ML20041F450
| ML20041F450 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/12/1982 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO. |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| References | |
| SBN-225, NUDOCS 8203160514 | |
| Download: ML20041F450 (91) | |
Text
.
o SEABM STAM IPUBLIC SEAVICE e.g..:: N orne.:
Companyof NewHW 1671 Worcester Road Framinoham, Massachusetts 01701 (617) - 872-8100 March 12, 1982
\\b - hg SBN-225 T.F. B 7. @-
V,-
.,,w C)
.t g
United States Nuclear Regulatory Commission
" S u 7 g 7a
,1 9-Washington, D. C. 20555 c a.:
Attention:
Mr. Frank J. Miraglia, Chief I,\\
h' D
<c' Licensing Branch #3 Nh Division of Licensing
[;
Re f ere nc es :
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated February 12, 1982, " Request for Additional Information," F. J. Miraglia to W. C. Tallman
Subject:
Responses to 260 Series RAIs; (Quality Assurance Branch)
Dear Sir:
We have enclosed responses to the subject RAIs, which you forwarded in Re fe rence ( b).
Very truly yours, YANKEE ATOMIC.LECTRIC COMPANY D)
John DeVincentis Project Manager JDV: ALL : dad rnclosure zoof
\\
S l
988 it8FJ888$a A
o 1
d 260.0 Quality Assurance Branch Question 260.1 Describe the criteria used for determining the size of the QA organization.
Response to 260.1 FSAR Section 17.2.1.3,will be amended as per Attachment A to provide this information.
O e
-~_-
9 Question 260.2 Describe the provisions which assure that designated QA individuals are involved in day-to-day plant activities important to safety (i.e., the QA organization routinely attends and participates in daily plant work sche-
_dule and status meetings to assure they are kept abreast of day-to-day work assignments throughout the plant and that there is adequate QA coverage relative to procedural and inspection controls, acceptance criteria, and QA staffing and qualification of personnel to carry out QA assignments).
Response to 260.2 FSAR Section 17.2.1.3 will be amended as per Attachment A to provide this information.
s Question 260.3 The qualification requirements for the Nuclear Quality Manager (NQ Mgr.)
are not satisfactory.
It is an NRC staff position that the qualifications and experience of the NQ Mgr. be at least equivalent to those described in Section 4.4.5 of A!lSI/ANS 3.1-1973, " Selection and Training of Nuclear Power Plant Personnel." In lieu of the above, we would accept a commitment to the education and experience described in the following Section 4.4.5 of ANS 3.1-1979:
EDUCATION: Bachelor Degree in Engineering or related science.
EXPERIENCE: 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 nuclear plant or a combination of the two.
At least one (1) year of this four years experience shall be nuclear power plant experience in the implemen-tation of the quality assurance program. Six (6) months of the one year experience shall be obtained within a quality assurance organization.
Provide a description to satisfy this position.
Response to 260.3 FSAR Section 17.2.1.3 will be amended as per Attachment A to provide this information.
Question 260.4 Give a brief summary of the company's corporate QA policies which are established at the Chief Executive Officer or Executive Vice President level.
Response to 260.4 FSAR Section 17.2 will be amended as per Attachment A to provide this information.
9
+
i r
Question 260.5 Identify the existing or proposed QA procedures in a matrix to reflect that each criterion of 10 CFR 50 Appendix B will be addressed.
i Response to 260.5 FSAR Appendix 17B will be added as per Attachment A to provide this information.
It must be noted that procedures are presently in the deve-lopment stage and as a result procedural titles may change or procedures may be combined in such a manner so as to most effectively integrate Station activities.
i i
9 1
I
Question 260.6 Describe the provisions which assure quality-affecting procedures required to implement the QA program are consistent with QA program commitments and corporate policies and are properly documented, controlled, and made man-datory through a policy statement or equivalent document signed by a responsible official.
Response to 260.6 FSAR Section 17.2.2.1 will be amended as per Attachment A to provide this information.
a i
i
Question 260.7 A commitment is made in Section 17.2.2.4 that "The OQAP complies with the intent of the following references:" To preclude any misinterpretation regarding the commitment statement, it is recommended that this sentence be revised as follows: After references, add " rad the regulatory position of the Regulatory Guides:"
Response to 260.7 FSAR Section 17.2.2.4 will be amended as per Attachment A to provide this information.
Question 260.8 Modify Section 17.2.2.4 to be consistent with current regulatory require-ments as follows:
(a) Delete reference to Regulatory Guide 1.54 since it is covered in other sections of the FSAR.
(b) Add Regulatory Guides 1.26-Rev. 3, " Quality Group Classification, and Standards for Water, Steam, and Radioactive Waste Containing Components of Nuclear Power Plants," dated 2/76 and 1.29-Rev. 3,
" Seismic Design Classification," dated 9/78.
Response to 260.8 FSAR Section 17.2.2.4 will be amended as per Attachment A to provide this information.
1
s Question 260.9 Provide the " exceptions, alternatives, and clarifications to be referenced standards" (Ref. p. 17.2-16).
Response to 260.9 FSAR Section 17.2.2.4 and Appendix 17A will be amended to provide this information.
l e
i l
l i
i s
4 l
i i
4 1
,,s
.._.e-.
y---,,
,.~r.
y
-e s.
.----,-----y
6 Question 260.10 It is an NRC staff position that qualified individuals in the QA organiza-tion, either onsite or offsite, shall be responsible for performing reviews and cancurring in documents (e.g., procedures / instructions addressing main-tenance, calibration, testing, etc.; drawings, specifications, etc.)
affecting quality and safety, including changes thereto, prior to issuance.
Modify Section 17.2.2.6 to address this position.
Response to 260.10 i
FSAR Section 17.2.2.6 will be amended as per Attachment A to provide this information.
1 Question 260.11 Identify the personnel authorized to approve changes to the list (Ref.
Appendix 17A of the FSAR) of structures, systems, components, and related consumables covered by the QA program and describe the method for controlling the distribution of the list.
Response to 260.11 FSAR Section 17.2.2.2 will be amended as per Attachment A to provide this information. Appendix 17A will be deleted because this information is covered in Tables 3.2-1 and 3.2-2 of the FSAR.
~
Question 260.12 i'
Clarify that the indoctrination and training programs (Ref. Section 17.2.2.8) are established such that:
(a) For formal training and qualification programs, documentation includes the objective, content of the program, attendees, and date of attendance.
(b) Proficiency tests are given to those personnel performing and verifying activities affecting quality, and acceptance criteria are developed to determine if individuals are properly trained and qualified.
(c) Proficiency of personnel performing and verifying activities affecting quality is maintained by retraining, reexamining, and/or recertifying g
as determined by management or program commitment.
Response to 260.12 FSAR Section 17.2.2.8 will be amended as per Attachment A to provide this information.
E b
D
,l t
't 4
(
I
Question 260.13 Clarify that procedures are established requiring a documented check to verify the dimensional accuracy and completeness of design drawing and specifications.
Response to 260.13 FSAR S ction 17.2.3.2 will be amended as per Attachment A to provide this I
.,i._.-.-,
w.
,f.e
Question 260.14 Clarify that procedures are established requiring that design drawings and specifications be reviewed by the QA organization to assure that the docu-ments are prepared, reviewed, and approved in accordance with company pro-cedures and that the documents contain the necessary quality assurance requirements such as inspection and test requirements, acceptance require-ments, and the extent of documenting inspection and test results.
Response to 260.14, FSAR Section 17.2.3.2 will be amended as per Attachment A to provide this information.
j i
l l
f l
?
l 1
s
Question 260.15 Clarify that procedures are established for design verification activities which assure the following:
(a) Design verification, if other than by qualification testing of a pro-totype or lead production unit, is completed prior to release for pro-curement, modification, or to another organization for use in other design activities.
In those cases where this timing cannot be met, the design verification may be deferred, providing that the justifica-tion for this action is documented and the unverified portion of the design output document and all design output documents, based on the unverified data, are appropriately identified and controlled.
Activities associated with a design or design change should not proceed without verification past the point where the installation would become irreversible (i.e., require extensive demolition and rework).
In all cases, the design verification should be complete prior to relying upon the component, system, or structure to perform its function.
(b) Procedural control is established for design documents that reflect the commitments of the SAR; this control differentiates between docu-ments that receive formal design verification by interdisciplinary or multi-organizational teams and those which can be reviewed by a single individual (a signature and date is acceptable documentation for per-sonnel certification). Design documents subject to procedural control include, but are not limited to, specifications, calculations, com-puter programs, system descriptions, SAR when used as a design docu-ment, and drawings including flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single line diagrams, structural systems for major facilities, site arrangements, and equip-ment locations.
Specialized reviews should be used when uniqueness or special design considerations warrant.
(c) The responsibilities of the verifier, the areas and features to be verified, the pertinent considerations to be verified, and the extent of documentation are identified.
Response to 260.15 FSAR Section 17.2.3.3 will be amended as per Attachment A to provide this information.
l
a Question 260.16 If the verification method is only by test, describe the provisions which assure that:
(a) Procedures provide criteria that specify when verification should be by test.
(b) Prototype, component or feature testing is performed as early as possible prior to installation of plant equipment, or prior to the point when the installation would become irreversible.
Response to 260.16 FSAR Section 17.2.3.3 will be amended as per Attachment A to provide this information.
i i
=
Ouestion 260.17 Clarify that procedures are established to assure th'at procurement docu-s-
ments identify applicable administrative and reporting requirements; drawings; specifications; codes and industrial standards; test and inspec-l tion requirements; and special process instructions that must be complied with by suppliers.
Response to 260.17 FSAR Section 17.2.4.2 will be amended as per Attachment A to provide this information.
1 4
C I
I
Question 260.18 Clarify that procedures are established to provide for the preparation of as-built drawings and related documentation in a timely manner to accura-tely reflect the actual plant design.
Response to 260.18 FSAR Section 17.2.5.1 will be amended as per Atachment A to provide this information.
I i
4 f
I
(
l l
Question 260.19 Describe the provisions which assure that selection of suppliers is docu-mented and filed.
If an LCVIP letter of confirmation or the " CASE" Register is used to establish the qualifications of the supplier, the docu-mentation should identify the " letter" or " audit" used.
Response to 260.19 FSAR Section 17.2.4.3 will be amended as per Attachment A to provide this info rmation.
c
(
l I
l l
l l
-,_e
--.~--+-~uw--
vw=
* *' ~ ~ ~
' ~ '
~^ ~ ' ^ "
~' ' '
Question 260.20 Describe the provisions which assure that procurement of spare or replace-ment parts for structures, systems, and components important to safety is subject to present QA program controls, to codes and standards, and to
' technical requirements equal to or better than the original technical requirements, or as required to preclude repetition of defects.
Response to 260.20 FSAR Section 17.2.4.2 will be amended as per Attachment A to provide this information e
Question 260.21 Describe the provisions which assure that for commercial "off-the-shelf" items where specific qualitr assuiance controls appropriate for nuclear applications cannot be impos?d in a practicable manner, special qual ~ty i
verification requirements shall be established and described to provide the necessary assurance of an acceptable item by the purchaser.
Response to 260.21 FSAR Section 17.2.4.2 will be amended as per Attachment A to provide this information.
l i
t W
Question 260.22 Identify the organization (s) for the " qualified Seabrook Staff members" performing receipt inspection (Ref. Section 17.2.7.3).
Response to 260.22 FSAR Section 17.2.7.3 will be amended as per Attachment A to provide this information.
h 1
4 e
a 4
e w--
w
-,m
,+,,-,mv o-s m n,
w----,-v,-
-, - - - +
---g w
-s-~.en-.,e
f Question 260.23 i
Describe the QA organizational responsibilities for qualifiertion of spe-cial processes, equipment, and personnel.
Response to 260.23 4
j FSAR Section 17.2.9.1 will be amended as per Attachment A to provide this information.
f
- E 4
i 1
l l
t
Question 260.24 Describe the provisions which assure that when inspections associated with normal operations of the plant (such as routine maintenance, surveillance, an'd tests) are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following controls are met:
(a) The quality of the work can be demonstrated through a functional test when the activity involves breaching a pressure retaining item.
(b) The qualification criteria for inspection personnel are reviewed and found acceptable by the QA organization prior to initiating the inspection.
Response to 260.24 FSAR Section 17.2.10 and Section 17.2.11.3 will be amended as per Attachment A to provide this information.
I 1
l
-~v-
'- -~~-
Question 260.25 t
Clarify that criteria are established to determine the accuracy require-ments of test equipment and to determine when a test is required or how and when testing activities are performed.
Response to 260.25 FSAR Section 17.2.11.3 will be amended as per Attachment A to provide this information.
1 1
l
- l 4
4 9
1
\\
Question 260.26 Describe the QA organizational responsibilities for establishing imple-menting, and assuring effectiveness of the calibration program.
Response to 260.26 FSAR Section 17.12.1 will be amended as per Attachment A to provide this information.
i 1
0 i
i i
I i
[
I l
i
~
o Question 260.27 Identify the organization (s) responsible for the review and concurrence of those procedures relating to calibration.
Response to 260.27 FSAR Section 17.2.12.1 will be amended as per Attachment A to provide this information.
I I
r l
I I
)
--_..._.i.._-,.--_-.--, -.
,, _.. -..., - -.. ~ - _., -, -... -. _..... -, -
1 e
t i
ATTACHMENT A FSAR CHAPTER 17 REVISIONS
b TAB 17,2 9 E IU ASSURANCE DURING THE OPERATIONS PHASE I
t l
?
I l
l
s SB 1 & 2 FSAR 17.2 QUALITY ASSURANCE UURING THE OPERATIONS PHASE It is the policy of Public Service Company of New Hampshire to operate Seabrook Station in a manner that reflects an emphasis on quality and professionalism.
The Chief Executive Officer has issued the following statement which is published in the Operational Quality Assurance Program:
A fundamental commitment of Public Service Company of Mew Hampshire is to provide safe, reliable and economic energy services with a minimum effect on the environment. To implement this poli,cy, proper attention to the quality of work activities and materials which go into the design, construction, and operation of Seabrook Station is essential.
Control of quality is exercised through the Seabrook Station Operational Quality Assurance Program.
Adherence to the Program and its supporting administrative and opera-tional procedures and controls is mandatory for all personnel per-forming activities within the scope of the Program.
To this end, the Operational Quality Assurance Program described below presents the outline of assignments, actions, and procedures that will result in
~
compliance with this policy and the requirements of the Code of Federal Regulations Title 10, Part 50, Appendix B.
17.2.1 Organization 17.2.1.1 Program Responsibility The ultimate responsibility for operation, including maintenance, modification and refueling, of Seabrook Station rests with Public Service Company of New 7
Hampshire (PSNH). The Executive Vice President - Engineering and Production has been designated as the responsible corporate officer.
As such, he has the authority and responsibility to develop and implement the Operational Quality Assurance Program, hereinaf ter referred to as the Program or OQAP.
The Program, which is presented in this and the following sections, ie expressed as an outline of the assignments, actions and procedures that, taken together, will result in proper management and operation of activities at Seabrook Station.
l l
Through the established organization, verification of conformance to established l
quality requirements is implemented by individuals or groups not having direct responsibilities for the work being verified.
Those individuals performing the verifications and other quality related functions have direct access to manage-ment levels in the Production Division which assures the ability to:
o Identify quality problems o
Initiate, recommend, or provide solutions through designated channels o
Verify implementation of solutions 1
17.2-1
V SB 1 & 2 FSAR The Vice President - Production will mediate disputes arising within the OQAP.
Where disagreement persists, the matter may be oppealed to the Executive Vice President - Engineering and Production for final resolution.
17.2.1.2 Delegation of Authority and Assignment of Responsibility a.
The Executive Vice President - Engineering and Production, while retaining full responsibility and the overall authority, has dele-gated the necessary authority and has assigned responsibility for management of the Program to the Vice President - Production and, through him, to the Nuclear Quality Manager (NQ Mgr.).
b.
Various services and support activities required for operational sup-port have been contracrad from the Nuclear Services Division (YNSD) of Yankee Atomic Electric Company (YAEC). YNSD has been assigned specific authority and responsibility to perform these contracted functions.
YNSD remains independent of PSNH but reports to and is responsible to the PSNH Executive Vice President - Engineering and Production.
I The scope of work and functional responsibilities for YNSD are generically defined in a formal agreement between YNSD and PSNH.
In exercising ultimate responsibility for the above contract, PSNH:
1.
Requires the submittal and approval of generic program documents prior to use to assure conformance with the commitments of the Program, FSAR and Technical Specifications.
2.
Performs audits of selected activities on a preestablished sche-dule to evaluate YNSD performance.
Results are reported to PSNH senior management.
3.
Performs an annual independent evaluation of YNSD services using audit reports, trend data, follow reports, and disposition of unsatisf actory items.
4.
Assigns a responsible, organizational element to assure the quality of YNSD work.
17.2.1.3 Organizational Structure a.
PSNH Organization The PSNH organizational structure discussed below is shown on Figure 17.2-1.
1.
Quality Assurance (QA)
QA is headed by the Nuclear Quality Manager (NQ Mgr.) who is responsible to the Vice President - Production for the conduct of l
17.2-2
9 SB 1 & 2 FSAR the Program. The NQ Mgr. has the authority, the staff and the resources to verify the implementation and to assess the results of the Program. Enough auditors and inspectors will be assigned to the Nuclear Quality staff to accomplish required functions of the quality assurance program. The NQ Mgr. directs and supervises quality activities such that he:
o Approves the Program and all changes to the Program.
o Maintains cognizance of, and open communications with, the Seabrook Station Compliance Manager and the YNSD QA Manager on all matters related to the implementation of the Program.
Directs the Seabrook Station Quality Assurance Supervisor for o
verification of on-site implementation of the OQAP.
o Develops a training program for quality assurance personnel, and provides for their certification when needed, Identifies quality problems and evaluates their extent and o
safety implications.
o Recommends, provides or initiates solutions to identified quality problems.
o Verifies implementation of approved solutions to such problems.
o Administers the audit program of site, YNSD, and Nuclear Production staff functions.
o Evaluates and reports the effectiveness of the Program trends in quality performance, o
Refers to the Vice President - Production for mediation of cases where he is unable to establish mutual agreement with, or between, other organizations involved in the implemen-tation of the Program.
The NQ Mgr. meets or exceeds the minimum qualification require-ments of Regulatory Guide 1.8 " Personnel Selection and Training" as clarified in Appendix 17A.
l (a) Quality Assurance Supervisor The Quality Assurance Supervisor reports directly to the l NQ Mgr. and receives from him normal corporate guidance, management and all professional and technical direction g
and training. The Quality Assurance Supervisor and his I
staff provide on site management of the OQAP.
17.2-3
SB 1 & 2 FSAR The Quality Assurance Supervisor also receives Station l
priorities from the Compliance Manager who coordinates the quality activities with other on site organizations.
l The Quality Assurance Supervisor reports his findings I
and accomplishments to the NQ Mgr. as well as the Station Manager via the Compliance Manager.
The Quality Assurance Supervisor or his representative is a member of the Station Operating Review Committee, is on distribution for pertinent meeting notices, correspondence, and information, and will attend any meeting which appears appropriate.
The Quality Assurance Supervisor and his staff embody the necessary technical and professional qualifications and expertise and are responsible to:
(1) Assist the Training Manager in providing basic and advanced general QA Training for Station personnel.
(2) Certify selected Station personnel in the specific QA and QC practices and techniques required to review, inspect and assure quality and the quality control of Station operations, maintenance and other activities within the scope of the Program, i
(3) Monitor and review the conduct of quality control acti-vities and the performance of Station inspectors.
(4) Perform NDE or QC inspection functions when special skills or techniques are required or when requested by Station supervision.
(5) Review and audit to assure that contractors or service l
agencies performing on-site work within the scope of the OQAP employ approved procedures which meet the appli-cable quality requirements.
(6) Provide NDE or QC inspection processes or guidance to be written into Station operations or maintenance procedures.
(7) Exercise stop-work authority.
2.
Nuclear Production (NP)
NP is headed by the Nucle r Production Superintendent (NP Supt.)
who is responsible to the Vice President - Production for manage-ment and control of the operation of Seabrook Station and imple-mentation of the Program. This organization has four elements.
Two of the elements, Operational Support and Engineering, are located in the corporate offices with the NP Supt. Seabrook 17.2-4 t
SB 1 & 2 FSAR Station and the Training Center, the other two elements that complete the Nuclear Production organization, are located on-site. The compoaition snd lanctions of these four sections are presented below.
(a) NP - Operations Support Group (NP-OS) is headed by the Nuclear Production Operations Support Manager (NP-OS Mgr. )
who is responsible to the NP Supt. for the activities of this section in support of the Program by performing the following tasks:
(1) Provides support to the Station in refueling, main-tenance, non-licensed training, and operations.
(2) Coordinates interfaces between Station and YNSD opera-tion personnel.
(3) Maintains cognizance of operational support activities assigned to YNSD.
j (4) Reviews and recommends action on industry operating problems which may affect Station operations.
(b) NP Engineering Group (NP-E) is headed by the Nuclear Production Engineering Manager (NP-E Mgr. ) who is responsible to the NP' Supt. for the activities of this section in support of the Program by perfonning the following tasks:
(1)
Performs independent review of selected Station engi-neering activities and other engineering and licensing tasks assigned to YNSD.
l (2) Coordinates the implementation of design changes and backfit projects originated by others.
(3) Coordinated interface between Station and YNSD engi-neering personnel.
(4) Maintains cognizance of engineering support activities assigned to YNSD.
(c) Training Center (TC) is headed by the Training Center Manager (TC Mgr.) who reports directly to the NP Supt. and is respon-sible to him for the activities of the TC in support of the program by performing the following tasks:
(1) Directs the development of licensed training program used to prepare Seabrook Station personnel for the Nuclear Regulatory Commission (NRC) operator license and requalification examinations.
17.2-5
SB 1 & 2 FSAR (2) Ensures that NRC requirements necessary for simulator and instructor certification are satisfied.
(3) Ensures that the simulator and licensed training program remain current with applicable regulations and changes to Station design or operational procedures.
(4) Evaluates the performance and capabilities of each license cpplicant. Reports to the NP Supt. and to the Station Manager their readiness to be examined by NRC.
(5) Coordinates with the Station Manager the availability of personnel for initial license training and requalifica-tion courses and programs.
(d) Seabrook Station is headed by the Station Manger who reports directly to the NP-Supt, and is responsible to him for the operation and administration of Seabrook Station. To carry out his assignment the Statica Manager has the staff and organization shown in Figure ?.7.2-2.
The various parts of this organization implement ttair assigned aspects of the Program as follows:
(1) Station Manager and Assistant Station Manager a) Overall responsibility for implementation of the Program at Seabrook Station.
l b) Are Chairman and Vice Chariman, respectively, of the Station Operations Review Committee (SORC).
l l
(2) Compliance Manager l
l The Compliance Manager reports directly to the Station Manger and is responsible to him to:
a) Conduct surveillance of Seabrook Station activities, particularly those within the scope of the Program, bt t independent of the formal review functions per-fonned by the QA organization.
b) Maintain cognizance of, and open communication with, the PSNH and YNSD quality assurance managers on all matters related to the implementation of the l
Program.
l c) Coordinate schedules and interaction of internal and l
external audit, inspection and review activities.
d) Coordinate the interdepartmental resolution of 17.2-6
0
~
SB 1 & 2 FSAR Station discrepancies found during the performance of internal and external audit, inspection and review activities, and verify the implementation of approved corrective action.
e) Define Station priorities for reviews conducted by the Quality Assurance Supervisor and his staff and l
coordinate their on-site activities. Receive reports of their findings and accomplishments for distribution to Station Manager and others as appropriate.
(3) The Administrative Services Manager reports directly to the Station Manager and is responsible to:
a) Maintain a staff of administrative, security, fire protection, safety and first aid personnel who are trained and qualified to perform the duties required to implement the-Program.
b) Administer and monitor performance of Station security services.
c) Coordinate all Station drills related to security, fire protection and safety.
d) Supervise the procurement, receipt, handling, storage, issue and records associated with material and services that are encompassed by the Program.
(4) The Training Manager reports directly to the Assistant Station Manager and, through him, to the Station Manager and is responsible to:
a) Develop and maintain, for nonlicensed training, the program needed to train Station personnel in their assigned tasks and functions.
b) Conduct non-licensed training for each designated person of the Station staff, evaluate the perfor-mance and capabilities of each person and report their readiness to be assigned administrative or operational responsibilities.
l c) Coordinate, with the Department Supervisors, the selection and timing of personnel to be assigned to the initial training and retraining courses.
(5) The Technical Services Manager reports directly to the Assistant S tation Manager and, through him, to the 17.2-7
SB 1 & 2 FSAR Station Manager and is responsible to:
a) Perform the support functions that include chemistry sampling and analysis; radiation monitoring and health physics controls and exposure records; reac-tor engineering; quality engineering; computer operation and engineering; and general engineering services. Also included are the preventive main-tenance program, corrective maintenance program, Station modification and repair actions, the quality control monitoring of selected activities and quality assurance functions, b) Prepare the required procedures for performance of the above functions including technical and quality requirements.
Schedule tha performance of work, its technical and quality inspection and control of the material, per'sonnel and processes involved.
c) Review, monitor and coordinate Station activities related to regulatory inspections, NRC correspon-dence and other regulatory requirements and guidance.
d) Direct actions, within the realm of the Technical l
Services Department, to fulfill surveillance testing program requirements.
(6) The Operations Manager reports directly to the Assistant S tation Manager and, through him, to the Station Manager and is responsible to:
a) Operate all equipment at the Station in compliance with Technical Specification and other license requirements.
l b) Assist in the training of operations personnel to assure qualified employees for each task.
c) Prepare, review, approve and implement the operating procedures to be used for Station operations.
d) Direct actions, within the realm of the Operations Department, to perform the balance of the sur-veillance testing program required by Station license.
l b.
Yankee Atomic Electric Company - Nuclear Services Division (YNSD) l 1.
Organization I
17.2-8 i
l
o SB 1 & 2 FSAR The YNSD organization, and its interface with PSNH to accomplish support activities, is shown in Figure 13.1-2 The YNSD Vice President reports to and is responsible to the PSNH Executive Vice President-Engineering and Production, for all tasks per-formed by YNSD.
The YNSD organization consists of a variety of disciplines. The two that provide the direct interface with PSNH are the Quality Assurance Department and the Projects Department. The Projects Department draws upon the other YNSD technical disciplines to furnish the specific support services as they are needed.
2.
Responsibilities YNSD responsibilities in support of Seabrook Station are:
(a) Quality Assurance Department (1) Assure that YNSD activities comply with requirements of the OQAP.
(2) Provide, when requested by the NQ Mgr., evaulation, inspection and/or surveillance of vendor and contractor services for the Station. This includes evaluation of QA programs and procedures, the examination of vendors selected to fabricate or furnish material, equipment and services and maintenance of an updated list of such approved vendors.
(3) Provide the YNSD interface with Seabrook Station and PSNH QA personnel.
(b) Projects Department Draw upon the varied technical expertise within the YNSD, and i
coordinate activities in support of Seabrook.
(c) Technical Discipline Departments-Provide the Technical expertise required by the Projects Department in the areas of Operations, Plant Engineering, Licensing, Environmental Engineering, Fuel Cycle and Nuclear Engineering.
c.
Nuclear Safety Audit and Review Committee (NSARC)
NSARC is an executive body that is responsible for maintaining a cri-tical examination of Station activities, including Station operation, evaluation of procedures, investigations of abnormal conditions, and functioning of the OQAP. Technical Specifications define the respon-17.2-9
v SB 1 & 2 FSAR sibilities and authority of NSARC. A written charter, approved by the Executive Vice President - Engineering and Production designates the membership, authority and rules for conduct of activities.
d.
Station Operating Review Committee (SORC)
SORC is an advisory group composed of Station management and super-visory personnel, constituted for the purpose of reviewing current activities and determining the effect on operational safety.
SORC recommends to the Station Manager approval or disapproval of propo-sals considered by the Committee. Technical Specifications define the responsibilities and authority of SORC. A written charter, approved by the Nuclear Production Superintendent, designates mem-bership, authority and rules for conduct of activities.
e.
PSN11 Purchasing Division The PSNH Purchasing Division is headed by the Purchasing Director who reports to the Vice President - Employee Relations and Purchasing and, in turn, to the Executive Vice President - Operations and Services, as shown on Figure 17.2-1.
The Purchasing Division is mini-l mally involved in the implementation of the Program, since all ser-vices concerned with the aspects of procurement of materials and services that are within the scope of the Program are physically per-formed at Seabrook Station, and are under the administrative direc-tion and control of, the Administrative Services Manager and other personnel at Seabrook Station.
Specific functions and respon-sibilities of the Director of Purchasing where his duties interface with Station functions, are:
1.
Issue PSNH Purchase Orders in response to Material Purchase Requests that are generated and approved at Seabrook Station.
l 2.
Maintain current the commercial status of Purchase Orders.
17.2.1.4 Authority to Stop Work The NQ Mgr., the Quality Assurance Supervisor, and the Compliance l
Manager and their specified designated alternates have the respon-sibility and written authority to stop work or other activities that are not in compliance with the Program, which are observed in the operation, management or administration of the Seabrook Station or
[
any of its supporting organizations. Supporting organizations will l
exercise stop work through the managers specified above.
I l
17.2.1.5 Responsibility to Report r
Included in the corporate policy, and an essential part of this program, is the responsibility of all Seabrook Station, YNSD, Training Center and Nuclear Production Staff personnel working _ within the scope of this Program, to document and report to their supervisor any equipment, work or other activity that is not 1
I i
17.2-10
v SB 1 & 2 FSAR in compliance with this Program.
Should the circumstances warrant such action, particularly when a substantial safety hazard or when the public health and safety is involved, the situation is to be further reported to the Quality Assurance Supervisor, the Compliance Manager or to the NQ Manager, or to other l
increasingly higher levels of Seabrook Station or PSNil Management until appropriate action is observed to be undertaken.
17.2.2 Quality Assurance Program 17.2.2.1 Outline The commitments outlined in each section form the basis for preparation of docu-mented procedures, instructions and other administrative controls. These docu-mented controls assure that activities impo,Lant to safety at Seabrook are addressed and controlled to the extent necessary. They are implemented prior to the start of the activity and at least 90 days prior to fuel loading.
To assure the ef f ectiveness of the OQAP, the commitments of each section and their imple-menting controls are audited as described in Subsection 17.2.18.
Procedures af fecting quality, required to implement the QA program, are reviewed by a representative of the Nuclear Quality Manager to assure that they are consistent with QA program commitments and corporate policies. These procedures are published, documented, controlled, and made mandatory by a responsible manage-ment official.
Each section of the OQAP focuses on the Seabrook Staf f activities, however, where a major portion of an activity is performed by a group other than the Seabrook Staff, the group or organization is identified and discussed.
17.2.2.2 Scope a.
Structures, Systems and Components The OQAP applies to the structures, systems, components, related con-sumables, and service activities associated with any item noted in Table 3.2-1 and safety class 1, 2, and 3 fluid systems and components listed on Table 3.2-2.
The responsibility, authority and methods for proposing and approving changes to these tables are described in procedures. Applicable portions of the OQAP applies to lubricants, resins, chemicals, f uel oil, and other items.
b.
Fire Protection Systems Certain aspects of the OQAP apply to the fire protection system in order to meet the guidelines of the NRC Branch Technical Position (BTP) APCSB 9.5-1, Appendix A.
Those aspects include:
1.
Design control and procurement document control 2.
Instructions, procedures and drawings 3.
Control of purchased material, equipment and services 17.2-11
Inspection 5.
Test and test control 6.
Inspection, test and operating status 7.
Nonconforming items 8.
Corrective action 9.
Records 10.
Audits The extent of application and detail of implementation of the above are noted in the report Seabrook Station Fire Protection System Evaluation and Comparison to BTP APCSB 9.5-1, Appendix A.
c.
Activities Activities affecting designated structures, system and components are subject to the applicable controls of the OQAP.
If these activities require special equipment, controlled environmental conditions, skills or processes, they are provided and controlled.
17.2.2.3 Program Implementation It is recognized that the degree of quality assurance and Program applicability varies with different systems activities.
l The degree to which the requirements of the Program and its implementing proce-dures are applied are based upon the following:
The importance to safety of a malfunction or failure of an item or o
activity.
The design and fabrication complexity or uniqueness of the item.
o The need for special controls and surveillance or monitoring of pro-o cesses, equipment and operational activities.
The degree to which functional compliance can be demonstrated by o
inspection or test.
The quality history and degree of standardization of the item or o
activity.
A three-level approach is defined to assure program implementation to the degree necessary.
17.2-12
y _.-
Level 1 - This level includes independent inspections, checks and tests performed during routine and non routine activities by appropriately trained personnel on the Station Staff.
l s
b.
Level 2 - This level includes surveillance and monitoring activities that are performed by the Quality Assurance Supervisor and l
l his staff. Such activities include observation of tests and inspections, observation of significant operations,
~
j review of records and verification of test reports.
i Records of the surveillance and monitoring activities are maintained as permanent records.
I c.
Level 3 - This level includes a comprehensive audit and evaluation program initiated by the HQ Mgr. to assure proper func-l tioning of Levels 1 and 2.
The level includes measures l
performed by the QA Staff and YNSD-QAD personnel to verify that all activities required by the OQAP are established i
and satis fy regulatory requirements.
17.2.2.4 Program Standards PSNH maintains a working knowledge of applicable industry codes, standards, federal regulation and guides. The OQAP complies with the intent of the following referenef@s and the regulatory position of the Regulatory Guides l
a..
10CFR 15 art 50,AppendixA-GeneralDesignCriteriaForNuclear l'
Power Plants.
I j
b.
10 CFR, Part 50, Appendix B - Quality' Assurance Criteria For Nuclear l
Power Plants and Fuel Reprocessing Plants.
c.
10 CFR, Part 50.55a - Codes and Standards.
d.
10 CFR, Part 50.59 - Codes, Tests and Experiments.
f e.
10 CFR, Part 71, Appendix E - Quality Assurance Criteria For Shipping Packages For Radioactive Material.
f.
Regulatory Guide 1.8, May 1977, Personnel Selection and Training (endorses ANSI-N18.1-1971) g.
Regulatory Guide 1.26, Rev 3, February,1976, Quality Group
[
Classification, and Standards For Water, Steam, and Radioactive Waste i
Containing Components of Nuclear Power Plants.
i h.
Regulatory Guide 1.29, Rev. 3, September 1978, Seismic Design l
Classification.
f i
17.2-13 I
= - -
Regulatory Guide 1. 30, Augus t, 1972, Quality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Elec trical Equipment, (endorses ANSI-N 45.2.4-1972) j.
Regulatory Guide 1.33, February 1978, Quality Assurance Program l
Requirements (Operation), (endorses ANSI-N18.7-1976/ANS-3.2) k.
Regulatory Guide 1.37, March 1973, Quality Assurance Requirements for l
Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants, (endors es ANS I-N45. 2.1-1973) 1.
Regulatory Guide 1.38, May 1977, Quality Assurance Requirements for l
Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants, (endorses ANS I-N45. 2. 2-1972) m.
Regulatory Guide 1.39, September 1977, Housekeeping Requirements for Water-Cooled Nuclear Power Plants, (endors es ANS I-N45. 2. 3-1973) n.
Regulatory Guide 1.58, September 1980, Qualification of Nuclear l
Power Plant Inspection, Examination and Testing Personnel, (endorses ANS I-N4 5. 2. 6-1978) o.
Regulatory Guide 1.64, June 1976, Quality Assurance Requirements for l
the Design of Nuclear Power Plants, (endors es ANS I-N45. 2.11-1974) p.
Regulatory Guide 1.74, February 1974, Quality Assurance Terms and l
Definitions, (endorses ANSI-N45. 2.10-1973) q.
Regulatory Guide 1.88, October 1976, Collection, Storage and l
Maintenance of Nuclear Power Plant Quality Assurance Records, (endors es ANS I-N45. 2.9-1974) r.
Regulatory Guide 1.94, April 1976, Quality Assurance Requirements for l
Installation, Inspection, and Testing of Structural Concrete and S truc tural Steel During the Construc tion Phase of Nuclear Power Plants, (endors es ANS I-N45. 2. 5-1974) s.
Regulatory Guide 1.116, May 1977, Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems, (endorses ANSI-N45. 2.8-1975) t.
Regulatory Guide 1.123, July 1977, Quality Assurance Requirements for l
Control of Procurement of Items and Services for Nuclear Power Plants, (endors es ANS I-N45. 2.13-1976) u.
Regulatory Guide 1.144, September 1980, Auditing of Quality Assurance l'
Programs for Nuclear Power Plants, (endorses ANS I-N45. 2.12-1977) v.
Regulatory Guide 1.146, Augus t 1980, Qualification of Quality l
Assurance Program Audit Personnel for Nuclear Power Plants, (endors es ANS I-N45. 2. 23-1978) 17.2-14
SB 1 & 2 FSAR Branch Technical Position (BTP) APCSB 9.5.1, Appendix A.
l w.
The Technical Specifications shall be the governing document in case of conflicts between the Technical Specifications and the above references.
Exceptions, alternatives and clarifications to the regulatory guides and their referenced standards are included in Appendix 17A.
17.2.2.5 Program Revision The NQ Mgr. is res ponsible to maintain the OQAP current. All proposed changes, whether reflecting editorial comments or major program policy revisions, are forwarded to the NQ Manager for approval and control.
Procedural controls exist to assure that prior to making any change to this OQAP, a written evaluation shall be prepared to identify the change, the reason it is needed, and the basis for concluding that the change results in an OQAP that continues to meet the criteria of Appendix B of 10 CFR 50.
For changes that, (1) affect the ainthority, independence or management reporting levels pre-viously established for organizations or persons perfonning QA functions or (2) affect the controls previously established over activities within the scope of the OQAP, the evaulation described above shall be subnitted to NRC within 30 days of making such changes.
17.2.2.6 P rocedures a.
PSNH To implement the quality assurance policies identified in the OQAP, and to assure compliance with the 10 CFR 50 Appendix B criteria, pro-cedures are prepared, reviewed, and approved in accordance with OCKP re qui rements.
Qualified individuals in the Nuclear Quality Staff either onsite or offsite will be responsible for performing reviews and concurring in documents aff ecting quality and safety, including changes thereto, prior to implementation of documents. A matrix in Appendix 17B reflects the individual criteria met by documented pro-cedures.
l l
b.
YNSD i
The NQ Mgr. reviews procedures for YNSD activities within the scope of the OQAP to assure that the documented controls are in effect and adequate to meet the requirmnents identified in the O(BP.
I c.
On-Site Contrac tors The Quality Assurance Supervisor approves procedures which are used for on-site work activities by contractors and service agencies.
i l
17.2-15
2 SB 1 & 2 FSAR 17.2.2.7 Management Evaluation In addition to any major quality problens, which are immediately a.
brought to the attention of upper management, the NQ Mgr. conducts quarterly meetings which give upper management an ongoing cognizance of the implementation and adequacy of the OCWP. The meetings address areas of audit and inspection results, quality trends, significant problems and interactions with the regulatory agencies. These quar-terly meetings provide upper management with the necessary awareness and involvement in the OQAP.
b.
The Executive Vice President - Engineering and Production assigns NSARC to perform at least an annual assessment. This provides upper management an impartial view of unplementation of, and compliance with, the OQAP. NSARC identifies and tracks any corrective action requi red.
17.2.2.8 Indoctrination and Training PSNH has two separate training programs, non-licensed and licensed. The non-licensed training program consists of introductory training and specialized training.
The introductory training segment instructs new or transf erred employees who may perform quality related activities as to the purpose, scope and method of imple-mentation of quality-related manuals, instructions and procedures. This segment also describes the company organization, interface with regulatory bodies and other topics pertinent to the employees job description. Specialized training in areas of ins pection, test, audi ting, etc. leads to certification or qualifi-cation of individuals. This training is initiated as early as practical to meet OQAP objectives. For the formal training programs documentation includes the o bj ective, content of the program, attendees, and dates of attendance.
Proficiency tests are given to those personnel performing and verifying activi-ties affecting quality, and acceptance criteria are developed to determine if individu als are properly trained and qualified. Proficiency of personnel per-fonning and verifying activities affecting quality is maintained by retraining, reexamining, or recertifying.
The licensed training program, discussed in Subsection 17.2.1. 3.a. 2(c ), assures that appropriately trained and licensed individuals are available to operate Seabrook Station.
17.2.3 Design Control 17.2.3.1 Scope Design control is exercised on design activities related to scructures, sys tems and components listed in Table 3.2-1 and Table 3.2-2. Design control is applied l
to activities such as field engineering; core physics, sei smic, stress, thermal, 17.2-16
u SB 1 & 2 FSAR hydraulic, and accident analyses; associated computer programs; compatibility of materials; accessibility for inservice inspection, maintenance and repair, and the inspection criteria for tests and inspections.
17.2.3.2 Design Document Preparation, Review and Approval The preparation, review and approval of design documents such as design cri-teria, design drawings, computer prograus, specifications, and procedures require the interface of PSnd, YNSD, and vendots/ contractors. Procedures are established which include requirements for a documented cheek to verify the dimensional accuracy and completeness of design drawings and specifications.
The organizational elements involved with the design document preparation, review and approval are the Engineering Services Department of the Seabrook Staf f, the NP-Engineering section, Nuclear Quality Staff, and YNSD engineering.
The interface between organizations is procedurally defined to assure proper control and to maintain design activity awareness of those activities of review, approval, release and distribution of the documents. The Nuclear Quality Staff reviews design documents to assure that the documents are prepared, reviewed, and approved in accordance with applicable procedures, and quality assurance requirements.
Criteria and methods used by vendors / contractors which may affect the design of Seabrook are evaluated and approved prior to use.
17.2.3.3 Design Verification The assigned lead design group or organization (i.e., PSNH, YNSD, supplier, architect engineer) assures that the designs and materials are suitable and that they comply with the design criteria, quality standards and regulatory require-ments.
Design verification is performed by individuals other than those who performed the original design. The extent of design verification is determined by the complexity of the system, the safety function to be performed and the applicability of regulatory requirements, codes, standards, FSAR commitments and QA requirements. The lead design group or organization identifies the method of verification:
1.e., design review, alternative calculation or test.
If testing is chosen, the most adverse design conditions are stipulated and demonstrated.
Procedures provide criteria for determining when verification may be by testing.
Prototype, component, or feature testing will be performed as early as possible prior to installation, but will always be performed before the component, system, or structure is relied upon to perform its safety function.
Procedures which control the design verification activities include internal and external interf aces, the timing and documentation of reviews, and the respon-sibilities and methods used by the verifier.
For computer programs, verifica-tion activities include the certification and specification of use.
Procedures assure that design verification, if other than by qualification testing of a prototype or lead production unit, is completed prior to release for procure-ment, modification, or to another organization for use in other design activi-ties.
In those cases where this timing cannot be met, the design verification 17.2-17
y SB 1 & 2 FSAR may be deferred.
The design verification must be complete prior to relying upon the component, system, or structure to perform its function.
Procedural control is established for design documents that reflect the commit-ments of the FSAR; this control differentiates between documents that receive formal design verification by interdisciplinary or multi-organizational teams and those which can he reviewed by a single individual (a signature and date is acceptable documentation for personnel certification).
Design documents subject to procedural control include, but are not limited to, specifications, calcula-tions, computer programs, FSAR when used as a design document, and drawings including flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single line diagrams, structural systems for major facilities, site arrangements, and equipment locations.
Specialized reviews will be used when uniqueness or special design considerations warrant.
Procedures specify the responsibilities of the verifier, the areas and features to be verified, the pertinent considerations to be verified, and the extent of documentation.
17.2.3.4 Design Changes All changes to the design of Seabrook Station require the same design control measures that were applicable to the original design. YNSD Engineering reviews and approves changes to the design, unless approval responsibility is specifi-cally delegated to another organization.
SORC will review modifications, which are important to safety, and related changes in Station procedures resulting f rom design changes to assure that chere are no unreviewed safety questions.
Design changes normally affect a wide range of design documents which must be reconciled. Administrative procedures ensure that the responsible Station per-sonnel are aware of the changes which may affect their duties.
Station design changes and related changes to station procedures are controlled and incor-porated in the licensed training program.
17.2.3.5 Deviations Procedures exist to document and control deviations from approved design docu-ments, including design standards that could adversely affect structures, systems and components. Also included, is the control of deviations from spe-cified quality standards.
In the case of errors or deficiencies, action is taken to determine the cause and to initiate appropriate changes based on the significance or recurrence of the error / deficiency. Errors / deficiencies may be revealed by verification measures, use of the document, audit, tests, actual failure, or other means.
17.2.4 Procurement Document Control 17.2.4.1 Procurement Planning The Seabrook Staff is the organizational element responsible for procurement activities.
In this effort, they identify tasks and assign responsibilities to execute an integrated procurement plan.
17.2-18
6 SB 1 & 2 FSAR 17.2.4.2 Procurement Document Preparation and Review The Seabrook Staff has the primary responsibility for preparation and review of procurement initiating documents e.g., Material Purchase Request (MPR).
The content is procedurally defined and includes as appropriate:
a.
Scope of Procurement b.
Technical Requirements c.
Quality Assurance Requirements d.
Documentation Requirements e.
Rights of Access Provisions f.
Nonconformance Reporting Provisions g.
Administrative and reporting requirements.
h.
Required drawings 1.
Required specifications J.
Required codes and industrial standards k.
Test and inspection requirements 1.
Special process instructions Procurement documents receive a technical and a quality review.
The technical l
l review, based on written guidelines, assures that appropriate technical, regula-tory and special requirements equal to or better than the original requirements, or as required to preclude repetition of defects, are included and properly identified.
The quality review is performed by personnel qualified in quality assurance practices to assure the quality requirements are properly specified.
The criteria for proper specification is documented and includes:
i a.
Quality requirements - correctly stated, inspectable and controllable.
b.
Acceptance and/or rejection criteria.
c.
Preparation, review and approval of the procurement document meets the OQAP requirements.
For commercial "off-the-shelf" items where specific quality assurance controls appcopriate for nuclear applications cannot be imposed in a practicable manner, special quality verification requirements will be established to provide the necessary assurance of an acceptable item.
17.2-19
4 SB 1 & 2 FSAR Upon completion of the Seabrook Staff and Quality Assurance activities, Purchasing Division transcribes the MPR infonnation on a PSNH purchase order l
the (P.O.).
The Purchasing Division cannot waive or change any noncommer'ial c
requirements of a procurement document without proper authorization from the Seabrook Staff. Copies of the MPR and executed P.O. are maintained at Seabrook station as quality records and for subsequent receipt ins pection functions.
During the procurement document preparation and review cycle, any changes or revisions to documents are subject to the same review and approval requirements as the original documents.
For procurement of spare parts, changes which affect design bases, saf ety evaluation, regulatory conformance, functional design, structural integrity and testing requirements require technical assessment and documented approval.
17.2.4.3 Selection of Procurement Sources The Nuclear Qual #.ty Manager is res ponsible to generate and maintain an Approved Vendors List (AVL) which identifies those vendors and consultants able to meet PSNH quality assurance and technical requirements for a given scope of work.
Each AVL ovaluation is based on one or more of the following:
Historical data re presentative of current ca pabili ty.
a.
b.
Status of the vendor's current quality program - review of proce-dures, QA manual, audits, etc.
Review of objective evidence which demonstrates implementation of c.
their QA Program.
All evaluations are documented and provide objective evidence of the approval i
basis.
If an LCVIP letter of confirmation, the " CASE" Register, or other means are used to establish the qualifications of the supplier, the documentation will identify the means used.
The Seabrook Staff and the Purchasing Division maintain a current copy of the AVL for procurement source infonnation.
Seabrook Staff personnel may delete or request addition of vendors as experience dictates.-
17.2.4.4 Bid Evaluation and Award Bid evaluations are perfonned by the requisitioning organization to assure that the bids received conform to the procurement document requirements.
Appropriately trained personnel in the technical and quality disciplines are used as needed to complete the evaulation consisting of, as applicable:
a.
Technical considerations.
b.
Quality Assurance requirements.
17.2-20
Supplier capability and performance record.
c.
d.
Alternatives / exceptions to the procurement document requirements.
Any unacceptable conditions resulting f rom the bid evaulation are resolved or an appropriate consibnent is obtained from the vendor prior to contract award.
17.2.4.5 Surveillance, Inspection and Audit During the Seabrook Staff quality review, the scope of vendor verification acti-vities is detenmined. This determination is based on the complexity, relative importance to safety, quantity of the item and supplier quality perfonnance and results in an, assignment of activities for which source and site surveillance, inspection or audit is deemed necessary. The source surveillance, ins pection and audit functions are perfonned by YNSD-QAD upon written notification fram the Seabrook Staf f or the NQ Mgr. Documented results of the surveillance activities are forwarded to Seabrook for evaluation, tracking and record-keeping.
Receiving inspection activities are performed by the Seabrook Staff using writ-ten check lists.
17.2.4.6 Acc ep tanc e The method used to accept an item is dependent on the scope of purchase and includes one or more of the following:
i a.
Source verification b.
Receiving Inspection Supplier Certificate of Conformance c.
d.
Post Installation Test I
The method chosen for the acceptance of each item or service is based on proce-dural guidelines and included in the procurement documents.
17.2.5 Instructions, Procedures and Drawings 17.2.5.1 PSNH PSNH controls and performs all activities, such as design, procurement and 3
o peration, through a series of instructions, procedures, drawings and other
]
documents which define the methods for complying with the eighteen criteria of 10CFR50 Appendix B and the guidelines of Regulatory Guid= 1.33.
The NP Supt. and the HQ Mgr. are responsible for the preparation of procedures which describe the systems and methods for accomplishing the various activities, and define the NP departmental relationships in a manner that assures compliance to the quality requirements delineated in the OQAP. Each NP Section Mgr. and 2~
the HQ Mgr. is responsible f or preparing procedures consistent with PSNH quality phil os ophy, this OQAP, and their assigned work activities.
1 17.2-21
.m r
e-,
u.-.
a
-r
,.,--e-m--
~
..w-r-n-a w.-<
- ~, --, --
e SB 1 & 2 FSAR The Seabrook Station departments prepare and maintain procedures for administra-tive control and technical support of the safe and efficient operation of the S tation. These procedures establish the system for off-site interf aces, conduct of operations and operating status. Procedures are established for the prepara-tion of as-built drawings and related documentation in a timely manner which will accurately reflect the actual plant design. The procedures provide instructions for performing activities in areas of Station administration, o per ations, refueling, maintenance, and other specialized technical support functions.
The Training Center Manager prepares and maintains procedures necessary to pro-vide instructions to administer and document the licensed training program and keep abreast of design changes which impact the use of the simulator.
The Purchasing Division provides instructions for accomplishing routine activi-ties within the division which define the interfaces with other PSNH departments that initiate procurement or contract documents.
All instructions, procedures and drawings contain applicable quantitative and qualitative acceptance criteria, as warranted, to enable determination of satis-factory accomplishment. System procedures contain checklists or reference docu-ments that contain checklists.
17.2.5.2 YNSD YNSD performs various support services for PSNH such as auditing, vendor or contractor evaluation, licensing and engineering. All such activities are prescribed by documents appropriate to the circumstances and internally reviewed to assure the inclusion of qualitative and quantitative requirements. The NQ Department maintains cognizance of the YNSD procedural implementation through audit and surveillance.
17.2.5.3 contrac tors / vendors Prior to perfmorning work or inspection on safety related structures, sys tems and components, contractors / vendors (except those which work as an integral part of PSNH) are required to develop and submit for approval procedures which define the scope and implementation of the task. The procedures reference applicable drawings, specifications, codes and standards, and include appropriate accep-tance criteria. The contractors / vendors are required to perform all work in accordance with the approved documents which also form a basis for monitoring and control of the activities assigned.
17.2.6 Document Control 17.2.6.1 Sc ope The PSNH document control program applies to the issuance and control of docu-ments which affect the quality of structures, sys tems and components. The controlled documents incl ude, but are not limited to the following:
17.2-22
~
Operational Quality Assurance Program.
a..
b.
Procurement documents and specifications.
Design documents. and drawings.
c.
d.
Administrative and operating procedures.
e.
Nonconformance reports f.
FSAR and Technical Specifications.
17.2.6.2 Issuance The review, approval and subsequent issue of documents is prescribed in docu-mented procedures. The review and approval cycle includes the SORC for S tation documents to assure technical adequacy and inclusion of appropriate quality requirements prior to implementation. An individual, other than the person who generated the document, qualified in quality assurance practices concurs with the quality related aspects of the document. Review and approval of documents in other organizations or at other locations also follow prescribe 1 procedures.
The quality review of maintenance, modification and inspection procedures includes:
- 1) a determination of the need for inspection, 2) identification of inspection personnel, 3) identification of the inspection requirements, methods and acceptance criteria, and 4). documentation of ins pection results.
Where several offices or organizations must be included in the review and appro-val process, adequate time is considered to assure approval prior to imple7en-tation.
When comments are resolved, and the SORC recommends approval, the l
S tation Manager documents final approval for S tation issuance.- The issuance is controlled by document name, number, revision status and location,1when i
as si gned, by the Document Control Center (DCC).
Similar controls are implemented at other locations by those organizations which perform work using documents that pertain to Seabrook Station.
17.2.6.3 Control
' DCC maintains a system to identify and control the current revision of instruc-l tions, procedures, specifications, drawings and procurement documents. As new or revised documents are approved, DCC enters these into the sys tem.
The controlled distribution of new and revised documents is limited to those docu-ments which are required for standard activities. All other documents are issued on a request basis. This system assures that the most current revision of a document is available for use at the required locations. All procedures include prerequisites to verify the revision status of documents, where appli-cable, before use.
17.2.6.4 Changes 17.2-23
u SB 1 & 2 FSAR Procedu es exist to assure that changes to documents are reviewed and approved by the same organizations that performed the initial review and approval or by other qualified responsible organizations delegated by PSNH. In either case, the reviewing organizations have access to pertinent background information upon which to base their review, and have an adequate understanding of the require-ments and intent of the original document. This includes design and procurement document changes identified in other sections of the OQAP.
Documents that are made obsolete or are superseded as a result of changes are removed f rom the controlled distribution when replaced by the new revision. For those documents which are not on controlled distribution, the required verifica-tion of revision status prior to each use results in purging outdated documents f rom the work areas. Audits of document control assure the proper implemen-tation and control.
S tation procedures are reviewed by an individual knowledgeable in the procedure at least every two years to determine if changes are necessary or desirable.
Reviews are documented and are at least as rigorous as the initial procedure revi ew.
17.2.7 Control of Purchased Material, Equipment and Services 17.2.7.1 Planning The Seabrook Staff has the responsibility to implement appropriate measures to assure that purchasel material, equipment and services conform to procurement documents. Appropriate measures may include source evaluation and selection, j
source inspection, surveillance or audit, or receipt ins pection.
During the review of procurement documents, the staff, following written procedures and guidelines, identifies those characteristics and/or processes important to the quality of the item or service and specifies inspection, audit or surveillance activities commensurate with the procurement s co pe.
17.2.7.2 Source Ac tivities l
l Ins pe ction, surveillance and audit activities at the source are identified in j
accordance with the plan developed for procurement. These activities are nor-mally performed by YNSD-QAD personnel.
Qualified personnel perform the activi-ties using written procedures / checklists and fonnally report to the S tation S taf f on their quality findings, including problem areas of the procurement.
Personnel assigned these activities have the delegated authority to stop work if ne cess ar y.
The NQ S taff maintains cognizance of and audits the activities of l
YNSD to assure proper implementation of source activities.
17.2.7.3 Receipt Inspec tion Receipt inspection is supervised by the Administrative Services Department using pre-planned written procedures / checklists which define those characteristics to be ins pected. The ins pectors are qualified in accordance with ANSI N45.2.6 and l
are certified by the Nuclear Quality Staff.
Where sampling inspection is spe-l 17.2-24
v SB 1 & 2 FSAR cified, the plan is based on nationally recognized standards. The personnel verify that the items are undamaged, that they conform to procurement require-ments when not verified by source surveillance, ins pection or audit, and that the required documentation is available.
17.2.7.4 Documenta tion Documented evidence that the items meet procurement requirements, such as receiving inspection reports, physical and chemical test reports, and cer-tification of conformance, mus t be available at the Station prior to installa-tion or use of the items. Written guidelines are used by the receipt inspection personnel to evaluate and accept the subnitted documentation. Measures exist to periodically evaluate Certificates of Conformance to assure validity.
17.2.7.5 S tatu s The status of procurement action is maintained through reports and inspection at the source and upon receipt. The documentation submitted by YNSD-QAD or the s upplier, or that which was internally generated during the course of procure-ment and receipt identifies the requirements that have and have not been met.
For those items delivered which deviate from procurement requirements, a noncon-formance report is prepared for tracking and disposition. Tagging and/or physi-cal segregation where possible is used to identify the inspection status of individual items or orders prior to assignment to controlled storage facilities or use in the S tation.
17.2.8 Identification and Control of Materials, Parts and Components 17.2.8.1 Identification P rocurement documents contain appropriate requirements for identification of mat erial s, parts and components.
Compliance to the specific procurement requirements is the responsibility of the supplier. The Seabrook Staf f person-nel assure, if not already verified and documented during source verification l
activi ties, that identification of items meets the procurement requirements upon j
receipt.
Station procedures covering the identification of items are prepared by the Seabrook Staf f and approved by SORC.
Identification by physical means is maintained where possible and through documentation when not physically prac-tical.
Mat erial s, parts and components are traceable to appropriate documen-tation, such as procurement or inspection documents.
l 17.2.8.2 Control Subsequent to the receiving functions at the S tation, identification and control of items is maintained in accordance with technical and administrative proce-dures. At storeroom issue, an item is verified by the user for correct iden-tification, and acceptability.
During the various phases of f abrication, installation, repair or modification of items, in process surveillance may be performed by Station and contractor personnel to verify the continuity of iden-tification.
When an item is subdivided, traceability of the item, when 17.2-25 i
i I
s.
l re qui red, is controlled by transcribing infonnation to the subdivided pieces.
The identification markings are placed on the item or on records traceable to the item.
If required identification is missing, obliterated or hidden, the item is considered nonconforming and is tagged and, where practical, placed in a segregated area pending resolution.
I 17.2.9 Control of Special Processes 17.2.9.1 Process Qualification Welding, heat treatment, nondestructive testing, chemical cleaning, plating and other special processes, where the required level of quality cannot be, or is 4
disadvantageous to be, measured by direct visual inspection, require qualifica-ti on.
The Seabrook Staff has the responsibility to qualify special processes to assure subsequent accanplishment under controlled conditions in accordance with applicable codes, standards and specifications. Process qualification records are maintained and updated as required.
For special processes not covered by existing codes or standards, the qualification criteria is defined and documented.
Qualification includes allowable control parameters of the process variables, specified equipment and personnel proficiency which are documented in special process procedures, approved by SORC and reviewed by the Nuclear Quality i
Department. Special process procedures contain the necessary prerequisites, personnel and equipment requirements, qualification data, limitations, acce p-tance criteria, results interpretation and records, as applicable.
When special processes are performed onsite by vendors or subcontractors, review of their procedures by the Quality Assurance Supervisor is required to assure conformance j
to applicable specifications codes and standards.
17.2.9.2 Personnel Qualification Personnel responsible for the performance of special processes are qualified in l
accordance with applicable codes, standards and specifications. Training and examinations are administered to determine the capability of each individual.
l Qualifications records of on-site personnel associated with special processes are established, filed and kept current. The period of validity and criteria for requalification are in accordance with the applicable codes, specifications and standards.
17.2.9.3 Process Performance Special processes are accomplished using written process sheets, procedures, checklists, travelers or equivalent. These documents provide for recording of evidence to indicate acceptance in accordance with the process requirements.
Acceptance of the results is performed by personnel qualified for acceptance of the special process. Records which verify that the required activities were accomplished in accordance with qualified procedures by qualified personnel are maintained and filed.
j!
17.2-26
+-
y..
,m
,, -,,, -~,
SB 1 & 2 FSAR 17.2.10 Inspection Inspections associated with normal operations of the plant, such as routine maint enance, surveillance, and tests, are performed by individuals other than those who performed or directly supervised the work.
Ins pectors meet the requirements of ANSI-N45.2.6 and are certified by the Nuclear Quality Staf f prior to initiating inspections.
17.2.10.1 Station Equipment Surveillance Inspection The S tation Manager directs the preparation of a surveillance program. The program requires that surveillance be perfonned to assure that the station equipment operates in accordance with documented procedures, Technical Specifications, FSAR and OQAP requirements. The original and subsequent revi-sions of the surveillance program require review by SORC and approval of the S tation Manager.
I 17.2.10.2 Maintenance and Modification Inspection Maintenance, modification, repair or replacement activities are inspected in accordance with the original ins pection requirements or engineering approved alternatives. Documents which provide instructions for perfonning the activi-ties specify the inspection requirements.
Inspection points are designated in the procedures when deemed necessary to control the quality of the item.
17.2.10.3 Receipt Inspec tion The scope of this inspection activity is described in Subsection 17.2.7.3.
17.2.10.4 Inservice Inspec tion Base line data for Inservice Inspection (ISI) is collected during Station construction. This data is used as standards for periodic inspections of items to comply with Technical Specifications, ASFE Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components" and Station Procedures. The deve-lopment of the overall program for inspection is assigned to YNSD, while imple-mentation rests with the Seabrook Staff. Records of ISI activities are maint'ained and used for comparison with the results of subsequent ins pe ctions.
17.2.10.5 Contractor and vendor Inspections The Seabrook Staff assures that inspection requirements are included as necessary in procurement documents which apply to contractors on-site and to vendors at their facilities (including service agencies such as nondestructive examination (NDE) s pecialists. )
17.2.10.6 Qualification of Inspectors The organization (PSNH, suppliers) responsible for the work normally performs the ins pections. The personnel performing ins pections, including NDE, have the 17.2-27 i
l l
_~ -
SB 1 & 2 FSAR necessary qualifications and are independent of the immediate supervisor directly responsible for perfonning the work being inspected. Personnel requiring special training are trained cad qualified in accordance with the applicable documents covering the function. The training is accomplished and documented in accordance with station procedures or approved suppliers proce-dures. Reevaluation of personnel is performed at periodic intervals. The NQ Manager is responsible for the review of inspection procedures and inspector qualifications.
17.2.10.7 Inspection Documents Inspection procedures, instructions and checklists used by personnel performing ins pection functions include the following, as appropriate:
a.
Identification of characteristics to be ins pected.
b.
Description of the method of ins pection.
c.
Identification of individuals or groups responsible for performing the ins pection.
d.
Acceptance and rejection criteria.
e.
Identification of hold and witness points.
f.
Requirements for indirect control by monitoring process methods, equipment and personnel, if direct inspection is not pos sibl e.
Both ins pection and process monitoring shall be provided when inadequate without both.
g.
Identification of the inspector or data recorder and the results of the ins pection operation.
h.
Specifying necessary measuring and test equipment, including accuracy requirements.
i.
Identification of required procedures, drivings and specifications, including revision status.
Sampling techniques, if used, are based on recognized standards, and jus tifica-tion is provided for sample size and selection process, 17.2.10.8 Results/ Records Inspection results are documented and traceable to the item ins pected. The res ponsible individual, or a group qualified in the inspection technique, eva-luates the acceptability of the results.
Inspection records are annotated with any deviations encountered and, if necessary, subsequent corrective action.
17.2.11 Test Control 1
17.2-28
SB 1 & 2 FSAR 17.2.11.1 Types of rests The Station Manager is responsible for the conduct of testing pertinent to the operation of Seabrook, such as:
Start-up Tests:
Precriticality tests,. criticality tests, low power tests, and power ascension tests performed af ter initial fuel loading and af ter each refueling.
NOTE:
During the preoperational phase, the Joint Test Group (JTG) supervises, reviews and approves proce-dures and practices of the preoperational testing activities. A member of the Seabrook Staff serves as a permanent member of the JTG. An alternate is appointed for each permanent member. The JTG exists until the start of initial fuel loading, at which time its function is replaced by SORC.
Surveillance Tests:
Periodic tests performed on Station systems and components to verify system and/or equipment operability requirements.
Maintenance or Modification Tests:
Tests performed on structures, systems and components by the Seabrook Staff or contractors af ter maintenance and modification to assure compliance to operating require-ments, codes and standards prior to returning the system to service.
17.2.11.2 Test Procedures Start-up, surveillance, maintenance and modifications test procedures are reviewed and approved by SORC and the Station Manager (see Note in Subsection 17.2.11.1).
In the case of contractor involvement, test procedures are sub-mitted for approval as required by procurement documents. Any proposed test or experiment which involves an unreviewed safety question, as defined in 10CFR50.59, is reviewed by SORC and NSARC.
Test procedures contain or provide the following, as required:
a.
Prerequisites, including enviro.nmental conditions and test instrumen-tation requirements.
f b.
Provision for assuring that test prerequisites have been met.
c.
Instructions for performing the test.
d.
Incorporation or reference to appropriste requirements and acceptance limits contained in the app?1 cable design and procurement documents.
e.
Acceptance criteria.
17.2-29
Inspection points, where applicable.
g.
Methods of documenting or recording test data and results.
17.2.11.3 Conduct of Test /Results Tests are performed by suitably trained, qualified or licensed personnel according to written procedures.
Procedures determine when tests should be per-formed, auch as to demonstrate the quality of work through a functional test when on activity involves breaching a primary pressure retaining item.
Procedures specify criteria to determine accuracy requirements of test equipment and specify when tests are to be performed.
Nonconfonnances or test anomalies discovered during testing are resolved bef. ore structures, systems or components are required to perform an intended safety function.
Results of testing are documented and evaluated for acceptability by qualified personnel to assure that test requirements have been satisfactorily compl eted. Documented test results are retained for record.
17.2.12 Control of Measuring and Test Equipment 17.2.12.1 Measuring and Test Equipment Lists Lists of measuring and test equipment required for Station testing, operations, maintenance and modification are prepared by the responsible departments of the Seabrook Staff. Each list identifies the type of measuring and test equipment, corres ponding identification numbers, and other information pertinent to control and calibration activities. Normal commercial items such as rulers, tapes and levels are excluded fram the lists. The list approval revision, addition or deletion requirements are procedurally controlled. The procedures are reviewed by the Nuclear Quality Department and regular audits of the calibration program are conducted to assure the effectiveness of the program.
17.2.12.2 Identific ation Each item on the measuring and test equipment lists is assigned a unique designation to assure positive control. The designation is permanently affixed t
I to the iten in a manner to afford proper identification without interfering with l
the item's function. Tags, labels and records traceable to the item, or other l
identifying means, document the calibration status of each item. A schedule is maintained which provides positive recall when recalibration is required and indicates the current status of all items.
I 17.2.12.3 Calibration Calibration is based on the manuf acturer's reconnended interval, however, the required accuracy, pur pose, degree of usage, stability characteristics and other conditions aff ecting measurement may modify the frequency.
Calibration activi-ties are also initiated when the accuracy of an item is suspect.
l 17.2-30
b SB 1 & 2 FSAR Procedures identify the recommended calibration interval, calibration tech-niques, required tools and standards, methods to document and evaluate the results and required record maintenance.
Items are calibrated to standards which have an accuracy of at least four times the required accuracy of the item being calibrated. Less accurate standards may be acceptable when the use of such standards and the basis of calibration acceptance is authorized and documented.
17.2.12.4 Standards S tandards used for calibration purposes within the program are traceable nationally recognized standards such as the National Bureaus of Standards (NBS).
Where national standards do not exist, the standard used for calibration is jus tified and documented. Calibrating standards have greater accuracy than standards being calibrated, unless authorized and documented for specific use.
~
17.2.12.5 Control Measuring and test equipment, including instruments, tools, gages, fixtures, reference and transf er standards and non-destructive test equipment, that is used in the measurement, ins pection, testing and monitoring of structures, systems and components is traceable to that activi ty.
To control and document the use of measuring and test equipment, the issue records or ins pection/ test documents contain appropriate information to identify the unique measuring and test equi pment, calibration status, dates used, and specify the activity for which the item was used.
Through this technique, the validity of ins pection or tests that utilized non-conforming measuring and test equipment can be determined and documented.
Reinspection or retest may be performed depending upon disposition of the non-conforming item. All records of calibration and control activities are main-tained as required.
17.2.13 Handling, S torage and Shipping 17.2.13.1 Procurement Provisions Requirements for special handling and storage, including cleaning, preservation, packaging and shipment of materials, spare parts and equipment are conditions of procurement documents, as applicable. Shipping requirements concerning the shipment method, container cleanliness, pressurization, dessication, labelling and others, are specified and reviewed during the procurement process.
When requested, the supplier prepares written procedures which specify handling, shipping and storage processes, and submits them to the Seabrook Staf f for approval.
Source ins pection by YNSD-QAD personnel may be employed to assure proper imple-mentation of supplier activities.
17.2.13.2 Receipt and S torage 17.2-31
SB 1 & 2 FSAR Upon delivery of items to the S tation, receiving activ. ties commence. The receiving actions are documented by procedure, and require inspection of the special provisions incorporated by suppliers to control cleanliness, labelling, marking, shipping characteristics, etc.
The inspection is documented and the item is assigned a storage location. Locations are established with regard to environmental conditions and limitations, cleanliness, physical restrictions, handling requirements, manuf acturers recommendations, and other pertinent data applicable to the item.
Items which require preventive maintenance, special protective environments, special coverings or other particular activities to maintain and preserve the item in storage, are contro11cd and ins pected through documented procedures.
Procedures for the storage and control of consumable materials, such as chemi-cals, reagents, lubricants and film, are provided to assure proper iden-tification and use with regard for special environmental conditions and shelf-life considerations.
17.2.13.3 Handling Detailed handling procedures and instructions are prepared for items that require special handling due to factors such as weight, size, susceptibility to shock and other conditions which warrant special controls.
Station procedures require the use of special handling procedures and instructions when required.
Special equipment and tools are maintained, inspected and documented, at inter-vals consistent with their application to assure their availability for use.
17.2.13.4 Packaging and Shipping Packaging and shipping activities originating on-site are controlled by admi-nistrative procedures.
Packaging requirements are divided into classification levels dependent upon the sensitivity of the item, transportation mode, item destination and other factors which may affect the integrity and function of the item.
Items returned to a supplier are returned in the original container, when possible, or repackaged to equivalent standards. Shipping requirements which are consistent with the mole of protecion are specified. For special nuclear material and sources, shipping is performed in accordance with the NRC fuel license and other regulatory agency provisions.
17.2.13.5 Personnel Personnel responsible for any phase of receiving, storage, handling, packaging or shipment of items are suitably trained and certified. where necessary, to assure proper implementation of the specified activities and controls.
17.2.14 Inspec tion, test and Operating Status i
17.2.14.1 S tatus Indicators The operating status of structures, sys tems and components during station opera-l tion, maintenance, testing and modification is indicated by devices such as 17.2-32
SB 1 & 2 FSAR tags, stamps or markings. These devices are identified, described and controlled through administrative procedures.
Inoperative or malfunctioning items are also documented and highlighted through the use of various devices to prevent inadvertent use. The res ponsibility for application and removal of tags, stamps and other status indicators is defined to assure positive control and to preclude inadvertant operation.
The test and inspection status of items is indicated by devices such as documen-tation, tags, stamps, or markings.
Nonconforming items are also documented and highlighted through the use of various devices to prevent inadvertent use.
17.2.14.2 Sequence of Operations T es t, ins pections and operations are controlled by documented procedures. Any alteration of the intent of a planned sequence is subject to the same review and approval controls as applied to the original. The authority and responsibility of personnel and methods to re-sequence actions are procedurally stated. Tests, inspections or other operations which are bypassed are properly documented and the effect of bypassing is evaluated and approved by the organization respon-sible for specifying the test, ins pection, or operation.
17.2.15 Nonconforming Materials, Parts or Components 17.2.15.1 Identification and control Materials, parts or components, which are deficient in characteristic, documen-tation or procedure which render the quality unacceptable or indeterminate are identified as nonconformances. The Supervisor of a technical area or activity that is within the scope of the OQAP is responsible for documenting tae noncon-fonnance in accordance with established procedures, and assuring proper control to prevent inadvertent use or installation. Controls may include marking, tagging or physical segregation. Affected organizations are notified of the nonconformance and subsequent actions taken through distribution of a nonconfor-mance report (NCR).
f 17.2.15.2 Disposition and Resolutien The Station Manager is responsible for assignment of technically qualified per-sonnel to evaluate the extent and impact of the nonconformance to determine a disposition for the item; i.e., repair, rework, scrap or use-as-is and to take appropriate action, when necessary, to prevent recurrence. For nonconfonnances involving repair or use-as-is dispasitions, which may affect the scope or intent of the material item or function, TNSD Engineering is responsible for the per-formance of an independent review function. All dispositions are documented and signed by responsible parties.
2 Acceptability of rework or repair of material parts and components is verified by qualified personnel reinspecting or retesting the item as originally spe-cified or by alternate means approved for the application.
17.2-33 l
SB 1 & 2 FSAR The Compliance Manager is responsible to coordinate the interdepartmental reso-lution of nonconformances and to follow-up corrective action.
17.2.15.3 Trend Analysis The NQ Mgr. maintains a system to recognize, evaluate and document quality trends. The system provides for periodic analysis of nonconformance reports and the submittal of significant results to the NP Supt. for information and to the VP-Production for review and assessment.
17.2.16 Corrective Action 17.2.16.1 Initiation Corrective action is that action taken to identify, correct and preclude recurrence of conditions adverse to the quality of activities, or equipment.
Station procedures identify those conditions for which corrective action may be warranted including:
a.
Failure of a structure, system or component important to safety.
b.
Defect of an item or service that could, if uncorrected, lead to failure or malfunction.
c.
Operation outside of specified limits, d.
Repetitive minor problems which may be symptomatic of a larger p roblem.
Reportable occurrences as defined by the Technical Specification.
e.
f.
Loss or apparent loss of special nuclear material (SNM).
g.
Significant deficiencies identified by the NRC, SORC, NSARC or audit program.
3 In the case of significant conditions adverse to safety, the corrective action includes an evaluation of the cause of the condition, the recommended action to prevent or reduce the probability of recurrence, and verification of completion of corrective action.
17.2.16.2 Documentation Corrective action is normally documented through appropriate system procedures.
A special repor may be prepared when a significant condition adverse to safety is identified.
This report identifies root causes and documents action taken to prec'>.le recurrence.
17.2-34 0
_.-,,,n
---n
i SB 1 & 2 FSAR 17.2.16.3 Assessment Procedures require that corrective action associated with nonconformance re port s, special corrective action reports and reportable occurrences are reviewed for adequacy and timeliness. The NQ Mgr. periodically reports to the VP-Production on the ef fectiveness of the corrective action process and status of incomplete items.
Corrective action reporting is included in the trend ana-lysis program.
17.2.17 gq-lity Assurance Records 17.2.17.1 Identification The NP Supt. and the NQ Mgr. have the joint responsibility for determining and identifying quality assurance records that are to be retained and their reten-tion period. Examples of the types of records retained include procurement documents, procedures, NDE resul ts; ins pection, audit and test results; material analyses; equi pment, process and personnel qualifications; calibration records, nonconformances and corrective action resul ts and station operating records.
Inspection and test records, where applicable, identify the inspector or data recorder, type of observation, res ul ts, acceptability and action taken in con-nection with any deficiencies noted. The compilation of records generated is f orwarded to the Administration Services Department for inclusion into the S tation records management system. The system is compatible with the design and construction phase records system.
17.2.17.2 Receipt, Storage and Retrieval S tation procedures identif y the responsibility of personnel and actions required to control the receipt, storage and retrieval of quality assurance records. A suitable storage facilicy, designed to prevent loss or deterioration of quality assurance records, is permanently located on-site with duplicate storage
(
available of f-si te.
All records, whether original or copies are indexed, filed and maintained to aid in the retrieval process.
I 17.2.17.3 Supplier Records l
Principal suppliers, their sub-tier suppliers and other suppliers are required to identif y quality assurance retards generated throughout the life of the contract in accordance with the appropriate provisions of the PSNH procurement documents. The suppliers are required to maintain a record system and, upon l
completion of the contract, either continue maintaining the records or forward I
them to PSNH for incorporation into the PSNH records management s ys t em.
Internal procedures identify the receipt, inspection and transmittal activities and responsibilities associated with supplier records.
I 17.2.18 Audits l
17.2.18.1 P lanning 17.2-35
SB 1 & 2 FSAR The NQ Mgr. is responsible for developnent and management of an audit program pertaining to activities associated with operating and operational support at Seabrook Station.
YNSD has the assigned responsibility for performance of in-station audits and those performed on suppliers. Formal reports are submitted to the HQ Mgr. and are distributed to other management positions as required by established procedures. An audit plan, which identifies the audits to be per-formed and their f requency, is prepared by the responsible parties and approved by the NQ Mgr. The audit plan is based on the status and safety significance of activities being perfonned and ensures that an audit or all functions is completed with a two-year period.
Audits of certain activities such as staff training and qualification and con-formance to technical specifications have specific minimum frequencies. These are identified and included in the plan which is updated semi-annually.
Additional audits may be scheduled when conditions warrant, i.e., extensive reorganization, quality becomes suspect, or the need to determine supplier capa-bilities prior to contract award.
17.2.18.2 Performanc e Audits, based on the pre-established schedule, are performed by trained and qualified personnel using appropriate procedures, instructions and checklists.
The procedures, instructions or checklists provide a basis for perfonnance of l
audits including pre-audit and post-audit conferences and the mechanics of the audit process. The mechanics of the process include an objective evaluation of practices, procedures, instructions; activities and items; and review of docu-ments and records to determine the extent that the quality assurance program is effective and is properly implemented. Auditors do not have direct respon-sibility in the area being audited. Their qualifications, as a minimum, are based on prior pertinent experience, specialized training and education in accordance with applicable procedures.
17.2.18.3 Reporting and Follow-Up An audit report is generated at the completion of each audit and submitted to the NQ Mgr. and to other appropriate management personnel, including management of the audited organization.
NSARC also receives a copy for their review and assessment of the audit program. Follow-up is required by both the audited and auditing organizations when deficiencies are identified. The audited organiza-tion is responsible to review and investigate the nature and cause of the defi-ciency and to provide appropriate corrective action. The NQ Mgr. is responsible for evaluation of proposed or completed corrective action and confirmation of satisf actory accomplishment. The evaluation shall assess the need for re-audit of the deficient areas.
17.2.18.4 Audit Program Review A review of the audit program effectiveness and appropriateness is conducted at least semi-annually by an independent review body, such as NSARC, or by a mana-gement representative appointed by the Executive Vice President - Engineering and Production.
17.2-36
iii e li
~
r
-ll i
l p.
I
_Ill lg
$1 lll Ii ili
-lil li i
ii i,l l
lll il ll ll ill ii
~ ~ ~--- -
ANALYSIS l
FKENE 17.2-1
l STATION MANAGER -q l
i I
I COMPLIANCE ASSISTANT l
ADMtNISTR ATIVE MANAGER STATION MANAGER ~~ 1 hA R CE oR I
l 1
r-----'
i I
l l
l I
OPERATIONS TECHNICAL l
TRAINING l
hERV C $
I MANAGER MANAGER AN GER
( NON-UC ENS E D )
g t
i I
- L______,
I i
l l
i I
Y O
AT N
SUPERVISO l
REVIEW COMMITTEE l
- REPORT 5 TO NUCLE AR QUALITV MANAGER t
PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE SEABROOK STATION I
ORGANIZATION CHART SEABROOK STATION - UNITS 1 & 2 FINAL SAFETY ANALYSIS REPORT l
FIGURE 17.2-2
T & celces k go tgj Fiy a 13.1-L l
l l
l li-ll PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE ll PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE AND l
SEABROOK S TATION - UNITS 1 & 2 YANKEE NUCLEAR SERVICE DIVISION INTERFACE CHART I
FINAL SAFE' Y ANALYSIS REPORT l
FIGURE 17.2-3
APPENDIX 17A EXCEPTIONS, ALTERNATIVES, AND CLARIFICATIONS TO PROGRAM STANDARDS, INDUSTRY CODES, FEDERAL REGULATIONS, AND CUIDES t
t I
l
3 General This Appendix lists the exceptions, alternatives, and clarifications to the Program standards which are referenced in Section 2.4.
a.
For each of the Reg. Guides and standards noted in this section, there are clarifications, alternatives and exceptions that primarily pertain to the design, construction and pre-operational testing pha-ses of the plant life.
These are presented in sectioa 1.8 and other referenced sections of the FSAR. What follows here are clarifica-tions, alternatives and exceptions that primarily apply to the opera-tional phase and the Operational QA Program and are in addition to those presented elsewhere in the FSAR.
b.
In each of the ANSI standards, other documents (i.e. other standards, codes, regulations or appendices) required to be included as a part of the standard are either identified at the point of reference or are described in a special section of the standard. The specific applicability or acceptability of these listed standards, codes, regulations or appendices is covered in other specific areas in the FSAR or the Operational QA Program.
c.
For Operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, PSNH shall control these activities under the Operational QA Program.
d.
Where strict conformance to the requirements or guidelines or Regulatory Guides or standards would conflict with reasonable compliance to the ALARA guidelines of Regulatory Guide 8.8, the degree of such conformance will be determined by appropriate levels of management.
e.
In the event of an emergency condition which could likely affect the health and safety of the public, if not promptly corrected, the Nuclear Production Superintendent or his designated alternatives may authorize emergency repairs and activities that deviate from written procedures. The nature of the emergency, its cause and the emergency corrective action taken shall be documented.
Regulatorv Guide 1.8 Personnel Selection and Training (Rev. 1-R, 9/75; reissued 5/77 Endorses ANS 3.1/ ANSI N18.1-1971 During the Operations phase, the Operational Quality Assurance Program includes and complies with this guide except that ANSI /ANS 3.1 - 1978 will be used as the standard in lieu of the 1971 revision.
a.
The following additional clarification applies to the 1978 revisions of the standard:
1.
WithregardtoSectionhAf^
~
l
the Nuclear Quality Manager who do not possess the formal educa-tional or experience requirements specified in this section shall not be automatically eliminated where other factors provide suf-ficient demonstrations of their abilities. These factors shall be evaluated on a case by case basis, documented and approved by the S tation Manager when found to satisfy the requirements. The Nuclear Quality Manager will comply with the requirements.
b.
For further clarifications and alternatives, see discussion in S ections 1.8, 13.1, 13.2, 16.6.3 and 16.6.4 of the Seabrook FSAR and in Reg. Guides 1.58 and 1.146 appearing later in this Section.
Regulatory Guide 1.30 Quality Assurance Requirements for the (Rev. O, 8/72)
Installation, Inspection and Testing of Instrumentation and Elec tric Equipment Endorses ANSI N45.2.4 - 1972 During the Operational phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a.
With regard to Section 3 of ANSI N45.2.4 - 1972 titled -
Preconstruc tion Verification:
Will be implemented as follows:
(1) is not considered applicable; (2) will be implemented with the clari-fication that " approved instruction manuals" shall be interpreted to mean the manuals supplied by the vendor as required by the procure-ment order - these manuals will not be reviewed and approved, per se, by PSNH; (3) no special checks will be made by the person withdrawing a replacement part from the warehouse - equivalent controls are assured by compliance with ANSI N45.2.2 as set forth in the Operational Quality Assurance Program; and, (4) will be compiled with, as stated, by individual technicians as part of the maintenance / modification process.
b.
With regard to Section 4 of ANSI N45.2.4 - 1972 titled - Installation:
Will be implemented by inclusion, as necessary, in the appropriate maintenance or modification procedure, where such procedures are used.
S tandard PSNH maintenance practices require that care be exer-cised in the six areas listed whether a procedure is required or not.
c.
With regard to Section 6 of ANSI N45.2.4 - 1972 titled -
Post-Construc tion Verification: Not generally considered applicable at operating f acilities because of the scope of the work and the relatively short interval between ins tallation and operation.
Where considered applicable, the elements described in the Section will be l
considered in the development and implementation of modification pro-cedures and the associated inspection and testing program.
d.
With regard to Section 6.2.1 of ANSI N45.2.4 - 1972 titled Equipment Tests: The last paragraph of this Section deals with tagging and labeling.
PSNH will comply with an alternate last paragraph which reads:
"Each safety-related iten of process ins trumentation is iden-tified with a unique number.. This number is utilized in instrument maintenance records so thct current calibration status, including 17A-2
V data such as the date of the calibration and the person performing the calibration, can be readily determined. Such information may also be contained on tags or labels which may be attached to ins talled ins trumentation."
Regulatory Guide 1.33 Quality Assurance Program Requirements (Rev.
2, 2/78)
(Operations)
Endorses ANSI N18.7 - 1976/ANS 3.2 During the Operational phase, the Quality Assurance Program includes and complies with this guide with the following clarification:
a.
Paragraph C.S.a of Regulatory Guide 1.33 (and Section 4.4 of ANSI N18.7 which it references) will be implenented with the clarification that "periodica11/' (as used in the second paragraph, first sentence) shall not require a set f re quency, and " documented" (as used in the second paragraph, second sentence) shall not require typed minutes, but may mean hand written notes or memoranda.
b.
Paragraph C.S.d of Regulatory Guide 1. 33 (and S ection 5. 2.7.1 of ANSI N18.7 which it references) will be implenented by adding the clarifying phrase "Where practicable" in front of the fourth sentence of the fif th paragraph. The Regulatory Guide's changing of the two uses of the word "should" in this sentence to "shall" unnecessarily restricts PSNH's options on repair or replacement parts.
It is not always practicable to test parts prior to use.
For modifications where these requirements are not considered practicable, a review in accordance with the provisions of 10CFR50.59 will be conducted and documented.
c.
Paragraph C.5. f of Regulatory Guide 1.33 (and Section 5.2.19 (2) of ANSI N18.7 which it references) will be implemented with the substi-tution of the word " feasible" for the word "possible" in the last sentence.
d.
With regard to Section 5.2.6 of ANSI 18.7 - 1976 titled Equipment Control: The fourth paragraph in this Section requires independent verification "where appropriate;" the fif th paragraph does not allow any exceptions to such " independent verification." PSNH will comply with the requirements of the Section by defining " independent verification" to mean " verification, by a second individual, that i
required actions have been completed.
Such verification will not l
require confinnation of the identical action when other indications can be used to verify completion of such actions." Examples include, l
but are not limited to:
verification of opening of a breaker by
(
observation of remote indicating lights; verification of trip point (set with a voltmeter or ammeter) by observing actuation of status lights or other indication at appropriate display instrument set points, verification of valve closure / opening by remote indicating lights or appropriate changes in flow indication.
e.
With regard to Section 5.2.7 of ANSI N18.7 - 1976 titled:
Maintenance and Modification:
Since some emergency situations could 17A-3 l
l
?
~
~
arise which might preclude preplanning of all activities, PSNH will comply with an alternate to the first sentence in the second paragraph which reads:
'Txcept in emergency or abnonnal operating conditions where immediate actions are required to protect the health and safety of the public, to protect equipment or personnel, or to prevent the deterioration of plant conditions to possible unsafe or unstable level, maintenance and modification of equipment shall be preplanned and perfonned in accordance with written procedures.
Where written procedures would be required and are not used, the l
activities that were accomplished shall be documented af ter-the-fact and receive the same degree of review as if 'they have been pre pl anned."
f.
With regard to Section 5.2.7.1 of ANSI N18.7
.1976Property "ANSI code" (as page type) with input value "ANSI N18.7</br></br>.1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Maintenance Programs: PSNH will comply with the requirements of this Section with the c.larification obtained by adding the phrase "Where feasible" before 'the first sentence of the fif th paragraph.
It is-not always possible to promptly determine the cause of a malfunction.
In all cases, PSNH will initiate proceedings to determine the cause, and will make such determinations promptly, where it is feasible.
g.
With regard to Section 5.2.17 of ANSI N18.7 - 1976 titled:
Inspec tions:
Inspection of operating activities may be conducted by-second-line supervisory personnel or by other qualified personnel not assigned first-line supervisory responsibility for conduct of the work. PSNH will allow the unit shif t supervisors (first-line supervisors) to perfonn inspections of surveillance tests, provided that an af ter-the-fact review of surveillance documentation is per-formed by the Shif t Superintendent (a second-line supervisor) or by other personnel not assigned first-line responsibility for the con-duct of the work.
h.
With regard to Section 5.3.9.3 of ANSI N18.7 - 1976 titled Procedures for Implementing Emergency Plan: PSNH has an NRC accepted Emergency Plan for the nuclear f acility which will be implemented in lieu of the requirements in this Section.
Regulatory Guide 1.37 Quality Assurance Requirements for (Rev. O, 3/73)
Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power P lants Endorses ANSI N45.2.1 - 1973 During the Operational Phase, the Operational QA Program includes and complies with this guide with the following clarification:
With regard to Paragraph C.4 of Regulatory Guide 1.37: Expendable a.
mat erial s, such as inks and related products; temperature indicating sticks; tapes; gunmed labels; wrapping materials (other than polyethylene); water soluable dan materials; lubricants; NDT penetrant materials and couplants, which contact stainless steel or nickel alloy surfaces shall niot contain lead, zinc, copper, mercury, cadmium and other low melting point metals, their alloys or compounds 17A-4
l as basic and essential chemical consitituents. Prescribed maximum levels of water leachable chlorides, total halogens, and sulphur and its compounds shall be imposed on expendable products.
b.
Section 2.1 of ANSI N45.2.1 - 1973 states, in part, " Planning f or cleaning activities shall include a review of the system and com-ponent design specifications and drawings." In clarification of this re quirements, a review of system and component design specifications and drawings will be required for only those modifications which change the design of a fluid system.
S ection 2. 3 of ANSI N45. 2.1 - 1973, last sentence, is revised to c.
read, " Test reports shall include in evaluation of the acceptability of inspection and test results and identify the individual who per-formed the evaluation."
d.
S ection 3.1. 2.1 of ANSI N45. 2.1 - 1973 states, in part, " Scattered areas of rust are permissible provided the aggregate areas of rust does not exceed two square inches in any one square foot area."
PS NH considers this two square inch limit as a guide only. Judgement by experienced personnel will be used this guidance in mind.
e.
Section 3.1.2.5 of ANSI N45. 2.1 - 1973 states, in part, "There shall be no evidence of organic contamination in the effluent water or on the fil ter."
PSNH intends to comply with this requirement. The pre-sence of organic contamination will be decennined visually or by feel.
f.
Section 7.1 of ANSI N45.2.1 - 1973 re quires, in the last sentence of the second subparagraph, that " Loose tools should be attached....
with a lanyard." PSNH will control loose tools by procedures or work permits. Precautionary measure such as barriers between work areas, and tool check-in and check-out controls may obviate the need for lanyards.
g.
Section 7.4 of ANSI N45.2.1 - 1973 requires checking of cleaning solutions for effectiveness of inhibitors (if used).
In clarifica-tion of this requirement, the effectiveness of inhibitors (if used) will be determined by documentation in technical literature or manuf acturer's or vendor's recommendations.
Regulatory Guide 1.38 Quality Assurance Requirements for (R ev.
2, 5/77)
Packaging, Shipping, Receiving, S torage and Handling of Items for Water-Cooled Nuclear Plants Endorses ANSI N45.2.2 - 1972 During the Operational Phase, the Operational QA Program includes and complies with this guide with the following clarification:
a.
With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Planning:
(First sentence). The specific items to be governed by the S tandard may not be identified.
H owever, the S tandard is part of the PSNH 17A-5
t Operational Quality Assurance Program and will, therefore, be applied to those structures, systems, and components which are listed in Appendix A of this document.
b.
With regard to Section 2.7 of ANSI N45.2.2 - 1972 titled Classification of Items: The four level classification system may not be used explicitly. H owever, the requirements of the S tandard I
that are appropriate to each class will generally be applied to the items suggested in each classification and to similar items such that all safety-related items are protected to an extent commensurate with their sensitivity and importance to safety. Therefore, satisfaction of requirements for packaging, shipping, receiving, storage and handling for particular items could be different than those suggested.
c.
With regard to Section 3.1 ANSI N45.2.2 - 1972 titled General:
(Last sentence). Many of the requirements of Apendix A-3 are unnecessarily restrictive and prescriptive. Therefore, those requirements may be neither the best nor the most effective methods to achieve the desired quality goals. Accordingly, while PSNH will consider all items in Appendix A-3 during the development of our own criteri.a, we do not cannit to this appendix. This clarification applies whenever Appendix A-3 or its subparts is referenced.
d.
With regard to Section 3.2.1 of ANSI N45.2.2 - 1972 titled Level A Items:
In subsection (1) temperature and humidity control con-siderations for packaging of Level A items are not considered appli-cable to nuclear fuel assemblies unless recommended otherwise by the nuclear fuel manufacturer.
PSNH will abide by the manuf acturer's recommendation. As an alternate to the requirements for packaging and containerizing items in storage to control contaminants, Subsections (4) and (5), PSNH may choose a storage to control contaminants, Subsections (4) and (5), PSNH may choose a storage atmosphere which is free of harmful contaminants in concentrations that could produce damage to stored items. S imilarly PSNH may obviate the need for caps and plugs with an appropriate storage atmos phere, and may choose to protect weld end preparations and threads by controlling the manner in which the items are stored. The clarifications apply whenever items (4), (5) or (7) are subsequently referenced and to Section 3.5.1 titled Caps and Plugs and Section 3.4 titled Methods of Preservation.
e.
With regard to Section 3.4 of ANSI N45.2.2 - 1972 titled Methods of P rese rva tion:
(First sentence) PSNH will comply with these require-ments subj ect to the clarifications of Section 3.2.1 (4) and (5) above, and the definition of the phrase " deleterious corrosion" to mean that corrosion which cannot be subsequently removed and which adversely affects form, fit, or function.
f.
With regard to Section 3.5.2 of ANSI N45.2.2 - 1972: The Last sen-tence is revised to read:
'* rapes used for identification rdther than sealing which are not near a welding operation may remain indefini-tely (see also Appendix Section 3.5.2 for additional requirements)."
g.
With regard to Section 3.7.1 of ANSI N45.2.2 - 1972 titled Containers:
Cleated, sheathed boxes may be used up to 1000 lbs.
rather than 500 lbs. as specified in 3.7.1 (1). This type of box is safe for, and has been tested for, loads up to'1000 lbs. O ther national standards allow this (see Federal Specification PPP-B-602).
Special qualification testing may be required for loads above 1000 lbs.
h.
With regard to Section 3.7.2 of ANSI N45.2.2 - 1972 titled crates and Skids:
Skids or runners will normally be used on containers with a gross weight of 100 lbs. or more.
If forklif t handling is required, minimum floor clearance for forklif t tines will be provided.
i.
With regard to Section 3.9 of ANSI N45.2.2 - 1972 titled Marking:
PSNH will comply with the non-parenthetical requirements of this Section. PSNH may not meet all of the very prescriptive and restric-tive marking requirements of Appendix A-3.9.
j.
With regard to Sections 4.3, 4.4, and 4.5 of ANSI N45.2.2 - 1972:
PSNH will comply with the requirements of these Sections, subject to the clarifications taken to other Sections which are referenced therein, if shipments are from PSNH to another nucl<ar facility.
Alternatively, since PSNH will not normally be a " shipper", PSNH might be subject to the requirements of this Section for shipments fran Seabrook to another. nuclear f acility.
Seabrook, when involved in such shipments, will comply with the requirements imposed by the receiving plant in their procurement document covering the shipment.
k.
With regard to Section 4.3.6 of ANSI N45.2.2 - 1972: Such requirements, consistent with PSNH clarified positions on Appendix A, and the provisions of A.3.9.6, will be specified "as appropriate".
1.
With regard to Section 5.2.1 of ANSI N45.2.2 - 1972 titled Shipping Damage Inspection:
Warehouse personnel will nonnally visually scru-tinize incoming shipments for damage of the types listed in this Section; this activity may not be performed prior to unloading. The person performing an inspection function as defined under Regulatory Guide 1.74; therefore, while he will be trained to perform this function, he may not be certified (N45.2.6) as an Inspector.
With regard to Section 5.2.2 - Item Inspection:
In lieu of the l
m.
requirement that "The ins pections shall be performed in an area j
equivalent to the level of storage requirements for the item", PSNH shall perform receiving inspections in a manner and in an environment which does not endanger the requisite quality of the item. Receiving area environmental controls, however, 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 established on a case basis for retention of items in the receiving area.
Retention time shall be such that deterioration is prevented and applicable manuf acturer recommendations are addressed.
This approach is justified since receipt inspection activities are 17A-7
for a much shorter duration and therefore should not be subjected to the same stringent requirements as required for storage.
n.
With regard to Section 5.2.3 - Special Inspection: PSNH takes excep-tion to the requirement that "Special Inspection" procedures shall be attached to the item. The "Special Inspection procedure shall be readily available to inspection personnel and may be attached to the item or containers.
o.
With regard to Section 6.1.2 (1) of ANSI N45.2.2 - 1972: T emperat ure and humidity controls required for the storage of Level A items are not considered applicable for nuclear fuel assemblies unless recom-mended otherwise by the nuclear fuel manufacturer. PSNH will abide by the manuf acturer's recommendation.
See remarks under Section
- 3. 2.1 above.
p.
With regard to Section 6.2.1 of ANSI N45.2.2 - 1972 titles Access to Storage Areas:
Items which f all within the Level D classification of the Standard will be stored in an area which may be posted to limit access, but other positive controls such as fencing or guards will not normally be provided.
q.
With regard to Section 6.2.4 of ANSI N45.2.2 - 1972 titled Storage of Food and Associated Items: The sentence is clarified to read;
'*T he use or storage of food, drinks, and salt tablet dispensers in any storage area shall be controlled and shall be limited to designated areas where such use or storage is not deleterious to stored items."
r.
With regard to Section 6.4.2 of ANSI N45.2.2 - 1972 titled Care of Items: The following alternatives are provided for indicated subsections:
(5) " Space heaters enclosed in electrical items shall be energized unless a documented engineering evaluation determines that such space heaters are not required."
(6) "Large (over 50 h.p. ) rotating electrical equipment shall be given insulation resistance tests on a scheduled basis unless a documented engineering evaluation determines that such tests are not re quired."
(7) " Prior to being placed in storage, rotating equipment weighing over approximately 50 pounds shall be evaluated by engineering personnel, with due regard for the manuf acturer's recommendation, to determine if shaft rotation in storage is required; the results of the evaluation shall be d cumented.
If rotation is required, it shall be perf ormed at specified intervals, be documented, and be conducted so that parts receive a coating of lubrication where applicable, and so that the shaft does not come to rest in the same position occupied prior to rotation. For long shaf ts or heavy equipment subj ect to undesireable bowing, shaf t orientation af ter rotation shall be specified and obtained."
~
s.
With regard to Section 6.5 of ANSI N45.2.2 - 1972 titled Removal of Items from Storage:
PSNH does not consider the last sentence of this Section to be applicable to the Operations Phase due to the relati-vely short period of time. between installation and use. The first sentence of the Section is replaced with:
"PSNH will develop, is s ue,
and implement a procedure (s) which cover (s) the removal of items from storage. The procedure (s) will assure that the status of all material issued is known, controlled, and appropriately dis posi tioned. "
t.
With regard to Section A3.4.1 of the A'ppendix ANSI N45.2.2 - 1972 titled Contact Preservitives:
During printing of the standard a transposition occurred between the last sentence of A3.4.1 (4) and A3.4.1(5). The correct requirements are:
(4) "However, the preservatives for inaccessible inside surf aces of pumps, valves and pipe systems containing reactor coolant water shall be water flushable type."
(5) *rhe name of the preservative used shall be indicated to facili-tate touch-up."
With regard to Section A3.5.1 (1) of the Appendix to ANSI N45.2.2 -
u.
1972 titled Caps and Plugs:
In lieu of the requirement that non-metallic plugs and caps shall be brightly colored, PSNH shall require the non-metallic plugs and caps be of a contrasting color.
v.
With regard to Section A3.5.2 of the Appendix to ANSI N45.2.2 - 1972 titled Tapes and Adhesives: Tapes will meet a sulphur limit of 0.30%
by weight instead of 0.10% as specified in A3.5.2(1)(a). This limit is reasonable based upon the chemical content of consercially available tapes.
When used on item surfaces, tapes will be of a contrasting color rather than " Brightly colored" r.s required by A3.5.2.(3).
With regard to Section A3.6.2 of the Appendix to ANSI N45.2.2 - 1972 w.
titled Vapor Barrier Material: The last sentence is considered unne-cessary guidance and not an appropriate requirement since vapor barrier materials are usually brown, cream,,or black in color.
x.
With regard to Section A3.7.1 of the Appendix to ANSI N45.2.2 - 1972 titled Fiberboard Boxes:
In lieu of the specific requirements for containers, PSNH will require that containers shall be of suitable construction to assure that material is received undanaged.
S ince this is the intent of this section, its content will bc considered as general guidance and adapted to accomplish the intended purpose with due regard for the actual condition of shipment and design of con-tainers and sealing devices, y.
With regard to Section A3.9 to the Appendix of ANSI N45.2.2 - 1972 titled Marking:
In lieu of the specific requirements of Subsections (1), (4) and (6) of the reviewed group, PSNH shall use this infor-
-mation as general guidance and shall ensure that markings on the out-side of containers are as numerous as necessary identification, traceability and instructions for special handling.
I Regulatory Guide 1.39 Housekeeping Requirements for (Rev.
2, 9/77)
Water-Cooled Nuclear Power Plants Endorses ANSI N45.2.3 - 1973 During the Operations Phase, the. Operational Quality Assurance Program includes and complies with this guide with the following clarification:
With regard to Section 2.1 and 3.2 of ANSI N45.2.3 - 1973 titled res pectively, Planning and Control of Facilities:
The zone designations and the requirements associated with each zone are not consistent with the requirements for an operating plant. Instead, pro-cedures or instructions for housekeeping activities, which include the applicable requirements outlines in Section 2.1. and which take into account radiation control considerations, security considerations, cleanli-ness requirements and personnel considerations are developed on a case basis for maintenance and modification work to be performed. As necessary, control of personnel, tools, equipment, and supplies will be established when major portions of safety-related systems are opened for inspection, maintenance or repair.
Regulatory Guide 1.54 Quality Assurance Requirements for (Rev.0, 6/73)
Protective Coatings Applied to Water-Cooled Nuclear Power Plants Endorses ANSI N101.4 - 1972' During the Operations phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a.
When the requirements of ANSI N101.4 apply, specific requirements, such as documented site meetings, field demonstrations, substrate priming, applicator reporting, inspection reporting and report forms will be considered on a job-by-job basis and involked only where found to provide a meaningful QA contribution to that task.
b.
When 10% or less of the surface of the item requires coating, it is considered to be touch-up work and only a general conformance to these requirements will be necessary.
Regulatory Guide 1.58 Qualification of Nuclear Power Plant (Rev.
1, 9/80)
Inspection, Examination and Testing Personnel Endorese ANSI N45.2.6 - 1978 During the Operations phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a.
PSNH may choose not to apply the requirements of this guide to those personnel who are involved in day-to-day operations, surveillance, maintenance and certain technical and support services whose qualifi-17A-10
cations are controlled by Technical Specification or other Operational QA Program requirements, b.
With regard to Position C1 and Section 1.2 of ANSI N45.2.6 - 1978:
Personnel who approve operational test procedures and test results and who direct such test activities will be qualified in accordance with the requirements of Regulatory Guide 1.8 with ANS 3.1 - 1978 used in lieu of ANSI N18.1 - 1971.
c.
With regard to Section 1.2 of ANSI N45.2.6 - 1978: Where the fourth paragraph requires that the S tandard be imposed on personnel other than PSNH employees; the applicability of the S tandard to suppliers will be documented and applied, as appropriate, in the procurement documents for such suppliers.
d.
With regard to Section 2.5 of ANSI N45.2.6 - 1978: PSNH will Laple-ment the requirements of this Section with the stipulation that, where no special physical characteristics are required, none will be s pecified. The converse is also true:
if no special physical requirements are stipulated by PSNH, none are considered necessary.
With regard to position C.5 and Sections 3.3 and 3.4 of ANSI N45.2.6 e.
- 1978: It is implied that individuals who perform various non-NDE functions and activities should meet all of the Level II or III capa-bility requirements delineated in Table 1 of N45.2.6-1978. PSNH pro-cedures will provide that, when unusual circumstances require, an individual who has been particularly experienced, trained or qualified in some, but not necessarily all, of the requirements for the normal Level II or III certification may be designated to perform limited of specific non-NDE inspection, exanination and testing func-tions or activities that are within the scope of this expertise. The personnel records of the individuals designated to perform such limited scope of Level II or III activities will contain documen-tation necessary to substantiate their qualificatio*s.
f.
With regard to position C.7 and Section 4 of ANSI N45.2.6 - 1978:
The clarification and alternative given above in regard position C.5 and Sections 3.3 and 3.4 applies here also.
g.
With regard to position C.8, the ALARA guidelines of Regulatory Guide 8.8 will be followed as discussed in FSAR Section 12.1.
h.
With regard to position C.10 and Sections 2.2 and 2.3 of ANSI N45.2.6
- 1978: The clarification and alternative given above in regard to position C.5 and Sections 3.3 and 3.4 applies here also.
Regulatory Guide 1.64 Quality Assurance Requirement for the (R ev. 2, 6/76)
Design of Nuclear Power Plants Endorses ANSI N45.2.11 - 1974 During the Operations phase, the Operational Quality Assurance Progran includes and complies with the following clarification:
M With regard to paragraph C.2(1) of Regulatory Guide 1.64: If in an a.
exceptional circumstance the designer's immediate Supervisor is the only technically qualified individual available, this review may be conducted by the Supervisor, prov ding that:
(a) the justification i
is individually documented and approved in advance by the Supervisor's management, and (b) quality assurance audits cover fre-quency and effectiveness of use of Supervisors as design verifiers to guard against abuse.
Regulatory Guide 1.74 Quality Assurance Terms and Definitions (Rev. O, 2/74)
Endorses ANSI N45.2.10 - 1973 During the Operations phas e, the Operational Quality Assurance Program includes and complies with this guide with the clarification presented in Section 1.8 of this FSAR.
Regulatory Guide 1.88 Collection, S torage and Maintenance of Nuclear Power Plant Quality Assurance Records Endorses ANSI N45.2.9 - 1974 During the Operations phase, Operational Quality Assurance Program includes and complies with this guide except that ANSI N45. 2.9 - 1979 will be used as the standard in lieu of the 1974 edition.
The following additional clarifications apply to the 1979 revisions a.
of the standard:
l 1.
With regard to Section 3.2.2 of ANSI N45.2.9 - 1979 titled Index:
l The "indef' and " indexing system" referred to are clarified to pertain to " record categories". Additional, more detailed, locating and indexing documents may be prepared as found to be useful. Furthermore, the specific location of a record "within the record systen" may not be delineated (e.g. The specific loca-tion within a computer record file may not be constant. Further, PSNH may utilize a computer assisted random access filing system where such location could not be readily " documented," nor would such a location be " relevant.") The storage location will be delineated, but where file locations change with time, the speci-fic location of a record within that file may not always be j
documented.
i 2.
With regard to Section 3.2.6 of ANSI N45.2.9 - 1979 titles Supplemental Information to Records: The first sentence is clarified to read as follows:
" Records may be corrected of supplemented in accordance with procedures which provide for appropriate review or approval by the originating organization or other organizations specifically designated".
3.
With regard to Section 4.2 of ANSI N45.2.9 - 1979 titled i
Timeliness: PSNH's contractual agreement with its contractors l
and suppliers will constitute fulfillment of the requirements of this Section.
4.
With regard to Section 4.3 of ANSI N45.2.9 - 1979 titled Receipt Control: Subsection 1. is clarified to mean that PSNH will unplement a sys tem of receipt control that includes a method of indicating which " record categories" are to be retained in tem-porary and/or permanent storage.
5.
With regard to Section 5.4 of ANSI N45.2.9 - 1979 titled Preservation: The following clarification is substituted for subsection 3:
" Provisions shall be made for special processed records (such as radiographs, photographs, negatives, microfilm and magnetic media) to prevent damage from excessive light, stacking, electromagnetic fields, temperature and humidity as appropriate to the record type".
6.
With regard to Section 5.6 of ANSI N45.2.9 - 1979 titled Facility: This Section provides no distinction between temporary and permanent facilities. To cover temporary storage, the following clarification is added:
" Active records will be stored in one-hour fire rated file cabinets. In general, records shall not be maintained in such temporary storage for more tl.tn three months after completion." Subsection 9 is clarified t.c read:
"No pipes or penetrations except those providing fire protection, lighting, temperature / humidity control, or communicatior.0 are to be located within the facility. All such penetrations 9ht11 be sealed or dampered to comply with a minimum two-hour fire protec-tion rating."
7.
With regard to Section 6.2 of ANSI N45.2.9 - 1979 titled Accessibility:
The first subparagraph is clarified to mean that the timeliness of record retrieval shall be based on station operational requirements for each of che various " record categories."
Regulatory Guide 1.94 Quality Assurance Requirements for (Rev. 1, 4/7o)
Installation, Inspection and Testing of S tructural Concrete and S tructural S teel During the Construction Phase of Nuclear Power Plants Endorses ANSI N45.2.5 - 1974 During the Operations phase, the Operational Quality Assurance Program includes and complies with this guide with the clarification presented in Section 1.8 of the FSAR.
Regulatory Guide 1.116 Quality Assurance Requirements for (Rev. 0-R, 6/76, 5/77)
Installation Inspection and Testing of Mechanical Equipment and Systems Endorses ANSI N45.2.8 - 1975 g.
17A-13 s
During the Operational phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a.
With regard to Section 2.3 of ANSI N45.2.8 - 1975: Last sentence is revised to read, " Test reports shall include an evaluation of the acceptability of inspection and test results and identify the indivi-dual who performed the evaluation."
b.
With regard to Section 2.8.2 of ANSI N45.2.8 - 1975 which states:
" Records of calibration shall be included in inspection and test res ul ts : " PSNH may not include calibration records in inspection and t es t res ul ts.
Instead, the calibration records will be maintained in separate file.
c.
With regard to See, tion 2.9e(6) of ANSI N45.2.8 - 1975 which states:
" Evidence that engineering or design changes are documented and approved prior to installation:" PSNH may permit installation of an item prior to approval of the related engineering or design change provided procedural controls, requiring evidence of engineering or design change approval prior to placing the affected item into service, are instituted.
d.
With regard to Section 3.2 of ANSI N45.2.8 - 1975: In the second sentence, PSNH will check identification of an item prior to release for installation; however, option is maintained to knowledgeably install equipment lacking full identification providing deficiencies are resolved prior to its use; i.e., operation. Such action is recorded in quality control documents.
Regulatory Guide 1.123 Quality Assurance Requirements for (Rev. 1, 7/77)
Control of Procurement of Items and Services for Nuclear Power Plants Endorses ANSI N45.2.13 - 1976 During the Operational phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a.
With regard to Section 1.2.2 of ANSI N45.2.13 - 1976 titled Purchaser's Responsibilities:
(a) Item c is one of the options which may be used by PSNH to assure quality; however, any of the options given in 10CFR50, Appendix B, Criterion VII as implemented by Section 17.2.4 and 17.2.7 of the Operational Quality Assurance Program may also be used.
(b) Item d is interpreted to mean that PSNH will assure that the appropriate requirements of the Operatoinal Quality Assurance Program will be implemented. ANSI N45.2 (referenced by this item) is not included in the PSNH Operational QA Program, although equivalent controls are established by way of the Program's commitments to other ANSI standards and Regulatory Guides.
b.
With regard to Section 1.3 of ANSI N45.2.13 - 1976 titled Definitions:
(a) The definition of procurement document" given in ANSI N45. 2.10 - 1973 will be used in lieu of the definition of the same words given in this Section.
. =
c.
With' regard to Section 3.1 of ANSI N45.2.13 - 1976 titled Procurement Document Preparatiori, Review and Change Control: The phrase "the same degree of control" is stipulated to mean " equivalent level of review and approval". The changed document may not always be re-reviewed by the originator;.however, at least an equivalent level of management shall review and approve any changes.
d.
With regard to Section 3.3.3 of ANSI N45.2.13 - 1976 titled Technical Requirements: The first sentence is revised to read:
'* Technical requirements shall be specified in the procurement docu-ments and/or, where appropriate, by reference to or inclusion of the specific drawings, s pecifications, codes, regulations, procedures or instructions including revisions thereto that describe the items or services to be furnished."
_ Regulatory Guide 1.144 Auditing of Quality Assurance Programs (Rev. 1,. 9 /80) for Nuclear Power Plants Endorses ANSI N45.2.12 - 1977 During the Operations phas e, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a.
With regard to Section 2.3 of ANSI N45.2.12 - 1977 titled Training:
Technical specialists who assist in perfonning audits in their area of special expertise may not be trained in auditing techniques.
However, when not so trained, they will be accompanied by a trained, qualified auditor.
b.
With regard to Section 3.3 of ANSI N45.2.12 - 1977 titled Essential Elements of the Audit System:
PSNH will comply with subsection 3.3.5 revised to read:
" Provisions for reporting on the effectiveness of the quality assurance program to the responsible management." Oth er than audit reports, PS E say not directly report the effectivener, of the quality assurance p-astamm to the audited organization when such organizations are outside
- PS NH.
c.
With regard to Section
. 3 o f ANS I N45. 2.12 - 1977 titled Scheduling:
Subsection 3.5.3.1 is.nterpreted to mean that PSNH may procedurally control qualification of contractor's or vendor's quality assurance program, prior to awarding a contract or purchase order, by means other than audit.
d.
With regard to Section 4.2.2 of ANSI N452.12 - 1977 titled Team S elec tion: PSNH will comply with the second sentence that is clarified to read:
" Audits shall be performed under the cognizance of personnel meeting the qualifications of ANSI N45.2.23 - 1978." ~
e.
With regard to Section 4.3.1 of ANSI N45.2.12 - 1977 titled Pre-Audit Confercace: PSNH will comply with the requirements of this Section by inserting the word "Nonnall/' at the beginning of the first sentence. This clarification is required because, in the case of certain unannounced audits or audits of a particular operational or work activity, a pre-audit conference might interfere with the spon-17A-15
taneity of the operation or activity being audited.
In-other cases, persons who should be present at a pre-audit conference may not always be available; such lack of availability should not be impedi-nent to beginning an audit. Even in the above examples, which are not intended to be all inclusir7, the material set forth in Section 4.3.1 will be covered (if considered necessary or desireable) during the course of the audit.
f.
With regard to Section 4.4 of ANSI N45.2.12 - 1977 titled Reporting:
(1) PSNH will comply with Subsection 4.4.3 clarified to read:
" Supervisory level personnel with whom major interactions or signifi-cant discussions were held during the course of pre-audit (where conducted), audit, and post-audit (where conducted) activities." ' - (2)
Audit reports may not necessarily contain an evaluation statement regarding the effectiveness of the quality assurance program elements which were audited, as required by Subsection 4.4.4, but they will provide a summary of the audited areas and the results.
Regulatory Guide 1.146 Qualification of Quality Assurance (Rev. O, 8/80)
Program Audit Personnel for Nuclear Power Plants Endorses ANSI N45.2.23 - 1978 During the Operations phas e, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a.
With regard to Section 2.2 of ANSI N45.2.23 - 1978 titled Qualification of Auditors: Technical specialists who assist in per-forming audits in their area of special expertise may not be trained in auditing techniques. However, when not so trained, they will be accompanied by a trained, qualified auditor.
j b.
With regard to Section 3.2 of ANSI N45.2.23 - 1978 titled Maintenance of Proficiency: PSNH will comply with the requirements of this Section by defining " annual assessment" as one which takes place j
every 12+3 months and which used the initial date of certification (not the calendar year) as the starting date for determining when I
such annual assessments are due.
c.
With regard to Section 4.1 of ANSI N45.2.23 - 1978 titled Organizational Responsibility: PSNH will comply with this Section with the substitution of the following sentence-in place of the last i
sentence in the Section:
"The Nuclear Quality Manager, S tation Quality Supervisor, or Lead Auditor shall, prior to commencing the L
audit, assign personnel who collectively have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited."
i I
d.
With regard to Section 5.3 of ANSI N45.2.23 - 1978 titled Updating of l
Lead Auditor's Records:
PSNH will substitute the following sentence for this Section:
" Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Section 3.2 (as clarified).
i 17A-16
m APPENDIX 17B MATRIX OF 10 CFR 50 APPENDIX B CRITERIA V
S. PROCEDURE
S I
i I
l 1
l
~.
C 5
t J
5 E
i 5
E m
m e
S a
E E 8 l
Q h
$ 8
~
e e s J
m s
s d e 5
0
$ s s :
8
~ S s '
z m
a 8 0 e
0 e 5 E J e
8 E
8 e
8 a
2
$ 8 e
M i s s s
5 E 8 E5 4 s
w a
z w E
E 8 2 8 5
- 5 G 5 W M I S M w
< a o x x zm m
< x w s <
t E E J E Em S5 8 E E E 8 s z
a 2
E t E 8 md e e
a E a
m z m
w S Q 8 E p s C SE S E J S $ 2 "
5 #
s 8 5 85 54 8 0 8 8 O k u s z
e x
b 5 3 S 8 E E R* ks E s B s E 8 s 3 h s
e s 0 8 E 8 5E s% 5 2 0 5 5 E 5 8 s e c
- o o a m a u<
-a u
- a o = - z o or <
PROCEDURE TITLE MATERIAL / CONTROL / STORAGE REQUEST MATERIAL / SHIPPING / RETURN X
X MATERIAL INVENTORY X
MATERIAL ISSUE X
X MATERIAL START-UP/ TURN-OVER/ ISSUE X
X DESIGN CHANGE PREPARATION X
DESIGN IMPLEMENTATION X
XX ENGINEERING CALCULATIONS X
DESIGN VERIFICATION X
X MEASURING AND TEST EQUIPMENT PROCEDURE X
CONTROL OF SPARE PARTS DATA FORMS X
X CONTROL OF NON-CONFORMANCES X
BID EVALUATION X
ASSIGNMENT OF PROCUREMENT LEVEL X
RECEIVING X
X RECEIPT INSPECTION X
ASSIGNMENT OF PROCUREMENT CLAUSES X
l PREPARATION AND REVIEW OF SPECIFICATIONS X
I MATERIAL PURCHASE REQUEST PROCEDURE X
COMMERCIAL ITEMS LIST X
X VERIFICATION ITEMS LIST X
X CERTIFICATION OF STATION INSPECTORS X
X SOURCE SURVEILLANCE X
X OPERATION OF THE RECORDS CENTER X
X HARD COPY FILES MAINTENANCE X
X FIRE PROTECTION PLAN X
X CORRESPONDENCE CONTROL X
RECORDS RETENTION X
X l
RECORDS STORAGE X
X l
DRAWING CONTROL DISTRIBUTION XX X
PROCEDURES DISTRIBUTION AND CONTROL X
MANUALS DISTRIBUTION AND CONTROL X
EQUIPMENT CONTROL X
IN PLANT AUDITS X
X DOCUMENT INDEXING X
STATION MANUAL PROCEDURE X
DOCUMENT MICRO-FILMING X
Ua-a
E 5
5 5
~
n E
2 E 8 5
5 5
0 "
5 E
Q s
u s x
z w
e E n 1
w w
R 8 e 2
$ 2 p
" S s n
5 8
m 9
l 8 5 Q
B e 5 s a e
E E
8 e
d O
o a
i
$ 8 8
"E M i E E E
5 E 8 a
e5 d G
s u
w z w e
h 5 2 8 5
- 8 G 8 W M s S e s
18 8
- E 8x s 5 8 s u s o
M 5
E
% 8 E n s E 8 "$ p8 8
sS 60 8 8 8
8 5 s 0 o p i8 5 S "
5 5 0 t an ti p 8 e P E p a
a E s t 8 s E s en sw e S e 3 8 8 8 t s
$ 1 G 8 M 8 Ea 5% E 8 d E E % 2 E S E 3 8 b5 $ 5 O OE OI O 3 $ 0 $ 5 e O 8 5 PROCEDURE TITLE QUALITY CONTROL INSPECTIONS PLANT HOUSEKEEPING PROGRAM XXX CORREGTIVE ACTION X
SATELLITE STATION FILE MAINTENANCE X
X TURN-0VER AND TRANSMITTAL OF NUCLEAR RECORDS X
'X MAINTENANCE PROGRAM X
PREVENTIVE MAINTENANCE PROGRAM
-X CORRECTIVE MAINTENANCE PROGRAM X
MAINTENANCE RECORD AND SCHEDULING SYSTEM X
GENERAL LIFTING AND HANDLING PROCEDURE X
X.
N. PROCEDURE
FOR CONTROL OF MAINTENANCE DEPARTMENT MEASURING AND TESTING EQUIPMENT X
')(
CONTROL OF TECH SPEC RELATED TESTING X
CONTROL OF IN-SERVICE INSPECTION TESTING X
TEST CONTROL PROCEDURE X
LICENSEE EVENT REPORTS-X
'X SITE OPERATIONS REVIEW COMMITTEE RESPON.
XX l
WITCHING AND TAGGING OF PLANT EQUIPMENT XXXXXXXXXXXXXXXXiXX BYPASS OF SAFETY FUNCTION AND JUMPER CONTROL XX X
X QUALIFICATION AND TRAINING OF PERSONNEL XX l
GENERAL EMPLOYEE TRAINING FIRE PROTECTION TRAINING XXX EMERGENCY PLAN TRAINING HOUSEKEEPING FOR MAINTENANCE j
NUCLEAR SAFETY AUDIT AND REVIEW COMMITTEE XX l
l l
I t
e SB 1 & 2 FSAR ADMINISTRATIVE CONTROLS Member:
Maintenance Department Supervisor Member:
Reactor Engineering Department Supervisor Member:
Chemistry Department Supervisor Member:
Instrument and Control Department Supervisor Member:
Health Physics Department Supervisor Member:
Technical Services Manager Member:
Engin-
.g Services Department Supervisor Member:
Computer Engineering Department Supervisor Member:
Quality Assurance Supervisor ALTERNATES 6.5.1.3 All alternate members shall be appointed in writing by the SORC Chairman to serve on a temporry basis; however, no more thsn two alternates shall participate as voting members in SORC activities or count toward a SORC quorum at any one time.
MEETING FREQUENCY 6.5.1.4 The SORC shall meet at least once per calendar month and as convened by the SORC Chairman or Vice Chairman.
i QUORUM l
6.5.1.5 A quorum of the SORC shall consist of a minimum of five people as follows:
a.
The Chairman or Vice Chairman plus four members, or b.
The Chairman and Vice Chairman plus three members.
RESPONSIBILITIES 6.5.1.6 The Station Operation Review Committee (SORC) shall be responsible for:
Review of 1) all procedures required by Specification 6.8 and changes a.
thereto, 2) all programs required by Specification 6.8 and changes thereto, and 3) any other proposed procedures or changes thereto as determined by the Station Manager to affect nuclear safety.
6-8
V-h n
ATTACIDiENT B REVISION TO TECHNICAL SPECIFICATIONS