines of responsibility and describes the organ-izational structure for the quality assurance functions required for the safe and reliable operation, maintenance, and modification of AP&L Nuclear Plants.

1.2 ARKANSAS POWER & LIGirr COMPANY (AP&L)

The AP&L Corporate Organization relevant to the operation of nuclear plants is depicted in Figure 1.1.

The ultimate responsibility for all power production facilities within AP&L, including Quality Assurance, lies with the Executive Director,

5 Generation & Construction. He provides management assessment of the Quality Program through review of Quality Assurance General Audit (ANO-14)

5 reports and reports of NRC activities.

The Vice President, Financial Services, shall be responsible for the purchasing functions affecting Plant operation as described in Gubsection 1.3.2.

1.3 SUPPORTIVE SERVICES

5 Purchasing services and overall personnel safety control requirements in support of the operation of AP&L Nuc1 car Plants are provided as shown in Figure 1-2.

The duties of individuals performing key functions related to the quality of the activities involved are as follows:

1.3.1 Manager of Safety The Manager of Safety reports to the Director of Personnel and shall be responsible for the following quality-related duties & activities:

1)

Serves as a member of the Safety Review Committee 2)

Establishes the corporate safety policies 3)

Publishes the Corporate Safety Manual 4)

Is responsible for AP&L implementation of OSHA requirements 5)

Inspects AP&L f acilities for compliance with the Corporate Safety Manual 1.3.2 Supervisor of Purchasing The Supervisor of Purchasing reports to the Manager, Purchasing and Stores, and shall be responsible for the following quality-related duties and activities:

QUALITY ASSURANCE MANUAL REV.

5 DATE TITLE: ORGANIZATION PAGE i of 39 2307 017

1)

Prepares purchase orders based upon receipt of reviewed and approved purchase requisitions.

)

Performs the commercial interface functions between AP&L and con-tractors or vendors.

3)

Assures that quality documentation prepared by Plant or Generation and Construction personnel are included in purchasing documents.

1.4 GENERATION AND CONSTRUCTION Generation and Construction, headed by the Vice President

, Generation and Construction, shall be responsible for all activitie s related to the operation of AP&L Nuclear Plants. These activities include design, procure-ment, modification, maintenance, and operation. Within Generation and Con-struction, coordination of the Quality Assurance Program shall be accomp-lished by the Manager of Quality Assurance. Generation and Construction consists of the following departments:

1) Generation Engineering

4) Technical & Environmental Services

2) Generation Operations

5) Administrative Services & Project

3) Projects Management Support

6) Generation Technology Generation and Construction, Little Rock General Of fice (LRGO) activities affecting quality are described in sections 2, 3, 4, 5, 6, & 7 of this manual. Procedures listed in Table 2-3 (GCP's) are utilized by LRGO persor.nel to control these activities.

5 1.4.1 The Director, Technical & Environmental Services reports to the Vice President Generation and Construction and is responsible for providing support to AP&L power plants during design, construction or operation in the areas of site selection, licensing, quality assurance, chemistry, environmental monitoring, nuclear fuel management, metallurgy and non-destructive examination. His duties include the following:

1)

Provide technical direction and administrative guidance to:

a)

Manager, Quality Assurance b)

Manager, Technical Analysis c)

Manager, Nuclear Fuel d)

Manager, Licensing 2)

Insure conformance to the Quality Assurance Program by instituting the necessary quality related procederes and instructions within the Technical & Environmental Services Department.

3)

Provides for development and control of implementation of the Program.

4)

Provides for liason between AP&L and applicable regulatory agencies.

5)

Provides for coordination of environmental surveillance programs.

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DATE QUALITY ASSURANCE MANUAL REV.

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TITLE: ORGANIZATION SECTION PAGE 2 of 19 1

2307 018

6)

Provides for procurement and design review of nuclear fuel.

5 7)

Serves as a member of the Safety Review Committee.

1.4.1.1 Quality Assurance Organization (QAO)

The APGL Quality Assurance Organization as shown in Figure 1-3, 1-3A and 1-4 is under the direction of the Manager of Quality Assurance, who reports to the Director, Technical 6 Environmental Services. The Quality 5

Assurance Organization perfoms review, surveillance and audit functions during design, construction and operational phases of AP6L's Nuclear Plants.

The duties and responsibilities of the Quality Assurance Organization during the design and construction phases are described in the AP6L Quality Assurance Manual - Nuclear Construction. QA0 duties and responsibilities in support of the operational phase are described below. The Quality Assurance

)rganization is independent of existing design, construction, and operation organizations, and reports directly to the Director, Technical 6 Environ-

5 mental Services.

1.4.1.1.1 Manager of Quality Assurance

5 The Manager of Quality Assurance shall possess the following qualifications:

1)

He shall possess a degree from an accredited school in engineering or a related scientific discipline or equivalent.

2)

He shall possess a minimum of five years experience in the quality assurance or quality control disciplines with at least two years in the nuclear field.

3)

He shall exhibit the ability to plan, schedule and direct the activities of others assigned to or functioning within the Quality Assurance Organization.

1.4.1.1.1.1 Responsibilities 1)

The Manager of Quality Assurance is responsible for developing Quality Assurance Program requirements for design procurement, manufacture, construction, modification, operation, and maintenance related to the Q-Listed system, structures, and components in AP6L Nuclear Plants.

2)

The Manager of Quality Assurance shall be responsible for the audit of the quality assurance activities as described in section 18 of this manual.

5 3)

The Manager of Quality Assurance is responsible for the review, approval and verification of the quality assurance requirements placed upon contractors or vendors that provide equipment, material, or services for APGL Nuclear Plants.

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2307 019

4)

The Manager of Quality Assurance has the authority to stop work where conditions exist that prohibit effective quality control inspections, or if faulty materials, incorrect workmanship or procedures are detected.

(For plant operations the stop work authority is directed through the General Manager.)

5 5)

The Manager of Quality Assurance is also responsible for the con-trol, and distribution of QA Manuals and QA Manual Revisions.

6)

The Manager of Quality Assurance is responsible for taview and approval of QA programs for outside organizations participating in the AP&L QA program.

7)

Disputes involving quality, arising from a difference of opinion between QA personnel and other personnel, which cannot be settled 5

interdepartmentally shall be settled by the Executive Director, Generation and Construction.

1.4.1.1.2 Quality Assurance Engineers and Supervisors 1.4.1.1.2.1 Quality Assurance Supervisor The Quality Assurance Supervisor reports to the Manger of Quality Assurance. He shall supervise QA Engineers and Inspectors, as assigned, and assist the Manager of Quality Assurance in the coodi-nation of activities of the QA Section. The Quality Assurance Super-visor may also perform duties normally assigned to Quality Assurance Engineers.

1.4.1.1.2.2 Quality Assurance Engineers

5 The Quality Assurance Engineers (QAE's) report to the Manager of Quality

5 Assurance or QA Supervisor, as assigned. Quality Assurance Engineers assure adequate control of quality activities in the areas of Construc-tion, Operations, Engineering and Audits. They possess the necessary functional independence and authority to investigate, identify and effect solutions to quality problems. Onecifically:

1)

The QAE's shall have the authority to audit or review practices,

5 records, files, instructions, directions or documents concerned with all areas affecting quality.

2)

The QAE's shall schedule and coordinate audits or surveillance

5 efforts in the areas assigned, document findings, and report to the Manager of Quality Assurance and the Manager of the audited area.

3)

The QAE's shall not perform any activity concerned with design,

5 procurement, or construction except in the areas of observation, review or audit. They shall have no in-line production ar con-

5 struction responsibilities.

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1.4.1.1.2.3 Qualifications The Quality Assurance Engineers and Supervisor report to the Manager of

5 Quality Assurance. They verify by audit the effective implementation of the Quality Assurance Program for Operations. They are thoroughly know-ledgeable of the Quality Assurance Program and associated procedures, Safety Analysis Reports, and 10 CFR 50, Appendix B.

They are familiar with the regulatory guides, codes, and standards that address quality assurance. They confer with the Manager of Quality Assurance in regard to technical issuee, periodic audits, reviews, nonconformances, correc-tive actions and external relations including inplant contractor and vendor representatives. The Quality Assurance Engineers and Supervisors shall possess the following qualifications:

l?

Be a graduate of a four-year accredited engineering or science school or equivalent with two years of experience in quality assurance, including testing or inspection of equivalent manu-facturing, construction and installation activities. At least one year of this experience should be associated with nuclear 6

facilities; or, if not the individual shall have completed train-ing sufficient to acquaint him thoroughly with the Quality Assurance requirements of a nuclear facility, or 2)

Be a high school graduate with at least five years experience in general quality assurance or engineering of equivalent manu-facturing, construction and installation activities. At least two years of this experience shall be in quality assurance, in-cluding testing or inspection of equivalent manufacturing, con-struction and installation activities. At least one year of this experience shall be associated with nuclear facilities; or, if not, the individual shall have training sufficient to acquaint him thoroughly with the Quality Assurance requirements of a nuclear facility, and 3)

Possess an understanding of management principles necessary to organize and direct the activities of the assigned personnel.

He shall have the ability to communicate clearly and provide effective leadership.

These education and experience requirements shall not be treated as absolute when other factors provide reasonable assurance that a person can competently perform a particular task.

Other factors may demonstrate capability in a given job through previous performance or satisfactory completion of proficiency testing.

1.4.1.1.3 Quality Assurance Auditors

5 The Quality Assurance Auditors report to the Manager of QA or designated QAE or QA Supervisor and assist him in the implementation of the program by performing audits and inspections as required to assure proper appli-cation of the Quality Assurance Program.

/ ~

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QA Auditors are assigned by discipline or specific responsibility and are

5 required to have specialized training and at least three years experience (or equivalent) in their area of responsibility.

5 1.4.2 Director, Projects Management

5 The Director, Projects Management reports to the Executive Director, Generation and Construction and has full responsibility for design and construction of new generating facilities. All AP6L, and major con-t2 actor (NSSS, A-E, Constructor) personnel assigned to the construction project report to the Director, Projects Management through the assigned Project Manager.

1.4.2.1

?roject Manager The Project Manager reports to the Director, Projects Management and shall be responsible for design, engineering, construction and startup activities of new generating facilities. His duties include the following:

1)

Provide tcchnical direction and administrative guidance to the proj ect organization.

2)

Ensures confomance to the Quality Assurance Program by instituting the necessary quality-related procedures and instructions within the Projects Management Department.

3)

Reviews and approves designs, engineering and fabrication perfomed by AP6L Prime Contractors or Vendors.

4)

Reviews and approves procurement documents that purchase equip-ment, material, and services for new generating facilities.

1.4.3 Director, Generation Operations The Director, Generation Operations reports

.o the Executive Director,

5 Generation and Construction and shall be responsible for the fomulation, implementation and discharge of operating policies and procedures relative to nuclear and fossil plant operations. His duties include the following:

1)

Provide technical direction and administrative guidance to:

a)

Manager, Nuclear Operations b)

Manager, Plant Maintenance c)

Manager, Fossil Operations d)

Supervisor, Data Analysis 2)

Ensure conformance to the Quality Assurance Program by instituting the necessary quality-related procedures and instructions within the Operations Department.

3)

Provides for review and approval of design and engineering performed for the operating nucicar plant.

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TITLE: ORGANIZATION PAGE Of 6

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4)

Provides for review and approval of procurement documents for equipment, material, and services as appropriate.

5)

Serves as chairman of the Safety Review Committee.

1.4.4 Director, Generation Engineering The Director, Generation Engineering, reports to the Executive Director, eneration and Construction and shall be responsible for design and engineering activities related to nuclear plant operations. Ilis duties inicude the following:

1)

Provide technical direction and administrative guidance to:

a)

Manager, Mechanical Engineering b)

Manager, Electrical Engineering c)

Manager, Civil Engineering d)

Manager, Nuclear Engineering e)

Manager, Instrumentation 6 Controls Engineering 2)

Ensure conformance to the Quality Assurance Program by instituting the necessary quality related procedures and instructions within the Engineering Department.

3)

Provides for review and approval of design and engineering performed by contractors, vendors, and AP6L personnel.

4)

Provides for review and approval of procurement documents for equipment, material, and services for engineering projects, as appropriate.

5)

Serves as a member of the Safety Review Committee.

1.4.5 Director, Administrative Services 6 Project Support The Director, Administrative Services 6 Project Support reports to the Executive Director, Generation and Construction and shall be responsible for the development of administrative programs, systems and services supportive to Generation and Construction management. Ilis duties in-clude the following:

5 1)

Provide technical direction and guidance to:

a)

Manager, General Services b)

Manager, Planning, Scheduling, and Cost Control c)

Manager, Training d)

Manager, Contracts Administration 2)

Maintain overall department fiscal direction and control, and provide supportive accounting functions.

3)

Provide contract administration and administration of proce-dures for Generation and Construction Little Rock General Office (LRGO) activities.

DATE REV.

QUALITY ASSURANCE MANUAL 5

TITLE: ORGANIZATION SE ION PAGE of 7

g 2307 023

4)

Administration of the training and development effort for the Generation and Construction staff.

5)

Ancillary support services to Generation and Construction operating sections.

1.4.6 Manager, Nuclear Operations The Manager of Nuclear Operations reports to the Director, Generation Operations and is responsible for overall management activities related to the effective operation and maintenance of nuclear generating facilities.

His duties include the following:

1)

General Office decision making for problems or situations referred by ANO Plant Management.

2)

Provide technical direction and administrative guidance to the ANO General Manager.

3)

Operations General Office review, approval, and coordination of design changes.

4)

Major purchase requisition review and approval.

5)

Interface with other departments to assure effective implementa-tion of Regulatory and Company requirements.

5 6)

Communication interface dealing with all activities at ANO.

1.5 ARKANSAS NUCLEAR ONE ORGANIZATION 1.5.1 General Manager 1.5.1.1 The General Manager reports to the Manager, Nuclear Operations on the corporate level and has direct responsibility for operating the station in a safe, reliable, and efficient manner. He is respon-sible for operating the plants in accordcnce with the provisions of the operating licenses, including the on site quality program.

1.5.1.2 The General Manager has the authority to shut the plant down if required and has final approval of plant procedures.

1.5.1.3 Reporting to thc General Manager are the following positions:

Operations and Maintenance Manager, Plant Administration Manager, Engineering and Technical Support Manager, Planning and Scheduling Supervisor and Quality Control Supervisor.

1.5.2 Operations and Maintenance Manager The Operations and Maintenance Manager (Fig. 1-4A) is responsible for

5 the operations and mechanical, electrical and electronic control systems maintenance of the plants.

It is his responsibility to maintain all plant QUALITY ASSURANCE MANUAL DAE REV.

5 TITLE: ORGANIZATION PAGE 8 Of 19 2307 024

t personnel holding a NRC Operator License in a fully trained condition and direct the day-to-day operations and maintenance activities of the plant. Reporting to him are the Operations Superintendent, the Maintenance Superintendent, and the Instrumentation and Control Superintendent to assist in each of these areas.

1.5.2.1 Operations Superintendent The Operations Superintendent shall be responsible for directing the actual day-to-day operations of the plant. lie supervises 5

the operating staff and interfaces with the Maintenance Superin-tendent of the Instrumentation and Controls Superintendent to accomplish operation related maintenance activities.

1.5.2.1.1 The Assistant Operations Superintendents report to and

5 assist the Operations Superintendent in directing the day-to-day operation of the power plant. They are responsible for coordi-nation of the daily review of operating surveillance tests and

5 coordination of operation related maintenance activities. They will assist the Operations Superintendent in the supervision of core refueling, which includes advance planning for the outage, 5

plant preparation, equipment check-out, and the refueling operation.

1.5.2.1.2 The Shift Operatiig Supervisor shall be responsible for the actual operation of the unit during his assigned shift. lie directs activities of the unit during his assigned shift. lie airects activities of the operators on his shift and is cognizai.t of all operation-related maintenance activities being performed while he is on duty. In the absence of health physics personnel, he shall be responsible for having health physics activities performed as the need arises. The Shift Operating Supervisor on duty has the authority to shut down the unit if, in his judgment, conditions warrant such action.

1.5.2.2 Maintenance Superintendent The Maintenance Superintendent shall direct activities of the mechanical, electrical and plant services groups. lie shall be responsible for organ-ining and conducting an effective preventive maintenance program for all equipment under his control. lie shall provide guidance to the training group to ensure adequate training for maintenance personnel. IIe has the responsibility to ensure that the Plant Storekeeper is informed of all spare parts needed and an adequate inventory of spare parts is on hand for all equipment under his cognizance, lie shall ensure that mainten-ance of equipment is conducted in conformance with approved standards, 5

codes and procedures when related to nuclear safety systems. Ile shall review all applicable procedures to assure conformance with technical specifications, lie shall coordinate operation-related maintenance activities with the Operations Superintendent and the Planning and Scheduling Supervisor. The Maintenance Superintendent shall have the authority to make repairs on any structure, system, or component under his control. The Mechanical Maintenance and Electrical Maintenance, Superintendents and Plant Services Supervisor report to the Maintenance Superintendent.

QUALITY ASSURANCE MANUAL REV.

5 TITLE: ORGANIZATION SECTION PAGE 9 of 19 1

2307 025

e5 1.5.2.3 Instrumentation and Controls Superintendent The Instrument and Control Superintendent is responsible for super-5 vision of activities to accomplish maintenance, checking, adjustment, testing and surveillance of all instrument and controls systems inherent to the power plant. This includes the plant computer and the maintenance of the test equipment lab to assure the most accurate test equipment 5

possible. The Instrument and Controls Supervisor, reports directly to the Instrument and Controls Superintendent. The Instrument and Controls Superintendent is also responsible for keeping the plant computer operational for data collection, fuel management, and equipment status; maintain inventory of spare parts for I 6 C reliability and perfomance, as necessary. Assistant Instrument and Controls Supervisors report

5 directly to the Instrument and Controls Superintendent.

1.5.3 Engineering and Technical Support Manager The Engineering and Technical Support Manager (Fig.1-4B) is respon-sible for previding engineering support services as well as technical e

and plant analysis support services to the plant staff. Reporting to the Engineering and Technical Support Manager are the Techrical Analysis 5

Superintendent, the Plant Analysis Superintendent, and the Plant Engineering Superintendent.

1.5.3.1 The Technical Analysis Superintendent maintair.s overall

5 responsiblity for the areas of health physics, radiochemistry and chemistry and environmental evaluations.

1.5.3.1.1 The liealth Physics Supervisor reports to the Technical Analysis Superintendent. The fiealth Physics Supervisor is directly responsible for and has the authority ot implement the llealth Physics program at Arkansas Nuclear One and to maintain exposure as low as 5

reasonably achievable (ALARA). The liealth Physics Supervisor's daily duties include supervision of Assistant Ilealth Physics Supervisors.

The }{ealth Physics Supervisor's reporting relationship is shown in Fig. 1-4B.

1.5.3.1.2 The Radiochemistry Supervisor reports to the Technical Analysis Superintendent. lie has the responsibility for assuring the reactor 5

plant water conditions are maintained within acceptable limits and for management of liquid and gaseous radwaste.

1.5.3.1.3 The Chc stry and Environmental Supervisor reports to the Technical Anmysis Superintendent. lie has responsibility for 5

assuring that secondary plant water conditions are maintained within acceptable limits. The scope of his responsibility includes surveillance and maintenance of water quality conditions in the condensate and feedwater cycle, startup boiler, nuclear and non-nuclear loops of the intermediate cooling water system and evaluation of circulating water chlorination system.

QUALITY ASSURANCE MANUAL REV.

5 TITLE: ORGANIZATION PAGE Of 10 19 2307 026

1.5.3.2 Plant Analysis Superintendent The Plant Analysis Superintendent is responsible for the areas of 5

plant performance, nuclear support and computer support. A super-visor is provided for each of these areas.

1.5.3.2.1 The Plant Performance Supervisor reports to the Plant Analysis 5

Sup erint endet.t.

liis responsibilities include:

1) Evaluating equip-ment and system performance over extended periods and recommending methods of improving and maintaining good plant efficiency, 2) in-vestigating and evaluating equipment malfunctions or failures and recommending corrective action to prevent excessive recurrences, and

3) provide assistance in completing records and reports that require special knowledge and/or skill.

1.5.3.2.2 The Nuclear Suport Supervisor is responsible for monitoring reactor core and Nuclear Steam Supply System (NSSS) performance for 5

conducting reactor performance and physics testing as required to assure safe and reliable operation and to provide carrent accurate information to operations. lie is responsible for collection and transmittal of nuclear fuel management data to the Nuclear Fuel Section in Little Rock, Middle South Services in New Orleans, and the reactor vendors as required. The Nuclear Support Supervisor is responsible for on-site safeguards and accountability of the nuclear fuel and assists in planning of all fuel movements including new fuel receipt and inspection, fuel shuffling at refueling, inspection of irradiated fuel, and shipment of spent fuel.

1.5.3.2.2.1 Nuclear Engineers assist the Nuclear Support Supervisor in performing the tasks of reactor and NSSS perfomance nonitoring and evaluation, collection and transmittal of nuclear fue management data maintaining the safeguards and accountability program for nuclear fuel, and planning, movements and inspection of nuclear 5

fuel.

1.5.3.2.3.

The Computer Support Supervisor reports to the Plant Analysis Superintendent and is responsible for the maintenance, revision and development of computer software for the plant monitoring computers. lie provides technical assistance to the Nuclear Support Supervisor and Nuclear Engineers in development and use of test apparatus for evaluation of fuel, core and NSSS per-formance. lie provides technical assistance to the plant staff in solving computer related problems.

1.5.3.3 Plant Engineering Superintendent The Plant Engineering Superintendent is responsible for providing support in the areas of design changes, design change implementation, and techni-cal expertise for plant engineering. Reporting to him are supervisors for the mechanical and electrical disciplines.

/

QUALITY ASSURANCE' MANUAL REV. 5 TITLE: ORGANIZATION PAGE of SECTION 11 19 1

2307 027

1.5.4 Plant Administration Manager The Plant Administration Manager (Fig.1-4C) reports to the General Manager and aids him 'n the administrative aspects of the plants' operation. He directs the activities of the adminiatrative staff and has reporting to him the Records and Admimistrative Supervisor, the Fire Control and Safety Coordinator, the Security Ccordinator, the Material Management Supervisor, and the Human Resources Super-visor.

1.5.4.1 The Records and Administrative Supervisor is responsible for 5

administration of the clerical staff activities and the accumulation and disposition of records related to all phases of the nuclear power plant.

1.5.4.2 The Fire Control and 9afety Coordinator is responsible for complying with the NRC regulations dealing with Fice Protection as well as to provide a centralization of OSHA and plant a.fety pro-5 grams.

g 1.5.4.3 The Security Coordinator is responsible for coordination of the efforts of the security force and to manage the operation of 5

the security system.

1.5.4.4 The Materials Management Supervism is responsible for disposal of surplus materials, equipment and strengthening pur-5 chasing / expediting support.

5.4.5 The Human Resources Supervisor is responsible for career counseling employment, industrial relations, and training.

5 1.5.5 Quality Control Supervisor The Quality Control Supervisor (.ig. 1-4) is responsible for implementation

5 of the Quality Assurance Program for Operations at the plant. He reports to and receives direction from the General Plant Manager. The Quality Control

5 Supervisor has authority and is responsible to communicate with the Manager, Quality Assurance or his representative for technical assistance or coordi-nation in resolving significant conditions adverse to quality. This communi-cation may be accomplished verbally or by written memorandum.

1.5.5.1 The duties of the Quality Control group include surveillance, checks, inspections, reviews of quality-related activities and doc-uments, and maintenance of the Quality Control files. Used in this context, listed below are definitions of surveillance,

5 checks, inspections, and reviews.

I Surveillance The continuing analysis and evaluation of records, methods, and procedures, including the act of verifi-cation, to ascure conformance with technical require-ments.

QUALITY ASSURANCE MANUAL REV. 5 DAE TITLE: ORGANIZATION 8

0 Q

PAGE 12 of 19 2307 028

Checks The tests, measurements, verifications, or controls placed on an activity by means of investigations, comparisons, or examinations to determine satis-factory condition, accuracy, safety, or performance.

Inspections A phase of quality control which by means of exam-ination, observation, or measurement determines the conformance of materials, supplies, components, parts, 5

appurtenances, systems, processes, or structures to pre-determined quality requirements.

Review An element of inspection to determine conformance to specified requirements, which can be determined by examination of cocuments and activities.

1.5.5.2 The Quality Control Supervisor shall have the authority to place

5 any item in a non-confoming status when he detemines such item to be in violation of purchase documents, applicable codes and standards of FSAR requirements. Reporting to the Quality Control Supervisor

5 is the Quality Control Engineer and a staff of Inspectors.

g 1.6 QUALITY PROGRAM COMMITTEES l

1.6.1 Safety Review Committee (SRC) l.6.1.1 Membership Director, Generation Operations (Chairman)

Director, Generation Technology Director, Generation Engineering Director, Technical & Environmental Services Arkansas Power & Light Company Manager of Safety 5

Arkansas Nuclear One General Manager Manager, Technical Analysis Arkansas Nuclear One plant Analysis Superintendent Radiation and Health Physics Consultant Nuclear Safety Consultant In his absence, the Chaiman shall appoint an Acting Chairman.

Alternates:

1)

Each pemanent voting member shall have an alternate to serve in his absence. Alternates shall be appointed in writing by the SRC Chairman.

2)

No more than two alternates shall serve on a committee at any one time as voting members.

1.6.1.2 Function Members and alternates shall collectively review and audit the areas of:

QUALITY ASSURANCE MANUAL REV. 5 TITLE: ORGANIZAIION m

PAGE 13 of 19 2307 029

5 1)

Nuclear Power Plant Operations 2)

Nuclear Engineering 3)

Chemistry and Radiochemistry 4)

Metallurgy 5)

Instrumentation and Control 6)

Radiological Safety 7)

Mechanical and Electrical Engineering d)

Environmental Considerations 9)

Other appropriate Fields Required by the Unique Characteristics of the Nuclear Power Plant.

When the nature of a particular situation dictates, special consultants will be utilized to provide expert advice to the SRC upon request of the SRC Chairman.

1.6.1.3 Meeting Frequency The Safety Review Committee shall meet on call by the Chairman but not less frequently than once per 6 months. During the period of initial operation, Safety Review Committee shall meet no less fro-quently than once per calendar quarter.

1.6.1.4 Quorum 1)

A quorum shall consist of the Chairman or his designated

5 alternate and four members including alternates.

2)

No more than a minority of the quorum shall have line res-ponsibility for nuclear unit operation.

1.6.1.5 Authority and Responsibility The Safety Review Committee shall report to and be advisory to the Executive Director, Generation & Construction in those areas of res-ponsibility specified in 1.6.1.6 and 1.6.1.7.

1.6.1.6 Review The SRC shall review:

1)

The safety evaluations for 1) changes to pr;cedures, equipment or systems end 2) tests or experiments completed under the provisions of 10 CFR 50.59, to verify that such actions did not constitute an unreviewed safety question.

2)

Proposed changes to procedures, equipment or systems which involve an unreviewed safety. question as defined in 10 CFR 50.59.

3)

Proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59.

4)

Proposed changes in Technical Specifications or licenses.

^

QUALITY ASSURANCE MANUAL REV. 5 TITLE: ORGANIZATION SECTION PAGE 14 of ig i

2307 030

5)

Violations of applicable statutes, codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

6)

Significant operating abnormalities or deviations from nomal end expected performance of plant equipment that affect nuclear safety.

7)

Reportable occurrences requiring 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months notification to the Comission.

8)

Reports and minutes of Plant Safety Committee meetings.

1.6.1.7 Audits

5 Audits of facility activities shall be performed under the cogni-zance of the SRC. These audits shall encompass:

g 1)

The conformance of facility operation to provisions con-tained within the Technical Specifications and applicable license conditions at least once per year.

2)

The performance and retraining of all members of the facility management and operations staff, and the performance, train-ing, and qualifications of new members of the entire facility staff at least once per year.

3)

The results of all actions taken to correct deficiencies occur-ing in facility equipment, structure, systems or methods of operation that affect nuclear safety at least once per six months.

4)

The Facility Emergency Plan and implementing procedures at least once per two years.

5)

The Facility Security Plan and implementing procedures at least once per two years.

6)

Any other area of facility operation considered appropriate by the SRC or the Executive Director, Generation 6 Construction.

5 7)

The Facility Fire Protection Program and implementing procedures

5 at least once per two years.

1.6.1.8 Records Records of SRC activities shall be prepared, approved and distributed as indicated below:

1)

Minutes of each (SRC) meeting shall be prepared, approved and forwarded to the Executive Director, Generation 6 Construction

5 within 30 days following each meeting.

A QUALITY ASSURANCE MANUAL REV.

5 TITLE: ORGANIZATION PAGE 15 of 19 2307 031

2)

Reports of reviews encompassed by Section 1.6.1.5, 6) 7), and

8) above, shall be prepared, approved and forwarded to the Executive Director, Generation 6 Construction within 30 days

5 following completion of the review.

3)

Audit reports encompassed by Section 1.6.1.7 above, shall be forwarded to the Executive Director, Generation and Construction

5 and to the managernent positions responsible for the areas audited within 30 days after completion of the audit.

1.6.2 Plant Safety Comittee PSC 1.6.2.1 Membership Chaiman:

Operations and Maintenance Manager 5

Member:

Technical Analysis Superintendent Member:

Instrumentation 6 Controls Superintendent Member:

Operations Superintendent Member:

Maintenance Superintendent g

Member:

Plant Analysis Superintendent

5 Member:

Health Physics Supervisor The General Manager shall appoint an acting chaiman in the l5 absence of the Operations and Maintenance Manager.

1.6.2.2 Meeting Frequency Monthly, and as required, on call of the Chairman or his designated alternate.

1.6.2.3 Quorum Chaiman plus three members including alternates.

1.6.2.4 Alternctes Designated alternates shall be appointed by the Chairman in writing and shall serve only on a temporary basis; however, there shall be no more than two (2) alternate members serving on the comittee as voting members at any one time.

1.6.2.5 Responsibilities The Comittee shall be Ovsponsible for:

1)

Review of all procedures required by Appendix A of the Technical Specifications and revisions and any other proposed procedures

5 or revisions as determined by the General Manager to affect nuclear safety.

^

QUALITY ASSURANCE MANUAL REV.

5 TITLE: ORGANIZATION SECTION PAGE 16 ofl9 1

2307 032

2)

Review of proposed tests ar.d experiments which affect nuclear safety.

3)

Review of proposed changes to the Appendix A Technical Specifications.

4)

Review of proposed changes to modifications to plant systems or equipment which affect nuclear safety.

5)

Review of nuclear unit operations to detect potential nuclear safety hazards.

6)

Investigation of all violations of the Technical Specifi-cations involving activities under the responsibility of the

5 General Manager, including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the General Manager.

5 7)

Performance of special reviews and investigations and render g

reports thereon as requested by the General Manager.

5 8)

Review of the Plant Security Plan and implementing procedures and shall submit recommended changes to the General Manager.

5 9)

Review of the Emergency Plan and implementing procedures and shall submit recomended changes to the General Manager.

5

10) Review of those reportable occurrences rea,uiring 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months noti-fication to the NRC.

1.6.2.6 Authority The Plant Safety Committee Shall:

1)

Recomend to the General Manager written approval or disapproval

5 of proposals under items 1.6.2.5 (1) through 1.6.2.5 (4) above.

a)

In the event of a disagreement between the recommendations of the Plant Safety Committee and the actions contemplated by the General Manager, the course determined by the General Manager to be more conservative will be followed. Records of the disagreement will be sent for review to the Executive 5

Director, Generation 6 Construction or Manager, Nuclear Operations and the Safety Review Committee by the General Manager on the next working day.

2)

Render tentative deteminations, in writing, as to whether or not items considered under 1.6.2.5 (1-4) and 1.6.2.5 (6) above involve unreviewed safety questions.

/'

QUALITY ASSURANCE MANUAL TITLE: ORGANIZATION SECTION PAGE 17 of 19 1

2307 033

~

1.6.2.7 Records Minutes shall be kept by the commiteee of all meetings of the Plant Safety Committee and copies.shall be sent to the Chairman of the

5 Safety Review Committee by the General Manager.

1)

Coordination of Environmental Technical Specification development with th; Safety Technical Specification.

2)

Proposed changes to the Envi19nmental Technical Speci-fications and the evaluated impact of the changes.

3)

Proposed written procedures, as described in Specification 5.5, and proposed changes thereto which affect the plant's environmental impact.

4)

Proposed chages or modifications to plant systems or equipment which would affect the plant's environmental impact and the evaluation of the impact of these changes.

L 5)

Results of the Environmental Monitoring Programs prior to their submittal in each semiannual Envirorsental Monitoring Report.

6)

Investigations of all reported instances of viciations of Environmental Technical Specifications. Where investigation warrants, instances shall be evaluated and recommendations formulated to prevent recurrence.

1.7 ORGANIZATIONAL INTERFACES AND RESPONSIBILITIES As owner and operator, AP6L assumes full responsibility and authority for the Plant and shall take all appropriate action to assure that the Plant is operated in accordance with sound engineering practices, including applicable codes, specifications and procedures.

The Projects Management Department is responsible for establishing

5 technical and management interfaces between the constructor, archi-tect-engineer (A/E), nuclear steam supply system (NSSS) vendor, and AP6L. These interfaces may be utilized as needed during operation of a nuclear unit for technical consultation and services. These interfaces are established prior to the complete phase out of the design and construction forces to assure an orderly transition within the contractor firms.

Each supplier of equipment, material or services and each maintenance or modification contractor is responsible for administering the appli-cable quality control functions as required by AP6L. The Quality Assurance Organization is responsible fcr assuring by surveillance 5

audit or review of objective evidence (e.g. audit reports conducted by others, etc.), that these functions are accomplished for systems and structures that affect the safety and integrity of the plant.

QUALITY ASCURANCE MANUAL Dm REV.

5 TITLE: ORG\\NIZATION ON i

PAGE 18 of 19 2307 034

Visits to manufacturer's shops by Quality Assurance Organization personnel are conducted when deemed necessary based upon safety 5

significance, complexity, method of acceptance, and past history of the vendor, to establish product quality and to ensure that quality assurance and quality control programs function in accor-dance with AP6L requirements.

The Manager, Quality Assurance is responsible for communications with m NRC Regional Office regarding NRC quality assurance requirements related to the quality assurance activities described in the Quality Assurance Program for Operations and the implementation of the pro-cedures within AP6L support organizations.

The General Manager is responsible for communcations with the NRC

5 Regional of fice regarding the adequacy, implementation and use of the Quality Assurance Program for Operations at the Plant.

Arkansas Power 6 Light Company delegates to Middle South Services, I

Inc., a wholly owned subsidiary of Middle South Utilities, Inc.,

the responsibility for performing those quality assurance functions 5

necessary to ensure that its nuclear fuel is designed and fabricated in accordance with regulatory requirements and accepted codes, standards and specifications. The MSS quality assurance section monitors the design and fabrication of the fuel through a program of audits of the fuel fabricator, including both design review audits and fuel fabrication audits. MSS also conducts audits of component suppliers as deemed necessary by the Manager QA (MSS),

5 to ensure the quality of the fuel.

Formal audit reports ere issued by MSS to document their audit activities and to identify non-conformances or other items requiring action by the fuel fabricator.

Resolution of nonconformances or other iter _s requiring action is verified by MSS and documented in follow-up reports. The AP6L Quality Assurance Manager is on distribt' tion for all audit and follow-up reports.

4 DATE REV.

QUALITY ASSURANCE MANUAL 5

TITLE: ORGANIZATION PAGE of g

g 2307 035

~

CllAIPJIAN 0F TIIE BOARD PRESIDENT 6 CilIEF EXECUTIVE OFFICER VICE PRESIDENT SENIOR VICE PRESIDENT DIRECTOR DIRECTOR, RATES GENERATION 6 SYSTD1 ENGR. 6 TREASURER CORPORATE 6

RESEARCil CONSTRUCTION PLANNING COFNUNICATIONS DIRECTOR PUBLIC AFFAIRS IL DIRECTOR DIRECTOR DIRECTOR DIRECTOR DIRECTOR DIRECTOR PROJECTS GENERATION GENERATION GENERATION ADMINISTRATIVE TECIINICAL 6 MANAGBIENT ENGINEERING TEC!IN0 LOGY OPERATIONS SERVICES 6 ENV IP.ONMENTAL DIRECTOR PROJECT SUPPORT SERVICES PERSONNEL i

SENIOR VICE PRESIDENT N

s u

O N

o DIRECTOR u

ARKANSAS POWER S LIGiff COMPANY CORPORATE L%

CORPORATE ORGANIZATION SERVICES Figure I-I Rev. 5

PRESIDENT & CHIEF OPERATING OFFICER SR.VICE PRESIDENT PERSONNEL DIRECTOR DIRECTOR OF CORPORATE SERVICES MANAGER OF SAFETY MANAGER OF

'URC11ASING AND STORES N

LN O

N SUPERVISOR OF PURCHASING O

LN N

ARKANSAS POWER & LIGHT COMPANY Figure 1-2 SUPPORTIVE SERVICES Rev. 5

VICE PRESIDENT GENERATION 6 CONSTRUCTION SAFETY REVIEW C0bNITTEE DIRECTOR DIRECTOR DIRECTOR DIRECTOR DIRECTOR DIREC'IVR ADM. SERVICES PROJECTS GENERATION GENERATION TECIINICAL 6 GENERATION AND PROJECT MANAGEMENT EbGINEERING TECHNOLOGY ENVIRONMENTAL OPER?TIONS

{

SERVICES SUPPORT e

e MANAGER PROJECT MANAGER MANAGER MANAGER QUALITY NUCLEAR ASSURANCE FUEL

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MANAGER MANAGER GENEF.AL TECIINICAL LICENSING MANAGER ANALYSIS E

QUALITY PLANT CONTROL SAFETY g

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SUPERVISON C0bHITTEE O

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U CD Arkansas Power 6 Light Company Generation 6 Construction Figure 1-3

VICE PRESIDEN; GENERATION CONSTRUCTION I

DIRECTOR TECHNICAL AND ENVIRONMENTAL SERVICE!

(

s MANAGER QUALITY ASSURANCE i

QUALITY QUALITY QUALITY FOSSIL FOSSIL ASSURANCE ASSURANCE ASSURANCE QUALITY CONSTRUCTION ENGINEER ENGINEER ENGINEER ASSURANCE INSPECTORS AUDIT (LR)

JPERATIONS(ANO)

ENGINEERING (LR)

PERSONNEL

QUALITY QUALITY ASSURANCE ASSURANCE AUDITOR (LR)

AUDITOR (ANO)

Are Utilized Periodically For Nuclear Q.A. Auditing 2307 039 Arkansas Power & Lif-Company Fig. 1-3A Quality Assurance Or Ization

GENERAL MANAGER OF MANAGER QUALITY ASSURANCE COMMUNICATION QUALITY CONTROL INSPECTORS PLANNING &

QUALITY SCHEDULING CONTROL SUPERVISOR SUPERVISOR QUALITY CONTROL ENGINEER OPERATIONS &

PLANT ENGINEERING N

MAINTENANCE AMINISTR.

& TECHNICAL trJ MANAGER MANAGER SUPPORT C

MANAGER N

O 4

O Arkansas Power & Light Company Fig. 1-4 ANO Organization

GENERAL MANAGER r

i 1

J OPERATING 6 MAINTENANCE MANAGEP OPERATIONS MAINTENANCE INSTR. 6 SUPT.

SUPT.

CONTROL SUPT.

16C ASSISTANT OPERATIONS SUPVRS.

SUPERINTS.

UNIT 1 UNIT 2 S11IFT SilIFT 91f PVR 9.

91fPVRS.

PLANT PLANT OPER.

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PLANT PLANT OPER.

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OPER.

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ELECTRICAL MECilANICAL PLANT MAINTENANCE MAINTENANCE SERVICES 9UPT.

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Arkansas Power 6 Light Company ELECTRICAL MECliANICAL ANO Organization MAINTENANCE MAINTENANCE SUPVRS.

SUPVRS.

Fig. 1-4A 2307 041

r GENERAL p_________________

MANAGER I

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l l

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l TECHNICAL l

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MANAGER I

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ANALYSIS ANALYSIS ENGINEERING l

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HEALTH PERFORMANCE MECHANICAL L.

PHYSICS SUPERVISOR ENGINEERING SUPERVISOR SUPERVISOR NUCLEAR l

SUPPORT ASSISTANT SUPERVISOR HEALTH ELECTRICAL PHYSICS ENGINEERING SUPERVISORS SUPERVISOR NUCLEAR ENGINEERS RADIO CHEMISTRY SUPERVISOR COMPUTER Sl'PPORT SUPERVISJR 2307 042 CHEMISTRY &

ENVIRONMENTAL COMPUTER SUPERVISOR ENGINEERS l

l Arkansas Power & Light Company Fig. 1-4B ANO Organization

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GENERAL MANAGER l

r

(

)

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PLANT ADMINSTR.

MANAGER RECORDS HUMAN MATERIALS

& ADMINSTR.

RESOURCES MANAGEMENT SUPERVISOR SUPERVISOR SUPERVISOR FIRE CONTROL SECURITY

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2307 043 Arkansas Power & Light Company Fig. 1-4C ANO Organization r

2.

QUALITY ASSURANCE PROGRAM 2.1 SCOPE 2.1.1 The AP6L Corporate Quality Assurance Program for Operations (Program) addresses those requirements, responsibilities, and actions that pro-vide managerial and administrative controls to assure safe plant opera-tion. The Program shall comply with the Requirements of regulatory 5

positions in Regulatory Guides 1.8 Rev. 1 (5/77), 1.28 Rev. 1 (3/78,

1.30 (8/11/72),1.33 Rev. 2 (2/78),1.37 (3/16/73),1.38 Rev. 2 (5/77),

1.39 Rev. 2 (9/77),1.58 (8/73),1.64 Rev. 2 (6/76),1.74 (2/74),1.88 Rev. 2 (10/76),1.94 Rev. 1 (4/76),1.116 Rev. 0-R (5/77),1.123 Rev. 1 (7/77), and ANSI 45.2.12 Draft 4, Rev. 2 (1/1/76) subject to the inter-pretations clarifications / exceptions listed in Appendix A.

The above requirements are implemented by controlling activities as described in this manual and procedures referenced in this nanual.

2.2 PURPOSE 2.2.1 'The purpose of the Program is to ensure that Arkansas Power 6 Light Company nuclear power plants are operated in a safe, reliable and efficient manner in compliance with NRC regulations, applicable in-5 dustiral standards and codes and all applicable Company policies, rules, approved operating procedures and license provisions. A matrix of QA procedures cross-referenced to each criterion of 10CFR50 Appendix B is included as Appendix B to this Program.

2.3 APPLICABILITY 2.3.1 The Program is applied to systems, equipment and components to the extent consistent with their importance in preventing or mitigating the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The Program is therefore

5 applied, but not limited to the structures, systems and components defined in the Plant Q-List (safety related). Changes to the Q-List require review / approval by Engineering, Licensing and Quality Assurance.

Distribution of the Q-List is maintained and controlled by the Licensing Section. Control also includes revision number and date of each change and maintenance of a list of personnel in possession of the Q-List.

2.3.2 The Program functions in addition to the Quality Assurance Manual -

Nuclear Construction. The Manager of Quality Assurance, the Director of Technical and Environmental Services, and the Executive Director

5 of Generation and Construction shall approve the Program. Program adequacy and effectiveness is determined by performance of audits.

2.3.3 AP6L shall be responsible for the assurance that nuclear fuel used in AP6L Nuclear Plants is designed, procured, manufactured, and utilized in accordance with regulatory requirements, and related industrial codes and standards. Nuclear Fuel Assemblies are considered to be Q-List (i.e. safety-related) items. AP6L delegates to Middle South Services the actual performance of quality assurance functions related t the design, procurement and manufacture of nuclear fuel (reference--

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13 2307 044

(continued) 2.3.3 for the performance of this activity is reviewed and approved by the Manager of Quality Assurance. The technical interface with Middle South Services is the responsibility of the Manager, Nuclear Fuel. The interface and its attendant duties and responsi-bilities are contelled by the procedure for fuel management control (GCP - 310). On site quality control for nuclear fuel is implemented through the use of procedures in the Master Plant Manual. Site-re-lated nuclear fuel activities are described in procedure OP 1502.05 (Control and Accountability of Nuclear Fuel). Detailed nuclear fuel

5 inspections are carried out as described in OP 1503.02 (Fresh Fuel Inspection and Storage - Unit 1) or in OP 2503.01 (Fresh Fuel Inspec-tion and Storage - Unit 2).

Inspection and handling activities are specified in procedure 1502.05. The Nuclear Engineer maintains a listing of those individuals qualified to perform receipt inspections.

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2.3.4 The Program defines responsibilities and duties te specific positions.

These responsibilities and duties may be performed by other qualified persons if the specified individual is not available.

2.4 PROCEDURES 2.4.1 Activities which affect quality shall be defined in appropriate proce-dures. Procedures shall be developed to cover AP6L administration and control. The procedures shall state the policies and instructions nec-essary to fulfill the intent of the Program. Procedures shall provide for standard forms, lists, and checkoffs used in documentating the in-spections, certifications, reviews and audits. The program and the procedures shall be modified or supplemented from time to time as the need for change arised during the life of the Plant.

2.4.2 The procedures ensure that activities affecting quality are performed under suitably controlled conditions. Controlled conditions include the use of appropriate equipment; suitable environmental conditions for performing the activity such as adequate cleanness and assurance that required prerequisites for the given activity have been satisfied.

The procedures also specify the need for special controls, processes, and 1st equipment to attain the required quality, and the need for verification of quality by inspection and test.

2.4.3 Program Procedures

1) Quality Assurance Procedures The Quality Assurance Organization employs a system of procedures designated as Quality Assurance Procedures (QAP) in order to im-plement the requirements of the Program. The QAP's and revisions thereto are prepared by the Quality Assurance Organization, re-viewed and approved by the Manager of Quality Assurance and ap-

5 proved by the Director, Technical 6 Environmental Services and

5 Executive Director Generation and Construction. QAP's referenced

5 in this document are listed by title in Table 2-1.

2) Quality Control Procedures The plant operation organization employs a system of procedures designated as Quality Control Procedures (OCP) in order to imple-ment Program requirements that control onsite activities. The QCP's and revisions thereto are prepared by the plant staff, re-viewed by the Plant Safety Committee, QC Supervisor, and the Manager

5 of quality Assurance, and approved by the General Manager. QCP's

5 re'crenced in this document are listed by title in Table 2-2.

3) Generation 6 Construction Procedures

5 The Generation and Construction Department-Little Rock General Office (LRGO) employs a system of procedures designated as Gen-

5 eration and Construction Department Procedures (GCP) in order to

5 implement Program requirements for the control of design, engineer-ing and procurement activities in support of the operating plant.

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The GCP's and revision thereto are prepared by Generation 6 Con-

5 struction LRGO personnel, reviewed by the Manager of Quality Assurance, and approved by the Generation md Construction (LRGO)

5 Procedures Task Force. GCP's referenced in this document are listed by title in Table 2-3.

2.4.4 Other organizations within AP6L may establish written pro-cedures to control support activities affected by the require-ments of this Program. Procedures developed by such organizations shall be prepared and reviewed for technical adequacy within the cognizant organization, reviewed by the Manager of Quality Assurance and approved by the cognizant organization's manager.

5 2.4.5 Any procedure used at the operating plant in the master plant manual will be reviewed and approved in accordance with the Pro-cedure QCP 1004.21. Review of procedures by the QC Supervisor, or 5

his designee, is required as stated in paragraphs 5.2.6 and 10.1.4 of this TOPICAL.

2.5 PROGRAM REVISION AND CONTROL 2.5.1 Program revision and control shall be the responsibility of the Manager of Quality Assurance.

2.5.2 Proposed changes to the Program shall be submitted by the Manager of Quality Assurance to cognizant directors and managers for review

5 and comment prior to approval. The Nuclear Regulatory Commission Quality Assurance Branch, Division of Project Management, shall be notified of changes to this TOPICAL as follows:

1) Programmatic 5

Changes (except for those that are editorial in nature) prior to implementation of the change and 2) organizational changes within thirty days after announcement.

2.5.3 After resolution of comments as described in paragraph 2.5.2,

5 changas to the AP6L Quality Assurance Program shall be approved by the Manager of Quality Assurance, Director, Technical 6 Environ-mental Services, and the Executive Director, Generation and Con-struction.

2.5.1 Quality Assursnce Prognms of Others 2.5.4.1 The Program includes provisions that require suppliers, centractors, subcontractors, consultants, etc., to maintain and use adequate quality assurance programs.

2.5.4.2 C(ntractor quality assurance programs shall be reviewed and approved by the MGR., QA or his designee.

The review and approval l5 of such documents by APGL in no way relieves the contractor of his responsibility to AP6L to meet the applicable quality require-ments of the licensing agency as outlined in 10 CFR 50, Appendix B.

Audits by the Quality Assurance Organization provide assurance of compliance with applicable procedures.

2.6 SYSTEM, STRUCTURE, AND COMPONENT CLASSIFICATION AL

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2.6.1 The system, structures and components that perform safety-related functions are designated as Q-List items. The Q-List specifically identifies those systems, structures and components whose failure could cause an uncontrolled release of radioactivity, or those essential for safe shutdown and the immediate and long-term opera-tion following a Loss of Coolant Accident. When structures, systems or equipment as a whole are on the list, portions not associated with a loss of safety function are not meant to be included.

2.6.2 The Q-List is initially generated by the architect-engineer during the design phase of the project. The Q-List is considered a derign document and is reviewed and approved in accordance with the proce-

5 dure for Licensing / Document Control (GCP-300). The approved Q-List is retained as a functional document throughout the life of the plant to provide for the application of Program requirements to a specific system, structure or component. The Manager of Licensing is respon-

5 sible for maintaining and controlling the Q-List. Changes to the Q-List require review (approval by Licensing, QA, and Engineering.

Distribution of the Q-List is maintained and controlled by the Licensing Section. Control also includes revision number and date of each change, 5

and maintenance of a list of personnel in possession of the Q-List.

2.6.3 Expendable and/or consumable items whose quality is necessary for the performance of Q-List structures, systems, and components are controlled to assure service quality. This is accomplished as follows:

Diesel Fuel - Service Quality is assured by provisions / tests required by Technical Specification 4.6.1.4 (e) - Unit 1 and 4.8.1.1.2 (b) - Unit 2.

5 Welding Rod - Service Quality is assured by procurement from an evaluated source, requiring material test results, and controlling the rod on-site prior to use, to prevent degradation.

Boric Acid - Service Quality is assured by procurement from an evaluated source, requiring a batch analysis to assure conformance with our specification requirements, and on-site control prior to use, to prevent degradation.

.7 TRAINING AND PERSONNEL Employees whose duties and responsibilities are related to the quality assurance activities at the Plant shall participate in appropriate indoctrination and training programs. It shall be the responsibility of the employee's immediate management to arrange for the quality assurance indoctrination program. The General

5 Manager has responsibility for Plant Staff personnel indoctrination regarding the Quality Assurance Program.

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C 2.7.1 Quality Assurance Indoctrination The purpose of quality assurance indoctrination,is to familiarize the employee with the Quality Assurance Program. Emphasis is placed on the importance and meaning of quality assurance as it applies to the employee's particular position and function.

2.7.2 The quality assurance indoctrination for the management of AP6L support organizations shall be conducted by the Manager of Quality Assurance of his designated representative. The management fo the support organ-ization in turn is responsible for conducting an indoctrination of employees in their respective groups. The indoctrinations they conduct shall cover the areas in which the group or employee has particular responsibilities. The Quality Assurance Program indoctrination is coordinated at the plant by the Training Supervisor or his designated representative. Quality assurance indoctrination includes the following items:

1) Discussion of the philosophy and objectives of the Quality Assurance Program.

2) E::planation of the Company's quality assurance organization and demonstration of how it affects the duties and responsibilities of the employee.

3) Summary of the QAP's and QCP's contentas applicable with specific emphasis placed on those sections which most directly affect the employee's position.

4) Discussion of interfaces with the NRC and contracted organizations.

3 A record of attendance at quality assurance indoctr2.tation sessions shall be maintained by the Manager of Quality Assurance, for members of the Quality Assurance Organization and AP6L support organizations.

The Training Supervisor maintains the record of attendance for

5 plant staff.

2.8 PROGRAM REVIEW 2.8.1 The Manager of Quality Assurance shall be responsible for an annual review of the Quality Assurance Program for Operations to determine

3 the effectiveness and proper implementation of the Program (ANO-14).

2.8.2 Assigned Quality Assurance personnel regularly review the status, adequacy, and effectiveness of the implementation procedures as part

4 of daily work (ANO-13, ANO-17 and ANO-18).

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Table 2-1 Quality Assurance Procedures ANO-3 Surveillance Audits This procedure establishes methods for performing quality assurance surveil-lance audits for Arkansas Power 6 Light Company at the manufacturing, design, or engineering facilities of companies supplying systems, materials, and/or components. It is specifically designed to verify the quality programs of suppliers and provides a method of reporting findings and identifying defi-ciencies.

4 ANO-6 Supplier Quality Assurance System Evaluation This procedure establishes methods for performing quality assurance audits at the supplier's facility. It is specifically designed to verify the qua-

1 lity programs of suppliers to 10 CFR 50, Appendix B and ANSI N45.2, and pro-vide a method of reporting findings and identifying deficiencies.

ANO-13 Central Chemistry Laboratory Surveillance Audit This procedure establishes a method for frequent surveillance audits of the

4 Central Chemistry Laboratory to assure compliance with the AP&L Quality Assurance Program. It provides methods to identify areas of deficiency (or potential deficiency) for necessary corrective action.

ANO-14 AP&L Quality Assurance General Audit

3 This procedure establishes methods for general audit of the operating plant (s),*

Generation & Construction Organization, QA Section and others to assure that

5 quality activities conform to the requirements of 10 CFR 50, Appendix B.

ANO-15 Review of Supplier Documentation. Evaluation and Qualification This procedure is designed to establish a method for documentation of reviews

4 and evaluations performed in-house by AP6L QA personnel to qualify suppliers for providing Q-list materials or services. This includes the review and evaluation of the Supplier's Quality Assurance Program, Manual, procedures and/or other supporting documentation, as appropriate.

ANO-17 Operating Plant Surveillance Audit This procedure establishes a method for frequent surveillance audits of plant quality activities to assure compliance with the AP&L Quality Assurance Program. It provides methods to identify areas of deficiency (or potential deficiency) for recessary corrective action.

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Table 2-2 ARKANSAS NUCLEAR ONE PLANT QUALITY C0f(TROL PROCEDURES

2 1004.01 Design Control This procedure establishes the methods for control and design measures for the modification of those plant systems and plant equipment identified on the plant Q-List. The interface control and responsibilities between ANO and offsite Departments for design work are established.

5

5 1004.04 Turnover of Q. A. Documents from Construction to AP6L This procedure describes the methodology for Review of Quality Assurance Records associated with plant turnover.

It assures that documents are

3 complete and adequate, and that structures, items or components are accept-

3 able to APSL.

1004.05 Purchase Requisition Preparation and Processing This procedure establishes the methods and responsibilities for preparation, review and approval of purchase requisitions for safety-related items to assure that the procurement documents contain the quality requirements necessary to verify that the item is in conformance with the applicable specifications.

1004.06 Material Receiving and Inspection This procedure establishes the methods by which material is received at ANO and inspected to assure that it is the correct material, conforms to require-ments and has the proper identification and documentation.

1004.07 Control of Special Processes This procedure covers the establishment of process controls and requirements for qualifications of personnel, procedures and equipment, 2004.08 Q.C. Inspection This procedure provides control for inspection planning (including inspec-

3 tion hold points), performance of inspection, and reporting for all activi-ties affecting quality.

3 J--

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TABLE 2-3 GENERATION 6 CONSTRUCTION (G6C) PROCEDURES

5 These Procedures apply for those activities conducted with the APGL Generation

5 and Construction Little Rock General Office (LRGO).

GCP-100 Procedure Development Methodology and Documentation Standards This procedure establishes the methods by which Generation and Construction 5

Department LRGO procedures (GCP's) are prepared, revised, and controlled.

GCP-101 Drawing Control

5 This procedure establishes the responsibility of the LRGO and the method by

5 which engineering drawings, either in paper form or on aperture cards, are controlled, including receipt, filing, disposition of superseded drawings, and retention.

GCP-102 Procurement This procedure establishes the responsibilities anc. methods by which procure-ment of safety-related parts, material or services is reviewed and approved by the LRGO.

In includes the required QA review and technical review of 5

contractor-prepared purchase specifications and documents. This procedure also provides detailed control for the actual preparation, review and approval of a purchase requisition and for the distribution control and follow-up of the actual purchase order release to the vendor by the Supervisor of Purchasing.

GCP-201 Design Change Package Control

5 This procedure establishes the methods used within the LRGO to maintain control of design changes during design and control of modifications to 5

operating nuclear plants.

GCP-202 Design Process This procedure explains the process by which design inputs are translated into documents to accomplish final design. This includes design analysis 5

and calculations, rhen applicabic. This procedure also establishes the methods used within the LRGO for the independent checking of design documents through a formalized design review or alternate calculation or oualification testing.

GCP-203 Document Preparation, Change, and Review

5 This procedure establishes those design documents that are controlled

5 within the LRGO by providing a standardized preparation, change and review system.

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TABLE 2-3 GENERATION 4 CONSTRUCTION (G6C) PROCEDURES Continued...

GCP-204 Design Deficiency / Corrective Action

5 This procedure formalizes the reporting of design deficiencies and provides a method of poAtive feedback to assure that appropriate corrective action is taken to prevent recurrence of the deficiencies.

GCP-310 Fuel Management Control

5 This procedure establishes the methods by which the Manager, Nuclear Fuel controls the interface for fuel management between Middle South Services,

5 the operating nuclear plant and the LRGO.

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3.

DESIGN CONTROL 3.1 SCOPE 3.1.1 Design activities shall be controlled to assure that proposed plant changes to the structures, systems, equipment and components conform to applicable regulatory requirements and that design bases are cor-rectly translated into appropriate design documents. Design Control 5

activity will be in accordance with the requirements of Regulatory Guide 1.64 - Rev. 2 (11/76) as inte rpreted in Appendix A.

3.2 GENERAL 3.2.1 Generation and Construction LRCO shall be responsible for the continued

5 upgrading and modification of plant design. Design documents (drawings, specifications, procedures and instructions) originating or released for review through these departments shall be based upon the required regulatory requirements, quality standards and design bases in accord-ance with NRC licensing requirements. Design activities may include calculations, analyses, materials, selection, equipment arrangement and layouts, and specifications of test and inspection criteria that are essential to the safety-related functions of the structures, systems and components. Those design activities performed by indivi-dualt within the Generation and Construction LRGO are controlled by the use of QAP's for the design process (GCP-202

).

The plant staff 5

uses QCP 1004.01 for the control of design activities.

3.2.2 Design standards and requirements shall be at least equivalent to those employed during the construction of the station and shall be consistent with the Technical Specifications and license provisions.

3.3 DESIGN PROCESS / VERIFICATION 3.3.1 To assure that the design is adequate and that the above requirements and procedures are satisfied, each design is reviewed by Generation 5

and Construction LRGO personnel. Alternately, design verification may also be accomplished using alternate calculation methods or by the establishemnt of a suitable test program. Where a tes.t program is used to verify the adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualification testing of a prototype unit under the most adverse conditions.

3.3.2 Design reviews generated within AP&L are accomplished using the design verification section of the Ucsign Process procedure l5 (GCP-202).

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3.3.3 During the above reviews, particular attentien shall be given to the following areas:

1) Assurance that all appropriate standards are clearly delineated.

5 Where it is considered necessary to deviate from these standards, separate written approval shall be required from the Director, Generation Engineering and shall be appended to the approval

5 sheet releasing the document (s) for implementation.

2) Assurance that the qualifying information for the materials, com-ponents, equipment and processes is contained in the documents and is suitabic fcr the intended applications. This information shall include, as applicable, the physics, hydraulics, thermal, strength and accident analysis utilized; the compatibility of design for in-service inspection, maintenance and repair; and the acceptance criteria for inspections and tests. Performance history and failure data on installed components is considered when similar components are intended for installation as part of a system or structure modification.

3) Assurance that design interfaces are compatible and consistent with the overall design bases and existing systems where more than one activity has participated in t.he designs.

4) Assurance that the design document is consistent with the Safety Analysis Reports and, if required, that the need for NRC approval

]

prior to the final approval of the design document has been identi-fled.

5) Assurance that the inspection requirements of Section 10 are included and adequate.

6) Assurance that significant and recurring errors and deficiencies

5 discovered in the design as a result of the reviews are documented and disposition assigned. A feedback system of corrective action by distribution of the review comments to the originating activity shall be used to prevent repetitive errors or deficiencies in the design process.

3.3.4 Additional changes to the basic document (s) (including field changes as a result of modifications which in any way affect the technical adequacy of the design) shall be subject to the same reuew criteria as the basic documents.

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3.4 DESIGN RECORDS 3.4.1 The Plant Administration Manager shall be responsible for maintaining

5 permanent records of the design documents for the construction and testing phases. In addition, he shall be responsible for maintaining records of the upgrading or modification of these documents as de-scribed in this section. The controls for maintaining these records are established by specific procedures described in Section 17.

These records provide the historic reference necessary for the safe and reliable operation of the plant.

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4.

PROCUREMENT DOCUMENT CONTROL a-4.1 SCOPE 4.1.1 Control of the procurement activities shall provide assurance that applicable regulatory requirements, design bases, technical require-ments and quality assurance criteria are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by AP&L or by its contractors and/or subcontractors. Procurement documents are the drawings, specifications and purchase requisitions that result in a purchase order. Procurement document control activities will be in accordance with Regulatory Guide

5 1.123 rev. 1-7/77 (reference Appendix A).

4.2 GENERAL 4.2.1 Vendors shall be selected from the Qualified Vendor List (QVL). Quality Assurance personnel as designated by the Mgr. QA shall normally evaluate the QVL quarterly but at least once per year to determine the need to 5

requalify inactive suppliers or remove their names from the QVL.

4.2.2 Vendors may be placed on the QVL as approved by the MRQA, or his designee by any of the following methods:

1)

By satisfactorily meeting 10CFR50, Appendix B requirements that are applicable to the vendor by facility survey by ApSL.

(ANO-6) 5 2)

Pursuant to appropriate documented information received from others, i.e., Architect-Engineer, NSSS Supplier, other utilities, NRC, ASHE, etc., indicating a program meeting appropriate requirements of 10CFR-50, Appendix B.

3)

A review of the Supplier's current quality records supported by evidence of documented qualitative and quantitative information which can be evaluated. This includes review and evaluation of the Supplier's Quality Assurance Program, Manual, and Procedures, as appropriate.

(ANO-15) 4)

Survey of the vendor or contractor to assess his capability to document and execute controls that meet the requirements of the purchase order, including verification that his technical capa-bility, organization, facilities and inspection measures are commensurate with P.O. requirements (ANO-19). Vendors qualified by this method are limited to thosa supplying in-kind or off the shelf replacement parts that do not alter the design intent of the original component specification.

4.2.3 Purchase documents for spare or replacement parts or parts of safety-related structures systems or components, including "off the shelf" items, procured by the plant staff shall be reviewed by the Plant Quality Control Supervisor, or his designee, for adequacy of quality *5 requirements. The review determines similarity, compatability, current regulatory applicabliity and inclusion of, at a minimum, the quality assu-rance requirements and acceptance criteria of the original part, b

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As part of the review, a document control form shall be included which specifies the documents to be supplied by the vendor to verify that engineering quality, inspections, and tests have been completed.

4.2.4 The preparation, review and control of procurement documents are established in the procedures for purchase requisition preparation

5 and processing (GCP.102; QCP 1004.05).

4.2.5 The Manager, Quality Assurance shall verify the compliance with procurement procedures and shall evaluate the effectiveness of these procedures. Methods of verification and evaluation are delineated in quality assurance procedures for surveillance audits and general audits (ANO-3, ANO-6, ANO-14, ANO-17, ANO-18, ANO-19, and ANO-20).

4.2.6 hhen multiple procurement is involved, the Purchasing Department shall apply identical quality assurance requirements to each vendor.

4.2.7 APGL purchase documents shall require prime vendors to apply the applicable quality assurance requirements to each sub-tier vendor where such requirements apply to the goods or services being purchased by AP6L from the prime vendor.

4.3 REQUISITIONS 4.3.1 Plant staff initiated requisitions for Q-List material, equipment or services may be initiated by any plant employee, but shall be reviewed 6 approved by the cognizant supervisor, Plant Quality Control Super-visor or his designee and by a plant manager or his designee before 5

issue of a purchase order (QCP 1004.05). Changes, other than minor changes, to plant staff initiated purchase requisitions, purchase orders, and supporting documentation shall be reviewed by the Cogni-zant Supervisor and the QC Supervisor or their designees. A plant manager or his designee approve the change when the required reviews have been completed. Minor changes will be made as indicated in the last sentence of paragraph 4.3.2.

4.3.2 Little Rock General Office (LRGO) requisitions are initiated when a Q-List design change is involved as described in the procedure for Procurement Control (GCP-102) or by the plant staff as described in 4.3.1.

LRGO initiated requisitions are reviewed by QA personnel, approved by cognizant engineering personnel and the Manager, Nuclear Operations or his designee. Major changes to LRGO initiated requisi-tions such as changes in Q-designation, changes in quality require-ments, etc. shall be subject to the same degree of control as was utilized in preparation of the original requisition. Minor changes such as inconsequental editorial corrections, or changes to commercial terms 6 conditions can be made by the Nuclear Buyer after verbal approval from the affected originating individuals.

4.3.3 Requisitions for Q-List items shall be clearly indentified as Q-List.

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4.4 SPECIFICATIONS 4.4.1 Specifications for Q-List replacement parts shall be at least equiva-lent to the applicable portions of specifications under which the equipment was originally furnished.

In situations where a part is being replaced for inadequate service or because its operational requirements were modified, its specification must reflect the new requirements imposed.

4.2.2 Q-List specifications shall be reviewed by the Generation and

5 Construction LRGO Organization to assure that applicable codes, standards and other design bases a..e included or referenced and that appropriate and sufficient requirements for quality assurance documen-tation are incorporated therein. Applicable codes, standards and other design bases are determined trom a review of the FSAR, Q-List, material control list, drawings and other design disclosure documents which apply to the "as-built" plant. These review requirements are specified in the quality assurance procedure for Licensing / Document Control (GCP-300).

5 4.5 PURCHASE ORDERS 4.5.1 Purchase orders shall be issued by APGL Purchasing Department and shall affirm those requirements set forth in the specification.

4.5.2 Purchase orders for Q-List items shall require that vendors and their subvendors possess a Quality Assurance Program consistent with the applicable requirements of 10CFR50, Appendix B, or ANSI N45.2 which apply to the specific goods or services provided by that vendor. The Purchase Order shall include provisions for source surveillance and inspection. Source surveillance and/or inspection will be conducted when deemed necessary based on the importance of malfunction or failure of the item, ability to verify the quality of an item through receipt inspection or acceptance testing at the jobsite, degree of standarization, and vendor history.

5 The purchase originator will be responsibic for establishing the need for surveillance. APSL QA/QC review of the procurement document signifies concurrence with the decision for source surveillance and/or inspection.

4.5.3 Changes to purchase orders and reference documents for Q-List items are to be subject to review equivalent to that of the original documents.

(Reference paragraphs 4.3 1 and 4.3.2)

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5.

INSTRUCTIONS, PROCEDURES AND DRAWINGS 5.1 SCOPE 5.1.1 Instructions, procedures and drawings shall be provided as necessary for the control of those activities which affect quality. Activities controlled by procedures include: Administration, normal operations, maintenance, security, inspection, testing, health physics, chemistry, refueling, surveillance, emergency operations, quality assurance, quality control, and LRGO activities.

,5 5.1.2 Additional procedures may be required as determined by a cognizant manager or director.

5.2 GENERAL 5.2.1 Instructions, tests, calibration, specifications, procedures, main-tenance, modification and repair processes are developed, reviewed and approved according to the administrative procedure on handling of procedures (QCP 1004 13). Generation and Construction LRGO

,5 procedures are developed, reviewed, and approved in accordance with the administrative procedure for revision and control (GCP - 100).

Drawings are controlled by the administrative procedure for drawing

5 control (QCP 1004.23, and GCP - 101). Drawings and specifications related to plant modifications are reviewed according to the proce-dures for design change control (QCP 1004.01 and GCP-201) for QA concurrence of the quality designation of the design change package.

QA review of drawings is conducted by the Plant Safety Committee (PSC) for design changes authorized by Plant Staff personnel. QA review of LRGO authorized design changes, drawing revisions, etc.,

is accomplished by LRGO engineering personnel. QA review entails assuring that drawing revisions incorporate quality requirements equivalent to those originally specified. QA review of new purchase specifications or revised purchase specifications is accomplished by QA personnel. This review assures that quality requirements specified 5

are consistent with Program requirements. QA review of procedures and changes of procedures referenced in Table 2-1, 2-2, 6 2-3 is conducted by QA personnel. This review assures that the procedure change is consistent with QA Program requirements. QA review of plant operating procedures, other than those procedures described in paragraphs 5.2.6 and 10.1.4, is conducted by the PSC. This review assures that each specific procedure is consistent with commitments applicable to the procedure.

5.2.2 Instructions, procedures and drawings which prescribe activities which affect quality shall include appropriate quantitative or qualitative criteria for determining that important activities have been satisfactorily accomplished.

5.2.3 Procedures which affect quality shall include measures to document the activity being performed.

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5.2.4 To assure accomplishment of the activities in accordance with approved instructions, procedures and drawings, each supervisor shall be re-sponsible for quality compliance of personnel under his supervision.

Surveillance by the Plant Quality Control Group and periodic sur-l5 veillance by Quality Assurance personnel ensures compliance with approved instructions, procedures and drawings. Additionally, audits by the Quality Assurance Engineer s0perations) and Quality Assurance Engineer (Engineering) verify compliance with approved instructions,

5 procedures and drawings.

5.2.5 The format, content and philosophy of instructions and procedures shall comply with the guidelinee provided in ANSI N18.7-1976, " Administrative

5 Controls of Nuclear Power Plants".

5.2.6 The QC Supervisor reviews and approves all changes to the 1004.XX procedures. The QC Supervisor is responsible to assure that the QC 5

organization properly become familiar with the procedures & changes.

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5.3 TEMPORARY CHANGES 5.3.1 Temporary changes to procedures in the Master Plant Manual which do not change the intent may be made provided such changes are appoved by two members of the plant staff at least one of whom holds a senior reactor operators license on the unit affected. Additional

'5 reviews are required for specific procedures listed in paragraph 5.2.6.

5.3.2 Temporary changes to the procedures in the Master Plant Manual which involve an intent change may be made provided such changes are reviewed by the PSC, approved by the Plant Manager or his representa+

5 tive prior to implementation. Additional reviews are requi~ed for

{5 specific procedures listed in paragraphs 5.2.6 and 10.1.4.

5.4 CHANGES TO PROCEDURES 5.4.1 Changes or revisions to approved Plant instructions, procedures or drawings which affect quality are controlled by the procedure on Handling of Procedures (QCP 1004.21).

5.4.2 Changes or revisions to Quality Assurance Procedures require the same review and approval as specified by paragraph 2.4.3.

5.4.3 Changes or revisions to Generation and Construction LRGO procedures

5 are controlled by the procedure on revision and control (GCP-100).

5.5 REVIEW OF PROCEDURES, INSTRUCTIONS, AND DRAWINGS 5.5.1 Applicable procedures, instructions and drawings shall be reviewed following any unusual incident (e.g., abnormal equipment malfunction or accident) and revised, as necessary to prevent recurrence of such incidents.

5.5.2 Applicabic instructions, procedures and drawings shall be reviewed, and revised as necessary, following any mofifications to the plant.

5.5.3 Applicable instructions and procedures shall be reviewed, and revised as necessary, following major changes to the Quality Assurance Program.

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6.

DOCUMENT CONTROL 6.1 SCOPE 6.1.1 The issue, receipt, use, and storage, and changes thereto, of documents which affect quality shall be controlled. Documents which shall be controlled include drawings, specifications, instructions, and precedures.

6.1.2 Documents are controlled by the following procedures:

1) Design Change Package Control (GCP-201) 5

2) Document Change and Review (GCP-203)

3) Plant Records Management (QCP 1004.24)

4) Document Retention (QCP 1004.24)

5) Document Control (QCP 1004.22)

6) Drawing Control (QCP 1004.23 and GCP-101)

5 6.2 GENERAL 6.2.1 Documents pertaining to quality-related activities such as specifi-cations, procedures and drawings shall be used only after proper review and approval.

6.2.2 The Plant Administration Manager snail supervise the issuance of the

5 Master Plant Manual and shall assure that the approved revisions are distributed to the location where the subject activity is being performed.

6.2.3 An issue sheet or facsimile shall be employed to maintain a record of persons to whom documents have been issued.

6.2.4 Changes in documents shall be subject to the following:

1) Prior to implementation, documents affecting quality such as instructions, procedures and drawings shall be reviewed to assure that they are adequate and timely, and that appropriate quality requirements are clearly and accurately stated.

2)

Individuals and groups responsible for reviewing, approving and issuing documents and revisions thereto are identified in procedures for handling of procedures (QCP 1004.21), and document control (QCP 1004.22).

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.s 3)

Changes to documents such as operating procedures, maintenance procedures and as-built drawings shall be reviewed and approved by the same organizations which pe rform the original review and approval. If such is not possible, the review is delegated to

5 appropriate qualified responsible groups.

4)

Obsolete and superseded documents shall be destroyed (except for one file copy) or marked to prevent inadvertent use.

6.2.5 Permanent plant documents are stored at the plant site by the pla nt l5 staff under supervision of the Plant Administration Manager. Records (or copies, as appropriate) generated by Generation and Construction, Quality Assurance, or others are provided to the plant staff for storage. These records include:

1)

Procurement documents for items purchased by Generation and Construction.

5 2)

Design specifications, drawings, and design criteria originated or revised by Generation and Construction.

3)

Design Change Request packages and supporting documents.

6.3 DOCUMENT IDENTIFICATION 6.3.1 Documents shall contain a title descriptive of their purpose or applicability and shall be conspicuously labeled as to current status (Draft, Preliminary, Approved, Void, etc.)

6.3.2 An indication of current revisions to specifications, procedures and drawings shall be maintained in a document control register or within a revision record page or other appropriate means.

6.4 STORACE AND FILING REQUIRENENTS 6.4.1 Documents which affect quality shall be stored at the plant in per-manent storage facilities in a manner which allows ready and positive identification and retrievability. The storage technique shall mini-mize damage and preserve the integrity of the documents. Storage con-trols are set forth in procedures for plant records management, and document retention (QCP 1004.24; QCP 1004.25).

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.s 7.

CONTROL OF PURCHASED MATERIAL. EQUIPMENT AND SERVICES 7.1 SCOPE 7.1.1 The purchase of material, equipment and services shall be controlled to aseure that, whether purchased directly or through vendors, the material, equipment and services which affect quality conform to the procurement documents. Procurement control shall include provisions, for the evaluation and selection of vendors and examination of pro-ducts upon delivery. The depth and necessity of procurement controls 5

depend upon the uniqueness and complexity of the item / service, pro-curement frequency with the same supplier and past supplier performance for the specific items or services covered by the procurement document.

The control of purchased material, equipment, and services will be in accordance with the requirements of Regulatory Guides 1.38 Rev. 2 (5/77) and 1.123 Rev. 1 (7/77) as interpreted in Appendix A.

7.2 SOURCE EVALUATION 7.2.1 Vendors chall be selected on the basis of demonstrated capability during the design and construction phase to provide a quality product, process or service in accordance with the procurement documents for the operational phase. The verification of the validity of suppliers 5

certificate of conformance is accomplished as pa rt of the total supplier control and product acceptance program. The degree of verification required will depend ipon the type of item or service and their safety importance. The means of verification may include source witness / hold points, source audits, and document reviews, independent inspections at the time of material receipt, user tests on selected commodities, or tests after installation on selected components and systems.

7.2.2 When the vendor is not n the Qualified Vendors List (QVL), the Manager of Quality Assurance shall review and approve the vendor's qualifications as described in paragraph 4.2.2.

7.3 DOCUMENTATION OF QUALITY 7.3.1 Verifiable evidence of quality shall be furnished by vendors as prescribed in the procedure for procurement control.

(GCP-102 )

5 7.3.2 Documentary evidence that material and equipment conform to the pro-curement requirements shall be available at the site prior to installation or use of such material and equipment. As necessary, vendors are to be requested to maintain documentation. A certificate of conformance is to be maintained at the plant site to reference any documentation by the vendor. Such documentary evidence shall be retained at the site and shall be sufficient to identify the specific requirements, such as codes, standards or specifications, met by the purchased material and equipment. On a case basis the QCE may release certain equipment f or installation without proper documentation, but before the equipment is used all documents shall be received. A non-conformance report is filed in such a case.

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7.4 SOURCE INSPECTION 7.4.1 The effectiveness of quality control by vendors shall be assessed by the QA organization at intervals consistent with the importance, complexity, method of receipt, and quantity of the product or S

service. Requests for source inspection by QA personnel are made by the plant QC Supervisor or his designee or as determined by the QA Engineer (Audit) during review of purchase requisitions.

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7.4.2 Source inspection shall be documented and shall provide a record of compliance by the vendor with regard to:

1) The vendor's quality assurance program.

2) 10 CFR 50, Appendix B, or ANSI N45.2 (applicable to the product or service provided).

3) Design and quality classification, codes and standards which apply to the product or service provided.

4) The procurement document requirements.

7.5 RECEIPT INSPECTION Upon receipt of Q-List materials at the plant, a receiving inspection shall be performed and the condition of the material c1carly and completely record-ed in a receiving report as prescribed in the procedure for material receiv-ing and inspection (QCP 1004. 06). This procedure assures that:

1) The material, equipment or component is properly identified and corres-ponds with the receiving documentation, as required by 4.2.3.

2)

Inspection of the material, component or equipment and acceptance records is performed in accordance with predetermined inspection instructions, prior to installation or use.

3)

Items accepted and released are identified as to their inspection status and forwarded to a controlled storage area or released for installation.

4) Nonconforming items are held in a segregated, controlled area when practical and are clearly identified until proper disposition is made in accordance with the procedure for nonconformance and corrective action (reference paragraph 8.5.3).

5

5) Supplier non-conformances which have been accepted by APGL prior to shipment of the item shall be documented in the procurement records furnished by the supplier at the time of receipt or the item shall be considered non-conforming as required by procedure 1004.06 and 1004.13.

7. 6 STORAGE 7.6.1 Q-List materials shall be handled and stored as prescribed in the procedure for handling, storage, and shipping of Q-List materials (QCP 1004.11).

7.6.2 Q-List material shali be clearly identified as such and stored in a controlled area.

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EQUIPMENT AND SERVICES 7

8.

IDENTIFICATION AND CONTROL OF MATERIALS. PARTS AND COMPONENTS 8.1 SCOPE 8.1.1 Identification and control measure shall be established to assure that quality-related materials, parts, components and partiatly fabricated assemblies are traceable to the documentation which verifies their acceptance throughout fabrication, receipt,

5 storage, installation and use of each item.

8.1.2 The measures shall be sufficient to prevent the use of incorrect, defective or illegibly marked materials, parts and components.

8.2 IDENTIFICATION AND MARKING 3.2.1 Materials, parts and components shall be identified and. marked by suppliers in accordance with requirements set forth in applicable codes and in the procurement documents. The requirements shall assure that:

1)

Marking of shipping containers or packages is sufficient to allow proper handling of the container or package and positive id ntification of received items at the plant.

2)

Identification of parts and cot responding documents,ill accompany all partially fabricated assemblies shipped as one unt. Such documentation shall incinde, astapp10 cable, heat.nugber,.part numbers, serial numbers, mate rial certifications and weld quali-fications to provide sufficient bases for determining the accept-ability of the assembly and its component parts.

8.2.2 Markings of items or material shall be done using methods not deleterious to the integrity of the material.

8.2.3 When specified by purchasing document, individual items shall be permanently marked.

8.2.4 Group or bundle marking and temporary marking me, be authorized by the Quality Control Supervisor as conditions varrant, and provided

5 that positive identification and traceability of the items or material can be maintained.

8.2.5 All Q-List materials, parts and components are identified as required by 1004.18.

8.3 TAGGING 8.3.1 In addition to being marked, Q-List materials, parts and components received at the plant site shall be tagged with a "Q Tag".

5 8.3.2 The Q-Tag shall identify the item received, the associated permanent 5

records file and the status (e.g. clear for installation, return to vendor, hold for documentation, or hold for repair).

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8.3.3 Tagging shall be performed in accordance with the procedure for material identification (QCP 1004.06).

8.4 DOCUMENTATION 8.4.1 Documentation for parts and materials received from vendors shall be stored in the Quality Control File as described in the procedure for plant records management (QCP 1004.24).

8.4.2 The removal of Q-List items from storage and their subsequent dis-position shall be documented and controlled by the Release to Maintenance form described in the procedure for material identification (OCP 1004.18).

8.5 DEFECTIVE OR INCORRECT ITEMS 8.5.1 Defective or incorrect materials, parts and components which cannot be reworked or repaired for their intended use by acceptable methods shall be handled in accordance with Section 15 of the Program and the procedure for nonconformances and corrective action (QCP 1004.13).

8.5.2 Defective or incorrect items shall be clearly identified on the "Q" tag.

8.5.3 Defective or incorrect items shall be stored in segregated areas except for those items which due to their size, weight, configuration, etc. are impractical or impossible to store in the designated Controlled 5

Storage Area.

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9.

CONTROL OF SPECIAL PROCESSES 9.1 SCOPE 9.1.1 Special processes performed in the course of operations at the Plant are controlled by the procedures on special processes (QCP 1004.07) to assure that they are properly and safely accomp-lished.

9.2 RESPONSIBILITY 9.2.1 The General Manager shall be responsible for assuring compliance

5 with the requirements for control of special processes, and for developing adequate staff training and procedures for special processes identified in the future.

9.2.2 The Operations and Maintenance Manager, Engineering and Technical Support Manager and Quality Control Supervisor shall develop pro-5 cedures and provide qualified personnel for current special processes as delineated in the procedure for control of special processes (QCP 1004.07).

9.2.3 Quality Assurance personnel shall periodically audit special process procedures and personnel qualification to assure compliance with appitcable codes and specifications.

9.3 GENERAL 9.3.1 Special processes include, but are not necessarily limited to:

1)

Special maintenance and cleaning.

2)

Metal joining, such as welding, and brazing.

3)

Thermal cutting.

4)

Hot and cold working and bonding.

5)

Coating and plating.

6)

Nondestructive examination.

7)

Heat treating.

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9.4 QUALIFICATION 9.4.1 Personnel shall be qualified and/or certified for each special process according to applicable regulations, industrial standards and other requirments as described in the procedure for control of special processes (QCP 1004.07).

9.4.2 The Training Supervisor maintains records of personnel qualification

5 appropriate to each special process. On request, he shall provide lists of qualified personnel and their particular qualifications to the cognizant supervisor of the special process to be performed.

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10.

INSPECTION 10.1 SCOPE 10.1.1 On and offsite activities affecting quality are inspected to verify conformance with applicable procedures, design documents, codes and specifications for accomplishing the activity.

10.1.2 Inspection of quality-related activities is controlled by the process for inspection (QCP 1004.08) which specifies inspection requirements, techniques, documentation and responsibilities as described in Sections 3, 4 6 7 of the program.

10.1.3 QC personnel reporting to the QC Supervisor are responsible for quality inspection activities in the area < of special processes, plant modifications, repairs, operation of safety-related items, non-routine maintenance activities, and inservice inspection.

Inspection of receipt of Q-List materials, parts, or components is accomplished 5

as follows: A level I QC Inspector, who may report to the Production Storekeeper, performs the material reccipt inspections. A level II QC Inspector who nomally reports to the QC Supervisor then reviews the results of the material inspections, reviews the PO, QA records, and other documentation associated with the received item and authorizes the Hold for QC Clearance or Release fcr Installation.

10.1.4 Safety-related modification and non-routine maintenance procedures, and changes to those procedures which involve intent changes, are 5

reviewed prior to impicmentation by the plant QC organization. The plant QC organization is responsible during this review to determine the need for inspection, ider.tification of inspection personnel, documentary inspe.ccion results, and hold points.

10.1.5 Inspection hold points are inserted in procedures discussed in paragraph 10.1.4 and in procurement documents based upon safety significance, complexity of the item or activity, and degree of standardization of the item or activity, past performance of the vendor, 5

procurement frequency with the vendor, and the ability to verify l

quality by job site testing.

10.2 RESPONSIBILITY LO.2.1 The General Manager shall be responsible for assuring that plant personnel comply with the regulations, codes and procedures controlling

5 inspection.

10.2.2 The Quality Control Supervisor or his designated representative

5 shall perform inspections within the plant as described in paragraph 10.1.3.

Source surveillance shall be the responsibility of the Manager of Quality Assurance. The Quality Control Supervisor or his

5 designated representative is responsible for inspection records and for assuring that inspection hold points are properly documented.

10.2.3 Quality Assurance personnel shall periodically audit inspection procedures, inspection records and personnel qualifications to assure that inspection requirements are being fulfilled.

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10.3 INSPECTION PROCEDURES 10.3.1 To accomplish inspections, written procedures, instructionr, diagrams, forms, or checklists shall be provided which as a minimum contain the following:

1) Qualitative and quantitative acceptance criteria.

2)

Identification of those individuals responsible for performing the inspection operation.

3) A description of the method on inspection examination, measurement or test of material or product process necessary to be performed to assure quality.

4)

Identification of any special tools, equipment or skills required.

5) A signoff by signature, initial or a controlled stamp

5 showing evidence of completing and verifying the inspection.

6) The results of *.he inspection operation.

10.3.2 If inspection of processed material or products is impossible disadvantageous, indirect control by monitoring processing methods, equipment, and personnel shall be provided.

Both inspection and process monitoring shall be provided when con-trol is inadequate without both.

5 10.3.3 Inspection personnel shall verify that inspection equipment utilized is within calibration prior to performing any inspection operation.

If improper or out-of-calibration equipment is found, the inspector has the authority to suspend the inspection activities. The criteria for determining the accuracy require-ments for measuring and test equipment used for inspections and 5

tests will either be as a result of historical data or as rec-ommended in the manufacturer's specifications.

10.3.4 If an inspection of a quality-related activity reveals that a nonconformance has occurred, the inspector has the authority to suspend further activity until the nonconformance is rectified.

10.3.4.1 Nonconformances are reported and corrective action is implemented in accordance with Sections 15 and 16 of the Program and the procedure for nonconformance and corrective action (QCP 1004.13).

10.4 INSPECTOR QUALIFICATION 10.4.1 Personnel qualified to perform inspections are normally the on-site quality control staff. Personnel qualified to perform 5

inspections shall meet the following requirements:

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1) Be independent from the individual or group performing the activity being inspected.

2) Itave satisfmetorily completed the qualification requirements as specified in the procedure for qualification and certifica-tion of quality control personnel (QCP 1004.20).

5

3) Be currently qualified and so designated on a list of qualified inspectors approved by the Quality Control Supervisor of the Manager of Quality Assurance.

5 10.5 DOCUMENTATION 10.5.1 Records of inspections shall be maintained by the Quality Control Supervisor in accordance with the procedures governing document

5 contral, and document retention (QCP 1004.22; QCP 1004.25).

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TEST CONTROL 11.1 SCOPE 11.1.1 Necessary testing requirements to determine whether safety related

5 structures, systems and components perform satisfactorily in service shall be established in written test procedures. The test procedures shall incorporate the requirements and acceptance limits contained in the Technical Specifications, codes and regulations, and applicable design, operating, maintenance and manufacturer's documents. Testing within the scope of this section includes both periodic testing and those tests required as a result of modification, maintenance, or repair of safety-related items.

11.2 SURVEILLANCE TESTING 11.2.1 Testing of safety related structures, systems and components shall be

5 performed by a qualified personnel in accordance with approved written test procedures. The supervisor responsible for performing the test shall verify that all teit equipment is properly calibrated.

11.2.2 The test procedures shi.11 include the following (as applicable):

1)

Test procedure approval sheet.

2)

Test objective or applicability.

3)

Prerequisites for testing.

4)

Acceptance criteria.

5)

References.

6)

Special test equipment.

7)

Limits and precautions.

8)

Step-by-step instructions.

9)

System lineup check 14 sts for test and return to normal.

10)

Data sheets providing sufficient parameter checks and data gathering.

11)

Test results review and approval signature sheet.

11.2.3 In addition to regularly scheduled surveillance tests, tests shall be performed following significant plant modification or significant changes in operating procedures to confirm that the modification or changes are not detrimental to the safe and efficient operation of the plant. provisions which assure that modifications, repairs, and replacements are in accordance with the original des,ign and testing

5 requirements or acceptable alternatives include the following procedures:

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(1) QCP 1004.01 (Design Control)

(2) QCP 1004.05 (Purchase Requisition Preparation and Processing)

(3) QCP(s) 1004.12A 6 B (Operational Test Control) 5 (4) QCP 1004.17 (On-Site Contractor / Constructor / Vendor Control)

(5) AP 1005.08 (ASME Code Section XI Operational Readiness Testing) 11.2.4 All surveillance calibration, checks and inspections required by Section 4 of the Technical Specifications shall be specified on an " Operational Test Control List".

This list shall state the title, type of surveil-lance activity, frequency and cognizant individual responsible for completion of the surveillance activity.

11.2.5 To ensure that the requied tests are performed as scheduled within each time interval, a computer program has been devised to indicate when tests are required. The computer program has a master list of plant components. Associated with each component is information pertaining to the frequency of tests or maintenance activities for that component. With this information, the program generates a weekly schedule 5

with activities to be worked the upcoming week.

If an activity is due to be worked during a week, it will be on the schedule irregardless of whether it is monthly, quarterly, semi-annual, or annual in nature. The schedules are then distributed to the individual departments to be worked.

11.3 PROCEDURE APPROVAL 11.3.1 Test procedures shall be subject to the same review and approval process as outlined in Section 6 of the program.

11.4 DOCUMENTATION AND REVIEW OF TEST RESULTS 11.4.1 Test results shall be documented and reviewed to assure that the test objective has been met and that action called for by the test is taken.

11.4.2 Records of test results shall include at least the following:

1)

Identity of part of material, system, structure, or component under test.

2) Date of test.

3) Data taken.

4) Name and signature of individual performing test.

5) Test results and conclusions.

6)

Identity of portable test equipment.

7) Recommendations for corrective action or retesting resulting from the test.

8) Review and approval signatures.

5 N

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11.4.3 Testing records shall provide objective evidence that the testing was performed in compliance with approved procedures. Testing records shall be maintained in the plant files in accordance with the pro-cedures for document retention (QCP 1004.25).

11.5 PREOPERATIONAL TESTING 11.5.1 A manual describing the provisions that control the transfer of safety related equipment and records from the principal contractors to APSL during the preoperational testing phase up to fuel loading, shall be prepared and shall include the identification of those significant QA-related activities, provisions established to assure proper inspec-tion and verification of equipment; the means of tagging and identifying structure systems and components in a manner that denotes the inspection and test status; and provisions to assure the effective transfer, storage and control of records.

11.5.2 Beginning with issuance of an operating license, additional administra-tive controls governing testing activities must be implemented. The administrative controls utilized during previous testing activities must, in some cases, be modified. The ANO Plant Procedures provide for admin-istrative controls to assure the safe operation of the plant.

11.5.3 The Manager, Quality Assurance is responsible for establishing audits of the preoperational testing program (ANO-20).

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12.

CONTROL OF MEASUREMENT AND TEST EQUIPMENT 12.1 SCOPE 12.1.1 A control program shall be established to assure that tools, gages, instruments and other measuring and testing devices used in activities af fecting cuality are controlled and calibrated with sufficient sche-duled frequency to assure that accuracy is maintained within the limits specified by the inspection or test requirements. This activity is referenced in the procedure for calibration control (OCP 1004.10).

12.2 GENERAL 12.2.1 All measuring and testing devices used in conjunction with 0-List items or systems shall be properly controlled, calibrated, and adjusted at specified intervals to maintain accuracy within the necessary limits.

12.2.2 Calibration of these devices shall normally be in accordance with manufacturer's recommendations, when available, and in all instances shall be in a manner that maintains the tolerance for accuracy of the equipment.

12.2.3 Calibration procedures shall conform to recognized standards and local, State and Federal regulations.

12.2.4 The procedure shall be clearly noted on a calibration report, and the comparison standards utilized in the calibration method shall be traceable to the National Bureau of Standards, and supported by certification reports and data sheets when applicable.

12.2.5 Measuring and test equipment shall be calibrated against working standard which should have an accuracy of at least four times the required accuracy of the measuting and test equipment. However, 5

accuracies less than four times will be acceptable when warranted by statistical analysis or limited by the state-of-the-art.

12.2.6 When inspection, examination, measurement and test equipnent is found to be out of calibration through use or damage, an evaluation of the validity of previous inspection, examination, or test results and the acceptability of items previously inspected, examined, or tested shall be made and documented by written report on a case basis.

The General Manager of his designee has final approval of such eval-

5 uation, and at his discretion may require repetition of the inspection, examination, or test.

12.3 RESPONSIBILITIES 12.3.1 The Instrumentation and Controls Superintendent and Maintenance 5

Superintendent shall be responsible for compiling a list of all measuring and testing devices under their control that require perodic calibration.

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12.3.2 The control of measuring and testing devices used in the calibra-tion of 0-List equipment shall be the responsiblity of the cogni-zant supervisor, who shall ensure that the devices are used only by qualified personnel and are properly segregated from other devices.

12.3.3 Plant personnel shall be responsible for utilizing only properly identified and calibrated equipment.

12.3.4 The Quality Control Supervisor or his designee shall be responsible

5 for monitoring test equipment control and use in order to verify compliance with the program.

12.4 EQUIPMENT IDENTIFICATION 12.4.1 The equipment identification list identifying equipment requiring calibration shall contain sufficient information to uniquely ident-ify each item listed and shall include calibration intervals and tolerances for accuracy.

12.4.2 Each item listed on the equipment identification list shall be labeled in such a manner that clearly identifies the equipment and shows date of last calibration and date recalibration is due.

12.5 DOCUMENTATION 12.5.1 The following records shall be maintained in a permanent plant file:

1)

Ecuipment identification 2)

Calibration reports and test data (until recalibrated) 3)

Manufacturer's data sheets 4)

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13.

HANDLING. STORAGE. AND SHIPPING 13.1 SCOPE 13.1.1 Appropriate controls shall be applied to Q-List material, parts, components and assemblies to ensure that they are handled, stored and shipped in a manner which will prevent damege and deterioration of the item. These activities are referenced in the procedure for handling, storage and shipping of QaList materials (QCP 1004.11).

13.2 SPECIAL REQUIREMENTS 13.2.1 When special cleaning, preserving, handling, packaging or shipping of purchased material is required, such requirements shall be deline-ated in appropriate purchase order documents.

13.2.2 Additionally, vendors shall be requested to recommend special pro-

5 cedures required for handling, storage or perservation of supplied materials, parts or components for exceptionally sensitive or l5 critical iteas af ter their arrival at the station.

13.3 RECEIVING INSPECTION 13.3.1 Upon arrival of material at the station, the Production Storekeeper

5 shall be responsible for assuring that the items are inventoried, and inspected for damage, deterioration and cleanliness as described in the procedure for material receiving and inspection (QCP 1004.06).

The QC inspector is responsible for inspecting and classifying Q-List materials.

13.3.2 Results of the receiving inspection and disposition of the material shall be noted in the material received inspection report.

13.4 STORAGE AND PRESERVATION The Production Storekeeper shall be responsible for assuring that:

13.4.1 When possible and practicable materials are stored indoors, and in all instances in a manner that provides adequate protection against damage or misuse.

13.4.2 Designated items receive special protection such as controlled envi-ronment, locked storage, special coverings and segregation to prevent contamination.

13.4.3 Storage areas are monitored by the Production Storekeeper so that the security and integrity of stored items is effectively maintained.

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13.5 RADI0 ACTIVE MATERIALS 13.5.1 The Health Physics Supervisor shall be responsible for ensuring that radioactive materials are handled, stored and shipped in accordance with applicable regulatory requirements.

13.6 RECORDS 13.6.1 The Quality Control Supervisor shall be responsible for assuring that

5 the following permanent records are maintained to demonstrate proper control over the handling, storage, shipping, cleaning, and preser-vation of Q-list materials:

1) Material Received Reports

2) Quality Control Receiving Inspection Reports 2307 081

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PAGE 2 Of 2 SECIbON

14.

INSPECTION, TEST. AND OPERATING STATUS 14.1 SCOPE This section describes the measures to be employed in determining the inspection, test, and operational status of systems, structures, and components required to prevent or mitigate the consequences of postu-lated accidents that could cause undue risk to the health and safety of the publi- (Q-List items). It describes the means used to identify levels to the operator, and for documenting and correcting status substandard conditions.

5 14.2 DETERMINING OPERATIONAL STATUS 14.2.1 Q-List items shall be subjected to a controlled program of surveil-lance testing and inspections to ensure that failures or substandard performances do not remain undetected, and that the required reliabi-lity of safety systems is maintained. The procedure for operational test control (QCP 1004.12) identifies the surveillance tests and in-spections to be performed. Nonconfonnances discovered shall be docu-mented and resolved as prescribed in the procedure for nonconformances and corrective action (QCP 1004.13). Controls for assuring that tests arescheduled as required and that test results are obtained are pro-vided by a computerized program or a master test control chart. If a test or inspection is not performed within its required surveillance interval, the General Manager is informed. He will take action to

5 assure emphasis is placed on conductance during the scheduled interval.

14.2.2 The adequacy of initially installed components is ensured by manu-facturer's testing as required by the procurement contractor, and by procedures controlling material receipt and inspection, and handling (QCP 1004.06; QCP 1004.07). Startup testing and performance test following modifications verify the adequacy of newly installed items.

14.3 IDENTIFICATION OF OPERATIONAL STATUS 14.3.1 The quality conformance and safe operational status of Q-List mater-ials, systems, structures, and compraents shall be indicated to the operator through systems of tagging, as described in the procedure for Hold, Caution and QC Tagging (QCP 1004.19). The tagging process clearly identifies materials, sys tems, structures, and components containing nonconforming items, and provides administrative control of their use.

14.3.2 Overall Plant Status 14.3.2.1 The Shift Operating Supervisor shall maintain sufficient knowledge of overall plant status tests and inspections to control overall plant operations. The shift operators will maintain a ready reference of plant systems, structures and components alignments as well as a status board summary of abnormal conditials. The Shift Operating Supervisor shall ensure that personnel performing tests and inspections keep the shif t operators informed of the current status of tests and inspections.

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15.

NONCONFORMING MATERIAL. PARTS. OR COMPONENTS 15.1 SCOPE 15.1.1 Nonconforming items include materials, parts, components, processes and documents that do not conform to applicable regulations, codes, standards, specifications or contractual documents.

15.1.2 Nonconforming items shall be centro 11ed to prevent their inadvertent use or installation. Appropriate procedures shall be established to assure the prompt detection, recording, segregation, verification, technical review and disposition, including records of disposition, of nonconforming items. These activities are referenced in proce-dures for purchase requisition preparation and processing, material receipt and inspection, inspections, and nonconformance and correct-ive action (QCP's 1004.05; 1004.06; 1034.08; 1004.13).

15.2 GENERAL 15.2.1 All nonconforming materials, parts, components, processes or documents shall be identified as such and reported to the cognizant supervisor (s) for disposition and corrective action. This rule shall apply no matter where or when the discrepant item is discovered (e.g. during vendor surveillance, receiving inspection, storage surveillance installation, or operation).

15.2.2 Documents used by plant staff personnel for identifying, documenting, and reporting conditions adverse to quality including those responsible for identification and disposition / corrective action include:

15.2.2.1 Failure Disposition Report (FDR) - Procedure QCP 1004.13 The FDR is utilized when a Q-list item fails in service and is to be repaired or reworked at the plant site and returned to stock, or returned to the vendor for remanufacture. The FDR is not required if an NCR (see paragraph 15.2.2.2) has also been initiated. The cognizant group supervisor determines the disposition / corrective action. The QC Supervisor,or his designee, reviews and accepts or 5

rejects the disposition / corrective action.

15.2.2.2 Nonconformance Report (NCR) - Procedure QCP 1004.13 Each plant supervisor is responsible for identifying nonconformances whether related to product, process or documentation. TL cognizant supervisor confers with interfacing groups to determine an assigned cause and a recommended disposition. The QC Supervisor reviews the disposition and recommends approval / disapproval by the Genet *1 Manager. The General Manager then reviews and approves the NGR.

Disposition involving use-as-is or repair shall also be reviewed by the Director, Generation Operations, or Manager, Nuclear Operations.

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5 TITLE: NONCONFORMING MATERIAL, PARTS SECTION OR COMiONENTS PAGE 1 of 2 15 2307 083

15.2.2.3 Trouble Reporta(TR's) - Procedures QCP 1004.02 and 1004.14 Trouble Reports are initiated by any plant in dividual. The group supervisor then reviews the trouble report and takes appropriate measures to institute corrective action. The QC Supervisor is responsible to assure that the trouble report has correctly been designated (Q or Non-Q). The Group Supervisor or his representative is responsible for initiating a Job Order for action on Q-list items documented by a trouble report. The job order describes the work / action to be performed to rectify the situation discussed by the trouble report. The QC Supervisor or his designee, is res-ponsible for reviewing all Jo'o Orders issued.

5 15.2.2.4 Receiving Inspection Report (RIR) - Procedures 1004.06 and 1004.05 The RIR is utilized to denote conditions adverse to quality discovered during the receiving process. A Level II Quality Control Inspector authorizes the hold for QC clearance or release for installation based upon retults of the receiving inspection and initiates action I

to rectify nonconformances discovered during the receipt process.

l 15.2.3 The specifications for quality assurance in each procurement document or contract require the vendor or contractor to identify all material or parts that do not conform tothe procurement requirements. All such vendor nonconformances shall be reported tc >P&L as required by the applicable purchase order or contract.

15.2.4 The acceptability of rework or repair of caterials, parts, components, systems and structures, or of remanufactured items shall be verified by reinspecting the item as originally inspected or by a method which is at least equal to the original inspection method. The rework and repair inspection records shall be documented and shall become part of the quality assurance records for the item.

15.3 TAGGING AND STORAGE 15.3.1 Nonconforming materials, parts and components shall be tagged with a "Q" Tag, or otherwise identified, to prevent inadvertent use and segregated storage sh711 be provided except those items which due to their size, weight, configuration, etc. are impractical or 5

impossible to store in the designated controlled storage area.

Use of the "Q" tag is described in the procedure for material receiving and inspection (QCP 1004.06).

15.4 DOCUMENTATION 15.4.1 Reports of nonconforman es and documentary evidence of their proper resolution shall be maintained in the Quality Control files. The Quality Control Supervioor shall issue a monthly report to the 5

General Manager listir.g all open nonconformance reports.

DATE QUALITY ASSURANCE MANUAL REV. 5 TITLE: NONCONFORMING MATERIAL, PARTS I

OR COMPONENTS PAGE 2 of 2 SECgoN 2307 084

16.

CORRECTIVE ACTION 16.1 SCOPE 16.1.1 A corrective action system shall be established to assure that condi-tions adverse to quality are promptly identified and corrected. The corrective action system shall provide for determination that the specified corrective measures have been implemented and an assessment of the effectiveness of the corrective measures.

16.2 GENERAL 16.2.1 When deviations, deficiencies, malfunctions or other abnormal occurences or conditions are encountered, they shall be reported to responsible authorities for review and disposition in accordance with Section 15 of the Program.

16.2.2 Cognizant supervisors shall review discrepancies discovered during the course of station operations, determine their cause, and take necessary corrective action to prevent their recurrence.

16.2.3 The cognizant plant cupervisor shall propose corrective action to the General Manager. The General Ebnager reviews the nonconformance and

5 approves corrective action. Corrective action shall be prompt and shall prevent recurrence of the nonconformance.

If the condition is of "significant consequence", the General Manager shall request that

5 the Director, Generation Engineering, evaluate the nonconformance for final disposition.

16.2.4 When vendors furnish products or services that do not conform to the requirements of the applicable purchase contract, and in the opinion of the QC Supervisor, the vendor warrants consideration for reappraisal, the QC Supervisor shall submit a vendor reappraisal request to the Manager, Quality Assurance, for determination of action to be taken.

5 Results of the reappraisal, together with a request for specific corrective actions, shall be transmitted to the supplier.

If the ven-dor does not improve his quality assurance system and products as requested, the Manager, quality Assurance, may remove the vendor from the Qualified Vendor List (QVL).

16.3 SIGNIFICANT NONCONFORMANCES 16.3.1 The following actions shall be taken for reportable occurrences:

1) The NRC shall be notified and/or a report submitted pursuant to Technical Specification requirements.

2) Each reportable occurrence requiring 24-hour notification to the NRC shall be reviewed by the Plant Safety Committee and submitted to the Safety Review Committee, and the Manager, 5

Licensing, by the General Manager.

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QUALITY ASSURANCE MANUAL REV.

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TITLE: CORRECTIVE ACTION btLiloN PAGE 1 of 2 16 2307 085

16.3.1.1 Nonconformances of "significant consequence" include those noted below:

1)

Conditions that have directly affected the safety of the Plant or personnel.

2)

Conditions that have caused tha uncontrolled release of radio-active contaminants (liquid, solid, gaseous or air particulate).

3)

Conditions where a number of nonconformances indicate a trend which could lead to unsafe plant operations.

4)

Any condition the General Manager considers to be of major con-

5 sequence.

Conditions adverse to quality other than violations of Technical Specifications shall be documented as required by the precedu re for nonconformance and corrective action (QCP 1004.13).

16.3.2 Verification by surveillance or audit of the effective implementation of corrective action shall be documented by Quality Assurance personnel.

Yerfication is accomplistied hr periodic conductance of QA audits AN044, ;g AN047, and AN048, 2307 086 QUALITY ASSURANCE MANUAL REV.

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TITLE: CORRECTIVE ACTION I

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17.

QUALITY ASSURANCE RECORDS 17.1 SCOPE 17.1.1 Quality-related documentation covering design, construction, pro-curement, fabrication, inspection, maintenance, nonconformance and corrective action, test and audit activities shall be filed and safely stored to provide a written evidentiary record of quality-related activities. Records control activities will be in accordance 5

with the regulatory position of Regulatory Guide 1.88 Rev. 2 (10/76) as interpreted in Appendix A.

17.1.2 Documents made part of quality assurance records shall include oper-ating icgs, results of reviews, inspections, tests, audits, materials analyses, qualifications of personnel, procedures, drawings, specifi-cations, correspondence and related records pertinent to quality as defined in the procedure for records management.

17.2 RESPONSIBILITY 17.2.1 The Plant Administration Manager shall be responsible for the estab-

5 lishment, implementation and maintenance of the records management program to be used throughout the operational life of the plant.

17.2.2 The Plant Administration Manager, under the technical guidance and l5 review of the Quality Control Supervisor, shall be responsible for ensuring that documentation retention requirements comply with applicable codes and regulations.

17.2.3 Quality Assurance personnel shall periodically audit quality assurance records and records filing and storage procedures to assure that the records management program is being properly implemented.

17.3 DOCUMENTATION RETENTION 17.3.1 Lifetime Quality Assurance Records 17.3.1.1 Lifetime records are defined as those which meet one or more of the following criteria (QCP 1004.25).

1)

Those which would be of significant value in demonstrating capability for safe operation.

2)

Those which would be of significant value in maintaining, reworking, repairing, replacing, or modifying the item.

3)

Those which would be of significant value in determining the cause of an accident or malfunction of an item.

4)

Those which provide required baseline data for in-service inspection.

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17.3.1.2 Lifetime quality assurance records shall be maintained for the life of the particular item while it is installed in the plant or stored for future use, as prescribed in the procedure for document retent-ion and disposition (QCP 1004.25).

17.3.2 Non-permanent Quality Assurance Records 17.3.2.1 Non-permanent records are defined as those which meet all of the following criteria:

1)

Those of no significant value in demonstrating capability for safe operation.

2)

Those of no significant value in maintaining reworking, repair-ing, replacing, or modifying the item.

3)

Those of no significant value in determining the cause of an accident or malfunction of an item.

4)

Those which do not provide baseline data for in-service inspection.

17.3.2.2 Non-permanent records shall provide evidence that an activity was performed in accordance with applicable requirements, and shall be retained for specified pe riods as directed by the procedure for document retention and disposition (QCP 1004.25).

17.3.3 Categories of records to be maintained and their appropriate retention periods are described in the procedure for document retention and disposition (QCP 1004.25).

17.3.4 The Quality Control Supervisor shall be responsible for receiving,

5 inspecting and authenticating such documents as directed by the procedure for turnover of quality assuracce documents for con-struction to AP&L (QCP 1004.04).

17.3.5 When approved for receipt by the Quality Control Supervisor or his 5

designee, such records shall be transmitted to the Plant Administ-ration Manager for aling and storage.

17.4 GENERATION AND CONSTRUCTION

5 17.4.1 Generation and Construction personnel, other than Plant Staff, that

5 perform work on the plant in the areas of design, procurement, main-tenance, modification, testing, Quality Assurance and special nuclear materials shall document such work and forward the records to the Plant Administration Manager.

5 2307 088 QUALITY ASSURANCE MASUAL REV. 5 r

7 TITLE: QUALITY ASSURANCE RECORDS SECTION PAGE Of 2

4 17

17.5 STORAGE 17.5.1 Permanent records shall be stored in the records vault and shall be:

1) Adequately protected from earthquake, flood and similar hazardous natural phenomena.

2) Made safe and secure from theft, vandalism and unauthorized use.

3) Adequately protected against environmental deterioration.

4) Adequately protected against fire.

17.5.1.1 The following features or suitable alternatives shall be incorporated in the design of the storage facility:

1) Reinforced concrete, concrete block, masonry, or equal construc-tion.

2) Concrete floor and roof with sufficient slope for drainage; if a floor drain is provided, a non-return check valve (or equal) shall be included.

3) Fire retardant door (two-hoar Underwriters' rating minimum).

4) Sealant applied over walls as a moisture or condensation barrier.

5) Surface sealant on floor providing a hard-wear surface to minimize concrete dusting.

6) Foundation ealant and provision for drainage.

7) Forced-air circulation with filter system.

8) Dry chemical or gas fire protection system.

9) No pipe other than those providing fire protection to the storage facility is to be located within the facility.

17.5.1.2 For storage of film and other special processed records, humidity and temperature controls shall be provided to maintain an environ-ment as recommended by the manufacturer.

17.5.1.3 A list shall be prepared designating those personnel who shall have access to the files.

17.5.2 Plant storage systems shall provide for the accurate retrieval of information without undue delay and shall be sufficient to control

4 and account for records removed from the storage facility.

DATE REV. 4 QUALITY ASSURANCE MANUAL 9/8/77 e

TITLE: QUALITY ASSURANCE RECORDS SECTION PAGE 3 of 4 37 2307 089

17.6 RECORDS INDEXING AND RECEIPT CONTROL 17.6.1 Indexing methods and systems for quality-related records are deline-ated in the procedure for plant records management (QCP 1004.24).

17.6.2 Records submitted for filing in either lifetime or temporary files shall be subject to the following requirements for receipt control:

1)

Establishment of a records check list designating the required quality-related records.

2)

Establishment of a system designating criteria for document inspection to assure that records are accurately completed, legible, and received in good condition.

3)

A file system to indicate which quality-related documents have been received.

17.6.2.1 Implementation and enforcement of receipt control requirements shall be the responsibility of the Plant Administration Manager.

5 17.7 FINAL DISPOSITION 17.7.1 Final disposition of quality-related records is controlled by the procedure for document retention and disposition (QCP 1004.25) which requires that the Plant Administration Manager periodically

5 purge the non-permanent files of records retained past their authorized retention date.

2307 090 DATE QUALITY ASSURANCE MANUAL dEV.

5 TITLE: QUALITY ASSURANCE RECORDS PAGE 4 Of 4

18.

AUDITS 18.1 SCOPE 18.1.1 The scope and applicability of the audit program includes safety related structures systems, components, and activities associated with meeting 5

QA program requirements. Audits shall be performed to determine the compliance with, and effectiveness of, applicable quality assurance programs. The audits shall be performed on a planned and periodic basis in accordance with the audit schedule. Supplementary audits shall be performed as required. The Quality Assurance section per-forms audits of these activities except for those activitied ident-ified in section 6.5.2 of the Technica1 Specifications which are 5

performed by the Safety Review Committee, reference paragraph 1.6.1.7.

18."

GENERAL 18.2.1 Reviews and audits of records, station operation, design activities, procurement, construction, maintenance, modification, examination for conformance to the eighteen criteria of 10 CFR 50, Appendix B, and other quality-related activities shall be performed by the Quality Assurance Organization to assess the adequacy of the Quality Assurance Program and to verify compliance with established quality program requirements. These activities are performed using the Quality Assurance Procedures for audits (ANO-14, ANO-17, ANO-18, ANO-20).

18.2.2 Audit responsibilities of QA personnel for onsite operating activities include periodic audits of implementation of each of the quality 5

program procedures listed in Table 2-2, 18.2.3 Results of these reviews and audits shall be recorded, reported, and distributed to responsible management as outlined in the

. Subsection 18.5.

5 18.2.4 QA personnel shall perform scheduled audits of vendors and service

5 contractors as required to verify and evaluate their quality assurance programs, procedures, and activities, and to assure supplier compliance 5

with procurement requirements. QA personnel also verifies that vendors and contracters review and audit the quality assurance programs of their suppliers. This activity is referenced in the procedures for vendor audits (ANO-3, ANO-6, ANO-19).

18.2.5 The Manager, Quality Assurance approves audit schedules and audit procedures of on-site QA personnel and LRGO-QA personnel. 'A copy of each audit conducted by AP&L QA personnel is also distributed to 5

the Manager, Quality Assurance for review.

18.3 IN-PIANI REVIEW AND SURVEILIANCE 18.3.1 In addition to Quality Assurance audits, an in-plant program for review and surveillance of quality-related activities shall be conducted by the Quality Control Staff.

5 QUALITY ASSURANCE MANUAL REV.

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3 18 2307 091

18.3.2 The program shall include:

1)

Document and record review.

2)

Surveillance and evaluation of compliance with established procedures, instructions, methods, and other requirements.

3)

Investigation of nonconformance and other unusual events.

4)

Verification of required corrective action implementation.

18.3.3 The Quality Control Supervisor shall submit reports to the General

'b nage r. If the General Manager feels further action is required 5

he may refer the deficiency to the Manager, Nuclear Operations.

18.4 AUDIT PERSONNEL 18.4.1 The Quality Assurance Section, including the Quality Assurance Engineer (Operations), shall be cssigned auditing responsibilities based on experience or training which establish that their qualifi-cations are commensurate with the complexity or special nature of the activities to be audited. When audit assignments are specified, considerations are given to special abilities, specialized technical training, prior pertinent expertise, personal characteristics, education and physical capability.

18.4.2 Audit personnei are provided appropriate training to assure their compentence for performing the required audits. Proficiency of audit personnel is maintained by one or more of the following methods:

1)

Regular, active participation in the audit process.

2)

Review and study of codes, standards, procedures, and instructions.

3)

Participation in training or orientation programs.

18.5 DOCUMENTATION 18.5.1

, Audit Reports 18.5.1.1 Upon completion of any audit, a signed written report shall be prepared which includes at least the following items:

1)

Description of audit scope and date.

2)

Identification of the auditor (s).

3)

A summary of audit results.

4)

Details of nonconformances or programmatic deficiencies.

5)

Recommendations for correcting nonconformances or improving the Quality Assurance Program as appropriate.

i DATE t

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5 TITLE: AUDITS PAGE 2 of 3 SEgfl0N 2307 092

18.5.1.2 The findings of internal AP&L audits conducted by Quality Assurance personnel shall be reported to the Manager, Quality Assurance, Manager

& Director of the area audited. Review of the audit report and findings by the Manager QA is accomplished to assure that sufficient audit detail & depth is being accomplished, and that findings are satisfactorily identified and resolved. Review of the audit report and findings by the Manager and Director of the audited area assures their awareness of the findings. The specific person to whom audit finding (s) is (are) address-ed is responsible for meaningful corrective action, however the above mentioned positions will be copied on internal AP&L audits conducted by QA personnel if they are not the specific addressee. In addition to the above, the Vice President, Generation and construction 5

(VPG6C) will be copied on all ANO-14 audits. Review of these audits by VPG6C assures upper management awareness of findings resulting from examination of the APSL Quality Program. The VPG60 initiates additional corrective action a3 he so determines based on review of the ANO-14 audits and findings. The above reviews are not required to be documented, however, audit distribution shall be listed such that the above personnel are assured of receiving the required audit copies. When audits are conducted within organizations other than AP&L, written responses are required to describe measures taken to correct deficiencies and prevent recurrence. For audits conducted within AP&L, written responses may be required depending upon the nature of findings. When a written response is requested, the audited organization is responsible for providing the written response in a timely manner. Appropriate follow-up including re-audits is made to determine that non:onformances are effectively corrected and that the corrective action precludes repetitive occurrences. Follow-up action for each finding is required.

18.5.2 Records 18.5.2.1 The following records shall be maintained to represent the status of the plant's activities in complying with all aspects of the Quality Assurance Program.

1)

Audit reports.

2)

Reports from affected organizations indicating completion and effectiveness of action taken to correct deficiencies.

3)

Reports of re-audit activities.

18.6 Audit Activities Audit activities described in paragraph 18.2 will be in accordance with the requirements of ANSI N45.2.12 draft 4 rev. 2 (1/1/76) as interpreted in Appendix A.

f DAIE QUALITY ASSURANCE MANUAL REV.

5 f

TITLE: AUDITS PACE 3 of 3 18 2307 093

APPENDIX A Rev. S n

Regulatory Guide / ANSI Std.

Requirement Interpretation / Alternate Exception Reference General Certain Regulatory Guides The AP6L commitment refers to the Regulatory Guides invoke or imply Regulatory and ANSI Standards, specifically identified in this Guides and standards in TOPICAL. Additional Regulatory Guides, ANSI Standards, addition to the standard Guides and similar docunents implied or referenced in each primarily endorses.

those specifically identified in this TOPICAL are not part of this commitment.

Certain ANSI Standards invoke or imply additional standards.

General Certain ANSI Standards and/

Our commitment to those standards applies only to those or Regulatory Guides extend systems, structures, and components whose satisfactory the scope of applicability performance is required to prevent postulated accidents to include systems, struc-that could cause undue risk to the health and safety of tures, and components whose the public; or to mitigate the consequences of such satisfactory performance is accidents. Reliable operation of the plant may depend required for a plant to upon other systems, structures and components which are operate reliably, or not covered by this commitment.

"high-value articles".

General Certain Regulatory Guides 6 Our commitments apply to the requirements.

ANSI Standard; contain both requirements and guidance.

The majority of ANSI Standards to which APGL has committed are concerned with the design and/or construction phases of nuclear power plants. Consequently, AP6L has adapted these General NRC Regulatory Guides and standards to its operations phase, where practicable, and ANSI Standards do not has developed provisions for certain condtions not addressed provide for deviation from in the standards.

rs) any requirement (s) when L/4 emergency or other urgent In the event of an emergency condition which, if not promptly C:3 conditions make deviation corrected could likely affect the health and safety of the

d necessary public, the Director, Generations Operations or his desig-nated alternate (s) may authorize emergency repairs and C

deviations from written procedures. The nature of the PAGE l OF 29

0 APPENDIX A Rev. 5 Regulatory Guide / ANSI Std.

Interpretation / Alternate Reference Requirement Exception emergency, its cause and the corrective action taken are documented.

In the event of an emergency not covered by an approved procedure, operations personnel shall take actions so as to minimize personnel injury a'd damage to the facility and to noted health and safety.

General Certain ANSI Standards The majority of ANSI Standards to which APGL has contain requirements committed are concerned with the design and/or con-which, under certain struction phases of nuclear power plant. Consequently, conditions, may con-APGL has adapted these standards to its operations phase, flict with limiting where practicable, and has developed provisions for personnel radiation certain conditions not addressed in the standards.

exposure.

h' hen conformance with particular standards require-ments; e.g., cleaning of fluid systems, housekeeping, would conflict with limiting personnel radiation exposure, the degree of conformance to the standards is determined by appropriate levels of management.

General Various standards Except in ANSI N45.2.5, the frequencies of required require inspections, inspections, examinations and tests are not specified examinations, and in the standards. Accordingly, the frequency of in-tests, but do not spections, examinations and tests required by the PN) specify the fre-standards--other than ANSI N45.2.5--is identified on led quencies of these a job-by-job bacis. The amount of inspections, examina-C:)

activities.

'd tions and tests identified is based upon safety signi-ficance complexity of the item or activity and degree

_)

of standardization of the item or activity.

W L.n PAGE 2 0F [L9

.~

APPENDIX A Rev. 5 Regulatory Guide / ANSI Std.

Referenc e Requirement s Interpretation / Alternate / Exception ANSI N.18.7 (a) " Maintenance or modifica-Requirements (a), (b), and (c), as a whole, require First Sentence tion...shall be performed a degree of quality for replacement items consis-of 5.2.7 in a manner to ensure tent with their function. Our program allows this quality at least equiva-degree of quality to be more or less stringent than lent to that specified in the original, as determined through an equivalent original design bases and review process by Engineering and QA/QC prior to use.

requirements, materials specifications, and in-spection requirements..."

(b) "A maintenance program shall be developed to maintain safety-related structures, systems and components at the quality required for them to perform their intended functions."

(c) " Purchased to specifi-cations and codes IN) equivalent to those specified l>4 for the original equipment, CZ) or those specified by a

'd properly reviewed and approved revision."

C3 ANSI N18.7 C7%

Secti'n 5.2.14 General. Requirements Paragraph 5.2.14 applies to programmatic as well as for nonconforming items to specific provisions of ANSIN 18.7 and its associated references. Consistent with paragraph 5.2.14, our quality assurance program will contain provisions for controlled, documented waivers to its requirements.

PAGE 3 OF JU)

.~

APPENDIX A Rev. 5 Regulatory Guide / ANSI Std.

Reference Requirements Interpretation / Alternate /Exeption ANSI N18.7 Requires certain Per 5.2.13 procurement document contents for replacement Section 5.2.13.1 provisions in items will be based primarily on original procurement procurement document contents. The provisions of 5.2.13.1 will be documents.

included if required by original procurement document or warranted by performance of the item. When require-nents of ANSI standards are included in procurement docu-ments, the requirements may not be identified as excerpts from ANSI standards. Procurement documents are developed and reviewed as described in Section 4 of this 'IT)PICAL.

ANSI N18.7 Section

"... drawings, specifi-Drawings may be identified by 5.2.13.1 (2) cation and industrial drawing number, revision codes and standards...

number, and title.

shall be identified by titles and dates of issue...."

ANSI N18.7 Section Where changes are made Consistent with the requirements 5.2.13.1 to procurements, they of ANSI N45.2.11, paragraph 1st Para.

shall be subject to 7.2, minor changes to (procurement) the same degree of documents, such as, inconsequential control as was used editorial corrections, or changes in the preparation of to commercial terms and conditions the original documents.

may not require that the revised (procurement) document receive N

the same review and approval as the original documents.

~

CD N

PAGE 4 0F 29

APPENDIX A Rev. 5 Regulatory Guide / ANSI Std.

Reference ANSI N18.7 Section S.2.17 Deviations, their cause, Consistent with the documentaiton requirements Last Paragraph, and any corrective of Criterion XVI, Appendix "B" to 10 CFR 50, next to last sentence action completed or for corrective action, significant deviations /

planned shall be documented conditions their cause and any corrective action completed or planned are documented.

ANSI N18.7 Section 6 "When the preceding Our commitment to ANSI Standards Ref-n ences American National does not extend beyond the standards Standards referred to (date, revision, etc.) identified in this document are in this TOPICAL.

superseded by a revision approved by the American National Standards Institute, Inc., the revision shall apply."

ANSI N18.7 Section 4.5 Review of Reports Consistent with requirements of ANSI N45.2.12, reports of audits conducted by QA personnel shall be distributed to responsible' management of both the audited and auditing organizations for review. Violations of applicable statutes, codes, regulations, orders, Technical Speci-fications, license requirements or of internal procedures or instructions discovered during audit conductance are reviewed by the independent is) review body.

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Regulatory Guide JC.SI Std.

Requirenent I nt e rpre t at ion / Alt ernat e Re fe re::ee xception Regulatory GutJe 1.37 Section 1.4 Any undesirable foreign material such ANSI N45.2.1 Definition of Contamination as grit, metal particles, oil, grease, loosely adhering slag or scale, film and fiber on the surface of. an.ds or, gases.

item in the atmosphere or in process liqui ANSI N45.2.1 Section 3.2 Consistent with ANSI N45.2.1 Draft 3 Fresh water criteria for Rev 6 (1/78), the turbidity require-chlorides, and Jackson ment on fresh water is deleted and the Turbidity Units chloride requirement is revised to read "less than 250 ppm."

The turbidity requirement for deminer-alized water is deleted.

ANSI N45.2.1 Section 3.1 Consistent with ANSI N45.2.1 Draft 3 Cleanliness Classifications Rev. 6 (1/78) allowable particle size Particle Size will be as follows:

a) Section 3.1.2.5 - There shall be no particles larger than 1/32 inch by 1/16 inch long (.8 mm X 1.6 mm).

b) Section 3.1.3 - There shall be no particle larger than 1/32 inch by 1/16 inch iong (.8 mm X 1.6 mm),

c) Section 3.1.4.4 - There shall be no particle larger than 1/16 inch by 1/8 inch long (1.6 mm X 3.2 mm).

ANSI N45.2.1 Section 5 AP6L will also allow the use of wood, metal caps, rubber and duct tape to close openings and pipe end when work is not in progress. These alternative methods are considered to meet the intent of the IN3 Standard, which is to keep the internal

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APPENDIX A Rev. 5 Regulatory Guide / ANSI Std.

Reference Requirement Interpretation / Alternate / Exception ANSI N45.2.2

..."The 'Special Inspec-The "Special Inspection" procedure shall be Paragraph 5.2.3 tion' procedure, complete readily available to inspection personnel with documentation instruc-and may be attached to the item or container.

tions shall be attached to the item or container..."

ANSI N45.2.2 "A statement documenting A statement documenting the authority and Paragraph 5.3.3 the authority and techni-justification for the conditional release is cal justification for the prepared. Justification may not always be of a conditional release...

technical nature.

shall be prepared..."

ANSI N45.2.2 The use or storage People working in storage areas have a right of Subsection 6.2.4 of food, drinks, and access to water dispensers per OSHA requirements.

salt tablet dispensers Additionally, due to location and layout of the in any storage area is building, personnel may temporarily store lunches prohibited.

in the workplace. This area is policed for sanitation.

ANSI N45.2.2

" Container markings shall Containers are adequately marked for storage, iden-Appendix (A-3) appear on a minimum of two tification, and retrieval. Multiple marking re-A.3.9 (1) sides of the container, quirements are imposed, where necessary.

Second Group preferably on one side N

and one end."

u CD N

ANSI N45.2.2

" Container markings Container markings are of a size which permits Appendix (A-3) shall be...no less than easy recognition.

A.3.9 (4) 3/4" high container g

Second Group permitting."

g PAGE 9 0F 2.9

APPENDIX A Rev. 5 Regulatory Guide / ANSI Std.

Reference Requirement I n t e rp re t a t i on/A l t e rna t e/ Exc ept i on ANSI N45.2.2

" Container marking The information required in container marking Appendix (A-3) shall include the is evaluated on a case-by-case basis. Marking A.3.9 following informa-is adequate in each case.

tion:.. "

ANSI N45.2.2 "Non-metallic plugs Non-metal plugs and caps are of a suitably Appendix (A-3) and caps shall be visible color.

Section A 3.5.1 (1) brightly colored."

ANSI N45.2.2 Plugs or caps shall In c ses where plugs or caps do not snugly fit, Appendix (A-3) be secured with additional securing devices or measures which will Section A 3.5.1 (5) tape or other means not be detrimental to the item will be used.

as necessary to prevent accidental removal.

ANSI N45.2.2 Marking of items not The last paragraph of Section A.3.9 could be Appendix (A-3) within a container.

interpreted as prohibiting any direct marking Section A3.9 on bare austenitic stainless steel and nickel alloy metal surfaces.

In lieu thereof, para-graphs A.3.9 (1) anl (2) will be used to con-trol marking on the surface of austenitic stainless steels and nickel base alloys subject to the following limitations: " Marking materials containing sulfur, lead, zinc, mercury, copper and other low melting alloys as a basic chemical constituent shall not be brought in contact, or shall not be used on surfaces of corrosion resis-Ps) tant alloys. Low sulfur, low fluorine and/or L/4 Icw chlorine compounds may be used on austenitic C:3 stainless steels". The maximum limits for the

'd above mentioned marking materials will be as follows:

~ a) Total inorganic and organic halogen (,4 content shall not exceed one (1) percent. b) The sulfur content shall not exceed one (1) percent. PAGE /O OF 29

APPENDIX A Rev. 5 Regulatory Guide / ANSI Std. Reference Requirement Interpretation / Alternate / Exception ANSI N45.2.2 Inert Gas Blankets There may be cases involving large or complex shaped for which an inert or dry air purge is provided, rather than static has blanket in order to provide adequate protection due to difficulty of providing a leak proof barrier. In their cases, a positive pressure purge flow may be utilized as an alternate to a leak proof barrier. ANSI N45.2.2 Limits halogen and Engineering may allow the use of tapes con-Appendix A,A.3.5.2, sulphur content of taining greater amounts of halogens after (1), (a)

tape, appropriate evaluation, however, the quantities shall not be such that harmful concentrations could be leached or released by breakdown of the compounds under expected environmental conditions Nu CD N

4 PAGE // OF 29

APPENDIX A Rev. 5 Regulatory Guide /ANS Std. Requirement Interpretation / Alternate Reference Exception Regulatory Guide L39 General Alternative equivalent zone designations and ANSI N 45.2. 3 requirements may be utilized to cover those situations not included in the subject Standard; for example, situations in which shoe covers and/or coveralls are required but material accountability is not. In addition, zones might be combined into the next more restrictive cate-gory in order to reduce total number of zones. ANSI N45.2.3 Identifies various When this standard is applied, its housekeeping re-requirements are implemented in those quirements, includ-areas affected by work activities as-ing cleanliness, fire sociated with modifications, operations, prevention, and fire or maintenance as determined necessary protection which must by Plant Staff. be accomplished during the progress of con-struction. Nu O N O LT1 PAGE /2 0F 29

APPENDIX A Rev. 5 Regulatory Guide / ANSI Std. Reference Requir ement Interpretation / Alternate / Exception Regulatory Guide 1.30 Pre Construction This section required verification that items ANSI N 45.2.4 Verficatior. are in satisfactory condition for installation and have not suffered since initial receipt inspection. I?pon receipt, items are inspected and stored in an environment which will not adversely affect the item. Documented routine inspections and periodic audits of the storage areas assure that stored items are maintained in satisfactory conditions. Documentation of pre-construction verfication in addition to documentation of initial receipt inspection, periodic storage inspections, and audits of storage is not required. ANSI N 45.2.4 Identifies various tests During the operational phase, these tests will to be performed. be performed "as appropriate" as determined by Engineering or Generation Operations based upon the significance of change or modification. ANSI N 45.2.4 "Mechnical tests shall For the plant operational phase " system Subsection 5.2.2 be performed to ascertain pressure ratings" is interpreted to mean Mechanical Tests that... components or system operating pressure. For the Reactor systems can withstand Coolant System, Facility Technical Specifications system pressure ratings." identify testing requirements. N (ja ANSI N 45.2.4 " Items requiring cali-Items requiring calibration are tagged indicating C:3 Subsection 6.2.1 bration shall be tagged... date of calibration. Identity of person that %J indicating date of cali-performed the calibration shall be indicated bration and identity of on the tag or traceable through records. person..." CD Os PAGE /25 0F 515)

APPENDIX A Rev. 5 Regulatory Guide / ANSI Std. Requirement Interpretation / Alternate Re ference Exception ANSI N 45.2.4 "These tests shall be For the 1. ant operation,-hase, this re-Subsection 6.2.2 made to verify that quirement is interpreted as not requiring Systems Tests all parts of a system that an entire system be re-tested after properly coordinate completion of modification of only a por-with each other." tion of that system. The testing require-ments of the Facility Technical Specifi-cations are met for inoperable equipment. Nu CD N N PAGE /4 0F 29

V V APPENDIX A. REV. 5 Regulatory Guide 1.94, Revision 1, April, 1976 (ANSI N45.2.5 - 1974 Installation, Inspection, and Testing of Structural Con-crete and Structural Steel During the Construction Phase of Nuclear Power Plants). The requirements of the reference Standard will be applied to the quality program for construction of safety related items as interpreted in the Regulatory position as modified and interpreted below. 1) Section 1.4 defines in-process tests and states: "... samples of these tests must be taken from the lot or batch of materials supplied to the site for use." This requirement for reinforcing steel will be inter-preted to permit taking the rebar test specimen at the fabrication shop, prior to start of fabrication of the rebar from the beat or fraction thereof represented by the test speciren. For these tests performed at the fab-rication shop, certification shall be available to pro-vide objective evidence that the test specimens represent the material supplied for use at the site. 2) Section 4.4, Preplacement Preparations, item 4, states. " Inspection of formwork...to verify... condition of form material to produce the specified concrete finish." Section 4.6, Finishing and Repair, states " Inspection shall be performed to verify that specified finishes... are obtained." Inspections of formwork and finishing and repairing shall be accomplished as follows: Inspection instructions vill provide for inspections prior to concrete placement including inspection of forms to verify that location and configuration are within the speci-fled tolerances and as shown on the design drawings. Inspec-tions after form removal include inspection for imperfections that expose rebar or damaged or honeycombed areas. If such imperfections in the finished concrete exist, inspections of performed and documented, in-concrete repair operations are cluding removal of unsouno concrete, surface preparation, con-crete replacement and curing. After the completion of repairs and concrete curing a final inspection is performed. The ins-pection of " finishes", whether provided by a wood float, mag-nesium float or other finishing tool, is not included within the inspection program, since the finish of the concrete has negligible effect on the structural integrity of the concrete. 2307 108 \\ PAGEl5 0F 29 x'

V V APPENDIX A, REV. 5

3) Section 4.5, Concrete Placement, references American Concrete Institute (ACI) standards ACI-305-72, " Recommended Practice for Hot Weather Concreting" and ACI 306-66, " Recommended Practice for Cold Weather Concreting."

In order to clarify use of these ACI standards, we will apply the following requirements: PLACING TEMPERATURES OF CONCRETE: A. During hot weather concreting: Placing temperatures of concrete will be limited to the following.

1) Concrete members less than 3 feet in least dimension will not exceed 85F.

2) Concrete members from 3 feet to 6 feet in least dimension will

.at exceed 70F,

3) Concrete members more than 6 feet in least dimension will have placing temperature as near 50F as can be obtained by use of ice as necessary up to 100 percent of adding mixing water; and by shading aggregate and sprinkling the coarse aggregate the day it is to be used, Care will be taken so that no unmelted ice remains in the concrete at the end of the mixing period.

B. During the cold weather concreting: In heating the water and aggregate, live steam to heat the fine and coarse aggregate shall not be used. The permissible range for concrete temperature shall be as follows:

1) Sections less than 3 feet in least dimensions:

55 to 75F.

2) Mass concrete 3 feet or more in least dimension:

45 to 65F. The mixing water and aggregate will be purchased as required. The materials will be free of ice, snow and frozen lumps before they enter the mixer.

4) Section 4.8, "In-process Test on Concrete and Reinforcing Steel" states, " Samples for in-process test of concrete shall be taken c* the sampling point in accordance with ASTM C172.

This point may be at the truck mixer discharge if the last piece of conveying equipment is a chute, bucket, conveying system, or similar equipment. Pumped concrete must be sampled from the pump line discharge." For performance of correlation tests the requirements of ANSI N45.2.5 - 1978 shall be followed. 2307 109 PAGE/6 0F 23

V V APPENDIX A, REV. 5 5) Section 4.8, "In-process Tests on Concrete and Reinforcing Steel" contains Table B entitled, " Required In-process Tests". The followirg modifications to this table will be applied: 5.1 CROUT Table B lists grout as one of the materials requiring testing for compressive strength daily during production. These re-quirements specified for grout will not apply for the reasons given below. The test method per ASTM C-109 listed in this table is the s'andard method of test for compressive strength of hydraulic mortars used in testing cements and would not be applicable to testing job-mixed grout. The term " grout" is normally associated with any one of the following: a) A semi fluid concrete used on construction joints prior to placing additional concrete, b) An especially designed fluid concrete for intrusion grouting of pre-placed aggregate. c) A semi fluid filler used under base plates normally a manufactured, pre-packaged, material that only requires the addition of water to produce a non-shrink grout, d) Replacement for concrete in congested areas. Grout under the first and last items is tested under the regular concrete testing program as grout in this case con-sists of the same ingredients and quantities as structural concrete except the course aggregate is left out. In the second case, the grout is tested using the intrusion grout for filling preplaced aggregate cylinder samples. Successful grouting with an approved non-shrink material under aase plates is largely a matter of good technique and workman-ship. Daily checking of grout made from the same lot is not necessary. Therefore non-shrink grout shall be tested to assure that the " lot" received meets the specified requirements. The testing methods are as follows: Test Method for Non-Shrink Grout a) Compressive strength tests will be made once per lot per ASTM C-109. b) Non-shrink grout will be tested per CRD-C-589, 2307 110 PAGEj7 0FR

APPENDIX A REV. 5 v v 5.2 ADMIXTURES In-process tests using infrared spectrophotometry analysis are not necessary and may not be used. The test procedures for pH and solids content specified in ASTM C-260 and C-494 will be required for establishing the equivalence of materials from different lots or different portions of the same lot. The manufacturer is required to furnish certification for every delivery stating that the admixtures supplied for use in the work are essentially identical in concentration, composition and performance to the admixture tested under Bech tel/APf L spec-i fication. The test method described above (manufacture's certification) is that specified in ANSI N45.2.5 - 1978. 5.3 REINFORCING STEEI; In-process testing of reinforcing steel will include the mechanical properties of yield strength, tensile strength and percent elogation on full size specimens for each bar size for each 50 tons or fraction thereof from each mill heat. Bend tests are performed during material qualification testing only, except as noted below for bar sizes #14 and #18. Table A " Required Qualification Tests" as applied to re-inforcing steel will include bend tests as required by ASTM A615 and summarized below: a) For bar sizes #3 through #11, one full size specimen from largest bar size rolled from each mill heat, unless material from one heat differs by three or more designation numbers. When this occurs, one bend test shall be made from both the highest and lowest designation number of the deformed hars rolled. b) For bar sizes #14 through #18, Supplementary Requirements S1 of ASTM A615 will be applied. One full size specimen for each bar size for each mill heat. If supplementary require-ments are not followed for mill tests, they will be applied as in-process tests. The above interpretation is consistent with Regulatory Guide 1.15, " Testing Reinforcing Bars for Category I Concrete Struc-tures", Revision 1, December 1972. In-process test specimens may be selected at the rebar fabri-cation shop, prior to start of fabrication of the rebar from the heat or fraction thereof represented by the test specimen. 2307 111 PAGE /8 0F 2$

y APPENDIX A, REV. 5 v Acceptance criteria for any failed test ( qu a li f i c a t ion as well as in-process) may be the same as that for tensile tests specified in Subarticle CC-2331.2 of ASME Section III, Div. 2 Code (1975). This states that if a test specimen fails to meet the specified strength requirements, two (2) additional specimens from the same heat and of the same bar size would be tested, and if either of the two additional specimens fails to meet the specified strength requirements, the material represented by the tests would be rejected for the specified use. Alternative use of rejected material under strict control may be subject to evaluation by the Proj ec t Engineer. 6) Section 4.9, Mechanical (Cadweld) Splice Testing states in paragraph 4.9.4 " Separate test cycles shall be established for mecnanical splices in horizontal, vertical and diagonal bars, for each bar size and for each splicing crew..." The terms " horizontal, vertical and diagonal bars" will be interpreted to apply respectively to the following types of splice positions: a. Horizontal, including 10' to horizontal b. Verticle, including 10* to verticle c. 45' angle, including 10' to 80* angle The words " splicing crew" will be interpreted to refer to all members on the project that are ac t iv e ly engaged in preparing and assembling cadweld mechanical splices at the final splice location. Separate test cylces will be estab-lished for each bar size and each splice position. 2307 112 PAGE10F 29

APPENDIX A, REV. 5 Regulatory Guide 1.58, dated August 1973 (ANSI N45.2.6-1973, Qualifications of Inspection, Examination and Testing Personnel for the construction phase manufacturing / fabrication phase of Nuclear Power Plants). The requirements of the referenced standard, as modified and interpreted in the regulatory position will be applied to the AP6L Quality Program dur-ing the operational phase as described in this topical report subject to the following clarifications:

1) Substitute new Section 1.1 and 1.2 and modify first paragraph only of 1.3.

Section 1.1 Scope This standard delineates the requirements for qualification of personnel who perform inspection, examination and testing to verify conformance to specified requirements of nuclear facility items (structures, systems and components of nuclear power plants, fuel reprocessing plants, plutonium processing plants and pluto-nium fabrication plants) whose satisfactory performance is required to prevent postulated accidents which could cause undue risk to the health and safety of the public; or to mitigate the consequences c,f such accidents if they were to occur. The requirements may also be extended to other items of nuclear facilities when speci-fied in contract documents. Section 1.2 Applicability The requirements of this standard apply to personnel who perform inspections, examinations and tests during fabrication prior to and during receipt of items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear facilities. The requirements of this standard do not apply to personnel who perform inspections for government or municipal authorities, or who perform as authorized inspectors in accordance with the ASME Boiler and Pressure Vessel Code. The requirements of this standard are not intended to apply t., per-sonnel who only perform inspection, examination or testing in accord-ance with employer practices which are in compliance with "Recom-mended Practice No. SNT-TC-1A", since these personnel are certified in accordance with the requirements of SNT-TC-1A and its applicable supplements. The requirements of this standard are optional, at the dismretion of the employer, for application to personnel who per-form calibration or to craftsmen who perform installation checkouts as part of their basic installation responsibility to ready the installation for preoperational testing. This standard is to be used in conjunction with ANSI N45.2-1977. 2307 113 PAGE20 0F 2,9

The requirements apply to personnel of the owner. The requirements apply to architect-engineers, nuclear facility system designers and system sup-pliers, plant designers and plant constructors, equipment suppliers, out-side testing agencies and consultants when specified by the owner. Other standards or codes may contain qualification requirements for personnel such as nondestructive examination personnel as required by the ASME Boiler and Pressure Vessel Code, and Quality auditor personnel as may be required by Quality Systems or Quality Assurance Program standards. When this is the case, this standard is not to be interpreted to require a duplication of effort. Section 1.3 Responsibility It is the responsibility of each organization participating in the project to assure that only those personnel within their respective organizations who meet the requirements of this standard are pemitted to perform inspection, examination and testing activities covered by this standard that verify conformance to quality requirements.

2) Since this Standard does not apply to personnel who perfom non-destructive examinations, delete Section 2.2.2.

3) Section 2.2.3. Evaluation of Performance.

The periodic internal for re-evaluaticn of personnel shall not exceed three years.

4) The requirements of this Standard shall apply cnly to personnel who perform inspection, examination and testing; and accordingly Section 3 and 3.1 shall be revised to read:

3. Qualifications ? 1 General The requirements contained within this section define the minimum capabilities that qualify personnel to perform inspections, examinations and tests which are within the scope of this standard. There are three levels of qualification. The requirements for each Icvel are not limiting with regard to organizational position or professional status, but, rater, are limiting with regard to functional activities which are within the scope of this standard. Following is the recommended personnel education and experience for each level. These education and experience recommendations should be treated to recognize that other factors may provide reasonable assurance that a person can competently perform a particular task. Other factors which may demonstrate capability in a given job are previous perfomance or satisfactory completion of capability testing. 2307 114 PAGE][ OF 29

The education and experience requirements shall cake provision for personnel who have not graduated from high school or who have earned an Associate degree. According to paragraphs 3.1.1, 3.1.2, and 3.1.3 shall be revised to read: 3.1.1 Level I (1) Two years of related experience in equivalent inspection examination or testing activities, or (2) High School graduation and six months of related experience in equivalent inspection, examination or testing activities, or (3) Completion of college level work leading to an Associate degree in related discipline plus three months of related experience in equivalent inspection, examination or testing activities. 3.1.2 Level II (1) One year of satisfactory performance as Level I, or (2) High school graduation plus three years of related experience in equivalent inspection, examination or testing activities, or (3) Completion of college level work Icading to an Associate degree in related discipline plus one year related experience in equivalent inspection, examination or testing activities, or (4) Four-year college graduation plus six months of related experience in equivalent inspection, examination or testing activities. 3.1.3 Level III (1) Six years of satisfactory performance as a Level II, or (2) liigh school graduation plus ten years of related experience in equivalent inspection, examination or testing actibities; or high school graduation plus eight years experience in equ iva lent inspection, examination or testing activities, with at least two years as Level II and with at least two years associated with nuclear facilities -- or if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of nuclear facility, or (3) Completion of college 1cvel work leading to an Associate degree and seven years of related experience in equivalent inspection, examination or testing activities, with at least two years of this experience associated with nuclear facilities-- or if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility, or 2307 115 PAGEJ20F29

(4) Four-year college graduation plus five years or related experience in equivalent inspection, examination or testing activities, with at least two years of this experien:e associated with nuclear facilities -- or if not, at least sufficient training.to be acquainted with the relevant quality assurance aspects of a nuclear facility. 6) Section 3.2.1 Physical, (revise to read); APGL shall identify anf special physical characteristics needed in the performance of each activity. Personnel requiring these characteristics shall have them verified by examination at intervals not to exceed one year. 7) Section 3.2.2. Technical, (revise to read) Level I Personnel Capabilities 3, A Level I person shall be capable of performing and docu-menting the inspections, examinations and tests that are required to be performed in accordance with documented pro-cedures and/or industry practices. The individual shall be familiar with the tools and equipment to be employed and shall have demonstrated proficiency in their use. The in-dividual shall also be capable of determining that the cali-bration status of measuring and test equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection, examination and test pro-cedures are approved, b. Level II Personnel Capabilities A Level II person shall have all of the capabilities of a Level I person, Additionally a Level II person shall have demonstrated capabilities in planning inspections, examinations and tests; in setting up tests including preparation and set-up of related equipment, as appropriate; in supervising or maintaining surveillance over the inspections, examinations and tests; in supervising and certifying lower level personnel; in reporting inspection, examination and testing results; and in evaluating the validity and acceptability of inspection, examination and test results. c. Level III Personnel Capabilities A Level III person shall have all of the capabilities of a Level II person. In addition, the individual shall also be capable of evaluating the adequacy of specific programs used to train and test inspection, examination and test personnel whose qualifications are covered by this standard. The individual shall also be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the adequacy of activities to accomplish the inspection, examination and test objectives. 2307 116 PAGE23 0F 23

8) Section 4 Performance, (revise last sentence to read)

When a single inspection cr test requires implententation by a team or group, personnel not meeting the requirements of this Standard may be used in data-taking assignments or in plant or equipment operation pro-vided they are supervised or overseen by a qualified individual partici-pating in the inspection, examination or test.

9) Section 5 Records, (revise to read)

A file of records of personnel qualification shall be established and maintained by the employer. Collection, storage and control or records required by this Standard shall be in accordance with R.G.1.88 Rev. 2.

10) Table 1, (revise to read)

Implement inspection and test procedures and document results. 2307 117 PAGE240FlQ

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APPENDIX A Rev. 5 Regulatory Guide / ANSI Std. Interpretation / Alternate Reference Requirement Exception ANSI N45.2.12 shall respond within the time frame Paragraph 4.5.1 (Cont. ) stated in the audit report. This may be less than or greater than thirty days. If corrective action cannot be completed within this time frame, the responsible auditor may grant a verbal extension to the audited group. The verbal extension will be documented on the punch list for the particular audit finding. Nu CD N PAGE MOF 29

APPENDIX A Rev. 5 Regulatory Guide / ANSI Std. P.eference Requirement Interpretation / Alternate / Exception ANSI N45.2.13 Specifies subjects to Except in special cases items d., e., and Section 5.2 be evaluated during

f. may be evaluated prior to submittal to bid evaluation.

bids. ANSI N45.2.13 C of C The requirements of this section are interpreted as follows: The person attesting to a certificate Section 10.2.d shall be an authorized and responsible employee of the supplier, and shall be identified by the Supplier. ANSI N45.2.13 C of C The verification of the validity of supplier certificates and the effectiveness of the Section 10.2.f certification system is accomplished as an integral part of the total supplier control and product acceptance program, and no seperate system exists that addresses itself solely to such verifi-cation. The degree of verification required will depend upon the type of item of service and their safety importance. The means of verification may include source witness / hold points; source :"dits and document reviews; independent in;pections at the time of material receipt; user tests on selectef commodities, such as concrete components; or tests after installation on selected components and systems. p) All of these means verify whether or not a supplier (,q has fulfilled procurement document requirements, and C) whether or not a certification system is effective. 'sJ N N PAGE;29P OF 28)

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Q G p1 m v a t U s $ d d Y d v 9 b PROCMXTRE U NuxsER Trrts Q _AA-2 QUALI'IY ASSURA!!CE ORGA'JIZATIO!1 X QAA-1 QUALITY ASTRM;CE APINIS7FATIVE FRnCEIXPE X QAA-ll QUALITY ASSLEA?1CE qRAIITItn X AfD-1 CUALITY ASSUPRJCE PROCEDUPES X 1004.01 DESIGN COTTIRCL X GCP-201 [El3IGN CFR!GE PACKAGE 00!Tr!OL X E 202 DESIGN PROCESS X 1004.05 P.R. PREPARATICTI % FHOCESSI?U X GCP-102 PEOCUIEJE!."2 CCi; TROL X X 1004.02 INITIATICN & PROCESSI?U OF TFOUFTE REFolfrS X 1004.14 INITIATION & FiOCNIIU OF JOB CEERS X TJ04. L7 ot.SIIE CO:."IIIA TOR /cC :STFUCTP/VF', TOR CO?frROL X X W el FUd.".JL))JG CE' FHOCEDIRES X X TC}-101 ERA'4Ita COffrROL X ~ F 203 PGCG7:7?PREPAruGIO:4, CR bt. AIw nr.Vlu X 3004.23 DRAWI?ti COh"mOL X QAA-10 COf7Ih0L OF AF4L CA M/J;UAL X 1004.22 DOC 11'E?tr CO!7N3L X 1004.06 ". AERIAL FICEIVIhG AND I!!OPECrIO!! X QAA-34 CUALIFIED WJIDCH I,ISP X AfD-l'; 3EV1F CF SiTPLIER FOC. EVAIPATIC?!. CUALIFICATIC? X 1004.15 GCEhDL TDFJ7FIFICATIOff X 1001.07~ COffrFCL OF SFF"fAL PRCCFI M Y 4 7004.0c QUALin CO::7ICL II SFECTIO?j Y 1004.1;JA CFD!ATID?;AL ES"' CC?TIECL Y T5DI.12B orFFATIOriAL TEST Cc:TmOL-12IIT 2 v ~I6U4.10 CALTP2ATIC:: CCITIEGL Y T564.11 HANDLl?i% jiURAGE & SHIFPI?!G OF G MAERIAI.S Y TCCli'IFliOL3L Calf!IDJ & GC TAGGI!U PROCED8 E Y TUO4.13 SCC::FOILI:CE ff;I) CORRECTIVE APTICII X Y GGF-<04 ESIGN EEFICIE!!CY/CCPliECTIVE ACTICII Y Y QAA-13 3DIT FINDIID PEitPT Y Y QAA-l'i CALIIY ACTION hEClFSP X Y TUU'GL7C!TP RECCiES VR:AGFIE!!r Y WuT-* GUiVElLL/J.CE AUDi~. PEN ?II!D Y W -0 DISBIEkHICJ A!.I) REVIEW OF AUDITS Y QAA-19 UAL11ICATICIT GF AUDl:CRS Y At+3 foCEDLEE FER LA SURVEIUJJICE AUDI"'S Y AI&ls AF&L QLALiiY A.13UPRiCE GE?EHAL AUDITS Y ~Reld W!GRING SUhVEIURICE AUDITS Y A?ol7 ufERATITU PLAITIE SifrWEILLANCE ATIDI"S Y DAIE A-QUALITY ASSURANCE MANUAL REV. 5

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TITLE: QUALITY ASSURANCE PROCEDURES MATRIX PAGE 1 o 1 APP. B / i 2307 123}}

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