ML19289C389
| ML19289C389 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/09/1979 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| TAC-06531, TAC-6531, NUDOCS 7901120125 | |
| Download: ML19289C389 (32) | |
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GENC A AL OFFaCE P. O. BOX 499, COLUMBUS, NEB R ASKA 68601 Nebraska Public Power D. is tr.
ic t 1EtEP-ONE son s64..m January 9,1979 Director, Nuclear Reactor Regulation Attention: Mr. Tho=as A. Ippolito, Chief Operating Reactors Branch No. 3 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Sectior 8.0 to Amendeent 39 Quality Assurance Progra=
Cooper Nuclear Station NRC Docket No. 50-298, DPR-46
Reference:
Letter, J. M. Pilant to Thocas A. Ippolito Dated November 9, 1978 Additional Information - Quality Assurance Progran
Dear Mr. Ippolito:
We indicated, in the referenced letter, that Appendix A to Amendment 39 would be submitted by January 15, 1979 which would identify the exceptions we are proposing to take relative to the " Orange Book". We have elected to provide this information as an additional section (8.0) of Amendment 39 rather than an appendix.
Inas=uch as review and approval of these proposed exceptions may tcke several conths, we would like to reiterate our previous request that the revised Quality Assurance Progrs= be approved with the exception of the proposed Section 8.0. As stated previously, the District will conply with the requirements of tha " Orange Saok" until such time all exceptions are satisfactorily resolved and approved by the Commission.
Should you have any questions or require additional information regarding Section 8.0 to A=endment 39, please do not hesitate to contact me.
In addition to one signed original, 39 copies of this information are also submitted.
Sincerely, M
Jay .. Pilant Director of Licensing and Quality Assurance
/c=k Enclosure 79011201626 P
NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLE *R STATION QUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT TABLE OF CONTENTS 1.0 PROGRAM DEFINITION . . . . . . . . . . . . . . . . . . . . D-9-1 1.1 Purpose. . . . . . . . . . . . . . . . . . . . . . . D-9-1 1.2 Policy . . . . . . . . . . . . . . . . . . . . . . . D-9-2 1.3 Objectives . . . . . . . . . . . . . . . . . . . . . D-9-4 1.4 Scope. . . . . . . . . . . . . . . . . . . . . . . . D-9-6 1.5 Definition of Terms. . . . . . . . . . . . . . . . . D-9-7 2.0
SUMMARY
DESCRIPTION. . . . . . . . . . . . . . . . . . . . D-9-11 2.1 Organization . . . . . . . . . . . . . . . . . . . . D-9-12 2.2 Quality Assurance Program. . . . . . . . . . . . . . D-9-12 2.3 Design Control . . . . . . . . . . . . .. . . . . . D-9-15 2.4 Procurement Document Control . . . . . . . . . . . . D-9-17 2.5 Instructions, Procedures & Drawings. . . . . . . . . D-9-18 2.6 Document Control . . . . . . . . . . . . . . . . . . D-9-19 2.7 Control of Purchased Material, Equipment, and Services . . . . . . . . . . . . . . . . . . . . D-9-20 2.8 Identification and Control of Parts, Materials, and Components . . . . . . . . . . . . . . . . . . . D-9-22 2.9 Control of Special Processes . . . . . . . . . . . . D-9-22 2.10 Inspection . . . . . . . . . . . . . . . . . . . . . D-9-23 2.11 Test Control . . . . . . . . . . . . . . . . . . . . D-9-24 2.12 Control of Measuring Test Equipment. . . . . . . . D-9-25 2.13 Handling, Storage and Shipping . . . . . . . . . . . D-9-26 2.14 Inspection, Testing and Operating Status . . . . . . D-9-27 2.15 Non-conforming Materials, Parts, or Components . . . D-9-28 2.16 Corrective Action. . . . . . . . . . . . . . . . . . D-9-30
- 2. 17 Quality Assurance Records. . . . . . . . . . . . . . D-9-31 2 18 Audits Assurance Records . . . . . . . . . . . . . . D- 9-3 2 u.
Mr. Thomas A. Ippolito January 9, 1979 Page 2 STATE OF NEBRASKA )
) ss PLATTE COUNTY )
Jay M. Pilant, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this information on behalf of Nebraska Public Power District; and that the statements in said application are true to the best of his knowicdge and belief.
M L ~
Q y h. Pilant Subscribed in my presence and sworn to before me this day of 7anuary, 1979.
[ NOTARY PUBLIC g/
My Commission expires / .
stattu setut.stne a s nrista MARLYN R. HOHNDORF M IfrCemek 4 Oct 14.1980
TABLE OF CONTENTS (Cont 'd) 3.0 ORGANIZATION AND RESPONSIBILITIES. . . . . . . . . . . . . D-9-47 3.1 General. . . . . . . . . . . . . . . . . . . . . . . D-9-47 3.2 General Office Management. . . . . . . . . . . . . . D-9-4 8 3.2.1 Aseistant General Manager -
Power Operations Group. . . . . . . . . . . . D-9-4 8 3.2.2 Director, Licensing and Quality Assurance . . . . . . . . . . . . . . . . . . D-9-49 3.2.3 Quality Assurance Manager . . . . . . . . . . D-9-5 0 3.2.4 Quality Assurance S taf f . . . . . . . . . . . D-9-51 3 2.5 Assistant General Manager -
Power Projects Group. . . . . . . . . . . . . D-9-54 3.2.6 Director of Power Supply. . . . . . . . . . . D-9-54 3.3 Cooper Nuclear Station Management. . . . . . . . . . D-9-55 3.3.1 Station Superintendent. . . . . . . . . . . . D-9-55 3.3.2 Station Line Supervisor -
Cooper Nuclear Station Personnel. . . . . . . D-9-56 3.4 Safety Review and Audit Board (SRAB) . . . . . . . . D-9-56 3.5 Station Operations Review Committee (SORC) . . . . . D-9-57 3.6 Outside Vendors, Contractors, Subcontractors and Consultants. . . . . . . . . . . . . . . . . . . D-9-58 4.0 QUALITY ASSURANCE DOCUMENTS. . . . . . . . . . . . . . . . D-9-6 3 4.1 NPPD Internal Documents. . . . . . . . . . . . . . . D-9-63 4.1.1 Quality Control Inspection. . . . . . . . . . D-9-64 4.1.2 Quality Assurance Instructions (QAI). . . . . D-9-66 4.1.3 Quality Assurance Plans (QAP) . . . . . . . . D-9-67 5.0 METHOD OF IMPLEMENTATION . . . . . . . . . . . . . . . . . D-9-'7 2 6.0 RECORDS RETENTION AND DISPOSITION. . . . . . . . . . . . . D-9-7 5
7.0 REFERENCES
. . . . . . . . . . . . . . . . . . . . . . . . D-9'77 Assignment of QC inspectors is a function of station management. The majority of the QA/QC inspections are assigned to engineers, licensed reactor operators or lead technicians. This method for selecting and assigning inspectors has assured station management that the best qualified individual (either throgh education or years of experiene,e) is assigned to monitor " essential" or safety-related activities.
The method endorsed by ANSI N45.2.6 places emphasis on certifying individuals and establishing levels of qualification. It is our contention that even though an individual is certified and qualified to the apprpriate level, he may not be the best inspector in all situations.
The current method of selecting and assigning QC inspectors at CNS has proven to be very effective. We therefore take exception to sections 2.0 and 3.0 of ANSI N45.2.6. If future operation indicates that our present system is inadequate, efforts will be made to establish the system endorsed by ANSI N45.2.6.
CNS does not have the in-house capability to perform nondestructive examinations in accordance with SNT-TC-1A. These services are currently contracted to an approved vendor.
(c) Implementation The guidance set forth by ANSI N45.2.6 will not be implemented at Cooper Nuclear Station until the present system of selecting and assigning qualified inspection and testing personnel is found to be inadequate.
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TABLE OF CONTENTS (Cont'd) 8.0 IMPLEMENTATION, WASH-1283, -1284 and -1309 . . . . . . . . D-9-79 8.1 ANSI N45.2-1971 . . . . . . . . . . . . . . . . . . D-9-80 8.2 ANSI N45.2.1-1973 . . . . . . . . . . . . . . . . . D-9-81 8.3 ANSI N45.2.2-1972 . .. . . . . . . . . . . . . . . D-9-83 8.4 ANSI N45.2.3-1973 . . . . . . . . . . . . . . . . . D-9-84 8.5 ANSI N45.2.4-1972 . . . . . . . . . . . . . . . . . D-9-86 8.6 ANSI N45.2.5-1974 . . . . . . . . . . . . . . . . . D-9-89 8.7 ANSI N45.2.6-1973 . . . . . . . . . . . . . . . . . D-9-93 8.8 ANSI N45.2.8-Draft 3, Rev. 3 Apr. 1974. . . . . . . D-9-95 8.9 ANSI N45.2.9-1974 . . . . . . . . . . . . . . . . . D-9-96 8.10 ANSI N45.2.10-1975. . . . . . . . . . . . . . . . . D-9-97 8.11 ANSI N45.2.11-1974. . . . . . . . . . . . . . . . . D-9-98 8.12 ANSI N45.2.12-1974. . . . . . . . . . . . . . . . . D-9-99 8.13 ANSI N45.2.13 Draft 2 Rev. 4 Apr. 1974. . . . . . . D-9-100 8.14 ANSI-N18.1-1971 . . . . . . . . . . . . . . . . . . D-9-102 8.15 ANSI-N18.7-1972 . . . . . . . . . . . . . . . . . . D-9-10;
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8.0 Implementation, WASH-1283, -1284 and -1309 Except as modified in the sections which follow, it is intended that the CNS QA Program for Plant Operations will utilize the guidance provided by NRC publications WASH-1283 (5-24-74), FASH-1284 (10-26-73) and WASH-1309 (5-10-74) (" rainbow" series) to the extent that these documents provide practical guidelines for safety-related activities occurring during the operational phase of plant life.
The existing operational QA Program does not address all of the detailed requirements set forth in the " rainbow books". A detailed review has been made to determine where the CNS QA Program differs from the ANSI Standards cited in the " rainbow books".
With respect to the applicability of the " rainbow books" and the associated standards, it is impracticable to apply all of the require-ments set forth by these documents to a plant for whfe.h important, and (in some respects) irreversible commitments were made 8 to 10 years ago. It is also impracticable to apply requirements to an operating plant which were intended solely for the design and construction phase.
The following sections summarize the scope and applicability of ANSI Standards and describe specific exceptions that will be taken in applying the guidance of these documents to the CNS QA Program.
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- 8. l' ANSI N45.2-1971 Qualitv Assurance Program Requirements for Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.28 shall be applied to the Operational QA Program to those activities affecting the safety-related aspects of the operational phase of CNS.
Where codes or standards arc referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the SAR, the SAR commitments shall govern.
Later revisions of applicable codes and standards may be specifically invoked by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.
(b) Specific Exceptions Quality Assurance Program (Section 2)
The QA Program describes the measures utilized to comply with the requirements of 10CFR50 Appendix B to the extent that ANSI N45.2 parallels that NRC regulations, the CNS QA Program conforms to this ANSI Standard. Where other particular ANSI Standards apply, they are referenced in the QA Program and implementing procedures.
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Inspection (Section 11)
First Level inspection has been assigned to plant personnel.
Contrary to the requirement of this standard that such persons shall not report directly to the same immediate supervisor, our program requires only that inspection activities to verify quality of work shall be performed by persons other than those who performed the activity being inspected.
(c) Implementation Existing program requirements do not necessarily address all of detailed guidance set forth by ANSI N45.2. However, the CNS QA Program does establish the levels of control required by ANSI N45.2.
8.2 ANSI N45.2.1-1973 Cleaning of Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plants (a) Scope and General Applicablity Insofar as the requirements of N45.2.1 are directed primarily at contractor activity during construction, this standard cannot be directly applied to operational requirements.
The guidance provided by this standard and the associated Regulatory Guide 1.37 shall be applied to safety-related maintenance, repair, and modification activities occurring during the operational phase of Cooper Nuclear Station to the extent that such activities are comparable in nature and degree to similar activities occurring during the design and construction phase.
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(b) Specific Exceptions General Requirements (Section 2)
Cleaning requirements for almost all maintenance, repair and modification work will be considered as a part of the overall job requirements. In this respect, detailed cleaning procedures will not generally be prepared as separate documents. Necessary requirements, consistent with the scope of the work, will be included as a part of the overall work instructions.
Criteria for Cleaning (Section 3)
For cleanness classifications where the scope of plant modi-fication work is such at to make application of the guidance provided by this standard practicable, the cleanness classifi-cations and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work requirements. For most modification or maintenance work, however, involving only small portions or individual co=penents of larger systems, it is not considered practicable to conduct ASTM E11-70 cleanness tests. Appropriate cleanness will be maintained during the work and appropriate preoperational flushing will be conducted, consistent with the scope of the work perfor=ed and the original design requirements.
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8.3 ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handline of Items for Nuclear Power Plants (During the Con-struction Phase)
(a) Scope and Applicability The guidance provided by this standard shall be evaluated and applied to those packaging, shipping, receiving, storage and handling activities associated with safety-related items, to the extent that such activities are ce= parable in nature and degree to similar activities occurring during the construction phase.
(b) Specific Require =ents Our progra= is structured to identify safety-related equipment and provide for designation of packaging, shipping, receiving, storage and handling require =ents for purchased parts and materials. The classifications of this standard cannot be applied directly to individual spare parts or subasse=blies of the parent equip =ent. Due to difference in volume, ce=plexity, inspectability, etc., the packaging, shipping, handling and storage require =ents of spare parts and subasse=blies will necessarily be different frem the require =ents which may be imposed on the entire co=ponent or piece of parent equipment.
The =ajority of ite=s purchased for an operating plant consist of co=ponents, subasse=blies and individual spare parts which could be used in a =ultitude of different applications. Such ite=s are purchased to the highest require =ent of intended use. The volu=e and character-istics of purchases during the operational phase differ significantly D-9-83
f rom those purchases made during the design and construction phase, and storage facilities are considerably different. Items that require special measures of storage protection will be identified as a past of the purchasing docu=ents. Ite=s that cust be stored outdoors (equiv-alent of Level D) or items that =ust be stored in covered but unheated conditions (equivalent of Level C) will be evaluated on an individual case basis. However, it is not considered practicable to preclassify individual parts by levels are required by Section 2.7 of this standard.
Shipping and packaging require =ents for such ite=s vill likewise be handled in the purchase order docu=ents, as appropriate.
(c) Imolementation Adequate control is being =aintained by standard warehcuse practices and by specific review of all purchase orders for safety-related items per the existing plant procedures.
8.4 ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants (a) Scone and General Applicability The guidance provided by this standard and the associated Regu-latory Guide 1.39 for control of housekeeping require =ents shall be applied to work conditions and other applicable activities which could affect quality of i=portant operational aspects of CNS to the extent that such activities are comparable in nature and degree to similar activities occurring during the design and construction phase.
3-9-84
(b) Specific Exceptions General Requirements (Section 2)
The plant has been divided in zones for fire protection and security purposes. The zone designated for cleanness in the ANSI Standard are primarily intended for control of work during construction of the plant. Therefore, the CNS facilities will not be classifed by the zones designated in the Standard general housekeeping rules. Limitations on eating, drinking, and smoking are already provided in existing CNS procedures. Where special cleanness controls and tool and material accountability are required for particular types of work, temporary clean areas will be designated and defined in the procedures for accomplishing the work.
Requirements (Section 3)
Fire protection and prevention equipment will be provided as set forth in accordance with NPPD evaluation of the CNS fire protection system as submitted to the NRC on 10/17/76 and 4/6/77.
(c) Implementation Existing maintenance procedures will be reviewed to determine the need for particular cleanness, housekeeping and control provisions.
Where indicated, procedures will be revised to incorporate such provisions.
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8.5 ANSI N45.2.4-1972 Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction Phase of Nuclear Power Generating Stations (a) Scope and Applicability This standard was written to apply to construction of nuclear plants and the requirements set forth are based on the construction situation. As such, implementation of all the requirements of this standard for operating plants, considering the scale of plant modifi-cation versus initial construction, is not practicable.
The guidance provided by this standard and the associated Regu-latory Guide 1.30 shall be applied to installation, inspection and testing of electrical equipment and systems associated with on-site safety-related modification work occurring during the operational phase of CNS to the extent that such work is comparable in nature and extent to similar work occurring during the design and construction phase.
Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the SAR and other appropriate design docu-ments, the original design requirements shall govern.
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(b) Specific Exceptions Definititions (Section 1.4)
The definition of Class I and Class IE electrical equipment set forth by this standard does not conform to the equipment categories of CNS. 's- ntial electrical items upon which the Operational QA __ogram is based are included in the SAR Amendment 39. The scope and applicability of this standard shall necessarily be limited to these defined areas.
Procedures and Instructions (Section 2.3)
Appropriate requirements for installation, inspection and tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the various areas of this standard. However, in the developmeat of the work package, consideration will be given to the areas outlined in Section 2.3, as appropriate.
Installation, Verification and Test (Section 4.0, 5.0 and 6.0)
The requirements of the installation and the associated inspections, verifications and tests are included in the work instructions as appropriate, consistent with the scope of the work and the imporatance of quality. In the develop-D-9-87
ment of the work instructions, consideration will be given to the guidance provided by Sections 4.0, 5.0 and 6.0 of this standard, and appropriate requirements will be incorporated into the instructions. It is not intended that separate procedures be established which specifically address all of the areas referenced.
Applicable Codes, Standards and Guides (Section 9.0 and Appendix B)
Application of the guidance provided by the additional codes and standards listed in Appendix B will be considered to the extent that such codes and standards provide useful and practical guidance for the work being performed. Commitment to the guidance of N45.2.4 shall not include commitment to the guidance of referenced standards. (See Regulatory Guide 1.30, Safety Guide 30)
(c) Implementation It is not intended that the QA program requirements address all of the detailed guidance set forth by ANSI N45.2.4. Appropriate controls have been implemented to control modification work and testing to assure that such work meets or exceeds original design requirements.
Existing procedures include appropriate requirements for installation, inspection and testing.
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8.6 ANSI N45.2.5-1974 Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants (a) Scope and Applicabiltiy This standard was written for use during construction of nuclear plants and the requirements set forth are based on construction situ-ation. As such, implementation of all the requirements of this standard for operating plants, considering the scale of plant modification versus initial construction, is not practicable.
The guidance provided by this standard and the associated Regu-latory Guide 1.97 shall be applied to activities involving safety-related concrete and structural steel work occurring during the operational phase of Cooper Nuclear Station to the extent that such activities are comparable in nature and degree to similar activities occurring during the design and construction phase.
Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the SAR and other appropriate design docu-ments, the original design requirements shall govern.
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(b) Specific Exceptions Procedures and Instructions (Section 2.2)
Appropriate requirements for installation, inspection and tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the various areas of this standard. However, in the development of the work package, consideration will be given to the areas outlined in Section 2.2, as appropriate.
Personnel Qualifications (Section 2.4)
The existing Operational QA Program does not include provisions for certification of personnel per N45.2.6. (Please refer to Section 7.7 of this document.)
Calibration and Control (Section 2.5.2)
The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied to all measuring and test equipment used by NPPD or their agents, test laboratories and contractors. Such require-ments, however, will not be imposed on commercial batch plant facilities. Instrumenatation at commercial batch plant facilities will be evaluated to determine that sufficient accuracy can be obtained.
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Oualification Tests (Section 3.2.1),
For s=all quantities of concrete involved in todification work, all concrete =ust be purchased fro = co==ercial concrete batch plants. For s=all quantities of concrete, it is un-reasonable to expect co==ercial facilities to shut down nor=al operations to provide certified aggregate, ce=ent, ad=ixtures, fly ash, water, etc. In this respect, the qualification tests required by Table A for aggregate; ce=ent; ad=ixtures; fly ash and pozzolans; water and ice will not be required. Appropriate evaluations will be =ade to deter =ine that good quality and generally acceptable
=aterials are used. This evaluation, coupled with slu=p tests, air entrain =ent tests and concrete cylinder strengths, will provide adequate control and qualification of the concrete.
Design =ixes consistent with, or equivalent to, original require =ents will be specified and the results of the cylinder tests will be evaluated based on the acceptance criteria associated with the original design =ix require =ents.
Protection of Materials (Section 4.2)
The inspection require =ents of Section 4.2 will not generally be perfor=ed, as the s=all quantities of concrete involved in nodification work will no doubt be =ixed using =aterials already in the batch plant bins. Control of storage of
=aterials would not be practicable.
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Measuring, Mixing and Transporting (Section 4.3)
If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the requirements of ACI-304, ASTM C-94.
Where certifications are not available, two concrete test cylinders representing the first and last one-third of truck mixer contents shall be taken for evaluation of the mixer truck, over and above the normal ccncrete cylinders taken to evaluate the in-place concrete. The concrete batch plant facility shall be inspected to assure that reasonable controls are being exercised with reference to the inspection guide-lines set forth by Section 4.3(1) and (2).
Preplacement Preparation (Section 4.4)
Inspection of soils and earthwork will meet the general requirements set forth. The extent to which individual inspection requirements are met will depend upon the nature and scope of the work to be performed.
In-Process Tests on Concrete and Reinforcing Steel (Section 4.8)
Except for normal batch qualification tests (slump, air content, temperature and compressive strength) and initial reinforcing stee.1 certifications, the in-process tests required by Table B are generally applicable to the periodic control which must be exercised with reference to long-term D-9-92
consturction type programs. The in-process test require-ments of Table B are not considered applicable to short-term modification work as would be required by QA at CNS.
(c) Implementation Existing program requirements do not address the guidance set forth by ANSI N45.2.5. Where the need arises, measures will be implemented to meet the intent of this standard with the ex-ceptions noted above.
8.7 ANSI N45.2.6-1973 Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and the associated Regu-latory Guide 1.58 shall be applied to inspection, examination and testing activities associated with safety-related modification work accomplished during the operational phase at CNS.
(b) Specific Exceptions It has always been the belief of CNS and NPPD that, in order to be effective, quality control must be built into the operation of the plant. With this in mind, CNS incorporated quality control inspection and test functions directly into the station operating procedures.
Inspection points are then witnessed and signed-off by members of the operating staff not directiv involved in the activity being inspected.
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8.8 ANSI N45.2.8 - Draft 3, Rev. 3 Apr. 1974 Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants (a) Scope and Applicability This standard was written to apply to construction of nuclear plants and, as such, the requirements set forth and the feasibility, both f rom an economical viewpoint and a practical viewpoint, are based on the construction situation. As such, implementation of all the requirements of this standard for operating plants, considering the scale of plant modification versus initial construction, is not practicable.
The guidance provided by this standard shall ba applied to in-stallation, inspection and testing of electrical equipment and systems associated with on-site safety-related modification work occurring during the operational phase of CNS to the extent that such work is comparable in nature and extent to similar work occurring during the design and construction phase.
Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the SAR and other appropriate design documents, the original design requirements shall govern.
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(b) Implementation It is not intended that the QA program requirements address all of the detailed guidance set forth by ANSI N45.2.8. Appropriate controls have been implemented to control modification work and testing to assure that such work meets or exceeds original design requirements. Existing procedures include appropriate requirements for installation, inspection, and testing.
8.9 ANSI N45.2.9-1974 Requirements for Collection, Storage, and Maintenance of Ouality Assurance Records for Nuclear Power Plants (a) Scope and Applicability Consistent with the implementation date set forth below, the guidance provided by this standard and the associated Regulatory Guide 1.88 shall be applied to quality assurance records associated with the operational phase of CNS.
For those design, manufacturing, construction and operating records generated prior to implementation of this standard, it is not our intent to backfit the detailed requirements of this standard to those records. All such records, however, have been initially designated for lifetime storage, until specific review dictates otherwise, and will be stored in the per=anent record storage facility. Appropriate record indexes and filing system shall be established to permit reasonable identification and retrieval. The records will be stored and preserved per the requirements of Section 5.0 of this standard.
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(b) Implementation NPPD has established a document storage and retrieval system consistent with the guidelines of ANSI N45.2.9. All quality-related
. documents will be reviewed, dispositioned, coded, microfilmed (if practical) and stored in accordance with a pre-determined retention time. Procedures to implement this sytem will be continually upgraded to reflect the current operation.
8.10 ANSI N45.2.10-1975 Quality Acsurance Terms and Definitions (a) Scope and Applicability The quality assurance terms and definitions contained in this standard shall be used as guidance and applied as appropriate to the Operational QA Program for Cooper Nuclear Station.
(b) Implementation The use of this standard and the associated Regulatory Guide 1.74 shall be effective immediately. There may be instances where existing procedures contain definitions that may not be in strict accordance with those provided by this standard. As existing procedures are revised, however, such definitions shall be evaluated to determine if the intent of all definitions meets the intent of those provided by this standard.
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8.11 ANSI N45.2.ll-1974 Quality Assurance Requirements for Design of Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and the associated Regu-latory Guide 1.64 shall be applied to design activities involving safety-related modification work and the revision or development of plant design documents occurring during the operational phase of Cooper Nuclear Station.
Where codes, standards or design requirements are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the SAR, the SAR commitments shall govern. Later revisions of applicable codes and standards may be specifically invoked by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.
(b) Implementation The quality assurance requirements for the design of Cooper Nuclear Station are addressed in the FSAR (Amendment 39) and in the QA Program implementing procedure (QAP-1700).
The quality assurance program for monitoring design control at CNS and at the corporate level follows the guidelines set forth in ANSI N45.2.11. It is not intended that the QA Program address all of the detailed guidance set forth by this standard, however, the guidance provided is presently being used.
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8.12 ANSI N45.2.12-1974 Reauirements ror Auditing of Quality Assurance Programs for Nuclear Plants (a) Scope and Applicability Except as expressly modified below, the guidance provided by this standard shall be applied to the audit program identified by the Operational QA Program for Cooper Nuclear Station.
(b) Specific Exceptions Audit Schedule (Section 3.4.2)
Due to the large scope of our QA Program and the audit areas der'ined, it is not practicable to audit and entire program on an annual basis. Our scheduling provides for applicable elements of the QA Program to be audited at least once every two (2) years.
The audited oreanization is requ1 red by existing procedures to respond in writing to deficiencies noted in the audit report. A minimum response time is not specified because corrective action var? 9s depending on the nature and extent of the deficiency. However, corrective action is subject to follow-up audits and reports to higher management within eight (8) weeks of issuance of the original audit report.
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(c) Implementation The guidance provided by this standard is presently being used as a part of the Operational QA Program for Cooper Nuclear Station.
8.13 ANSI N45.2.13 Draft 2 Rev. 4 Apr. 1974 Quality Assurance Requirements for Control of Procurement of Items and Services, for Nuclear Power Plants (a) Scope and Applicability To the extent that the information set forth by this standard provides useful and practical guidelines for purchasing activities associated with nuclear safety-related equipment, components, parts, materials and services, the guidance provided will be applied to such activities associated with the CNS Operational QA Program.
It must be recognized, however, that equipment and components pur-chased during the design and construction phase were not purchased on the basis of present-day standards, especially with reference to vendor qualification and vendor quality assurance programs, In this respect, replacement parts and spare parts for existing equipment are often limited to sole-source suppliers, some of whom may not meet present-day qualification standards. Such replacement parts or spare parts are purchased to appropriate quality standards to maintain an equal to, or better than, condition but it is uot considered practicable to backfir the r.quirements of the standards to all such vendors.
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(b) Specific Exceptioqs Selection Measures (Section 4.2)
In addition to the methods outlined by subparagraphs 4.2.a.,
4.2.b and 4.2.c, consideration will be given to products in which quality can be verified by receiving inspection, test or other means. Evaluation of procurement sources for such items may be made on the basis of subparagraph 4.2.a. but on a much less restrictive basis.
Sole-source replacement part or spare part suppliers may have to be evaluated based on prc. t performance and maintenance of an equal to, or better than, condition.
Conformance to Procurement Documents (Section 5.2)
Measures shall be established to assure the successful bid contorms to procurement document requirements. There will be no requirement, however, to document the bid evaluations.
Preaward Evaluation (Section 5.3)
The requirement and extent to which preaward evaluations are performed will be subject to the conditions of Section 6.2 of the standard.
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Certificate of Conformance (Section 10.2)
The minimum criteria set forth are much too restrictive for general application of certification of conformance involving off-the-shelf itens and many applications involving the purchase of simple spare parts. The requirements set forth by this section will be considered in purchasing activities to the extent that the guidance provided is useful and can be practicably applied to our purchasing activities.
(c) Implementation Existing program requirements conform to the guidance set forth by ANSI N45.2.13.
8.14 ANSI-N18.1-1971 The CNS Technical Specifications (Sectica 6.1.4) require that plant personnel meet the requirements of ANSI N18.1-1971.
CNS Administrative Procedure No. 1.5 specifies the requirements for the training program for plant personnel. This procedure meet the requirements of ANSI N18.1-1971 and 10CFR55 (including Apper. dix A).
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8.15 ANSI-N18.7 - 1972 The operational QA Program for CNS is considered to conform to the guidance provided by this standard. For certain minor details regarding content and format, CNS procedures accomplish this intent by means other than specified in the ANSI standards. For example, in lieu of a matrix which indexes documents to the requirements of N18.7, the QA Policy Document identifies operating and QA procedures and cross-references them to the requirements of 10CFR50 Appendix B. This accomplishes the intent of Paragraph 5.1 and it is not considered necessary to duplicate this index in a different form.
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