ML19343A559
ML19343A559 | |
Person / Time | |
---|---|
Site: | Arkansas Nuclear |
Issue date: | 10/10/1980 |
From: | ARKANSAS POWER & LIGHT CO. |
To: | |
Shared Package | |
ML19339B966 | List: |
References | |
APL-TOP-1A-01, APL-TOP-1A-1, APL-TOP-1A-R5, NUDOCS 8011180243 | |
Download: ML19343A559 (75) | |
Text
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Copy No./O GUALITY ASSURANCE MANUAL
<O OPERATIONS l
l SRKANSAS POWER & LIG H T t
HELPING BUILD ARKANSAS
'~O golllioA43 APL-TOP 1 A RE\ ISION: 5
a 4' UNITED STATES g g NUCLEAR REGULATORY COMMISSION
- a wAswincios. o. c. 20sss j8 MAY 0 51980 0f .....
Mr. David Trimble Manager, Licensing Arkansas Power & Light Company
th & Louisiana Streets L4ttle Rock, AR 72203
Dear Mr. Trimble:
SiTdJECT: NRC ACCEPTANCE OF REVISED ARKANSAS POWER & LIGHT COMPANY'S QUALITY ASSURANCE TOPICAL REPORT The Trimble/Haass letter of June 11, 1979 submitted Revision 5 to Arkansas Power &
Light Company's (AP&L) topical report, APL-TOP-1A, " Quality Assurance Manual -
Operations," for staff review and approvcl. Subsequent page changes were submitted via letters dated January'9 and 16, and March 31, 1980. Revision 5 revises the topical report to reflect organizational changes, commitments to the latest regula-tory guides, and editorial changes.
Based on our review and evaluation of Revision 5, we find that all applicable require-ments of Appendix B to 10 CFR Part 50 are included in the QA program requirements.
Therefore, your revised topical report is acceptable, and you may implement it imme-diately. To use the topical report in license applications, AP&L need only reference q this topical report in Section 17 of the Safety Analysis Report. We do not intend to V repeat our review of this topical report when it is r'eferenced in an application.
AD&L's exception to Section C, 52 of Regulatory Guide 1.123 is considered an open item. A staff position on this subject (i.e., utilization of ANSI N45.2.13 in con-junction with Code requirements) will be transmitted at a later date.
Should regulatory criteria or regulations change such that our conclusions about this topical report are invalidated, we will notify you. You vill be given the oppor-tunity to revise and resubmit it should you so desire. Programmatic changes by AP&L to this topical report are to be submitted to NRC for review prior to implementation.
Organizational changes are to be submitted no later than 30 days after announcement.
Please replace our letter-of September 8,1977 and its enclosure, which was the staff's evaluation of the report through Revision 4, with a copy of this letter and the enclosed
" ical report evaluation in your report, renumber the report APL-TOP-1A, Revision 5, e... resubmit 36 copies. Please note in your transmittal letter that the program des-cribed in Revision 5 will be implemented on Arkansas Nuclear One, Unit Nos. I and 2.
.Should you have any questions regarding our review or if we can provide assistance, please feel free to contact Mr. James Conway on (301) 492-7741.
Sincerely. -
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Walter . Haass, Chief O. auality Assurence 8ceacs Division of Engineering
Enclosure:
Topical- Report Evaluation
TOPICAL REPORT EVALUATION O
Report Number: APL-TOP-1A, Revision 5
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Report
Title:
Quality Assurance Manual - Operations Report Date: May 1980 Originating Organization: Arkansas Power & Light Company
, Reviewed By: Quality Assurance Branch
SUMMARY
OF TOPICAL REPORT Topical Report APL-TOP-1A, Revision 5 describes the quality assurance (QA) program which Arkansas Power & Light (AP&L) applies to those operational phase activities involving safety-related structures, systems, and components of nuclear power plants within the AP&L scope of work. APL-TOP-1A, Revision 5 commits AP&L to comply with the requirements of Appendix B to 10 CFR Part 50 and to follow the regulatory position provided by the NRC in Regulatory Guides 1.8-Revision 1-R (May 1977),1.28-Revision 1 (March 1978),1.30 (August 11,1972),1.33-Revision 2 (February 1978), 1.37 (March 16, 1973),1.38-Revision 2 (May 1977),1.39-Revision 2 (September 1977), 1.58 (August 1973),
1.64-Revision 2 (June 1976), 1.74 (February 1974),1.88-Revision 2 (October 1976),
1.94-Revision 1 (April 1976),1.116-Revision 0-R (May 1977), and 1.123-Revision 1 (July 1977), as well as ANSI N45.2.12, Draft 4-Revision 2 (January 1976) as docu ented in Appendix A in the report.
OAest hes provided for our eveluet4en e eetei,ed orgenizetions, description er those individuals and groups involved in carrying out activities required by the QA program and a delineation of duties, responsibilities, and authority of those organizational elements involved in the QA program. APL-TOP-1 A, Revision 5 contains a description of the measures used to carry out the APL QA program activities and describes how applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied by the ad-ministration and implementation .of these measures.
SUMMARY
OF REGULATORY EVALUATION AND POSITION We have evaluated the QA program and the organizations responsible for QA functions as described in APL-TOP-1 A, Revision 5. We find that QA policy and direction originate at an acceptably high manacemant level and are effectively comunicated to other parts of the organization. Individuals performing QA functions have responsibility and authority commensurate with their duties in implementing the QA program. We also find that measures have been established to be implemented by written procedur.es and instruc-tions which address each of the criteria of Appendix B to 10 CFR Part 50 in an accept-able manner.
Based on our review and evaluation of APL-TOP-1A, Revision 5, we conclude that:
- 1. The organizations and persons performing-QA functions within AP&L have the' required independence and authority to effectively carry out the QA program without undue -influence from those directly responsible for costs and schedules.
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, v2. The AP&L QA program contains requirements and controls which, when properly i
-implemented, comply with the requirements of Appendix B to 10 CFR Part 50.
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i 3. The AP&L topical report, APL-TOP-l'A, Revision 5, " Quality Assurance Manual -
Operations," is acceptable for use in the operations phase activities of AP&L's nuclear power plants.
I A staff position on the subject of utilizing ANSI N45.2.13 in' conjunction with Code t requirements will be transmitted at a later date. .
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! I TABLE OF CONTENTS ARKANSAS POWER & LIGilT COMPANI SECTION SUBJECT TAB PAGE POLICY STATEMENT FOREWORD TERMS AND DEFINITIONS
- 1. ORGANIZATION 1 1 1.1 SCOPE 1 1.2 ARKANSAS POWER & LIGilT COMPANY l 1.3 SUPPORTIVE SERVICES 1 1.3.1 MANAGER, SAFETY & WORKERS' COMPENSATION 1 1.3.2 NUCLEAR BUYEF 2 1.4 GENERATION AND CONSTRUCTION 2 1.4.1 DIRECTOR, TECHNICAL & ENVIRONMENTAL SERVICES 2 1.4.1.1 QUALITY ASSURANCE ORGANIZATION (QAO) 3 1.4.2 DIRECTOR, PROJECTS MANAGEMENT 6 1.4.3 DIRECTOR, NUCLEAR OPERATIONS 7 1.4.4 DIRECTOR, FOSSIL OPERATIONS 8
(~s 1.4.5 DIRECTOR, GENERATION ENGINEERING 8
\- 1.4.6 DIRECTOR, GENERATION TECHNOLOGY 8 1.4.7 DIRECTOR, ADMINISTRATIVE SERVICES & PROJECT SUPPORT 9 1.4.8 MANAGER, NUCLEAR SERVICES 9 1.5 ARKANSAS NUCLEAR ONE ORGANIZATION 10 1.5.1 GENERAL MANAGER 10 1.5.2 OPERATIONS MANAGER 10 1.5.3 MAINTENANCE MANAGER 11 1.5.4 ENGINEER & TECllNICAL SUPPORT MANAGER 11 1.5.5 PLANT ADMINISTRATION MANAGER 13 1.5.6 MANAGER OF NUCLEAR QUALITY CONTROL 14 1.6 QL\LITY PROGRAM COMMITTEES 15 1.6.1 SAFETY REVIEW COMMITTEE 15 1.6.2 PLANT SAFETY COMMITTEE 18 1.7 ORGANIZATIONAL INTERFACES AND RESPONSIBILITIES 21
- 2. QUALITY ASSURANCE PROGRAM 2 1 2.1 SCOPE 1 2.2 PURPOSE 1 2.3 APPLICABILITY l 2.4 PROCEDURES 2 2.5 PROGRAM REVISION AND CONTROL 4 2.6 SYSTEM STRUCTURE AND COMPONENT CLASSIFICATION 4 2.7 TRAINING AND PERSONNEL 5 7s 2.8 PROGRAM REVIEW 6 i
QUALITY ASSURANCE MANUAL REV. 5 10/$h0 TITLE: TABLE OF CONTENTS PAGE 1 of 6 ffB(OF
I SECTION SUBJECT TAB PAGE
- 3. DESIGN CONTROL 3 1 3.1 SCOPE 1 3.2 GENERAL 1 3.3 DESIGN PROCESS / VERIFICATION 1 3.4 DESIGN RECORDS 3
- 4. PROCUREMENT DOCUMENT CONTROL 4 1 4.1 SCOPE 1 4.2 GENERAL 1 4.3 REQUISITIONS 2 4.4 SPECIFICATIONS 3 4.5 PURCHASE ORDERS 3
- 5. INSTRUCTIONS, PROCEDURES AND DRAWINGS 5 1 5.1 SCOPE 1 5.2 GENERAL 1 5.3 TEMPORARY CilANGES 2 5.4 CHANGES TO PROCEDURES 3 5.5 REVIEW OF PROCEDURES, INSTRUCTIONS AND 3 DRAWINGS
- 6. DOCUMENT CONTROL 6 1 6.1 SCOPE 1 6.2 GENERAL 1
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6.3 DOCUMENT IDENTIFICATION 2 6.4 STORAGE AND FILING REQUIREMENTS 2
- 7. s)NTROL OF PURCilASED MATERIAL, 7 1 E]UIPMENT & SERVICES 7.1 SCOPE 1 7.2 S )URCE EVALUATION 1 7.3 DOCUMENTATION OF QUALITY l 7.4 SOURCE INSF ?CTION 1 7.5 RECEIPT INS'ECTION 2 7.6 STORAGE 3
- 8. IDENTIFICATION & CONTROL OF MATERIALS, 8 1 PARTS & COMPONENTS 8.1 SCOPE 1 8.2 IDENTIFICATION AND MARKING 1 8.3 TAGGING 1 8.4 DOCUMENTATION 2 8.5 DEFECTIVE OR INCORRECT ITEMS 2
- 9. CONTROL OF SPECIAL PROCESSES 9 1 9.1 SCOPE 1 DATE QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: TABLE OF CONTENTS PAGE 2 of 6 TABLE OF CONTENTS
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(- SECTION SUBJECT TAB PAGE
'v 9.2 RESPONSIBILITY l 9.3 GENERAL 1 9.4 QUALIFICATION 1
- 10. INSPECTION 10 1 10.1 SCOPE 1 10.2 RESPONSIBILITY l 10.3 INSPECTION PROCEDURES 2 10.4 INSPECTOR QUALIFICATION 3 10.5 DOCUMENTATION 3
- 11. TEST CONTROL 11 1 11.1 SCOPE I 11.2 SURVEILLANCE TESTING 1 11.3 PROCEDURE APPROVAL 2 11.4 DOCUMENTATION AND REVIEW 0F TEST RESULTS 2 11.5 PRE 0PERATIONAL TESTING 3
- 12. CONTROL OF MEASUREMENT AND TEST 12 1 EQUIPMENT 12.1 5' COPE 1 12.2 GENERAL 1 12.3 RESPONSIBILITIES 2
('" ) 12.4 EQi'IPMENT IDENTIFICATION 2 12.5 DOCUMENTATION 2
- 13. HANDLING, STORAGE AND SilIPPING 13 1 13.1 'iCOPE 1 13.2 SPECIAL REQUIREMENTS 1 13.3 RECEIVING INSPECTION 1 13.4 STORAGE AND PRESERVATION 1 13.5 RADIOACTIVE MATERIALS 2 13.6 RECORDS 2
- 14. INSPECTION, TEST AND OPERATING 14 1 STATUS 14.1 SCOPE 1 14.2 DETERMINING OPERATIONAL STATUS 1 14.3 IDENTIFICATION OF OPERATIONAL STATUS 1
- 15. NONCONFORMING MATERIAL, PARTS OR 15 1 COMPONENTS 15.1 SCOPE 1 15.2 GENERAL 1 15.3 TAGGING AND STORAGE 2 15.4 DOCUMENTATION 2
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DATE QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITL F: TABLE OF CONTENTS PAGE 3 of 6 TABLE OF
__ CONTENTS
SECTION SUBJECT TAB PAGE
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- 16. CORRECTIVE ACTION 16 1 16.1 SCOPE 1 16.2 GENERAL 1 16.3 SIGNIFICANT NONCONFORMANCES 1
- 17. QUALITY ASSURANCE RECORDS 17 1 17.1 SCOPE 1 17.2 RESPONSIBILITY l 17.3 DOCUMENT RETENTION 1 17.4 GENERATION AND CONSTRUCTION 2 17.5 STORAGE 3 -
17.6 RECORDS INDEXING AND RECEIPT CONTROL 4 17.7 FINAL DISPOSITION 4
- 18. AUDITS 18 1 18.1 SCOPE 1 18.2 GENERAL 1 18.3 IN-PLANT REVIEW AND SURVEILLANCE 2 18.4 AUDIT PERSONNEL 2 18.5 DOCUMENTATION 2 18.6 AUDIT ACTIVITIES 4 APPENDIX A INTERPRETATIONS OF REGULATORY GUIDE 19 1
& ANSI STANDARDS APPENDIX B QUALITY ASSURANCE PROCEDURES MATRIX 19 1 i
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FIGURES AND TABLES
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FIGURES NUMBER TITLE TAB PAGE 1-1 Arkansas Power & Li Fht Company 1 23 Corporate Organizatian 1-2 Arkansas Power & Light Company 1 24 Administrative Services-Purchasing 1-3 Arkansas Power & Light Company 1 25 Generation & Construction 1-3A Arkansas Power & Light Company 1 26 ,
Quality Assurance Organization 1-4, A, B, C Arkansas Power & Light Company 1 27 ANO Organization
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TITLE: TABLE OF CONTENTS PAGE 5 of 6 TABLE OF CONTENTS s
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1 TABLES 4
NUMBER TITLE TAL PAGE !
l 2-1 Quality Assurance Procedure; 2 8 1
l 2-2 ' Plant Quality Procedures 2 9 2-3 Generativa & Construction 2 12 I
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ARKANSAS POWER & LIGHT COMPANY POLICY STATEMENT QUALITY ASSURANCE PROGRAM FOR OPERATION It is the policy of the Arkansas Power & Light Company (AP&L), from the highest level of corporate management, that its Quality Assurance Pro-gram for Operation shall meet the requirements of the Code of Federal i Regulations, 10 CFR 50, Appendix B, with respect to operation, main- ~
tenance, refueling,. repair and modifications, and inservice inspection of AP&L Nuclear Plants.
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.Under the Program, the Vice President, Generation and Construction, is the final management authority responsible for assuring that this policy statement and the Quality 4surance Program are implemented within AP&L.
The General Manager is rer g nsible for the daily implementation of the Program's procedural requirements at the plant. Each Generation and
- Construction Director (Director, Technical & Environmental Services, 4
Director, Generation Engineering, Director, Nuclear Operations, Di--
rector, Fossil Operations, Director, Project Management, etc.), is
} responsible for the procedural implementation of the program within his j assigned area.
The Manager of-Quality Assurance shall be responsible for establishing the Program. The Manager of Quality Assurance, Director of Technical &
Environmental Services, and the Vice President of Generation and Con-s - struction sLall be responsible for approval of the program.
Quality .L.=rance personnel reporting to the Manager of Quality As-
- surance shall be responsible for auditing the Program as necessary and monitoring activities required-by the Program to assure compliance with its requirements. The Manager of Nuclear Quality Control shall have the
, authority and organizational freedom necessary to meet the requirements
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The Manager of Quality Assurance shall provide for annual review of the adequacy and overall effectiveness of the Program. Any defects in the implemention of either this policy or the Program that are revealed during the review, and that require action for correction, will be reported to appropriate levels of management together with appropriate recommendations.
Implementation of this policy is necessary in order to achieve the reliability and safety required at our Nuclear Plants. Each person involved in activiti- concerning our Nuclear Plants shall be re-
, sponsible for assuring quality in his own work, and for compliance .with t
the requirements of the Program. The Quality Assurance Program pol-i icies, manuals, and procedures are mar.datory requirements which must be implemented and enforced by all responsible organizations and indivi-duals, '
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O A W.'Cavanaugh, III O Vice President, Generation & Construction l
l Dated: /0//D/ PO -
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.r's) i FOREWORD o
Quality assurance requirements have been established for the design and construction of AP&L nuclear plants to assure that regulatory require-ments and licensing commitments, codes and standards are correctly translated into the as-built plant. It is the objective of this program to establish quality assurance requirements to ensure that activities such as aperating, testing, refueling, repairing, maintaining and modi-fying the plant are conducted in accordance with good engineering prac-tices. To meet this objective, a Quality Assurance Program for Opera-tion applicabla to AP&L Nuclear Plants has been established by Arkansa =
Power & Light Company. The Program, identified as the Quality Assurance for Operations, provides criteria to be applied to the operational phase of the plant. The program controls those phases, as applicable, for the design, procurement, manufacturing and fabrication, installation, repair, maintenance or changes made to existing plant structures, components and systems that prevent or mitigate the consequences of a postulated acci-dent which may cause undue risk to the health and safety of the public.
It assures that the necessary operational safeguards are applied in accordance with the criteria for safe, efficient, and reliable opera-tion. The Program is an outgrowth of the principle that quality as-surance emanates from each individual contributor, and that management is responsible for creating an awareness of quality.
, _ . AP&L's initial Quality Assurance Program was formalized on March 10,
( ) 1971, with the initial issue of AP&L's Quality Assut mee Manual. The program was revised and upgraded seven times (12/17/71, 4/5/72, 8/22/72, 2/6/73, 6/5/73,12/4/73, 3/26/74), and on 6/11/74, the Quality Assurance Program for Operations was described in a manual separate from the construction program.
Quality Assurance Program changes are made as required by the Manager of Quality Assurance to implement additional or changed requirements.
The Quality Program is implcmented through quality assurance procedares contained in the following manuals.
Quality Assurance Procedures Manual Quality Assurance Administrative Procedures Manual
- Generation & Construction Procedures Manual ANO Master Plant Manual - Administrative Procedures All procedures contained in these manuals which are identified in this program are reviewed and approved as described in paragraph 2.4.3. The procedures are developed and revised as necessary by the cognizant group. The procedures and revisions are examined by the Manager of Quality Assurance to assure that Quality Assurance Program commitments are met.
(7 DATE j QUALITY ASSURANCt MANUAL REV. 5 10/10/80 TITLE: FOREWORD PAGE 1 of 1 FOREWORD
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,e - TERMS AND DEFINITIONS m-Approval- An act of endorsing or adding positive authorization, or both.
Appurtenance- a part that is attached to a component which has been completed.
As-Built Data- Documented data that describes the condition actually achieved in a product.
Assembly- A combination of suba-semblies or components, or both, fitted together to form a unit.
Audit- tn activity to determine through investigation, the adequacy of, and adherence to, established procedures, instructions, specifications, codes, and standards or other applicable contractual and licensing requirements, and the effectiveness of implementation.
Bid Evaluation- A formal evaluation of all proposals received in response to an inquiry to determine the vendor to whom the purchase order will be awarded.
Certificate of Conformance- A written statement, signed by a qualified
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,_s party, certifying that items or services comply with specific re;atrements.
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Certi_f_icate of Compliance- A written statement, signed by a qualified party, attesting that the items or services are in accordance with specified requirements and accompanied by additional information to substantiate the statement.
Cert i fied Test Report.- A written and signed document, approved by a qualified party, that contains sufficient data and information to verify the actual properties of items and the actual results of all required tests.
Certification- The action of determining, verifying and attesting, in writing, to the qualifications of personnel or material.
Characteristic- Any pro.aerty or attribute of an item, process, cr service that is distin. describable, and measurable, as conforming or nonconf orming to specit ied quality requirements. Quality characteristics are generally identified in specifications and drawings which descr.be the item, process, or service.
Checks- The tests, measurements, verifications or controls placed on an activity by means of investigations, comparisons, or examinations, to determine satisfactory conditions, accuracy, safety or performance.
L DATE ff QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: TERMS AND DEFINITIONS PAGE 1 of 6 TERMS
O Cleanness- A state of being clean in accordance with predetermined s standards, and usually implies freedom fro'.i dirt, scale, heavy rust, oil or other contaminating impurities.
Component- A piece of equipment such as a vessel, piping, pump, valve or core support structure, which will be combined with other components to form an assembly.
Construction Phase- A period which con nences uth receipt of items at the construction site and ends when the components and systems are ready for turnover to operations personnel.
Contaminants- Foreign materials such as mill scale, dirt, oil, chemicals and any matter that renders a fluid, solid or st.rface impure and ut: clean according to preset standards of acceptable cleanness.
Contractor- Any organization under contract for furnishing items or servi.as. It. includes the terms Vendor, Supplier, Subcontractor, fabritat >r and sub-tier levels of these where appropriate.
Defective Material- A material or ccmponent which has one or more characteristics that do not comply with specified requirements.
Deviation- A ronconformance or departure of a character:stic from specified requirements.
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f D(.mumentation- Any written or pictorial information describing, defining, specifying, reporting or certifying activities, requirements, procedures, or results.
Examinction- An element of inspection consisting of investigation of materials, components, supplies or services to determine conformance to those specified requirements which can be determined by such investigation.
Examination is usually nondestruct.ive and incluhs simple physical manipu-lation, gaging, and measuremeat.
Generating Station- A utility company complex, constructed and operated for the purpose of producing electric power.
Guidelines- Particular provisions which are considered good pract. ice but which are not mandatory. The term "should" denotes a guideline; the term "shall" denotes a mandatory requirement.
Ilandling- An act of physically moving items by hand or mechanical means, but not including transport modes.
Inqu i ry- A document that contains the necessary information for a vendor to make a proposal. An inquiry may include specifications pertaining to the equipment, materials, or services proposed to be procured. ,
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Inspector (State or Code)- A qualified inspector employed by a legally
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constituted agency of a Municipality or State of the United States, or Canadian Province, or regularly employed by an Authorized Inspection Agency and having authorized jurisdiction at the site of manufacture or installation.
Inspector (Owner's or Installer's)- A qualified inspector employed by the Owner or Installer whose duties include the verification of quality-related activities or installations or both.
Inspection- A phase of quality control which by means of examination, observation or measurement determines the conformance of materials, supplies, components, parts, appurtenances, systems, processes or structures to predetermined quality requirements.
Item- Any level of unit assembly, including structure, system, s e' jotem, subassembly, component, part or material.
Manufacturer- One who constructs any class of component, part, or appurtenance to meet prescribed design requirements.
Master Plant Manual- A manual consisting of various subsets of procedures, such as operating procedures, emergency procures, test and maintenance procedures, used by plant operatiores staff, and maintained for the life of the plant.
m Material- A substance or combination of substances forming components, parts, pieces and equipment items. (Intended to include such as machiner-castingc, liquids, formed steel shapes, aggregates, and cement.)
Modification- A planned t.ange in plant design or operation cnd accomplished in accordance with the requirements and limitations of applicable codes, standards, specifications, licenses and predetermined safety restrictions.
Nonconformance- A deficiency in characteristic, documentation, or procedure which renders the quality of an item unacceptable or indeterminate.
Examples of nonconformance include: physical defects, testr ailures, incorrect or inadequate documentation, or deviation from prescribed processing, inspection or test procedures.
Objective Evidence- Any statement of fact, information, or record, !
either quantitative or qualitative, pertaining to the quality of an item l or service based on observations, measurements, or tests which can be l verified.
Operation- The total v f administrative, maintenance and monitor l activities necessary t o sustain the power generating capabilities of the plant after initial start-up.
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' 10/10/80 TITLE: TERMS AND DEFINITIONS PAGE 3 of 6 TERMS
'l c' owner- The person, group, company or corporation who will have or
,j has title to the facility or installation under construction.
Package- A wrapping or container including its contents of material or equipment.
Packaged Unit- An assembly of items and parts which can be disassem-bled without destroying the integrity of the individual parts.
Part- An item which has work performed on it and which is attached to and becomes part of a component before completion of the component.
Plant- The equipment, piping, structures, buildings and property that comprise an installation or facility.
Procedure- A document that specifies or describes how an acti-vity is to be performed. It may include methods to be employed, equipment or materials to be used and sequence of operations.
Procurement Documents- Coatractually binding documents that identify and define the reg.sirements which items or services must meet in order to be considered acceptable by the purchaser.
Project- A planned series of activities including all actions necessary to provide, utilize, and maintain a facility or portion
, thereof.
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Proposal- A bid, usually written by a vendor in response to an in-iry, which provides the issuing party with the vendor's proposed compliance to the inquiry and the cost.
Pucchase Order (or Contract)- A document authorizing a vendor to provide equipment, material or services in accordance with stated terms and conditions.
Purchaser- The organization or organizations responsible for issuance and administration of a contract, subcontract, or purchase order.
0-List- A list which specifically identifies those structures, systems and components whose failure could cause an uncontrolled release of radioact ivity, or those essential for the safe uhutdown and immediate and long-term operation following a Loss of Coolant Accident.
Qualification (Personnel)- The characteristics or abilities gained through t raining or experience or both that enable an individual to perform a required function.
DATE fc QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: TERMS AND DEFINITIONS PAGE 4 of 6 TERMS
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Qualified Party- A person or organization competent and recognized s_/ as knowlegeable to perform certain functions.
Qualified Procedure- A procedure which incorporates all applicable codes and standards, manufacturer's parameters, and engineering specifi-cations and has been proven adequate for its intended purpose.
Qualified Vendor List- A listing of vendors having quality assurance programs consistent with the requirements of applicable portions of 10CFR50, Appendix B.
Quality Assucance- All those planned and systematic actions necessary to provide adequate confidence that an item or a facility will perform satisfactorily in service.
Quality Control- Those quality assurance actions which provide a means to control and measure the characteristics of an item, process, or facility to established requirements.
Receiving- Taking delivery of an item at a designated location.
Repair- The process of restoring a nonconforming c.uracteristic to a condtion such that the capability of an item to function reliably and safely is unimpaired, even though that item still may not conform to the original requirement.
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( J Report- Something (document) that gives information for record purposes.
Rework- The process by which a nonconforming item is made to conform to a prior specified requirement by completion, remachining, reassembl-ing or other corrective means.
Source Surveillance- A review, observation, or inspection for the purpose of verifying that an action has been accomplished as specified at the location of material procurement or manufacture.
Specification- A concise statement of a set of requirements to be satisfied by a product, a material or process indicating, whenever appropriate, the procedure by means of which it may be determined whether the requirements given are satisfied.
Standard- The result of a particular standardization effort approved by a recognized authority.
S t o ra ge- The act of holding items at iS construction site or in an area other than its permanent location in .he plant.
Subsystem- A group of assemblies or components or both combined to performed a single function.
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System- A group of subsystems united by some interaction or inter-dependence, performing many duties but functioning as a sinhl e unit.
System Performance Test- A test perform ed on a completed systeia in-cluding electric, instrunentation, controls, fluid and mechanical subsystems under normal or rJmulated norma? process conditions such as temperatuie, riow, level, and pressure.
Testing- The determination or verification of the capability of an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental or operating conditions.
Transit- The state of being conveyed or transported from one place to another.
Transit Carrier (0 pen)- Trucks, trailers, railroad cars, barges, aircraft or ships which do not afford items protection from the environment.
Transit Carrier (Closed)- Trucks, trailers, railroad cars, barges, aircraft or ships which provide protection of items from the environment by nature of their closed design.
Set-Point- A predetermined critical level at which a bistable device changes state to indicate that the quantity under surveil-
,, lance has reached the selected value.
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Use-As-Is- A disposition which may be imposed for a noncon-formance when it can be established that the discrepancy will result in no adverse conditions and that the item under con-sideration will continue to meet all engineering functional requirements including perforeauce, maintainability, fit and safety.
Vendor- Any organization under contract for furnishing items or services. It includes t:te terms Contractor, Subcontractor, Sup-plier, Fabricator and sub-tier levels where appropriate.
Verification- An act of confirming, substantiating and assuring that an activity or condition has been implemented in conformance with the specified requirements.
Work Instructions- Written instructions used to transmit detailed information on the specific measures necesr.ary to comply with the requirements of quality assurance procedures or any complex or dif-ficult quality-related task.
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I r~s RECORD OF REVISIONS i N-]
REVISION NUMBER DESCRIPTION DATE O Initial Issue 6/11/74 1 Response to AEC Questions Submitted 12/13/74 11/21/74. Revisions to Section 2, 4, and 7 as indicated.
2 Response to NRC Questions Submitted 3/ 4/75 2/7/75. Procedure Numbert 1005.xx changes to 1004.xx (Number Change Cnly).
3 General revision to change AEC to NRC, 9/ 8/76 update organization, reflect NSP re-visions, minor program implementation changes.
Eliminate Quality Assurance Committee 9/ 8/77 Changes to Procurement Control -
Qualification of Vendors. Organ-
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izational Changes. Incorporate Technical Specification Changes.
5 Incorporate Organizational Changes 10/10/80 and responses to subsequent NRC Questions. Incorporate Regulatory Guides and retype document in its entirety in standardized format.
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O . 1 ARKANSAS POWER & LIGHT COMPANY j QUALITY ASSURANCE PROGRAM FOR OPERATIONS f TOP-1A-REV. 5 APPROVED: # '
DATE: /s//p/Fo MANAGER,N UALITY ASSURANCE APPROVED:
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DIRECTOR, TECHNICAL DATE: /d d 70 ENVIR0* ENTAL SERVICES APPROVED: ~ M- DATE: /0//0/80 l VICE PRESIDENT I GENERATION & CONS C ION l
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c', 1. ORGANIZATION s_-
1.1 SCOPE This section defines lines of responsibility and describes the organizational structure for the quality assurance functions required for the safe and reliable operation, maintenance, and modification of AP&L nuclear plants.
1.2 ARKANSAS POWER & LIGilT COMPANY (AP&L)
The AP&L Corporate Organization relevant to the operation of nuclear plants is depicted in Figure 1-1.
The ultimate responsibility for all power production facilities within AP&L, including Quality Assurance, lies with the Vice President, Generation & Construction. lie provides management assessmen; of the Quality Program through review of Quality As-surance General Audit (ANO-14) reports and reports of NRC activities.
The Executive Director, Administrative Services, shall be responsible for the purchasing functions affecting plant operation as described in Subsection 1.3.2.
1.3 SUPPORTIVE SERVICES (m
(5 Purchasing services and overall personnel safety control require-ments in support of the operation of AP&L nuclear plants are provided as shown in Figure 1-2. The duties of individuals performing key funcdons related to the quality of the activities involved are as follows:
1.3.1 Manager; Safety & Workers' Compensation The Manager, Safety & Workers' Compensation reports to the Director of Personnel and shall be responsible for the follow-ing quality-related duties & activities:
(1) Establishes the corporate safety policies (2) Publishes the Corporate Safety Manual (3) Is responsible for AP&L implementation of OSilA require-ments (4) Inspects AP&L facilities for compliance w'.th the Corporate Safety Manual p
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1.3.2 Nuclear Buyer
~i The Nuclear Buyer reports to the Supervisor of Purchasing who reports to the Manager, Purchasing and Stores, and shall be responsible for the following quality-related duties and activities:
(1) Prepares purchase orders based upon receipt of rc tiewed and approved purchase requisitions.
(2) Performs the commercial interface functions between AP&L and contractors or vendors.
(3) Assures that quality documentation prepared by Plant or Generation and Construction personnel are included in purchasing documents.
'.4 GENEPdTION AND CONSTRUCTION Generation and Construction, headed by the Vice President, Generation and Construction, shall be responsible for all activities related to the operation of AP&L Nuclear Plants.
These activities include design, procurement, modification, maintenance, and operation. Within Generation and Construction, coordination of the Quality Assurance Program shall be accomplished by the Manager of Quality Assurance. Generation and Construction 7s consists of the following departments: (See Figure 1-3)
(1) Generation Engineering (4) Technical & Environmental Services (2) Nuclear Operations (5) Administrative Services & Project (3) Projects Management Support (6) Jeneration Technology (7) Fossil Operations Generation and Construction, Little Rock General Office (LRGO) activities aftecting quality are described in Sections 2, 3, 4, 5, 6, and 7 of this manual. Procedures listed in Table 2-3 (GCP's) are utilized by LRGO personnel to control these activities.
1.4.1 The Director, Technical & Environmental Services reports to the Vice President, Generation and Construction and is responsible for providing support to AP&L power plants during design, construction and operation in the areas of site selection, licensing, quality assurar.ce, chemistry, en-vironmental monitoring, metallurgy and nondestructive -
examination. llis duties include the following: l (1) Provides technical direction and administrative !
guidance to:
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(~3 (a) Manager, Quality Assurance
\> (b) Manager, Technical Analysis
, (c) Manager, Licensing (2) Insures conformance to the Quality Assurance Program by instituting the necessary quality rel:ted procedures and instructions within the Technical & Environmental Services Department.
(3) Provides for development and control of implementation of the Program.
f4) Provides for liason between AP&L and app]icable regu-latory agencies.
(5) Provides for coordination of environmental surveillance p rog rams .
(6) Serves as a member of the Safety Review Committee.
1.4.1.1 Quality Assurance Organization (QAO)
The AP&L Quality Assurance Organization as shown in Figures 1-3 and 1-3A is under the direction of the Manager of Quality Assurance, who reports to the Director, Technical
- & Environmental Services. The Quality Assurance Organization
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performs review, surveillance and audit functions during design, construction and operational phases of AP&L's nuclear plants.
The duties and responsibilities of the Quali / Assurance Organization during the design and construction phases are described in the AP&L Quality Assurance Manual - Nuclear Construction. QA0 duties and responsibilities in support of the operational phase are described below. The Quality Assurance Organization is independent of existing design, construction, and operation organizations, and reports directly to the Director, Technical & Environmental Services.
1.4.1.1.1 rianager of Quality Assurance The Manager of Quality Assurance shall possess the following ,
qualifications.
l (1) lie shall possess a degree from an accredited school in engineering or a related scientific discipline or equiv-alent.
(2) lie shall possess a minimum of five years experience in the p)
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quality assurance or quality control disciplines with at
_, least two years in the nuclear field.
(3) !!e shall exhibit the ability to plan, schedule and direct the activities of others assigned to or functioning within the Quality Assurance Organization.
1.4.1.1.1.1 Responsibilities (1) The flanager of Quality Assurance is responsible for developing Quality Assurance Program requirements for design, pcoeurement, manufacture, construction, modification, operation, and maintenance related to the Q-Listed systems, structures, and components in AP&L nuclear plants.
(2) The Manager of Quality Assurance shall be responsible for the audit of the quality assurance activities as de-scribed in Section 18 of this manual.
(3) The flanager cf Quality Assurance is responsible for the review, approval and verification of the quality as-surance requirements placed upon contractors or vendors that provide equipment, material, or services for AP&L nuclear plants.
,_s (4) The Manager of Quality Assurance has the authority to stop
('"l work where conditions exist that prohibit effective quality control inspec_ ions, or if faulty materials, incorrect work-manship or procedures are detected.
(For plant operations the stop work authority is directed through the General Manager.)
(5) The t!anager of Quality Assurance is also responsible for the control, and distribution of QA rianuals and QA Manual Revisions.
(6) The flanager of Quality Assurance is responsibl.e for review and approval of QA programs for outside organiza-tions participating in the AP&L QA program.
(7) The Manager of Quality Assurance serves as a member of the oafety Review Committee.
(8) Disputes involving quality, arising from a difference of opinion between QA personnel and other personnel, which cannot be settled interdepartmentally shall be settled by the Vice President, Generati m and Construction.
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/ 1.4.1.1.2 Quality Assurance Engineers and Supervisors 1.4.1.1.2.1 Quality Assurance Supervisor The Quality Assurance Supervisor re ports to the Manager of Quality Assurance. He shall supervise QA Engineers and Auditors, as assigned, and assist the Manager of Quality Assurance in the coordination of activities of the QA Section.
The Quality Assurance Supervisor may also perform duties normal-ly assigned to Quality Assurance Engineers.
1.4.1.1.2.2 Quality Assurance Engineers The Quality Assurance Engineers (QAE's) report to the Manager of Quality Assurance or QA Supervisor, as assigned.
Quality Assurance Engineers assure adequate cont rol of quality activities in the areas of Construction, Operations, Engineer-ing and Audits. They possess the necessary functional independ-ence and authority to investigate, identify and effect solutions to quality problems. Specifically:
(1) The QAE's shall have the authority to audit or review practices, records, files, instructions, directions or documents concerned with all areas affecting quality.
7- (2) The QAE's shall schedule and coordinate audits or surveillance efforts in the areas assigned, document findings, and report to the Manager of Quality Assur-ance and the Manager of the audited area.
(3) The QAE's shall not perform any activity concerned with design, procurement, or construction except in the areas of oiservation, review or audit. They shall have no in-line production or construction responsibilities.
1.4.1.1.2.3 Qualifications The Quality Assurance Engineers and Supervisor report to the Manager of Quality Assurance. They verify by audit, the effective implementation of the Quality Assurance Program for Operaticas.
They are thoroughly knowledgeable of the Quality Assurance Program and associated procedures, Safety Analysis Reports, and 10 CFR 50, APpe'idix 11. They are familiar with the regulatory guides, codes, and standards that addre.;s quality assurance. They confer with the Manager of Quality Assurance in regard to technical issues, periodic audits, reviews, nonconformances, corrective actions and external relations including inplant contractor and vendor representatives.
The Quality Assurance Engineers and Supervisor shall passess the following qualifications:
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(1) Be a graduate of a four year accredited engineering or science school or equivalent with two years of experience in quality assurance, including testing or inspection of equiva-lent manufacturing, construction and installation activities.
At least one year of this experience should be associated with nuclear facilities; or, if not the individual shall have completed training sufficient to acquaint him thoroughly with the Quality Assurance requirements of a nuclear facility, or (2) Be a high school graduate with at least five years experience in general quality assurance or engineering of equivalent manufacturing, construction and installation activities. At least two years of this experience shall be in quality assurance, including testing or inspection of equivalent manufacturing, construction and ir.stallation activities. At least one year of this experience shall be associated with nuclear facilities; or, if not, the individual shall have training sufficient to acquaint him thoroughly with the Quality Assurance requirements of a nuclear facility, and (3) Possess an understanding of management principles necessary to organize and direct the activities of the assigned personnel.
He shall have the ability to communicate clearly and provide effective leadership.
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'> These education and experience requirements shall not be treated as absolute when other factors provide reasonable assurance that a person can competently perform a particular task. Other factors may demonstrate capability in a given job through previous performance or satisfactory completion of proficiency testing.
1.4.1.1.3 Quality Assurance Auditors The Quality Assurance Auditors report to the Manager of Quality Assurance or designated QAE or QA Supervisor and assist him in the implementation of the program by performing audits and inspections as required to assure proper application of the Quality Assurance Program.
QA Auditors are assigned by discipline or specific responsibility and are required to have specialized training and at least three years experience (or equivalent) in their area of responsibility.
1.4.2 Director, Projects Management The Director, Projects Management reports to the Vice Presiderd, Generation and Construction and has full responsibility for design and construction of new generating facilities. All AP&L, and major contracter (NSSS, A-E, Constructor) personnel assigned to
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the construction project report to the Director, Projects Management lV through the assigned Project Manager.
1.4.2.1 Project Manager The Project Manager reports to the Director, Projects Management and shall be responsible for design, engineering, construction and startup activities of new generating facilities. His duties include the following:
(1) Provides technical direction and administrative guidance to the project organization.
(2) Ensures conformance to the Quality Assurance Program by instituting the necessary quality-related procedures and instructions within the Projects Management Department.
(3) Reviews and approves designs, engineering and fabrication performed by AP&L Frime Contractors or Vendors.
(4) Reviews and approves procurement documents that purchase equipment, material and services for new generating facilities.
1.4.3 Director, Nuclear Operations
() The Director, Nuclear Operations reports to the Vice President, Generation and Construction and shall be responsible for the formulation, implementation and discharge of operating policies and procedures relative to nuclear plant operations and for nuclear fuel management. His duties include the following:
(1) Provides technical direction and administrative guidance to:
(a) ANO General Manager (b) Manager, Nuclear Services I
(2) Ensures conformance to the Quality Assurance Program by instituting the necessary quality-related procedures and j instructions within the Nuclear Operations Department.
(3) Provides for review and approval of design and engineering j performed for the operating nuclear plants. '
(4) Provides for review and approval of procurement documents for equipment, material and services as appropriate.
l (5) Provides for procurement and design review of nuclear fuel.
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~N (6) Serves as a member of the Safety Review Committee. I (G
1.4.4 Director, Fossil Operations The Director, Fossil Operations reports to the Vice President, Generation and Construction and shall be responsible for the formulation, implementation and discharge of operating policies and procedures relative to fossil plant operations.
1.4.5 Director, Generation Engineering The Director, Generation Engineering reports to the Vice President, Generation and Construction and shall be responsible for design and engineering activities related to nuclear plant operations.
IIis duties include the following:
(1) Provides technical direction and administrative guidance to:
(a) Manager, Mechanical Engineering (b) Manager, Electrical Engineering (c) Manager, Civil Engineering (d) Manager, Nuclear Engineering (e) Manager, Instrumentation & Controls Engineering (2) Ensures conformance to the Quality Assurance Program by instituting the necessary quality-related procedures and
(,) instructions within the Engineering Department.
(3) Providec for review and approve.1 of design and engineer-ing performed by contractors vendors, and AP&L personnel.
(4) Provides for review and approval of procurement documents for equipment, material, and services for engineering pro-jects, as appropriate.
(5) Serves as a member of the Safety Review Committee.
1.4.6 Director Generation t Technology The Director, Generation Technology reports to the Vice President, Generation and Construction and shall be responsible for engineering support activities related to nuclear plant operations. ;
llis duties include the following:
(1) Provides technical direction and administrative guidance to:
(a) Manager, Plant Performance & Evaluation ,
(b) Manager, Generation Research & Development I (c) Manager, Plant Maintenance l (d) Manager, Availability Engir?ering LJ DATE g'G y l"' QUALITY ASSURANCE MANUAL REV. 5 10/10/80 E '
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x/ 2. Directs development of programs aimed at maximizing efficiency and availabilities.
- 3. Reviews outage data and makes recommendations for p correcting similar problems in like components.
- 4. Directs the plant maintenance support activities that are assigned to the G.O.
- 5. Serves as a member of the Safety Review Committee.
1.4.7 Director, Administrative Services & Project Fupport The Director, Administrative Services & Project Support reports to the Vice President, Generation and Construction, and shall be responsible for the development of administrative programs, sys-tems and services supportive to Generation and Construction manage-ment. His duties include the following:
(1) Provides technical direction and guidance to:
(a) Manager, General Services (b) Manager, Planning, Scheduling, and Cost Control (c) Manager, Training (d) Manager, Contractc Administration (2) Maintains overall department fiscal direction and control, and provides supportive accounting functions.
[s LJ (3) Provides contract administration and administration of pro-ceduces for Generation and Construction Little Rock General Office (LRGO) activities.
(4) Administration of the training and development effort for the Generation and Construction staff.
(5) Ancillary support services to Generation and Construction operating sections.
1.4.8 Manager, Nuclear Services The Manager of Nuclear Services reports to the Director, Nuclear Operations and is responsible for providing the necessary support services related to the effective operation and maintenance of nuclear generating facilities. His duties include the following:
(1) Operations General Of fice review, approval, and coordina-tion of design changes.
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,- (2) Purchase requisition review and approval.
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(3) Interface with other departments to assure effective im-plementation of Regulatory and Company requirements.
(4) Communication interface dealing with all activities at ANO.
1.5 ARKANSAS NUCLEAR ONE ORGANIZATION 1.5.1 General Manager 1.5.1.1 The General Manager reports to the Director, Nuclear Operations on the corporate level and has direct responsibility for operating the station in a safe, reliable, and efficient manner, lie is responsible for operating the plants in accor-dance with the provisions of the operating licenses, including the on site quality program.
1.5.1.2 The General Manager has the authority to shut the plant down if required and has final approval of plant procedures.
1.5.1.3 Reporting to the General Manager are the following positions: Operations Manager, Maintenance Manager, Plant Ad-ministretion Manager, Engineering and Technical Support Man-
, ager, Planning and Scheduling Supervisor, Manager of Nuclear (v ; Quality Control and Manager, Special Projects. (See Figure 1-4) 1.5.2. Operations Manager The Operations Manager (Figure 1-4A) shall be responsible for directing the actual day-to-day operations of the plant. He supervises the operating staf f and interfaces with the Main-tenance Manager to accomplish operation-related maintenance activities.
1.5.2.1. The Operations Superintendents report to and assist the Operations Manager in directing the day-to-day operation of the power plant. They are responsible for coordination of the daily review of operating surveillance tests and coordination of operation-related maintenance activities. They will assist the Operations Manager in the supervision of core refueling, which includes advance planning for the outage, plant preparation, equipment check-out, and the refueling operation.
1.5.2.2 The Shift Operating Supervisor shall be responsible fo r the actual operation of the unit during his assigned shif t lie directs activities of the unit during his assigned shift. He directs activities of the operators on his shift and is cognizant
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,i of all operation-related maintenance act.ivities being performed
'"' while he is on duty. In the absence of health physics personnel, he shall be responsible for having health physics activities performed as the need arises. The Shift Operating Supervisor on duty has the authority to shut down the unit. if, in his judgment, conditions warrant such action.
1.5.3 Maintenance Manager The Maintenance Manager shall direct activities of the in-strumentation and controls, mechanical, electrical and plant services groups. He shall be responsible for organizing and conducting an effective preventive maintenance program for all equipment under his control. He shall provide guidance to the training group to ensure adequate training for maintenance person-nel. He has the responsibility to ensure that the Plant Store-kt.per is inf ormed of all spare parts needed and an adeqtate inventory of spare parts is on hand for all equipment under his cognizance. He shall ensure that maintenance of equipment is conducted in conformance with approved standards, codes and procedures when related to nuclear safety systems. He shall review all applicable procedures to assure conformance with technical specifications. He shall coordinate operation-related maintenance activities with the Operations Manager and the Planning and Scheduling Supervisor. The Mainten-p ance Manager shall have the authority to make repairs V on any structure, system, or component under his control. The instrumentation and controls maintenance, Mechanical Maintenance and Electrical Maintenance, Superintendents and Plant Services Supervisor report to the Maintenance Manager.
1.5.4 Engineering and Technical S,upport Manager The Engineering and Technical Support Manager (Fig. 1-4B) is responsible for providing engineering support services as well as technical and plant analysis support services to the plant staff. Reporting to the Engineering and Technical Support Manager are the Technical Analysis Superintendent, the Plant Analysis Superintendent, the Plant Engineering Superinten-dent and the Operations Assessment Superintendent.
1.S.4.1 The Technical Analysis Superint endent. maintains overall responsibility for the areas of health physics, radiochemistry and chemistry and environmental evaluations.
1.5.4.1.1 The Health Physics Supervisor reports to the Technical Analysis Superintendent. The Health Physics Supervisor is direct-ly responsible for and has the authority to implement the Health Physics program at Arkansas Nuclear One and to maintain expasure U" & DATE f.f QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: ORGANIZATION PAGE 11 of 30 SECTION 1
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as low as reasonably achievable (ALARA). The llealth Physics
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Supervisor's daily duties include supervision of Assistant llealth Physics Supervisors. The llealth Physics Supervisor's reporting relationship is shown in Fig. 1-4B.
1.5.4.1.2 The Radiochemistry Supervisor reports to the Tech-nical Analysis Superintendent. Ile has the responsibility for assuring the reactor plant water conditions are maintained within acceptable limits and for management of liquid and gaseous radwaste.
1.5.4.1.3 The Chemistry and Environmental Supervisor reports to the Technical Analysis Superintendent. Ile has responsibili-ty for assuring that secondary plant water conditions are main-tained within acceptable limits. The scope of his responsibili-ty includes surveillance and maintenance of water quality c ndi-tions in the condensate and feedwater cycle, startup boiler, nu-clear and non-nuclear loops of the intermediate cooling water system and evaluation of circulating water chlorination system.
1.5.4.2 Plant Analysis Superintendent The Plant Analysis Superintendent is responsible for the areas of plant performance, nuclear support and computer support. A supervisor is provided for each of these areas.
{} 1.5.4.2.1 The Plant Performance Supervisor reports to the Plant.
Analysis Superintendent. Ilis responsibilities include: 1)
Evaluating equipment and system performance aver extended per-iods and recommending methods of improving and maintaining good plant efficiency, 2) investigating and etaluating equip-ment malfunctions or failures and recommending corrective action to prevent excessive recurrences, and 3) provide as-sistance in completing records and reports that require special knowledge and/or skill.
1.5.4.2.2 The Nuclear Support Supervisor is responsible for monitoring reactor core and Nuclear Steam Supply System (NSSS) performance, for conducting reactor performance and physics testing as required to assure safe and reli-able operation and to provide current accurate information to operations. lie is responsible for collection and trans-mittal of nuclear fuel management data to the Manager, Nuclear Services in I.ittle Itock, Middle South Services in New Orleans, and the reactor vendors as required. The Nuclear Support Supervisor is responsible for on-site safeguards and ac-countability of the nuclear fuel and assists in planning of all fuel movements including new fuel receipt and inspe -
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tion, fuel shuf fling at refueling, inspection of irradiated fuel aid d.ipment of spent fuel.
1.5.4.2.2.1 Nuclear engineers assist the Nuclear Support ;
Supervisor in performing the tasks of reactor and NSSS per- '
formance monitoring and evaluation, collection and trans-l mittal of nuclear fuel management data maintaining the safe-guards and accountability program for nuclear fuel, and plann-ing, movements and inspection of nuclear fuel.
1.5.4.2.2.2 The Computer Support Supervisor reports to the Plant j Analysis Superintendent and is responsible for the maintenance,
- revision and development of computer software for the plant monitoring computers. lie provides technical assistance to .
the Nuclear Support Supervisor and Nuclear Engineers in de-j velopment and use of test apparatus for evaluation of fuel, i core and NSSS performance. lie provides technical assistance t to the plant staff in solving computer related problems.
1.5.4.3 Plant Engineering Superintendent
- The Plant Engineering Superintendent is responsible for pro-viding support in the areas of design changes, design change
- implementation, and technical expertise for plant engineering.
! Reporting to him are supervisors for the mechanical and electri-cal disciplines.
l 1.5.4.4 Operations Assessment Superintendent The Operations Assessment Superintendent provides the capability to perform engineering evaluations of operating experiences which occur both at the ANO facility and at other nuclear power plants.
Ile will review operating experiences from ANO, publications such as IE Bulletins, Circulars and Noticcs, pertinent NRC and industrial assessments of operating experience and operating experiences from other operating nuclear power stations.
1.5.5 Plant Administration Flanager The Plant administration flanager (Fig. 1-4C) reports to the General Manager and aids him in the administrative aspects of the plants' operation. lie directs the activities of the ad-
- ministrative staff and has reporting to him the Office Services Supervisor, the Fire Control and Safety Coordinator, the Secur-8 ity Coordinator, the Materiais Management Supervisor and the lluman Resources Supervisor.
1.5.5.1 The Of fice Services Supervisor is responsible for ad-ministration of the clerical staff activities and the accumu-O l
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lation and disposition of records related to all phases of the nuclear power plant.
1.5.5.2 The Fire Control and Safety Coordinator is responsible for complying with the NRC regulations dealing with Fire Protec-tion as well as to provide a centralization of OSilA and plant safety programs.
1.5.5.3 The Security Coordinator is responsible for coordination of the efforts of the security force and to manage the operation of the security system.
1.5.5.4 The Materials Management Supervisor is responsible for disposal of surplus materials, equipment and strengthening pur-chasing / expediting support.
1.5.5.5 The lluman Resources Supervisor is responsible for career counseling employment, industrial relations and training.
1.5.6 Manager of Nucleac quality Cont rol The Manager of Nuclear Quality Control (Fig. 1-4) is responsible for implementation of the Quality Control Program for Operations at the plant (1000.23 Quality Control Program). Ife reports to and receives direction from the General Manager. The Manager 7_s of Nuclear Quality Control has authority and is responsible
("; to communicate wit! the Manager, Quality Assurance or his representative for technical assistance or coordination in resolving significant conditions adverse to quality. This communication may be accomplished verbally or by written memorandum.
1.5.6.1 The duties of the Quality Control group include surveil-lance, checks, inspections, reviews of quality-related ac'ivities and documents and maintenance of the Quality Control files. Used in this context, listed below are definitions of surveillance, checks, inspections and reviews.
Surveillance The continuing analysis and evaluation of records, methods and procedures, including the act of verifi-cation, to assure conformance with technical require-ments.
Checks The tests, measurements, verifications or controls placed on m activity by means of investigations, comparisons or examinations to determine satis-factory condition, accuracy, sa fety or performance.
Inspections A phase of quality control which by means of exam-ination, observation or measurement determines the g]
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/ conformance of materials, supplies, components, parts, appurtenances, systems, processes or e'.ructures to pre-determined quality requirements.
Review An element of inspection to determine conformance to specified requirements, which can be determined by examination of documents and activities.
1.5.6.2 The Manager of Nuclear Quality Control shall have the authority to place any item in a non-conforming status when he determines such item to be in violation of purc! ase documents, applicable codes and standards or FSAR requirements. Reporting to the Manager of Nuclear Quality Control is the Quality Control Engineer and a staff of Inspectors.
1.6 QUALITY PROGRAM COMMITTEES 1.6.1 Safety Review Committee (SRC) 1.6.1.1 Membership Director, Nuclear Operations Director, Generation Technology Director, Generation Engineering
,~ Director, Technical & Environmental Services
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- Manager, Quality Assurance Arkansas Nuclear One Plant Safety Committee Chairman Manager, Technical Analysis Arkansas Nuclear One Plant Analysis Superintendent Manager, I&C Engineering Middle South Services Manager, System Nuclear Operations The Chairman and ".lternate Chairman shall be appointed from among the Director level personnel of the SRC membership by the Vice President. Generation & Construction.
Alternates:
(1) Each permanent voting member shall have an alternate to serve in his absence. Alternates shall be appointed in writing by the SRC Chairman.
(2) No more t han two alternates shall serve on the committee at any one t ime as voting nembers.
1.6.1.2. Function Members and alternates shall collectively review and audit the
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7- 3 areas of:
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(1) Nuclear Power Plant Operations (2) Nuclear Engineering (3) Chemistry and Radio ~ristry (4) Metallurgy (5) Instrumentation and Con 6rol (6) Radiological Saf-ty (7) Mechanical ar' strical Engineering (8) Quality Assurance Practices When the nature of a particular situation dictates, special consultants will be utilized to provide axpert advice to the SRC upon request of the SRC Chairman.
1.6.1.3 Heeting Frequency The Safety Review Committee shall meet on call by the Chairman but no less frequently than once per 6 months. During the period of initial operation, Safety Review Committee shall meet no less frequently than once per calendar quarter.
1.6.1.4 Quorum (1) A quorum shall consist of the chairman or his designated 7_ alternate and four members including alternates, i i (2) No more than a minority of the quorum shall have line res-
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ponsibility for nuclear unit operation.
1.6.1.5 Authority and nesponsibility The Safety Review Committee shall report to and be advisory to the Vice President, Generation & Construction, in those areas of res-ponsibility specified in 1.6.1.6 and 1.6.1.7.
1.6.1.6 Review The SRC shall review:
(1) The safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provisions of 10 CFR 50.59, to verify that such actions did not constitute an unreviewed safety question.
(2) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50.59. l l
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(w_/) (3) Proposed tests or experiments wich involve an unreviewed safety question as defined in 10 CFR 50.59.
(4) Proposed changes it technical specifications or licenses.
(5) Violations of applicable statutes, codes, regulations, orders, technical specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
(6) Significant operating abnormalities or deviations from normal and expected pe.-formance of plant equipment that affect nuclear safety.
(7) Events requiring 24-hour notification to the Commission.
(8) Reports and minutes of Plant Safety Committee meetings.
1.6.1.7 Audits Audits of facility activities shall be performed under the cognizance of the SRC. These audits shall encompass:
(1) The conformance of facility operation to provisions con-tained within the Technical Specifications and applicable license conditions at least once per year.
I (2) The performance and retraining of all members of the facility
)
management and operations staff, and the performance, training, and qualifications of new members of the entire facility staff at least once per year.
(3) The results of all actions taken to correct deficiencies occurring in facility equipment, structure, systems or methods of operation that affect nuclear safety at least once per six months.
(4) The Facility Emergency Plan and implementing procedures at least once per two years.
(5) The Facility Security Plan and implementing procedures at least once per two years.
(6) Any other area of facility operation considered appropriate by the SRC or the Vice President, Generation & Construction.
(7) The Facility Fire Protection Program and implementing procedures at least once per two years.
(
DATE QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: ORGANIZATION PAGE 17 of 30 SECTION 1
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1.6.1.8 Records l
)
Records of SRC activities shall be prepared, approved and distributed as indicated below:
(1) Minutes of each (SRC) meeting shall be prepared, approved
.and forwarded to the Vice President, Generation & Construction, within 30 days following each meeting.
('t) Reports of ' reviews encompassed by Section 1.6.1.5, (6) (7),
and (8) above, stall be prepared, approved and forwarded to the Vice President, Generation & Construction, within 30 days following completion of the review.
(3) Audit reports encompassed by Section 1.6.1.7 above, shall be forwarded to the Vice President, Generation and Construction, and to the management positions responsible for the areas audited within 30 days after completion of the audit.
1.6.2 Plant Safety Committee (PSC) 1.6.2.1 Membership Member: Operations Manager Member: Maintenance Manager Member: Engineering & Technical Support Manager
() Member:
Member:
Special Projects Manager Administrative Manager Member: Technical Analysis Superintendent Memb J: Plant Analysis Superintendent Member: Plant Engineering Superintendent Merher: Health Physics Supervisor i
Meuber: Station Engineers as Assigned by the General Manager The General Ma' iger shall designate, in writing, the Chairman and the Alternate Chairman from the Plant Safety Committee membership.
! 1.6.2.2 Meeting Frequency Monthly, and as required, on call of the Chairman or his designated alternate.
1.6.2.3 Quorum Chairman plus three members including alternates. No more than one l station engineer assigned by the General Manager shall participate )
as a ting member in PSC activities at any one time.
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DATE QUALITY ASSURANCE MANUAL REV. 5 -
10/10/80 TITLE: ORGANIZATION PAGE 18 of 30 SECTION 1 4
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1.o.2.4 ilternates Design.+ed alternates shall be appointed by the Chairman in writing and shall serve only on a temporary basis; however, there shall be no more than two (2) alternate members serving on the committee as voting members at aay one time.
1.6.2.5 Responsibilities The Commit ce shall be responsible for:
(1) Review of all procedures required by Appendix A of the Technical Specifications and revisions and any other proposed procedures or revisions as determined by the General Manager that affect nuclear safety.
(2) Review of proposed tests and experiments which affect nuclear safety.
(3) Review of proposed changes to the Appendix A Technical Specifications. ,
(4) Review of proposed changes to modifications to plant systems or equipment which affect nuclear safety.
()
(5) Review of nuclear unit operations to detect potential nuclear safety hazards.
(6) Investigation of all violations of the Technical Specifications involving activities under the responsibility of the General Manager, including the preparation and forwarding of reports covering evaluations and recommendations to prevent recurrence to the General Manager.
(7) Performance of special reviews and investigations and render reports thereon as requested by the General Manager.
(8) Review of the Plant Security Plan and implementing procedures and shall submit recommended changes to the General Manager.
(9) Review of the Emergency Plan and implementing procedures and shall submit recommended changes to the General Manager.
(10) Review of those reportable occurrences requiring 24-hour notification to the NRC.
1.6.2.6 Authority g
(_J DATE REV. 5 QUALITY ASSURANCE MANUAL 10/10/80 TITLE: ORGANIZATION PAGE 19 of 30 SECTION 1
( The Plant Safety Committee shall:
)
(1) Recommend to the General Manager written approval or disapproval of proposals under items 1.6.2.5 (1) through 1.6.2.5 (4) above.
(a) In the event of a disagreement between the recommendations of the Plant Safety Committee and the actions contemplated by the General Manager, the course determined by the General Manager to be more conservative will be followed. Records of the disagreement will be sent fcr review to the Vice President, Generation & Construction, or Director, Nuclear Operations and the Safety Review Committee by the General Manager on the next working day.
(2) Render tentative determinations, in writing, as to whether or not items considered under 1.6.2.5 (1-4) and 1.6.2.5 (6) above involve unreviewed safety questions.
1.6.2.7 Records Minutes shall be kept by the committee of all meetings of the Plant Safety Committee and copies shall be sent to the Chairman of the Safety Review Committee by the General Manager.
1.6.3 Evnironmental Responsibilitier g-(_ )x The Plant Safety Committee and the Safety Review Committee shall review and audit the following:
(1) Coordination of Environmental Technical Specification development with the Safety Technical Specification.
(2) Proposed changes to the Environmental Technical Specifications and the evaluated impact of the changes.
(3) Proposed written procedures, as described in Specification 5.5, and proposed changes thereto which affect the plant's environmental impact.
(4) Proposed changes or modifications to plant systems or equip-ment which would affect the plant's environmental impac. and the evaluation of the impact of these changes.
(5) Re ults of the Environmental Monitoring Programs prior to their submittal in each semiannual Environmental Monitoring Report.
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DATE QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: ORGANIZATION PAGE 20 of 30 SECTION 1
(1/") (6) Investigations of all reported instances of violations of Environmental Technical Specifications. Where it.cestigation warrants, instances shall be evaluated and recommendations formulated to prevent recurrence.
1.7 ORGANIZATIONAL INTERFACES AND RESPONSIBILITIES As owner and operator, AP&L assumes full responsibility and au-thority for the plant and shall take all appropriate action to assure that the plant is operated in accordance with sound en-gineering practices, including applicable codes, specifications and procedures.
The Projects Management Department is responsible for establishing technical and management interfaces between the constructor, ar-chitect-engineer (A/E), nuclear steam supply system (NSSS) vendor and AP&L. These interfaces may be utilized as needed during opera-tion of a nuclear unit for technical consultation and services.
These interfaces are established prior to the complete phase-out of the design and construction forces to assure an orderly transition within the contractor firms.
Each supplier of equipment, material or services and each .nain-tenance or modification contractor is responsible for administering the applicable quality control functions as required by AP&L. The f~ Quality Assurance Organization is responsible for assuring by (s,) surveillance, audit or review of objective evidence (e.g., audit reports conducted by others, etc.), that these functions are ac-complished for systems and structures that affect the safety and integrity of the plant.
Visits to manufacturer's shops by Quality Assurance Organization personnel are conducted when deemed necessary based upon safety significance, complexity, method of acceptance and past history of the vendor, to establish product quality and to ensure that quality assurance and quality control programs function in accordance with AP&L requirements.
The Manager, Quality Assurance is responsible for communications with the NRC Regional Office regarding NRC quality assurance re-quirements related to the quality assurance activities described in tne Quality Assurance Program for Operations and the implementation of the procedures within AP&L support organizations.
The General Manager is responsible for communications with the NRC Regional Office regarding the adequacy, implementation and use of the Quality Assurance Program for Operations at the Plant.
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DATE QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: ORGANIZATION PAGE 21 of 30 SECTION 1
1 l
l Arkansas Power & Light Company delegates to Middle South Services,
/ Inc., a wholly owned s:bsidiary of Middle South Utilities, Inc., i the responsibility for performing those quality assurance functions necessary to ensure that its nuclear fuel is designed and fabri-cated in accordance with regulatory requirements and accepted codes, standards and specifications. The MSS Quality Assurance section monitors the design and fabrication of the fuel through a program of audits of the fuel fabricator, including both design review ardits and fuel fabrication audits. MSS also conducts audits of component suppliers as deemed necessary by the Manager, Quality Assurance (MSS), to ensure the quality of the fuel. Formal audit reports are issued by t9 to document their audit activities and to identify nonconformanc r other items requiring action by the fuel fabricator. Resolut.u.. 21 nonconformances or other items requiring action is verified by MSS and documented it. follow-up reports.
The AP&L Quality Assurance Manager is on distribution for all audit and follow-up reports.
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DATE REV. 5 QUALITY ASSURANCE MANUAL 10/10/80 TITLE: ORGANIZATION PAGE 22 of 30 SECTION 1
l CHAIRMAN l O 0F THE k) BOARD PRESIDENT & CHIEF EXECUTIVE OFFICER SYSTEM ENGIN.
& PLANNING SR. VICE PRES.
GENERATION DIRECTOR
& CONSTRUCTION NUCLEAR VICE PRESIDENT OPERATIONS DIRECTOR
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QUALITY ASSURANCE MANUAL REV* 5 IY 10/10/80 F TITLE: ORGANIZATION SECTION PAGE 23 of 30 4
j PRESIDENT & CHIEF EXECUTIVE OFFICER EXECUTIVE DIRECTOR OF ADMINISTRATIVE SERVICES DIRECTOR OF DIRECTOR OF CORPORATE PERSONNEL SERVICES l
C MANAGER OF MANAGER OF PURCHASING & S AFETY &
OES CO N T ON i SUPERVISOR OF PURCHASING NUCLEAR BUYER p
V AhANSAS POWER & LIGHT COMPANY FIGURE 1-2 SUPPORTIVE SERVICES 97 I?
9 l REV. 5 DATE QUALITY ASSURANCE MANUAL 10/ 10 /80 TITLE: ORGANIZATION PAGE 24 of 30
l VICE PRESIDENT GENERATION &
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SAFETY REVIEW COMMITTEE e
DIRECTOR r' GENERAL ANO MA ER MAEN 0E T ONS r, DIRECTOR /" MANAGER PLANT GENERATION - NUCLEAR - SAFETY ENGINEERING r/ SERVICES COMMITTEE I
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NUCLEAR TECHNOLOGY f# FUEL QUALITY CONT.
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LICENSING MANAGEMENT ARKANSAS POWER & LIGHT COMPANY FIGURE 1-3
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CONSTRUCTION DIRECTOR TECHNICAL &
ENVIRONMENTAL SERVICES r C J s MANAGER QUALITY ASSURANCE QUALITY QUALITY QUALITY FOSSIL FOSSIL ASSURANCE ASSURANCE ASSURANCE QUALITY CONSTRUCTION ENGINEER ENGINEER ENGINEER ASSURANCE INSPECTORS AUDI" (LR) OPERATIONS (ANO: ENGINEERING (LR) PERSONNEL
- QUALITY QUALITY ASSURANCE ASSURANCE AUDITOR (LR) flf9ITOR(ANO)
- Are Utilized Periodically for Nuclear Q.A. Auditing A.' KANSAS POWER & LIGHT COMPANY FIGURE 1-3A p) x QtALITY ASSURANCE ORGANIZATION DATE REV. 5 f km hW QUALITY ASSURANCE MANUAL 10 / 10/ 80 TITLE: ORGANIZATION PAGE 26 of 30 SECTION J
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DATE I'I QUALITY ASSURANCE MANUAL REV. 5 10 / 10 /80 TITLE: ORGANIZATION SECTION PAGE 28 of 30 1
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"' 10/ 10/ 0 TITLE: ORGANIZATION SECTION PAGE 30 of 30 l 1 .
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- 2. QUALITY ASSURANCE PROGRAM V
2.1 SCOPE 2.1.1 The AP&L Corporate Quality Assurance Program for Operations (program) addresses those requirements, responsibilities, and actions that provide managerial and administrative controls to assure safe plant operation. The program shall comply with the Requirements of regulatory positions in Regulatory Guides 1.8 Rev.
1 (5/77), 1.28 Rev. 1 (3/78), 1.30 (8/11/72), 1.33 Rev. 2 (2/78),
1.37 (3/16/73), 1.38 Rev. 2 (5/77), 1.39 Rev. 2 (9/77), 1.58 (d/73), 1.64 Rev. 2 (6/76), 1.74 (2/74), 1.88 Rev. 2 (10/76), 1.94 Rev. 1 (4/76), 1.116 Rev. 0-R (5/77), 1.123 Rev. 1 (7/77), and ANSI N45.2.12 Draft 4, Rev. 2 (1/1/76) subject to the interpretations clarifications / exceptions listed in Appendix A. The above re-quirements are implemented by controlling activities as described in this manual and procedures referenced in this manual.
2.2 PURPOSE 2.2.1 The purpose of the program is to ensure that Arkansas Power &
Light Company nuclear power plants are operated in a safe, reliable and aTficient manner in compliance with NRC regulations, opplicable industrial standards and codes and all applicable Company policies, rules, approved operating procedures and license provisions. A
,-m matrix of QA procedures cross-referenced to each criterion of 4
(_) 10 CFR 50 Appendix B is included as Appendix B to this Program.
2.3 APPLICABILITY 2.3.1 The program is applied to systems, equipment and components to the extent consistent with their importance in preventing or mitigating the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The program is therefore applied, but not limited to the structures, systems and components defined in the plant Q-List (safety re-lated). Changes to the Q-List require review / approval by En-gineering, Licensing and Quality Assurance. Distribution of the Q-List is maintained and controlled by the Licensing Section.
Control also includes the revision number and date i.f each change and maintenance of a list of personnel in possession of the Q-List.
2.3.2 The program functions in addition to the Quality Assurance Manual-Nuclear Construction. The Manager of Quality Assurance, the Director of Technical and Environmental Servic2s, and the Vice President of Generation and Construction shall approve the program.
Program adequacy and effectiveness is determined by performance of i audits. '
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( 1 2.3.3 AP&L shall be responsible for the asso that nuclear fuel
(_,) used in APhL nuclear plants is designed, procured, manufactured, and utilized in accordance with regulatory requirem<nts, and re-lated industrial codes and standards. Nuclear fuei assemblies are considered to be Q-List (i.e., safety-related) items. AP&L dele-gates to Middle South Services the actual performance of quality assurance functions related to the design, procurement and manu-facture of nuclear fuel (reference- paragraph 1.7). The Middle South Services Quality Assurance Program for the performance of this activity is reviewed and approved by the Manager of Quality Assurance. The technical interface with Middle South Services is the responsiblility of the Manager, Nuclear Fuel. The interface and its attendant duties and responsibilities are controlled by the Procedure for fuel wanagement control (GCP-310). On-site quality control of nuclear fuel is implemented through the use of station administrative procedures. These procedures include the receipt, inspection, handling, storage, and accountability of Special Nuclear Material (SNM). The Nuclear Engineer mair.tains a listing of those individuals qualified to perform receipt inspections.
2.3.4 The program assigns responsibilities and duties to specific positions. These responsibilities and duties may be performed by other qualified persons if the specified individual is not avail-able.
,, 2.4 PROCEDURES
('~')
l 2.4.1 Activities which affect quality shall be defined in appro-priate procedures. Procedures shall be developed to cover AP&L administration and cont rol. The procedures shall state t he poli-cies and instructions necessary to fulfill the intent of the pro- am.
Procedures shall provide for standard forms, lists, and cher" l used in documenting the inspections, certifications, reviews audits. The program and the procedures shall be modified or t plemented from time to time as the need for change arises during the life of the Plant.
l 2.4.2 The procedures ensure that activities affecting quality are i performed under suitably controlled conditions. Controlled con-ditions include the use of appropriate equipment; suitable environ-mental conditions for performing the activity such as adequate cleanliness and assurance that required prerequisites for the given activity have been satisfied. The procedures also specify the need for special controls, processes, and test equipment to attain the required quality, and the need for verification of quality by inspection and test.
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DATE REV. 5 QUALITY ASSURANCE MANUAL 10/10/80 TITLE: QUALITY ASSURANCE PROGRAM PAGE 2 of 13 SECjl0N
() 2.4.3 Program Procedures (1) Quality Assurance Procedures The Quality Assurance Organization employs a system of procedures designated as Quality Assurance Procedures (QAP) in order to im-plement the requirements of the program. The QAP's and revisions thereto are prepared by th e Quality Assurance Organization, re-viewed and approved by the Manager of Quality Assurance and ap-proved by the Director, Technical & Environmental Services and the Vice President, Generation and Construction. QAP's referenced in this document are listed by title in Table 2-1.
(2) Station Administrative Procedures The station operation organization employs a system of procedures designated as ANO Administrative Procedures. These p.acedures implement Quality Assurance Program requirements and control on site activities. Station Administrative Procedures and changes
, thereto are prepared by the ANO staff, reviewed by the Plant Safety Committee and approved by the General Manager. The pro-cedures and revisions are examined by the Manager of Quality As-surance to assure that Quality Assurance Program commitments are met.
(~ ) (3) Quality Control Procedures v
The station Quality Control Organization employs a system of pro-cedures which are part of the Station Administrative Procedures.
These procedures provide technical and administrative guidelines to the Quality Control staff from the ANO General Manager. The QC procedures provide direct support to the Quality Assurance Program and employ a system of surveillance and inspection to verify con-trol of quality at ANO.
(4) Generation and Construction Procedures The Generation and Construction Department-Little Rock General Office (LRGO) employes a system of procedures designated as Generation and Construction Department Procedures (GCP) in order to implement Program requirements for the control of design, engineering and procurement activities in support of the operating plant.
The GCP's and revision thereto are prepared by Generatien & Con-struction LRGO personnel, reviewed by the manager of Quality As-surance, and approved by the Generation and Construction (LRGO)
Procedures Task Force. GCP's referenced in this document are listed by title in Table 2-3.
m L) i DATE QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: QUALITY ASSURANCE PROGRAM PAGE 3 of 13 SECjl0N
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, ; 2.4.4 Other organizations within APSL may establish written pro-(J cedur;s to control support activities affected by the requirements of this program. Procedures developed by such organizations shall be prepared and reviewed for technical adequacy within the cog-nizant organization, reviewed by the Manager of Quality Assurance and approved by the cognizant organization's manager.
2.4.5 Any procedure used at the operating plant in the master plant manual will be reviewed and approved in accordance with adminis-trative procedure 1000.06 (see Table 2-2). Review of procedures by the Manager of Nuclear Quality Control, or his designee, is required as stated in paragraphs 5.2.6 and 10.1.4 of this TOPICAL.
2.5 PROGRAM REVIS10N AND CONTROL 2.5.1 Program revision and control shall be the responsibility of the Manager of Quality Assurance.
2.5.2 Proposed changes to the program shall be stJ mitted by the Manager of Quality Assurance to cognizant directors and managers for review and comment prior to approval. The Nuclear Regulatory Commission Quality Assurance Branch, Division of Project Management shall be notified of changes to this TOPICAL as follows: 1) Pro-grammatic Changes (except for those at are editorial in nature) prior to implementation of the change and 2) organizational changes p within thirty days af ter announcement .
t ,
s 2.5.3 After resolution of comments as described in paragraph 2.5.2, changes to the AP&L Quality Assurance Program shall be approved by the Manager of Quality Assurance, Director, Technical & Environ-mental Services, and the Vice President, Generation and Construc-tion.
2.5. Quality Assurance Programs of Others 2.5.4.1 The program includes provisions that require suppliers, cont ractors, subcont ractors, consultants, etc., to maintain and use adequate quality assurance programs.
2.5.4.2 Contractor quality assurance programs shall be reviewed and approved by the Manager of Quality Assurance or his designee. The review and appcoval of such documents by AP&L in no way relieves the contractor of his responsibility to AP&L to meet the applicable qtta1ity requirement s of the 1icensing agency as out1ined in 10 CFR 50, Appendix B. Audits by the Quality Assurance Organization provide assurance of compliance with applicable procedures.
2.6 SYSTEM, STRUCTURE, AND COMPONENT CLASSIFICATION 2.6.1 The systems, .;t ructures and components that perform safety-n
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DATE QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: QUALITY ASSURANCE PROGRAM PAGE 4 of 13 SECTION 2
,s
) related functions are designated as Q-List items. The Q-List specifically identifies those systems, structures and components whose failure could cause an uncontrolled release of radioactivity, or those essential for safe shutdown and the immediate and long-term operation following a Loss of Coolant Accident. When struc-tures, systems or equipment as a whole are on the list, portions not associated with a loss of safety function are not meant to be included.
2.6.2 The Q-List is initially generated by the architect-engineer during the design phase of the project. The Q-List is considered a design document and is reviewed and approved in accordance with the procedure for Licensing / Document Control (GCP-300). The approved Q-List is retained as a functional document throughout the life of the plant to provide for the application of Program requiremencs to a specific system, structure or component. The Manager of Licers-ing is resonsible for maintaining and controlling the Q-List.
Changes to the Q-List require review and approval by Licensing, QA, and Engineering. Distribution of the Q-List is maintained and controlled by the Licensing Section. Control also includes re-vision number and date of each change, and maintenance of a list of personnel in possession of the Q-List.
2.6.3 Expendable and/or consumable items whose quality is necessary for the performance of Q-List structures, systems, and components
(_
- are controlled to assure service quality. This is accomplished as follows
Diesel Fuel Service Quality is assured by provisions / tests required by Technical Specification 4.6.1.4 (e)
Unit I and 4.8.1.1.2 (b)-Unit 2.
Welding Rod Service Quality is assured by procurement from an evaluated source, requiring material test results, and controlling the rod on-site prior to use, to prevent degradation.
Boric Acid Service Quality is assured by procurement from an evaluated source, requiring a batch analysis to assure conformance with our specification require-ments, and on-site control prior to use, to prevent degradation.
2.7 TRAINING AND PERSONNEL Employees whose duties and responsiblities are related to the quality assurance activities at the Plant shall participate in appropriate indoctrination and training programs. It shall be the responsibility of the employee's immediate management to arrange n
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DATE REV. 5 QUALITY ASSURANCE MANUAL 10/10/80 T TLE: QUALITY ASSURANCE PROGRAM PAGE 5 of 1 ", SECTION 2
.3 for the quality assurance indoctrination program. The General Manager has responsibility for Plant Staff personnel indoctrination regarding the Quality Assurance Program.
2.7.1 Quality Assurance Indoctriaation The purpose of quality assurance indoctrination is to familiarize the employee with the Quality Assu;ance Program. Emphasis is placed on the importance and meaning of quality assurance as it applies to the employee's particular position and function.
2.7.2 The quality assurance indoctrination for the management of AP&L support organizations shall be conducted by the Manager of Quality Assurance or his designated representative. The management of the support organization in turn is responsible for conducting an indoctrination of employees in their respective groups. The indoctrinations they conduct shall cover the areas in which the group or employee has particular responsibilities. The Quality Assurance Program indoctrination is coordinated at the plant by the Training Supervisor or his designated representative. Quality assurance indoctrination includes the following items:
(1) Discussion of the philosophy and objectives of the Quality Assurance Program.
/m
) (2) Explanation of the Company's quality assurance organization and demonstration of how it affects the duties and responsi-bilities of the employee.
(3) Summary of the Quality Assurance Procedures (QAP's), Quality Control Procedures (QCP's) and the ANO Aministrative Procedures with specific emphasis placed on those sections which most directly affect the employee's position.
(4) Discussion of interfaces with the NRC and contracted organizations.
A record of attendance at quality assurance indoctrination sessions shall be maintained by the Manager of Quality Assurance, for members of the Quality Assurance Organization and AP&L support organizations. The Training Supervisor maintains the record of attendance for plant staf f.
2.8 PROGRAM REVIEW 2.8.1 The Manager of Quality Assurance shall be responsible for an annual review of the Quality Assurance Program for Operations to l dete rmine the effectiveness and proper implementation of the Program i (ANO-14).
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DATE QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: QUALITY ASSURANCE PROGRAM SEC ION PAGE 6 of 13
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2.8.2 Assigned Quality Assurance personnel regularly review the status, adequacy, and effectiveness of the implementation procedures as part of daily work (ANO-17 and ANO-18).
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_) TABLE 2-1 QUALITY ASSURANCE PROCEDURES ANO-6 Supplier Quality Assurance System Evaluation This procedure establishes methods for performing quality assurance audits at th supplier's facility. It is specifically designed ;o verify the quality programs of suppliers to 10 CFR 50, Appendix B ana ANSI N45.2, and provide a method of reporting findings and identifying deficiencies.
ANO-14 AP&L Quality Assurance General Audit This procedure establishes method, for general audit of the operating plant (s), Generation & Construction Organization, QA Section and others to assure that quality activities conform to the requirements of 10 CFR 50, Appendix B.
ANO-15 Review of Supplier Documentation, Evaluation and Qualification This procedure is designed to establish a method for documenting reviews and evaluations performed in-house by AP&L QA personnel to qualify suppliers providing Q-List materials or services. This includes the review and evaluation of the Supplier's Quality Assurance Program,
('
Manual, procedures and/or other supporting documentation, as appropriate.
ANO-17 Operating Plant Surve.l'ance Audit This procedure establishes a method for frequent surveillance audits of plant quality activities to assure compliance with the AP&L Quality Assurance Program. It provides methods to identify areas of deficiency (or potential deficiency) for necessary corrective action.
ANO-18 Generation & Construction LRGO Surveillance Audit This procedure establishes a method for frequent surveillance audits of LRGO Generation & Construction Organization quality acticities to assure compliance with the AP&L Quality Assurance Program. It provides methods to identify areas of deficiency (or potential deficiency) for necessary corrective action.
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( TABLE 2-2 ARKANSAS NUCLEAR ONE Procedures Referenced in the QA Program 1000.06 - Procedure Review, Approval and Revision Control This procedure establishes responsibilities, requireents and methods for the review, approval and revision of plant procedures and work plans, and changes thereto, including temporary changes as defined in the Technical Specification. It also provides guidelines in the safety-related classification of procedures and work plans.
1000.07 - Deviations, Failures and Non-conformances This procedure provides management control to assure identification, ,
documentation, segregation, review, disposition and notification to affected organizations of non-conforming materials, parts, components or services and to assure adequate c.orrective action is accomplished.
1000.09 - Surveillance Test Program Control This procedure establishes responsibilities and provides the description for the Sarveillance Testing and Inspection Program at Arkansas Nuclear
(~] One which assures that structures, systems and components operate within i / normal parameter limits and will put the plant in a safe conditfan if these limits are exceeded.
1000.11 - Purchase Requisition Preparation and Control Procedure This procedure establishes the methods and responsibilities for the preparation, review, approval and processina of Purchase Requisitions for items and services to be used at ANO.
1000.13 - Control of Station Modifications This procedure establishes contcol of station modifications. It establishes responsibilities and provides a general methodology for the review, classification and implementation of station modifications to assure that design changes receive appropriate review and control.
1000.16 - Document Control Requirements this procedure establishes responsibilities and instructions for the receipt, control, distribution and updating of controlled drawings and documents which include design drawings, FSAR, lechnical Specifications and Procedures.
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(-] 1000.17 - Records Management v
This pro:edure establishes records management control and describes the organization and operation of the Records Management System at Arkansas Nuclear One.
1004.01 - Quality Control Program Implementation This procedure establishes responsibilities and provides the ANO Quality Control staff with detailed guidance for implementation of the Quality Control Program.
1013.09 - Document Retention and Disposition This procedure provides a uniform method for establishing the retention requirements for all QA documents and Plant Administrative Records.
Retention periode are designated for all documents concerning the design, testing and operation of the plant.
1032.03 - Design Document / Drawing Control This procedure establishes responsibilities and requirements for activities to be performed by Plant Engineering and Drawing Control to design documents at Arkansas Nuclear One.
73 1032.04 - Control of Spccial Processes
.a i This procedure establishes the interface controls between the Engineering Department at ANO and the contractors hired to perform special processes such as welding, heat treating and NDE.
1032.06 - Procurement Technical Assistance This procedure provides for engineering evaluation by qualified individuals in the procurement of spare and replacement parts, materials and services to ensure that they are purchased to specifications and codes equival, those specified for the original equipment, and any changes to tL o.tginal specification are documented and approved prior to procurement.
1033.01 - Material Receiving and Inspection This procedure establishes the method by which material is received and inspected to assure that material is in satisfactory condition, conforms to purchase order requirements, other required standards, codes and specifications, and contains proper identification and documentation.
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' j 1033.02 - Control of Material This procedure provides specific instructions and requirements for handling, storage and shipment of materials by stores personnel at ANO.
1033.06 - Stores Receipt, Issue and Return This procedure establishes the administrative controls and requirements related to the receipt, s to ra ge , issue and return of materials, parts, components and equipment under the control of the Material Management Supervisor.
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) TABLE 2-3 GENERATION & CONSTRUCTION (G&C) PROCEDURES These Procedures apply for those activities conducted at the AP&L Generation and Construction Little Rock General Office (LRGO).
GCP-100 Procedure Development Methodology and Documentation Standards This procedure establishes tne methods by which Generation and Con-struction Department LRGO procedures (GCP's) are prepared, revised, and controlled.
GCP-101 Drawing Control This procedure establishes the responsibility of the LRGO and the method by which engineering drawings, either in paper form or on aperture cards, are controlled, including receipt, filing, disposition of super-seded drawings, and retention.
JCP-102 Procurement This procedure establishes the responsibilities and methods by which procurement of safety-related parts, material or services is reviewed
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and approved by the LRGO. It includes the required QA review and tech-nical review of contractor prepared purchase specifications and docu-ments. This procedure also provides detailed control for the actual preparation, review and approval of a purchase requisition and for the distribution control and follow-up of the actual purchase order released to the vendor by the Supervisor of Purchasing.
GCP-201 Design Change Package Control This procedure establishes the methods used within the LRGO to maintain control of design changes during design and control of modifications to operating nuclear plants.
GCP-202 Design Process This procedure explains the process by which design inputs are trans-lated into documents to accomplish final design. This includes de-ign analysis and calculations, when applicable. This procedure also estab-lishes the methods used within the LRGO for the independent checking of design documents through a formalized design review or alternate calcula-tion or qualification testing, g
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TAB 12 2-3 GENERATION & CONSTRUCTION (G&C) PROCEDURES (Continued)
GCP-203 Document Preparation, Change, and Review ,
This procedure establishes those design documents that are controlled within the LRGO by providing a standardized preparation, change and review system.
GCP-204 Design 'eficiency/ Corrective Action This procedure formalizes the reporting of design deficiencies and provides a method of positive feedback to assure that appropriate corrective action is taaen to prevent recurrence of f,he deficiencies.
GCP-310 Fuel Management Control This procedure establishes the methods by which the Manager, Nuclear Fuel controls the interface for fuel mariagement between Middle South Services, the operating nuclear plant and the LRGO.
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( 3. DESIGN CONTROL 3.1 SCOPE 3.1.1 Design activities shall be controlled to assure that proposed plant changes to the structures, systems, equipment and components conform to applicable regulatory reqe.irements and that design bases are correctly translated irito appropriate design documents. Design Control activities will be in accordance with the requirements of Regulatory Guide 1.64 - Rev. 2 (11/76) as interpreted in Ap-pendix A.
3.2 GENERAL 3.2.1 Generation and Construction LRGO shall be responsible for the continued upgrading and modification of plant design. Design documents (drawings, specifications, procedures and instructions) originating or released for review through these departments shall be based upon the required regulatory requirements, quality stand-ards and design bases in accordance with NRC licensing require-ments. Design activities may include calculations, analyses, materials, selection, equipment arrangement and layouts, and sped fications of teat and inspection criteria that are essential to the ;afety-related fJnctions of the structures, systems and comp, rents. Those design activities performed by individuals within the Generation and Construction LRGO are controlled by (n $
the use of GCP's for the design process (Gle-202). The plant staf f uses Administrative Procedure 1000.13 for the control af design act.ivities.
3.2.2 Design standards and requirements shall be at least equiva-lent to those employed during the construction of the station and shall be consistent with the technical specifications and license provisions.
3.3 DESIGN PROCESS / VERIFICATION 3.3.1 To assure that the design is adequate and that the above requirements and procedures are satisfied, each design is reviewed by Generation and Construction LRGO personnel. Alternately, design verification may also be accomplished using alternate calculation methods or by the establishment of a suitable test program. Where a test program is used to verify the adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualification testing of a prototype unit under the most adverse conditions.
3.3.2 Design reviews generated within AP&L are accomplished using N ._ '
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4 the design verification section of the design process procedure (GCP-202).
3.3.3 During the above reviews, particular attention shall be given to the following areas:
(1) Assurance that all appropriate standards are clearly delineated. Where it is considered necessary to deviate from these standards, separate written approval shall be required from the Director, Generation Engineering and shall be appended to the approval sheet releasing the document (s) for implementation.
(2) Assurance that the qualifying information for the ma-terials, components, equipment and processes is con-tained in the documents and is suitable for the in-tended applications. This information shall include, as applicable, the physics, hydraulics, thermal, strength and accident analysis utilized; the com-patibility of design for in-service inspection, main-tenance and repair; and the acceptance criteria for inspections and tests. Performance history and failure data on installed components is considered when similar components are intended for installation as part of a system or structure modification.
(. (3) Assurance that design interfaces are compatible and con-sistent with the over'all design bases and existing sys-tems shere more than one activity has participated in the designs.
(4) Assurance that the design document is consistent with the Safety Analysis Reports and, if required, that the need for NRC approval prior to the final approval of the design docu-ment has been identified.
(5) Assurance that the inspection requirements of Section 10 are included and adequate.
(6) Assurance that significant and recurring errors and de-ficiencies discovered in the design as a result of the ;
revicus are documented and disposition assigned. A feed-back system of corrective action by distribution of the review connents to the originating activity shall be used to prevent repetitive errors or deficiencies in the design process.
3.3.4 Additional changes to the basic document (s) (including field
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s_ changes as a result of modifications which in any way affect the l technical adequacy of the design) shall be subject to the same review criteria as the basic documents.
3.4 DESIGN RECORDS 3.4.1 The Plant Administration Manager shall be responsible for maintaining permanent records of the design documents for the construction and testing phases. In addition, he shall be re-sponsible for maintaining records of the upgrading or modification of these documents as described in this section. The controls for maintaining these records are established by specific procedures described in Section 17. These records provide the historic re-ference necessary for the safe and reliable operation of the plant.
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( 4. PROCUREMENT DOCUMENT CONTROL 4.1 SCOPE 4.1.1 Control of the procurement activities shall provide assurance that applicab: a regulatory requirements, design bases, technical re-quirements and Tiality assurance criteria are suitably included or referenced in tie documents for procurement of material, equipment, and services, whether purchased by AP&L or by its contractors and/or subcontractors. Procurement documents are the drawings, specifica-tions and purchase requisitions that result in a purchase order. Pro-curement document control activities will be in accordance with Regu-latory Guide 1.123 Rev. 1 (7/77) (reference Appendix A).
4.2 GENERAL 4.2.1 Vendors shall be selected from the Qualified Vendor List (QVL).
Quality Assurance personnel as desigcated by the Manager of Quality Assurance shall normally evaluate the QVL quarterly but at least once per year to determine the need to requalify inactive suppliers or re-move their names from the QVL.
4.2.2 Vendors may be placed on the QVL as approved by the Manager of Quality Assurance or his designee by any of the following methods:
f1 (1) By satisfactorily meeting 10 CFR 50, Appendix B requirements that
(,! are applicable to the vendor by facility survey by AP&L (ANO-6).
(2) Pursuant to appropriate documented information received from others, i.e., architect-engineer, NSSS supplier, other utilities ,
NRC, ASME, etc., indicating a program meeting appropriate require-ments of 10 CFR 50, Appendix B.
(3) A review of the supplier's current quality records supported by evidence of documented qualitative and quantitative information which can be evaluated. This includes review and evaluation of the supplier's quality assurance program, manual and procedures, as appropriate (ANO-15).
(4) Evaluating the supplier's history of providing a product which performs satisfactorily in actual use. Evaluation information includes:
- a. Experience of users of identical or similar products of the prospective supplier and/or
- b. Purchase records that have been accumulated in connection with previous procurement actions and product operating expertence. l l
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,) 4.2.3 Purchase documents for spare or replacement parts or parts of safety-related structures, systems or components, including "off the shelf" items, procured by the plant staff shall be reviewed by the Manager of Nuclear Quality Control or his designee for adequacy of quality requirements. The review determines similarity, compatabil-ity, current regulatory applicability and inclusion of, at a minimum, the quality assurance requirements and acceptance criteria of the original part.
As part of the review, a document control form shall be included which specifies the documents to be supplied by the vendor to verify that engineering quality, inspections and tests have been completed.
4.2.4 The preparation, review and control of procurement documents are established in the procedures for purchase requisition prepara-tion and processing (GCP-102; AP-1000.11).
4.2.5 The Manager of Quality Assurance shall verify the compliance with procurement procedures and shall evaluate the effectiveness of these procedures. Methods of verification and evaluation are delin-cated in quality assurance procedures for surveillance audits and general audits (ANO-14, ANO-17, ANO-18).
4.2.6 When multiple procurement is involved, the Purchasing Department shall apply identical quality assurance requirements to each vender.
t i 4.2.7 AP&L purchase documents shall require prime vendors to apply the applicable quality assurance requirements to each sub-tier vendor where such requirements apply to the goods or services being purchased by AP&L from the prime vendor.
4.3 REQUISITIONS 4.3.1 Plant staff initiated requisitions for Q-List material, equip-ment or services may be initiated by any plant employee, but sha 1 be reviewed and approved by the cognizant supervisor, Manager of Nuclear Quality Control or his designee and by the General Manager or his des-ignee before issue of a purchase order (AP-1000.11). Changes, other than minor changes, to plant staff initiated purchase requisitions, purchase orders and supporting documentation shall be reviewed by the cognizant supervisor and the Manager of Nuclear Quality Control or their designees. The General Manager or his designee approves the change when the required reviews have been completed. Minor changes will be r.iade as indicated in t he last sentence of paragraph 4.3.2.
4.3.2 Little Rock General Office (LRGO) requisitions are initiated when a Q-List design change is involved as described in the procedure for procurement control (GCP-102) or by the plant staff as described
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(~^ in 4.3.1. LRGO initiated requisitions are reviewed by QA personnel, x_/ approved by cognizant engineering personnel and the Director, Nuclear '
Operations or his designee. Major changes to LRGO initiated re-quisitions such as changes in Q-designation, changes in quality requirements, etc. shall be subject to the same deFree of control as was utilized in preparation of the original requisition. Minor changes such as inconsequential editorial corrections or changes to commercial terms and conditions ,an be made by the Nuclear Buyer after verbal approval from the affer: 4 originating individuals.
4.3.3 Requisitions for Q-List items shall be clearly identified as Q-List.
4.4 SPECIFICATIONS 4.4.1 Specifications for Q-List replacement parts shall be eval-uated against the specifications under which the equipment was originally furnishad. This evaluation shall resalt in the estab-lishment of Baseline Quality Requirements by a qualifie? engineer (reference AP-1032.06).
4.4.2 Q-List specifications shall be reviewed by the Generation and Construction LRGO organization to assure that applicable codes, standards and other design bases are included or referenced and that appropriate and sufficient requirements for quality assurance
,s documentation are incorporated therein. Applicable redes, standards
( ,) and other design bases are determined f rom a review of the FSAR, Q-List, material control list, drawings and other design disclosure documents which apply to the "as-built" plant. These review require-ments are specified in the Quality Assurance procedure for licensing /
document control (GCP-300).
4.5 PURCllASE ORDERS 4.5.1 Purchase orders shall be issued by AP&L Purchasing Department and shall affirm those requirements set forth in the specification.
4.5.2 Purchase orders for Q-List items shall require that vendors and their subvendors possess a Quality Assurance Program consistent with the applicable requirements of 10 CFR 50, Appendix B, or ANSI N45.2 which apply to the specific goods or services provided by that vendor. The Purchase Order shall include provisions for source sur-veillance and inspection. Source surveillance and/or inspection will be conducted when deemed necessary based on the importance of malfunc-tion or failure of the item, ability to verify the quality of an item through receipt inspection or acceptance testing at the jobsite, degree of standtrdization and vendor history. The purchase eviginator will be responsible for establishing the need for surveillance. AP&L QA/
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p QC review of the procurement document signifies concurrence with the V decision for source surveillance and/or inspection.
4.5.3 Changes to purchase orders and reference documents for Q-List items are to be subject to review equivalent to that of the original documents (reference paragraphs 4.3.1 and 4.3.2.)
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(~1 S. INSTRUCTIONS, PROCEDURES AND DRAWINGS
.J 5.1 SCOPE 5.1.1 Instructions, procedures and drawings shall be provided as necessary for the control of those activities which affect quality.
Activities controlled by procedures include: Administration, nor-mal operations, maintenance, security, inspection, testing, health physics, chemistry, refueling, surveillance, emergency operations, quality assurance, quality control and LRGO activities.
5.1.2 Additional procedures may be required as determined by a cognizant manager or director.
5.2 GENERAL 5.2.1 Instructions, tests, calibration, specifications, procedures, maintenance, modification and repair processes are developed, re-viewed and approved according to the administrative procedure on handling of procedures (AP-1000.06). Generation and Construction LRGO procedures are developed, reviewed and approved in accordance with the administrative procedure for revision and control (GCP-100).
Drawings are controlled by the administrative procedure for drawing control (AP-1032.03 and GCP-101). Drawings and specifications re-lated to plant modifications are reviewed according to the procedures
,s for design change control (AP-1000.13 and GCP-201) for QA concurrence
( of the quality designation of the design change package. QA review of drawings is conducted by the Plent Safety Committee (PSC) for design changes authorized by Plant Staff personnel. QA review of LRGO authorized ign changes, drawing revisions, etc., is accom-plished by LRGO Lugineering personnel. QA review entails assuring that drawing revisions incorporate quality requirements equivalent to those originally specified. QA review of new purchase specifi-cations or revised purchase specifications is accomplished by QA personnel. This review assures that quality requirements specified are consistent with program requirements. QA review of procedures and changes to procedures referenced in Tables 2-1, 2-2, and 2-3 is conducted by QA personnel. This review assures that the procedure change is consistent with QA Program requirements. QA review of plant operating procedures, other than those procedures described in paragraphs 5.2.6 and 10.1.4, is conducted by the PSC. This re-view assures that each specific procedure is consistent with commit-ments applicable to the procedure.
5.2.2 Instructions, procedures and drawings which prescribe activ-ities which affect quality shall include appropriate quantitative or qualitatise criteria for determining that important activities have been satisfat t orily accomplished.
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's 5.2.3 Procedures which affect quality shall include measures to u- document the activity being performed.
5.2.4 To assure accomplishment of the activities in accordance with approved instructions, procedures and drawings, each super-visor shall be responsible for quality compliance of personnel under his supervision. Surveillance by the ANO Ouality Control staff and periodic surveillance by Quality Assurance personnel ensures compliance with approved instructions, procedures and drawings. Additionally, audits by the Quality Assurance Engi-neer (Operations) and Quality Assurance Engineer (Engineering) verify compliance with approved instructions, procedures and drawings.
5.2.5 The format, content and philosophy of instructions and procedures shall comply with the guidelines provided in ANSI N18.7-1976, " Administrative Controls of Nuclear Power Plants".
5.2.6 The Manager of Nuclear Quality Control reviews and approves, including changes, the following types of procedures:
(1) Safety-related administrative and QC procedures.
(2) Maintenance and surveillance procedures which involve major disassembly and reassembly or replacement of subassemblies 7s or components which affect the safety-related functional
(, performance of the equipment / component.
This review is performed to ensure compliance with the requirements of the AP&L QA Program and adequacy of inspection hold points. Im-plementation of these procedures will be subject to hold points and surveillance 2nspection by the QC sect. ion.
5.3 TEMPORARY CllANGES 5.3.1 Temporary changes to procedures in the Master Plant Manual which do not change the intent may be made provided such changes are approved by two members of the plant staf f, at least one of whom holds a senior reactor operators license on the unit affected.
Additional reviews are required for specific procedures listed in pa ragraph 5.2.6.
5.3.2 Temporary changes to the procedures in the Master Plant Manual which involve an intent change may be made provided such changes are reviewed by the PSC, approved by the General Manager or his representa-tive prior to implementation. Additional reviews are required for specific procedures listed in paragraphs 5.2.6 and 10.1.4.
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. 5.4.1 Changes or revisions to approved plant instructions, procedures or drawings which affect quality are controlled by the procedure on handling of procedures (AP-1000.06).
5.4.2 Changes or revisions to Quality Assurance procedures require the same review and approval as specified by paragraph 2.4.3.
5.4.3 Changes or revisions to Generation and Construction LRGO pro-cedures are controlled by the procedure on revision and control (GCP-100).
5.5 REVIEW OF PROCEDURES, INSTRUCTIONS AND DRAWINGS 5.5.1 Applicable procedures, instructions and drawings shall be re-viewed following any unusual incident (e.g., abnormal equipment mal-function or accident) and revised, as necessary, to prevent recurrence of such incidents.
5.5.2 Applicable instructions, procedures and drawings shall be re-viewed and revised, as necessary, following any modifications to the plant.
5.5.3 Applicable instructions and procedures shall be reviewed and
,s revised, as necessary, following major changes to the Quality Assur-() ,
ance Program.
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i c', 6. DOCUMENT CONTROL V
6.1 SCOPE 6.1.1 The issue, receipt, use and storage and changes thereto of documents which affect quality shall be controlled. Documents which shall be controlled include drawings, specifications, instructions and procedures.
6.1.2 Documents are controlled by the following procedures:
(1) Design Change Package Control (GCP-201)
(2) Document Change and Review (GCP-203)
(3) Records Management (AP-1000.17)
(4) Document Retention (AP-1013.09)
(5) Document Control Requirements (AP-1000.16)
(6) Drawing Control (AP-1032.03 and GCP-161) 6.2 GENERAL s 6.2.1 Documents pertaining to quality-related activities such as
,, specifications, procedures and drawings shall be used only after proper review and approval.
6.2.2 The Plant Administration Manager shall supervise the issuance of the Master Plant Manual and shall assure that the approved revi-sions are distributed to the location where the subject activity is being performed.
6.2.3 An issue sheet or facsimile shall be employed to maintain a record of persons to whom documents have been issued.
6.2.4 Changes in documents shall be subject to the following:
(1) Prior to implementation, documents affecting quality such as instructions, procedures and drawings shall be reviewed to assure that they are adequate and timely and that appropriate quality requirements are clearly and accurately stated.
(2) Individuals and groups responsible for reviewing, approving and issuing documents and revisions thereto are identified in procedures for handling of procedures (AP-1000.06) and document control (AP-1000.46).
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( ) (3) Changes to documents such as operating procedures, maintenance x> procedures and as-built drawings shall be reviewed and approved by the same organizations which performed the original review and approval. If such is not possible, the review is delegated to appropriate qualified responsible groups.
(4) Obsolete and superseded documents shall be destroyed (except for one file copy) or marked to prevent inadvertent use.
6.2.5 Permanent plant documents are stored at the plant site by the plant staf f under supervision of the Plant Administration Manager. Records (or copies, as appropriate) generated by Gene-ration and Construction, Quality Assurance or others are provided to the plant staff for storage. These records include:
(1) Procurement documents for items purchased by Generation and Construction.
(2) Design specifications, drawings and design criteria originated or revised by Generation and Construction.
(3) Design tuange Request packages and supporting documents.
6.3 DOCUMENT IDENTIFICATION 7 s 6.3.1 Documents shall contain a title descriptive of their purpose
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_ or applicability and shall be conspicuously labeled as to current status (Draft, Preliminary, Approved, Void, etc.).
6.3.2 An indication of current revisions to specifications, proce-dures and drawings shall be maintained in a document control register or within a revision record page or other appropriate means.
G.4 STORAGE AND FILING REQUIREMENTS 6.4.1 Locuments which affect quality shall be stored at the plant in permanent storage facilities in a manner which allows ready and positive identification and retrievability. The storage technique shall minimize damage and preserve the integrity of the documents.
Storage controls are set forth in procedures for plant records man-agement and document retention (AP-1000.17; AP-1013.09).
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c' 7. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES v
7.1 SCOPE 7.1.1 The purchase of material, equipment and services shall be controlled to assure that, whether purchased directly or through vendors, the material, equipment and services which affect quality conform to the procurement documents. frocureme.it control shall include provisions for the evaluation and selection of vendors and examination of products upon delivery. The depth and necessity of procurement controls depend upon the uniqueness and complexity of the item / service, procurement frequency with the same supplier and past supplier performance for the specific items or services covered by the procurement document. The control of purchased material, equipment and services will be in accordance with the requirements of Regulatory Guides 1.38 Rev. 2 (5/77) and 1.123 Rev. 1 (7/77) as interpreted in Appendix A.
7.2 SOURCE EVALUATION 7.2.1 Vendors shall be selected on the basis of demonstrated capa-bility during the design and construction phase to provide a quality product, process or service in accordance with the procurement docu-ments for the operational phase.
7s 7.2.2 When the vendor is not on the Qualified Vendor List (QVL), the
! l Manager of Quality Assurance shall review and approve the vendor's qualifications as described in paragraph 4.2.2.
7.3 DOCUMENTATION OF QUALITY 7.3.1 Verifiable evidence of quality shall be furnished by vendors as prescribed in the procedure for procurement control (GCP-102).
7.3.2 Documentary evidence that material and equipment cc. form to the procurement requirements shall be available at the site prior to installation or use of such material and equipment. As necessary, vendors are to be requested to maintain documentation. Measures are established and maintained which control further processing, delivery or installation of a nonconforming or defective item depending on its disposition.
7.4 SOURCE INSPECTION 7.4.1 The effectiveness of quality control by vendors shall be assessed by the QA organization at intervals consistent with the importance, complexity, method of receipt and quantity of the pro-o f
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, y duct or service. Requests for source inspection by QA petsonnel
( -J are made by the Manager of Nuclear Quality Control or his designee or as determined by the QA Engineer (Audit) during review of purchase re-quisitions.
7.4.2 Source inspection shall be documented and shall provide a record of compliance by the vendor with regard to:
(1) The vendor's quality assurance program.
(2) 10 CFR 50, Appendix B, or ANSI N45.2 (applicable to the pro-duct or service provided).
(3) Design and quality classification, codes and standards which ,
apply to the product or service provided.
(4) The procurement document requirements.
7.5 RECEIPT INSPECTION 7.5.1 Upon receipt of Q-List materials at the picnt, a receiving inspection shall be performed and the condition of the material clearly and completely recorded in a receiving report as prescribed in the procedure for material receiving and inspection (AP-1033.01).
This procedure assures that:
(1) The material, equipment or component is properly identified and corresponds with the receiving documentation, as required by 4.2.3.
(2) Inspection of the material, component or equipment and accep-tance records is performed in accordance with predetermined inspection instructions, prior to installation or use.
(3) Items accepted and released are identified as to their inspec-tion status and forwarded to a controlled storage area or re-leased for installation.
(4) Nonconforming items are held in a segregated, controlled area when practical and are clearly identified until proper dispo-sition is made in accordance with the procedure for nonconfor-mance and corrective action (reference paragraph 8.5.3).
(5) Supplier nonconformances which have been accepted by AP&L prior i to shipment of the item shall be documented in the procurement records furnished by the supplier at the time of receipt or the item shall be considered nonconforming as required by Procedure 1000.07.
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(~) 7.6 STORAGE V
7.6.1 Q-List materials shall be handled and stored as prescribed in the procedure for handling, storage and shipping of Q-List materials (AP-1033.02).
7.6.2 Q-List material shall be clearly identified as such and stored in a controlled area.
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- 8. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONEN'fS 8.1 SCOPE 8.1.1 Identification and control measures shall be established to assure that quality-related materials, parts, components and parti-ally f abricated assemblies are traceable to the documentation which verifies their acceptance throughout fabrication, receipt, storage, installation and use of each item.
8.1.2 The measures shall be sufficient to prevent the use of in-correct, defective or illegibly marked materials, parts and compo-nents.
8.2 IDENTIFICATION AND MARKING 8.2.1 Materials, parts and components shall be identified and marked by suppliers in accordance with requirements set forth in applicable codes and in the procurement documents. The requirements shall assure that:
(1) Marking of shipping containers or packages is sufficient to allow proper handling of the container or package and positive identification of received items at the plant.
s (2) Identification o' arts and corresponding documents will accom-s, -
pany all partiatry fabricated assemblies shipped as one unit.
Such documentation shall include, as applicable, heat numbers, part numbers, serial numbe rs, material certifications and weld qualifications to provide sufficient basis for determining the acceptability of the assembly and its component parts.
8.2.2 Marking of items or materials shall be done using methods not deleterious to the integrity of the material.
8.2.3 When specified by purchasing documents, individual items shall be permanently marked.
8.2.4 Group or bundle markings and temporary markings may be autho-rized by the Manager of Nuclear Quality Control as conditions warrant, provided that positive identification and traceability of the items or material can be maintali.ed.
8.2.5 All Q-List materials, parts and components are identified as required by Procedure AP-1033.02.
8.1 TAGGING 8.3.1 In addition to being marked, Q-List materials, parts and compo- !
nents received at the plant site shall be tagged uith a "Q Tag". )
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REV. 5 7)figfgg TITLE: IDENTIFICATION AND CGNTROL 0F MATERIALS, PARTS AND COMPONENTS PAGE 1 of 2 SECTION 8
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permanent records file and the status (e.g., clear for installation, return to vendor, hold for documentation, or hold for repair).
8.3.3 Tagging shall be performed in accordance with the procedure for material identification (AP-1033.01).
8.4 DOCUMENTATION 8.4.1 Documentation for parts and materials received from vendors shall be processed to Records Management for disposition and storage in accordance with Procedures AP-1000.ll and AP-1000.17.
8.4.2 The removal of Q-List items from storage and their subsequent disposition shall be documented and controlled by the Release to Maintenance form described in Administrative Procedure 1033.06,
" Stores Receipt Issue and Raturns".
8.5 DEFECTIVE OR INCORRECT ITEMS 8.5.1 Defective or incorrect materials, parts and components which cannot be reworked or repaired for their intended use by acceptable methods shall be handled in accordance with Section 15 of the program and the procedure for nonconformances and corrective action (AP-1000.07).
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8.5.2 Defective or incorrect itemn shall be clearly identified on the "Q Tag" 8.5.3 Defective or incorrect items shall be stored in segregated areas except for those items which, due to their size, weight con-figuration, etc. , are impractical or impossible to store in the designated controlled storage area.
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, 9. CONTROL OF SPECIAL PROCESSES V
9.1 SCOPE 9.1.1 Special processes performed in the course of operations at the plant are controlled by the procedure on specia? processes (AP-1032.04) to assure that they are properly and safely accom-plished.
9.2 RESPONSIBILITY 9.2.1 The General Manager shall be responsible for assuring compli-ance with the requirements for control of special processes and for developing adequate staf f training and procedures for special pro-cesses identified in the future.
9.2.2 The Operations Manager, Maintenance Manager, Engineering and Technical Support Manager and :lanager of Nuclecr Quality Control shall develop procedures and provide qualified personnel for current spe-cial processes as delineated in the procedure for control of special processes (AP-1032.04).
9.2.3 Quality Assurance personnel shall periodically audit special process procedures and personnel qualifications to assure compliance with applicable codes and specifications.
() 9.3 GENERAL 9.3.1 Special processes include, but are not limited to:
(1) Special maintenance end cleaning.
(2) Metal joining, such as welding and brazing.
(3) Thermal cutting.
(4) llot and cold working and bonding.
(5) Coating and plating.
(6) Nondestructive examination.
(7) Heat treating.
9.4 QUALIFICATION 9.4.1 Personnel shall be qualified and/or certified for each special process according to applicable regulations, industrial standards and other requirements as described in the procedure for control of special processes (AP-1032.04).
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< 10. INSPECTION 10.1 SCOPE l
10.1.1 Onsite and offsite activities affecting quality are inspected to verify conformance with applicable procedures, design documents, codes and specifications for accomplishing the activity.
10.1.2 Inspection of quality-related activities is controlled by the process for inspection (AP-1004.08) which specifies inspection requirements, techniques, documentation and responsibilities as des-cribed in Sections 3, 4 & 7 of the program.
10.1.3 QC personnel reporting to the Manager of Nuclear Quality Control are responsible for quality inspection activities in the areas of special processes, plant modifications, repairs, operation of safety-related items, non-routine maintenance activities and in-service inspection. Receipt inspection of Q-List materials, parts or components is accomplished as follows: A Level I QC Inspector, who may report to the Production Storekeeper, performs the standard count, damage and identification inspections associated with the receipt of all material. A Level II QC Inspector, who normally re-ports to the Manager of Nuclear Quality Control, performs any addi-tional receipt inspection (s) required by the Receipt Inspection Re-port. The Quality Control Engineer then reviews the results of the
,_, material inspections, the PO, QA records and other documentation
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associated with the received item, and authorizes the Hold for QC Clearan ' or Release for Installation.
10.1.4 Safety-related modification and non-routine maintenance pro-cedures and changes to those procedures which involve intent changes are reviewed prior to impleme ntation by the Manager of Nuclear Quality Control or his designee. The Manager of Quality Control or his desig-nee is responsible during this review to determine the need for inspec-tion, identification of inspection personnel, documenting inspection results and hold points.
10.1.5 Inspection hold points are inserted in procedures discussed in paragraph 10.1.4 and in procurement documents based upon safety significance, complexity of the item or activity and degree of standardization of the item or activity, past performance of the vendor, procurement frequency with the vendor and the ability t.o verify quality by job site testing.
10.2 RESP 0NSIBILITY 10.2.1 The General Manager shall be responsible for assuring that plant personnel comply with the regulations, codes and procedures control 1ing inspection.
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TITLE: INSPECTION PAGE 1 of 3 SECTION 10 l
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10.2.2 The Manager of Nuclear Quality Control or his designated representative shall perform inspections within the plant as des-cribed in pa ragraph 10. ; .3. Source surveillance shall be the responsibility of the Manager of Quality Assurance. The Manager of Nuclear Quality Control or his designated representative is respon-sible for inspection records and for assuring that inspection hold points are properly documented.
10.2.3 Quality Assurance personnel shall periodically audit in-spection procedures, inspection records and personnel qualifica-tions to assure that inspection requirements are being fulfilled.
10.3 INSPECTION PROCEDURES 10.3.1 To accomplish inspections, written procedures, instructions, diagrams, forms or checklists shall be provided which as a minimum contain the following:
(1) Qualitative and quantitative acceptance criteria.
(2) Identification of those individuals responsible for performing the inspection operation.
(3) A Cescription of the method of inspection examination, measure-ment or test of material or product process necessary to be performed to assure quality.
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(4) Identification of any special tools, equipment or skills re-quired.
(5) A sign-off by signature, initial or a controlled stamp showing evidence of completing and verifying the inspection.
(6) The results of the inspection operation.
10.3.2 If inspection of processed material or products is impossi-ble or disadvantageous, indirect control by monitoring processing methods, equipment and personnel shall be provided. Both inspec-tion and process monitoring shall be provided when control is in-adequate without both.
10.3.3 Inspection personnel shall verify that inspection equipment utilized is within calibration prior to performing any inspection operation. If improper or out-of-calibration equipment is found, the inspector has the authority to suspend the inspection activities.
The criteria for determining the accuracy requirements for measuring and test equipment used for i spections and tests will either be as a result of historical data ar as recommended in the nanufacturer's specifications, n
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) 10.3.4 If an inspection of a quality-related activity reveals that
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a nonconformance has occurred, the inspector has the authority to suspend further activity until the nonconformance is rectified.
10.3.4.1 Nonconformances are reported and corrective action in implemented in accordance with Sections 15 and 16 of the progran and the procedure for nonc"nformance and corrective action (AP-1000.07).
10.4 INSPECTOR QUALIFICATION 10.4.1 Personnel qualified to perform inspections are normally the onsite Quality Control staff. Personnel qualified to perform inspections shall meet the following requirements:
(1) Be independent from the individual or group performing the activity being inspected.
(2) llave satisfactorily completed the qualification requirements as specified in the procedurc for qualification and certifi-cation ef quality control personnel (AP-1004.04).
(3) Be currently qualified and so designated on a list of quali-fied inspectors approved by the Manager of Nuclear Quality Control or the Manager of Quality Assurance.
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(_) 10.5 DOCUMENTATION 10.5.1 Records of inspections shall be maintained by the Manager of Nuclear Quality Control in accordance with AP-1004.01, "QC Pro-gram Implementation".
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c 11. TEST CONTROL w J' 11.I SCOPE 11.1.1 Necessary testing requirements to dc+. ermine w:iether safety-related structures, srstems and components perform satisfactorily in service shall be established in written test procedures. The test procedures shall incorporate the requirements and acceptance limits contained in the Technical Specifications, codes and regu-lations, and applicable design, operating, maintenance and manufac-turer's documents. Testing within the scope of this section in-cludes both periodic testing and those tests required as a result of modification, maintenance, or repair of safety-related items.
11.2 SURVEILLANCE TESTING 11.2.1 Testing of safety-related structures, systems and components shall be performed by qualified personnel in accordance with approved written test procedurt.s. The supervisor responsible for performing the test shall verify that all test equipment is properly calibrated.
11.2.2 The test procedures shall include the following (as appli-cable):
(1) Test procedure approval sheet.
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() (2) fest objective or applicability.
(3) Prerequisites for testing.
(4) Accceptance criteria.
(5) References.
(6) Special test equipment.
(7) Limits and precautions.
(8) Step-by-step instructions.
(9) System lineup checklists for test and return to normal.
(10) Data sheets providing sufficient parameter checks and data gathering.
(l1) Test results review and approva1 signature sheet..
11.2.3 In addition to regularly scheduled surveillance tests, tests shall be performed following significant plant modification or sig-ni fi cant changes in operating procedures to confirm that the modifi-L,)
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r' cation or changes are not detrimental to the safe and efficient s/ operation of the plant. Provisions which assure that modifica-
- ions, repairs and replacements are in accordance with the orig-inal design and testing requirements or acceptable alternatives include the following procedures
(1) AP-1000.13 Control of Station Modifications (2) AP-1000.11 Purchast Requisition Preparation & Control (3) AP-1000.09 Surveillance Test Control (4) AP-1000.12 Control of Site Contractors (5) AP-1015.06 Section XI Pump & Valve Testing 11.2.4 All surveillance, calibration, checks and inspections re-quired by Section 4 of the Technical Specifications shall be specified on an " Operational Test Control List". This list shall state the title, type of surveillance activity, frequency and cog-nizant individual responsible for completion of the surveillance activity.
11.2.5 To ensure that the required tests are performed as sche-duled within each time interval, a computer program has been de-7 vised te indicate when tests are required. The computer program
() has a master list of plant compcnents. Associated with each com-ponent is information pertaining to the frequency of tests or maintenante activities for that component. With this information, the program generates a weekly schedule with activities for imple-mentation during the upcoming week. If an activity is due for im-plementation during a week, it will be on the schedule irregardless of whether it is monthly, quarterly, semi-annual, or annual in nature. The schedules are then distributed to the individual de-partments for implementation.
I1.3 PROCEDURE APPROVAL 11.3.1 Test procedures shall be subject to the same review and I approval process as outlined in Section 6 of the program.
11.4 DOCUtlENTATION AND REVIEW OF TEST RESULTS l
11.4.1 Test results shall be documented and reviewed to assuce that the test objective has been met and that action called for by the test is taken, 11.4.2 Records of test results shall include at least the following:
(1) Identity of part of material, system, structure or component under test.
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(3) Data taken.
(4) Name and signature of individual performing test.
(5) Test results and conclusions.
(6) Identity of portable test equipment.
(7) Recommendations f or corrective action or retesting resulting from the test.
(8) Review and approval signatures.
11.4.3 Testing records shall provide objective evidence that the testing was performed in compliance with appt <ed procedures. Test-ing records shall be maintained in the plant files in accordance with the procedure for document retention (AP-1013.09).
11.5 PREOPERATIONAL TESTING 11.5.1 A manual describing the provisions that control the transfer of safety-related equipment and records from the principal contractors to AP&L during the preoperational testing phase up to fuel loading
, ~3 shall be prepared and shall include the identification of those sig-(_j nificant QA-related activities; provisions established to assure proper inspection and verification of equipment; the means of tagging and identifying structures systems and components it. a manner that denotes the inspection and test status; and provisions to assure the ef f ective transfer, storage and control of records.
11.5.2 Beginning with issuance of an operating license, additional administrative controls governing testing activities must be imple-mented. The administrative controls utilized during previous test-ing activities must, in some cases, be modified. The ANO plant pro-cedures provide for administrative controls to assure the safe oper-ation of the plant.
11.5.3 The flanager of Quality Assurance is responsible for estab-lishing audits of the preoperational testing program.
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(~} 12. CONTROL OF MEASUREMENT AND TEST EQUIPMENT U
12.1 SCOPE 12.1.1 A control program shall be established to assure that tools, gages, instruments and other measuring and testing devices used in activities affecting quality are controlled and calibrated with suf-ficient scheduled frequency to assure that accuracy is maintained within the limits specified by the inspection or test requirements.
This activity is referenced in the procedure for calibration control (AP-1000.14).
12.2 GENERAL 12.2.1 All measuring and testing devices used in conjunction with Q-List items se systems shall be properly controlled, calibrated and adjusted at specified intervals to maintain accuracy within the necessary limits.
12.2.2 Calibration of thase devices shall normally be in accordance with manufacturer's recommendations, when available, and in all in-stances shall be in a manner that maintains the tolerance for accu-racy of the equipment.
12.2.3 Calibration procedures shall conform to recognized standards fx and local, state and federal regulations.
b 12.2.4 The procedure shall be clearly noted on a calibration report and the comparison standards utilized in the calibration method shall be traceable to the National Bureau of Standards and supported by certification reports and data sheets when applicable.
12.2.5 Measuring and test equipment shall be calibrated against a working standard which should have an accuracy of at least. four times the required accuracy of the measuring and test equipment.
ifowever, accuracies less than four times will be acceptable when warranted by statistical analysis or limited by the state-of-the-art.
12.2.6 When inspection, examination, measurement and test equipment is found to be out of calibration through use or damage, an evalua-l tion of the validity of previous inspection, examination or test re- l sults and the acceptability of items previously inspected, examined or tested shall be made and documented by written report on a case basis. The General Manager or his designee has final approval of such evaluations, and at his discretion may require repetition of the inspction, examination or test.
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QUALITY ASSURANCE MANUAL REV. 5 DATE 10/10/80 TITLE: CONTROL OF MEASUREMENT AND TEST EQUIPMENT PAGE 1 of 2 SECTION 12
/ 12.3 RESPONSIBILITIES C/
12.3.1 The Maintenance Manager shall be re-ponsible for compiling a list of all measuring and testing devices under his control that require periodic calibration.
12.3.2 The control of measuring and testing devices used in the calibration of Q-List equipment shall be the responsibility of the cognizant supervisor, who shall ensure that the devices are used only by qualified personnel and are properly segregated from other devices.
12.3.3 Plant personnel shall be responsible for utilizing only properly identified and calibrated equipment.
12.3.4 The Manager of Nuclear Quality Control and his staff shall he responsible for monitoring test equipment control and use in rder to verify compliance with the program.
12.4 iQUIPMENT IDENTIFICATION 12.4.1 The equipmant identification list identifying equipment re-quiring calibration. shall contain sufficient informat ion to uniquely identify each item listed and shall include calibration intervals and tolerances for accuracy.
(_j 12.4.2 Each item listed on the equipment identification list shall be labeled in such a manner that clearly identifies the equipment and shows date of last calibration and date recalibration is due.
12.5 DOCUMENTATION 12.5.1 The following records shall be maintained in a permanent plant file:
(1) Equipment identification.
(2) Calibration reports and te t data (until recalibrated).
(3) Manufacturer's data sheets.
(4) Calibration procedures.
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. '- ) 13. IIANDLING, STORAGE AND SHIPPING i_/
13.1 SCOPE 13.1.1 Appropriate controls shall be applied to Q-List material, parts, components and assemblies to ensure that they are handled, stored and shipped in a manner which will prevent damage and deter-ioration of the item. These activities are referenced in the pro-cedure for handling, storage and shipping of Q-List materials (AP-1033.02).
13.2 SPECIAL REQUIREMENTS 13.2.1 When special cleaning, preserving, handling, packaging or shipping of purchased material is required, such requirements shall be delineated in appropriate purchase order documents.
13.2.2 Additionally, vendors shall be requested to recommend special procedures required for handling, storage or preservation of supplied materials, parts or components for exceptionally sensitive or critical items af ter their arrival at the station.
13.3 RECEIVING INSPECTION 13.3.1 Upon arrival of material at the station, the Production Store-rx keeper shall be responsible for assuring that the items are inventor-i ) ied and inspected for damage, deterioration and cleanliness as des-cribed in the procedure for material receiving and inspection (AP-1033.01). The QC inspector is i:sponsible for inspecting and class-ifying Q-List materials.
13.3.2 Results of the receiving inspection and disposition of the material shall be noted in the material received inspection report.
13.4 STORAGE AND PRESERVATION The Production Storekeeper shall be responsible for assuring that:
13.4 1 When possible and practicable, materials are stored indoors and, in all instances, in a manner that provides adequate protection against damage or misuse.
13.4.2 Designated items receive special protection such as controlled environment, locked storage, special coverings and segregation to pre-vent contamination.
13.4.3 Storage areas are monitored by the Production Storekeeper so that the security and integrity of stored items is effectively main-tained.
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13.5.1 The llealth Physics Supervisor shall be responsible for I ensuriag that radioactive materials are handled, stored and shipped in accordance with applicable regulatory requirements.
13.6 RECORDS 13.6.1 The Manager of Nuclear Quality Control shall be responsi-ble for assuring that the following permanent records are main-tained to demonstrate proper control over the handling, storage, shipping, cleaning and preservation of Q-List materials:
(1) Material Received Reports.
(2) Quality Control Receiving Inspection Reports.
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/ j 14. INSPECTION, TEST AND OPERATING STATUS LJ 14.1 SCOPE This section describe = the measures to be employed in determining the inspection, test and operational status of systems, structures and components required to prevent or mitigate the consequences of potulated accidents that could cause undue risk to the health and safety of the public (Q-List items). It describes the means used to identify status levels to the operator and for documenting and correcting substandard conditions.
14.2 DETERMINING OPERATIONAL STATUS 14.2.1 Q-List items shall be subjected to a controlled program of surveillance testing and inspections to ensure that failures or substandard performances do not remain undetected and that the re-quired reliability of safety systems is maintained. The procedure for operational test control (AP-1000.09) identifies the surveil-lance tests and inspections to be performed. Nonconformances dis-covered shall be documented and resolved as prescribed in the pro-cedure for nonconformances and corrective action (AP-1000.07).
Cantrols for assuring that tests are scheduled as required and that test results are obtained are provided by a computerized program or a master test control chart. If a test or inspection is not per-O formed within it.s required surveillance interval, the General Mana-(/ ger is informed. lie will take action to assure emphasis is placed on conductance during the scheduled interval.
14.2.2 The adequacy of initially installed components is ensured by manufacturer's testing as required by the procurement contractor and by procedures controlling material receipt and inspection and handling (AP-lG33.01; AP-1033.27). Startup testing and performance tests following modifications verify the adequacy of newly installed items.
14.3 IDENTIFICATION OF OPERATIONAL STATUS 14.3.1 The quality conformance and safe operational status of Q-List materials, systems, st ructures and components shall be indicated to the operator through systems of tagging, as described in the pro-cedure for hold, caution and QC tagging (AP-1000.27). The tagging process clearly identities materials, systems, structures and compo-nents containing nonconforming items and provides administrative cont rol of their use.
14.3.2 Overall Plant Status 14.3.2.1 The Shift Operat ing Supervisor shall maintain sufficient knowlege of overall plant status tests and inspections to control l
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!. ' QUALITY ASSURANCE MANUAL REV. 5 10 M 0 TITLE: INSPECTION, TEST AND OPERATING STATUS PME 1 of 2 SECTION 14 l l
rm The shift operators will maintain a ready overall plant operations.
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_ reference of plant systems, structures and components' alignments, as well as a status board summary of abnormal conditions. The Shift Operating Supervisor shall ensure that personnel performing tests and inspections keep the shift operators informed of the current status of tests and inspections.
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- 15. NONCONFORMING MATERIAL, PARTS OR COMPONENTS f ,
15.1 SCOPE 15.1.1 Nonconforcing items include materials, parts, components, processes and documents that do not conform to applicable regula-tions, codes, standards, specifications or contractural documents.
15.1.2 Nonconforming items shall be controlled to prevent their inadvertent ase or installation. Appropriate procedures shall be established to assere the prompt detection, recording, segregation, verification, technical review and disposition, including records of disposition of nonconforming items. These activities are ref-erenced in procedures for purchase requisition preparation and processing, material receipt and inspection, inspections and non-conformance and corrective action (AP-1000.ll, AP-1033.01, and AP-1000.07).
15.2 GENERAL 15.2.1 All nonconforming materials, parts, components, processes or documents shall be identified as such and reported to the cog-nizant supervisor (s) for disposition and corrective action. This rule shall apply no matter where or when the discrepant item is discovered (e.g., during vendor surveillance, receiving inspection,
,o storage surveillance, installation or operation).
O 15.2.2 The document used by plant staff personnel for identifying, documenting and reporting conditions adverse to quality shall be the Noncoaformance Report. Identification, disposition and correc-tive action sha'l be document ed on the Nonconf ormance Report and will be supported by the tollowi . .NO control documents:
(1) Job Orders (2) Desipi Changes (3) Receipt inspection Reports (4) Surveillance Test Reports (5) Plant Eng t ure ri ng/ Ana l y s i s Reports 15.2.2.1 [L is t he responsibility of each individual at ANO to iden-tity nonconformance, whether related to product, process or documen-tation. The cognizant supervisor confers with interfacing groups to determine an assigned cause and a recommended disposition. The ANO General Manager and the Manager of Nuclear Quality Cor. trol review the disposition and specify any additional corrective action needed. Upon completion of the corrective action, the QC staff performs independent verification and clor,es the nonconformance report. The Flanager of U
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Nuclear Quality Control issues a formal report each month keeping ANO
(_) management informed as to the status of "open" NCR's. Disposition involving use-as-is shall be transmitted to the Manager, Nuclear Oper-ations for review.
15.2.3 The specifications for quality assurance in each procurement document or contract require the vendor or contractor to identify all material or parts that do not conform to the procurement requirements.
All such vendor nonconformances shall be reported to AP&L as required by the applicable purchase order or contract.
15.2.4 The acceptability of rework or repair of materials, parts, components, systems and structures, or of remanufactured items shall be verified by reinspecting the item as originally inspected or by a method which is at least equal to the original inspection method. The rework and repair inspection recordg ; hall be documented and shall become part of the quality assurance records for the item.
15.3 TAGGING AND STORAGE 15.3.1 Nonconforming materials, parts and components shall be tagged with a "Q Tag", or otherwise identified, to prevent inadvertent use and segregated storage shall ha provided except for those items which, due to their size, weight, configuration, etc., are impractical or impossible to store in the designated controlled storage area. Use of the "Q Tag" is described in the procedure for material receiving
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7-and inspection (AP-1033.01).
15.4 DOCUMENTATION 15.4.1 Reports of nonconformance and documentary evidence of their proper resolution shall be maintained in the Quality Control files.
The Manager of Nuclear Quality Control shall issue a monthly report to the General Manager listing all "open nonconformance reports.
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) 16. CORRECTIVE ACTION O
16.1 SCOPE 16.1.1 A corrective action systeu shall be established to assure that conditions adverse to quality are promptly identified and cor-rected. The corrective action system shall provide for determina-tion that the specified corrective measures have been implemented and an assessment of the effectiveness of the corrective measures.
16.2 GENERAL 16.2.1 When deviations, deficiencies, malfur ctions or other abnor-mal occurrences or conditions are encountered, they shall be re-ported to responsible authorities for revie i and disposition in accordance with Section 15 of the program.
16.2.2 Cognizant supervisors shall review discrepancies discovered during the course of station operations, determine their cause and take necessary corrective action to prevent their recurrence.
16.2.3 The General Manager reviews the nonconformance and specifies only additional corrective action that is needed. The General Man-ager also reviews the monthly status report concerning "open" non-conformance reports and takes the appropriate action to ensure cor-r- rective action is both prompt and prevents recurrence. If the con-x ,) dition is of "significant consequence", the General Manager shall request that the Director, Generation Engineering, evaluate the non-conformance for final disposition.
16.2.4 Wlen vendors furnish products or services that do not conform to the rec,uirements of the applicable purchase contract and, in the opinion of the Manager of Nuclear Quality Control, the vendor war-rants consideration for reappraisal, the Manager of Nuclear Quality Control shall submit a vendor reappraisal request to the Manager of Qualit y Assurance for determination of action to be taken. Results of the reappraisal, together with a request for specific corrective actions, shall be transmitted to the vendor. If the vendor does not improve his quality assurance system and products as requested, the Manager of Quality Assurance may remove the vendor from the Qualified Vendor List (QVL).
16.3 SIGNIFICANT NONCONFORMANCES 16.3.1 The following actions shall be taken for reportable occur-rences-(1) '.he NRC shall be notified and/or a report submitted pursuant to Technical Specification requirements.
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('~'l (2) Each reportable occurrence requiring 24-hour notification to the NRC shall be reviewed by the Plant Safety Committee and submitted to the Safety Review Committee and the Manager, Licensing by the General Manager.
16.3.1.1 Nonconformances of "significant consequence" include those noted below:
(1) Conditions that have directly affected the safety of the plant or personnel.
(2) Conditions that have caused the uncontrolled release of radio-active contaminants (liquid, solid, gaseous or air particulate).
(3) Conditions where a number of nonconfo-mances indicate a trend which could lead to unsafe plant operations.
(4) Any condition the General Manager considers to be of major consequence.
Conditions adverse to quality other than violations of Technical Specifications shall be documented as required by the procedure for nonconformance and corrective action (AP-1000.07).
16.3.2 Verification by surveillance or audit of the effective imple-( ' ) mentation of corrective action shall be documented by Quality Assur-V ance personnel. Verification is accomplished by periodic conductance '
of QA audits (ANO-14, ANO-17 and ANO-18).
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17.1 SCOPE 17.1.1 Quality-related documentation covering desien, construction, procurement, f ab ri ca ti on , inspection, maintenance. nonconformance and corrective action, test and audit activities all be filed and safely stored to provide objective evidence of quality-related activ-ities. Records control cetivities will be in accordance with the regulatory position of Regulatory Guide 1.88 Rev. 2 (10/76) as interpreted in Appendix A.
17.1.2 Documents made part of quality assurance records shall include operating logs, results of reviews, inspections, tests, audits, material analyses, qualifications of personnel, procedures, drawings specifications, cc rrespondence and related records pertinent to quality as defined in the procedure for records management.
11.2 RESPONSIl3ILITY 17.2.1 The Plant Administration Manager shall be responsible for the establishment, implementation and maintenance of the records management program to be used throughout the operational life of the plant.
17.2.2 The Plant Administration Manager shall be responsible for
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ensuring that documentation retention requirements comply with applicable codes and regulations. The Manager of Nuclear Quality Control shall assist the Administration Manager in interpreting the codes and regulations and shall provide independent verification of ANO compliance.
17.2.3 Quality Assurance personnel shall periodically audit quality assurance records and records filing and storage procedures to assure that the records management program is being properly implemented.
17.3 DOCUMENTATION RETEN." ION 17.3.1 Lifetime Quality Assurance Records 17.2.1.1 Lifetime records are defined as those which meet one or more of the following criteria:
(1) Those which would be of significant value in demonstrating capability for safe operation.
(2) Those which would be of significant valae in maintaining, reworking, repairing, placing or modifying the item.
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-') (3) Those which would be of significant value in determining the cause of an accident or malfunction of an item.
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(4) Those which provide required baseline data for inservice inspection.
17.3.1.2 Lifetime quality assurance records shall be maintained for the life of the particular item while it is installed in the plant or stored for future use as prescribed in the procedure for document retention and disposition (AP-1013.09).
17.3.2 Non-permanent Quality Assurance Records 17.3.2.1 Non permanent records are defined as those which meet all of the following criteria:
(1) Those of no significant value in demonstrating capability for sa fe operation.
(2) Those of no significant value in maintaining, reworking, re-pairing, replacing or modifying the item.
(3) Those of no significant value in determining the cause of an accident or malfunction of an item.
s (4) Those which do not provide baseline data for inservice inspec-(_j tion.
17.3.2.2 Non permanent records shall provide evidence that an activity was performed in accordance with applicable requirements and shall be retained for specified periods as directed by the pro-cedure for document retention and disposition (AP-1013.09).
17.3.3 Categories of records to be maintained and their appropriate retention periods are desetibed in the procedure for document reten-tion and disposition (AP-1013.09).
17.3.4 The Manager of Nuclear Quality Control shall be responsible for receiving, inspecting and authenticating such documents as di-rected by the procedure for turnover of quality assurance documents for construction to AP&L.
17.3.5 When approved for receipt by the Manager of Nuclear Quality Control or his designee, such records shall be transmitted to the Plant Administration Manager for filing and storage.
17.4 GENERATION AND CONSI'RUCTION 17.4.1 Generation and Construction personnel, other than plant staff,
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that perform work on the plant in the areas of fesign, procurement,
(_), maintenance, modification, testing, quality assurance and special nuclear materials shall document such work and f orward the records to the Plant Administration Manager.
17.5 STORAGE 17.5.1 Permanent records shall be stored in the records vault and shall be:
(1) Adequately protected from earthquake, flood and similar hazar-dous natural phenomena.
(2) hade safe and secure from theft, vandalism and unauthorized use.
(3) Adequately protected against environmental deterioration.
(4) Adequately protected against fire.
17.5.1.1 The following features or suitable alternatives shall be incorporated in the design of the storage facility:
(1) Reinforced concrete, concrete block, masonry or equal construc-tion.
,s (2) Concrete floor and roof with sufficient slope for drainage; if
('~,) a floor drain is provided, a non-return check valve (or equal) shall be included.
(3) Fire retardant door (two-hour Underwriter's rating minimum).
(4) Sealant applied over walls as a moisture or condensation barrier.
(5) Surface sealant on floor providing a hard-wear surface to min-imize concrete dusting.
(6) Foundation sealant and provision for drainage.
(7) Forced-air circulation with filter system.
(8) Dry chemical or gas fire protection system.
(9) No pipe other than those providing fire protection to the storage J facility is to be located wittin the facility. I 17.5.1.2 For storage of film and other special processed records, humidity and temperature controls shall be provided to maintain an environment as recommended by the manufacturer.
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c 17.5.1.3 A list shall be prepared designating those personnel who
(_/ shall have access to the files.
17.5.2 Plant storage systems shall provide for the accurate retrie-val of information without undue delay and shall be sufficient to control and account for records removed from the storage facility.
17.6 RECORDS INDEXING AND RECEIPT CONTROL 17.6.1 Indexing methods and systems for quality-related records are delineated in the procedure for plant records management (AP-1013.09).
17.6.2 Records submitted for filing in either lifetime or temp-orary files shall be subject to the following requirements for receipt control:
(1) Establishment of a records check list designating the required quality-related records.
(2) Establishment of a system designating criteria for document inspection to assure that records are accurately completed, legible and received in good condition.
(3) A file system to indicate which quality-related documents have
,_ been received.
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17.6.2.1 Implementation and enforcement of receipt control require-ments shall be the responsibility of the Plant Administration Manager.
17.7 FINAL DISPOSITION 17.7.1 Final disposition of quality-related records is controlled by the procedure for document retention and disposition (AP-1013.09) which requires that the Plant Administration Manager periodically purge the non permanent files of records retained past their autho-rized retention date.
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, 18. AUDITS d
18.1 SCOPE 18.1.1 The scope and applicability of the audit program includes safety-related structures, systens, components and activities as-sociated with meeting QA program requirements. Audits shall be performed to determine the compliance with, and effectiveness of, applicable Quality Assurance requirements. The audits shall be performed on a planned and periodic basis in accordance with an audit schedule. Supplementary audits shall be performed as re-quired. The Quality Assurance section performs audits of these activities except for those activities identified in section 6.5.2 of the Technical Specifications which are performed by the Safety Review Committee, refereace paragraph 1.6.1.7.
18.2 GENERAL 18.2.1 Reviews and audits of records, station operation, design activities, procurement, construction, maintenance, modification; examination for conformance to the eighteen criteria of 10 CFR 50, Appendix B; and other quality-related activities shall be performed by the Quality Assurance organization to assess the adequacy of the Quality Assurance Program and to verify compliance with established quality program requirements. These activities are performed using
,~ the Quality Assurance procedures for audits (ANO-14, ANO-17 and
() ANO-18).
18.2.2 Audit responsibilities of QA personnel for onsite operating activities include periodic audits of implementation of each of the quality program procedures listed in Table 2-2.
18.2.3 Results of these reviews and audits shall be recorded, re-ported and distributed to responsible management as outlined in the subsection 18.5.
18.2.4 QA personnel shall perform scheduled audits of vendors and service contractors as required to verify and evaluate their quality assurance programs, procedures, and activities, and to assere supplier compliance with procurement requirements. QA personnel also verify that vendors and contractors review and audit the quality assurance programs of their suppliers. This activity is referenced in the pro-cedure for vendor audits (ANO-6).
18.2.5 The Manage ^uality Assurance approves audit schedules and audit procedures s QA personnel and LRGO-QA personnel. A copy of each audit conducted by AP&L QA personnel is also distributed to the Manager of Quality Assurance for review.
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(3) Those which would be of significant value in determining the cause of an accident or malfunction of an item.
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(4) Those which provide required baseline data for inservice inspection.
17.3.1.2 Lifetime quality assurance records shall be maintained for the life of the particular item while it is installed in the plant or stored for future use as prescribed in the procedure for document retention and disposition (AP-1013.09).
17.3.2 Non permanent Quality Assurance Records 17.3.2.1 Non permanent records are defined as those which meet all of the following criteria:
(1) Those of no significant value in demonstrating capability for safe operation.
(2) Those of no significant value in maintaining, reworking, re-pairing, replacing or modifying the item.
(3) Those of no significant value in determining the cause of an accident or malfunction of an item.
(4) Those which do not provide baseline data for inservice inspec-tion.
g' V 17.3.2.2 Non permanent records shall provide evidence that an activity was performed in accordance with applicable requirements and shall be retained for specified periods as directed by the pro-cedure for document retention and disposition (AP-1013.09).
17.3.3 Categories of records to be maintained and their appropriate retention periods are described in the procedure for document reten-tion and disposition (AP-1013.09).
17.3.4 The Manager of Nuclear Quality Control shall be responsible for receiving, inspecting and authenticating such documents as di-rected by the procedure for turnover of quality assurance dscuments for construction to AP&L.
17.3.5 When approved for receipt by the Manager of Nuclear Quality Control or his designee, such records shall be transmitted to the Plant Administration Manager for filing aad storage.
17.4 GENERATION AND CONSTRUCTION 17.4.1 Generation and Construction personnel, other than plant staff, i
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) 18.5.1.1 Upon completion of any audit, a signed written report shall be prepared which includes at least the following items:
(1) Description of audit scope and date.
(2) Identification of the auditor (s).
(3) A summary of audit results.
(4) Details of nonconformances or programmatic deficiencies.
(5) Recommendations for correcting nonconformances or improving the Quality Assurance Program as appropriate 18.5.1.2 The findings of internal AP&L audits conducted by Quality Assurance personnel shall be reported to the Manager of Quality Assurance, the manager and the director of the area audited. Review of the audit report and findings by the Manager of Quality Assurance is accomplished to assure that sufficient audit detail and depth is being accomplished and that findigs are satisfactorily identified and resolved. Review of the audit report and findings by the mana-ger and director of the audited area assures their awareness of the findings. The specific person to whom audit findings are addressed is responsible for meaningful corrective action, however, the above mentioned positions will be copied on internal AP&L audits conducted
(, by QA personnel if they are not the specific addressee. In addition
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to the above, the Vice President, Generation and Construction (VPG&C),
will be copied on all ANO-14 audits. Review of these audits by VPG&C assures upper management awareness of findings resulting from examina-tion of the AP&L Quality Program. The VPG&C initiates additional cor-rective action as he so determines based on review of the ANO-14 audits and findings. The above reviews are not required to be documented, however, audit distribution shall be listed such that the above per-sonnel are assured of receiving the required audit copiea. When audits are conducted within organizat. ions other than AP&L, written responses are required to dercribe measures taken ta correct def'ciencies and prevent recurrence. For audits conducted within AP&L, written re-sponses may be required depending upon the nature of findings. When a written response is requested, the audited organization is respon-sible for providing the written response in a timely manner. Appro-priate followup including re-audits is made to determine that noncon-formances are effectively corrected and that the corrective action precludes repetitive occurrences. Followup action for each finding is required.
18.5.2 Records 18.S.2.1 The following records shall be maintained to represent the status of the plant's activities in complying with all aspects of the Quality Assurance Program:
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(^) (1) Audit reports.
U (2) Reports from affected organizations indicating completion and effectiveness of actions taken to correct deficiencies.
(') Reports of re-audit activities.
18.6 AUDIT ACTIVITIES Audit activities described in paragraph 18.2 will be in accordance with the requirements of ANSI N45.2.12 Draft 4 Rev. 2 (1/1/76) as interpreted in Appendix A.
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( ; Regulatory Guide / ANSI Std.
-> Reference Requirement Interpretation / Alternate / Exception General Certain Regulatory Guides The AP&L commitment refers to the invoke or imply Regulatory Regulatory Guides and ANSI Standards, Guides and standards in specifically identified in this addition to the standard TOPICAL. Additional Regulatory each primarily endorses. Guides, ANSI Standards, Guides and similar documents implied or referenced in those specifically identified in this identified in this TOPICAL are not part of this commitment.
Certain ANSI Standards invoke or imply additional standards.
General Certain ANSI Standards and/or Our commitment to those standards Regulatory Guides extend the applies only to those systems, scope of applicability to structures, and components whose include systems, structures, satisfactory performance is re-and components wose satis- quired to prevent postulated ac-factory performance is re- cidents that could cause undue quired for a plant to operate risk to the health and safety reliably, on "high-value of the public; or to mitigate articles." the consequences of such ac-
,r' 3 cidents. Reliable operation
()m of the plant may depend upon other systems, structures and components which are not covered by this commitment.
Gen ral Certain Regulatory Guides Our commitments apply to the and ANSI Standards contain requirements. It is our in-both requirements and guid- tent to implement the guide-ance. lines contained in the ANSI Standards endorsed by R.G.'s 1.30, 1.37, 1.39 Rev. 2, 1.58, 1,64 Rev. 2, 1.88 Rev. 2, 1.94 Rev. I and 1.116 Rev. 0-R unless acceptable alternatives are con-Lained within this TOPICAL. The General NRC Regulatory Guides and majority of ANSI Standards to ANSI Standards do not pro- which AP&L has committed are vide for deviation from any concerned with the design and/
requirement (s) when emergency or construction phaaes of or other urgent conditions make nuclear power plants. Con-deviation necessary. sequently, AP&L has adapted 1
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# Reference Requirement Interpretation / Alternate / Exception operations phase, where practicable, and has developed provisions for certain conditions not addressed in the standards.
In the event of an emergency con-dition which, if not promptly cor-rected could likely affect the health and safety of the public, the Director, Generation Opera-tions or his designated alter-nate(s) may authorize emergency repairs deviations from written procedures. The nature of the emergency, its cause and the cor-rective action taken are docu-mented.
In the event of an emergency not covered by an approved procedure, operations personnel shall take
('; actions so as to minimize person-
\> nel injury and damage to the facility and tc noted health and safety.
General Certain ANSI Standards The majority of ANSI Standards to contain requirements which AP&L has committed are con-which, under certain cerned with the design and/or con-conditions, may con- struction phases of nuclear power.
flict with limiting Consequently, AP&L has adapted personnel radiation these standards to its operations exposure. phase, where practicable, and has developed provisions for certain conditions not addressed in the standards.
When conformance with particular standards requirements; e.g.,
cleaning of fluid systems, housekeeping, would conflict i 1 J
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'm) Reference Requirement Interpretation / Alternate / Exception conflict with limiting personnel radiation exposure, the degree of conformance to the standards is determined by appropriate leves of management.
General Various standards Except in ANSI N45.2.5, the require inspections, frequencies of required in-examinations, and inspections, examinations and tests, but do not and tests are not specified specify the fre- in the s'?ndards. Accordingly, quencies of these the frequency of inspections, activities. examinations and test required by the standards--other than ANSI N45.2.5--is identified on a job-by-job basis. The amount of inspections, exam-inations and tests identified as based upon safety signi-ficance complexity of the item or activity and degree of standardization of the item q or activity.
G ANSI N.18.7 (a) " Maintenance or modi- Requirements (a), (b), and First Sentence shall be performed in (c), as a whole, require of 5.2.7 a manner to ensure a degree of quality for quality at least replacement items con-equivalent to that sistent with their func-specified in original Lic- It is AP&L's intent design bases and re- that maintenance and modi-quirements, materials fications includir.g procure-specifications, and in- ment and use of replacement spection requirements. " items are to technical re-quirements equal to or better than those specified on the original item or activity.
A reduction in the technical (b) "A maintenance pro- and administrative requirements l gram shall be de- from the endorsed ANSI Standards i veloped to maintaia shall be documented with ap- l safety-relatcJ propriate rationale for the l structures, systems reduction and approved by I and components at Engineering.
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_, Regulatory Guide / ANSI Std.
Reference Requirement Interpretaton/ Alternate / Exception required for them to and QA/QC personnel.
perform their intended functions.
(c) " Purchased to specificatione and codes equivalent to those specified for the original equip-ment, or those specified by a prope:1; reviewed and approved revision."
ANSI N18.7 General Requirements for Paragraph 5.2.14 applies to pro-nonconforming items. grammatic as well as to speci-fled provisions of ANSIN 18.7 and its associated references.
Consistent with paragraph 5.2.14, our quality assurance program will contain provisions for controlled, documented waivers to its require-ments.
( , ANSI N18.7 Requires certain provisions Per 5.2.13 procurement document Section 1 in procurement documents. contents for replacement items will be based primarily on original procurement document contents.
The provisions of 5.2.13.1 will be included if required by original procurement document or warranted by performance of the item. When requirements of ANSI standards are included in procurement documents, the requirements may not be identi-fied as excerpts from ANSI standards.
Procurement documents are developed and reviewed as described in Sec-tion 4 of this TOPICAL.
ANSI N18.7 Where changes are made to Consistent with the requirements Section procurements, they shall of ANSI N45.2.11, paragraph 7.2, 5.2.13.I be subject to the same minor changes to (procurement)
Ist para. degree of control as was documents, such as, inconsequen-used in the preparation tial editorial corrections, or of the original documents. changes to commercial terms and i
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<-s Regulatory Guide / ANSI Std.
( j Reference Requirement Interpretation / Alternate / Exception conditions may not require that the revised (procurement) docu-ment receive the same review and approval as the original documents.
ANSI N18.7 Deviations, their cause, Consistent with the documentation Section and any corrective action requirements of Criterion XVI, Ap-5.2.17, Last completed or planned shall pendix "B" to 10 CFR 50, for cor-Paragraph, be documented. rective action completed or plan-next to last ned are documented.
sentence.
ANSI N18.7, "When the preceding Our commitment to ANSI Section 6 American National Standards does not extend References, referred to in this beyond the standards (date, document are super- revision, etc.) identified seded by a revision in this TOPICAL.
approved by the Am-erican National Stand-ards Institute, Inc.,
the revision shall ap-ply.
O ANSI N18.7 Review of Reports Consistent with requirements Section 4.5 of ANSI N45.2.12, reports of audits conducted by QA person-nel shall be distributed to responsible management of both the audited and auditing or-ganizations for review. Vio-lations of applicable statues, codes, regulations, orders, Technical Specifications, license requirements or of internal procedures or in-structions discovered.
during audit conductance are reviewed by the in-dependent review body.
Rego?itory Section C Paragraph 2 The quality assurance pro-Guide 1.123 gram requirements for con-trol of procurement of safety DATE
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Regulatory Guide / ANSI Std.
ll[ Reference Requirement Interpretation / Alternate / Exception l
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related items and services are established in' accordance with the requirements of ANSI N45.2.13, normally, by invoking portions of 10 CFR 50 Appendix B/ ANSI N45.2 as well as other applicable codes and standards, or by invoking other specific requirements which meet the intent of this standard. The Appendix to N45.2.13 is used for guidance in making determination.
For safety related parts of Code items not covered by the Code, such as non pressure retaining parts, or for Code items performing safety related functions other than pres-sure retaining, the requirements of the Code program:
(a) May be extended to cover such parts and quality related activities when the require-ments of the Code program 9 are considered to meet the intent of the ANSI Standard.
(b) Will be supplemented by the applicable quality assurance requirements in accordance with ANSI N45.2.13 (as en-dorsed by Regulatory Guide 1.123) to cover the appro-priate quality related activities for which the Code program requirements are not considered equiva-lent.
For those parts or items covered by the Code, for which the Code program requirements for quality related activities are considered equivalent to l l (p ~ - DATE
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W Reference Requirement Interpretation / Alternate / Exception the ANSI Standards, only the quality assurance requirements of the Code will apply. The invoking of N45.2.13, by specific reference, is not con-sidered to be required.
Regulatory Section 1.4 Any undesirable foreign Guide 1.37 Definition of material such as grit, ANSI h45.2.1 Contamination metal particles, oil, grease, loosely adher-ing slag or scale, film and fiber on the surface of an item, in the at-mosphere or in pro-cess liquids or gases.
ANSI N45.2.1 Section 3.2 Consistent with ANSI Fresh water criteria N45.2.1 Draft 3 Rev. 6 for chlorides, and (1/78), the turbidity Jackson Turbidity requirement on fresh G Units, water is deleted and the chloride require-ment is revised to read " lees than 250 ppm." The turbidy requirement for deminer-alized water is deleted.
ANSI N45.2.1 Section 3.1 Consistent with ANSI N45.2.1 Cleanliness Rev. 6 (1/78) allowable par-Classifications ticle size will be as follows:
Particle Size (a) Section 3.1.2.5 -
There shall be no particles larger than 1/32 inch by 1/16 inch long
(.d mm X 1.6 mm).
(b) Section 3.1.3 - There shall be no particle larger than 1/32 inch by 1/16 inch long l I pp QUALITY ASSURANCE MANUAL REV. 5 10/ 0 80 TITLE: APPENDIX A PAGE 7 of 28 SECTION 19
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\_) Reference Requirement Interpretation / Alternate / Exception
(.8 mm X 1.6 mm).
(c) Section 3.1.4.4 -
There shall be no particle larger than 1/16 inch by 1/8 inch long (1.6 mm X 3.2 mm).
ANSI N45.2.1 Section 5 AP&L will also allow the use of wood, metal caps, rubber and duct tape to close openings and pipe end when work is not in progress. These alterna-tive methods are considered to meet the intent of the Standard, which is to keep the internal surfaces clean.
ANSI N45.2.2 "The specific items to be Items governed by this stand-Section 2.1 governed by this standard ard or portions thereof are fs shall be identified." identified on a case-by-case
(_) basis during the design document
, and procurement document deveop-ment ANSI N45.2.2 Each of the specific All safety-related items are Section 2.7 items governed by this protected to an extent com-standard shall be clas- mensurate with their sen-sified into one of four sitivity and importance to levels. safety, but are not specifi-cally classified in various levels per the guidance of paragraph 2.1. Therefore, satisfaction of requirements for packaging, shipping, re-ceiving, storage, and handling for particular items could be different than those sug-gested.
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Regulatory Guide / ANSI Std.
{'
U Reference Requirement I n te rp re t a t i o n/ Al te rna t e / Excep t i on ANSI N45.2.2 General marking Some items of a size, shape Subsection requirements. or consistency which pre-3.9 ,
clude marking. Marking in such casr .s applied to box or otnec enclosure.
Tagging is employed, where necessary.
ANSI N45.2.2 " Preliminary visual Inspection after unloading is Subsection inspection or examina- sufficient to determine the 5.2.1 tion shall be performed condition of many items. In prior to unloading..." , special instances, pre-unload-ing examination is performed.
ANSI The (receiving inspections Receiving inspection is performed N45.2.2 shall be performed in an in a manner and in an environment Section area equivalent to the which do not endanger the requisite 5.2.2 level of storage require- quality of an item. The receiving ment for the item. inspection area environmental re-quirements for that item, however, the short time spent in the less a stringent receiving inspection ij area shall be of such duration that will not adversely affect the item being received.
ANSI .." The 'Special The "Special Inspection" pro-N45.2.2 Inspection' pro- cedure shall be readily avail-Paragraph cedure, complete able to inspection personnel 5.2.3 with documentation and may be attached to the instructions shall be item or container.
attached to the item or container. "
ANSI "A statement document- A statement documenting N45.2.2 ing the authority and the authority and justifi-Subsec- and technical justifi- cation for the conditional tion 5.3.3 cation for the condi- release prepared. Justifi-tional release...shall cation may not always be of be prepared, a technical nature.
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o Regulatory Guide / ANSI Std.
E' Reference Requirement Interpretation / Alternate / Exception ANSI The use or storage of People working in storage N45.2.2 food, drinks, and salt areas have a right of access Subsec- dispensers in any to water dispensers per OSHA tion 6.2.4 storage area is requirements. Additionally, prohibited. due to location and layout of the building, personnel may temporarily store lunches in the work place. This area is policed for sanitation.
ANSI " Container markings Containers are adequately N45.2.2 shall appear on a marked for storage, iden-Appendix minimum of two sides tifcation, and retrieval.
(A-3) of the container, pre- Multiple marking require-A.3.9 (1) fer:sbly on one side and ments are imposed, where Second one end." necessary.
Group ANSI N45.2.2 " Container markings Container markings are of a Appendix (A-3) shall be...no less than size which permits easy A.3.9 (4) 3/4" high container recognition.
,~ Second Group. permitting."
ANSI " Container marking The information required N45.2.2 shall include the in container marking is Appendix following informa- evaluated on a case-by-(A-3)A.3.9 tion..." case basis. Marking is adequate in each case.
ANSI N45.2.2 "Non-metallic plugs Non-metal plugs and caps are i Appendix (A-3) and caps shall be of a suitably visible color.
Section A brightly colored."
3.5.1 (1)
ANSI N45.2.2 Plugs or caps shall be In cases where plugs or caps Appendix (A-3) secured with tape or other do not snugly fit, additional Section A means as necessary to pre- securing devices or measures 3.5.1 (5) vent accidental removal, which will not be detrimental to the item will be u.;ed.
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1 I
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(_, Reference Requirement Interpretation / Alternate / Exception ANSI Marking of items The last paragraph of Sec-N45.2.2 not within a con- tion A.3.9 could be in-Appendix tainer, terpreted as prohibiting (A-3) Sec- any direct marking on bare tion A3.9 austenitic stainless steel and nickel alloy metal sur-faces. In lieu thereof, para-graphs A.3.9 (1) and (2) will be used to control marking on the surface of austenitic stainless steels and nickel base alloys subject to the following limitations:
" Marking materials contain-ing sulfur, lead, zinc, mercury, copper and low melting alloys as a basic chemical constituent shall not be brought in contact, or shall not be used on surfaces of corrosion re-sistant alloys. Low sul-fur, low fluorine and/or (j
fs low chlorine compounds.
may be used on austenitic stainless steels." The maximum limits for the above mentioned marking materials will be as follows:
(a) Total inorganic and organic halogen content shall not exceed one (1) percent.
(b) The sulfur content shall not exceed one (1) percent.
ANSI Inert Cas Blankets There may be cases involving N45.2.2 large or complex shaped for which an inert or dry air purge is provided, rather than static has blanket in order to provide adequate protection due to difficulty of providing a leak proof barrier. In their cases, a positi ve pressure purge flow ma" be utilized as an alternate to a leak proof barrier.
7_
x eu ~ ~ DATE fp QUALITY ASSURANCE MANUAL REV. 5 10/10/80 l TITLE: APPENDIX A PAGE 11 of 28 SECTION 19
Regulatory Guide / ANSI Std.
7
(_ )3 Reference Requirement Interpretation / Alternate / Exception ANSI Limits halogen and Engineering may allow the N45.2.2 sulphur content of use of tapes containing Apendix A, tape. greater amounts of halogens A.3.5.2, af ter appropriate evaluation, (1), (a) however, the quantities shall not be such that harmful concentrations could be leached or relased by breakdown of the com-pounds under expected environmental conditions.
Regulatory Gener:41 Alternative equivalent Guide 1.39 requirements may be ANSI N45.2.3 utilized to cover those situations not included in the subject Standard; for example, situations
'.n which shoe covers and/
or coveralls are required but material accountability is not. In addition, zones fs might be combined into the
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next more restrictive category in order to reduce total number of zones.
ANSI N45.2.3 Identifies various When this standard is applied, housekeeping require- its requirements implemented ments, including clean- in those areas affected by liness, fire prevention, work activities associated and fire protection with modifications, opera-which must be accomp- tions, or maintenance as lished during the pro- determined necessary by gress of construction. Plant Staff.
Regulatory Pre Construction / This section required Guide 1.30 Installation verification that items ANSI N45.2.4 Verification are in satisfactory condition for installa-Regulatory tion and have not suf-Guide 1.116 tered since initial receipt ANSI N45.2.8 inspection. Upon receipt, items are inspected and stored in an environment which will not adversely affect the item. Documented routine ..tspections and O
- q. pygg REV. 5 lN QUALITY ASSURANCE MANUAL 10/10/80 TITLE: APPENDIX A PAGE 12 of 28 SECTION 19
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Regulatory Guide / ANSI Std.
s - Reference Requirement In te rp re ta t ion / Al t e rna te / Ex c ep t ion l periodic audits of the storage areas assure that stored items are maintained in satisfactory conditions.
Documentation of pre-con-struction verificatian in addition to documentation of initial receipt inspec-tion, periodic storage inspections, and audits of storage is not required.
ANSI Identifies various During the operational N45.2.4 tests to be per- phase these tests will formed. be performed "as appro-priate" as determined by Engineering or Genera-tien Operations based upon the significance of change or modification.
ANSI " Mechanical tests shall For the plant operational 7_)
N45.2.4 be performed to ascertain phase, " system pressure Subsection that... components or sys- ratings" is interpreted to 5.2.2 Mech- tems can withstand system mean system operating pres-anical Tests pressure ratings." sure. For the Reactor Coolant System, Facility Technical Speci-fications identify testing requirements.
ANSI " Items requiring cali- ltems requiring ca'libration N45.2.4 bration shall be tagged are tagged indicating date Subsection . . indicating date of of calibration. Identity of 6.2.1 calibration and identity person that performed the of person..." calibration shall be in-dicated on the tag or trace-able through records.
ANSI N45.2.4 "These tests shall be For the plant operation phase, Subsection made to verify that all this requirement is inter-6.2.2 parts of a system pro- preted as not requiring that Systems perly coordinate with an entire system be re-tested Tests each other." after completion of modifica-tion of only a portion of that 3
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p ., - DATE fy QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: APPENDIX A PAGE 13 of 28 SECTION 19
Regulatory Guide / ANSI Std.
(/
x-T Reference Requirement Interpretation / Alternate / Exception system. The testing require-ments of the Facility Tech-nical Specifications are met for inoperable equipment.
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DATE h QUALITY nSSUPANCE MANUAL EV. 5 10/10/80 TITLE: APPENDIX A PAGE 14 of 28 SECTION 19
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(,) Regulatory Guide 1.94, Revision 1, April, 1976 (ANSI N45.2.5 - 1974, Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants).
The requirements of the reference Standard will be applied to the quality program for construction of safety related items as interpreted in the Regulatory position as modified and interpreted below.
- 1) Dec*lon 1.4 defines in-process tests and states:
.. samples of these tests must be taken from the lot or batch of materials supplied to the site for use."
This requirement for reinforcing steel will be interpreted to permit taking the rebar test specimen at the fabrication shop, prior to start of fabrication of the rebar from the heat or fraction thereof represented by the test specimen. For these
- -sts performed at the fabrication ship, certification shall be aailable to provide objective evidence that the test specimens represent the material supplied for use at the site.
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DATE 0 ! '" REv. 5 pp QUALITY ASSURANCE MANUAL 10/10/80 TITLE: APPENDIX A PAGE 15 of 28 SECTION 19
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- 2) Section 4.5, Concrete Placement, references American Concrete Institute (ACI) standards (ACI-305-72, " Recommended Practice for Hot Weather Concreting" and ACI 306-66, " Recommended Practice for Cold Weather Concreting." i In order to clarify use of these ACI standards, we will apply the following requirements:
PLACII' TEMPERATURES OF CONCRETE:
A. During hot weather concreting:
Placing temperatures of concrete will be limited to the following:
- 1) Concrete members less than 3 feet in least dimension will not exceed 90 F.
- 2) Concrete members from 3 feet to 6 feet in least dimension will not exceed 70 F.
- 3) Concrete members more than 6 feet in least dimension will have placing temperature as near 50 F as can be obtained by use of ice as necessary up to 100 percent of adding mixing water; and by shading aggregate and sprinkling the s coarse aggregate the day it is to be used. Care will s ) be taken so that no unmelted ice remains in the concrete at the end of the mixing period.
B. During the cold weather concreting:
In heating the water and aggregate, live steam to heat the fine and coarse aggregate shall not be used. The permissi range for cencrete temperature shall be as follows:
- 1) Sections less than 3 feet in least dimensions:
55 to 75 F.
- 2) Mass concrete 3 feet or more in least dimension:
45 to 65 F.
The mixing water and aggregate will be purchased as required.
The materials will be free of ice, snow and frozen lumps before they enter the mixer.
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fia '~" DATE V . b.
fF QUALITY ASSURANCE MANUAL 10/10/80 TITLE: APPEND:X A PAGE 16 of 28 SECTION 19
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(N 3) Setion 4.8, "In-process Test on Concrete and Reinforcing
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~ Steel" states, " Samples for in process test of concrete shall be taken at the sampling point in accordance with ASTM C172. This point may be at the truck mixer discharge if the last piace of, conveying equipment is a chute, bucket, conveying system, or similar equipment. Pumped concrete must be sampled from the pump line discharge."
For performance of correlation tests, the requirements of ANSI N45.2.5 - 1978 shall be followed.
- 4) Section 4.8, "In process Tests on Concrete and Reinforcing Steel" contains Table B entitled, " Required In-process Tests." The following modifications to this table will be applied:
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m t. "' DATE REV. 5
[F QUALITY ASSURANCE MAWSAL 10/10/80 TITLE: APPENDIX A PAGE 17 of 28 SECTION 19
/D 4.1) REINFORCING STEEL U
In process testing of reinforcing steel will include the mechanical properties of yield strength, tensile strength and percent elogation on full size specimens for each bar size for each 50 tons or fraction thereof from each mill heat. Bend tests are performed during material qualification testing only, except as noted below for bar sizs #14 and
- 18.
Table A, " Required Qualification Tests" as applied to reinforcing steel will include hend tests as required by ASTM 4615 and summarized below:
a) Ecr bar sizes #3 threugh #11, one full size specimen from .
largest bar size rolled from each mill heat, unless material from one heat differs by three or more designation numbers.
Whea this occurs, one bend test shall be made from both the highest and lowest designation number of the deformed bars rolled.
b) For har sizes #14 thtough #18, Supplementary Requirements SI ut nalM A615 will be applied. One full size specimen for each bar size for each mill heat. If supplementary requirements are not followed for mill tests, they will be applied as in-process tests.
,3 The above interpretation is consistent with Regulatory Guide 1.15,
(, " Testing Reinforcing bars for Category I Concrete Structures,"
Revision 1, December 1972.
In process test specimens may be selected at the rebar fabrication shop, prior to start of fabrication of the rebar from the heat or fraction thereof represented by the test specimen.
Acceptance criteria for any failed test (qualifications as well as in process) may be the same as that for tensile tests specified in Subarticle CC-2331.2 of AStfE Section III, Div. 2 Code (1975). This states that if a test specimen fails to meet the specified strength requirements, two (2) additional specimens from the same heat and of the same har size would be tested, and if either of the two additional specimens fails to meet the specified strength requirements, the material represented by the tests would be rejected for the specified use. Alternat ive use of rejected material under strict control may be subject to evaluation by the Project Engineer.
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- DATE l REV. 5 Fr QUALITY ASSURANCE MANUAL 10/10/80 l
TITLE: APPENDIX A PAGE 18 of 28 SECTION 19
1
(; 5) Section 4.9, Mechanical (Cu weld) Splice Testing states in
'n / paragraph 4.9.4 " Separate test cycles shall be established for mechanical splices in horizontal, vertical and diagonal bars, for each bar size and for each splicing crew..."
The terms "borizontal, vertical and diagonal bars" will be interpreted to apply respectively to the following types of splice positions:
- a. Horizontal, inc14 ding 10 to horizontal
- b. Verticle, including 10 to vertical
. 45 angle, including 10 to 80 angle The words " splicing crew" will be interpreted to reiu. to all members on the project that are actively engaged in preparing and assembling cadweld mechanical splices at the final splice location. Separate test cycles will be established for each bar size and each splice position.
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F,4 DATE l pc QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: APPENDIX A PAGE 19 of 28 SECTION 19 l
^3 Regulatory Guide 1.58 dated August 1973 (ANSI N45.2.6 - 1973, Qualifications m) of Inspection, Examination and Testing Personnel for the cor.struction phase manufacturing / fabrication phase of Nuclear Power Plants).
The requirements of the referenced standard, as modified and interpreted in the regulatory position will applied to the AP&L Quality Progcam during the operational phase as described in this topical report subject to the following clarifications:
- 1) Substitute new Section 1.1 and 1.2 and nodify first paragraph only of 1.3.
Section 1.1 Scope This standard delineates the requirements for qualification of personnel who perform inspection, examination and testing to verify conformance to specified requirements of nuclear facility items (structures, systems and components of nuclear power plants, fuel reprocessing plants, plutonium processing plants and plutonium fabrication plants) whose satisfactory performance is required to prevent postulated accidents which could cause undue risk to the health ind safety of the public; or to mitigate the consequences of such accidents if they were to occur. The requirements may also be extended to other items of nuclear facilities when specified to contract documents.
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Section 1.2 Applicability The requirements of this standard apply to personnel who perform inspections, examiniations and tests during fabrication prior to and during receipt of items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear f acilities. The requirements of this standard do not apply to personnel who perform inspect. ions for government or municipal authorit.ies, or who performs a authorized inspectors in accordance with the ASME Boiler and Pressure Vessel Code The requirements of this standard are not intended to apply to personnel who only perform inspection, examination or testing in accordance with employer practices which are ia compliance with
" Recommended Practice No. SNT-TC-1A and its applicable supplements.
The requirements of this standard are operational, at the discretion of the employer, for application to personnel who perform calibration or to craf tsmen who perform installation checkouts as part of their basic installation responsibility to ready the installation for preoperational testing.
This standard is to be used in conjunction with ANSI N45.2-1977.
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l DATE j%;""
- QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE
- APPENDIX A PAGE 20 of 28 SECTION 19
q The requirements apply to personnel of the owner. The requirements j apply to architect-engineers, nuclear facility system designers and system suppliers, plant designers and plant constructors, equipment suppliers, outside testing agencies and consultants when specified by the owenr. Other standards or codes may contain qualification requirements for personnel such as acndestructive examination personnel as required by the ASME Boiler and Pressure Vessel Code, and Ouality auditor personnel as may be required by Quality Systems or Quality Assurance Program standards. When this is the case, this standard is not to be interpreted to require a duplication of effort.
Section 1.3 Responsibility It is the responsibility of each organization participating in the project to assure that only those personnel within their respective organizations who meet the requirements of this standard are permitted to perform inspect ion, examination and testing activities covered by this standard trat verify conformance to quality requirements.
- 2) Since this Standard does not apply to personnel who perform non-destructive examinations, delete Section 2.2.2.
- 3) Section 2.2.3. Evaluation of Performance.
The periodic internal for re-evaluation of personnel shall not s exceed three years.
)
~
- 4) The requirements of this Standard shall apply only to personnel who perform inspection, examination and testing; and accordingly Section 3 and 3.1 shall be revised to read:
- 3. Qualifications 3.1 General The requirements contained within this section define the minimum capabilities that qualify personnel to perform in-spec t. ions , examinations and tests which are within the scope of this standard.
There are three levels of qualiiication. The requirements for each level are not limiting with regard to organizational position or professional status, but, rather, are limiting with regard to functional activities which are within the scope of this standard.
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- QUALITY ASSURANCE MANUAL REV. 5 DATE 10/10/80 TITLE: APPENDIX A PAGE 21 of 28 SECTION 19
7 ") Following is the recommended personn i education and experience N/ for each level. These education and experience recommendations should be treated to recognize that other factors may provide reasonable assurance that a person can competently perform a particular task. Othen factors which may demonstrate capability in a given job are previous performance or satisfactory completion of capability testing.
The education and experience requirements shall make provision for personnel who have not graduated from high school or who have earned an Associate degree. According to paragraphs 3.1.1, 3.1.1, and 3.1.3 shall be revised to read:
3.1.1 Level I (1) Two years of related experience in equivalent inspection examination or testing activities, or (2) High school graduation and six months of related experience in equivalent inspection, examination or testing activities, or (3) Completion of college level work leading to an Acsociate degree in related discipline plus three months of related experierce in equivalent inspection, m
examination or testing activities.
3.1.2 Level II (1) One year of satisf actory performance as Level I, or (2) High school graduation plus three years of related experience in equivalent inspection, examination or testing activities, or (3) Completion of college level work leading to an Associate degree in related discipline plus one year realted experience in equivalent inspection, examination or testing activities, or (4) Four-year college graduation plus six months of related experience in equivalent inspection, examination or test-ing activities.
3.1.3 Level Ill (1) Six years of satisfactory performance as a Level II, or i
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f QUALITY ASSURANCE MANUAL REV. 5 DATE 10/10/80 TITLE: APPENDIX A PAGE 22 of 28 SECTION 19
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(2) High school graduation plus ten years of related experience
_/ in equivalent inspection, examination or testing activities; or high school graduation plus eight years experience in Lluivalent inspection, examination or testing activities, with at least two years as Level II and with at least two years associated with nuclear facilities - or, if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of nuclear facility, or (3) Completion of college level work leading to an Associate degree and seven years of related experience in equivalent inspection, examination or testing activities, with at least two years of this experience associated with nuclear facilities - or, if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility, or (4) Four year college graduation plus five years or related experience in equivalent inspection, examination or testing activities, with at least two years of this experience associated with nuclear facilities - or, if act, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility.
- 6) Section 3.2.1 Physical (Revised to read)
AP&L shall identify any special physical characteristics needed in the performance of each activity. Personnel requiring these characteristics shall have them verified by examination at intervals not to exceed one year.
- 7) Section 3.2.2 Technical (Revised to read)
- a. Level I Personnel Capabilities A Level I person shall be capable of performing and documenting the inspections, examinations and tests that are required to be performed '.n accordance with documented procedures and/or industry prrctices. The individual shall be familiar with the tools and equipment to be employed and shall have demonstrated proficiency in their use. The individual shall also be capable of determining that the calibration status of measuring and l test equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection, examina-tion and test procedures are approved.
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DATE fh Ev. 5 QUALITY ASSURANCE MANUAL 10/10/80 TITLE: APPENDIX A PAGE 23 of 28 SECTION 19
f3 b. Level II Personnel Capabilities N]-
A Level II person shall have all of the capabilities of a Level I person. Additionally, a Level II person shall have demonstrated capabilities in planning inspections, examinations and tests; in setting up tests including pre-paration and set-up of related equipment, as appropriate; in supervising or maintaining surveillance over the inspections, examinations and tests; in supervising and certifying lower level personnel; in reporting inspection, exar: ation and testing results; and in evaluating the validity and accepta-bility of inspection, examination and test results.
- c. Level III Personnel Capabilities A Level III person shall have all of the capabilities of a Level II person. In addition, the individual shall also be capable of evaluating the adequacy of specific programs used to traita and test inspection, examination and test personnel whose qualifications are covered by this standard. The indi-vidual shall also be capable of reviewing and approving in-spection, examination and testing procedures and of evaluating the adequacy of activities to accomplish the inspection, examina-tion and test objectives.
,_s 8) Section 4 Performance (Revised last sentence to read)
('~')
When a single inspection or test requires implementation by a team or group, personnel not meeting the requirements of this Standard may be used in data - taking assignments or in plant or equipment operation provided they are supervised or overseen by a qualified individual partici-pating in the inspection, examination or test.
- 9) Section 5 Records (Revised to read)
A file of records of personnel qualification shall be established and maintained by the employer. Collection, storage and control of records required by this Standard shall be in accordance with R.G.I.88 Rev. 2.
- 10) Table 1 (Revised to read)
Implement inspection and test procedures and document results.
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85 DATE pj QUALITY ASSURANCE MANUAL REV. 5 10/10/80 TITLE: APPENDIX A PAGE 24 of 28 SECTION 19
i s
3 Regulatory Guide / ANSI Std.
O Reference Requirement Inte rpreta tion /Alte rnate/ Exception .
Regulatory " Quality Assurance-Terms Whcre terms' defined in ANSI Guide.l.74' and Definitions." N45.2.10 are also defined in
- ANSI other standards to which AP&L N45.2.10. has referred in this program description, the definitions !
in those other standards shall i apply.
ANSI Definitions of Certifi-- Based upon-the guidance of 1 N45.2.10 cate.of Conformance ANSI N45.2.13, 10.2, the '
of Compliance." definitions of these two terms will be exchanged.
i ANSI Definition of "Modifica- Modification - A' change to N45.2.10 tion." an item's configuration, mat-
. terial(s) of function (s) such j that the item does not conform to previously approved design documents.
f ANSI Program procedures shall A variety of experience reports N45.2.11 cover making experience from a number of sources are Section 2.2 reports available made available to design person-i O to cognizant design personnel.
nel without benefit of written-procedures.
ANSI Individual Audit Plans For those routine audits con-
- N45.2.12 ducted during operations, a
- Paragraph written procedure covering d
4.2.1 ' classes of audits (i.e., plant
) site operational audits of plant staff activities, etc.)
will be utilized as opposed to an individual plan for each audit. The procedure (s) will identify the audit scope, a re-quirement that individual check- <
lists be utilized listing re-quirements which are to be audited and notification of the audited. group.
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hh Il QUALITY ASSURANCE MANUAL REV. 5 10/ 0 0 l_ TITLE: APPENDIX A PAGE 25 of 28 SECTION 19
Hegulatory Guide / ANSI Std.
V Reference Requirement Interpretation / Alternate / Exception ANSI Audit Notification Audit Notification shall be N45.2.12 given either in writing or Pa ragraph verbally to the involved 4.2.4 organizations.
ANSI Pre-Audit Conference For those routine audits N45.2.12 conducted during operations, Paragraph in some instances, a formal 4.3.1 pre-audit conference is not necessary. For those cases where formal pre-audit con-ferences are not held for routine on-site day-to-day audits, the audited organiza-tion shall be on distributon for the audit schedule and the auditor shall notify the organization by phone or personal contact prior to actual start of each audit. The auditor as-signed the task of con-O5 ducting the audit is responsible for estab-lishing if a formal pre-audit conference is required. This de-cision should be made after input from the audited group.
ANSI Follow-up by Audited Management of the audited N45.2.12 Organization organization or activity Pa rag raph shall respond as requested 4.5.1 by the audit report. For less significant findings, a re-audit may be scheduled and conducted without requir-ing a written response. When a written response is requested, management of the audited organization or activity.
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DAE jjrus~,, [] QUALITY ASSURANCE MANUAL REV. 5 10/10/80 l_ TITLE: APPENDIX A- PAGE 26 of 28 SECTION 19
d Regulatory Guide / ANSI Std.
. {-.'-)
Reference Requirement Interpretation / Alternate / Exception f
/
ANSI Follow-up by Management of the audited or-
- N45.2.12 Audited Organization ganization or activity shall Paragraph respond as requested by the 4.5.1 audit report. For less signi-ficant findings, a re-audit may be scheduled and conducted with-out requiring a written response.
When a written response is re-quested, management of the i audited organization or activity.
J ANSI Shall respond withir the time N45.2.12 frame stated in the audit re-Paragraph port. This may be less than 4.5.1 <or greater than thirty days.
If corrective action cannot be completed within this time frame, the responsible auditor may grant a verbal extension to the audited group. The verbal extension will be docu-O mented on the punch list for the particular audit finding.
ANSI Specifies subjects to Except in special cases, items N45.2.13 be evaluated during d,e, f, may be evaluated prior Section bid evaluation, to submittal to bids.
ANSI C of C The requirements of this section N45.2.13 are interpreted as follows: The Section person attesting to a certificate 10.2.d shall be an authorized and re-sponsible employee of the sup-plier, and shall be identified by the Supplier.
i ANSI C of C The verification of the validity N45.2.13 of supplier certificates and the Section effectiveness of the certification
, 10.2.f system is accomplished as an in-tegral part of the total supplier control and product acceptance O
$;c y 1 DATE fy [3 QUALITY ASSURANCE MANUAL REV. 5 10/10/80 e
l_ TITLE: APFtNDIX A PAGE 27 of 28' SECTION 19
Regulatory Guide / ANSI Std. l Reference Requirement Interpretation / Alternate / Exception program, and no separate system exists that ad-dresses itself solely to such verification.
The degret of verifica-tion required will de-pend upon the type of item of service and their safety importance.
The means of verification may include source witness /
hold points; source audits and document reviews; in-dependent inspections at the time of material re-ceipt; user tests on selected commodities, such as concrete com-ponents; or tests after installation on selected components and systems.
All of these means verify h whether or not a supplier has fulfilled procurement document requirements, and whether or not a certifica-tion system is effective.
i I DATE QUALITY ASSURANCE MANUAL REV. 5 10/10/80 6'
TITLE: APPENDIX A PAGE 28 of 28 SECTION 19
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-a r"- 1000.0! Orgsnization & Pesponsibility x qy SAA-2 Qu3))ty_ Assurance Organiza11gn x r- -< .QAA-1 Quality _ Assurance Admi g rative Procudgre x C>o SAA .l.1 QAA-10 Quajily_ Assurance Trainino Control of AP&L QA Mangal x
x m c 1000d3 GCP-202 ControLgf Stalign Mcdifisa_11gns Design Process x
x 9$
o o 100 M O Co.ntrol of Prgturew nt x GCP-102 Procuremont Cgntrol x x 100h04 Proqedgral.Erggram Requi rements g g 1000.24 Control of Maintenange -
x x
z GCP-101 Drawing _Cqntrol a g, 1032.02 Des 12n Document /Drawina Contrgl x r- 1000.16 Dogument Cgntrol Pgguirements x GCP-203 Document Preparatigndtlinge & Review x
_103h01 Regeip1_Inspecti.pn x QAAd4 Qualified Vendors List .
ANO-6 Supplier _Qyal11LA ssurance Sv11em (va}glion x 1033.02 Control of Maler!al x 1032,04 Contrcl of SngqiaLP_rgc_enes x 10001 23 Quali.ty 1qnt_rg L P_rggram x 10001 09 Suryei!.langel qu l gntrgl _
x m 1015.05 Section XI Pump _&_Lalvej g31inq
> N 1000.14 Control of Meaturing A Test Eqylpment a: d StanddIdi x
x 4
O 103h02 Control of Liaterial x 1000.27 Hold and Caution Card Control x
- m 1000.07 Deviationk ailures f and Nongonfgmances x 1004.01 QC Program implementation x f., 1004.02 Nonconformancqs and Corrective Action x GCP-204 Des 21 n Deficiengyf_CorrectivrAction x
- Audit Findin.g_Repnrt
.QAA-13 x
,_, 1000.17 Records Management x O Surveillance Audi_t Planning rn De [QAA-4 QAA-6 Distri.bution and Review of Audits x
x Q R> _QAA-15 Qualification of Auditors x mN ANO-14 AP&L 00ality Assurance General Audits x 9 O
~ 3 -18 EnqineerTna Syngillance Audi ts X 1 #-17 Operatino Plants Surveillance Audits X W
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _