ML20010J465

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ML20010J465
Person / Time
Site: Maine Yankee
Issue date: 10/01/1981
From: Frizzle C, Lawton R, Randazza J
Maine Yankee
To:
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ML20010J463 List:
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NUDOCS 8110050123
Download: ML20010J465 (75)


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MAINE YANKEE ATOMIC POWER COMPANY OPERATIONAL QUALITY ASSURANCE PROGRAM k N,[pNc-4 REVIEWED BY:

R. R. Lawton,"Direc tor, Operational Quality Assurance Maine Yankee Atomic Power Company REVIEWED BY:

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6. D. Frizzle, Manag'er, Nuclear Support Maine Yankee Atomic Power Company REVIEWED BY:

W E. C. Wood, Plant Manager Maine Yankee Atomic Power Company REVIEWED BY:

W. P. lo son, Vice Fren dent Yankee 1 telear Services Division APPROVED BY:

(gs 7v 1/ B. Randazza,@e President-Manager of Operations Maine Yankee Atomic Power Company s

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a POLICY STATEMENT Operstional Quahty Assurance Prooram

~

As a matter of company policy, the Maine Yankee Atomic Power Company Operational Quality Assurance Program shall comply with the requirements of the Code of Federal Regulations Title 10, Part 50, Appendix B, with respect to

~

the operation and maintenance of, and changes to the nuclear generating facility.

The Program shall conform with the ANSI standards and regulatory position of the regulatory guides specified in Section II of the Program as mcdified in Appendix B of the Program.

The Vice President Manager of Operations is responsible for establishment.

and implementation of the Program hin the Maine Yankee Atomic Power Company.

The Director of Operational 4ality Assurance shall be responsible for Gnsuring that the Program is implemented for all activities requiring quality assurance.

The Quality Assurance staff shall be responsible for auditing the program as necessary end surveying / inspecting activities required by the Program to assure compliance with its requirements.

The Quality Assurance staff shall have the authority and organizational freedom necessary to meet the requirements of 10CFR50, Appendix 8.

The Plant Manager shall be responsible for the day-to-day implementation of the Program's procedural requirements at the plant.

The Wclear Safety Audit and Review Committee (NSARC) shall review the adequacy and effectiveness of the Program semiannually.

Any discrepancies in the implementation of this policy or the Program that are revealed during the review and that require corporate action for correction, will be reported to both the Vice President Manager of Operations and the Vice President, Yankee W clear Services Divicion, together eith appropriate recommendations.

Implementation of this policy will enhance the reliability and safety of the nuclear generating facility.

Each person involved in activities affecting the quality of structures, systems, and components used to prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public, shall be responsible for assuring quality in his own work, and for compliance with the requirements of the Program.

The Operational Quality Assurance Program is a document which shall be adhered to by all responsible organizations and individuals.

h0 !? kk!

Elwin W. Thurlow President

I

Title:

Section I. Organization Page: 1 of 11 Rev. No.:

1 Date: Octooer 1, 1981 I.

ORGANIZATION A.

SCOPE This section of the Operational Quality Assurance Program describes the duties and responsibilities of the personnel involved in establishing and Secuting the Operational Quality Assurance Program.

B.

RESPONSIBILITY The responsibility for design, evaluation, maintenance, and operation of the Plant rests ivich the Maine Yankee Atomic Power Company.

The responsibility for developing and implementing the Operational Quality Assurance Program is vested in the Vice President Manager of Operations.

He has delegated areas of authority for the development and implemer ;ativa of certain phases of the Program as set forth in tne following paragraphs of this section.

The Operational Quality Assurance Department has t e organizational responsibility for the continuing review ano audit # tne implementation of the Operational Quality Assurance Program.

C.

ORGANIZATIONAL RELATIONSHIPS Maine Yankee Atomic Power Company Aines of authority of all personnel involved in the in., ' mentation of the Operational Quality Assurance Program are shown in.'igure 1.

A Vice President of Maine Yankee Atomic Power Company is also a corporate officer of the Yankee Atomic Electric Coapany, Nuclear Services Division (YNSD), wnicn has a continuing ;cntractural obligation to provide services to the Maine M.%ee Atomic Power Company.

This interlocking corporate officer shall be herein identified as the Vice President (YNS0).

The Vice President (YNSD) conducts, through NSARC, an indepencent review of all aspects of plant safety and, by virtue of his interlocking positions, assures that YNSD provides the services assigneo and requested.

D.

QUALITY ASSURANCE FECCRAM RESPONSIBILITIES 1.

Vice President Manager of Ocerations a.

Assumes and maintaDs responsibility for the Operational Quality Assurance Program.

b.

Establishes and enforces company policies in the area of Operational Quality Assurance.

c.

Establishes ar.

1plements an organization capable of and directed toward a proper Operational Quality Assurance Program.

/

Title:

Section I. Organization Page: 2 of 11 Rev. No.:

1 Date: October 1, 1981 d.

Provides for a periodic review of the Operational Quality Assurance Program to determine the adequaci and effectiveness raf the Program.

e.

Ensures that personnel performing 0;ality Assurance functions have sufficient authority and organizational freedom to:

1.

identify quality r roblems, 2.

initiate, recommend, or provice solutions thro;gn designated channels, and, 3.

verify implementation of solutions.

f.

Provides for review and approval of training programs.

g.

Evaluates the audit " discrepancy", " discrepancy response", and

" Recommended Corrective Action" ar.d prepares " Implementation Directives" to resolve disagreements.

h.

Approves all changes to the Operational Quality Assurance Program.

i. Reviews the qualification requirements for the principal Quality As5JranCe management position to assure Competence commensurate with responsibility.

(See Appendix A) j.

Provides for resolution of NSARC recommendations.

j 2.

Vice President - Yankee Nuclear Services Division a.

Provide independent review of all aspects of plant safety, via l

the Nuclear Safety Audit and Review Committee.

Appoint the membersnip of the Committee, and review their reports.

b.

Monitor response to NSAR Committee and MY Project Manager recommendations and bring to the attention of the Maine Yankee President, all safety related disputes, disagreements or discrepancies which cannot be resolved at a lower level.

c.

Provides via the YNSD Operational Quality Assurance Department for independent aucits of the Maine Yankee Atomic Power l

Company Operational Quality Assurance Department to verify compliance with the Quality Assurance Program.

d.

Provides via the YNSD Engineering Department for independent engineering review of proposeo cesign changes to verify the l

adequacy of designs anc to assure tne quality and consistency with safety and licensing requirements.

l

I

Title:

Section I. Oroanization Page:

3 o f 11 Rev. No.:

1 Date: October 1, 1981 e.

Provides via the YNSO Engineering Department for the development, maintenance, and control of special process procedures, such as, NDE, Welding, and Heat Treating.

f.

Provides for technical, engineering, licensing, compliance, operational, and quality assurance support as requested.

g.

Provides via the YNSO Operational Quality Assurance Department for Internal Audits, vendor surveillance, inspection, or audit as requested by the Manager of tbclear Support.

h.

Prov2 des for emergency preparedness, environmental, fuel management, and nuclear engineering support as requested.

1.

Provides via the VNSD Engineering Department for the development, mai.itenance, and control of Yankee POclear Services Division General Specifications.

j.

Provides a qualified Fire Protection Engineer to review design changes to fire protection systems and components.

k.

Review the operational quality assurance program and changes thereto.

3.

Manager - Nuclear Support a.

Reports Directly to the Vice President Manager of Operations.

b.

Reviews all changes to the Operational Quality Assurance Program.

c.

Provides for review of and compliance with feceral and state regulations and standards for nuclear power facilities.

d.

Provides for the control and storage of appropriate quality assurance records.

e.

Provides for the coordination of the engineering requirements necessary to support enanges related to operation of the plant.

f.

Prepares " Recommended Corrective Action" to be taken on Internal Audit Discrepancies, g.

Establishes the qualification requirements for the principal Quality Assurance management position to assure competence commensurate with responsibility.

n.

Resolves disputes between Quality Assurance Department and other departments / organizations, involving quality.

Title:

Section I. Oraanizatica Page:

4 of 11 Rev. No.: 1 Date: October 1, 1981 i.

Acts in an advisory capacity in the areas of engineering, licensing, compliance, and quality assurance when requested by the Plant Operation Review Committee (PORC) or the fAJclear Safety Audit and Review Committee (NSARC).

4.

Plant Manacer a.

Reports directly to the Vice President Manager of Operations.

b.

Reviews all changes to the Operational Quality Assurance Program Manual.

c.

Establishes the on-site implementation of the Operational Quality Assurance Program, including compliance with all State and Federal licenses and regulations.

d.

Acts as Chairman of the Plant Operations Review Committee with authority and responsibility as established in the Technical Specifications of the plant operating license.

e.

Assumes overall responsibility for all activities at the plant.

f.

Acts in an advisory capacity in the areas of plant activities, such as, maintenance, operation, testing, training, when requested by NSARC.

g.

Interfaces between the Company and Yankee Nuclear Services Division for on-site activities.

h.

Provides via the Operations Department for the review of industry operating problems with the aim of minimizing likelihood of occurrence at the plant.

i.

Coordinates activities necessary to support plant reporting requirements.

j. Coordinates pint activities necessary to support the plant environmental surveillance programs.

k.

Provides via the Emergency Plan Coordinator for implementation of the Maine Yankee Emergency Plan.

5.

Director, Training a.

Reports to the Manager, Nuclear Support.

b.

The Director, Training is responsible for:

1.

Development, implementation, scheduling, documentation, evaluation, and update of the following:

(

Title:

Section I. Organization Page:

5 of 11 Rev. No.: 1 Date: October 1, 1981 a.

General Plant Training b.

Operator Qualification and Requalification c.

Shift Technical Advisor Qualification and Requalification d.

Specialty Training Programs 2.

Coordination with management, department heads, and directors to develop long and short range plans to meet operational and regulatory training requirements.

3.

Advising management of any practices, circumstances, deficiencies or personnel problems which impact on the quality, quantity, or availability of training.

4.

Advising management on developments in training techniques, industry standards, and regulations which impact on Maine Yankee training policies and practices.

5.

Development and maintenance of Maine Yankee training policy and procedures.

6.

Coordination with all outside agencies for training matters.

6.

Director of Plant Engineering a.

Reports directly to the Manager of Nuclear Support.

b.

Maintains the Operational Quality Assurance Program Manual and the associated administrative implenenting quality assurance procedures.

c.

Coordinates the development, review, and implementation of plant changes and alterations.

d.

Establishes and maintains the Plant Inservice Inspection Program.

e.

Directs via the Plant Engineering Department the engineering reviews of material purchase requests.

f.

Directs via the Plant Engineering Department the engineering reviews of nonconformances and corrective actions.

l g.

Directs via the Plant Engineering Department independent engineering and quality assurance reviews of maintenance and repair activities.

1 h.

Maintains and disseminates informatico regarding codes, standards, criteria, and guidelines to applicable personnel.

l

/

Title:

Section I. Orgarization Page:

6 of 11 j

Rev. No.:

1 Date: Octooer 1, 1981 1.

Coordinates interfacing plant engineering activities between the Company, Yankee Nuclear Services Division, and outside

acencies,
j. Directs vic the Plant Engineering Department plant surveillance programs assigned by the Manager of Nuclear Support.

k.

Directs via the Plant Engineering Department plant test programs assigned by the Manager of (Juclear Support.

1.

Acts in an advisory capacity in the area of plant engineering when requested by PORC or NSARC.

m.

Provides via the Plant Engineering Department for technical support to the plant.

n.

Provides for the documentation and maintenance of quality assurance records associated with plant engineering.

7.

Director of Nuclear Enoineering and Licensing Reports directly to the Manager of Nuclear Support, a.

b.

Acts in an advisory capacity in the areas of licensing and nuclear engineering when requested by PORC or NSARC.

Directs the licensing activities necessary to support and c.

maintain the Technical Specifications, Safety Analysis Report, and other licensing issues.

d.

Estaclishes and maintains radiological environmental surv-illance programs.

Provides for the documentation and maintenance of quality e.

assurance records in licensing, f.

Coordinates interfacing licensing activities between tne Company, Yankee Nuclear Services Division, and outside agencies.

Coordinates interfacing nuclear engineering activities between g.

the Company, Yankee Nuclear Service 3 Division, and outsice agencies.

Establisnes Emergency Plans pursuant to state and federal h.

regulatory requirements and Company policy.

Provides for the general supervision and cooroination of all 1.

core component design.

/

Title:

Section I. Organization Page:

7 o f 11 Rev. No.:

1 Date: Octooer 1, 1981 j.

Coordinates activities necessary to support plant safety analysis issues.

8.

Director of Operational Quality Assurance a.

Reports Jit?ctly to the Manager of Nuclear Support.

b.

Assures ihat the Operational Quality Assurance Program satisfies the requirements of 10CFR50, Appendix B ANSI N18.7-1976.

c.

Directs via the Operational Quality Assurance Department the review of design changes and material purchase requests for adequacy of quality requirements.

d.

Directs via the Operational Quality Assurance Department the evaluation, inspection and/or surveillance of contractor / vendor activities at the operating plant to assure effective lines of communication and compliance with the applicable criteria of 10CFR50, Appendix B and ANSI N18.7-1976, e.

Directs via the Operational Quality Assurance Department the inspection, surveillance and/or audit of activities affecting the quality of structures, systems and components important ta safety.

f.

Ensures through verification that the Program is implemented for all activities requiring quality assurance.

g.

Directs via the Operational Quality Assurance Department the independent verification of plant operational activities to assure that applicaole approved procedures, spccifications, licenses and safety regulations are satisfied, h.

Reviews all changes to tne Operational Quality Assurance Program.

1.

Ensures that the Program is modified and/or revised as standarcs, regulaticns ano experience dictate.

J.

Directs via the Operational Quality Assurance Department the quality assurance reviews of nonconformances.

k.

Coordinates interfacing quality assurance activities between tne Company, Yankee Nuclear Services Division, and cutside agencies.

1.

Acts in an advisory capacity in tne area of quality assurance when requested by PCRC or NSARC.

/

Title:

Section I. Orcanization Page:

8 of 11 Rev. No.:

1 Date: Octooer 1, 1981 m.

Establishes and maintains the Internal Audit Program to verify compliance with all aspects of the Quality Assurance Program and to determine the effectiveness of the program.

n.

Provides for the documentation and maintenance of oepartment quality assurance records.

o.

Responsibility and authority to stop unsatisfactory work and control further processing, delivery, or installation of nonconforming material.

p.

Provides for review and inspection of repair and maintenance activities.

q.

Approves all changes to the Operational Quality Assurance

Manual, r.

Review and concurrance with dispositions and corrective actions of nonconformance reports.

9.

Director of Operational Sucoort a.

Reports directly to the Manager of Nuclear Support.

b.

Acts in an advisory capacity in the area of regulatory compliance when requested by PORC or NSARC.

c.

Directs the activities necessary to support federal and state I

enforcement documents.

d.

Provides via Operational Support Department for the documentation and maintenance of quality assurance records in regulatory compliance activities.

l e.

Coordinates interfacing compliance activities between the Company, Yankee Nuclear Services Divisicn, and outside agencies.

f.

Provides via the Operational Support Department for an independent operational review.

g.

Coordinates the review of industry operating problems with tne i

aim of minimizing likelihood of occurance at the plant.

h.

Provides for operational support to the plant.

10. Administration Decartment Fead a.

Reports directly to tne Plant Manager.

l

/

Title:

Section I. Organization Page:

9 of 11 Rev. No.:

1 Date: Octocer 1, 1981 b.

Establishes the means for the control and distribution of the Operational Quality Assurance Program and revisions thereto.

C.

Establishes the means for the control, distribution, and storage of the Quality Assurance Documents and Records under the jurisdiction of the Manager of Nuclear Support.

d.

Establishes the means for the control and distribution of the Maine Yankee audit and surveillance program.

e.

Establishes the means for the control, distribution, and storage of the Quality Assurance Documents and Records under the jurisdiction of the Plant Manager.

f.

Provides via the Fire Protection Supervisor for an approved

[

Fire Protection Program and training of personnel therein.

g.

Provides via the Security Supervisor for an approved Security l

Program and training of personnel therein.

h.

Provides for the preparation of requisition for purchase

[

orders, i.

Provides via the Stores Department for the control and

[

identification of material and equipment upon receipt, storage, and issuance.

j. Establishes the control and storage of Quality Assurance

[

l documentation of purchased materials.

k.

Provides via the Stores Department for the control and l

maintenance of the plant spare parts inventory system.

1.

Establishes the retention period for the Quality Assurance l

l Documents and Records,

11. Maintenance Department Head a.

Reports directly to the Plant Manager.

b.

Prepares, senedules and directs approved maintenance activities.

c.

Directs via the Maintenance Department preparation and implementation of procedures utilizing sound engineering policies and practices for the installation of new material, equipment or spare parts.

d.

Establishes and maintains an approved program of preventive maintenance, calibration, and testing for instruments and electrical / mechanical equipment in conformance with approvec procedures.

\\Q/

Title:

Section I. Organization Page: 10 of 11 Rev. No.:

1 Date: Octooer 1, 1981 e.

Ensures the implementation of a continuing surveillance program as outlined in tne Technical Specifications.

f.

Provides for the training and qualification of department personnel in the application of special processes, such as, BOE and Welding.

g.

Provides for the occumentation and maintenance of quality assurance recoros in Maintenance Depart:nent activities.

12. Ooerations Decartment head a.

Reports directly to the Plant Manager.

b.

Assures plant operations are conducted in accordance with approved documents and specifications.

c.

Provides via the Operations Department for system surveillance and operational testing.

d.

Verifies the operability of systems and/or components I

following maintenance, or changes by provioing for the performance of written test documents which incorporate the requirements and acceptance criteria contained in applicaule design occuments.

e.

Ensures for the safe handling of core and reactor components l

during refueling operations.

1 f.

Provides for the documentation and maintenance tf quality l

assurance records in Operation Department activities.

g.

Provides via the Operations Department for the development.

l control, and maintenance of operating and emergency operating procedures.

13. Technical Succort Decartment Head a.

Reports directly to the Plant Manager.

b.

Provioes via the Reactor Engineering Group for the general I

supervision and coordination of reactor physics and nuclear tests for plant operation and adherence to applicable Tecnnical Specifications.

c.

Follows ano reviews radiation protection programs and activities at the plant.

d.

Establishes and maintains raciological and nonradiological effluent release control and surveillance program.

Q/

Title:

Section I. Organization Page:

11 of 11 Rev. No.: 1 Date: Octooer 1, 1981 e.

Provices for the maintenance of refueling procedures relative to fuel core components handling and inspection.

f.

Provides for fuel cycle, nuclear engineering, and economic studies requested by plant manager via the Reactor Engineering Group.

g.

Provides for the documentation and maintenance of quality I

assurance records in chemistry, health pnysics, environmental, reactor physics and nuclear fuel via the applicable department.

h.

Provides for the control and maintenance of plant computer i

systems, i.

Provides for the preparation and maintenance of procedures associated with radiological, chemistry, reactor physics and computer via the applicable group.

E.

REVIEW AND AUDIT Two committees have been established for the operating plant whose objectives are to insure the plant is operated safely, utilizing accepted engineering practices.

The committees are charged with making recommendations to mocify operational methods or safety precautions when appropriate.

One Committee, the Plant Operations Review Comittee, is made up of Plant personnel.

The other Committee, the Nuclear Safety Audit and Review Comittee, is made up of individuals not having line responsibility for the operation of the plant.

1 Plant Ocerations Review Committee See Section 5.5, " Review and Audit" of Technical Specifications to the Operating License DPR-36.

2.

Nuclear Safety Audit and Review Committee See Section 5.5, " Review and Audit" of Technical Specifications to the Operating License DPR-36.

MATNE YANKEE ATOMIC POWER COMPANY ORGANIZAT10NAL CHART PRESIDENT MAINE VANKEE ATOMIC l

YANXEE ATOMIC ELECTRIC COMPANY POWER COMPANY NUCLEAR SERVICE DIVISION (MYAPC)

(YNSD)

I VICE VICE PRESIDENT VI g R g NT PRESIDENT E

PRESIDENT MANAGER OF AND OPERATIONS VICE PRESIDENTS FINANCE ADMINISTRATION [

l 0FFSITE

- - -- ONSITE MAINE YANKEE NUCLEAR SAFETY MANAGER l

PLANT AUD EW NUCLEAR SUPPORT MANAGER PROJECT g

MANAGER l

ADMINISTRATIVE I

MAINTENANCE SUPERVISOR I

DEPARTMENT HFAD I

ADMINISTRATION DIRECTOR l

DEPARTMENT YANKEE NUCLEAR NUCLEAR ENGINEERING HEAD SERVICES

& LICENSING l

DIVISION STAFF OPERATIONS DIRECTOR l

DEP ENT

  • 0ne Corporate Officer of YNSD is also a OPERATIONAL i

Corporate Officer of MYAPC, and shall be QUALITY I

TECHNICAL referred to as "Vice President (YNSD)"

ASSURANCE SUPPORT

    • Administrative Reporting: Technical Support J

I DEPARTMENT Department Head DIRECTOR l

HEAD

      • Functional Reporting: Director-Plant l

PLANT i

Engineering ENGINEERING

        • Functional Reporting: Director-Operational l

DIRECTOR PLANT Quality Assurance ENGINEERING OPERATIONAL SUPPORT

  • II, l

f DIRECTOR A SURANCE TRAINING l

Plant Operations Figure 1 Rev.I l

Review Committee Per Tech. Spec. 5.5

/

Title:

Section II. QA Program Page:

1 of 4 Rev. No.:

1 Date: Octooer 1, 1981 II. CUALITY ASSURANCE FROGRAM A.

SCOFE The Quality Assurance Program provides control over activities affecting the quality of identified structures, systems and components, to an extent consistent with their importance to safety.

The program takes into account the need for special controls, processes, environmental conditions, equipment, tools, and skills to attain the required quality and the need for verification of quality by inspections, evaluations or tests.

B.

RESPONSIBILITIES Compliance with the requirements of the Operational Quality Assurance Program is the responsibility of all personnel involved with activities affecting operational safety.

Individuals responsible for establishing and executing the Operational Quality Assurance Program are delineated in Section I, " Organization", of the program.

Operational Quality Assurance shall regularly review the status and adequacy of the quality assurance program.

C.

IMPLEMENTATION Establishment of an effective Operational Quality Assurance Progra is assured through conformance with the ANSI Standards and the regulatory position of the regulatory guides specified in this section of the QA Program as modified by Appendix B of the Q. A. Program.

Implementation of this program is assured through Quality Assurance procedures derived from Quality Assurance policies, goals and objectives.

1.

Title 10 of the Code of Feceral Regulations, Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants 2.

ANSI N18.17-1973, Industrial Security for Nuclear Power Plants.

3.

Regulatory Guide 1.8, Revision 1, (September, 1975) Personnel Selection and Trainino (Endorses ANSI N18.1-1971) 4.

Regulatory Guide 1.28, Revision 2, (Feoruary 1979) Quality Assurance Program Requirements (Endorses ANSI N45.2-1977) 5.

Regulatory Guioe 1.29, Revision 3, (September 1978) Seismic Desian Classification 1

6.

Regulatory Guide 1.30, August 11, 1972, Cuality Assurance Recuirements for the Installation, Inspection ano Testing of Instrumentation ano Electric Ecuipment (Encorses ANSI Ne.2.4-1972) 7.

Regulatory Guide 1.33, Revision 2 (February 1978) Quality Assurance Prcoram Recuirements (Endorses ANSI N18.7 - 1976)

/

Title:

Section II. QA Program Page: 2 of 4 Rev. No.: 1 Date: Octooer 1, 1981 8.

Regulatory Guide 1.37, Maren 16,1973, Quality Assurance Recuirements for Cleaning of Fluid Systems and Associated Comoonents of water-Cooled Nuclear Power Plants (Encorses ANSI N45.2.1-1973) 9.

Regulatory Guide 1.38, Revision 2, May 1977, OJality Assurance Recuirements for Packaging, Shiocing, Receiving, Storage and Hanoling of Items for Water-Cooled Nuclear Power Plants (Encorses ANSI N45.2.2-1972)

10. RegJlatory Guide 1.39, Revision 2, September 1977, Housekeeping Recuirements for Water-Cooled Nuclear Power Plants (Endorses ANSI N45.2.3-1973)
11. Pegulatory Celde 1.54, June, 1973, Quality Assurance Recuirements for Protective Coatirgs Acolied to Water-Cooled Nuclear Power Plants (Encorses ANSI N101. 4-1972)
12. Regulatory Guide 1.58, Revision 1, Septemoer 1980, Qualification

+

of Nuclear Power Plant Insoection, Examination, and Testing Personnel (Encorses ANSI N45.2.6-1378)

13. Regulatory Guide 1.64, Revision 2, June 1976, Quality Assurance Recuirements for the E esian of Nuclear Power Plants (Endorses ANSI N45.2.ll-1974)
13. Regulatory Guide 1.74, February,1974, Quality Assurance Terms and Definitions (Endorses ANS N45.2.10-1973)
15. Regulatory Guide 1.88, Revision 2, October 1976, Collection t Storace and Maintenance of Nuclear Power Plant Quality Assurance I

Records (Encorses ANSI N45.2.9-1974) l l

16. Regulatory Guide 1.94, Revision 1 (April, 1976), Quality Assurance l

Reauirements for Installation, Insoection and Testing of Structural Concrete anc Structural Steel During tne Construction Phase of Nuclear Power Plants (EnCorses ANSI N45.2.5-1974)

17. Regulatory Guide 1.116, Revision 0-R, May 1977, Quality Assurance Recuirements for Installation, Inspection, and Testing of W cnanical Eauioment and Systems (Encarses ANSI N45.2.8 - 1975) 1
18. Regulatory GJice 1.123, Revision 1, July 1977, Quality Assurance Recuirements for Control of Procurement of Items ano Services for Nuclear Power Plants (Encorses ANSI N45.2.13 - 1976)
19. Regulatory Guide 1.144, January 1979, Auditing of Quality

+

l A33JranCe Pr) grams for Nuclear Power Plants (Encorses ANSI N45.2.12 - 1977)

20. Regulatory GJide 1.146, August 1980, Qualification of Quality

+

Assurance Program Audit Personnel for IAJclecr Power Plants (t.ncorses ANSI N45.2.23 - 1978)

{

/

Title:

Section II. CA Program Page:

3 of 4 Rev. No.:

1 Date: Octocer 1, 1981 NOTES:

1)

The plant Technical Specifications shall be the governing document when determining requirements to be imposed in all areas which are addressed in both technical specifications and the above noted guides and standaros.

2) Revisions to the above listed documents will be considered for applicability to the Maine Yankee Operational Quality Assurance Program upon written direction thereof by the Nuclear Regulatory Commission

- Office of Nuclear Reactor Regulations - Quality Assurance Branch.

3)

ANSI Standard N18.7-1976 is the endorsing document for all other above referenced ANSI Standaros.

All sucn endorsed ANSI Standards will be implemented to the degree of applicacility indicated in ANSI N18.7-1976.

4Property "ANSI code" (as page type) with input value "ANSI N18.7-1976.</br></br>4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.)

This Program shall be applicable to those activities requiring quality assurance wnich occur commencing 90 days after acceptance of the Program by the Nuclear Regulatory Commission.

5)

The NRC shall be notified of changes (1) for review and acceptance in the accepted description of the QA program prior to implementation, and (2) in organizational elements within 30 days after announcement.

(Note - editorial changes or personnel reassignments of a non-substantive nature do not l

require NRC notification.)

  • Exceptions and alternatives to the provisions contained in this Standard / Guide are detailed in Appendix 6.

D.

MANAGEMENT EVALUATION The Vice President, YNSD, directs a thorough evaluation of tne established Operational Quality Assurance Program by assigning tne tbclear Safety Audit and Review Committee the task of reviewing for compliance with and evaluating the effectiveness of the quality assurance program.

E.

TRAINING l

1.

The Vice President, Manager of Operations is ultimately responsible to insure that personnel performing activities affecting the management, planning, operations, maintenance ano quality assurance are adequately trained and qualified to perform tneir assigned tasks.

8!III

%(,,,e

Title:

Section II. QA Program Page: 4 of 4 Rev. No.: 1 l

Date: Octob~,r 1, 1981 l

2.

The Plant Manager is responsible to the Vice President, Manager of I

Operations for the training and qualification of all personnel assigned to the Maine Yankee Plant.

3.

The Manager, Nuclear Support Staff is responsible to the Vice President, Manager of Operations for the training and qualification of all personnel assigned to the Nuclear Support Staff.

In addition, he is responsible to provide support to the Plant Manager in fulfilling his training responsibilities.

4.

The Vice President, Yankee Naclear Services Division is responsible to the Vice President, Manager of Operations to insure that all Yankee NSD perconnel working in behalf of or at Maine Yankee are properly trained and qualified to perform their i

assigned tasks for activities requiring quality assurance.

5.

The indoctrination and training programs shall provide the following:

a.

Instruction as to the purpose, scope, and implementation of

(

quality assurance manuals, instructions, and procedures, b.

Training and qualification in the principles and techniques of the activity being performed.

c.

Maintenance of personnel proficiency by retraining, reexamining, and/or recertifying.

d.

Documentation of the training sessions including content, attendance, dates and results.

a b

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/

Title:

Section III. ; asian Control Page: 1 of-3 Rev. 140. :

1 Date: Octooer 1, 1961 III. DESIGN Cor4 TROL A.

SCOFE This secticn of the Operational Quality Assurance Program establishes i

measures to assure that the design of and changes to structures, systems, and components covered by the Operational Quality Assur nce Program are controlled.

B.

RESPONSIBILITIES l.

The Operational Quality Assurance Department shall be responsible for:

a.

Providing for Surveillance of the implementation of design J

control.

b.

Review of engineering drawings and specifications to assure that appropriate design control practices, checks, and reviews are included.

c.

Review of design bases for inclusion of quality requirements.

j 2.

The Plant Engineering Department shall be responsible for:

a.

The design and control of design activities (including design interfaces) for the change of structures, syrtems, or components including the requirement for independent review.

b.

Identification, documentation, and control of deviations from specified design requirements and/or quality standards.

I c.

Delineation of acceptance criteria for inspictions and tests.

{

3.

The Fire Protection Coordinator shall be responsible for:

a.

Design and control. of design activities for Fire Protection Equipmei.*. in accordance with the Yankee Nuclear Services Division General Specifications YA.rff4-9.

4.

The Plant Operations Review Committee shall be responsitda for:

a.

Review of all proposed plant design enanges and recomending their approval or oisapproval to the Plant Manager.

D.

Determination of whether proposed Cnanges involve unrevieweo 4

safety questions.

5.

The Plant Manager shall De responsible for:

a.

Review of the recommendations of the Plant Operations Review Comittee.

1

Title:

Section III. Design Control Page:

2 of 3 Rev. No.:

1 Date: October 1, 1981 b.

Review and approval of proposed plant changes.

6.

The Nuclear Safety Audit and Review Committee shall be responsible for the review of design changes.

7.

The Yankee Nuclear Services Division shall t'e responsible for:

a.

Establishment of approved policy for processing engineering design changes.

b.

Independent engineering review of proposed design changes to verify the adequacy of designs and to assure the quality and consistency with safety and licensing requirealents.

C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall be assured through the implementation of the Maine Yankee and Yankee Nuclear Services Division actions listed below:

a.

Correct translation of applicable regulatory requirements and design bases into specifications, drawings and written documents.

b.

Application of suitable design controls to such activities as reactor physics; seismic, stress, thermal, hydraulic, radiation, and accident analyses; compatiblity of materials; and accessibility for inservice inspection, maintenance and repair.

c.

Design reviews to assure that desi>Jn characteristics can be controlled, inspected and tested.

d.

Performance of proper selection and accomplishment of design verification or checking process such as design reviews, alternate calculations, qualification testing or test programs. When a test program is used to verify the adequacy of a design, a qualification test of a prototype unit under the most adverse design conditions shall be useo.

If the verificatica method is only by test, procedures shall provide criteria that specify when verification should be by test and that prototype, comonent or feature testing is performed as early as possiole prior to installation of plant equipment, or prior to the point when installation would become irreversible.

e.

Subjection of design and specification cnanges to the same design controls and approvals that were applicable to the original cesign unless designated in writing to another responsible organization.

/

Title:

Section III. Desion Control Page: 3 of 3 Rev. tb. :

1 Date: Octcoer 1, 1981 f.

Documentation of errors and deficiencies in the design process that adversely affect safety classified structures, systems, and components; performance of corrective action to preclude repetition, g.

Review of standard "off the shelf" commercial or previously approved materials, parts, and equipment that are essential to the safety functions of structures, systems, and components, for suitability of application prior to selection.

h.

Selection of suitable materials, parts, equipment, and processes for safety classified structures, systens, and components.

1.

Fire Protection controlled in accordance with Yt4SD YA-GEN-9.

j. Maintenance of records which correctly identify the as-built condition of the facility for the life of the item while installed.

/

Title:

Section IV. Procurement Document Control Page:

1 of 2 Rev. No.:

1 Date: October 1, 1981 IV.

FROCUREMENT 00CtNENT CONTROL A.

SCOPE This section of tne Operational Quality Assurance Prograa establishes the measures necessary to assure that applicable requirements necessary to assure adequate quality, are suitably included or referenced in the documents for procurement of material, equipment and services.

B.

RESR)NSIBILITIES 1.

The Operational Quality Assurance Department snall be responsible for:

a.

Surveillance and/or audit of procurement document control, including the preparation, review, and approval of purchase requests for material, equipment, and services covered by the Operati nal Quality Assurance Program.

o b.

Review of procurement documents initiated by Maine Yankee to assure that applicable requirements necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services.

2.

Maine Yankee shall be responsible for:

a.

The preparation, review, issue, and control of purchase documents, b.

Preparation of details as to how purcnase documents are prepared, reviewed, approved, issued, and controlled.

3.

The Plant Engineering Department shall be responsible for:

a.

Preparation of engineering specifications wnich detail toe technical and quality requirements for material, equipment and services.

b.

Providing technical and quality requirements for material, equipment, and service purchases.

C.

IMPLEMENTATION 1.

Satisfacticn of tne criterion snall be assured through the implementation of the Maine Yankee actions listed below; a.

Occumentation of the review and approval of procurement documents prior to release and availaoility of this documentation for verification.

Title:

Section IV. Procurement Document Control Page:

2 of 2 Rev. No.:

1 l

Date: Octoner 1, 1981 b.

Identification of the vendor's quality assurance requirements applicable to the items or services procured.

c.

Identification in the procurement documents of the documentation to be prepared, maintained, and/or submitted to j

the purchaser prior to use, such as:

1.

drawings, specifications, procedures 2.

inspection and fabrication plans 3.

inspection and test records 4.

personnel and procedure qualificatio.'s 5.

chemical and physical test results of material 4

6.

the company's right of access to the vendor's facilities and records for surveillance to procurement specifications.

d.

Review and approval of changes and revisions to procurement documents at least equivalent to those for the original document.

f e.

Control of procurement documents for spare and replacement parts such that the technical requirements are equal to or better than the original and administrative control to the current CA Program requirements.

.. ~,. _ _ _ _ _ _. _ _ _.. _,

/

Title:

Section V.

Instructions, Proc. &

Drawings Page:

1 of 2 Rev. No.:

1 Cate:

Octooer 1, 1961 V.

INSTRUCTIONS, FROCEDURES, AND DRAWINGS A.

SCOPE This section of the Operational Quality Assurance Program establishes the measures for prescribing and accomplishing activities requiring quality assurance in accoraance with approved drawings, instructons, or procedures.

B.

RESPONSIBILITIES Persons preparing and approving documents are responsible for assuring that specifications, instructions, procedures and drawings include appropriate quantitative or qualitative acceptance crite71a for determining that activities have been satisfactorily accomplished; assuring that the applicable criteria of 10CFR50 Appendix B and/or Af4SI N18.7 are specified; and assuring that the documents are kept current.

In addition, tne following departments have the distinct responsibilities delineated below.

1.

The Operational Quality Assurance Department shall be responsible for:

a.

Providing for surveillance of instructions, procedures, ano drawings.

b.

Review and approval of all Plant Operational Quality Assurance procedures.

c.

Review of maintenance, modification and inspection procecures for inclusion of quality assurance requirements.

2.

Maine Yankee shall be responsible for the preparation, review, approval, maintenance, and implementation of all instructions anc procedures associated with Maine Yankee activities including computer programs for items important to safety controlled by Maine Yankee.

3.

The Yankee Nuclear Services Division shall ce responsible for:

a.

Updating and control of original drawings and special process procedures and distribution of copies tnereof.

A.

The Plant Operations Review Committee shall be responsible far reviewing proceoores affecting nuclear safety orlor to tneir approval by the Plant Manager.

/

Title:

Section V.

Instructions, Proc. &

Drawings Page: 2 of 2 Rev. tb. :

1 Date: Octooer 1, 1981 C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall be assured through the implementation of the Maine Yankee and/or Yankee Nuclear Services Division actions listed below:

a.

Establishment of provisions which clearly delineate the sequence of actions to De acconpli.shed in the preparation, review, approval, and control of instructions, procedures, and drawings.

b.

Review of inspection plans; test, calibration, special process, maintenance and repair procedures; drawings and specifications; and changes thereto.

2.

Emergency procedures shall contain the following as necessary:

a.

Title - descriptive of tne emergency for which the procedure is provided.

D.

Symptoms - to aid in the identification of the emergency.

c.

Automatic actions that will probably occur as a result of the emergency.

d.

Immediate operator actions for operation of controls or confirmation of automatic actions that are required to stop the degradation of conditions and mitigate their consequences.

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e.

Steps to return the reactor to a normal condition or to provide for a safe extended shutdown period under abnormal or emergency conditions.

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Title:

Section VI. Document Control Page:

1 of 3 Rev. No.:

1 Date:

Octooer 1, 1961 VI.

DOCUMENT CONTROL A.

SCOPE This section of the Operational Quality Assurance Program establishes the measures for controlling documents, including revision thereto, which affect quality activities.

B.

RESPONSIBILITIES 1.

All participating departments shall establish document control measures which provice for the following:

a.

Identification of cepartments responsible for preparation, review, approval, and control of documents, b.

Identification of documentation to be used in performing activity.

c.

Coordination and control of interface documents.

d.

Establishment of distribution lists.

e.

Action to be taken for obsolete or superseded documents.

In addition, the following cept'tments have the unique responsibilities delineated below:

2.

The Operational Quality Assurance Department shall be responsible for surveillance and/or audit of document control systems at Maine Yankee and vendors.

3.

Maine Yankee shall be responsible for:

a.

Controlling the issuance of operating, maintenance, repair, refueling, change documents, computer program procedures.

b.

Distribution and maintenance of all approveo and/cr revised documents assuring quality at the location wnere the activity is performed.

c.

A system of review, approval and distribution of Maine Yankee Quality Assurance documents.

4.

The Yankee Nuclear Services Division snall be responsiale for:

a.

Controlling the issuance of engineering orawings, General l

Specifications, welding and nondestructive examination l

procecures.

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I

Title:

Section VI. Document Control Page:

2 of 3 Rev. to. :

1 Date: Octooer 1, 1961 b.

Revision and distribution of welding and nondestructive examination procedures.

c.

Maintenance and distribution of General Specifications and controlled drawings.

5.

The Vice President - Manager of Operations shall be responsible for establishing the means for the control and distribution of the Operational Quality Assurance Program, and revisions thereto.

C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall be assured through the implementation of the Maine Yankee and/or Yankee Nuclear Services Division actions listed below:

a.

Review and approval of document changes by the same organizations that performed the original review and approval ol by other responsible organizations delegated by Maine Yankee.

b.

Inclusion of approved changes in instructions, drawings, and other applicable documents prior to placing the system in operating status, i

c.

Provision of availability of documents at tne location where the activity is to ce performed pric to commencing the work.

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d.

Establishment, revision, and distribution of a master list or l

equivalent to identify the current revision number of instruction, specifications, drawings, or other quality assurance documents.

e.

Control of documents identifieo as follows:

1.

Design specifications 2.

Design, manufacturing, construction, and installation drawings 3.

Procurement documents 4.

Operational Quality Assurance Program, maintenance, and operating procedures 5.

Manufacturing, inspection and test instructicns 6.

Test documents 7.

Cesign change requests 8.

tenconformance reports

/

Title:

Section VI. Document Control Page:

3 of 3 Rev. No.:

1 Date: Uctooer 1, 1981 2.

Appendicies to the Operational QJality Assurance Program are considered part of the Program and are reviewed and approved per the Program.

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Title:

Section VII. Control of Purcnased Mat'1, Ecuip. & Services Page:

1 of 3 Rev. tb. :

1 Date: Lttocer 1, 1981 VII. CONTROL OF RJRCHASED MATERIAL, EQUIPMENT AND SERVICES A.

SCOPE This section of the Operational Quality Assurance Program establishes measures to assure that purchased material, equipment and services, whether purchased directly or througn contractors and subcontractors, conform to the procurement documents.

8.

RESPONSIBILITIES 1.

The Operational Quality Assurance Department shall be responsible for:

a.

Provide via YNSD, Operational Quality Assurance Dept. for evaluation of vendor quality assurance programs.

b.

Provide for maintenance of a listing of qualified vencors based upon (a).

c.

Surveillance of plant or vendor material and/or services control.

d.

Receipt inspection of material end equipment, e.

Evaluation of bids to assure acequacy of QA requirements.

2.

Maine Yankee shall be responsible for:

a.

Control of material and equipment.

b.

Bid evaluation and control, c.

Evaluation of purcnased services during and/or after completion of the service.

3.

Stores snall be responsible for the control of material and equipment until issued.

4.

Each department snall be responsible for control of equipment and material after issuance from stores.

C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall De assured through the iroplementation of the actions listed below:

a.

Evaluation of vendors based on one or more of tne following:

Title:

Section VII. Control of Purchased MaJ 1, Equip. & Services Page:

2 of 3 Rev. No.:

1 Date: Octooer 1, 1981 1.

Vendor's capability to comply witn the applicaole criteria of 10CFR50 Appendix B and/or ANSI N18.7.

2Property "ANSI code" (as page type) with input value "ANSI N18.7.</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..

Review of vendor's previous records anc performances.

3.

Surveillance of vendor's facilities / services and QA program to determine his ability to produce the item to the purchase specifications.

4.

Review of the Supplier's current quality recoros supported by qualitative and quantitative information which can be objectively evaluated.

The evaluation may include review and evaluation of tne Supplier's Quality Assurance Program, Manual and Procecures, as appropriate.

b.

Documentation and maintenance of the results of vencor evaluations.

c.

Planned venoor surveillances which provide for:

1.

Specification of processes to be witnessed or verified, the surveillance method and documentation required, and personnel responsible for performing the surveillance.

2.

Assurance that the vendor complies with the quality requirements by survaillance of in-process work.

d.

Transfer of tne following records from the vendor to Maine Yankee:

1.

Documentation that identifies the purchased material and j

the specific procurement requirements met by thr item.

2.

Documentation that identifies any deviation from l

procurement requirements including a description of those i

deviations dispositioned " accept as is" or " repair".

1 i

e.

Review and acceptance of vendor cocuments by a responsible l

quality assurance individual.

f.

Receipt inspection of vencor furnisned material to assure:

1.

Material is identified and conforms with receiving cocumentation identification.

2.

Material and documentation are inspected in accordance with p;. determined instructions and are cetermined i

acceptable prior to use.

'Q

Title:

Section VII. Control of Purchased Mat'1, Eculo. & Services Page:

3 of 3 Rev. No.:

1 Date: Octooer 1, 1961 3.

Inspection records or certificates of conformance atesting to material acceptability are o.'-site prior to use.

4.

Items are identified as to their inspection status prior to release for controlled storage, installation or further work.

g.

Evaluation of the vendor's effectiveness to control quality is performed at intervals consistent with the importance, complexity and quality of the item.

h.

Certificates of conformance shall contain as a minimum:

1.

Purchased material or equipment, such as by the purchase order.

2.

Specific procurement requirements met by the purchased material or equipment, such as codes, standards and other specifications.

3.

RJEChase requirements not met and the resolution of tne nonconformance.

4.

Attested to by a person responsible for the quality assurance function including position.

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Title:

Section VIII. Idsntification &

Control of Mat'1, Parts, &

Components Page: 1 of 1 Rev. No.: 1 Date: Octooer 1, 1961 VIII. IDENTIFICATION AND CONTROL OF MATERIAL, PARTS, AND COMPONENTS A.

SCOPE This section of the Operational Quality Assurance Program establishes the measures for identification and control necessary to prevent the use of incorrect or defective material, parts, and components.

B.

RESPONSIBILITIES 1.

The Operational Quality Assurance department shall be responsible for:

a.

Surveillance, at t and/or inspection of the control and issuance of materials, parts, and components covered by the Operational Quality Assurance Program.

b.

Review of vendor Quality Assurance programs for traceability of materials through the use of heat number, part number, or serial number, eit.her on the item or on records traceable to the items.

2.

Maine Yankee shall De responsible for:

a.

Preparation, review and approval of documents for the identification and control of materials, parts, and components including lubricants, consumables, chemicals and reagents (including shelf life),

b.

Maintenance of traceability of materials, parts, and components received, stored, installed, and used at the Plant.

C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall be assured througn the implementation of the actions listed below:

a.

Traceability of the identification of materials and parts to the appropriate documentation such as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and Chemical mill test reports.

b.

Identification of the item in a location and with a metnod which coes not affect its fit, function or quality.

c.

Documented verification of correct identification of materials, parts, and components prior to release for use.

\\s(,,,,,

Title:

Section IX. Control of Special Processes Page: 1 of 2 Rev. No.:

1 Date: Octooer 1, 1981 IX. CONTROL OF SPECIAL PROCESSES A.

SCOPE This section of the Operational Quality Assurance Program establishes the measures necessary to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel in accordance with applicable codes, standards, specifications, criteria and other special rcquirements.

B.

RESPONSIBILITIES 1.

The Operational Quality Assurance Gepartment shall be responsible for:

a.

Providing surveillance, audit and/or inspection of the control of special processes.

b.

Providing performance and/or evaluation of certain nondestructive tests in accordance with Yankee Nuclear Services Division Welding and Nondestructive Examination Procedures".

c.

Providing training, qualification, and requalification of Maine Yankee personnel in nondestructive testing (liquid penetrant examination).

d.

Review of special process documents provided by vendors.

2.

The Yankee Nuclear Services Division shall be responsible for:

i a.

Preparation of documents for welding, heat treating, and nondestructive examinations.

3.

Maine Yankee shall de responsible for:

I a.

Assurance that maintenance and change work involving special processes are performed by qualified personnel in accordance with approved documents.

b.

Control of material used in special processes by plant L

personnel.

c.

R5 view and approval of special process documents provided by l

the vendor.

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/

Title:

Section IX. Control of Special Processes Page:

2 of 2 Rev. tb. :

1 Date: Octooer 1, 1981 C.

IMPLEMENTAT ION 1.

Satisfaction of tnis criterion shall be assured througn the implementation of Maine Yankee and/or Yankee tAaclear Services Division actions listed below:

a.

Qualification records of documents, equipment, and personnel connected with special processes in accordance with applicable codes, standards, and specifications, b.

Special processes accomplished in accordance with written process sheets or equivalent with recorded evicence of verification.

c.

Maintenance and updating of qualification records of spacial process documents, equipment, and personnel.

/

Title:

Section X. Insoection Page:

1 of 2 Rev, tb.:

1 Date: October 1, 1981 X.

INPSECTION A.

SCOPE This section of tne Operational Quslity Assurance Program establishes measures for inspection of activities requiring quality assurance to verify conformance with approved procedures, drawings, specification anc instructions.

B.

RESPONSIBILITIES 1.

The Operational Quality Assurance Department shall be responsicle for:

a.

Review of engineering specifications for inclusion of inspection requirements and acceptance criteria, b.

Review of documentation pertinent to the Inservice Inspection Program.

c.

Surveillance of inspection activities and personnel.

d.

Incorporation of mandatory witness points for plant activities.

e.

Incorporation of mancatory witness points for vendor / service group activities.

f.

Writing and approving inspection instructions and check lists.

2.

Maine Yankee shall be responsible for:

a.

Assuring that activities requiring quality assurance meet predetermined requirements.

b.

Providing qualified personnel and necessary equipment for examinations to assure quality work.

C.

_ IMPLEMENTATION 1.

Satisfaction of tnis criterion shall be assured through the implementation of the actions listed below:

a.

Independence of personnel performing the inspection from the personnel performing the activity being inspected.

b.

Use of instruction or check lists wnich incorporate the details listed in Section XVII Item c.l.a.

c.

Use of necessary drawings and specifications wNo performing inspection cperations.

/

Title:

Section X. Inscection Page:

2 of 2 Rev. No.:

1 Date: _0ctober 1, 1961 d.

Inspection of repairs and replacements in accordance with the original cesign and inspection requirements or acceptable alternatives.

e.

Surveillance of processing methods, equipment, and personnel when direct inspection is not possible.

f.

Qualification of inspectors in accordance with applicable codes, standards, and company training programs; and maintenance of qualifications and certifications.

g.

Review of maintenance documents by qualified personnel knowledgeable in quality assurance to determine the need for inspection, identification of inspection personnel, and documenting inspection results.

h.

When inspections associated with normal operations of the plant (such as routine maintenance, surveillance, and tests) are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following Centrols shall be met:

1.

The quality of the work can De demonstrated through a functional test when the activity involves breaching a pressure retaining item.

2.

The qualification criteria for inspection personnel are reviewed and found acceptable by the QA organiration prior to initiating tne inspection.

Title:

Section XI. Test Control Page:

1 of 2 Rev. No.:

1 Date: October 1, 1981 XI. TEST CONTROL A.

SCOPE This section of tne Operational QJality Assurance Program establishes the measures for a test program to cemonstrate that structures, systems, and components will perform satisfactorily in service.

B.

RESFONSIBILITIES 1.

The Operational OJality Assurance Department snall be responsible for:

a.

Providing surveillance of the control of the test program, b.

Surveillance of the documentation generated during the test program.

2.

The Plant Engineering Department snall be responsible for:

a.

Preparation or review of specifications, requirements, and acceptance criteria for testing following plant changes and maintenance activities..

b.

Determination of when testing is required following plant changes and maintenance activities.

3.

Eacn Plant Department shall be responsible for:

a.

Provision of qualified personnel and calibrated equipment for testing.

b.

Development of test documents, performance of tests, and documentation, evaluation, and approval of test results.

4.

The Plant Operations Review Committee shall review all proposed tests and experiments that affect nuclear safety.

l 5.

The Nuclear Safety Audit and Review Committee shall be responsible for reviewing proposed tests or experiments not cescribed in the safety analysis report which involve a cnange in tne technical specifications or an unreviewea safety question as defined in i

i section 50.59, 10CFR.

C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall De assured through the implementation of the actions listeo below:

1

Title:

Section XI. Test Control Page:

2 of 2 Rev. No.:

1 Date: October 1, 1981 a.

Assurance that changes, repairs, and replacements are tested in accordance with Maine Yankee approved programs, codes, standards and specifications, b.

Review of written test documents for incorporation or reference of the following as appropriate:

l 1.

Purpose 2.

Requirements and acceptance limits contained in applicable l

design and procurement documents.

3.

Reference sources, such as vendor's literature.

[

4.

Instructions for performing the test.

l 5.

Test prerequisites, such as:

l a.

Calibrated instrumentation b.

Adequate and appropriate equipment c.

Trained, qualified, and licensed / certified personnel d.

Completeness of item to be tested e.

Suitable and controlled environmental conditions f.

Provisions for data collection and storage g.

Completion of other procedures l

6.

Mandatory inspection hold points for witness by owner, I

contractor or inspector, when applicable.

7.

Precautions to alert the individual to important measures.

l 8.

Acceptance and rejection criteria.

9.

Method of documenting test data and results.

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c.

Test procedures shall contain criteria for determining the l

accuracy requirements of test equipment.

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'Q)

Title:

Section XII. Control of Measuring

& Test Eouloment Page: 1 of 2 Rev. No.:

1 Date: Octooer 1, 1981 XII. CONTROL OF MEASURING AND TEST EQUIRAENT A.

SCOPE This section of the Operational Quality Assurance Program established the measures for the control, Calibration and periodic adjustments of tools, gages, instruments, and other measuring and test devices used to verify conformance to established requirements.

B.

RESPONSIBILITIES 1.

The Operational Quality Assurance Department shall De responsible for:

a.

Surveillance and/or audit of the established program for the control of measuring and test equipment.

b.

Review and approval of all implementing documents for control of measuring and test equipment.

2.

Each Plant department shall be responsiole for:

a.

Development of the implementing documents for control of measuring and test equipment including identification and calibration for equipment under their control.

b.

Provision of Calibrated tools, gages and instruments necessary to perform required measurements and tests.

c.

Maintenance of Calibration records.

j 1

d.

Preparation and review of specifications for measuring and test equipment, such that all applicable requirements are I

satisfied.

C.

IMPLEMENTATION l

1.

Satisfaction of tnis criterion shall be assured through the I

implementation of tne actions listed below:

a.

Identification and traceability of measuring and test equipment to the calibration test data.

l b.

Labelling or tagging of measuring and test equipment to l

indicate due date for calibration.

\\ ',,s,/

Title:

Section XII. Control of Measuring

& Test Equipment Page: 2 of 2 Rev. No.:

1 Date: Octcber 1, 1981 c.

Calibration of measuring and test equipment at specified intervals based on required accuracy, rarpose', degree of usage, stability characteristics, an( other conditions affecting the measurement.

d.

Documentation of measures taken to determine the validity of previous inspections performed when measuring and test equipment is found to be out of calibration.

e.

Measuring and test equipment shall have an accuracy of four times the required accuracy of the equipment being calibrated. When accuracy requirements cannot be attained, an accuracy that assures that the equipment being calibrateo will be within required tolerance and that the basis of acceptance is documented and authorized by responsible management will be used.

f.

Documentation and maintenance of the status of all items under the calibration system, g.

Traceability of reference and transfer standards to ns.tionally recognized standards; or, decumentation of the basis for calibration where national standards are nonexistent.

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Title:

Section XIII. Handling, Storage

& Snippino Page:

1 of 2 Rev. [40. :

1 Date: Octotwr 1,1981 XIII. HANDLING, STORAGE AND SHIPPING A.

SCOPE This section of the Operational Quality Assurance Program establishes measures to control the handling, storage, shipping, cleaning and preservation of material and equipment to prevent damage or deterioration.

B.

RESPONSIBILITIES 1.

The Operational QJality Assurance Department shall be responsible for:

a.

Providing surveillance, audit and/or inspection of the handling, storage and shipping of materials, parts, and components, b.

Providing review of handling, storage, and shipping documents, c.

Providing review of Engineering and Plant specifications to assure that proper handling, storage, and shipping requirements have been specified.

2.

The Plant shall be responsible for:

a.

Development of the implementing documents for handling, storage and shipping of materials and equipment.

b.

Provisions of suitable facilities and equipment for handling, storage, and shipping of materials.

c.

Inspection and test of special handling tools and equipment.

d.

Providing and controlling special handling tools and equipment to ensure safe and adequate handling.

1 C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall be assured through the i

implementation of the actions listed below:

l a.

Specification and accomplishment of special handling, preservation, storage, cleaning, packaging, and shipping requirements by qualified individuals in accordance with predetermined work and inspection instructions for critical, sensitive, perishable or high value items.

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W,

Title:

Section XIII. handling, Storace

& Shipping

)

Page: 2 of 2 j

Rev. No.:

1 Date: Octooer 1, 1981 b.

Preparation of instructions in accordance with desjgn and specification requirements which control the clear,ing, handling, storage, packaging, shipping and preservation of safety classified materials, components and systems to preclude damage, loss or deterioration by environmental conditions such as temperature or humidity.

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Title:

Section XIV. Inspection, Test a Operating Status Page:

1 of 1 Rev. No.:

1 Date: Octooer 1, 1961 XIV. INSPECTION, TEST AND OPERATING STATUS A.

SCOPE I

This section of the Operational Quality Assuance Program establishes the measures for indicating the status of items undergoing inspections and tests (via tags, labels, etc.), to prevent the unintentional bypass of required tests.

In addition, this section establishes measures for indicating the operating status of components and systems to prevent their inadvertent operation.

8.

RESPONSIBILITIES 1.

The Operational Quality Assurance Department shall be responsible for the surveillance of inspection, test and operational status of ccmponents and systems and their repair.

j 2.

The Plant shall be responsiblie for:

a.

Ensuring indication of the status of operating equipment or systems to be removed from service for maintenance, test, inspection, repair, or change.

i l

b.

Designation of personnel who are responsible for directing i

the status change of equipment and systems.

3.

The Operations Department shall be responsible for:

l a.

Periodic review and update of standing orders.

b.

Periodic review, updating and cancellation of special orders.

c.

Periodic review to evaluate plant operations and plan future activities.

The important elements of the reviews shall ce documented.

C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall be assured througn the l

implementation of the actions listed below:

a.

Notification of affected organizations for changes in the inspection, test and operating status of structures, systems, and components.

b.

Procedural control to prevent the inadvertent bypassing of rec;uired inspections, tests and other critical operations, l

c.

Procedural control to assure that the application and removal j

of inspection and status indicators sucn as tags, markings, l

labels, and stamps are controlled.

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Title:

Section XV. Nonconforming Matl's, Parts & Comoonents Page:

1 of 2 Rev. No.:

1 Date: October 1, 1981 XV.

NONCONFORMING MATERIALS, PARTS, AND COMPONENTS, A.

SC0pe This section of the Operational Quality Assurance Program establishes the meesures to control materials, parts, or components which do not conform to requirements, in order to prevent their inadvertent use.

B.

RESPONSIBILITIES 1.

The Vice President - Manager of Operations shall be responsible for:

a.

Review and approval of all nonconformance report dispositions.

2.

The Operational Quality Assurance Department shall be responsible for:

a.

Surveillance of the control, evaluation, and disposition of nonconforming material, parts and components.

b.

Review and concurrance of dispositions and corrective actions of nonconformance reports.

c.

Surveillance for repetitive nonconforming materials.

d.

Establishment of feedback system between Maine Yankee ano vendor representatives in regard to nonconforming material.

e.

Establishment of measures to provice for the documented control of rionconforming materials, parts, and components.

f.

Preparaticn of documents to be followed in the review ano resolution of nonconforming items, services, or activities.

3.

The Plant Engineering Department snall be responsible for:

a.

Review of nonconforming items which cannot be corrected by vendor action.

b.

Preparation or approval of implementing documents for repair and/or rework of nonconforming items.

C.

IMPLEMENTATION 1.

Satisfaction of tnis critericn shall oe assured through tne implementation of the actions listed below:

a.

Identification, disposition, inspection ano segregation of nonconforming items.

Title:

Section XV. Nonconformino Matl's, Parts & Components Page:

2 of 2 Rev. tb.:

1 Date: Octooer 1, 1981 b.

Identification of those individuals or groups celegateo the responsibility and authority for the disposition and written approval of nonconforming items.

c.

Inspection and test of reworked or repaired items which require reinspection and retest to original methods or methods equivalent thereto.

d.

Inclusion of nonconformance reports dispositioned " accept as is" or " repair" as part of the inspection records furnished to the plant.

e.

Periodic analysis of nonconformance reports to show quality trends with tne results reported to management for review and assessment.

2.

The icentification, description, disposition, inspection and signature approval of the disposition for nonconformance shall be documented in a noncorformance report.

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Title:

Section XVI. Corrective Action Page:

1 of 2 Rev. tb. :

1 Date: Octooer 1, 1981 XVI. CORRECTIVE ACTION A.

SCOPE This section of the Operational Quality Assurance Program estaolishes measures to assure that conoitions aaverse to quality, sucn as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

B.

RESPONSIBILITIES 1.

The Operational Quality Assurance Department shall be responsible for:

a.

Surveillance and/or audit of plant activities involving tne identification, review and correction of conditions adverse to quality.

b.

Surveillance and/or review of documentation of corrective action.

2.

Paine Yankee shall be responsible for:

a.

Identification of.auses of conditions aaverse to quality.

b.

Preparation of recommendations to prevent reoccurrence of a deficiency.

c.

Implementation of the corrective action.

d.

Documentation of corrective action taken.

3.

The Plant Engineering Department shall be responsible for:

a.

Review of conditions adverse to quality whicn involve design deficiencies to cetermine the cause of the conoition.

b.

Recommendations or corrective action to precluce repetition of design deficiencies.

4.

The Plant Operations Review Committee shall be responsible for:

a.

Review of conditions adverse to quality and reccmmencing corrective action.

b.

Recommendations involving repetition of operating deficiencies.

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Title:

Section XVI. Corrective Action Page:

2 of 2 Rev. No.:

1 Date: Octooer 1, 1981 C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall be assured through the implementation of the actions listed below:

a.

Initiation of corrective action following the determination of a condition adverse to quality to preclude recurrence.

b.

Follow-up reviews to verify proper implementation of co

+1ve actions and to close out the correctiva action dow..

tation.

c.

Reporting of significant conditions adverse to quality, the cause of the conditions, and the correction action implemented to the cognizant levels of management for review and assessraent.

Title:

Section XVII. Quality Assurance Recoros Page: 1 of 2 Rev. No.: 1 Date: Octooer 1, 1981 XVII.0UALITY ASSURANCE RECORDS A.

SCOPE 1.

This section of the Operational Quality Assurance Progam establish 3s the measures for maintenance of records which provide documentary evidence of the quality of items and the activities affecting quality. Requirements shall be established for identification, transmittal, retrievability and retention of quality assurance records including durathn, location, orotection and assigned responsibility.

2.

The quality assurance records shall include plant history; operating logs; principal maintenance; design change activities, reportable occurrences; nonconformance reports; results of reviews, inspection, tests, audits and material analys;3; monitoring of work performance; qualification of personnel, occuments and Squipment; drawings; specifications; procurement documents; calibration documents and reports; and corrective action reports.

B.

RESPONSIBILITIES 1.

The Operational Quality Assurance Department shall oe responsible for:

a.

Surveillance and/or audit of quality assurance record review, control and retention.

b.

Maintenance of audit, vendor evaluation, surveillance and inspection records of quality assurance activities generated by the Operational Quality Assurance Department personnel or their designates.

2.

Maine Yankee shall be responsible for:

a.

Writing implementation documents for the estaolishment and maintenance of Operational Quality Assurance records.

b.

Designating individuals and estaolisning requirements for the control of plant design, procurement, and operational records involving quality assurance.

c.

Maintenance of qualification / certification record 3 for Maine Yankee personnel.

d.

Provision of facilities to prevent deterioration or loss of documentation.

Title:

Section XVII. Quality Assurance Recoros Page:

2 of 2 Rav. No.:

1 Date: October 1, 1981 e.

Provision of a system for the review, approval and retention of plant prepared documents such as reportable occurrences, technical reports, required records and the meeting minutes of official committees.

f.

Control and distribution of the Operational Quality Assurance Program and revisions thereto.

C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall be assured through the implementation of the actions listed below:

a.

Specifying the details required for inspection and test records including the following as applicaole:

1) Description of the type of observation.
2) Evidence of completion and verification of tranufacturing, inspection, or test operations.
3) The date and results of the.tnspecticn or test.

4)

Information related to conditions adverse to quality.

5)

Inspector or data recorder identification.

6) Evidence as to the acceptability of the results.

7)

Identification of characteristics and activities to be inspected.

8) Acceptance and rejection criteria.

9)

Icentification of required procecures, crawings, and specifications and revisions.

10' Specifying the necessary measuring and test equipment including accuracy requirements.

b.

Providing for record acministration, receipt, storage, preservation, safekeeping, retrieval anc final disposition.

c.

Construction, location and security of record storage facilities to prevent destruction of the records by fire, floocing, theft, and deterioration by environmental concitions such as temperature or humidity.

Duolicate records shall be stored in a sepaIate remote location wnen the type of document is not included in the record storage facility.

Title:

Section XVIII. Audits Page: 1 of 3 Rev. No.:

1 Date: October 1, 1981 XVIII. AUDITS A.

SCOPE This section of the Operational Quality Assurance Program establishes the measures for a comprehensive system of planned and documented audits to verify compliance with all aspects of the Program and to assess the effectiveness of the Program.

B.

RESPCNSIBILITIES 1.

The Operational Quality Assurance Department shall be responsible for:

a.

Providing approved audit check lists for surveillance of activities encompassed by the 18 criteria of 10CFR50 Appendix B and ANSI N18.7.

b.

Providing for training of audit personnel.

c.

Scheduling and coordinating of the formal Internal Audit

Program, d.

Review and approval of the implementing documents for Internal Audits.

e.

Preparing information regarding the Internal Audit Frogram for review by the Nuclear Safety Audit and Review Ccmittee, f.

Performing random informal surveillance of plant activities.

g.

Provice for evaluatior.3 of vendors.

h.

Identifying program discrepancies and deficiencies.

i.

To verify correction of discrepancies discovered during audits.

J.

Making recommendations to preclude possible audit discrepancy repetition.

2.

The Manager - Nuclear Support shall De responsible for evaluation of and recommend corrective action for Ir,ternal Audit discrepancies.

4 3.

The Plant shall be responsible for:

a.

Documentation of the discrepancy response concerning any outstanding item resulting from an audit at the plant.

Title:

Section XVIII. Audits Page:

2 of 3 Rev. te.:

1 Date: October 1, 1981 b.

Implementation of corrective action to be taken as agreed upon by the Manager - Nuclear Support.

4.

The fAaclear Safety Audit and Review Committee shall De responsible for:

a.

Review of tne Operational Quality Assurance Program to determine its cverall effectiveness.

b.

Reporting results of Program reviews and recommendations resulting therefrom to Maine Yankee Vice President / Manager of Operations and YNSD Vice President.

C.

IMPLEMENTATION 1.

Satisfaction of this criterion shall be assured through the implementation of Maine Yankee documents.

2.

The implementing documents shall provide for the following:

a.

Documentation of audit results and review with management having responsibility in the area audited.

D.

Necessary action to be taken by responsible management to correct deficiencies revealed by the audit.

c.

Reaudit of deficient areas until corrections have been accomplished to preclude recurrence of the deficiencies.

c.

Inclusion of an objective evaluation of quality-related practices, procedures, instructions anc the effectiveness of implementation in the audit.

e.

Inclusion of an objective evaluation of work areas, activities, processes and items and the review of documentaton in the audit.

f.

Performance of audits in the below listed areas where tne requirements of Appendix B to 10CFR Part 50 and ANSI N18.7 are being implemented.

1) Operation, maintenance and repairs.

2)

The preparation, review, approval, ano control of designs, specifications, procurement documents, instruction, proceoures, and orawings.

3)

Receiving and plant inspections.

4)

Incoctrination and training programs.

I

Title:

Section XVIII. Audits Page:

3 of 3 Rev. No.:

1 Date: Octooer 1, 1981 5)

Implementation of operating and test procedures.

6)

Calibration of measuring and test equipment.

7) Security
8) Emergency Plan
9) Health Physics
10) Corrective Action g.

Scheduling of audits regularly on the basis of the status and safety importance of the activities being performed.

h.

Regularly scheduled aucits shall be supplementec by audits as determined by the Director, Operational Qaality Assurance, for one or more of the following conaitions:

1.

When significant changes are maoe in functional areas of the quality assurance program such as significant reorganization or procedure revisions.

2.

When it is suspected that the quality of the item is in jeopardy due to deficiencies in the quality assurance program.

3.

When a systematic, independent assessnent of program effectiveness is considered necessary.

4.

When necessary to verify implementation of required corrective action.

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Title:

Appendix A. Qualification Requirements Page:

1 of 1-Rev. No.:

1

' Ate: Octocer 1, 1981 QUALIFICATION REQUIREMENTS FOR THE DIRECTOR, OPERATICNAL QUALITY ASSURANCE DEPARTMENT The Director, Operational Quality Assurance Department must meet the below listed qualification requirements:

EDUCATION: Bachelor Degree in Engineering or related science, or the equivalent in practical experience.

EXFERIENCE: Four (4) years experience in the field of quality assurance, or equivalent number of years of nuclear plant experience in a supervisory position preferably at an operating neulear plant or a combination of the two. At least (1) year of this four years experience shall be nuclear power plant experience in the implementation of the quality assurance program. Six (6) months of the one year experience shall be obtained within a quality assurance organization.

Title:

Appendix 8. (Exceotions)

Page:

' o f 15 Rev. No.:

1 Date: Octooer 1, 1961 APPENDIX B (Exceptions)

The sub-categories of this Appendix summarize the cxceptions noted in Section II of the Maine Yankee Operational Quality Assurance Program.

Appendix 8 Sub-Catecory Standard /Guioe Title B-1 ANSI N18.7-1976 Administrative Controls and QJality Assurance for the Operational Phase of Nuclear Fower Plants B-2 ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants B-3 ANSI N45.2.10-1973 Quality Assurance Terms and Definitions B-4 ANSI N45.2.12-1977 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants B-5 ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handling af Items for Nuclear Power Plants B-6 Regulatory Guide 1.26 Quality Group Classifications Rev. 3, 2/76 and Standards for Water, Steam, and Radioactive - Waste

- Containing Components of Nuclear Power Plants.

B-7 Regulatory Guide 1.29 Seismic Design Classification Rev. 3, 9/78 B-8 ANSI N45.2.6-1978 Qualification of Inspection, Examination anc. Testing Personnel for Nuclear Power Plants B-9 ANSI N45.2.23-1978 Qualification of Quality Assurance Program Audit Personne). for Nuclear Power Plants

Title:

Accendix B. (Exceptions) Sub Cat. B-1 Page: 2 of 15 Rev. tb.: 1 Date: Octooer 1, 1981 ANSI N18.7 - 1976, Administrative Controls and Quality Assurance for the Phase of Nclear Power Plants EXCEPTION:

The following exception is taken by Maine Yankee.

ANSI standards not referenced in ANSI N18.7-1976, but wnich are referenced in an ANSI standard endorsed by N18.7-1976 shall not be considered as applicable to the Maine Yankee Operational Quality Assurance Program.

ALTERNATIVE:

Maine Yankee may use the noted standards as guides, as necessary.

/

Title:

Aopendix 8. (Exceotions) Sub Cat. B-2 Page:

3 of 15 Rev. No.: 1 Date: Octooer 1, 1981 ANSI N45.2.3-1973, Housekeeping During the Construcion Phase of Nuclear Power Plants A.

EXCEPTION:

Subsection 2.1 - Planning Maine Yankee takes exception to the five-zone rec Arements specified in the subject standard.

ALTERNATIVE:

Maine Yankee shall establish as a minimum a three-zone program as follows:

Zone III Z ine III criteria shall be applied to major portions of the reacter coolant system which are opened for inspection, maintenance or r9 pair.

1.

Access control over personnel shall be required.

2.

Cleanliness shall be maintained, commensurate with the work being performed, so as to preclude the entry of foreign material to the Reactor Coolant System.

3.

A documented cleanliness inspection shall be performed immediately prior to closure.

NOTE:

The Zone III requirements may be expanded for certain maintenance / repair activities if deemed approprhte by plant management.

In such instances applicable sections of Zones I & II shall be specified.

Zone IV Zone IV criteria snall be applied to the radiation control areas of the plant.

1.

Stancard janitorial and work practices snall be utilized to maintain a level of cleanliness commensurate with company policy in the areas of Housekeeping, Plant and Personnel Safety and Fire Protection.

2.

Additional housekeeping requirements shall oe implemented as required for the control of radioactive contamination.

3.

Smoking and eating shall be controlled consistent with good nealth physics practices and to maintain cleanliness.

Q/

Title:

Appendix B. (Exceptions) Suo Cat. B-2 Page:

4 of 15 Rev. No.:

1 Date:

Octooer 1, 1981 ANSI N45.2.3-1973 (Cont.)

Zone V Zone V criteria shall be applied to the remainder of the plant.

1.

Standard janitorial and work practices shall be utilized to maintain a level of cleanliness commensurate with company policy in the areas of Housekeeping, Plant and Personnel Safety and Fire Protection.

B.

EXCEPTION:

Subsection 3.2 - Control of Facilities Maine Yankee takes exception to the control of tools, equipment, materials and supplies used in Zone III.

ALTERNATIVE:

Maine Yankee shall verify control for Zone III as indicated in Exception A of this sub-category.

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Title:

Appendix B. (Exceotions) Sub Cat. B-3 Page:

5 of 15 Rev. No.:

1 Date: Octooer 1, 1981 ANSI N45.2.10-1973, Quality Assurance Terms and Definitions EXCEPTION:

Subsection 2 - Terms and Definitions Maine Yankee takes exception to the definitions of " Certificate of Conformance" and " Certificate of Compliance".

ALTERNATIVE:

Maine Yankee shall rGverse the cefinitions of the above terms so our Prog"am will be in compliance with the implied definitions in the ASME B&PV Code and Maine Yankee specifications.

4,,,e

Title:

Appendix B. (Exceptions) Sub Cat. B-4 Page: 6 of 15 Rev. No.: 1 Date: October 1, 1981 ANSI N45.2.12, 1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants A.

EXCEPTION:

I Subsection 4.2.2 Team Selection Maine Yankea takes exception to the requirement that a " Lead Auditor" be appointed as team leader.

ALTERNATIVE:

Team Selection Audits will be performed under the cognizance of a lead auditor.

B.

EXCEPTION:

Subsection 3.5.3.3 i

Maine Yankee takes exception to the requirement for supplemental audits.

ALTERNATIVE:

Maine Yankee Internal Audits are performed on a calendar year frequency and preclude the need for supplemental audits. Supplemental Audits will be initiated by the Director, Operational Quality Assurance as deemed.

necessary for significant changes in the QA Program or procedures.

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Title:

Accendix B. (Exceptions) Sub Cat. b-5 Page:

7 of 15 Rev. No.:

1 Date: Octooer 1, 1981 ANSI N45.2.2 - 1972, Packaoing, Shiocing, Receiving, Storage & Handling of Items for Nuclear Power Plants A.

EXCEPTION:

Subsection 3.7.1 & A3.7.1 - Containers Maine Yankee takes exception to the specific requirements for containers.

ALTERNATIVE:

Containers shall be of suitable construction to assure material is received undamaged.

JJSTIFICATION:

Containers shipped by closed carrier, stored inside and not subjected to a wet environment do not require weather resistant fiberboard, therefore, this is an unnecessary expense.

Additionally, numerous vendors utilize snipping containers that do not comply with tne specific requirements of this section, i.e.,

flaps overlap.

The acceptance criteria for a shipping container should be established based on the capability of the container to maintain the component / material in a safe condition.

Technology has advaced beyond the stanoard.

B.

EXCEPTION:

Subsection 3.7.2 - Crates and Skids Maine Yankee takes exception to the requirement that skids and runners shall be used on boxes with a gross weight of 100 pounds or more.

ALTERNATIVE:

Skids or runners shall be used on boxes with a gross weight cf 100 pounds or more if practical.

3)STIFICATION:

Storage methods and container design frequently are sucn that runners or skids are not feasible.

Title:

Appendix 8. (Exceotions) Suo Cat. B-5 Page:

8 of 15 Rev. No.:

1 Date: Uctooer 1, 1981 ANSI N45.2.2 (Cont.)

C.

EXCEPTION:

Subsection 5.2.1 - Shipoino Damage Inspection Maine Yankee takes exception to the requirement that a preliminary visual inspection or examination be performed prior to unloading.

ALTERNATIVE:

Maine Yankee shall perform those required inspections ifter unloading.

In special instances, pre-unloading inspections shall be performed.

JJSTIFICATION:

Post unloading inspection is adequate to cetermine any damage that may have been incurred during snipping and handling.

D.

EXCEPTION:

Subsection 5.2.2 - Item Inscection Maine Yankee takes exception to the requirement, that "The inspections shall be performed in an area equivalent to the level of storage requirements for the item".

ALTERNATIVE:

Maine Yankee shall perform receiving inspection in a manner ano in an environment whicn does not endanger the requisite quality of the item; however, receiving area environmental controls may be less stringent than storage environmental controls for that item. When inspections are performed in receiving areas with environmental controls less stringent than storage area environmental controls, a time limit shall be establisned on a basis for retention of items in the receiving area.

Retention time shall be such that deterioration is prevented and applicable manufacturer recommendations are addressed.

JUSTIFICATION:

Recaipt inspection activities are for a much shorter duration and therefore should not be subjected to the same stringent requirements as required for storage.

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Title:

Aopendix B. (Exceotions) Sub Cat. B-5 Page: 9 of 15 Rev. No.: 1 Date: Octooer 1, 1981 ANSI N45.2.2 (Cont.)

E.

EXCEPTION:

Subsection 5.2.3 - Soecial Insoection Maine Yankee takes exception to attaching special inspection procedures to the item or container.

ALTERNATIVE:

Special inspection procedures shall be readily available to personnel performing ine?ections.

JUSTIFICATION:

Procedures are subject to less abuse and more stringent controls when maintained on file and not attached to the item.

Inspection status is maintained by tagging and procedure control.

F.

EXCEPTION Subsection 6.1.2 - Levels of Storage Maine Yankee takes exception to two specific requirements associated witn fuel storage (classified level A).

ALTERNATIVE:

Maine Yankee shall meet the requirements of level A storage for new fuel with the exception of special air filtering; and termperature and humidity controls.

JUSTIFICATION:

The existing storage conditions at Maine Yankee plants are consistent with the protection provided to the fuel while in storage at the manufacturer (vendor) and/or while in transit to the plant site and are judged to provide adequate protection to the fuel assemoly structure which is of hignly corrosion resistant materials. We believe that the above listed requirements are intended for application at the menofacturing facility (vendor) where the uranium pellets may be exposed t.

.he atmosphere and not in its fully encapsulated, and therefore, fully protected form in a completed fuel assembly.

G.

EXCEPTION:

Accendix A-3 Subsection A3.5.l(l) - Caos & Plugs Maine Yankee takes exception to tne requirement that non-metallic plugs and caps shall be brightly colored.

Title:

Appendix B. (Exceptions) Sub Cat. B-5 Page:

10 of 15 Rev. No.:

1 Date: Octouer l l961 u

ANSI N45.2.2 (Cont.)

ALTERNATiE:

Non-metallic plugs and caps shall be of a contrasting color.

JUSTIFICATIONS:

The purpose of utilizing brigatly colored plugs and caps is to assist in assuring obstructions are not inadvertently placed in operating components or systems. By using plugs and caps of a contrasting color this objective can be achieved.

H.

EXCEPTION:

Aopendix A-3 Subsection A3.9(1) - Second Grouo, Markinos Maine Yankee takes exception to the requirement tnat container markings shall appear on a minimum of two sides.

ALTERNATIVE:

Containers shall be adequately marked to provide identification and retrievacility.

JUSTIFICATION:

Containers are tagged to provice identification and inspection status.

Employment of two tags on small containers adds bul.. and confusion and does not provide for better icentification or traceability.

I.

EXCEPTION:

Appendix A-3, Suosection A.3.9(4) - Second Group, Marking Maine Yankee takes exception to tne requirement that container markings shall be no less than 3/A" high container permitting.

ALTERNATIVE:

Container markings shall be of a size which permits easy recognition.

JUSTIFICATION:

Markings were intendeo to provice identification and instructions.

The criteria should be that the markings clearly provide the same.

J.

EXCEPTION:

Accendix A-3 Subsection A.3.9(6) - Second Grouo, Marking Maine Yankee takes exception to tne information required for container marking.

Title:

Appendix 8. (Exceptions) Sub Cat. B-5 Page: 11 of 15 Rev. No.: 1 Date: Uctooer 1, 1981 ANSI N45.2.2 (Cont.)

ALTERNATIVE:

i;arkino shall be adequate in each case to provide identification, traceability and instructions for special handling, as applicable.

JUSTIFICATION:

The information required is excessive.

Cluttering a container with excessive markings only reduces the main objectives, maintaining i'.atification and establishing special controls.

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Title:

Appendix B. (Exceptions) Sub Cat. B-6 Page:

12 of 15 Rev. No.:

1 Date: October-1, 1981 Regulatory Guide 1.26, Rev. 3, (2/76), Quality Grouc Classifications and Stancaros for water, Steam and Radioactive - Waste - Containing Comoonents of Nuclear Power Plants EXCEPTION:

Maine Yankee takes exception to the Guice in its entirety.

ALTERNATIVE:

Maine Yankee shall continue to classify structures, components and systems in accordance with ANSI Standard N18.2, " Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants" as in the past.

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Title:

Appendix B. (Exceptions) Sub Cat. B-7 Page:

13 of 15 Rev. No.:

1 Date: October 1, 1981 Regulatory Guide 1.29, Rev. 3,1978, Seismic Design Classification EXCEPTION:

Maine Yankee takes exception to the application of Reg. Guide 1.29, Rev. 3, (9/78).

ALTERNATI Q Maine Yankee shall apply Reg. Guide 1.29, Rev. 3 (9/78) to those structures, systems and components as defined in the Maine Yankee FSAR Section 2.5.

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Title:

Appendix B. (Exceotions) Suo Cat. B-8 Page: II~of 15 Rev. No.:

1 Date: Octooer 1, 1981 ANSI N45.2.6 - 1978, Qualification of Inscection, Examination and Testing Personnel for Nuclear Power Plants EXCEPTION:

Maine Yankee takes exception to the application of tne Standaro to all Maine Yankee personnel performing inspection, examination and testing.

ALTERNATIVE:

Maine Yankee personnel identified in ANSI N18.1-1971 who perform inspection, examination and testing will be qualified to ANSI N18.1-1971.

Maine Yankee personnel not identified in ANSI N18.1-1971 who perform inspection, examination and testing will te qualified to ANSI N45.2.6.-1978.

Contractor personnel who perform inspection, examination and testing at Maine Yankee will be qualified to ANSI N45.2.6-1978.

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Title:

Appendix B. (Exceotions) Sub Cat. B-9 Page: 15 of 15 Rev. No.:

1 Date: Octooer 1, 1981 ANSI N45.2.23 - 1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants EXCEPTION:

Maine Yankee takes exception to implementation of ANSI N45.2.23-1978 commencing 90 days after NRC approval.

ALTERNATIVE:

Maine Yankee shall implement ANSI N45.2.23-1978 prior to June 1,1982 to allow adequate time to qualify auditors.

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Title:

Apoendix C. Maine Yankee Classifications Page: 1 of 7 Rev. No.: 1 Date: Octooer 1, 1981 MAINE YANKEE CLASSIFICATION OF STRUCTURES, COMPONENTS AND SYSTEMS SAFETY CLASS I. STRUCTURES Vapor Conta'.ner 2

II. ELECTRICAL SYSTEMS AND COMPONENTS Electrical and Instrumentation systems and components designed in accordance with IEEE Standard 279, " Criteria for Protection Systems for Nuclear Power Generating Stations" and IEEE Standard 308, " Criteria for Class IE Electric Systems for Nuclear Power Generating Stations" have been classified as safety class, and are listed below:

A.

4160 Volt Switch gear (Engineered Safety Features Buses) l 8.

4160 - 480 Volt Transformers ( Associated with Engineered Safety Features)

C.

4000 and 460 Volt Motors (Associate with Engineered Safety Features)

D.

480 Volt Switch gear (Engineered Safety Features Buses)

E.

480 Volt Motor Control Centers (Associated with Engineered Safety Features)

F.

125 volt DC Batteries /

ociated with Engineered Safety Features)

G.

Battery Chargers ( Associated with Engineered Safety Features) l H.

Inverters, 125 Volt DC to 120 Volt AC (Vital Instrument Euses)

I.

Vital Instrument Bus Panels J.

Regulated Instrument Buses Panels (240/120 Volts AC Single Phase)

K.

125 Volt DC Power Panels (Associated sith Engineerea Safety Features)

L.

Transformers, dry type, 280-120/240 Volt (Associated with Regulated Instrument Buses)

M.

Cable Trays (Associated with Engineered Safety Features)

N.

Containment Penetration Assemolies 0.

Power Cables (Associated with Engineered Safety Features System)

P.

Instrumentation and Control Cables ( Associated with Engineered Safety Feature System)

Q.

AC Control Room Lignting R.

Diesel Generators S.

Diesel Generator Control Panels T.

Heat Tracing for Boric Acid Injection U.

Reactor Protective Systems V.

Engineered Safety Features Actuation Systems

Title:

Aopendix C. Maine Yankee Classifications Page: 2 of 7 Rev No.:

1 Date: Uctooer 1, 1981 SECTION II TOTES:

1.

For those electrical and instrumentation systems designated above, Quality Assurance electrical and instrumentation program requirements are applicable only to those portions of systems defined in Section IV as necessary to perform the system safety function.

2.

Instrumentation components included within each instrumentation system include power supply, sensors, relays, wiring and final operating device (solenoid, relay, etc.) as necessary to perform the system safety function.

3.

Electrical components included within each electrical system incluce power source, breaker, control circuit, cable, relaying and operating device (motor, solenoid, heater, relay, etc.) as necessary to perform the system safety function.

4.

Certain components are excluded from the QA program requirements if they meet the criteria described in Section III.

III. ELECTRICAL AND INSTRLNENTATION SYSTEM COMPONENT EXCLUSION CRITERIA 1.

Any component of an electrical or instrumentation system (Section II) is excluded from the QA Program requirements if it meets the following criteria:

l a.

A failure of the component by the electrical shorting, open circuiting, grouncing or mechanical failure would not render the system incapable of performing its intended safety function l

l b.

A failure of the fluid pressure boundary of the c.omponent would not render the system incapable of performing its intended safety function.

c.

It is not used to operate or control a device required by Tecnnical Specifications.

2.

Small spare parts having no traceability, such as commercial off-the l

shelf items, may be purchased as non-safety-related and tnen qualified for use in equipment requiring Quality Assurance.

Examples of sucn items are resistors, capacitors, switches, indicators, coils, wire, connectors, solid state cevices and miscellaneous haroware.

IV.

MECHANICAL SYSTEMS AND CGMPONENTS i

Mecnanical systems and components have been nuclear safety classifieo in accordance with ANSI Standard N18.2, " Nuclear Safety Criteria for tne Design of Stationary Pressurized Water Reactor Plants".

I

Title:

Appendix C. Maine Yankee Classifications Page:

3 of 7 Rev. No.:

1 Date:

Octooer,1, 1961 Instruments, controls, motors, sensors, etc. associated with the nuclear safety classified components which assist the components in performing a safety function are in the same safety class as the component to which they are associated except as noted in Section II above.

Corresponding component supports that provide a safety function are in the same safety class as the components for which they provide support.

Component safety class designations are listed in the attached Taole C.1 v.

OTFER ITEMS RECUIRING QUALITY ASSURANCE 1.

Fuel Assemblies 2.

Boric Acid 3.

Diesel Fuel Oil 4.

Weld Rod 5.

Chemicals a.

Hydrogen D.

Nitrogen c.

Morpholine d.

Hydrazine e.

Resins 6.

Reagents a.

Those reagents used in performance of analyses required by Technical Specifications.

7.

Packaging of radioactive waste materials for transport.

Title:

Aopendix C. Maine Yankee Classifications Page:

4 of 7 Rev. No.: E Date: October 1, 1981 TABLE C.1 (Sheet 1 of 4)

MECHANICAL SYSTEMS AND COMPONENTS CLASSIFICATION' LIST SAFETY CLASS COMPONENT Reactor Coolant System Reactor Vesstl 1

Full Length Control Rod Drive Mechanism Housing 1

Part Length Control Rod Drive Mechanism Housing 1

Steam Generator (tube side) 1 (shell side) 2 Pressurizer 1

Reactor Coolant Piping, Fittings, and Fabrication 1

Surge Pipe, Fittings amd Fabrication 1

Safety Valves 1

Relief Valves 1

valves to Reactor Coolant System Boundary 1

Reactor Coolant Pump Casting 1

Main Flange 1

Feedwater System Auxiliary Feedwater Pumps 3

Demineralized Water Storage Tank 3

Feedwater Piping (inside containment and outside containment to feed REG Isolation Valve) 2 Service Water System Service Water Pumps 3

Valves and Piping 3

Containment Soray System

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Title:

Appendix C. Maine Yankee Classifications

~~

Page:

5 of 7 Rev. No.:

1 Date: Octooer 1, 1961 TABLE C.1 (Sheet 2 of 4)

SAFETY CLASS COMPONENT Spray Chemical Addition Tank 2

Containment Spray Pumps 2

Chemical and Volume Control System Regenerative Heat Exchanger 2

Letdown Heat Exchanger (tube side) 2 (shell side) 2 Reactor Coolant Purification Cemineralizers 2

Reactor Coolant Filter 2

Charging Pumps Centrifugal 2

Auxiliary Charging Pump 2

Seal Water Supply Filters 2

~

Seal Water Return Filter 2

Seal Water Heat Exchanger (tube side) 3 (shell side) 3 Boric Acid Storage Tank 3

Boric Acid Transfer rumps 3

Boric Acid Filter 3

Boric Acid Mix Tank 3

Volume Control Tank 2

Letdown Flow Control Valves 2

Safety Injection System Refueling Water Storage Tank 2

Safety Injection Tanks 2

Low Pressure Safety Injection Pumps 2

Residual Heat Removal System Residual Heat Excnangers (tube side) 2 (shell sice) 3 Radioactive Gasecus Waste System

N se

Title:

Appendix C. Maine Yankee Classifications Page: 6 af 7 Rev. No.: 1 Date: October 1, 1981 TABLE C.1 (Sheet 3 of 4)

SAFETY CLASS CDMPDNLNT Waste Gas Compressor 3

Waste Gas Surge Tank 3

Gas Decay Drums 3

Component Cooling Water System Component Cooling Water Pump 3

Component Cooling Water Surge Tank 3

Component Coolina Water heat Exchangers 3

Main Steam System Main Steam Piping (from Steam Generator up to and including non-return valves) 2 Safety Valvas 2

Atmospheric Dump Valve 2

Steam Generator Slowdown System Piping (up to and including isolation valve) 2 Emercency Diesel Generator System Diesel Fuel Day Tank 3

Diesel Generator Air Tanks 3

Diesel Engines 3

Startino Air System Air Tanks 3

Piping and Fittings 3

Valves 3

Filters 3

Title:

Accendix C. Maine Yankee Classifications Page:

7 of 7 Rev. No.: 1 Date: Octcoer 1, 1981 TABLE C.1 (Sheet 4 of 4) 3AFETY CLASS COMPONENT Spent Fuel Pool Cooling and Cleanuo System Spent Fuel Pool Pump 3

Spent Fuel Pool heat Exchanger 3

Spent Fuel Pool Cooling Loop Valves 3

Spent Fuel Pool Cooling Loop Piping 3

Handling Eculoment for Fuel and Reactor Vessel Internals Fuel Transfer Tube Outer Sleeve 2

Expansicn Joints 2

Fuel Transfer Tuce and Flange 2

Ecuipment and Floor Drainace System High Pressure Drain Cooler 2

Primary Drain Tank 3

Primary Drains Degasf fier 3

Primary Drain Pumps 3

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