ML19325D450
| ML19325D450 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point, 05000000 |
| Issue date: | 10/02/1989 |
| From: | Buckman F, Heins G, Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18054B044 | List: |
| References | |
| CPC-2A, NUDOCS 8910240126 | |
| Download: ML19325D450 (90) | |
Text
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QUALITY ASSURANCE
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PROGRAM DESCRIPTION jg FOR OPERATIONAL NUCLEAR POWER PLANTS
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SUBJECT:
STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS POWER COMI ANY QUALITY ASSURANCE PROGRAM FOR OPERATIONAL NUCLEAR POWER PLANTS As Chief Operating Officer of Consumers Power Corpany. I have the ultimate management authority for the establishment of Corporate Quality Assurance Policy. This Policy is provided in the Consumers Power Company Quality Assurance Program Description for Nuclear Power Plants. The Quality Assurance Program Description complies with the quality assurance requirements contained in Appendix B of 10CFR$0. " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and responds to the additional guidance con-tained in ANSI N18.7. and to the ANSI N45.2 Series of Standards and corre-sponding Reg,ulatory Guides within the context of applicability imposed by N18.7.
The Quality Assurance Program Description for Operational Nuclear Power Plants outlines the actions thct are implemented during the operational phase including fueling, testing, operation, refueling, procurement, mainte-nance, repair, and modification design and construction of the safety-related portions of the nuclear power plants.
I have delegated the authority for the establishment and maintenance of the Quality Assurance Program Description through the Senior Vice President.
Energy Supply to the Vice President. Nuclear Operations for operational phase activities and plant modifications, and in turn to the Director. Quality Assurance. The Director. Quality Assurance is also authorized to verify the effective implementation of the Quality Assurance Program Description.
The Quality Assurance Program Description contains mandatory requirements whic'a must be implemented and enforced by all responsible organizations and individual..
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A CAL 3 GNERGYCOMPANY
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QUALITY ASSURANCE PROGRAM DESCRIPTION j
FOR OPERATIONAL NUCLEAR POWER PLANTS REVISION 10 APPROV Y:
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Senibr Vice'Precident, Energy Supf,y I
Date G L Heins l
t Vice President - N e
Operations Date' l
D P Hoffman D
- f. di Vice #res1&ent, Effergy Supply Services
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Dite R J Nicholson f
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NO fice President, Distri6ution Operations
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D V Voigt 4
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Mee' President'7Torporate Services Date '
R A Wells i
i il Vice President. Fossil & Hydro Operations Date P A Elbert i
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I Pcg3 111 Rev 10 Date: 10/1/89 t
i QUALITY ASSURANCE PROGRAM DESCRIPTION POR I
OPERATIONAL NUCl. EAR POWER PLANTS
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CONTENTS Section Title Pase l
Statement of Responsibility and Authority.......
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Approval Page..
11 Contents.
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1.0 organization.
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2.0 Quality Assurance Program.
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3.0 Design Control....................
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4.0 Procurement Document Control.............
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f 5.0 Instructions Procedures and Drawings..
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6.0 Document Control...........
33 I
7.0 Control of Purchased Material, Equipment l
a nd S e rv i c e s.....................
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5 8.0 Identification and Control of Items..
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t 9.0 Control of Special Processes........'.....
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,1 43
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10.0 Inspection..
v 11.0 Test Control.....................
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12.0 Control of Measuring and Test Equipment.
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13.0 Handling, Storage and Shipping...
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14.0 Inspection. Test and Operating Status..
51 1
15.0 Nonconforming Materials Parts or Components....
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r 16.0 Corrective Action 55 L
17.0 Quality Assurance Records..
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18.0 Audits.
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Rev 10 Date: 10/1/89 Section Title Page Appendix A Regulatory Guide and ANSI i
61 (2pp)
Standard Commitments.....
Part 2 CP Co Exceptions to Operating Phase Standards and 63 (22 pp)
Regulatory Guides......
i FIGURES l
1 Consumers Power Company Corporate E
Organization..
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2 Energy Supply Organization.
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Nuclear Operations Department Organization..
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Quality Assurance Organization..........
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Energy Distribution and l
Corporate Services. Organizations..........
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6 Energy Supply Services Organization 16 I:
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PD1081-0535A-QA04-QA06 L
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Rev 10 Date: 10/1/89 1.0 ORCANIZATION f
1.1 POLICY Consumers Power Company (CP Co) is respoasible for establishing and implementing the Quality Assurance Program, as described herein, for the operational phase of its nuclear power plants. Although authority I
for development and execution of some parts of the program is delegat-ed to others', such as contractors and consultants. CP Co retains overall responsibility.
This section of the Quality Assurance Program Description (QAPD)
I identifies the CP Co organizations responsible for activities affect-g ing the quality of safety-related nuclear power plant structures, g
systems and components and describes the authority and duties assigned to them. It addresses responsibilities for both attaining quality objectives and for the assurance functions of establishing and main-I t aining the Quality Assurance Program and verifying that activities affecting the quality of safety-related items are performed in accor-dance with QA program requirements.
Quality assurance functions (audits, surveillance, certain reviews and control of this QAPD) are performed by personnel within formally I
designated Quality Assurance (QA) organizational units that report to the Director. Quality Asrurance.
Specific areas of responsibility and authority are delegated to these units by the individual assigned overall responsibility and authority for the QA "rogram.
The report-l ing level of the Quality Assurance organization affords sufficient y
authority and organizational freedom, including sufficient indepen-dence from the cost and schedule impacts of QA organization actions, to enable people in that organization to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementa-tion of solutions.
1.2 IMPLEMENTATION 1.2.1 Source of Authority The President and Chief Operating Officer (see Figure 1 of Company Organization Charts) of CP Co is responsible for safe operation of a
CP Co nuclear power plants. Authority and responsibility for estab-g lishing and implementing the QA Program for plant operations, mainte-nance and modifications is delegated through the Senior Vice President. Energy Supply to the Vice President - Nuclear Operations (see Figure 2).
This delegation is formalized in a STATEMENT OF RESPONSIBILITY AND AUTHORITY signed by the President and Chief Operat-ing Officer. Other quality-related functions are provided by other organizations as described herein.
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1.2.2 Responsibility for Attaining Quality Objectives in the Nuclear gi Operations Organization gi The Vice President - Nuclear Operations is responsible to the Senior l
Vice President, Energy Supply for operation and maintenance of CP Co nuclear power plants. Directors and Managers who report to him are i
responsible for directing the performance of activities thai; affect safe plant operation and/or safety-related functions of structures, j
systems and components of the operating nuclear power plants in accordance with QA Program requirements.
a.
The Plant General Manager / Plant Manager (see Figure 3) are respon-sible to the Vice President, Nuclear Operations for operation and i
maintenance of the nuclear power plants in such a manner as to achieva compliance with Plant licenses, applicable regulations and the QA Program.
Each Plant General Manager or Manager delegates to appropriate managers and staff personnel in his organization l
responsibility for carrying out applicable controls required by g:
the Quality Assurance Program. QA Program activities performed on 3,
the authority of the Plant General Manager / Manager includes Qualification of plant operating and maintenance personnel.
Control of preparation, review and approval of Q-List updates.
Control of preparation, review and approval of plant procedures and instructions.
Control of plant initiated procurement, including preparation.
l ruviews and approval of purchase requests for spares, replacement items, consumables, and naterials, items and services.
Control also includes submittal of purchase requests to Purchasing, vendor surveys for urgent procurements, planning and execution of source i
l surveillance or inspection, receiving inspection, and review of supplier quality-related documentation.
Functioning as the Company design and configuration control authority for compliance of plant modifications and design chcntc't 3,
to existing plant design criterin.
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Project responsibility for modifications, including design, procurement, construction and testing activities as assigned by the Plant General Manager / Manager.
Safety assessments, operating experience reviews including NRC Information Notices, administrative and technical support for t
l Pl.nt Review Committee (Palisades) activities and technical j
l support for onsite review organizations.
l Developing and maintaining Plant Security Plans and administering i
I the contract (s) for the security force.
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l Authorizing use of secondary calibration standards whose accuracy B
is equal to that of equipment being calibrated, and assuring that such use cannot result in operation outside Technical Specifica-tions limits.
l Maintaining Echelon III calibration facilities for Portable and Laboratory Mearuring and Test Equipment (PL-M&TE) and Health I
Physics PL-M&TE (HPPL-M&TE). Calibration / maintenance of installed plant instrumentation.
Controlling a calibration recall system.
Maintaining a Master List for plant-owned PL-M&TE.
Operating onsite Document Control Centers.
Onsite evaluation of corrective action documents, including initial determination of reportability to the NRC.
Providing for storage and protection of purchased materials and I
items and items awaiting disposition implementation after removal from service, assuring preservation of identification.
Developing and maintaining Plant Fire Protection Plans.
Implementing security, fire protection, health physics and emer-gency plans.
Performing start-up and operational testing, such as precritical l
and criticality tests, low-power, power ascension and plant tests, and surveillance testing.
Maintaining equipment status control.
l Maintaining required controls over chemical standards and P
reagents.
Conducting the inservice inspection program in accordance with technical specifications and State of Michigan rules.
Conducting a water chemistry program in accordance with technical specifications.
Performing reactor engineering functions, such as fuel calcula-l tions and specification, fuel movement calculations, reactor p
thermal profile studies, safety analysis, etc.
b.
The Director, Nuclear Safety Services Department (see Figure 3),
is responsible fort Performance of the offsite safety review functions for the nuclear power plants as described in plant technical specifications.
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Development and maintenance of nuclear plant probabilistic risk assessment models and application of PRA technology to severe accident management and plant reliability improvement.
Conduct of the biennial assessn.ent of QA Program effectiveness.
Assessing the effectiveness of the corporate Health Physics program and maintaining standards for control of Radiological i
Materials and personnel exposure and recommending program improve-ments to reduce on-site and offsite radiation exposure caused by plant operations, operating the dosimetry icboratory and main-taining records of personnel radiation exposure.
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The Director Nuclear Licensing (see Figure 3) is responsible for:
Accomplishing plant licensing activities including maintaining i
licensing documents up-to-date, interfacing with the NRC, accom-p11shing and/or tracking licensing commitments and coordinating internal action on NRC bulletins, generic letters, etc.
Providing necessary corrective action processing and status l[
l reporting for assigned corrective action documents, including 3
offsite determination of NRC reportability.
d'.
The Director Nuclear Fuel Supply (see Figure 2) is responsible through the Vice President Nuclear Operations to the Senior Vice l
President, Energy Supply for the procurement of nuclear fuel and i
l associated services.
e.
The Emergency Planning Administrator (see Figure 3) is responsible
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for coordinating Corporate Nuclear Emergency Planning.
f.
The Director, Nuclear Training, is responsible for establishing, implementing and documenting the training of nuclear operations l
and technical support personnel, including QA Program indoctrina-tion and training.
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l 1.2.3 Responsibility for Attaining Quality Objectives in the Energy Supply t
Services Organization W
The Vice President Energy Supply Services (see Figure 6) is responsi-f ble to the Senior Vice President, Energy Supply for certain services, g
including standards for calibration of M&TE, and performing assigned I
modifications to CP Co nuclear power plants. Directors and Mr.nagers
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reporting to him are responsible for directing the performance of activities in accordance with QA Program requirements.
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The Manager Energy Supply Technical Services (ESTS) is responsi-ble, through personnel reporting to him, fort 3
Maintaining / testing electrical protective devices.
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Performing design verification testing associated with electrical protective devices, except when such testing is procured from approved outside contractors.
Maintaining the Company's Echelon 11 calibration facility for calibrating reference and secondary standards and general usage portable and laboratory atasuring and test equipment.
Controlling the calibration recall system for Portable and Labora-tory M&TE owned by ESTS, and other departments, as requested.
l Maintaining a Master PL-M&TE List for ESTS PL-M&TE'and for other g
departments, as requested.
Maintaining a Company PL-M&TE Inventory List.
Providing chemistry support to Nuclear Operations, as requested.
Preparing, reviewing, approving and obtaining additional reviews and approvals if required, of purchase requests for services, I
equipment and consumables, and submitting such requests to pur-chasing for procurement action.
I Conduct:ing performance tests on materials, equipment and systems.
Performing nondestructive examination, and controlling / maintaining NDE equipment.
Providing qualified NDE procedures and equipment and NDE persocnel.
Providing chemical and metallurgical analytical services.
Providing necessary corrective action processing and status reporting for assigned corrective action documents, b.
The Manager, Projects. Construction and Equipment (PC&E) is responsible, through personnel reporting to him fort l
Performing the construction, preoperational testing and overall i
project management of assigned generating plant modification projects.
Providing necessary corrective action processing and status reporting for assigned corrective action documents.
Providing electrical equipment and turbine-generator expertise and developing and qualifying special process procedures for welding and heat treating operations.
PD1081-0535A-QA06
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The Manager, Field Maintenance Services provides Field Maintenance Services for assigned modifications and plant outages.
i d.
The Manager, Engineering is responsible, through personnel report-E, ing to him fort 5,
Performing the engineering associated with generating plant g
modification projects as assigned by the Plant General gl Manager / Manager.
j Providing, as requested, technical expertise and review capability to Nuclear Operations in the areas of metallurgy, special process-L es, coatings, electrical, mechanical and civil-structural engi-t neering and application of codes and standards.
Providing necessary corrective action processing and status j
reporting for assigned corrective action documents.
e.
The Director, Management and Budget, is responsible, through personnel reporting to him, for Maintaining the Records Management System including required W (
retention, protection and retrievability, operating the General Office (offsite) Document Control Center and Engineering Records 3(
Center, and for maintaining the Uniform File Index. This includes 5;
collecting, storing, maintaining, distributing and controlling j
plant engineering / design documents.
iI!i Providing necessary corrective action processing and status reporting for assigned corrective action documents.
1.2.4 Responsibility for Attaining Quality Objectives Outside Nuclear I
Operations and Energy Supply Services Certain functions that constitute part of the Nuclear Operations QA f
Program are performed by CP Co organizational units outside the Nuclear Operations Department or Energy Supply Services. Engineering and design tasks executed in support of plant activities are subject to review and acceptance by the associated plant organization respon-l sible f or that activity (as the design authority).
i a.
The Director, Administrative Operations and Planning (see Figure
- 5) is responsible through the Vice President, Corporate Services i
to the President and Chief Operating Officer for microfilming of 1
specified QA records and plant engineering / design documents.
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b.
The Manager, Purchasing, Land and Materials (see Figure 5) is responsible through the Vice President, Corporate Services to the i
l President and Chief Operating Officer for initiating procurement 5
action based on approved purchase requests received from organiza-tions parforming or supporting plant operation, maintenance or 31 modification, and for preparing and obtaining required reviews and El approval of contracts.
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The Manager Engineering and Construction Department (see Figure
- 5) is responsible through the Vice President, Distribution Opera-tions to the Senior Vics President, Energy Distribution for determining settings for electrical protective systems and relay control systems, and for design, review and recommending changes to electrical protective schemes and associated settings.
d.
The Executive Engineer - System Dynamics and Plant Auxiliaries is g
responsible through the Director - Power Resources and System l
g Planning and the Vice President, Possil and Hydro Operations, to the Senior Vice President ' Energy Supply for analytical studies to appraise the adequacy of electrical supply to safety-related I
equipment in nuclear power plants from the principle power supply facilities of the transmission network and onsite power supply.
The Director Performance improvement, Planning and Training is e.
responsible to the Senior Vice President - Energy Supply for operating the Skill Centers and training and qualifying personnel and equipment for welding operations.
1.2.5 Responsibility for Quality Assurance Punctions The Director Quality Assurance Department (see Figure 4), is respon-sible to the Vice President, Nuclear Operations for the definition, direction and effectiveness measurement of the Naclear Operations QA I
Program, including modifications, and for verifying that activities affecting the quality of safety-related items are performed in accor-dance with QA Program requirements.
He is also responsible for I
providing management direction to department heads reporting to him as indicated below for corporate environmental auditing. The Director's authority includes the following major functions for work under his jurisdiction:
Establishing the QA Program for operating nuclear plants.
Continuing evaluation of QA Program status and adequacy, reporting his conclusions to CP Co Management.
Assuring that verification activities are accomplished by personnel not directly responsible for the work being performed.
Stopping unsatisfactory work to control further processing, delivery or installation of nonconforming materials or items.
Recommending that a plant be shut down if such action appears neces-sary (the order is issued by the Vice President, Nuclear Operations or
-3 the Plant General Manager /Manag'er).
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Reviewing and concurring with organizational administrative procedures and procedure changes for compliance with QA Program requirements.
l Assuring that nonconforming items are properly identified, segregated and dispositioned.
Administering an Enhanced Performance Intentive Program according to Section 2.3.
QA engineering associated with modification design, procurement, g
construction and testing, including verification that quality-related gi test prerequisites have been accomplished, identification and partici-pation in resolution of ins *allation inspection and test problems and nonconformances, and maintenance and reporting of status of hardware and test quality and corrective action.
(This function will be i
carried out by plant and/or general office QA staff, as assigned by g*!
the Director. QA.)
g The Director's job description includes the following prerequisites t
Previous management experiencel knowledge of quality assurance regula-tions, policies, practices and standards; and experience working in i
quality assurance or related activities in reactor design, construc-tion or operations, or in a similar high technology industry. The quality management office, consisting of the Director and his immedi-E, ate staff, meet or exceed the qualifications established in Paragraph W,
4.4.3 of ANSI /ANS 3.1, 12/79 Draft as endorsed by Regulatory Guide 1.8.
i The Director. Quality Assurance has no other duties or responsibili-ties unrelated to QA that would prevent his full attention to QA matters, is sufficiently free from schedult and cost pressures to give i
appropriate weight to quality consideration" in his decisions and recommendations, and has direct access to hc.sh enough levels of Management to obtain resolution of quality problems. As Director, he g!
delegates authority and holds his organization responsible for accom-gl plishing QA functions for operational nuclear power plants, as follows:
a.
The Palisades Plant QA Director and the Big Rock Point Plant QA Superintendent are required to possess the educational and experi-ence qualifications specified in Regulatory Guide 1.8.
Each is responsible to the Director - Quality Assurance for the following 1
operating phase activities for work under his jurisdiction:
Plant site quality assurance surveillances of safety-related activities, including operations, maintenance, modifications, procurement, testing, etc.
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t Review of and concurrence with plant administrative procedures for compliance with Nuclear Operations QA Program requirements.
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,D101-esm-Qq 3
Page 9 Rev 10 Date 10/1/89 Verificatiot,of onsite corrective action implementation and the I
ef fectiveness of corrective action for sf s n. f! cant safety-related problems, including, for modifications, the: n. sevnformances are incorporated into the appropriate correctis$ system.
y Review and concurrence with procurement quality requirements for nuclear fuel, source audit / surveillance / inspection at fuel suppli-er facilities, fuel inspection upon delivery, and review of fuel l
supplier quality-related documentation.
Plant site quality control inspection program, including inspec-tien of maintenance, modifications, testing and fuel handling.
-l Participation in daily work schedule and status meetings to remain l
abreast of day-to-day work assignments throughout the plant and to assure adequate QA coverage relative to procedural and inspection controls, acceptance criteria and staffing and qualification of site QA persoanel to carry out their assignments.
Review of maintenance, modification, test, and fuel handling l
procedures and instructions, and work authorizing documents for QA l
aspeers, inspection plenning, and inclusion of necessary Hold and Notification points.
Review and concurrence with administrative procedures that control
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methods for indicating inspection, test and operating status and attachment / removal of inspection status indicators.
Review and concurrenct > 'h 0-Lists and Q-List changes to assure compliance with QA Program commitments and to assure that the extent that QA controls are to be applied to specific structures, systems and components is appropriate.
b.
Quality Assurance Section Heads (Corporate Office) are responsible to the Director, Quality Assurance for the Nuclear Operations QA audit program, QA program development, and special studies includ-ing the follow 1ngt QA, Security and Environmental audit programs (plant sites and Corporate Office), including follow-up on corrective action for i
audit findings.
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Verification of the implementation and effectiveness of Corporate 1
1 Office corrective action for significant problems.
4 Supplier surveys and evaluation including review / approval of' supplier QA programs, and maintenance of the NOD Approved Suppli-I ers List.
Review of and concurrence with quality requirements of procurement l
request packages generated in the Co porate Office, as required.
l PD1081-0535A-QA06
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Maintenance / operation of corrective action system.
Maintenance of the QA Program Description for Operational Nuclear Power Plants.
Review of Nuclear Operations Department Standards (NODS) and h
review and concurrence with Corporate Office administrative
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procedures for compliance with QA Program requiremente.
- Development and maintenance of Quality Assurance Department Procedures.
Ar.alysis of new and/or changed regulatory direction, codes and standards to determine their effect on the QA Program.
Administrative control of Nuclear Operations Department Standards.
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Pegs 11 Rev 10 Date: 10/1/89 5
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PRESIDENT AND I
CHIEF OPERATING 0FFICER
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ENERGY DISTRIBUTION ENERGY SUPPLY
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Figure 1 - Consumers Power Company Corporate Organization PD1081-0535A-QA06 i
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Pass 12 Rev 10 Date: 10/1/89 I
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SENIOR l
VICE PRESIDENT 5
ENERGY SUPPLY h
h DIRECTOR VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT PERF IMP, ENERGY SUPPLY FOSSIL & HYDRO NUCLEAR PLNG & TRG SERVICES OPERATIONS OPERATIONS gi
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DIRECTOR,'
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SYSTEM PLANNING
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NUCLEAR OPERATIONS DFPARTMENT VICE PRESIDENT NUCLEAR OPERATIONS I
NUCLEAR NUCLEAR SAFETY SERVICES f
FUEL SUPPLY l
DIRECTOR DIRECTOR l
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NUCLEAR NUCLEAR CORPORATE
. QUALITY I
PLANTS LICENSTNG EMERGENCY ASSURANCE J
PLANNING i
h W/ GEN MGR DIRECTOR ADMINISTRATOR DIRECTOR L
I' NUCLEAR j
TRAINING DEPARTMENT DIRECTOR I
i Figure 3 - Nucleer Operations Department Organization f
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QUALITY ASSURANCE 4
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1 DIRECTOR SUPERINTENDENT l
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.Rev 10 Date: 10/1/89 l'
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VICE PRESIDENT AND ENERGY DISTRIBUTION CHIEF OPERATING OFFICER-I VICE PRESIDENT VICE PR/SIDENT DISTRIBUTION CORPORATE OPERATIONS SERVICFS j
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I MANAGER MANAGER DIRECTOR ENGINEERING AND PURCHASING ADMINISTRATIVE CONSTRUCTION LAND &'
OPERATIONS AND 1
MATERIALS PLANNING (GRAPHIC OPERATIONS) i I
DIVISION HEAD i
SYSTEM PLANNING AND PROTECTION y
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1 Figure 5 - Energy Distributicn and Corporate Services Organizatier.s
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VICE PRESIDENT ENERGY SUPPLY SERVICES
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ENGINEERING FIELD MAINT l
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Rev 10 Date: 10/J/89 2.0 QUALITY ASSURANCE PROCRAM 2.1 POLICY Policies that define and establish the Consumers Power Company (CP Co) l Quality Assurance Program for Operational Nuclear Power Plants are stated in the individual sections of this document. The program is I
implemented through procedures and instructions responsive to provi-sions of the QAPD and will be carried out for the life of each plant.
l Quality assurance controls apply to activities affecting the quality B
of safety-related structures, systems and components, to an extent based on the importance of those structures, systems, or components to g
safety. Such activities are performed under suitobly controlled g
conditions, including the use of appropriate equipment, maintenance of proper environmenta3 conditions, assignment of qualified personnel and assurance that all applicable prerequisites have been met.-
Quality Assurance Program status, scope, adequacy and compliance with 1
10CFR50 Appendix B are regularly reviewed by CP Co Management through I
reports, meetings and review of audit results. Biennially, a pee-planned and documented assessment of the Nuclear Operations QA Program is performed by a management team independent of the Quality Assurance Department.
2.2 IMPLEMENTATION I
2.2.1 The President of Consumers Power Company, as Chief Operatir.g Officer, has stated in a' formal STATEMENT OF RESPONSIBILITY AND AUTHORITY, signed by him, that it is corporate policy to comply with the provi-sions of applicable legislation and regulations pertaining to quality assurance for nuclear power plants as defined by 10CFR50 Appendix B.
The statement makes this QAPD and the associated implementing proce-i dures and instructions mandatory and requires compliance by all I
responsible organizations and individuals.
It identifies the Manage-3 ment positions in the Company vested with responsibility and authority for implementing the Program and assuring its effectiveness.
2.2.2 The Quality Assurance Program at CP Co consists of controls exercised by organizations responsible for attaining quality objectives and by organizations responsible for assurance functions (see Section 1.0, i
ORCANIZATION).
2.2.3 The effectivity and applicability of this QAPD are as follows:
i For Big Rock Point and Palisades, the QAPD became effective on 1
a.
April 1, 1982, with full implementation on January 1, 1983.
)
b.
The QA Program described in this QAPD is intended to apply for the life of CP Co's nuclear power plants.
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The QA Program applies to activities affecting the quality of j
safety-related structures, systems, components and related consumables during plant operation, maintenance, testing and all modifications. These activities having a direct impact on l,
Q-listed items shall be procedurally' controlled.
Safety-related 5j structures, system, components and related consumables are identi-
,l fied in Q-Lists, which are developed and maintained for each plant l
in accordance with the criteria of Regulatory Guide 1.29 as clarified by Items No. 20a and No. 20b in Part 2 of Appendix A to this QAPD.
l 2.2.4 This QAPD, organized to present the CP Co Quality Assurance Program for Operational Nuclear Power Plants in the order of the'18 criteria of 10CFR50 Appendix B,' states CP Co policy for each of the critoria g
and describes how the controls pertinent to each'are carried out.
Any g
chatsges made to this QAPD that do not reduce the commitments previous-ly accepted by the NRC must be submitted to the NRC at least annually.
3 Any changes made to this QAPD that do reduce the commitments previous-g-
ly accepted by the NRC must be-submitted to the NRC and receive NRC approval prior to implementation. 'The submittal of the changes described above shall be made in accordance with the requirements of l
5 The program described in this QAPD will not be changed in any way that g,
would prevent it from meeting the criteria of 10CFR50 Appendix B.
3, 2.2.5 Documents used for implementing the provisions of the QAPL include the following:
a.
Nuclear Operations Department Standards (NODS) and/or administra-tive procedures specify the standard methods of accomplishing l6 operational phase activities.
Because the Quality Assurance E;
Program is an integral part of the operational phase activities, the methods for implementing Quality Assurance Program controls 3
are integrated inte.these documents.. The Quality Assurance g'
Department reviews the NODS and administrative procedures for compliance with QA Program requirements and. Corporate QA policy.
j b.
When Contractors perform work under their own quality ' assurance programs, these programs are reviewed for compliance with the applicable requirements of 10CFR50' Appendix B and the contract and g) are approved by CP Co prior to the start of work.
3J l
c.
Applicable elements of the operations Quality Assurance Program 3 - 1 are applied to emergency plans, security plans, radiation and fire -
'g ;
protection plans for CP Co nuclear power plants. These plans describe QA controls applicable to associated equipment and activities.
Il PD1081-0535A-QA06 n
Pcg2 19 Rev 10 Date: 10/1/89 2.2.6 Provisions of the Quality Acsurance Program for Operational Nuclear.
Power Plants apply to activities.affecting the quality of safety-related structures, systems, components and related con <.umables.
,.g Appendix A to this QAPD lists the ANSI Standards and Regulatory Guides g
to which CP Co commits. Appendix A also describes necessary excep-tions and clarifications to the requirements of those documents. The scope of the program and the extent to which its controls are applir.d are established as follows' a.
CP Co uses the criteria specified in Regulatory Guides 1.26 and 1.29 in engineering analysis of an item's function in relation to safe operation and shutdown to identify structures, systems and components to which the Quality Assurance Program applies (See i
Appendix A).
b.
This identification procecs results in the classification of equipment as either Q or non-Q, and the inclusion of this classi-
~
fication in an equipment data base. This data base is available for inquiry by individuals involved in plant operation. The classification of structures, systems and consumables is also identified, documented, and controlled.
c.
The extent to which controls specified in the Quality Assurance Program are applied to Q-listed items is determined for each item I
considering its relative importance.to safety.
Such determina-tions are based on data in such documents as the plant risk analysis, plant Technical Specifications and the FSAR/FHER (See Appendix A).
2.2.7 Activities affecting the quality of safety-related items are accom-g plished under controlled conditions. Preparations for such activities 3
in:1ude confirmation that prerequisites have been met, such as:
I a.
Aseigned personnel are qualified.
b.
Work has been planned to the proper revisions of applicable l
engineering and/or technical specifications.
c.
Specified equipment and/or tools, if any, are on hand to be used.
l d.
Materials and items are in an acceptable status.
e.
Systems or structures on which work is to be performed are in the proper condition for the task.
f.
Authorized current instructions / procedures for the work are available for use.
g.
Items and facilities that could be damaged by the work have been l
protected, as required.
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Provisions have been made for special controls, processes, tests and verification methods.
2.2.8 Development, control and uso of computer programs affecting nuclear E
power plant design and operation at CP Co are subject to QA Program 5
g decign controls (see Section 3.0, DESIGN CONTROL).
2.2.9 Responsibility and authority for planning and implementing indoctrina-tion and training are specifically designated in the CP Co organiza-tfon (see Section.1.0, ORGANIZATIOM).
a.
The training and indoctrination program provides for ongoing W
training and periodic refamiliarization with the Quality Assurance Program for Operational Nuclear Power Plants.
b.
Personnel who perform inspection md examination functions are qualified in accordance with requirements of Regulatory Guide g
1.58, SNT TC-1A, or the ASME Code, or Section 10.2.7 of this QAPD, 5
as applicable.
c.
Personnel who participate in quality assurance audits are quali-fied in accordance with Regulatory Guide 1.146.
d.
Personnel assigned duties such as special cleaning procest,es, g
welding, etc. are qualified in accordance with applicable codes, 3
standards and regulatory guides.
e.
The training / qualification program for personnel performing QA functions includes provisions for retraining, reevaluation and recertification to ensure that proficiency is maintained.
f.
Certificates of qualification for personnel performing QA func-tions designate specific functions that the named personnel are qualified to perform and indicate the performance criteria on which the qualification was based.
g.
Training and qualification records including documentation of objectives, content of program, attendees and dates of attendance are maintained at least as long as the personnel involved are performing activities to which the training / qualification is relevant.
h.
Personnel responsible for performing activities that affect quality are instructed as to the requirements identified in applicable quality related manuals, instructions and procedures.
1.
The Quality Assurance Department provides trainin6 in quality assurance principles related to procurement for those personnal E
performing procurement quality assurance actions, including review 5
of procurement documents, source verification and receipt inspection.
PD1081-0535A-QA06
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_A Pags 21 Rev 10 Date: 10/1/89 2.2.10 Status and adequacy of the quality assurance program are regular.ly assessed by CP Co Management. The following activities constitute formal elements of that assessment y
Audit' reports, including follow-up on corrective action accom-a.
plishment and effectiveness, are distributed to appropriate levels of Management (see Section 18.0, AUDIT).
b.
Semi-annual QA Program Status Meetings are held, involving the Vice President, Nuclear Operations, the Director, Quclity I
Assurance and the Managers of the organizations responsible for implementing elements of the QA Program for Operacional Nuclear Power Plants.
Management teams independent from the Quality Assurance organiza-c.
tion, but knorriedgeable in auditing and quality assurance, bienni-ally review the effectiveness of the Quality Assurance Program for Operational Nuclear Power Plants.
This review may be performed as part of the independent audit of the Quality Assurance organi-i zation. Conclusions and recommendations are reported to the Senior Vice President, Energy Supply.
Corrective actions in response to recommendations are tracked in the regular corrective action tracking system (see Section 16.0, CORKECTIVE ACTION).
I 2.3 ENHANCED PERFORMANCE INCENTIVE PROGRAM l
B 2.3.1 The Director, Quality Assurance evaluates performance of organization-I al units to determine which, if any, may have the level of QA over-g sight of in-process activities reduced. Consideration is given to the l
following in making the determinations regulatory performance; qt lification, knowledge and performance of personnel; internal
/ surveillance / inspection results; results of assessments by other a
1..
'ndent organizations; overall conformance to ectablished require-j metu-; and corrective action performance.
l 2.3.2 Those organizational units selected may receive reduced QA/QC atten-l tion in areas such as direct reviews (for example, maintenance / work order or procedure review), inspection coverage. or surveillance, as I
warranted. Audit frequcncy is not subject to reduction.
F 2.3.3 An Enhanced Performance Incentive Program Plan is developed for each organizational unit ente-iag the Program to define the performance criteria to be maintained, the creas where QA/QC will be reduced, and the intervals at which performance will be assessed and reporteo.
- i 2.3.4 Performance of organizational units in the Program is monitored and I
reported to the Director, Quality Assurance, at intervals established as part of the entry conditions. Declining performance results in return to nor.aal or increased QA/QC attention.
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P ge 23 Rev 10 Date: 10/1/89 3.0 DESIGN CONTROL I
3.1 POLICY Modifications to safety-related structures, systems and components are accomplished in accordance with approved designs. Activities to develop such designs are controlled.
Depending on the type of modifi-I cation, these activities include design and field engineering; the performance of physics, seismic, stress, thermal, hydr:.alic, radiation and Safety Analysis Report (SAR) accident analyses; the development l
and control of associated computer programs; studies of material p
compatibility; accessibility for inservice inspection and maintenance; j
and determination of quality standards. The controls apply to prepa-ration and review of design documents, including the correct transla-5 tion of applicable regulatory requirements and design bases into 1
design, procurement and procedural documents.
3.2 1MPLEMENTATION 3.2.1
/.uthority and responsibility for modification activities is under the cognizance of the Nuclear Operations Department as described in Section 1.0, ORGANIZATION.
This authority and responsibility includes the preparation, review, approval and verification of the following t
design documents: a) System descriptions; b) Design input and crite-ria; c) Drawings and specifications; and d) Engineering analyses and associated computer programs.
3.2.2 Errors and deficiencies in approve:! design documents, or in design j
methods (such as computer codes) that could adversely affect struc-tures, systems and components are documented. Action is taken to assure that the errors and deficiencies are corrected.
1 3.2.3 Materials, parts and processes that are essential to safety-related I
functions are selected and specified, based on the requirements of applicable codes and standards or on known, successful use under i
similar conditions. This includes standard commercial materials, parts and processes. Alternatively, materials, parts and processes j
j may be qualitied for use through qualificction testing:(see Item
{
3.2.8).
The adequacy of the selected materials, parts and processes is assured through the required design verifications or approvals.
i 3.2.4 Exceptions and waivers to or deviations from the engineering (quality) standards (ie, the required dimensions, material properties, features and other characteristics specified for modificttions) are required by i
procedure and by contract, when applicable, to be documented and controlled.
(See, also, Section 15 concerning the approval of "re-pair" or "use as is" dispositions of nonconformances.)
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l Pogo 24 Rev 10 Date: 10/1/89 When modifications involve design interfaces between internal or 3.:
.s external design organizations or across technical disciplines, these interfaces are controlled. Procedures are used for the review, l
approval, release, distribution and revision of documents involving 31 design interfaces to ensure that structures, syatems and components g,
are somps.tible geometrically, functionally and with processes and environment. Lines of communication are established for controlling
(
the flow of needed design information across design interfaces, including changes to the information as work progresses. Decisions and problem resolutions involving design it.terfaces are made by the CP Co organization having responsibility for engineering direction of g
I the design effort.
W' 3.2.6 Checks are performed and documented to verify the dimensional accuracy a+
and completeness of design drawings and specifications (ie, the gi products of a design process).
3.2.7 Modification. design document packages are reviewed by the Quality Assurance Department to assure that the documents that they contain have been prepared, verified, reviewed and approved in accordance with Company procedures and that they contain the necessary quality assur-g ance requirements. These requirements include the inspection and test g
requirements, quantitative and/or qualitative acceptance criteria and the requirements for documenting inspection and test results.
3.2.8 The extent of and methods for design verification are documented.
The extent of design verification performed is a function of the impor-tance of the item to safety, design complexity, degree of standardiza-l tion, the state-of-the-art and similarity vith previously proven m
designs. Methods for design verification include evaluation of the l
applicability of standardized or previously proven designs, alternate 3
calculations, qualification testing and design roviews. These methods g
may be used cingly or in combination, depending v:' the needs for the design under consideration.
I; When design verification is done by evaluating standardized or previ-ously proven designs, the applicability of such designs is confirmed.
Any differences from the proven design are documented and evaluated g
for the intended application.
3 Qt.21111 cation testing of prototypes, components or features is used a
when the ability of an item to perform an essential safety function 5
cannot otherwise be adequately substantiated. This testing is far-formed before plant equipment installation where possible, but always before reliance upon the item to perform a safety-related function.
l Qualification testing is performed under conditions that simulate the Wj
^
most adverse design conditions, considering all relevant operating modee. Test requirements, procedures and results are documented.
g 'j Results are evaluated to assure that test requirements have been g
satisfied. Modifications shown to be necessary through testing are i
made, and any necessary retesting or other verification is perf'rmed.
- i Scaling laws are established and verified, when apolicable. Test configurations are clearly documented.
]
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Page 25 Rev 10 Data: 10/1/89 Design reviews are performed by. multi-organizational or inter-disciplinary groups or by single individuah.
Criteria are estab-lished to determine when a formal group review is required and when review by an individual.is sufficient.
11nless otherwise stated, the verification of design addresses all information conveyed by the design document. When the verification is limited to certain areas or features, the scope or extent and any limications on the verification are documented.
3.2.9 Persons representing applicable tschnical disciplines are assigned to perform design verifications. These persons are qualified by appro-I priate education or experience but are not directly responsible for the design. The designer's immediate supervisor may perform the verification, provided that (1) He is the only techt.lcally qualified individual available, and (2) He has not specif'ed a singular design approach, ruled out certain i
desiEn considerations or established the design inputs for the particular design aspect being verified, and (3) His review is either:
Approved in advance by the supervisor's management, with a.
documentation of the approval included in'the design.packsge, I
b.
Controlled by a procedure reviewed and approved by the Quality I
Assurance Department. Such procedure shall providt specific limitations regarding the types of design work that may or may not be verified by a designer's supervisor, and shall provide for clear documentation that the supervisor performed the design verification.
l QA audits cover the frequency, effectiveness, and technical adequacy of the use of supervisors as design vocifiers to guard against abuse.
3.2.10 When designs must be taeased for use before they have been fully completed or before they have been verified, the incomplete or unveri-fled parts of the design and the hold point tc which work may proceed are identified. This hold point occurs before the work becomes j
irreversible or before the item is relied on to perform a safety-related function. Justification for such early release is documented.
I 3.2.11 Computer codes used in design are appropriately documented, verified, certified for use and controlled. Their ute as specified.
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l 3.2.12 Changes to design output documents, including field changes, are controlled in a manner commensurate with that used for the original 9
design.
Such changes are evaluated for impact. Those that affect fit, form or f inction are reviewed and approved by the same, or 3,
equivalent, organizations that approved the original design.
Informa-g' tion on approved changes is transmitted to all affected organizations.
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i Page 27 Rev 10 Date: 10/1/89 4.0 PROCURE::ENT DOCUMENT CONTROL l
4.1 POLICY Procurement documents for safety-related structuras, systems, compo-nents and services define the characteristics of 1 tem (s) to be pro-cured, identify applicable regulatory and industry codes / standards requirements and specify supplier quality assurance program require-ments to the extent necessary to assure adequate quality.
4.2 IMPLEMENTATION 4.2.1 Responsibilities and authorities for procurement planning and for preparation, review and approval of procurement documents are delin-i I
cated in Section 1.0, ORGANIZATION.
l I
Procurement request packages are reviewed and approved prior to j
I submittal to the Purchasing, Land and Materials Department. Re';tew includes verification that the necessary quality requirements are specified.
Th2 responsible project engineer performs bid evaluations.
l 4.2.2 Supplier selection.is described in Section 7.0, CONTROL OF PURCHASED l
MATERIALS, LQUIPMENT AND SER7 ICES.
4.2.3 The contents of procurement documents vary according to the item (s)
I being purchased and its function (s) in the plant. Provisions of this QAPD are considered for application to suppliers. As applicab.'e, procurement documents include:
Scope of work to be performed.
l a.
)
b.
Technical requirements, with applicable drawings, specifications, I
I codes cnd standards identified by title, document number and revision and date, with any required procedures such as special l
process instructions identified in such a'way as to indicate I
source and need.
Regulatory, administrative and reporting requirements.
c.
d.
Quality requirements appropriate to the complexity and scope of the work, including necessary tests and inspections.
I A requirement for a documented QA Program, subject to CP Co review e.
and written concurrence prior to the start of work.
I A requirement for the supplier to invoke applicable quality f.
requirements on subtier suppliers.
I
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Provisions far access to supplier and subtier suppliers' facili-ties and records for inspections, surveillances and audits.
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Identificetion of documentation to be provided by the supplier, identification of documents be compatible with the Engineering Records Center System, the schedule of submittals and identifica-J tion of documents requiring CP Co approval.
31 l
gI 4.2.4 Trained, qualified and certified personnel perform and document reviews of procurement request packages to assure that:
a.
Quality requirements (see 4.2.3 of this Section) are correctly stated, inspectable, and controllable.
b.
Adequate acceptance and rejection criteria are included.
c.
The procurement documents have been prepared, reviewed, and approved per the QA Program requirements.
4.2.5 Changes to the technical or quality requirements in procurement documents are. controlled in a manner commensurate with that used for the original requirements. Those that cot'1d af f ect fit, form, func-tion or the necessary assurance of quality are reviewed and approved by the same, or equivalent, organizations that approved the' original 3,
procurement request packages.
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d Page 29 Rev 10 Date: 10/1/89 5.0 INSTRUCTICNS, PROCEDURES AND DRAWINGS 5.1 POLICY Activities affecting the quality of safety-related structures, syn. cess l
and components.me accomplished using instructions, procedures and drawings appropriate to the circumstances which include acceptance I
criteria for detarmining if an activity has been satisfactorily completed.
5.2 IMPLEMENTATION The authority and responsibility for performing activities affecting I
the quality of safety-related structures, systems and components are assigned as described in Section 1.0, ORGANI1.ATION. Management personnel assigned these responsibilities assure that the instruc-tions, procedures and drawings necessary to accomplish the activity I
are prepared and implemented.
Instructions, procedures and drawings incorporate (1) a description of I
the activity to be accomplished and (2) appropriate quantitative (such-as tolerances and operating limits) and qualitative (such as workman-ship otandards) acceptance criteria sufficient to determine that the I
activity has been satisfactorily accomplished.
Temporary procedures may be issued to provide management instructions I
which have short-term applicability. Temporary procedures include a designation of the time period during which they may be used.
The procedures used by CP Co to control its activities include the following:
1.
Administrative Procedures, including Quality Assurance Department Procedures.
2.
System procedures that describe the operation of the plant.
I 3.
Start-up procedures that provide for starting the reactor from hot j
or cold condition and recovering from reactor trips.
i 4.
Shutdown procedures that provide for controlled reactor shutdown or shutdown following reactor trips.
[
5.
Power operation and load changing procedures that provide for steady state power operation and load changing, including response to unanticipated load changes.
I 6.
Process monitoring procedures that provide for monitoring plant system performance and which, as appropriate, identify limits for significant process parameters.
j i
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- 7. Fuel-handling procedures that provide for activities such as a.
Refueling c.
Fuel accountability d.
Receipt and shipment of fuel e.
Nuclear Safety measures
- 8. Maintenance procedures that provide for:
a.
Preparation for' maintenance b.
Performance of maintenance I]i 1
c.
Post-maintenance and operability checks and tests d.
Use of supporting maintenance documents
- 9. Radiation control procedures that provide for:
a.
Implementation of the radiation control program including the acquisition of radiation data b.
Identification of equipment for performing radiation surveys c.
Measurement, evaluation and assessment of radiation hazards
- 10. Calibration and test procedures that provide for:
a.
Periodic calibration and testing of safety-related instrumen-tation and control systems b.
Calibration of portable measuring and test equipment used in activities affecting safety
- 11. Chemical-radiochemical control procedures that provide for activi-ties including:
- i a.
Sampling and analyses b.
Maintenance of coolant quality c.
Control of deleterious agents d.
Control, treatment and management of radioactive nastes e.
The control of radioactive calibration sources PD1081-0535B-QA06 m
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- 12. Emergency procedures that provide guidance fort a.
Operations during potential emergencies so that a trained operator will know in advance the expected course of events that will identify an emergency and the immediate action he should take b.
Identifying symptoms of emergency conditions c.
Monitoring automatic action d.
Immediate operator action e.
Subsequent operator action
- 13. Emergency Plan Implementing Procedures 1
- 14. Inspection, test and examination procedures that identify:
1 a.
Objectives b.
Acceptance criteria c.
Prerequisite and special conditions I
j d.
Limiting conditions e.
Test or inspection instructions f.
Any required special equipment or calibration 8
Hold and Witness points, as appropriate
- 15. Modification procedures that provide for:
Administrative control and technical support during plant a.
modifications b.
The basis for a consistent method of performing recurring engineering, construction and' quality assurance activities Control of the interfaces between CP Co and its suppliers c.
d.
Offsite management control and visibility Control of onsite quality-related modification activities that i.
e.
assure the QA Program is implemented and its effectiveness is assessed and reported 1
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Pagr 33 Rev 10 Date: 10/1/89 6.0 DOCUMENT CONTROL I
6.1 POLICY Documents controlling safety-related activities within the scope defined in Section 2.0, QUALITY ASSURANCE PROGRAM are issued and changed according to established procedures. Documents such as instructions, procedures and drawings, including changes thereto, are reviewed for adequacy, approved for release by authorized personnel and are distributed,and used at the location where a prescribed activity is performed.
Changes to controlled documents are reviewed and approved by the same organizations that performed the original review and approval or by other qualified, responsible organizations specifically designated in I
accordance with the procedures governing these documents.
6.2 IMPLEMENTATION 6.2.1 The authority and responsibility for the control of documents are described in Section 1.0, ORGANIZATION.
6.2.2 Controls are established for approval, issue and change of documents in the following categories:
Design documents (eg, calculations, drawings, specifications, a.
analyses) including documents related to computer codes i
b.
As-built drawings (record drawings) and related documents i
c.
[
d.
Instructions and procedures for activities such as fabrication,
{
construction, modification, installation, inspection, test and plant maintenance and operation l
e.
Procedures that implement the Quality Assurance Program f.
Final Safety Analysis Report
{
g.
Reports of nonconformances h.
Plant Technical Specifications 6.2.3 The review, approval, issue and change of the above documents are controlled by:
Establishment of criteria to ensure that adequate technisr.1 and a.
quality requirements are incorporated b.
Identification of the organizations responsible for review, approval, issue and revision i
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l c.
Performance and documentation of a review for concurrence with QusJf ty Assurance related aspects of items 6.2.2 a, c. d (except frr vperating procedures), e and g.
![
d.
Review of changes to documents by the organization that performed the initial review and approval or by the organization designated i
in accordance with the procedure governing the review and approval of specific types of documents l
6.2.4 Controlled documents are issued and distributed so thats a.
The documents are available at the work location prior to commenc-ing work b.
Obsolete or superseded documents are removed from work areas and replaced by. applicable revisions in a. timely manner 6.2.5 Master lists or' equivalent controls are used to identify the current revision of instructions, procedures, specifications, drawings and procurement documents. When master lists are used they are updated and distributed to designated personnel who are responsible for.
maintaining current copies of the lists..
6.2.6 Accurate as-built drawings (record drawings) and related documentation are prepared in a timely manner.
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Page 35 Rev 10 Date: 10/1/89 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1 POLICY Activities that implement approved procurement requests for safety-f related material, equipment and services are contr'olled to assure conformance with procurement document requirements. Controls include I
a system of supplier ev'aluation and selection, source inspection, examination and acceptance-of items and documents upon delivery, and periodic assessment of supplier performance. Objective evidence of I
quality that demonstrates conformance with specified procurement document requirements is available to the nuclear power plant site prior to use of equipment, material or services.
7.2 IMPLEMENTATION 7.2.1 Authority and responsibility for implementing the controls outlined i
I herein are described in Section 1.0, ORGANIZATION.
l 7.2.2 CP Co qualifies suppliers by performing a documented evaluation of I
their capability to provide items or services specified by procurement documents. To remain qualified, suppliers involved in active procure-ments are reevaluated annually and are audited triennially.
If the I
Coordinating Agency for Supplier Evaluation Register is used to establish the qualifications of the Supplier, the documentation identifies the audit used.
Evaluation of suppliers holding applicable ASME Certificates of Authorization is done by reference to the current I
ASME listing of certificate holders.
Supplier evaluation and triennial audits are not necessary when the items or services supplied are all of the following:
Relatively simple and standard in design, manufacture and test, i
a.
and b.
Adaptable to standard or automated inspections or tests of the end g
product to verify quality characteristics after delivery, and Such that receiving inepection does not require operations that c.
could adversely affect the integrity, function'or cleanness of the item.
In the above cases, source and/or receipt inspection provides the necessary assurance of an. acceptable item or service.
I i
7.2.3 Supplier activities that affect quality-are verified in accordance with writtan procedures. These procedures provide the method of verifying (such as audit, surveillance or inspection) and documenting f
that the characteristics or processes meet the requirements of the procurement document. For commercial "off-the-shelf" items where the requirements for a specific quality assurance program appropriate for
'i nuclear applications cannot be imposed in a practical manner, source 1
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verification is used to provide adequate assurance of acceptability unless the quality of the item can be adequately verified upon i
receipt.
7.2.4 Spare and replacement parts are procured in such a manner that their performance and~ quality are at least equivalent to those of the parts i
that will be replaced.
a.
Specifications and codes referenced in procurement documents for I
spare or replacement items are at least equivalent to those for the original items or to properly reviewed and approved revisions.
b.
Parts intended as spares or replacements for "off-the-shelf" items, or other items for which quality requirements were not E
originally specified, are evaluated for performance at least 3
equivalent to the original.
c.
Where qualicy requirements for the original items cannot be j
determined, requirements and controls are established by engineer-1ng evaluation performed by qualified individuals.
The evaluation assures there is no adverse effect on interfaces, interchangeabil-ity, safety, fit, form, function or compliance with applicable
. regulatory or code requirements. Evaluation results are documented.
d.
Any additional or modified design criteria, imposed after previous procurement of the item (s), are identified and incorporated.
7.2.5 Receipt inspections are performed to verify that items are undamaged and properly identified, that they conform with safety-related pro-curement requirements not previously verified by source surveillance E
or inspection and that required supplier furnished documentation is W
available.
Items inspected are identified as to their acceptance status prior to their storage or release for installation.
i 7.2.6 Suppliers are required to furnish the following records:
a.
Applicable drawings and related engineering documentation that identify the purchase 1 item and the specific procurement require-ments (eg, codes, standards and specifications) met by the item.
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b.
Documentation identifying any procurement requirements that have not been met.
c.
A description of those nonconformances from the procurement requirements dispositioned " accept as is" or " repair."
L d.
Quality records as specified in the procurement requirements.
The acceptability of these documents is evaluated during source and/or receipt inspection.
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U.2,7 Supplier's certiff. cates of conformance are periodically evaluated by j
audits, independent inspections or tests to assure that they are valid. The results of these evaluations are documented.
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8.0 IDI:NTIFICATION AND CONTROL OF ITDtS i
8.1 POLICY
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Safety-related materials, parts and components (items) are identified and controlled to prevent their inadvertent use.
'dentification of ltems is maintained either on the items, their stor:3s areas or t
containers or on records traceable to the items.
8.2 IMPLEMENTATION
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I 8 2.1 Controls are established that provide for the identification and control of materials (including consumables), parts and components.
(including partially fabricated assemblies).
Responsibility for the identification and control of items is described in Section 1.0, ORGANIZATION.
8.2.2 Items are identified by physically marking the item, its storage area or its container or by maintaining records traceable to the item. The method of identificStion is such that the quality cf the item is not degraded.
8.2.3 Items are traceable to applicable drawings, specifications or other g
pertinent documents to ensure that only correct and acceptable items
!g are used. Verification of traceability is performed and documented prior to release for fabrication, assembly or installation.
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9.0 CONTROL OF SPECIAL PROCESSES I
4 9.1 POLICY Special processes affecting safety-related structures, systems and components are controlled and are accomplished by qualified personnel using qualified proceduros and equipment in accordance with applicable codes, standards, specifications, criteria and other special require-ments.
9.2 1MPLEMENTATION
(
9.2.1 Processes subject to special process controls at CP Co are those for which full verification or characterization by direct inspection is impossible or impractical.
Such processes include welding, heat treating, chemical cleaning, application of protective coatings, concrete placement and nondestructive examination.
9.2.2 Organizational responsibility for implementation of special processes and for qualification of procedures, personnel, and equipment used to perform special processes is indicated in Section 1.0, ORGANIZATION.
9.2.3 Special process procedures are prepared by personnel with expertise in-the discipline involved. The procedures are reviewed for technical adequacy by other personnel with the necessary technical competence, and are qualified by testing, as necessary.
9.2.4 Special process personnel qualification is determined by individuals authorized to administer the pertinent examinations.
Certification is
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based on examination results. Personnel qualification is kept current by performance of the special process (es) and/or reexamination at time intervals specified by applicable codes, specifications and standards.
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Unsatisfactory performance or, where applicable, failure to perforr within the designated time intervals requires recertification.
9.2.5 For special processes that require qualified equipment, such equipment is qualified in accordance with applicable codes, standards and specifications.
9.2.6 Qualification records are maintained in accordance with QAPD Section 17.
9.2.7 The Quality Assurance Department audits special process qualification activities and performs inspection and survaillance of special pro-cesses to assure they are satisfactorily performed when specified by applicable inspection planning and/or site procedures. Such inspection and surveillance includes verification that procese data are recorded as required, are within specified limits and are performed in accor-dance with applicable requiremente.
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Rev 10 Datet 10/1/89 10.0 INSPECTION l
10.1 POLICY l
Activities affecting the quality of safety-related structures, systems and componet.ts are inspected to verify their confermance with require-ments. These inspections are performed by peop3e other than those who perform the activity being inspected.
Direct inspection, process monit; ring, or both, are used as necessary.
Hold points are used as necessary to ensure that inspections are accomplished at the correct points in the sequence of work activities.
10.2 IMPLEMENTATION 10.2.1 Organizational responsibilities are as described in Section 1.0, ORGANIZATION.
10.2.2 Inspections are applied to procurement, maintenance, modifics. tion, testing, fuel handling and inservice inspection to verify that items and activities conform to specified requirements. Work authorizing documents (ag; procedures, instructions, maintenance work orJers) are reviewed in accordance with established criteria to do the following as necessary:
a.
Determine the need for inspection (s).
b.
Identify the inspection organization, c.
Identify Hold and Notification points.
d.
Determine how and when the inspections are to be performed.
l e.
Specify measuri.g and test equipment of the necessary accuracy for j
performing inspection.
f.
Provide for documentation of inspection results to provide ade-quate objective evidence of acceptability.
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Inspection is performed at each operation where it is necessary to
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verify quality.
Process monitoring is used in whole or in part where direct inspection l
alone is impractical or inadequate.
l 10.2.3 Training and qualification programs for personnel who perform inspec~
tions, including nondestructive examination, are established, imple-mented and documented in accordance with Section 2.0, QUALITY ASSURANCE PROGRAM.
These programs meet the requirements of applicable codes and standards. The Quality Assurance Departoont reviews and concurs with any such programs that are not under its direct responsi '
bility. Qualifications and certifications of inspection and NDE personnel are maintained.
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i 10.2.4 Inspection requirements are specified in procedures, instructions, drawings or checklists and are e.ither provided or concurred with by the authorized inspection p1 mning organization.
They (procedures, etc) provide for the follwing as appropriates a.
Identification of applicable revisions of required instructions, drawings and specifications.
m.
g1 b.
Identification of characteristics and activities to be inspected.
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c.
Inspection methods.
d.
Specification of measuring and test equipment having the necessary j
i accuracy.
e.
Identification of personnel responsible for performing the inspec-ticn.
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Acceptance and rejection criteria.
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Recording of the inspection results and the identification of the l
inspector.
i 10.2.5 Inspection points are designated as mandatory hold points by designat-3' ed inspection personnel when confirmation is needed that the work g:
accomplished up to that point is acceptable before she verk can be allowed to proceed further. Hold point inspections are performed, and work is released for further processing or use, by designated inspec-l tion personnel.
Hold points may be waived only by the designated inspection planning organization.
10.2.6 Inspections are performed and documented in accordance with the l
written instructions provided. The results are evaluated by designat-ed personnel in order to ensure that the results substantiate the g,'
acceptability of the item or work.
Evaluation and review results are 5
documented.
10.2.7 Inspection of work associated only with nn. sal operation of the plant.
l such as surveillance tests and verifications of routine maintenance ts ;
may be performed by individuals in the same group as that which performed the work, but not by personnel who directly performed or r
supervised the work. Peer inspection is acceptable provided a.
The quality of the work can be demonstrat i through a functional
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test when the work involves breaching r p eswure retaining item.
b.
The qualification criteria for ths inspection personnel have been reviewed and found acceptable by the Quality Assurance Department.
Minimum criteria are that individuals performing inspection must g]i possess qualifications et least equal to those of the pe'rsons authorized to perform the task (s) that will be inspected.
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11.0 TEST CONTROL l
11.1 POLICY Testing is performed in accordance with established programs to demonstrate that safety-related structures, systems and components will perform satisfactorily in service.
The testing is performed in I
accordance with written procedures that incorporate specified require-ments and acceptance criteria. The test program includes qualifica-tion (as applicable), acceptance, pre-operational, start-op.
I surveillance and maintenance tests. Test parameters, including any prerequisites, instrumentation requirements and environmental condi-tions are specified and met. Test results are documented and evaluated.
i 11.2 IMPLEMENTATION
-h 11.2.1 Organizational responsibilities for terting are described in B
Section 1.0, ORGANIi'ATION.
I Tests are performed in accordance with programs, procedures and 11.2.2 criteria that designate when tests are required and how they are to be performed.
Such testing includer the followingt Qualification tests, as applicable, to verify design adequacy in a.
accordance with Section 3.0, DESIGN CONTROL.
l b.
Acceptance teass of equipment and components to assure el.eir B
proper operation prior to delivery or to pre-operational tests.
I Pre-operational tests to ass *2re proper and safe operation of c.
systems and equipment prior to start-up tests or operations.
d.
Start-up tests, including precritical, criticality, low-power and power ascersion tests, perforted af ter refueling to assure proper p
and safe operation of systems and equipment.
Surveillance tests to assure continuing proper and safe operation
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of systems and equipment.
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Maintenance teste after preventive or corrective maintenance.
I 11.2.3 Test procedures and instructions include provisions f ar the following.
as applicable:
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The requirements and acceptance limits centained in applicable a.
design and procurement documents.
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b.
Test prerequisites such as calibrated instrumentation, adequate test equipment and instrumentation including accuracy require-ments, completenesa of the item to be tested, euitable and con-l trolled environmental conditions and provisions for data 3 {
g collection and storage.
c.
Instructions for performing the test.
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Mandatory inspectica hold points for witness by the appropriate i
authority.
e.
Acceptance and rejection criteria.
f.
Methods of documenting or recording test data and results.
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Assuring that tast prerequisites have been met.
h.
QA verification of completion of modification ac tivities.
Test procedures and instructions are rJviewed by the engineering organisations for technical content and by the Qualfty Assurance 3
Department for QA aspects.
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11.2.4 The. Quality Assurance Department verifies, through audits, inspection and surveillances, that test results are documented, evaluated and l
their acceptability is determined by responsible personnel.
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1.'!. 0 CONTROL OF MEASURING AND TEST EQUlPMENT 12.1 POLICY Measuring and testing equipment used in activities affecting the quality of safety-related systems, components and structures are properly identified, controlled, caliterated and adjusted at specified intervals to maintain accuracy within necesesry limits.
9 12.2 IMPLEMENTATION 12.2.1 The authority.and responsibility of personnel establishing, imple-menting and assuring effectiveness of calibration programs is de-scribed in Section 1.0, ORGANIZATION.
12.2.2 Procedures are established for measuring and test equipment utilized in the neasurement. inspection and monitoring of structures, syatema I
and components. These procedures describe calibration technique and frequency and maintenance and control of the equipment.
I 12.2.3 Measuring and test equipment te uniquely identified and is traceable to its ca31bration source.
g 12.2.4 CP Co uses a system of labels to be attached to measuring and test g
equipment to display the next calibration due dar. k'here labels cannot be attached, a control system $s used tha. identifies to potential users any equipment beyond the ca3tbration due date.
12.2.5 Measuring and test equipment (M&TE) and installed plant instrumenta-tion is calibrated at specified intervals bated on the required I
accuracy, purpose, degree of usage, utability characteristics, and other conditions affecting the measurement.
Calibration of M6TE is against standards that have an accuracy of at least four times the required accuracy of the equipment being cali-brated or, when this is not ptrelble, have an accuracy that assures the equipment being calibrated vill be within required tolerance and
'I the basis of acceptance is documenced and authorized by responsible management.
Calibration standards used for installed plant instrumentation shall normally have greater accuracy than the instrumentation being cali-brated.
Standards with the same accuracy may be used when shown to be adsquate for specific calibration, requirements.
The basis for this accepte.nce is iocumented and is approved by responsible management.
12.2.6 Calibrating su idards have greater accuracy than standards being calibrated. Calibrating standardt with the same accuracy may be used if it can be shown to be adequate for the requirements and the basis of acceptance is documented and authorized by responsible sanagement.
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Date: 10/1/80 12.2.7 Reference and tran.sfer standards are traceable to r.ationally recog-l nited standardst where national standards do not exist, provisions are p 1 established to document the basis for calibration.
j 12.2.8 k' hen measuring and testing equipment used for inspection and teot is found to be outside of rerguired accuracy limits at the time of cali-
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bration, evaluations are conducted to determine the validity of the j
i results obtained since the most recent calibration. The results of evaluations are documinted. Retests or reinspections are performed on suspect items.
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.tet 10/J/81 13.0 HANDLING STORAGE AND SHIPPING
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13.1 POLICY Activities with the potential for causi1g contamination or deteriera-tion that could adversely affect the ability of a safety-related item to perform its intended.afety functions, and activities necessary to prevent undetected or uncorrectable damage are identified and con-trolled. These activitiea include cleaning, packaging, preserving, handling, ehipping and sto*?ng. Contro1r ate effected through the use of appropriate procedures end instructions implemented by suitably trained personnel.
13.2 IMPLEMENTATION r'
13.2.1 The r.uthority and responsibility of personnel implementing and assur-(
ing the effectiveness of material cleaning, handling, storing, packag-ing, preserving and shipping activities is described in Section 1.0, ORGANIZATION.
13.2.2 Procedures are used to control the cleaning, handling, storing, packaging, preserving and shipping of materia'.s. components and systems in accordance with design and procurement requirements. These procedures include, but are not limited to, the following functions:
a.
Cleaning, to assure that required cleanliness levels are achieved and maintained.
b.
Packaging and preservativn, to provide edequate protection against damage or deterioration.
k' hen necessary, these precedures provide for special environments such as inert gas atmospheres, specific moisture content levels and temperature levels, c.
Handling, to preclude damage or safety hazards.
d.
Storing, to minimize the possibility of Irse, damage to or deteri-oration of items in storage, including consumables such as chemi-cals, reagents and lubricants.
Storage procedures also provide methods to assure that specified shelf lives are not exceeded.
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14.0 INSPECTION, TEST AND OPERATING STATUS 14.1 POLICY Operating status of safety-related structures, systems and components is indicated by tagging of valves and switches, or by other specified means, in such a manner es to prevent inadvertent operation. The etatus of inspections and tests performed on individual items is
,1early indicated by markings and/or logging under strict procedural controls to prevent inadvertent bypassing of such inspections and tests.
14.2 1MPLEMENTA' LION 14.2.1 Organizational responsibilities are as described in Section 1.0, ORGANIZATION.
I 14.2.2 For modificat.on activities, including item fabrication, installation and test, procurement documents. service contracts and procedures specify the degree of control required for the indication of inspec-tion and test a.iatus of structures, systemt and components.
14.2.3 Applicetion and removal of inspection and welding stamps and of such status indicators as tags, markings, labels, etc, are controlled by procedures.
14.2.4 The sequence of inspections, tests and other operations important to l
safe:y are controlled by procedures. Changes in the approved sequence l
are subject to the same review and approval as the original.
14.2.5 The status of nonconforming, inoperable or malfunctioning structures, systems and components is clearly identified and documented to prevent inadvertent use.
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'15.0 NONCONPORMING MATERIALS, PARTS OR COMPONENTS l
15.1 POLICY
- afet) related materials, parts or components that do not conform to requirements are controlled in order to prevent their ina' ertent use.
Nonconforming items are identified. docueenved, segregated when I
practical and dispositioned. Affected organizations are notified of noncunformances.
15.2 1MPLEMENTATION 15.2.1 Items, services or activities that are deficient in characteristic, 3
documentation or procedure, which render the quality unacceptable or g
indeterminate, are identified as ncnconforming and any further use is controlled. Nonconformences are docutanted and dispositioned, and notification is made to affected organizations.
Personnel authorized I
to disposit?.on, conditionally release and clore out nonconformances are designated. The authority and responsibility for the implementa-tion of activities related to the processing and control of noncon-forming materials, parts or con.ponents are described in Section 1.0, ORGANIZATION.
Nonconforming items are identified by marking, tagEing or segre~
~I a.
gating or by documented
'.ministrative controls.
Documentation describes the nonconformance, the disposition of the nonconfor-mance and the inspection requirements.
It also includes signature approval of the disposition.
b.
The original insper. tion planning authority reviews the dicposition of nonconformances, and documents concurrence with the acceptance, conditional release or repair of a nonconforming item.
c.
Items that have been repaired or reworked t.re inspected and tested l
in accordance with the original inspection and test equirements F
or alternatives that have been documented as acceptable and concurred with by the original inspection planning authority.
d.
Items that have the disposition of "r* pair" or "use as is" require documentation justifying acceptability. The changes are recorded to denote the as-built condition.
The Quality Assurance Department reviews "use as is" or " repair" e.
dispositions which result in deviation from original design or specification requirements.
i 15.2.2 Dispositions of conditionally released its are closed out before the j
items are relied upon to perform safety-re.ated functions.
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E Date: 10/1/89 15.2.3 Prior to the initiation of preoperational testing on an item, all i
nonconformances are corrected or dispositioned and evaluated for l
i impact upon the item or the testing program.
I 15.2.4 Nonconformsnee reports are analyzed to identify quality trends. Trend l
reports, which highlight significant results, are issued periodically Il-to upper management for review and assessment.
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are identified promptly and corrected as soon as practical.
For significant conditions adverse to quality, the cause of the condition is aetermined and corrective action is taker to preclude repctition. In these caser, the condition, cause and corrective action taken is documented and reported to appropriate levels of management for review and assessment.
16.2 IMPLEMENTATION l
16.2.1 The responsibility and authority for the control of corrective action N
an described in Sectien 1.0, ORGANIZATION.
16.2.2 controls are established to assure that conc'.ti. us adverse to quality are identified and documented and that appro-ee remedial action is taken.
16.2.3 For significant conditions adverse to quality, necessary corrective action is promptly determined and recorded. Corrective action in-cludes determining the cause and extent of the condition, and taking appropriate acticn to preclude simf.lar problems in the future. The controls also atsore that corrective action is implemented in a timely manner. The Quality Assurance Department reviews and documents concurrence with actions taken to prevent recurrence of significant conditions adverse to quality, performs follow-up to verify proper implementation and determines if additional action (such as audit or surveillance) is nee.essary to verify the effectiveness of action (e) taken.
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Pcge 57 Rev 10 Date: 10/1/89 17.0 QUALITY ASSURANCE RECORDS 17.1 POLICY Records that furnish evidence of activitios affecting the quality of safety-related structures, systems and contponents are maintained.
They are accurate, complete and legible arid are protected against damage, deterioration or loss.
They are identifiabla and retrievable.
17.2 IMPLEMENTATION j
17.2.1 Responsibilities for the identification and control of QA records are described in Section 1.0, ORGANIZATION.
17.2.2 Document.s that furnish evidence of activities af fectin3 quality are generated and controlled in accordance wi n the procedures that govern those activities. Upon completion, triese ilocuments are considered records. These records include Results of revievs uspections, surve:'.31ances, tests, audits ar.d a.
material analyses b.
Qualification of personnel, procedures and equipment c.
Operating logs d.
Maintenance and modification proceduru and related inspection resulto e.
Reportable occurrences f.
Records required b,
'he plant technical specifications g.
Nonconformance reports h.
Correctivt action reports 1.
Other documentation such as drawings, specifications, procurement documents, calibration proc +:dures and ieports 17.2.3 Inspe: tion and test records contain the fol. lowing where applicable a.
A description of the type of observation b.
The date and results of the inspection or test Information related to conditions adverse to qt.ality c.
9; 3
d.
Inspector or data. recorder identification Evidence as to the acceptability of the results e.
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Action taken to resolve any discrepancies noted j
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17.2.4 When a documet.t becomes a record, it is designated as permanent or nonpermanent and then transmitted to file. Nonpermanent records have specified retention times. Pernenent records are maintained for the Wi life of the item.
i 17.2.5 Temporary storage of completed documents during processing to become records is in special fire-resistant file cabinets.
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17.2.6 Only authorized personnel may issue corrections or supplements to j
records.
l 17.2.7 Traceability between the record and the item or activity to which it g
a applies is provided.
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17.2.8 Records are stored in remote, dual facilities to prevent damage, deterioration or 1cas due to natural or unnatural causes.
Records that can only be stored as originals, such as radiographs and some strip charts are retained in a four-hour fire-rated facility.
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18.0 AUDITS 18.1 POLICY A ccmpreheneive system of audits is carried out to provide independent evaluation of compliance with and the effectiveness of the Quality Assusance Program, including those elements, of the program implemented
.I by suppliers and contractors. Audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibility in the areas audited. Audit results are docu-I mented and are reviewed by management.
Follow-up action is taken where indicated.
18.2 1MPLEMENTATION 18.2.1 Responsibility and authority for the audit program is described in 1
Section 1. 0, ORGANIZATION.
18.2.2 Internal audits are performed in accordance with established schedules that reflect the status and importance to safety of the activities I
being performed. All areas where the requirements of 10 CFR 50 Appendix B apply are audited within a period of two years. The following are audited at least once evety 12 months:
I Conformance of facility operations with applicable conditions of a.
the technical specifications and license b.
The performance, training and qualifications of the facility stafi Controls over plant modifications, including the frequency, c.
ef fectiveness and technical adequacy of the use of supervisors as design verifters.
18.2.3 Audits of suppliers and contractura are scheduled based on the status I
and safety importance of the activities being performed and are initiated early enough to assure effective quality assurance during design, procurement, manufacturing, construction, installation, inspection and testing.
18.2.4 Principal contractors are required to audit their suppliers systemat-ically in accordance with the foregoing scheduling criteria.
18.2.5 Regularly scheduled audits are supplemented by special audits when significant changes are made in the Quality Assurance Program, when it is suspected that quality is in jeopardy or when an independent assessment of program effectiveness is considered necessary.
18.2.6 Audits include an objective evaluation of quality-related practices, procedures, instructions, activities and items and review of documents and records to confirm that the QA Program is effective and properly implemented.
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Date: 10/1/89 18.2.7 Audit procedures and the scope, plans, checklists and results of El individual audits are documented.
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18.2.8 Personnel selected for auditing assignments have experience or are f
given training commensurate with the needs of the audit and have no direct responsibilities in the areas audited.
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18.2.9 Audit data are analyzed by the Quality Assurance Department. The resulting audit reports identify any quality deficiencies and assess the effectiveness of the QA Program in the area audited.
The reports are distributed to the responsible management of both the audited and g,
auditing organizations.
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18.2.10 Management of the audited organization identifies and takes appropri-ate corrective action to correct observed deficiencies and to prevent recurrenys of any significant conditions adverse to quality. Follow-up is i,ertermed by the Quality Assurance Department to ensure that the apprbpriate corrective action is taken and is effective.
Such fol-low-up includes reaudits when necessary.
18.2.11 A*4dits of operational nuclear safety-related facility activities, shall g
be performed under the cognizance of Nuclear Safety Services Depart-g ment.
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QAPD MANUAL APPENDIX A. PART 1 s
- EGULATORY GUIDE AND ANSI STANDARD COMMITMENTS I
The Consumere Power Company Quality Assurance Program complies with the regulatory position of the Regulatory Guides referenced ir this appendix as I
modified by the exceptions stated in Part 2.
1.
Appendix B to 10 CFR, Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
2.
10 CFR, Part 50.55c - Codes and Standards.
3.
Regulatory Guide 1.8 - (9/80 Draft) - Personnel Qualification and Train-ing - Endorser. ANSI /ANS 3.1 - (12/79 Draft).
4.
Regulatory Guide 1.26 - (2/76. Rev 3) - Quality Group Classification, and Standards for Water, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants.
5.
Regulatory Guide 1.29 - (9/78, Rev. 3) - Seismic Design Classification.
g 6.
Regulatory Guide 1.30 (Safety Guide 30) - (8/11/72) - Quality Assurance g
Requirements for the Installation Inspection, and Testing of Instrumen-tation and Electrical Equipment - Endorses ANSI N45.2.4 - 1972.
l 7.
Regulatory Guide 1.33 - (2/78, Rev 2) - Quality Assurance Program Re-B quirements (Operation) - Endorses ANSI N18.7 - 1976.
8Property "ANSI code" (as page type) with input value "ANSI N18.7 - 1976.</br></br>8" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Regulatory Guide 1.37 - (3/16/73) - Quality Assurance Requirements for I
Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.1 - 1973.
l 9.
Regulatory. Guide 1.38 - (5/77. Rev 2) - Quality Assurance Requirements B
fct Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.2 - 1972.
10.
Regulatory Guide 1.39 - (9/77. Rev 2) - Housekeeping Requirements for Water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.3 - 1973.
11.
Regulatory Guide 1.58 - (9/80, Rev 1) - Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel - Endorses N45.2.6 1978.
12.
Regulatory Guide 1.64 - (6/76, Rev 2) - Quality Assurance Requirements for the Design Of Nuclear Power Plants - Endorses N45.2.11 - 1974 13.
Regulatory Guide 1.74 - (2/74) - Quality Assurance Requirements Terms and Definitions - Endorses ANSI N45.2.10 - 1973.
PD1081-05350-QA06
Pcge 62 Rev 10 Dste: 10/1/89 l5l
- 14. Regulatory Guide 1.88 - (10/76. Rev 2) - Collection. Storage, and Mainte-i nance of Nuclear Power Plant Quality Assurance Records - Endorses N45.2.9 i
- 1974.
- 15. Regulatory Guide 1.94 - (4/76 Rev 1) - Quality Assurance Requirements for Installation Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants -
Endorses ANSI N45.2.5 - 1974.
16.
Regulatory Guide 1.116 - (5/77) - Quality Assurance Requirements for Installation Inspection, and Testing of Mechanical Equipment and gj Systems - Endorses ANSI N45.2.8 - 1975.
g 17.
Regulatory Guide 1.123 - (7/77. Rev 1) - Quality Assurance Requitements for Control of Procurement of Items and Services for Nuclear Power Plants - Endorses N45.2.13 - 1976.
- 18. Regulatory Guide 1.144 - (9/80, Rev 1) - Auditing of Quality Assurance j
Programs for Nuclear Power Plants - Endorses N45.2.12 - 1977.
- 19. Regulatory Guide 1.146 - (8/80) - Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants - Endorses N45.2.23 -
)
1978.
20.
Branch Technical Position ASB9.5.1 (Rev 1) Guidelines for Fire Protection l
for Ntelear Power Plants.
l 21.
10CFR50, Appendix R. Fire Protection Program for Nuclear Power Facilities ll Operating Prior to January 1, 1979. Sections III G.,
III J. and III O.
W I:
I' I:
I
.I!
I I
PD1081-0535C-QA06
Pcge 63 Rev 10 Date: 10/1/89
(
QAPD MANUAL APPENDIX A. PART 2 CP CO EXCEPTIONS TO OPERATING PRASE STANDARDS AND REGULATORY GUIDES 1.
General Requirament Certain Regulatory Guides invoke or imply Regulatory Guides and stan-dards in addition to the standard each primarily endorses.
Certain ANSI Standerds invoke or imply additional standards.
Exception / Interpretation The CP Co commitment refers to the Regulatory Guides and ANSI Standards specifically identified in Appendix A. Part 1.
Additional Regulatory Guides ANSI Standards and similar documents implied or referenced in those specifically identified are not part of this commitment.
Imposition of these Regulatory Guides on CP Co suppliers and subtier suppliers will be on a cace-by-case basis depending upon the item or service to be procured.
2.
N!8.7 General Exception / Interpretation Consumers Power Company has established an organizational unit. Nuclear l
Safety Services Department (NSSD), for independent review activities.
l l
The standard numeric and qualification requirements may not be met by i
the NSSD.
Procedures will be established to specify how NSSD will I
acquire necessary expertise to carry out its review responsibilities in accordance with Plant Technical Specifications.
l j
2c.
N18.7. Sec 3.4.2 Requirement l
l "The Plant Manager shall have overall recponsibility for the execution of the administrative controls and quality assurance program at the l
plant to assure safety."
PD1081-0535C-QA06
lIi '
POge 64 Rev 10 Date: 10/1/89 i
Exception / Interpretation
.(
Since CP Co has more than one nuclear unit and more than one organiza-tion providing services to these units, overall responsibility cannot g,
be centralized in a single on-site position.
Instead, responsibilities 5!
are as designated within the QA Program Description.
l 2b.
Sec 4.3.1 Requirement l
" Personnel assigned responsibility for independent reviews shall be 3i specified in both number and technical disciplines and shall collec-l tively have the experience and competence required to review problems 3 ',
in the following areast..."
g Exception / Interpretation j
Nuclear Safety Services Department will not have members specified by W [
number or by technical disciplines and its members may not have the l
experience and competence required to review problems in all areas E ',
2 listed in this section; however, the NSSD will function as described in 5,
Plant Technical Specifications and will acquire the services of person-nel having such experience and con.petence as necessary.
2c.
Sec 4.3.4 l
Requirement
?
"The following subjects shall be reviewed by the independent review body:"
Es:ception/ Int erpretation la Subjects requiring review will be as specified in the Plant Technical Specifications.
m 2d.
Sec 4.3.4(3)
W Requirement g
gi
" Changes in the Technical Specifications or license amendments relating to nuclear safety are to be reviewed by the independent review body prior to implementation, except in those cases where the change is l';
identical to a previously reviewed proposed change.
W i PD1081-0535C-QA06 i
Pcgs 65 i
Rev 10
- I' Date: 10/1/89 J
4
)
Excepcion/ Interpretation The Nuclear Safety Services Department will not review Technical I
Specification Changes af ter NRC approval prior to implementation. Th e.
L basis for this position is that NSSD reviews all Technical Specification changes prior to submittal to the NRC.
'I 2e.
Sec 4.5 Requirement j
"1.*ritten reports of-audits gecified in ANSI N18.7 shall be reviewed by
~g.
the independent review body and by appropriate members of Managenent r
j including those having responsibility in the area audited."
Exception / Interpretation I
The indepencent review body reviews or arranges for reviews of those audits over which it has cognizance, in accordance with the individual plant Technical Specifications, f
Some of the QA audits required during the operational phase are in areas other than thone requiring independent review in accordance with
.I_
ANSI P18.7, Section 4.3.4.
e 2f.
Sec 4.5 Requirement I
Periodic review of the audit program nhall be performed by the indepen-dent review body or by a management representative at least semiannual-ly to assure that audits are being accomplished in accordance with requirements of technical specifications and of this standard.
Exception /Inteipretation t
I-(
I Audits of operctional nuclear safety related facility activities are performed under the cognizance of the offsite Nuclear Safety Services Department as describsi in individual plant technical specifications.
2g.
Sec 3.2.1 1.
Requirement "The responsibilities and authorities of the plant operating personnel shall be delineated."
I PD1031-Of350-7A06
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Exception /Interpretat_fon On-site personnel not directly associated with operating octivities, as defined in ANSI N18.7, Section 2.2, are not considered to be operating personnel.
c 2h.
Sec 5.2.2 Requirement
{
" Temporary changes, which clearly do not change the intent tf the E
approved procedure, shall as a minimum be approved by two asmbers of 5
'the plant staff knowledgeable in the areas affected by the procedures.
At least one of these individuals shall be the supervisor in charge of the shift and hold a senior operators. license on the unit affected."
ExceptiordInterpretation CP Co' conaiu rs that this requirement applies only to procedures identified in plant technical specifications. Temporary changes to these procedures shall be approved as deceribed in plant technical g
specifications.
B, 1
21.
Sec 5.2.6 Requirement I
l "In cases where required documsntary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.~14.
Until suitable documentary evidence is available to show the equipment or material is in conformance, affected 3) tystems shall be considered to be inoperable and reliance shall not be 3-pl.ced on such sr tems to fulfill their intended safety functions."
Exreption/ interpretation CP Co initiates appropriate corrective action when it is discovered that documentary evidence does not exist for'a t6st or inspection which E
is required to verify equipment acceptability. This action includes a B ;
technical evaluation of the equipment's operability status.
2j.
Sec 5.2.8 Requiremer-B_
l "A surveillance testing and inspection program...shall include the I
establishment of a' master surveillance schedule reflecting ti.e status of all planned inplant en
' lance tests and inspections."
g t
PD1081-0535C-QA06.
Pego 67 Rev 10 I
Date: 10/1/89 Exception / Interpretation Separate master schedules may exist for different programs such as ISI, Pump and Valve Testing and Technical Specification Surveillance Testing.
2k.
Sec 5.2.?3.1 Requirement I
"To the extent necessary, procurement documents shall require suppliers to provide a quality assurance program consistent with the pertinent requirements of ANS1 N45.2 - 1971."
Exception / Interpretation To the extent necessary, procurement documents require that the suppli-I er have a documented quality assurance program consistent with the pertinent requirements of ANSI N45.2 or other nationally recognized codes and standards.
21.
Sec 5.2.13.2 l
l Requirement I
ANSI N18.7 and N45.2.13 specify that where required by code, regulation or contract, documentary evidence that items conform to procurament requirements shall be available at the nuclear power plant site prior to installation or use of such items.
l Exception / Interpretation l
y The required documentary -;idence is available at the site prior to.
l use, but not necessarily prior to inste.11ation. This allows installa-t tion to proceed while any missing documents are being obtained, but precludes dependence on the item for safety purposes.
2m.
Sec 5.2.15 Requirement
~
l Plant pro edures e, hall be reviewed by an individual knowledgeable in I
the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable.
4 i
PD1081-05350-QA06
i Pago 68 Rev 10 Date: 10/1/S9 Exception / Interpretation Based on amplification providea in ANSI /ANS 3.2-1982, section 5.2.15, Consumers Power Company interprets that this requirement for routine 3g,'
followup review can be accomplished in several ways, including (but not limited to): documented step-by-step use of the procedure (such as occurs when the procedure has a step-by-step checkoff asso iated with l
it) or detailed scrutiny of the procedure as part of a documented training program, drill, simuletor exercise, or other such activity.
l 2n.
Sec 5.2.16 Requirement Records shall be made and equipment suitably marked to indicate cali-bration status.
Exception / Interpretation f
See Item 9c.
l 2o.
Sec 5.3.5(3)
Requirement Instructions shall be included, or referenced. [in maintenance proce-l dures), for returning the equipment to its normal operating status.
P
[
Exception / Interpretation At CP Co, equipment is returned to its normal operating status, ie, 3',
declared operable, by licensed Ope. rations Depar:: ment personnel, not g
Maintenance personnel. Operations personnel verify and document equipment operability through second level line-up verification or appropriate functicnal testing. Thus " maintenance procedures" do not l
contain or directly reference such instructions.
W L l2p.
Sec 5.3.5(4)
Requirement f
This section requires that where sections of documents such as vendor manuals, operating and maintenance instructions or drawings are incor-porated directly or by reference into a maintenance procedure, they.
shall receive the same level of review and approval as operat'ng l
l procedures.
Er l
3 PD1081-05350-QA06 4
3 W
Page 69 B
Rev 10 Date: 10/1/89 l-Exception / Interpretation Such documents are reviewed by appropriately qualified personnel prior I
to use to ensure that, when used as instructions, they provide proper.
and adequate inforuation to ensure the required quality of work.
Maintenance procedures which reference these documents receive the same level of review and approval as operating procedures.
3a.
RG 1.33, See C4a Requirement The results ef actions taken to correct deficiencies that affect I
nuclear safety and occur in facility equipment, structures, systems or method of operation are to be audited at least ence per six 'nonths.
1 Exception / Interpretation B
i The corrective action system trend reports are reviewed by the indepen.
dent review body.
In addition, the corrective action system is t.udited I
at least once every two years with additional audits and investigations performed as indicated necessary by the trend report reviews.
3b.
RG 1.33. Sec C4b Requirement i
The conformance of facility operations to provisions contained within the technical specifications and applicable license conditions - at least once per 12 months.
Exception / Interpretation Consistert with guidance presented in NRC letters dateJ March 29, 1983 (RLSpessard to JMTaylor) and January 30, 1984 (JGPartlow to RLSpessard),
Consumers Power Company interprets the commitment to audit technical i
specification / license conditions contained in 18.2.2(a) of thie QAPD, I
and in section 6.5.2.8(a) of both Palisades and Big Rock Point techni-l i
cal specifications, as follows:
i l
Consumers Power Company maintains a matrix that identifies all applica-ble Technical Specification line items to be audited. The matrix is j
updated annually to conform to approved Technical Specification chang-l During each 12 month period, e selected sample of line items in es.
i each of the following elements is audited:
1.
Limiting Conditions for Operation 2.
Limiting Safsty System Settings 3.
Reactivity Control Systems 4.
~ Power Distribution Limits i
S.
Instrumentacion I
i PDiO81-0535C-QA06 i
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iIi Pcgs 70 1
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Date: 10/1/89
-l 6.
Reactor Coolant Syctem j
7.
Emergency Core Cooling System 8.
Containment Systems l
9.
Plant Systems 3.*
l-10.
Electrical Power Systems g'
11.
Refueling Operations 12.
Special lests
- 13. Onsite Committee
- 14. Offsite Committee
- 15. Administrative controls Audits are scheduled so that a*.1 line items are covered within a maximum period o' 5 years. The audit period for any of the above elements may be reduced depending on Technical Specification compliance history.
4a.
ANS 3.l, General Exception /Intercretation The CP Co commitment in this QA Program Description to ANS 3.1 is g'
limited to those requirements which apply.to the trafning and qualifi-g cation of personnel perforting QA/QC functions.
Sa.
RG 1.8, C.3.1, General l
Exception / Interpretation The CP Co commitment in this QA Program Description is J hited to those requirements which apply to ths training and qualification of personnel performing QA/QC functions.
5b.
C1.2.2 Requirement i
"When an individual is hired to temporarily function as a plant employ-ee, such as for contracted services, evidence of previous education, g
experience and training should be provided and reviewed by the appro-3 priate professional-technical group loaders.
'the appropria:e group leaders should then determine the content for that individual's train-g.
ing, including plant-specific training.
is a minimum, each individual g
j should r::ceive General Employee Training."
Exception / Interpretation CP Co understands that this requirement applies both to CP Co employees from another site and to contract personnel who ar) temporarily as-g' signed to a nuclear power plant either as replacements for regular g
employees or to augment the staff during outages.
CP Co employees so L
t PD1081-05350-QA06
~
Pcge 71 l
Rev 10 1
Date: 10/1/89 assigned possess the required qualifications as a prerequisite to the assignat t and the review is waived.
The qualifications of contract personnel are reviewed and arrangements made for any necessary train-l ing. Temporarily assigned personnel requiring unescorted access 3
receive the site general orientation ca embodied in General Employee Training.
6a.
N45.2.1, Sec 3.1 Requirement N45.2.1 establishes criteria for classifying items into " cleanness levels," and requires that items be'so classified.
Exception / Interpretation Instead of using the cleanness level classification system of N45.2.1, I
the required cleanness for specific items and activities is addressed on a case-by-case basis.
l Cleanness is maintained, consistent with the work being performed, so 3
as to prevent the introduction of foreign material. As a minimum, cleanness inspections are performed prior to system closure. Fuch inspections are documented.
1 6b.
Sec 5 j
Requirement
" Fitted and tack-welded joints (which will not be immediately sealed by g
welding) shall be wrapped with polyethylene or other nnnhalogenated l
3 plastic film until the welds can be completed."
l Exception / Interpretation j
i CP Co sometimes uses other nonhalogenated material, compatible with the parent material, since plastic film is subject to damage and does not I
always provide adequate protection.
7a.
N45.2.2, General Requirement N45.2.2 establishes requirements and criteria for classifying safety-i related items into protection levels.
Exception / Interpretation f
Instead of classifying sa c' ted
..a into protection levele, controls over the,ukagi n s
- frg, alling and storage of such items are establisied on r.
tu-oasis with due regard for the PD1081-05350-QA06
Pogs 72 Rev 10 Date: 10/1/89 i
f item's complexity, use and sensitivity to damage.- Prior to
)
installation.or use, the items are inspected and serviced as necessary l
to assure that no damage or deterioration exists which could affect j
their function.
]
7b.
See 2.4 Requirement
".. 0ffsite inspection, examination or testing shall be audited and W
3 t
monitored by personnel who are qualified in accordance with N45.2.6."
Exception / Interpretation Offsite inspection, examination or' testing e.ctivities are audited or inspected by persons qualified snd certified in accordance with ANSI l
N45.2.23-1978, as endorsed by Reg Guide 1.146,'or ANSI N45.2.6, as endorsed by Reg Guide 1.58, respectively. Monitoring activities not involving audit or inspection may be c.onducted by persons trained and qua'ified to effectively carry out such tasks, but not necessarily certified to either ANSI N45.2.23 or N45.2.6.
7c.
Sec 3.4.1 and Appendix A, 3.4.l(4) and (5)
Requirement
"(4)... However, preservatives for inaccessible inside surfaces containing reactor coolant water shall be indicated to facilitate touch up.
L (5) The name of the pterervative used shall be the water flushable
)
type."
Exception / Interpretation I*
Based on comparison of these statements to ANSI /ASME NQA-2 1983, CP Co l-believes the intent was to establish the following as requirements-g.-
l (4)... However, preservatives for inaccessible inside su-faces of W
l pumps, valves and pipe for systems containing reactor coolant wate:
l shall be the water flushable type.
l g
l (5) The name of the preservative used shall be provided to facilitate touch-up..
7d.
Sec 3.9 and Appendix A 3.9 Regitirement "The item and the outside of containers shall be marked."
l (Further criteria for marking and tagging are given in the appendix.)
PD1081-0535C-QA06 1
l Page 73 Rev 10 Date: 10/1/89 Exception / Interpretation l
The.e requirements were originally written for items packaged and 3
shipped ro construction projects.
Full compliance is not always necessary in the case of items shipped to operating plants and may, in some cases, increase the probabil'ty of damage to the item. The requirements are implemented to the extent necessary to assure trace-ability ar.d integrity of the item.
7e.
Sec 5.2.2 Requirement "The inspections shall be performed in an area equivalent to the level of storage."
j Exception / Interpretation Receiving in6pection area environmental controls may be less stringent than storage environmental requirements for an item. However, such inspections are performed in'a manner and in an environment which do not endanger t,he required quality of the item.
7f.
Soc 6.2.4 Requirement "The use or storage of food, drinks and salt tablet dispensers in any storage area shall not be permitted."
Exception / Interpretation Packaged food for emergency or extended overtime use may be stored in material stock rooms. The packaging assures that materials are not j
contaminated.
Food will not be "used" in these areas.
7g.
Sen 6.3.4 Requirement "All items and their containers shall b'e plainly marked so that they are easily identified without excessive handling or unnecessary opening of crates and boxe.s."
Excertion/ Interpretation f>ee N45.2.2, Section 3.9 (Exception 7d.).
l'D1081-0535C-QA06 l
o Page 74 Rev 10 Date: 10/1/89 7h.
Sec 6.4.1 Requirement "Inspectiors and examinatiuns shall be performed and documented on a periooic basis to asettre that the integrity of the item and its con-tainer...is being maintained."
Exception / Interpretation l
The requirement implies that all inspections and examinations of items g'
in storage are to be performed on the same schedule.
Instead, the g
inspections and examinations are performed and documented in accordance with material storage rocedures which identify the characteristics to a
be inspected and include the required frequencies. These procedures g
are based on technical considerations which recognize that inspections and frequencies needed vary from item to item.
8a.
N45.2.3, Sec 2.1 Requirement gW' Cleanness requiremento for housekeeping activities shall be established on the basis of five' zone designations.
Exception / Interpretation Instead of the five-level zone designation system referenced in ANSI l
N45.2.3, CP Co bases its controls over housekeeping activities on a 5<
consideration of what is necessary and appropriate for the activity involved. The controls are effected through. procedures or instructions 3
which, in the case of maintenance or modifications work, are developed g-on a case-by-case basis.
Factors considered in developing the proce-dures and instructions include cleanliness control.. personnel safety.
fire prevention and protection, radiation control and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible. However, in preparing the3e proce-dures, consideration is also given to the recommendations of Section l
2.1 of ANSI N45.2.3.
9a.
N45.2.4, Sec 2.2
[
Requirement Section 2.2 establishes prerequisites which must be met before the 1
installatten, inspection and testing of insertaentation and electricci equipment may proceed. These prerequisites include personnel qualifi-cation, control of design, conforming and protected materials, and availability of specified documents.
I g
~
r
]
I:
1 i
Pcgs 75
)
Rev 10 I
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Exception /Interpretatig During the operations phase, this requirement is considered to be
,I applicable to modiff cations and initial start-up of electrica? equip-ment.
For routins er periodic inspection and testing, the prerequisite conditions will be tchieved as necessary, fb.
See 2.2(5)
Requiremenj Section 2.2(5) of ANSI N45.2.4 11stc documentc which are to be avail-able at the construction site.
Exception / Clarification All of the documents listed are not necessarily required at the plant site for instal]ction and testing.
CP Co assures that they are avail-able to the site as necessary.
I i
9c.
Sec 6.?.1 Roquirement
" Items requiring calibration shall be tagged or labeled on completion, g
indicatinE date of calibration and identity of person that performed
+
the calibration."
t Exception / Interpretation l
Frequently, phvsical size and/or location of Installed Plant Instru-mentation (IPI) mandates that calibration labels or tags not be affixed to IPI.
Instead, each instrument is uniquely identified and is trace-able to its calibration record.
t A scheduled calibration program assures that each instrument's calibra-I tion is current.
10a.
N45.2.5, Sec 2.4 l
Requirement
" Persons charged with engineering managerial responsibility of the inspection and testing organization at -he site in either a resident or non-resident capacity shall be certif'ed for Level III capability."
?
I l
e L
PD1081-0535C-QA06 C
.t.i
r Pago 76 "l
i Rev 10 Date: 10/1/89 Exception /__ Interpretation This standard (N45.2.5) was written for the constructicn phase of nuclear power plants; as such, it presumes significant activity in the g-areas of concrete and structural steel which do not generally occur at g
an operating plant. At Consumers Power, persons having engineering managerial responsibility for inspections and tests
- may be certified to Level III, or may meet other qualification criteria established for the position, including, but not limited to, nucleat power and manage,
i ment experience. For major modifications involving significant con-crete or structural steel work, the services of a properly qualified 3'
Level III individual will ba obtained in at least an advisory capacf.ty.
3,
- within the scope of N45.2.5 10b.
N45.2.5, Sec 2.5.2 E
i Requirement
.l "When discrepancies, malfunctions or inaccuracies in inspection and testing eq'tipment are found during calibration, all items inspected g'
with that eqdipment since the lart previous calibration shall be g
considered unacceptable until an evaluation has been made by the responsible atthority anc' appropriate action taken."
Exception'Interprctation CP Co uses the requirements of N18.7, Section 5.2.16, rather then g1 N45.2.5,'Section 2.5 2.
The N18.7 requirements are more'applici.ble to 3'
an operating plant.
10c.
Sec 5.4
' squiremenc
" Hand torque wrenches used for inspection shall be controlled and must be calibrated at least weekly and more oftet. if deemed necessary.
Impact torque wrenches used for inspection must be calibrated at least gl twice daily."
g Exception / Interpretation I;
Torque wrenches are controlled as measuring and test equipment in accordance with ANSI N18.7, Secxion 5.2.16.
Calibration intervals are based on use and calibration history rather than as per N45.2.5 1
I-I.
PD1081-0535C-QA06-n
' 1 i.
f
1 Pags 77 Rev 10 I
Datet 10/1/89 11a.
N45.2.6, Sec 1.2 Requirement j
"The requirements of this standard apply to personnel who' perform inspections, examinat.ons, and testa during fabrication prior to and during receipt of items at the construction site, during construction, I
during preoperational and start-up testing and during operational
[
phases of nuclear power plants."
Exception / Interpretation Qualification of plant personnel who are involved with testing associ-ated with plant operation is provided in specific plant specifications.
In addition, personnel participatin'3 in inspecticn or tecting who take data or make observations, where special' training is not required to I
perform this function, need not be o,ualified in accordat:ce with AUSI h45.2.6 but need only' be trained to the extent necess'ary te parform the assigned function.
12a.
RG 1.58. Sec'C.1 Requirement i
[
i "However, for qualification of personnel (1) who approve preoperation-al, start-up and operational test procedures and test results and (2)
I who direct or supervise the conduct of individual'preoperational, start-up and operational testo, the guidelines contained in Regulatory Guide 1.9, Personnel Selection and Training, should be folJowed in lieu of the Guidelines of AFSI N45.2.6 - 1978."
I Exception / Interpretation I
CP Co endorses this position, as also stated in lla, above, except that offsite support organizations involved in testing may apply ANSI j
N45.2.6.
Some of these departments have already developed their i
qualification programs based on ANSI N45.2.6, and provide services throughout the operations phase of CP Co Nucient Plants'.
12b.
Se.c C.5 l
I
'i Requiecment l
"In addition, the individual should be capable of reviewing and approv-s
,p ing inspection., examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, exmina-l tion and test objectives."
s PD1081- 0535C-QA06
)
~
a
i Pcgs 78 i
Rev 10 gI Date: 10/1/89 g]
I Exception / Interpretation hile a Level III individua) should be capable of reviewing and approv-ing inspection, examination and testing procedures and of evaluating gi I
the adequacy of such proceduros to accomplish the inspection, examina-3 tion and test objectivoa, this is not constrted by CP Co as requiring personnel who review, approve or evaluate such procedures to be certi-fied as Level III personnel.
12c.
Sec C.6 Requirement "Since only one set of recommandations is provided for the education 3
and experience of personnel, a commitment to comply with the regulatory 5
position of this guide in lieu of providing an' alternative to the recommendations of the standard means that.the specified, education and experiet:e recornendations of the standard will be followed."
Exception / Interpretation The sducation and experience recommen'.ations given in ANS; N45 2.6, i
Section 3.5 will be treated as such, sirce our qut.lificationiand certification program 1a based upon these recommendations, and more g ;'
3 s.tenificantly, upon satisfactory cc pletion of capability testing prio-to certification.
It is vur pust; an that a candidate.should not Le required to be a high school graduate or have earned the GED equivalent for the above reasons.
l' 12.d Sec C.10 Requirement t
"Use of the measures outlined in these actions to establish that an individual has the required qualifications in lieu of required educa-tion and experfence should result in documented evidence (ie, procedure and record of written test) demonstrating that the individual indeed p
does have comparable or equivalent ccmpetence to that which would be gained from having the required education and erperience.."
Exception /Inf.,erpre t,ation L
We will maintain documented' objective evidence that demonstrates that L
an individual does have " comparable" or " equivalent" competence to that L
which would be gained from having the required education and'experi-~
l ence. However, this may 1.ake the form of documentation other than
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" procedures and records of written test" such~as' documentation of oral tests and on-the-job performance demonstrations.
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N45.2.8, bec 2.7 Requirement Section 2.7 requires chat personnel performing inspection and test activities be qualified according to ANSI N45.2.6.
Exception /Inte ysg*ation See Exception /Incerpretation lla and 12a.
Test persvnnel who are part of the plent staff need not be certified to N45.2.6, provided they meet applicable qualification criteria of plant Technical Specifications.
13b.
Sec 2.9 L
Requirement Section 2.9 establishes prerequisites which must be met before the installation, inspection and testing of mechanical equipment may proceed. These prerequisites include personnel and procedure qualifi-cation, control of design, material selection and fabrication, and' availability of specified documents.
Exception / Interpretation During the operations phase, this requirement is considered to be applicable to modffications of me hanical equipment.
For routine or periodic inspection and testing, the prerequisites'will be achieved as l
necassary.
i 13c.
N45.2.8, Sec 2.9e i
l Requirement Section 2.9e of N45.2.8 lists documents relating to the' specific stage of installation activity which are to be available at the construction site.
Exception / Interpretation All of the documents licted are not nc essarily required g the plant site for installation und testing.
CP Co assures that the.y are avaf1-able g the site as necesaary.
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i 13d.
Sec 2.9c Requirement Evidence that engineering or design changes are documented and approved 1
shall be available at the construction site prior to installaM on.
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Equipment may be installed before final approval of engineering or design changes.
However, the system is rot declared operable until such changes are documented and approved.
13e.
Sec 4.5.2 l.
Requirement i
" Installed systems and components shall be cleaned, flushed and condi-g tioned according to the requirements of ANSI N45.2.1.
Special consid-g eration shall ne given to the following repirements:...."
(Requirements are given for chemical conditioning, flushing and process controls.)
Exceptioa/ Interpretation l$
Systems and components are cleaned, flushed and conditioned as deter-5, mined on a case-by-case basis. Measures are taken to help preclude the
+
need for cleaning, flushing and conditioning through good practices during maintenance or modification activities.
14a.
N45.2.9, Sec 5.4, Item 2 g.
Requiremeg Records shall not be stored loosely.
They shall be firmly attached in g,
l binders or placed in folders or envelopes for storage on shelving in 3l l
containers. Steel cabinets are preferred.
Exception / Interpretation i
Records are suitably stored in steel file cabinets or on shelving in contciners. Methods other than binders, folders or envelopes (for example, dividers) may be used to organize the records for storage.
l 14b.
Sec 6.2 E
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Requiremert "A list shall be main::ained designating those personnel who shall have access to the files."
t Exception / Interpretation Rules are established governing access to and control of files as-
[
provided for in ANSI N45.2.9, Section 5.3, Item 5.
These rules do not always include a requirement for a list of personnel who are authorized access.
It should be noted that duplicate files and/or microforms exist for general use and backup.
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RG 1.88, C2 Requirement "Two methods of protection of quality essurance records from the hazards of fire are described in Subdivision 5.6 of ANSI N45.2.9-1974.
NFPA No 232-1975... also contains provisions for records protection I
equiument and records handling techniques that provide protection from the hazards of fire. This nandard, within its scope of coverage, is considered by the NRC staff to provide an acceptable alternative to the I
fire protection provisions listed in Subdivision 5.6... When NFPA 232-1975 is used, quality assurtnce records should be classified as NFPA Class 1 records..."
Exception / Interpretation CP Ce adheres to ANSI N45.2.9-1974, Subdivision 5.o for the facility I
for permanent storage of non-duplicated records. Temporary storage of documents after completion and during processing as records is in file cabinets selected in accordance with provisions of NFPA 232-1975 for Clara 1 records (usually NFPA Class C, I hour or U1,-Class 350).
15a.
RG 1.64, C2 gquirement "Regardless of their title, individuals performing design verification I
should not (1) have immediate supervisory responsibility for the individual performing the design...."
Exception / Interpretation B
i CP Co follows the requirements of ANSI N45.2.11-1974, Section G.1, and i
the guidance of Section 3E4(a) of the Staudard Review Plan, with the f
I exception that use. of supervisors as design verifiers may be controlled by a procedure b "aad of individually approved in advance in each case (see Section 3.2.9, here.in). This approach is necessary to allov s.nall I
organizational units (having limited numbers of technically qualified staff, or having the only technically qualified staff available in the Company) the flexibility needed to most effectively accomplish their assigned tasks.
16a.
RG 1.144, See C3a(1)
Requirement This section requi n s that for operational phase actfvities, RG 1.33-I
" Quality Assurance Program Requiramants (Operctions.)" are to be fol-i loved.
One of the RG 1.33 requirementa is that the results of actions taken to correct deficiencies that affect nucir.ar safety and occur in f.icility equipment, structures, systems, or method of operation are to be audited at least once per six months.
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16b.
Sec C3a(2)
Re,quirement l
Applicable elements of an crganization's quality assurance program (for
" design and construction phase activities") should be audited at lenet annually or at least once within the life of the activity, whichever is shorter.
Exception / Interpretation Since most modifications are straightforward, they are not audited individually.
Instead, selected controls over modifications are i
audited periodically.
16c.
See C3b(1) l-E Requirement 3
l This section identifies procurement contracts which are exempted from l
being audited.
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_ Exception / Interpretation In addition to the exemptions of RG 1.144, CP Co considers that Author-ized Inspection Agencies, National Bureau of Standards or other State and Federal Agencies which may provide services to CP Co are not E'
required to be audited.
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17a.
N45.2.11 Sec 3.2.2 Requirement N45.2.13 requires that technical requirements be specified in procure-l!
ment documents by reference to technical requirement documents.
3
.Tr.chnical requirement documents are to be prepared, reviewed and released urder the requirements established by ANSI N45.2.11.
l Exceptfor./ Interpretation l
For replacement parts and materials", CP Co follows ANSI N18.7, Section l
5.2.13, subitem 1, which states:
"Where the original item or part is found to be commercially 'off the shelf' or without specifically l
identified QA requirements, spare and replacement. parts may be similar-g ly procured, but care shall be exercised to ensure ac leaet equivalent 3-performance."
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17b.
Sec 3.2.3 Requirement
" Procurement documents chall require that the supplier nave e document-ed quality assurance program that implements parts or all of ANSI N45.2 j
as well as applicable quality assurance program requirements of 'other i
nationally recognized codes and standards."
]
Exception /Interpretatioq Refer to Item 2k.
e 17c.
Sec 3.3(a)
Requirement Reviews of procurement documents chall be performed prior to release for bid and contract award.
Exception / Interpretation Documents may be released for bid or contract award Lefore completing the necessary reviews. However, these reviews are completed before the j
item er service is put into service or before work has progressed beyond the point where it would be impractical to reverse the action I
taken.
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17d.
Sec 3.3(b)
Requirement
- " Changes made in the procurement documents as a result of the bid
{
evaluations or precontract negotiations shall be.!ncorporated into the.
procurement documents. The review of such changes and their'effsets i
shall be completed prior to contract award."
Exception / Interpretation This requirement applies only to quality related changes (ie, changes to the procurement document provisions identified in ANSI N18.7, Section 5.2.13.1, Subitems 1 through 5.)
The timing of reviews will be the same as for review of the original procurement document.
17 e.'
Sec 7.5 Requirement i
" Personnel responsible for performing verification activities shall be qualified in ac.cordance with~ ANSI N45.2.6 as applicable."
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- Thus, personnel performing source verification audits may not be certified 3'
according to N45.2.6.
Personnel performing inspection as part of g
source verification will be certified to N45.2.6.
17f.
See 10.1 kequirement "Where required by code, regulation or contract requirement, documen-tary evidence that items confonn to procurement documents shall be available at the nuclear power plant site prior to installation or use g
of such items, regardless of acceptance methods."
g Exception / Interpretation l
l Refer to Itta 21.
I 17g.
Sec 10.3.4 (as modified by RG 1.123, C6e)
Requirement
" Post-installation test requirements and acceptance documentation shall i
be'autually established by the purchaser and supplier."
Exception / Interpretation l
In exercising its ultimate responsibility for its QA program, CP Co l
establishes post-installation test requirements, giving due considera-tion to supplier recommendations.
l 18a.
RG 1.26, General I
Requirement RG 1.26 establishes a system for classifying pressure boundary' iter.s into tour quality groups, which are then correlated with ASME B&PV Code and ANSI Standards requirements.
(However, RG 1.26 does not indicate which of the four quality groups are safety-related, and which are B
not.)
g E:.ception/ Interpretation RG 1.26 was used as a reference to establish piping system boundaries, but not for defining specific quality groups or making safety-related determinations. Regulatory Guide 1.29, subject to Exception /Iaterpreta-g' tion 20a, is used to determine what systems and equipment are g-safety-related.
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Branch Technical Position ASB9.5.1 and 10CFR50 Appendix R, Sections III G.,
III J. and III 0.,
General.
l Exception / Interpretation Fire protection measures, equipment and the individual plant Fire Protection Plans are in compliance with the NRC Safety Evaluation I
Reports and the required sections of 10CFR50 Appendix R except for the specific exemptions approved by the FRC.
20a.
RG 1.29, Sec C, Regulatory Position Rt;quirement The Regulatory Position states that the identified structures, systems, and components are to be designated Scismic Category I and should be designed to withstand the SSE.
Exception / Interpretation Both CP Co nuclear plants (Big Rock Point and Palisades) were designed, constructed and licensed based on criteria available prior to Revision 3 of this RegC atory Guide being it. sued.
The specific design criteria and seismic designations are reflected in the FHSR and FSAR, respec-I tively, and in other docketed analysis.
Thus, the design bases and seismic designations do not correspond to those of Regulatory Guide 1.29.
The criteria of this Regulatory Guide are used at CP Co primarily in the identification of systems, structures, and components to which the QA Program is applied (see 20b, below).
I 20b.
RG 1.29, General Requirement Apply pertinent Quality Assurance requirements of 10CFR50, Appe.ndix B.
Exception / Interpretation I
The pertinent QA requirements for these systems, structures and compo-nents will be determined in a graded manner using tools such as the plant specific Probabilistic Risk Assessment and the Technical Specifi-cations, and other docketed ar.alyses to determine the degree which Appendix B of 10CFR50 applies.
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