ML20070T447
| ML20070T447 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/01/1991 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9104040193 | |
| Download: ML20070T447 (66) | |
Text
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[3 ALTIMORE OASAND ELECTRIC CHARLES CENTER
- P O. BOX 1475 e BALTIMORE, MARYLAND 21203 1475
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April 1,1991 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION:
Document Control Detk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unii Nos.1 & 2: Docket Nos 50-317 & 50 318 PU3used Chantdo Ouality Assurance Procram Gentlemen:
In accordance with 10 CFR 50.54(a)(3), Baltimore Gas and Electric (ilG&E) Company hereby requests approval of a proposed change to the Quality Assurance Program for Calvert Clifts Units 1
& 2. The pro msed changa would transfer responsibility for the review of procurement documents from the Nuc car Quality Assurance Department (NOAD) to the recently created Procurement Engineering Unit within the Nuclear Support Services Department (NSSD). We propose to change the program as shown on the attached markup (see pp. 6,7,11,22,23,26 & 30). Nuclear Regulatory Commission approval is required prior to implementation of this change since the change is deemed to constitute a reduction in the quality assurance program commitments as previous'y accepted. The quality assurance program is also described in Section 1.D of the Calvert Cliffs UrJated Final Safety Analysis Report (UFSAR). The UFSAR is updated annuallyin accordance d 1 CFR 50.71.
Presently, procurement documents are prepared by the Procurement Engincering Unit. The review of these documents required by ANSI N45.2.13 is performed by the Procurement Quality Engineering (POE) Work Group in NOAD. This change would consolidate these preparation and review functions within the Procurement Engineering Unit.
Existing POE procedures for qualification of personnel and document revic,v will be integrated into Procurement Engineering Unit procedures resulting in two levels of qualifications:
Responsible Procurement Engineers (RPE's) l l
Procurement Review Engineers (PRE's)
The technical level of qualification for the reviewers (PRE's) will be commensurate with that of the preparers (RPE's), thereby enhancing the depth and scope of the review. Independence is maintained since the review will be performed by qualified individuals other than those who prepared the procurement document, g gpr6/[,
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Document Control Desk April l,1WI Page 2 The primary objective of this change is to climinate t.aneceasary complexity in the procurement arocess. In addition, this change: (1) addresses recommendations made in a 1990 Joint Utility Atanagement Audit (JUhtA); (2) partially addresses a finding by the Institute of Nuclear Power Operation (INPO); and (3) fulfills an action under ilG&E's Performance improvement Plan (PIP Action Plan 5.3.1).
i Plant operation in accordance with the proposed change would continue to satisfy 10 CFR Part 50, Appendix II, Criterion 4. " Procurement Document Control.* Although the procurement document preparation and review functions would be 4erformed within the same organleation, effective i
measures such as quality assurance audits wouk remain in place to ensure that applicable regulatory requirements, design bases, and other requirements necessary to assure c uality are suitably included i
or referenced in procurernent documents.
Considering the above information, we conclude that the proposed charige to our Quality Assurance Program will maintain the effectiveness of our procurement process. Should you have any questions L
regarding this matter, we will be pleased.o discuss them with you.
Very truly yours, k
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Attachment:
hlarkup of OA Policy, Revision 25 cc:
D. A. Drune, Esquire J. E. Silberg. Esquire R. A.Capra, NRC D. G. hicDonald, J r., N RC T. T. h1artin. N RC L E. Nicholson, NRC R.1. Mel.can, DN R J. II. Walter, PSC
QUALITY ASSUPJJ4CE POLICY Revision 25 Date 5 ~I:
MAR ? 5 591 liALTIMORE CAS AND ELECTRIC COMPANY Quality Assurance Policy for the Calvert Cliffs Nuclear Power Plant Calvert Cliffs (Appendix 1B of s
Final Safety Analysis Report)
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C.C.Crafal Vice Presigent Nuclear Energy Division l
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Page 1 of 60
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QUALITY ASSURANCE POLICY Revision 25 t
TABLE OF CONTENTS APPENDIX 1P.
OUALITY ASSUPANCE PROCPAM FOR THE OPERATIONS PRASE Eection EAtt 1B.1 ORGANIZATION AND RESPONSIBILITIES 4
18.2
. QUALITY ASSURANCE PROGRAM 13 1B.3 DESIGN CONTROL 19 1B.4 PROCUREMENT DOCUMENT CONTROL (5) 21 1B.5 IN!? RUCTIONS, PROCEDURES, AND DRAVINGS 24 18.6 DOCUMENT CONTROL 24 1B.7 CONTROL OF PURCHASED KATERIAL, EQUIPMENT, AND 26 SER\\ ICES (5)
I 1B.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND 30 COMPONENTS (5) 1B.9 CONTROL OF SPECIAL PROCESSES 31 1B.10 INSPECTION 33 IB.11 TEST CONTROL 35-1B.12-CONTROL OF MEASURING AND TEST EQUIPMENT 36 1B.13 RANDLING. STORACE, AND SHIPPIF 37
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1B.14 INSPECTION, TEST, AND OPERATING STATUS 38
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18.15 NONCONTORMING KATERIALS, PARTS, AND COMPONENTS 38 1B.16 CORRECTIVE' ACTION-39 1B.17 QUALITY ASSURANCE RECORDS 40 1B.18 AUDITS 41 l
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QUALITY ASSURANCE POLICY Revision 25 LIST OF TABLES Table No.
EALt c
1B.1 BALTIMORE CAS AND ELECTRIC COMPANY'S POSITION ON 42
(
GUIDANCE CONTAINED IN ANSI STANDARDS
)
LIST OF FIGURES Ficure No.
IB.1 BALTIMORE CAS AND 2LECTRIC COMPANY CORPORATE ORGANIZATION LIST OF ATTACHMENTS Attachment letter A
BASES FOR QA POLICY REVISIONS (1)
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QUALITY ASSUPANCE POLICY Revision 25 1B.1 ORCAS 12AT10N AND PESPONSIBILITIES Ceneral Ferrensibilities All levels of organization have definite and unique responsibilities in assuring safe, economical, and reliable operation of Calvert Cliffs Nuclear Power Plant (CCNPP).
Top level management is responsible for ensuring that policies are established, resources are authorized, managemest philosophy and commitments are communicated to lover levels of the organizatien, independent verification of management controls are performed, results are reviewed, and appropriate actions taken when necessary.
Middle level management.is responsible for t anslating management policies, philosophy, commitments, and goals; applicable federal, state, and local rules and regulations; Operating Licenses, Technical Specifications (TS), and the
-Final Safety Analysis Report (FSAR) into control programs for activities such as design, procurement, construction, testing, operation, refueling, maintenance, repair, modification, training, plant security, fire protection, records, independent verification, and corrective action.
Middle level management is also responsible for defining, measuring, and modifying the overall effectiveness of control programs; taking appropriate action on the results; and keeping top management informed of the status, ace ey, and effectiveness of s
control programs, and matters which could have an impact on nuclear safety.
First line craf t and non craf t supervisors are individually responsible for ensuring that appropriate procedures are understood and used to implement each activity described in the control programs; identifyit problems, seeking solutions, verifying implementation of solutions; invo.tigating root causes of problems and taking preventive actions; ensuring that conditions adverse to plant and personnel safety are promptly identified, reported, and corrected; detecting trends which may not be apparent to a day to day observer, recommending,_ generic solutions for adverse trends to management, and taking appropriate actions, to achieve desired results; ensuring that employees assigned-to do a job are properly cualified through appropriate training and experience; have properly qualified procedures, tools, equipment, and parts to do the job, and, ensuring that independent inspections of work are conducted in accordance with preestablished requirements.
First line non.craf t supervisors are responsible to ensure that procedures are written, reviewed, and approved; first line craf t supervisors may not have this responsibility.
Non supervisory personnel acting as job directors are responsible for ensuring that properly qualified procedures are understood and used; and ensuring that tools, equipment, and parts are on hand to do the job.
r Adherence to procedures is vital to the safe and reliable operation of the Calvert Cliffs Nuclear Power Plant, Personnel are responsib'.e for adhering to established procedures, interpreting them conservatively in case of doubt, and recommending changes when necessary.
Procedures with the potential to affect nucicar or personnel safety shall be strictly adhered to.
When an activity controlled by such procedures cannot be accomplished as described or accomplishment of such activity would result in an undesirable situation, the work shall be stopped and the plant placed in a safe condition.
Vork shall not resume until the procedure is changed to reflect correct work practices. (1)
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QUAL 8TY ASSURANCE POLICY Revision 25 Procedures may be deviated from during emergencies to prevent or minimize injury to personnel or damage to plant equipment.
Any such deviations should be thoroughly documented. (1)
Cornerate Orranization and Specific Resoonsibilities The Corporate Organization Chart of the Baltimore Gas and Electric Company
-(BC&E) is shown in Figure 18 1.
Persons responsible for the principal elements of the Company's Quality Assurance (QA) Program are as follows: (1) l Chairman of the Board Vice Chairman Vice President. Nuclear Energy Division (NED)
Plant Ceneral Manager Calvert Cliffs Nuclear Power Plant Department (CCNPPD)
Manager Nuclear Engineering Department (NED)
Manager Nuclear Quality Assurance Department (NQAD)
Manager. Nuclear Safety & Planning Department (NSPD)
Manager. Nuclear Support Services Department (NSSD)
Manager Nuclear outage & Project Management Department (NOPMD)
-In addition to these individuals, the Vice Presidents of the Fossil Energy Divistor, (FED), Electric Interconnection and Operations Division (EIOD), and the Ceneral Services Division (CSD), as well as the Managers of the Electric Test Department (ETD), Purchasing & Materials Management Department (PMMD),
Information Systems Department (ISD), Facilities Management Department (FMD),
Ceneration Maintenance Department (GKD) and Fossil Engineering Services Department (FESD) are assigned support responsibilities. (1)
Also, two advisory groups perform quality related functions for plant
, operations.
These are the Plant Operations and Safety Review Committee (POSRC)
' and the Off Site Safety Review Committee (OSSRC) whose makeup and responsibilities are described in the TSs for CCNPP.
'A subcommittee of the POSRC, the Plant Operating Experience Assessment Committee (POEAC), reviews the operating experience of CCNPP and other plants c
-imilar design to determine the applicability of cignificent events to CCNPP Chairman of the Board and Vice Chairman of the Comoany BC&E's QA Program for nuclear power plants is established under the, authority of the-Chairman of the Board and the Vice Chairman of the company, who are responsible for establishing the overall QA Policy.
They assign project responsibilities to the organizations shown in heavy lined boxes in Figure 1B.1.
(1)
The Chairman of the Board assigns authority through the Vice Chairman to the Vice President Nuclear Energy Division.
Primary responsibilities for implementing the QA Program are delegated to Department Managers who report to the Vice President Nuclear Energy Division.
Managers delegate their authority as required to implement their responsibilities. (1)
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QUALITY ASSURANCE POLICY Revision 25 Quality assurance mattsrs that cannot be resolved by the Hanagers or Vice Presidents are brought to the attention of the Vice Chairman or the Chairman of the Board for resolution.
Vice President Nuclear Enerry W ision The Vice President Nuclear Energy Divisiot, is responsible for ensuring that the QA Program is developed and n&tinisteret.
The authority to develop and administer the QA Program is assigned to the Manager NQAD.
The Vice President Nuclear Energy Division, is also responsible for ensuring that the requirements of the QA Program that relate to the design, operation, and maintenance of the plant are implemented. This riisponsibility is carried out through the Plant General Manager CCNPPD; the Manager NED; the Manager NQAD; the Manager NSPD; the Manager NSSD; and the Manager +NOPMD.
!!nnarer Nucicar OuaUly_pssurance De t,n r t me nt The Manager NQAD, is responsible for the detailed development, direction, and overall coordit;ation of the QA Prograra for CCNPP.
He is also t esponsible for auditing, quality verifica tion, and.ppsgam+nk--qul44y f
functions for CCNPP, These responsibilities include:
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Developing, and revising *.ie QA Manual for Nuclear Pow'er Plants.
2.
Reviewing and approving Quality Assurance Procedures (QAP) and their revisions before they are issued for use.
3.
Taking necessary corrective action, which can include the otoppage of vork when manufacturing, maintenance, or modification acti'ities fail to comply with approved specifications, plans, or procedurss.
Such corrective action is arranged through appropriate channels and is delegated when necessary.
When a unit is operating, the Manager NQAD, may recommend to the Plant General Manager that the plant be shut down.
The Finat General Nanager has the final responsibility for the overall evaluation of all aspects and implications of shutting dovn an operating unit.
NQAD personnel who report to the Manager bQAD, are independent of departments, sections, and employees responsible for performing specific activities, and have sufficient authority and organizationni freedom to identify quality problems; to initiate, recommend, or provide solutions through designated channels; and to verify implementation of solutions.
BC6E has established that the Manager NQAD, should have at least six years of responsible experience in engineering, design, manufacturing, construction, quality assurance, or power plant cparation, as well as a knowledge of regulations and standards related to nuclear power plants.
The organization of NQAD is shown in Chapter 12 of the FSAR.
The Nanager NQAD, delegates the following responsibilities for accomplishing required quality assurance activities:
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QUALITY ASSURANCE POLICY Revision 25 Planning and scheduling evaluations of vendor quality assurance programs.
viewing and approvin BG6E procurement documents for Safety Rela (SR QesignatedNonSafetyRelated(NSR) items (a NSR i h
LG6E has ma n g gulatory or design basis commitment; op.
or plant availability reasonhQE has ittplemented speci L-ce[trols to assurc 3
reliability) and services TM pliance wJ.th'the requirements of thic policy and implementing procedures
, Reviewing and approvLnt-1:he quality assurance p'rodstons of BG6E precurement - ocunre'iits for NSR materials, componentsMr4s, and se se o be controlled as SR in accordance with the BG gram.
Performing receipt inspection functions including special receipt inspections and coordinating testing performed to accept commercial grade items, designated NSR items or upgrade NSR items for use in SR applications.
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Reviewing proposed changes to QA Program documents for compliance with regulations and licensing documents.
Planning, scheduling, and performing internal audits and evaluations of on-site and off site functions performed under the nu: lear QA
)
Program.
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Supporting maintenance and operations activities by performing inspections and surveillances.
)s Plant General 'fanater Calvert Cliffs Nuclear Power Plant Department The Plant Gen 2ral Manager is responsible for operations, chemistry, i
l radiation safety, maintenance, and systems and performance engineering activities at CCNPP.
He must ensure that these activities are esnducted in accordance with the plant operating license and TSs, the FSAR, anv the Quality Assurance Manual for Nuclear Power Plants and its ittplemer ting procedures.
The Plant General Manager fulfills the position and requirements of the Plant Manager, as defined in ANSI N18.1 (1971).
The organization of CCNPPD is shown in Chapter 12 of the FSAR.
The Plant General Manager, delegates responsibilities for accomplishing requirsd activities as follows:
1.
The Superintendent heelear Operations (S NO) is responsible to the Plant General Manager, for the operation of the plant, including the general supervision of all shift operating personnel and priorici ation of maintenance activities to support operations. This responsibility covers the safety of plant personnel and equipment, all fuel handling and refueling activities, and adherence to applicable license and regulatory requirements.
The S NO fulfills the position and requirements of the Operations Manager as defined in ANSI N18.1 (1971) with the exception taken in Table 1B.1.
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QUALITY ASSURANCE POLICY Revision 25 k_
The S NO delegates primary management responsibility to the Shift Supervisor (SS) on 'aty to ensure the safe operation of the plent under all conditions. The SS maintains the broadest possible perspective on operational conditions that affect the safety of the plant.
As the senior member of plant management on each shift, he
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exercises the command authority of his position to take whatever steps he deems necessary during 3mergency situations to place and maintain J
in a safe configuration any unit that may be affected.
2.
The Superintendent Nuclear Maintenance (S.NM) is responsibic to the Plant General Manager for managing and directing activities of the Nuclear Maintenance Section to provide high quality mainteve :e programs, plans and schedules, and qualified personnel to perfoca
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maintenance functions necessary to assure the safe, reliable, and economic operation of the plant to generate power within applicable laws, standards, codes, and regulatory requirements, n.
The General Supervisor Electrical and Controls (CS E6C), is responsible to the Superintendent Nuclear Maintenance, for the t
conduct of electrical and instrument maintenance, repair, and
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modifications needed to keep the plant and itt facilities, systems, and equipment in safe and efficient working condition.
He is responsible for planning and supervising or controlling,ao electrical and instrument maintenance activities conducted by plant maintenance personnel, and for onsuring that work 14 performed in accordance with applicable Codes and Standards and mr that required m.intenance records are 'eveloped and kept.
He is reeponsible for controlling tools and equipment used for electrical and instrument maintenance, repair and m-difications activities.
b.
The General Supervisor Meet snical Maintenance (GS MM), is responsible to the Superintendent Nuclear Maintenance, f-the conduct of mechanical mal" ance. repair, end modificat..,
needed to keep the plant and its facilities, systems, and equipment in safe and efficient working condition.
He is responsible 'or plan ng and supo rvising or controlling the mechanical t.intenan.e a.criv' ties conducted by plant maintenance personnel, and for ensurir.g that work is performed in accordance with applicable codec and Standards and that required maintenance records are developed
.d kept.
He is responsible fe, E
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controlling tools and equipment used for mechanical maintenance, repair, and modifications activities.
3 3.
The Superintendent Technical Support (S TS) is responsible to the Plant General Manager for managing and directing the activities of the Technical Support Section to provide systems and nerformance engineering, chemistry and radiation sa:
ct necessary to
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assure the safe, reliable, and economic npe.. ton of the plant.
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QUALITY ASSURANCd-POL 7CY; Revision 25 a.:
The. General-Supervisor Chemistry (CS C).is responsible-to-the Superintendent Technical Support for;the chemistry and radio-chemistry:of the primary and secondary systems and for maintaining radioactive effluents within specified'11mits, b',
The General-Supervisor Radiation Safety (CS RS) under the nuclear QA Program, is responsible to the Superintendent Technical Support for:
Ensuriut radiation protection of personnel at CCNPP.
e Complying with radioactive matirial transport regulations.
The Gener'al Supervisor Plant Engineering (CS PE), is rosponsible.
c.
to the Superintendent Technical Support for providing t'ield engineering and technical evaluation of plant systems and to evaluate and coordinate resolution of system and component problems with operations, maintenance, and engineering personnel for the Calvert Cliffs Nuclear Power Plant, d.
The Principal Engineer Performance Engineering (PE PE) is responsible to the Superintendent Technical Suppost-for,Joviding<
plant reliability / availability-testing:and' evaluation,-plant performance improvement, and administration of the Surveillance Test Program'for the Calvert Clifis Nuclear Power Plant, fangfer Nucicar Encineerine Decartment 104 Manager NED, is responstole for directing the efforts of L.rsonnel and providing resources necessary to rupport design, modification a 4 eng;rrering activities' covered by the QA Program for CCNPP.
Thest activities include. nuclear, mechanical, civil,. reliability, and instrument 9
i and controls engineering; electrical modifications; electrical analysis; 4
fuel management; configuration management; life cy '.e management, and plant design support.
The. organization of NED'is shown in Chapter 12 of the FSAR.
The Mana6er-NED delegates responsibilities for accomplishing the following activities:
Providing conceptual and detailed engineering, design and plant design support of the power and control systems'for the Calvert Cliffs Nuclear Power Plant.
Directing and performing safety evaluations, fuel management, nuclear engineering related to core physics, reactor engineering and external fuel cycle management for the Calvert Clif: s Nuclear ~ Power Plant.
Development and integration of programs necessary to operate Calvert Cliffs Nuclear Power Plant up to and beyond its current licensed lifetime; reliability engineering; ano documentation and mait.tenance of plant design bases.
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QUAL 8TY ASSURANCE = POLICY Revision-25=
l Manarer. Nuclear-Outare and Proiect Manarement Deoartment The Manager NOPMD-is responsible for directing the efforts of personnel and providing resources necrasary to support site integrated scheduling, outage management and project managemsnt for assigned projcces.
The-organization of NOPMD is shown in Chapter 12 of the FSAR.
The Manager NOPMD delegates responsibilities for accomplishing the following activities:.
Developing, implementing and maintaining a site integrated ~ schedule which schedules all significant plant related ac'_ivities at CCNPP, Managing the planning, scheduling and performing of all outages at CCNPP.
1 Providing overall project management for engineering, procurement, construction and testing of nuclear power plant modification for-CCNPP.
Manacet Nuclear Safety and Plannine Deoartment 4
U.e Mana6er NSPD'is~ responsible for directing' licensing activities,.
- independent s3fety_ evaluation activities, strategic planning and emergency planning.
The organization of NSPD is she in Chapter 12 of the FSAR _
The Manager NSPD delegates responsibilities for accomplishing the following activities:-
Providing' licensing services including preparation and. review of.
nuclear safety, accident and transient analysis; coordination.and operation of various. industry information exchange cystems; evaluation of plant events and conditions adverse to quality for reportability to the NRC and other agencies, assisting in the investigation and evaluation of events, and preparation of the reports; coordination of tracking and resolution of company commitments to the-NRC; research and preparation of' responses to NRC letters, bulletins, circulars and information notices;-FSAR research and revision control'; maintenance-and revision of the current licensing basis for nuclear power -plants; coordination'of all compliance related communications with external
. agencies including-_ assistance in ensuring their consistency with existing licensing basis commitments; and coor.'.ination of regulatory inspections and visits and company presentations to the NRC.
- Directing investigations. of significant events-.to determine root cau.e, recommending. corrective. action,.and generating appropriate reports to document _the investigation results; directing a program for identifying trends within the corrective action systems.
Directing the efforts of BC&E' personnel involved in emergency _ planning activities.
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.- i QUAL 2TY ASSURANCE POLICY Revision 25 Development of the annual. Strategic plan for the Nuclear Energy.
Division including the Nuclear-Program _ Plan.
Manteer duelear suonort Servlees Deoartment The ManagertNSSD is responsible for training (except Security), industrial safety, fire protection, onsite procurement coordination, procurement engineering, procedures upgrade, state regulatory matters, and staff services functions for CCNPP,
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The"orgenization of NSSD is shown in Chapter 12 of the FSAR.
The Managar NFSD delegates responsibilities for accomplishing the following
-activities:
i Prov_id.ng support to Managers in the Nuclear Energy Divisio6 to ensure their. personnel are, prcoerly trained and qualified to perform their assigned duties, includi.ng 1. hose duties which implement the nuclear QA Progra'n.
Traini'ig required by special work forces and contractors would t.e perfor.aed by the appropriate BC&E Department, and/or Host Company (venoor).
Controlling, distributing, and coordinating the preparation of revisions to'the QA Manual and its associated procedures; collecting, storing, maintaining, and retrieving QA records for nuclear power
. plants; maintaining, controlling, and distributing drawings and technical manuals.related to equipment, materials, and services for nuclear power plants; coordinating investigations concerning state regulatory matters; coordinating the efforts of Nuclear Energy Division personnel involved in the procurement of structures, systems, t
components, parts, and services related.co the design, constructic.n, j;
fueling, maintenance, and modifications of CCNPP.
Directing the efforts of personnel under the Nuclear QA Program to =
develop,. implement and coordinate the industrial safety and fire protection program for the CCNPP, and to plan, schedule, and monitor 1
activities directly related to safety,' fire-protection, and prevention dyag Establishing procedures to,
ure.that procurement documents ide l-
-app tc Q technical and doc entation requirements:
t on,-
review, t e cRWteal--.a royal, e control ment documents at CCNPP; encuring spare-a '
arts are suitable for-their intended a.p.1.ioatttrn(s); specification o er eLcharacteristics and
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,,, acce ance criteria for dedication of commercial grad % ems; specification of special storage requirements for. age sensitiDteins.
_v, Individuals supporting the CCNPP Nuclear Program are designated as follows:
yice President-Fossil Enerev Division The Vice President-FED, is responsible for ensuring that the activities of FED 1nrsonnel involved in CCNPP maintenance and modifications: Materials Engineering Page 11 of 60
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hBrer foe A48t //
4 2R sdDNsR Establishing procedures to assure ' hat procurement documents Identify appi cab!c technical an C.nen:.a:an requirements; j
penewed (SR V d DNSR) cumen45 receive Indpo<nded (tvitid Md picperetion, rc.<lcw, :cchnice; approvnl, and contral af procureme-nt approval for #e P'*Per inclu.stw of -hechnical and Quali& ret re*YO A
buumuio ai dfNPP; ensuring spare and replacement parts are suitable for thcu w.ded application (s); specification of critical characteristics and acceptance criteria for dedication of commercial
- grade items; specification of special storage requirements for age sensitive items.
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QUALTTY ASSURANCE POLICY Rovision 25 and Analysis; and radivi6gical environmental monitoring, meet the requirements of the QA Program.
This responsibility is carried out through the Manager GMD, and the Manager FESD.
Manater Generation Maintenance Decartment The Manager GKD, is responsible for directing the efforts of GMD personnel involved in maintenance and modification activities at CCN~P.
Manater-Fossil Encineerine Services Decartment The 'Hanager FESD,1s. responsible for directing the efforts of personnel involved in: (1) ensuring compliance with Radiological Environmental Monitoring TSs, and (2) ensuring Materials Engineering and Analysis and Inservice Inspections relating to SR structures, systems, and components are completed in accordance with Company and regulatory requirements.
Vice Prerident Electric Interconnection and Ooerations Division The Vice President EIOD, is responsible for ensuring that the requirements of the QA Program that relate to the calibration of test equipment and the testing of protective. relaying, mecering controls for SR electrical powe,r. equipment and tradiological environmental monitoring support activities are implemented.
This responsibility is carried out through the Manager ETD.
Manacer Electric Test Decartment The Manager ETD, is responsible for directing the efforts of personnel involved in he testing of electrical power equipment, the calibration of test equipment and the testing of protective relaying and metering controls for the electrical power equipment of CCNPP.
The Manager ETD is also responsible for maintaining and operating Radiological Environmental Monitoring equipment and for performing sample collection and analysis for the FESD.
Vice President General Services Division The Vice. President GSD, is responsible for ensuring that the requirements of the QA Program that -relate to the operational, licensing, and training activities of planu security, the procurement of SR or designated NSR-structures, systems, comronents, and services are implemented, and fot support services for computer software and hardware.
These responsibilities are carried out through the Manager FMD, the Manager PKKD, and the Manager ISD.
Manneer-Purchasinc and Materials Management Deoartment The Manager FMMD, is responsible for directing the efforts of personnel involved in the purchasing and storage of items and services for CCNPP.
Manaver Facilities Mananement Denartment The Manager-FMD, is responsible for tMe operational, maintenance,
. licensing, and training activities associated with plant security at CCNPP.
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j QUALIlT ASSURANCE POLZCY L
Revision 25 l
Manacer Information Systems Department The Manager ISD, is responsible for d! * :ing the efforts of ISD personnel involved in acquiring and supporting computer sof tware and hardware.
1B.2 OUALITY ASSURANCE PROGRAM Ceneral Controls L
BC&E's QA Program for CCNPP is applied to structures, systems, components, and l
, activities that have been designated SR because they prevent accidents or l
mi,tigate"the consequences of postulated accidents that could cause undue risk to 1
l the health or safety of,the public.
The QA Program is also applicable to l
designated.NSR structures, systems, componente, and activities as committed to in regulations.
Designated NSR program requirements are based on a graded approach to Quality Assurance required to meet applicable regulatory requirements or guidance.
The level of QA Program controls placed on NSR items are defined in QAPs.
This Program is governed by the Quality Assurance Manual for Nuclear Power Plants, which specifies assignment of responsibilities for implementation of the jProgram7andestablishes'responsibilitiesforcontrollingand-ensyringthe quality of the Program's activities.
Controls have been established for specifying on a Quality List (Q List) all SR structures, systems, components, and activities that are subject to the
'requiremtees of the QA Program.
The Statement of Authority in the Quality A+surance Manual for Nuclear Power Plants, signed by the Chairman of the Board, est.ablishes the overall QA Policy L
of BC&E.
This Statement sets the goal of safe and reliable operation of CCNPP; l
commits the Company to a QA Program designed to ensure the plant's compliance with' regulatory requirements, BC&E commitments, and established practices for reliable plant operation; ana requires every person involved in QA Program activities to comply.with the previsions of the Program, il.
The Policy is approved by the Vice President NED and implemented by the Managers of NQAD, NED, NOPMD, NSPD NSSD, CCNPPD, ETD, FESD, CMD, PMMD, ISD, and FMD, (1) 3 l
The QA Progrem has established controls for BC&E and its contract-a as required l
to ensure that the criteria of 10 CFR 50, Appendix B, will be cet throughout the operations phase of the plant; i.e.,
during activities of testing, operation, maintenance, repair, modification, and refueling.
The QA Program has also established controls to ensure that the construction and L
operation of designated NSR structures, systems, components and activities for the Independent Spent Fuel Storage-Installation (ISFSI) are conducted in compliance with 10 CFR'72.
L "The Manager NQAD, coordinates the development of the CA Program and the -
l Manager-NSSD controls the issue and revision of the Quality Assurance Manual for l
Nuclear Power Plants.
Each change to the Manual a issued with a transmittal notice, which is completed by the recipient and returned to NSSD to indicate that the documents listed on the transmittal tave been received and incorporated l
Page 11 of 60 i
QUALITY ASSURANCE POLICY Revision 25 l
into the recipient's Manual.
The Manager NQAD, ensures that the Program is.
revised as regulations, standards, results, or experience dictate. (1) The Manager also determines and evaluates the degree of compliance of QA Program activities with the requirements of the Quality Assurance Manual for Nuclear Power Plants and its implementing Procedures.
..udits are conducted regularly to ensure compliance with established requirements, and the results of these audits are reported to responsible management personnel.
The Vice President NED, ensures that activities of the NQAD are audited regularly by personnel independent of the Department.
These auditors assess the effectiveness of the Section's implementation of appropriate portions of BC&E's QA Program.
The Vice President-Nuclear Energy Division, evaluates the report of the independent audit to determine if changes are required to the QA Program.
He is responsible for negotiating such changes with the appropriate level of management and for sending to the Chairman of the Board a copy of the audit report and an account of the corrective action taken.
If a difference of opinion arises between NQAD personnel and those of other Sections or Departments, the dispute is resolved as follows:
The Supervisor /Ceneral Supervisor of the QA Unit /Section involved first tries to esolve the matter with the organization responsible for conducting the etivity.
If a resolution cannot be obtained, the matter is referred up through the following management personnel until it is resolved:
(3) 1.
The Manager NQAD, and the Manager responsible for performing the activity.
NOTE:
If the dispute is with another Unit /Section in NQAD, the issue will be settled by the Vice President Nuclear Energy Division.
(3) 2.
The Vice President Nuclear Ener6y Division. (1) 3.
The Vice Chairman or the Chairman of the Board.
To ensure that important activities are performed correctly, BC&E conducts formal training programs for Company personnel with significant responsibilities.
These programs include both initial and cantinuing training and are conducted in accordance with written procedures or instructions.
Department Managers are esponsible for ensuring that the training needs of personnel-in their Departments are identified, formal traint'a programs to satisfy those needs are developed, and the training programs in accordance with the requirements of the Quality Assurance Manual for Nuclear Power Plants are implemented.
The QA Program was developed to meet the requirements of the Regulations, Regulatory Guides, and Industry Standards of the Nuc'. ear Regulate ry Commission (NRC) listed below.
Exceptions taken to guidance contained in these documents and equivalent BC&E alternatives are stated in Table 1B 1.
~
Page 14 of 60
QUALITY ASSURANCE POLICY Revision 25 REGU1ATION,j 10 CFR 50.55a Codes and Standards.
10 CPR 50.59 Changes Tests, and Experiments, 10 CPR 55 Operators' Licenses, f 10 CFR 50, Appendix B - Quality Assurance Criteria,_for Nuclear Power Plants and Fuel Repr'ocessing. Plants.
REGUIATORY JUIDES 1.8 - Personnel Selection and Training (Septembef; 1975)**.
This endorses ANSI N18.1 (03/08/71)***.
1.16 Reporting of Operating Information (ar specnied in Calvert Cliffs Technical Specifications).
1.30 - QA nequirements. for. Installation,. Inspect! m, and Testing,of.
iInstrumentation and Electric Equipment (08/11/72)'.
This endorses ANSI N45.2.4 (03/01/72).
1.33 - QA Program Requirements (Operation, Rev, 2, S2/78)**.
This endorses ANSI N18. 7 1976/ANS 3. 2 (02/19/'e ' ***.
1.37 - QA Requirements fot Jatat.ing of vluid Systems and Associated Components of Water Cooled Nuclear Powe' l' ants (03/16/73)**. Tnis endorses ANSI N45.2.1 (02/26/73)***,
,1.38 - QA Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items-for Water Cooled Nuv' ear Power Plants (Rev. 2, 05/77)**.
This endorses ANSI N454 2.2 (12/20/72)***.
1.39 Housekeeping Requirements for Water Cooled Nuclear Power Plants
- (03/16/73)*, This endorses ANSI N45.2.3 (03/15/73)***.
1.54 - QA Requirements for Protective Coatings Applied to Water-cooled Nuclear Power Plants (06/73)**.
This endorses ANSI N101.4 (11/28/72)***.
1.58 - Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel (09/80)**.
This endorses ANSI N45.2.6 (1978)***.
1,64 - QA Requirements for the Design of Nuclear Power Plants (10/73)*.
This endorses ANSI N45.2.ll, Draft 3, Rev. 1 (07/73).
Page 15 of 60
QUAL 2TY ASSURANCE POL 2CY Revision 25 1,68 Preoperational and Initial Startup Test Programs for Vater Cooled Power Reactors (11/73)**.
1.144 - Auditin6 of Quality Assurance Programs for Nuclear Power Plants, Rev. 1 (09/80)**.
This endornes ANSI N45.2,12 (1977).
1.146.
Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Aug. 1980).*.
This endorses ANSI N45.2.23 (1978)***.
INDUSTRY STANDARDS ANSI N45s2.5 Supplementary QA Requirements for Installation, Inspection, and Testing of Structural Concrete and Structura' Steel During the Construction Phase of Nuclear Power Plants; Draf* 3 Rev. 1 (01/?'4).
ANSI N45.2.8 Supplementary QA Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants; Draft 3, Rev. 2 (09/73).
ANSI N45.2.9 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants; Draft (10/76)***.
ANSI'N45.2.13 - QA Requirements for Control of Procurement.of Equipment, Materials, and Services for Nuclear Power Plants; Draft 2, Rev. 2, (10/73)***.
NOTATIONS FOR REGULATORY CUIDES AND INDUSTRY STANDARDS NRC endorses an Industry Standard or draft without reservation.
NRC takes exception to or provides additional guidance in a regulatory position statement.
- BG6E takes exception to guidance offered and states alternatives.
3 Y
a Page 16 of 60
QUAL 1TY ASSURANCE POLICY Revision 25 Procedural Controls The QA Program is documented in the Quality Assurance Manual for Nuclear Power Plants.
This Manual contains a QA Policy that identifies the NRC regulatory requirements, industry standards, and specific codes applicable to the eighteen criteria contained in 10 CFR 50, Appendix B.
The QA Policy also indicates l
action that will be taken by BG6E in response to these documents and to l
commitments made in the FSAR and TSs for CCNPP.
The Policy is approved by the Vico President Nuclear Energy Division. (1)
The Manual also contains a series of individual QAPs chat implement actions identifidd in the QA Policy, QAPs cover the majot' activities related to operating a nuclear power plant, such as plant operation, plant maintenance, training, purchase of items and services, calibrations, etc.
Each QAP is prepared by one or more of the Ospartments responsible for conducting the activity.
The QAP and revisions thereto are reviewed by the mat ager(s) of the responsible departments (those departments responsible for the QAP activity, and the Managers of Nuclear Energy Division). (1) The Vice President Nuclear Energy Division approves all QAPs and revisions thereto. The Manager NQAD reviews changes to QAPs and recommends approval to the Vice President NED, and the i
Manager NSSD issues all QAPs and revisions thereto. (1)
QAPs specify nterdepartmental relationships and departmental responsibilities as they relate to particular activities, regulatory requirements, and BG&E commitments.
One QAP controls the distribution and revision of the Manual.
Others ensure that:
1.
The f,eed for special controls, processes, test equipment, tools, and skills is specified when necessarj to ensure that required quality is attained in performance of the activity.
2.
Quality is verified by inspections and tests, 3.
Petconnel who perform activities affecting quality achieve and maintain suitable proficiency through appropriate training ar.d experience.
1 Department or lower level impleeenting Procedures are prepared either by Departments such as ETD and PMMD or by groups within Departments.
The controls for revicw and issue of implementing procedures are discussed in Sections 1B,5 and 13,6.
Review of Operations Procedures require that CCNPP shall be operated and maintained it, accordance with the plant TSs and operating license.
The follcwing organizations review plant operations to ensure that these procedures are followed:
Page 17 of 60
= -
- ~ _ _,
QUALITY ASSURANCE POLICY Revision 25 1.
The Manager NQAD provides independent verification that the requirements contained in the Plant's operating license, FSAR, TSs, and plant proceduros are met.
This is accomplished through quality assurance audits.
2.
The OSSRC provides independent verification by review that CCNPP is operated in accordance with established requirements.
The OSSRC, which functions under a written Charter approved by the Vice President Nuclear Energy Division, is composed of on site and off site personnel knowledgeable of in plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, radiological safety, instrumentation and control systems, mechanical and electrical systems, quality assurance, and environmental f actors.
The proceedings of all meetings are /ocumented and sent to the Vice President Nuclear Energy Division, Committ9e members, and others designated by the (,mmittee Chairaan.
3.
The on site POSRC reviews matters pertaining to nuclear plant safety.
This Committee screens subjects of potential concern to the OSSRC and performs preliminary iuvestigations under the direction of the Plant General Manager.
The POSRC, which is chaired by the Plant General Mand 6er, functions under a written Procedure which is approved by the Plant Ceneral Manager.
The results of all meetings are documented and sent to the memb Ts of the OSSRC, and others designated by the Committee Chairman.
s The maintenance and repair of systems, structures, and components subject to the QA Program are performed by personnel under the direction of the-General Supervisors of Electrical and Controls, Radiation Safety, and Mechanical Maintenance, according to written procedures and instructions as prepared by the maintenance force and approved as stated in the Quality Assurance Manual for Nuclear Power Plants.
These Procedures:
1, Ensure that quality related activities, such as inspections and tests, are performed with appropriate equipment and under suitable environmental condttions.
2.
Indicate inspections and checks that must be made and c.icords and data that must be kept.
3.
Show where independent verifications of inspections or checks should be performed by specified personnel other than those performing the work.
When necessary, non plant Company personnel or-outside contractors are brought
'in to supplement the plant work force.
In such instances, the approval of work procedures and the tagging of equipment are coordinated by a member of the BC6E erganization responsible for the performance of the work.
Control: are established in the Quality Assurance Manual for Nuclear Power Plants to easure that materials and parts used in the repair, maintenance, and modification of SR and designated NSR portions of the plant are appropriate for the ser-ice intended. Vritten procedures are prepared for tne storage and identification of materials and parts to ensure that they do not deteriorate in storage and can be correctly identified before instellation or use.
l l
Page 18 of 60 j
. ~ _ _
-QUALITY ASSURANCE POLICY
- 'l Revision-25 l=
Equipment manufceturers and contractors:used for the repair, maintenance, and L
modification of SR and designated NSR structures, systems,land components are required to have' quality' assurance programs-consistent with the importance of
- the end product toJsafety.
18.3 DESIGN CORTROL Control I
~
Plant modificationsLdescribed in the FSAR and considered significant for nuclear safety are controlled by the Quality Assurance Manual for Nuclear Power Plants, which istwritten to ensure compliance with RegulaEory Guide 1.64 and 10 CFR 50.59.
I L
- Alterations: to the Operating Licen:e, including TSs, the FSAR and the Emergency L
Response Plan (ERP)'are subject to the same controls as are alterations to l-changes, tests,'and experiments defined in 10 CFR 50.59.
p h
l Controls for changes,- tests, and experiments conducted at CCNPP vary according to the following:
1.
As.the item or activity affected is or is not described in,the FS.AR.
~.
2.
As the item or activity affected Sas.been classified SR or NSR.
3.
As a.safetf-analysis 11s'or is not required.
4 As the. proposed change, test, or-experiment-does or does.not constitute an 1
Unreviewed Safety Question or require a change to the TSs.
To ensure ' compliance with 10 CFR 50.59, chat,o$s, tests,. or l experiments have been divided into cctegories.
Three methods of treatment are allowed:
3
- 1.
_ Implementing the change, test, or expetiment according to' Company practice for operating power plants,--or accord'.ng to Procedures required by1the Quality Assurance-Manual for Nuclear-Power Plants.
jh Implementing the change,~ test, or experiment'according to Company practice L
for operating pover plant.s-by:using Procedures required by the Quality Assurance Manual for Maclear Power-Plants but controlling the change, test, ar' experiment with a. Facility Change Request-(FCR) so that the preparation and reporting of safety-analyses are controlled.
3.
. Controlling the change. test, or experiment with a FCR and not allowing the 1 implementing Tetivity to begin until the review requirements of 10 CFR 50.59 and 10 CFR 50, Appendix B, have been met, a
. Changes, tests, or-experiments >which require approval by the NRC are approved by the POSRC and by the OSSRC;
- Controls have been established to ensure that design changes to SR structures, systems, and components are reviewed either by.the organization that made the origir.al,designLo: by a Responsible Design Organization (RDO) that meets requirements specified in ANSI-N45.2 11,-Section 8.
Page 19 of 60
~. -,
QUALITY ASSURANCE POLICY i
Revision 35 Responsible Desien Orcanizations RDos, either on contract or within BG6E, ensure that:
refuitWtoN 1.
Applicable regulatory requirements and design basesgare correctly 4
translated into specifica '.ons, drawings, written procedures, and
)j instructions.
1 Appropriate standards for quality are specified in design documents, and deviations and cb.nges from such sttadards are controlled.
3.
Suitable desigi controls are uset in applying principles of reactor physics; makin 3 seismic, stress, thermal, hydraulic, radiation, and accident analyses;. ensuring compatibility of materials; and providing accessibility for in service inspection.
4.
Designs are' reviewed to ensure that design characteristics can be controlled, inspected, and tested, and that inspection and test criteria are identified.
5.
Interfaces, both external and internal, are controlled for the activities of all participating organizations, 6.
. Methods for verifying or checking, such as design reviews, alternative calculations, and qualification tescing are properly chosen and followed; the most adverse design conditions are specified for test programs used to verify the adequacy of designs.
7.
Individuals or groups responsible for design verification are other than the iginal designer and the designer's immediate supervisor.
8.
Design and specification changes are subject to design controls and approvals applicable to the original design.
9.
Design documents and revisions thereto are distributed to responsible individuals and controlled to prevent inadvertent use of superseded material.
10.
tesign errors and defici ncies that adversely affect SR structures, systems, and componant.
.e documenteu, and appropriate corrective action is taken.
11.
Design documents and reviews, records, and changes thereto are collected, stored, maintained, and c ntrolled systematically.
12.
Standard off-the shelf commercial or previously approved materials, parts, and tquipment essential to the SR functions of structuras, systems, and components are reviewed for suitability of application before they ar-selected.
13.
Tha persons or groups responsible for dtsign reviews and ether design verification activities and their authority and responsibilities ate identified.
(*
Page 20 of 60
QUALITY ASSURANCE POLICY Revision 25 14 Design changes to NSR items initiated and approved at the plant are controlled to ensure compliance with 10 CFR 50,59.
i 15.
Processes used to select suitable materials, parts, equipment, and processes for SR structuros, systems, and components includes the application of pertinent industry standards and specifications, material
(
and prototype hardware testing programs, and design reviews.
16.
Computer programs used in design are subject to design controls and program verification.
1E.4 PROCUREMENT DOCUMENT CONTROL (5)
Controls have been established to specify the requirements and sequence of actions for:
requesting items or services; revicu of the requested item or servic9 to establish the necessary technical and quality requirements; prep:::* ion, review and control of procurement documents; evaluation and s91ectior, of vendors and; control of deviations from the procurement document tequiremetits.
The degree to which these controls are imposed on the purchase of items and services"by-BG&E for=CCNPP depends on:
l 1.
The functional (safety) classification of each item or service as SR or NSR according Lv controls established by the RDO and 2.
The Procurement Category of the item within it's functional classification as a basic component, commercial grade item, esignated non safety related item (DNSR) or NSR item:
l a.
Commercial Crade An item satisfying all three of the following criteria:
L 1.
Not subject to design or specification requirements that are unique to nuclear facilities; and 1
2.
Used-in applications other than nuclear facilities; and 3.
Is to be ordered from the manufacturer / vendor on the basis of specifications set forth in the vendor's published product description (for example, a catalog).
j b.
Basic Component - An item either procured as a safety related l
item or as a commercial grade item which has been accepted and dedicated for safety related application.
This term is synonymous with " Safety Related Component",
c.
Designated Non Safety Related A NSR item which BC&E has made a 1
regulatory or design basis commitment; or, for plant availability reasons, BC&E has implemented special controls to assure reliab!11ty.
These NSR items are included within the qusiity l
rssu'ance process, j
Page 21 of 60 l
QUALITY ASSURANCE POLICY Revision 25 d.
Non Safety Related An item that does not perform a safety related function.
3.
The procurement method to be used for the item or service:
Purchase Crders placed by BC&E personnel for items or services intended for safety related applications and DNSR items and services fall into tvo categories, Nuclear Grade Method procurement and Commercial Grade Method procurement.
a.
Nuclear Grade Purchases that tre designated to be placed with vendors that maintain a 10CFR50 Appendix B quality program and supply items that meet the defin;t. ion of Basic C sponent.
The requirements of 10CFR21 vill be invoked on the endor under this method.
b.
Commercial Grade Purchases that are designated to be placed with commer:1al grade vendors that supply items or services that meet the definition of Commercial Grade.
These items must be dedicated icr SR use by BG6E.
Items classified as DNSR will be purchased using the 20mmerci Grade Method with technical requirteents established by a g i.
gj 3 juc,.f-gecurement docunents to ve51fy],
{ Dhn qualified NSSD personnel review al) correct funct a
safety) classification.
.n eccordence with apprpved
1 procedures, NSSD person QRDO e.uthority t eview SR 9MLgtiated NSR procurement documents for proper iwQ"precuro p eg.hnica % uirements.
Personnel in the NQAD review SR and desisnatad-NSPc ent documents to ensure that
- f the requirements statad-therein are correct, inspec controllable, contain adequate a prance and rejection criteria at d comply with equirements of the,pr.urement program.
These reviews and approvals are document or to
,ptacement of the purchase order.
All changes made to procurement documents, including specifications and orher ter.hnical attachments, are subject to the same levels of review, approva and cont.rol that were applied in preparing and processing the original documents.
Bids submitted tc supply safety related items or services receive the same r view and approval cycle as used for safety related procurement requisitions.
Vender Selection Personnel in NQAD evaluate vendors who provide SR and desi;aated NSR items and services to verify they can provide accepteble items and ervices.
Controls,for Nucitfr Grade Purchases l
Controls have been estaslished to ensure that, before p1rcement of a purchase order under the Nuclear Grade method of purchase, there is evidence of the following:
1.
The vendor has been evaluaced as stated in Section 1B.7 of this policy and found to have a satisfactory QA program.
Page 22 of 60 l
l
QUALTTY ASSUMNCE POLICY Revision 25 2,
The item to be purchased is manufactured under the requirements of the evaluated and approved program.
Controls for Commercial Grade Purchases Controls have been established to ensure that items or services available to general. industry will be sufficiently controlled to perform their SR and designated NSR function.
A& personnel will specify the acc9ptance methods to be used to verify the critical characteristics identified in the procurement document (s).
-Nggg/Ngg 5
f, roc u r e me'n t Document Reautrements
~
Procedure:; require that ' procurement documents shall:
1.
Reference part numbers or descriptions, and add.tional requirements to ensure t items ordered can be identified aad verification can be made that eat. item received is the item or6ered.
&dcproved chttwing Q.nd) by 2.
Contain/referance technical req,uirements for the b s of design,V including the applicable regulatory requireme component and material 9
identificationy n quir r m t:,
Ar 4% specifications, c o,d e s,. industrial standards,. test and inspection requirements, and special process instructions such as welding, heat treating, nondestructive testing, and cleaning.
3.
Identify the requirements of 10 CFR 50, Appendix B, which must be co ' lied with and described in the vendor's QA program, for Nuclear Grade Purcoases.
4, Require that niajor contractors designated as BG6E agents to purchase SR and designated NSR items or services must have procurement controls to ensure they purchase or acquire these items or services in compliance with the necessary sectiots of ANSI N45.2.13.
5Property "ANSI code" (as page type) with input value "ANSI N45.2.13.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Identify required documentatitu (1,e.,
- drawings, specifications, procedures, inspection and fabrication plara, inspection and test records, personnel and procedure qualifications, and matarial chemical and physical test results) to be prepared, maintained, at d submitted to BG6E or the purchaser for review and approval.
6.
Identify records which must be retained, controlled, maintained, or delivered to BG&E or the purchaser before use or installation of hardware.
l l
7.
Specify BG6E or its agsa:'s right of access to vendor facilities and records for source inspection, surveillance, verification and anoits.
8.
Identify requirements of the vendor's. quality control process which must be implemented when providing a commercial grade item.
l 9.
Reference or specify the critical characteristics that a commercial grade item must possess to ensure 4-s-oan ful f i ll - i t s SP or deel-gnat +4-N&Fe-
<4uw 4en-
//10l Y)c lldm recethed. is -lhe id*n
. pew & d.
Page 23 of 60 1
o
/dzer rot R4cc n I
a N$3D NGD Trained and qualifiedte999 personnel:e :e "'! p..
- ..r' 3
document;;c verif erretMunctienal(..afety) !:' " bat:
5 t
,,,..,.._.,i.,,..,_..:a,.,.,..,..,.,...J.t.....a.....-..,
- c i ~ '
- wit h RDO e e e n....
- authority review SR and designated NSR procurement documents for arid uel W Q
proper inclusion of technica equirements. {.}c:. 'anc. ;.. a.L;, M. ~A 4 h l'
m
- re.ie SR "Wedgn ned NSR precure:nenH!ae..nent- :a cnaarc th+ceqsremen: r'a'ed therein ::e e treet,la9 pee:able,'
ette""Sle, cantaifxulequateweeptarce end rejee:iaa cri:c::.. and-
....-....ca.....~........_.........-
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+
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ss s ug sy T J '., ufMN ytWG ftHNhRifHefNtK! [T,T : {!.ecl Ment-O[!be 1
1 paICsi'iInC O[Unw'N s
f
.Y m-
m._
QUALITY ASSURANCE POLICY Revision:25.
- 11 0.
Incorporate the requirements of 10 CFR 21 for Nuclear Grade procurements.
-11.
. Include requir.
for. QA program elements. to be passed on to sub vendors.
.1B ; 5.
-INSTRUCTION
S. PROCEDURE
S. AND DPM INCE Controls delineate the sequence of actions to be. performed in the preparation, review, approval, and control of instructions, procedures, and drawings.
Controls require that:
^
- 1.
. Methods-for complying-with each of,the applicable criteria of 10 CFR 50,
- 4ppendix.B,L aust be specified in instructions, procedures, and drawings.
L2.
Instructions,-
proce'dur.s, and drawings must specify appropriate quantitative- (such as. dimensions, t.olerances, and operating limits) and qualitative (such as workmanship samples) acceptance criteria for verifying that important activities have been satisfactorily accomplished.
Controls ensure that:
]
11 '.
l The QA Policy is approved-by the Vice President Nuclear Energy. Division.
'(1).
2.,
QAPs :are? developed -by Departments responsible for conducting particular activities,. reviewed by the : managers of the responsible department (s) for that particular activity, and approved by the Vice President Nuclear Energy
' Division.
(1)-
3.-
Department Procedure; are approved and controlled by the responsible Departments and concr, croceduressare reviewed by the Qu ty Audits Unit
- (QAU)T.
E4.
Plant,- section, and. unit procedures that control the topics, contents,
- review, approval, issue, distribution, and revision of plant, section, and unit procedures. that specify how-activities are to be-performed are reviewed by a member of QAU.
5. --
Other plant, section,'or unit procedures that specify hou activities are to.
be performed Jare controlled by theiresponsible orgariaation and reviewed
.and approved within'the responsible organizationr 16;.
The basis for changes to all procedures will be-recorded. (1) l-1B,6)
DOCUMENT CONTROL.
I 1Re'quirements have. ;been established to control the documentation of activities-controlled by the QA Program.
Controlled documents include the.FSAR for CCNPP; QAPs in the BG6E Quality Assurance Manual'for Nuclear Power Plants; department, t
section, unit, and plant procedures that implement the QAPs; specifications; and drawings.
f I'
Page 24 of 60 l
l ll
' QUALITY ASSURANCE POLICY Revision 25 QAPs are required to:
1.
Establish controls to ensure that regulatory requirements and BC&E commitments will be implemented, 2.
Describe interdepartmental interfaces and establish controls for l
interdepartmental activities, l
3.
Specify how important activities, such as plant maintenance or in service inspection, are to be performed, and give sufficient detail to control the procedures are clearly specified.
- requirements for lower level performance of the activity or to ensure that 4.
Be prepared and edntrolled in accordance with one QAP that describes the format; sequence of topics, contents, review and approval,- issue and distribution, and requirements for revision and record retention.
During the review of each QAP, coopliance with applicable criteria specified in 10 CFR 50, Appendix B, is verified and documented.
The Manager NSSD, is responsible for issuing, revising, and controlling QAPs, QAPs _are developed by one of the depa tments responsible for the subject l
~ activities.
Each procedure is given a corpliance review by a member of the QAU, and technical review by a member of one of the responsible departments. Each QAP is reviewed' by department manager (s) _ who have responsibilities. for activities governed by that QAP, and the Managers of the Nuclear Energy
- Division, (1)
Each' QAP is approved. by the Vice President Nuclear Energy Division and issued by the Manager NSSD, (1) i
- Department procedures are prepared when interfaces or activities within a
' department are not defined in a QAP or when they are needed to specify the
' content of plant, section, or-unit procedures.
As needed, department procedures describe how requ:,rements delineated in a QAP will be implemented at the department level.
They describe the interfaces between groups or units within a department and specify requirements to be-met by lower level documents, When two or more departments are closely involved in performing ar. activity that requires more detailed instruccions than are contained in a QAP, the activity is controlled by a common department level procedure provided that the managers, or their designee, of the affected departments agree to use this procedure, and managers or their designee, review revisions to those portions of the procedure that_ affect their department.
' Individual departments - are responsible fo*: preparing, issuing, revising, and i
controlling department procedures.
These are prepared and controlled according to a departmeat procedure that describes f ormat,. sequence of toptes, c ontent.s,
review and approval, issue and distribution, and requirements for revision und record retention.
l Page 25 of 60 1
QUAL 1TY ASSURANCE POLICY Revision 25 Each department procedure is given a technical review by a member of the same department.
QAU is required to perform compliance reviews of controlling procedures.
Other procedures are reviewed by QAU on a requested basis, plant, section, or unit procedures are prepared to describe how requirements delineated for subgroups within a department will be implemented when these requirements are not delineated in sufficient detail in QAPs or department procedures.
When two or more departments are closely involved in performing plant activities that require more detailed instructions than are contained in a QAP or department procedure, the activity is controlled by a common plant procedure provided that the managers, or their designeci of the affected departments agree to use this procedure.
Manegers, or their designee, review revisions to those portions of the procedures that affect their department.
, Functional groups within departments prepare, issue, revise, and control the procedures that control their work.
Group procedures must be reviewed by a member of the group, and may be reviewed by QAU, Group procedures are prepared and controlled according to control procedures that describe format, sequence of topics, contents, review and approval, issue and distribution, and requirements for revision and record retention.
Control procedures are reviewed by a member of QAU.
. Organizations that issue instructions, procedures, specifications, or drawings are required to establish controls that ensure the following:
1.
Changes to a document are reviewed and approved by the organization that performed the original review and approval unlese the control procedure designates another qualified responsible organizatan.
2.
Approved changes are promptly incorporated into instructions, procedures, drawings, and other documents associated with the change..
3.
Obsolete or superseded documents are controlled to reduce the possibility of inadvertent use.
Superseded documents retained for reference are marked and stored in separat-files.
Other superseded documents are removed from the files.
When changes to drawings or specifications are-required, cb.nge requests are prepared by the organization that desires the change.
Requests are reviewed and approved by BG6E RDos.
1B.7 CONTROL OF PURCHASED M.ATERIAL. EOUIPMENT. AND SERVICES (5)
Afb t
NQAD, NS$
nd PMMD personnel are responsible for the contr)1 of purchased items and services for SR and designated NSR applications.at CCNPP.
The controls include:
Accepting items or services only from vendors who have been evaluated and selected in accordance with this policy.
Page 26 of 60
QUALITY ASSUPM CE POLICY Revision 25 Procurement documents for spare or replacement parts of structures, systems, and components as designated under the QA Program subject to controls at least equivalent to those applied to the original equipment, or an evaluation / justification shall be documented when less stringent controls are involved.
Vendor surveillance, verification and audit activities, and receipt verincation are conducted to ensure the vendors comply with specified technical and quality requirements, and ensure items are identified, stored, handled and shipped in accordance with procurement document requirements.
Vendor Evaluation
_Tha vendor evaluation is conducted to determine acceptability of a vendor to provide the requented item or s e rvic e,_ to determine what vendor programs, procedures and documents need to be invoked by the procurement document, determining the vendor's performance history for supplying items to CCNPP and assessing the need to impose source surveillances and/or verifications during the manufacture of items or performance of services for BG6E.
Vendor evaluations depend on the procurement classification of the item (s) being supplied.
The National Institute of Standards and Technology (NIST), by virtue of its being the nationally recognized standard, is an acceptable provider of calibration masters, standards or services.
Utilities holding an NRC Construction Permit or Operating License are acceptable suppliers of all items except those defined as ASME materials.
Neither of the above are required to be listed on the Approved Vendors List (AVL).
Naclear Grade NQAD performs evaluations and audits to verify that the vendor has developed and implemented ar. acceptable quality assurance program that complies with the requirements specified in t' a procurement specification or proposed procure- 'nt specification.
These evaluations and audits are canducted and doct.ented using written procedures or checklists that l
identify-the QA requirements applicable to-the items supplied.
-Since BG6E accepts the responsibility of verifying the conformance of commercial grade items, they may be. procu.ed from vendors with no formal quality assurance program.
In this instance, BG6E dedicates the commercial grade item for SR use.
A survey may be performed of commercial vendors to assess what, if any documented controls are implemented in the manufacture of items or performance of services for BG6E.
l Vendor controls evaluated to be satisfactory may be invoked as requirements l
within the purchase order and may be used as part of the basis for l
acceptance of the item.
Page 27 of 60 l
l l
t
QUALTTY ASSURANCE POLICY Revision 25 The depth of vendor evaluation varies according to the comp)ixity and function of the item involved and to the role of the vendor in acceptance of the item, yendor Aporoval Upon completion of the evaluation, satisfactory vendors are added to BC&E's AVL.
The vendors on this list are evaluated on an ar.nual basis and subject to re audit or commercial grade survey on a trienniel basis to verify continued compliance with BG6E's requirements, An auditing organization such as NUPIC, at th; T contractor to BG&E, etc., may be used to verify that the vsnouf h J and implemented a QA program that complies with 10 CFR 50, App;n, nercial grade program that complies wich the requirements of 1.-
procurement requirements or similar requirements, i
k'he n required by operational considerations, an order may be placed with a vendor prior to completion of the evaluation and approval process only af ter obtaining the Manager NSSD's approval.
BC&E's acceptance of basic component items or services provided by an unapproved vendor is contingent un the subsequent NQAD evaluation and approval of the vendor as stated above.
' Verification of Vendor Activities Vendor surveillance, and-source verification activities are conducted by qualified NQAD personnel in accordance with written procedures or checklists, These procedures or checklists, along with the procurement documents, specify the characteristics or processes to be witnessed, inspected or verified, Personnel performing these activities are qualified to establish whether or not a vendor is capable of providing products of acceptable quality.
The depth and frequency of vendor surveillances, verifications and audits is aommensurate with the complexity and function of the item or service and the
.bility of the vendor to providt the necessary assurance of acceptability.
ihen a vendor's certificates of conformance are used as part of the acceptance of an item or service, the validity of these documents is periodically evaluated and documented by the above mentioned processes, Recelot PtetD is responsible for receiving and storing materials, parts, and components.
Additionally, NQAD is responsible for performing standard and special receipt inspections and coordinating testing necessary to accept SR items, designated NSR items and commercial grade items for SR use.
Standard receiving inspection of items is performed to assure the following:
1.
The -item is properly 4.dentified and that this identification cot esponds with the documentation received.
l Page 28 of 60
-. -.. -.. _..-.-.-.. -. _. - -... - ~ -. - -.
. QUALITY ASSURANCE POLICY'
-Revision 25 2.
Stated packaging,-shippins and handling requireme ts have been maintained.
3, Items have _ not ' been damaged, workmanship is-of-adequate = quality, and the-
~
items are adequately clean in accordance with -procurement document requirements.
24.
Documentation:. required by the Purchase Order has been received and is reviewed to assure that the item conforms to the purchase order requirements.
- Special receiving inspection may be require. if the item was not inspected at the source; when requested - by the RDO or; as part~of the acceptance basis for commercial grade items.
' A-- written ; record -- of the results of the NQAD receipt inspection -and' the disposition of received items is maintained an part of permanent plant records.
All.SR and designated NSR items accepted and released forzissue to a controlled storage area or released for installation or further work bear an acceptance tag and have documentation to support their acceptability.
If traceability is lost
-or the documentation review is - unsatisfactory, an item becomes subject to the controls established for non conforming items.
'Non conforming items are identified and handled in accordance with Section 1B.15 s
of this policy and, when practicable, are placed in a segregated area to prevent inadvertent installation-or use until proper disposition is made.
Documentation BG6E procurement documents require vendors to provide documentation identifying the purchased item and the specific procurement requirements that are met by the item.
Vendor inspeccion records or-certificates of conformance attesting to' acceptance must_ be in the possession of BG&E before the item may - be released for installation or use.
However, an unacceptable item may be given a " Conditional Release" if there' is _ reasonable assurance that it can'be'made acceptable after installation but.before the system that'contains it is considered operational.
Items L released :under " Conditional Release" must ' be controlled under the Non
- Conformance Report (NCR) systen.
Vendor requested -- deviations from procurement document requirements, including nonconformances dispositioned "use as is" or " repair" mus bel submitted to BG6E-for evaluation and approval of, th'e deviation or a recommet.ded disposition prior to shipment, I
Page 29 of 60
QUAL.ITY ASSURANCE Poi. ICY Revision 25 18.8 IDENTIFICATION AND CONTROL OF RATERI ALS. PARTS. AND COMPONENTS (5) f AlisD/NEL 4-HQ& personnel ensure that procurement documents require that SR and designated NSR items, including partially fabricated sub tssemblies, are identified and controlled to prevent the use of incorrect or defective material.
Requirements for identification by use of heat number, part number, or serial number, or by other means, are referenced or stated in procurement documents.
These documents require the identification to be placed on the item or in records traceable to the item so that the function and quality of the item are not affected.
This identification is required to be maintained throughout fabrication, storage, erection, installation, and use.
NQAD personnel ensure traceability information is correctly transferred when an item is sub divided.
Assigned PKMD personnel purchase identify, store, and issue items as specified by procurement controls and provide for maintaining the integrity of items and their traceability to associated documents during storage and issue.
BG&E contractors and their sub contractors (who are approved to work on site undar their own QA program) are responsible for establishing and implementing programs in accordance with specified requirements for identifying and controlling materials, parts, and couponents under their jurisdiction.
Identification of items important to the function of SR and designated NSR structures, systems, and components can be traced to appropriate documentation such as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and chemical mill test reports.
Recelot SR and designated NSR items.cceived at CCNPP are receipt inspected to verify that all requirements of the procurement documents have been met.
If a discrepancy is observed, such as damage or missing documentation, information to the effect is recorded on the receiving inspection report, and the discrepant item is identified as such and placed in a separate
" hold" area when practicable.
If the item is acceptable, it is identifled to indicate acceptance and that it is approved for storage or installation and use.
'w' hen groups of items in storage are subdivided, each subgroup is separately identified.
If.an item is found to be or is made discrepant during processing, it is identified as such and placed in a separate area when practicable.
Acceptance documentation is required to be traceable to a purchase order, drawing, spe c ifier. tion, requisition number, or assembly.
As individual items are assembled, installed, and inspected, their acceptance tag numbers are recorded in plant maintenance or operation records.
Af ter completion of tests and inspections, records that document test results and traceability are kept as part of the plant records.
Page 30 of 60 l
QUALITY ASSURANCE POU CY Revision 25 IB.9 CONTROL OF SPECL W OCESSES Controls Controls have been established for writing, qualifying, approving, end issuing procedures to control such special processes as welding, heat treating, and nondestructive testing used during the operation of CCNPP Special Process Procedures:
1.
Are prepared in accordance with applicable
- codes, standards, specifications, criteria, and other special requirements.
2.
Ensure that special processes are performed by qualified personnel according to qualified procedures that comply with applicable regulatory requirements.
3.
Specify requirements for control, p rameters to be considered, acceptable nethods of documentation, and th<
.ndes, standards, specifications, or criteria which govern the qualifica '
4.
4.
Define the necessary qualification of personnel, procedures, or equipment when special processes are not covered by existing codes or standards or when quality requirements 'for an ' item exceed the requirements of established codes or standards.
BG6E contractors and their sub contractors are responsible for controlling special processes used by them and for maintaining re cords to verify that special processes are performed in. accordance with requirements established by the portions of their QA programs that apply to special processes.
-Oualification of Methods Procedures, equipment, and personnel connected with special processes are qualified in accordance with applicable codes, standards, specifications, or supplementary requirements as follows:
1.
Welding activities conducted by BG6E are performed according to welding procedure specifications qualified in accordance with applicable welding requirements of the ASME Code.
Each welding procedure specification is
- written, qualified, and approved in accordance with a controlling documented procedure.
Copies of welding procedure specifications are made available to welders and, when required, to Authorized Inspectors.
Before contracting for welding, the Principal Metallurgist reviews and approves non BG6E weldhg procedure specifications and procedure qualification records in accordance with a written procedure.
2.
Heat treating requirements included in welding procedure specifications are established in conformance with heat-treating requirements of the applicable ASME Code.
3.
Nondestructive Examinations are performed to written procedures proved by actual demonstration, when practicable, to the satisfaction of t h e.
Principal Metallurgist and, when required, the Authorized Inspector.
Page 31 of 60
QUALTTY ASSURANCE f 0LICY Revision 25 l
l These procedures are prepared according to appropriate sections of the ASME Code for particular examination methods.
Procedures, personnel qualifications, and the records enat verify the Performance of Nondestructive Examinations are kept es nuclear plant records.
Nondestructive Examination Procedures describing methods not described in the ASME iode and/or SNT TC 1A and its Supplements are at least equivalent to those recognized by the American Society of Mechanical Engineers and the American Society for Non destructive Testing.
Training nrograms acceptable to the Principal Metallurgist are developed to complement
.aese alternative methods and to establish the capability of personnel to perform the required examination according to BC&E procedures and to the level of performance to which the individaal will be certified.
Methods of Nondestructive Examination include, but are not restricted to, radiographic,
' ultrasonic, liquid penetrant, magnetic particle, eddy current, visual, and leak testing examinations.
Procedures are prepared to cover these examinations in accordance with a QAP that details the specific examination, requirements for approval, and content of the procedure, such as certification level, accept / reject criteria, examination coverage and sequence, surface preparation, test equipment, records required, permissible marking, cleanup requirements, and reference to applicable sections of the ASME Code.
Qualification of Personnel Special processes are performed by certified personnel using written process
- sheets, shop procedures, checklists, and travelers (or equivalent),
with recorded evidence of verification as follows:
1.
BG6E welders.
ad welders under contract to BG&E. are qualified and certified in acev u.u. e with the requirements of Section IX of the ASME Code and the welding procedure specifications they will be using when velding.
The Principal Metallurgist maintains records of the welding procedure specifications, including essential variables under which the welders are examined, and the results of the examinations.
A welder is not permitted to weld SR and designated NSR items until an appropriate performance qualification record, a letter of certification, or, in an emergency, verbal clearance from the Principal Metallurgist, is on file at CCNPP.
Ec.ch welder is required to be requalified as specified in the applicabic code.
2.
Non BG6E welders are not permitted to weld SR and de;ignated NSR ltems until they are qualified and certified in accordance with Section IX of the ASME Code to the welding procedure specification they will be using.
3.
Nondestructive Examination personnel employed by or responsibin to BC&E are certified according to applicable sections of the ASME Ccde and/or SNT TC 1A and its Supplements.
BC&E employees are trained and certified in accordance with a written procedure, Non BG6E personnel are qualified to procedures approved by BG&E, and their qualifications and certifications of personnel are verified according to written procedures.
Page 32 of 60
i Q"ALITY ASSURANCE-POLTCY i
Revision 25-
, Qualification. records of procedures, equipment,. and personnel associated with special= processes conducted by BG6E are filed and kepc curront by the Principal
, Metallurgist.
- The Manager NQAD
- provides -independent verification chat' special processes are
_ performed by qualified personnel.
1Bl.10, INSPECTION 4
Activities'that affect the quality of SR and designated NL2 items are inspected as_specified in approved ins truc tio-procedures, and plans which set - forth requirements and acceptance criteria
.o ensure that work is done in conformance with-particular requirements.
Controls. exercised dut ing. inspections ensure that:
1.
Personnel who periorm qu.ality verification !nepections are independent of the personnel _ who performed the activity being ins pected.
J2.
Inspection procedures or instructions, with necessary drawings and specifications for use, are available before inspection operations are perforned.
3.-
In-ene case of special processes, inspectors are qualified, and their qualifications _ comply vich applicable codes and standards.
4 Test and measuring equipment is calibrated within required limits, 5..
Inspection-proceduras, as applicable, specify objective acceptance criteria, L prerequisites 'for performing inspections, limiting conditions, requirements for _ special equipment and Quality Verification (QV) hold points at which inspections are to be witnessed.
6.
'Approhriate_ inspection requirements are. established for modification, l repair. and replacement.
7.-
Personnel who perform : quality verification inspee,tions are qualified in accordance with appropriate
- cens, standards, and Company-training-programs,- and their qual.ification; and certifications are kept current.
8.
Procedures: for maintenan.ce and modification are-reviewed by QV personnel to determine-the need for. independent? inspection and the degree and method if
.such an --inspection - _is required, and-to - ensure the identification of inspection personnel and the documentation of inspection results.
9.x Procedures 'for Nondestructive Examination and Nuclear Fuel Inspection are reviewed. by -qualified personnel in Nuclear Engir.eering Departme nt.
to-determine the need; fer independent inspection and the degree-and method if such an ' inspection - is required, and to - ensuro _ the identification of inspection personnel and the documentation of-inspection results.
Page_33 of 60
QUAL.ITY ASSURANCE POLICY Revision 25 10.
Inspection results are recorded, evaluated, and retained.
Inspection procedures, instructions, and checklists used by QV personnel provide the following:
1.
Identification of characteristics to be inspected.
2.
Identification of individuals or groups responsible for performing the inspection.
3.
Acceptance and rejection criteria.
s 4
Description of the method of inspection.
5, Identification (including revision number) of required procedures, drawings and specifications.
6.
Identification of inspector or data recorder.
7.
Verification of completion and certification of inspection.
8.
Record of results of inspection.
9.
Provision for identifying mandatory inspection hold pointa for witness for an authori::ed inspector or BG6E inspection personnel.
10.
Provision for indirect control by monitoring processing methods, equipment, and personnel if direct inspection is not possible.
11.
Specification of necessary measuring and test equipment including requirements for accuracy.
The General Supervisor-Quality Verification (GS-QV) is responsible for the preparation and implementation of procedures for activities conducted by Quality Verification personnel.
{
Other inspections are conducted randomly to verify that overa'.1 plaat operations are being conducted according to approved procedures and tr ensure that the use of jumpers is properly documented; that equipment is returned to operating status after test. modification, or repair; that instruments are properly calibrated; and that personnel who perform tests are properly trained and qualified.
In-service inspections are performed on pressure-containing components within the reactor coolant system boundary according to requirements of the TSs.
In.ser/ ice inspections and examinations on components designated Class I or Class II by the ASME Code are witnessed or otherwise verified by an authorir/
Code Inspector who is responsible for ensaring that the work is performed oy qualified personnel according to writte, qualified procedures.
Records of in service inspections,
- results, corrective action recuired and
- tskin, inspection standards required for repair, and results of ins;:cetion of repait s are maintained and compared with the results of subsequent examination, l
Page 34 of 60 l
i
QUALITY ASSURANCE POLICY Revision 25 4..
1B,11 TEST CONTROL l
To demonstrate the ability of SR and designated NSR vnuctures, systems, and l
components to function as designed, they are subj e t tv.i to a program of l
surveillanc e and operational testing.
Procedures spectfy the systematic development, review, approval, and conduct of tests and raview of test results.
Conditions such as
- failures, mal func t io r.r.,
deficiencits, deviations, and non conformances discovered during testing are documented and evaluated, Whenever testing is required to demonstra;.e that SR and designed NSR material, parts, components, or systems will perform satisfactorily in s e rvic e, a test program 'i s established and procedures are used that bave been written and approved in accordance with basic requirements, Nuclear" Engineering Department, and CCNPPD conduct tests to verify that plant behavior confo rms to design criteria, ensure that failure and substandard perfo rmance are identified and controlled, and demonstrate satisfactory performance after plant modification and maintenance activities.
Written test procedures are developed, reviewed, and approved before esting is pe rfo rme d.
They specify instructions for testing, methods of
- . : t,
test l
_ equipment, and instrumentation; and for the following as applica,ble:
1.
Adequate and appropriate equipment.
2.
Preparation, condition, and completeness of item to be tested.
l 3,
Suitable and controlled environmental conditions.
4.
Mandatory inspection hold points for witness by BG&E inspection or aurhurized inspector personnel,
,5.
Provision for data collection and storage, i
E 6.
Acceptance and rejection cr!.teria, 7.
Methods of documenting or recording test data and results.
l 8.
Provision for ensuring that test prerequisites have been met.
l l
Test results are documented and evaluated; they are accepted or rej ected by a qualified, responsible individual or group.
With the exception.
testing performed as part of receipt inspection and of completed surveillance testo performed without malfunctions or out of specification data, results of tests are reviewed and evaluated by the POSRC and. accepted and approved by the Plant General Manager, Test records are kept.in sufficient detail to make possible an evaluation of test results and to show how individual tests demonstrate that SR and designated NSR structures, systems, and components and the plant as a unit can operate safely and as designed.
SR and designated NSR test records are retained as plant history records.
Page 35 of 60
i QUALITY ASSURANCE POLICY Revision 25 Results of testing performed as part of receipt inspection are evaluated, accepted and approved by qualified NQAD personnel. (5) 1B.12 CONTROL OF MEASURING AND TEST EOUIPMENT Calibration controls 'have been established to prescribe the technique and frequency of calibration, maintenance, and control of measuring and test instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive test equipment used in measuring, inspecting, and monitorine SR and designated NSR components, systems, and structures during the operations jphase of.CCNPP.
Personnel of the following functional organi:ations control, calibrate, and adjust measuring and test equipment:
Electric Test Department Calvert Cliffs Nuclear Power Plant Department
- Radiation Safety CCNPPD Performance Engineering Unit Mechanical Maintenance
- Electrical and Controls Nuclear Operations Chemistry Calibration controls require each group to identify measuring and test equipment and calibration test data related to it.
k'ritten procedures are prepared and implemented to ensure that tools, gauges, instruments, and related test and measuring devices are of proper accuracy to verify conformance to established requirements.
Manufacturer's Procedures are used for calibration or a procedure is prepared for each category of measuring and test equipnent as necessary.
These Calibration Procedures contain the following informt. tion:
1.
Identification of the item to be calibrated and its period of calibration.
2.
Standards to be used, specific test points, and checks,
- tests, and measurements to be made.
3.
Acceptance criteria to be used and special precautior.s to be taken when necessary.
Measuring and test equipment that require calibration are assigned an identifying serial number.
Instruments are calibrated at specified intervals according to the required accuracy,
- purpose, degree of usage, stability characteristics, and other conditions that affect the measurement.
i l
l Page 36 of 60
QUALITY ASSURANCE POLICY Revision 25-When equipment is found out of _ calibration, an evaluation is made by the supervisor responsible for that equipment to determine any adverse effect on items previously accepted on the basis of using that equipment.
Test and measuring equipment that cannot be adj us ted to required t ole r *.nc e s during calibration is identified and placed in a designated segregated atsa; if the equipment can be used in limited applications, the limitations are identified.
The status of each item contrdled under the cultb ation system is recorded and maintained.
Equipment is markeo or records of
- .ibrations are maintained to indicate calibration status.
An interval of cali-tion is established for each item of measuring and test equipment and recorded on a master record of calibrations prepared as a calibration schedule.
Measuring and test equipment is controlled to prevent the use of uncalibrated or defective equipment, the spread of radioactive contamination, the introduction of impurities into high purity systems, and damage to or loss of equipment.
Identification tags are placed on measuring and test equipment to indicate such special conditions as radioactive cleanliness, special limitations, or failure to meet established calibration requirements.
Measuring-and test equipment is calibrated and adjusted at speelfied intervals, or before use, against certified standards.
Reference and transfer standards are traceable to nationally recognized standards; or, where national standards do not exist, provisions are established to document the basis for calibration.
l IB.13 HANDLING. STORAGE. AND SHIPPING l
Appropriate and special requirements for handling, preservation,
- storage, cleaning, packaging, and shipping of SR and designated NSR items are specified in procurement documents.
Procedures -have been established to ensure that the handling, preservation,
_ storage, cleaning, packaging, and shipping of SR and designated NSR items are
' performed in accordance with specified requirements to reduce the likelihood-of damage, loss, or deterioration by such-environmental conditions as temperature or humidity.
Special handling, preservation, storage, cleaning, packaging, and shipping activities associated with SR and designated NSR items are performed by suitably trained personnel in accordance with specific written procedures.
l Controls have been established for the safe storage of hazardous materials.
Items with a limited shelf life are controlled to ensure that they will not be used in SR and designated NSR applications after expiration of designated shelf life periods.
Page 37 of 60
~
QL.iLITY ASSURANCE p0LICY Revision 25 1B'.14 INSPECTION. TEST. AND OPERATING STATUS Controls have been established for the application and removal of status indicators such as tags, markings, labels, and stamps to ensure that the inspection, test, and operating status of SR and designated NSR structures, systems, and components is clearly indicated at all times, procedures / instructions are prepared to identify and control inspection, identify testing, and operating status by the use of lo6s, forms, and tags the inspection,
- test, and operating status-of structures, t,,tems, and
- components; control the use of indicators, including the authority for their application and removal; control bypassing operations, such as jumping or temporary removal of electrical leads; and identify non conforming, inoperative, or malfunctioning structures, systects, or components.
Senior shift personnel are responsible for
- aligning, isolatin5, and appropriately tagging installed equipment and systems so that activities affecting quality can be performed.
The Manager-NQAD is responsible for the performance of surveillances to verify that the inspection, testing, and operating status of structure., systems, and components are properly identified and controlled during optr;.cibn, maintenance,
-and testing of the plant.
The bypassing of required inspections, te ts, and other crit ical operations is controlled to ensure that bypassed inspections or tests are properly documented and that the effect of bypassing the inspection or test is evaluated by the organization responsible for specifying the inspection or test.
Controls have been established to ensure that the status of non conformirg, inoperative, or malfunctioning SR and designated NSR structures, systems, or components is
-identified to prevent inadvertent use.
1B.15 NON CONFORMING MATERIALS. PARTS. COMPONENTS OR ACTIVITIES (6)
Controls %ve been established for identifying, documenting, segregating, reviewing,
- ispositioning,- and notifying af fected organizations of Conditions Adverse to luality affecting materials, parts, components (i.e.,
items) or activities.
I Conditions Adverse to Quality _ specifically affecting nuclear plant items or activities are referred to as-nonconformances.
Nonconformances are deficiencies in chn acteristic, documentation, or procedure which render the quality of an item or activity unacceptable or indeterminate.
Any individual identifying a suspected nonconforming condition is responsible I
for documenting and reporting such condition promptly to su ervisory or Nuclear i
Quality Assurance Department personnel.
Nonconformances are reviewed by designated individuals for impact on Technical Specification operability, hts.C reportability, safety significance and whether work shall be stopped.
1 page 38 of 60
QUALITY ASSURANCE POLICY Revision 25 Nonconforcances are controlled by documentation, marking, logging, tagging or physical segregation to prevent inadvertent use or installation.
Nonconformance control documents are submitted to responsible departments for resolution.
Designated personnel have the responsibility and authority for approving the resolution of nonconformances.
Nonconformance control documents are not closed until corrective actions have been verified.
Nonconforming items are dispositioned as
- rework, repair,
- reject, or accept-as is.
Dispositions are independently reviewed prior to implementation.
The disp 6sition of a repair or accept as is nonconformance is treated as a
~
design change and is evaluated and approved or rejected by the RDO.
Reworked, repaired, and replacement items are inspected and/or tested in accordance with the original inspection and/or test requirements or acceptable alternatives to ensure that critical characteristics possibly af fected by the nonconformance remain acceptable.
Nonconforming items may be conditionally released for installation,
- tests, energi:ation, pressurization, or use if the conditional release will not adversely affect nor preclude identification and correction of the
'nonconformance.
Nonconforming items required for Te chnical' Specification operability may be released for use following verification that the nonconf orming item meets all operability requirements specific to its function and is appr sved for use by authorized Operations personnel.
Conditionally released items will be resolved in accordance with this Section.
Conditional telease evaluations are documented,
- reviewed, and approved prior to implementation.
Nonconformances are periodically analyzed for the identification of adverse quality trends.
The existence of an adverse quality trend is resolved in accordance with Section 18.16.
A Trend Report is issued to management at intervals specified in approved procedures, z
1B.16 CORRECTTVE ACTION (6)
Controls have been established to ensute that Conditions Adverse to Quality are identified documented reviewed and corrected.
These controls are applied to deficiencies associated with the programmatic content and implementation of the Quality Assurance Program as well as material, part, component or activity related nonconformances (ref Section 1B.15).
Corrective actions include immediate actions, remedial actions and actions to prevent recurrence, based on the significance and extent of the adverse condition and are implemented by responsible personnel.
Conditions Adverse to Quality are evaluated for NRC reportability.
The VP NED, or designated alternate, is informed of adverse conditions that require NRC notification.
Corrective action verification is performed for Conditions Adverse to Quality prior to the close-out of the corrective action document.
Verification is performed and documented by indLviduals not directly involved with implementing Page 39 of 60
...~.
QUALITY ASSURANCE POLICY Revistcn 25 the corrective action (s).
Unacceptable correctivo action (s) are reported to
- supe rvisory or management personnel directly responsible for resolving the adverse condition with progressive escalation to higher levels of management occurring until the adverse condition is resolved.
Significant Conditions Adverse to Quality require the initiation of root cause analysis-and the implementation of corrective actions to prevent recurrence and are reported to management for review and assessment.
Conditions Adverse to Quality are periodically analyzed foi the identification of adverse quality trends.
The existence of an adverse quality trend is resolved in accordance with this section.
A Trend Report is issued to management at intervals. specified in approved procedures.
1B.17 OUALITY ASSURANCE RECORDS controls have been established to ensure that quality assurance records are maintained to provide documentary evidence of the quality of SR and designated NSR items and activities.
Applicable design specifications, procurement documents, test procedures, operational procedures, QAPs,
- TSs, and other
, documents specify records that, should be generated, supplied, or maintained by and for BC6E.
Quality assurance records are classified as lifetime or non permanent, Lifetime records, maintained for particular items for the life of CCNPP, for particular items have significant value in relation to demonstrating capability for safe operation; maintaining, reworking, repairing, replacing, or modifying an. item; determining the cause of an accident or malfunction of an item; and providing required baseline data for in service inspection, Non permanent records, which show evidence that a SR and designated NSR activity was, performed in accordance with applicable requirements, are retained for periods sufficient to ensure BC&E's ability to reconstruct significant events and to satisfy applicable regulatory requirements.
Retention periods are specified in the TSs or in procedures that control the performance of activities.
Procurement documents specify vendor responsibilities for the generation, retention, and submission to BC&E of quality assurance documentation related to the - fabrication, inspection, c;.d test of SR and designated NSR items and services.
Inspection and test records contain the fellowing as appropr iate:
1.
Description of the type of observation.
2.
Date and results of inspection or test.
3.
' Info rmation related to noted discrepancies, including action taken to resolve them.
4, Identification of inspector or recorder of data.
Page 40 of 60
QUALITY ASSi'RANCE POLICY Revision 25 5,
Statement as to acceptability of results.
Controls have been provided to ensure that records are protected from possible destruction.
Within established time intervals, completed lifetime records are transmitted to the Nuclear Plant Document Control Unit for incorporation into the Record Retention and Retrieval System, 1B,18 AUDITS Internal
- audits are performed by BC6E's Quality Aucits Unit to ensure that activities and procedures established to implement the requirements of 10 CFR 50, Appendix B, comply 'vith BC&E's overall QA Program.
These audits provide a comprehensive independent verification and evaluation of quality related activities and procedures.
Audits ensure the effective and proper implementation of BC6E's QA Program.
They are scheduled on the basis of the importance to safer.y of activities being performed.
l Vendor audits are performed to evaluate QA pro 5 rams, procedures, and activities.
Audits of major vendors are made early enough to ensure compliance with all aspects of BG6E's procurement documents.
Additional audits are pe rformed as
" required to ensure that all requirements of BG6E's QA Program are properly implemented according to procurement documents.
Audits of designated activities as required by the TSs are performed under cognizance of the OSSRC.
Audits are performed in accordance with preestablished written procedures or l
checklists by qualified NQAD personnel _who have no direct responsibility for the work being audited.
Technical specialists from other BG6E departments and l
outside consultants may assist as necessary in performing audits, Audits
, include objective evaluation of quality related practices, procedures, instructions, activities, and items, as well as review of documents and records.
Reports of audits are analyzed and documented.
Results that indicate the QA Program to be inadequate, ineffective, or improperly implemented, including the need for re audit of ceficient azeas, are reported to the Manager and Supervisor of the audited activity.
Controls have been cstablished for verifying that l
corrective action is taken promptly to correct noted deficiencies.
To ensure that BC&E's NQAD complies with the requirements of BG6E's QA Program, an independent management audit ~of NQAD activities is performed annually by a Joint Utility Management Audit (JUMA) Team.
1 Page 41 of 60
QUALITY ASSURANCE POL 2CY Revision 25 TABLE IB 1 BALTIMORE CAS AND ELECTRIC COMPANY'S POSITION ON CUIDANCE CONTAINED IN ANSI STANDARDS Revision of Industry Standards Apolicable to the Baltimore Gas and Electric Ouality Assurance Precram Recuirement
.Some of the Industry Standards listed in-Section 1B,2 identify other Standards that are-required, and some Regulatory Guides define the revisions of those Standards that are acceptable to the NRC.
Besconse BG6E's QA Program was developed to respond to the specific revision of the documents listed in Section 1B,2 and is not necessarily responsive to other documents listed in the referenced Industry Standards, ANS 3.2 - 1976 Item 1 Recuirement Section 5.2.1) requires that plant procedures shall oe reviewed by an individual knowledgeable in the area affected by the procedure every two years to determine if changes are necessary or desirable.
Response
BG6E applies this requirement of a two year review to all plant procedures except test procedures performed less often than every two years or at unspecified - frequencies.
These are reviewed no more thar, 60 days before performance, A one time extension of the two year review requirement has been allowed for plant procedures until they can be addressed under the Procedure Upgrade Plan (PUP) conditional upon a documented justification, Procedures that have lapsed periodic reviews and that-do not have a documented justification for continued use will be - restricted from use until they are either reviewed or justification (by individual procedure or by type) is provided.
The extension
-will expire for each procedure on an individual-basis once it has been revised under PUP.
The PUP is described in the Performance Improvement Plan transmittal
-letter from G. V. McGowan (BG6E) to J. M. Taylor (NRC), datad July 31, 1989, and is expected to be complete in December 1992.
(4) i l
Page 42 of 60 l
. ~ -.~ _
QUALITY ASSURANCE POLICY Revision 25 lltA12D Engineering Test Procedures (ETPs) and others like them are written for a one time only performance and kept for reference for future similar tests.
If they are used again, they are reviewed and modified to meet conditions existing at the time oi performance.
Some Surveillance Test Procedures (STPs) are performed every three to five years.
They too are reviewed before each performance to ensure that they are compatible with existing conditions and responsive to current needs.
Justification for the one time extension of two year review requirement is provided by a letter from Mr. M.
W. 1:odges of the USNRC to Mr.
C.
C. Creel of BC&E dated March 13, 1990, (4)
Item 2 i
Recuirement Section 5.2.2 specifies that temporary procedure changes that' clearly do not (
I change the intent of the approved proceoure shall as a minimum be approved by \\
two members of the plant staff knowledgeable in the areas affected by the procedure; and at least one of these individuals shall be the supervisor in charge of the shift and hold a senior operators' license on the unit affected, l
Response
BC&E does not require the Shift Supervisor to be the Senior Reactor Operator {
(SRO) approving temporary changes to procedures; any active SRO (either on shift or on staff) may provide the SRO approval for procedure changes, j
ILto.EO.D Many proposed temporary procedure changes do not require the Shift Supervisor's l
immediate attention or knowledge of the change since they do not affect plant
- safety, Other SR0s are available and qualified to perform this task since the l
Shift Superviser's detailed review of the proposed change is not necessary to l
ensure plant safety.
1 Requiring the Shift Supervisor to review all changes is burdensome and contrary f
to plant safety in light of the total number of procedures that exist and the time the Shift Supervisor must dedicate to ensuring the plant is safely operated g and wintained.
Additionally, our Technical Specification requires this approval be from someone holding an SRO license (not necessarily the Shift
)
Supervisor).
Page 43 of 60 4
QUALITY ASSURANCE F0i.lCY -
Revision 25 6NSI N18.1 - 3/j/21 Item _1 Recuirement Paragraph 4.2.2 states that at the time or initial core loading or appointment to the active position, the Operations Manager shall hold a Senior Reactor Operator's (SRO) License.
- Paragraph 3.2.1 states that positions at the functional level of Manager are those to which are assigned broad responsibilities for direction of major aspects of a nuclear power plant.
This functional level generally includes the plant -manager (plant superintendent, or other title), his line assistants, if any, and the principal members of the operating organization reporting directly to the plant manager and having overall responsibility for operation of the plant or for its maintenance or technical service activities.
Response
Baltimore Gas Electric has two positions in its organization, Superintendent-Nuclear Operations ~ and General Supervisor NucIcar Operations.
Neithereof these positions needs to individually meet all of the requirements of both paragraphs 3.2.1 and 4.2.2.
The S-No will satisfy paragraph 3.2.1 and most of 4.2.2 except that he will not maintain an SRO license.
Instead, the S NO
-will hold or have held an SRO license.
The GS NPO will hold and maintain an SRO license.
The GS NPO satisfies paragraph 4.2.2, but he does not satis fy 3.2.1 because he does not report directly to.the plant manager.
Reason The S NO will hold or have held an SRO license, as opposed to having a license.at the time of appointment to the position.
He will have an excellent understanding of plant operations.
The GS NPO will not only hold an SRO license at the time of appointment to the position, but he will maintain the license, nie GS NPO directly supe rvises the operating shift organization, whereas the S No is also responsible for operations procedure developuent, modifications acceptance, and operations /maittenance coordinations, The S N0's level of supervision 1does not require current indepth and plant specific knowledge which results from maintaining an SRO license.
ANSI N45.2.1 - 1973 Recuirement Subsection 3.2 outlines requirements for demineralized water.
Ecsoonse BG6E specifications for demineralized water are different than the specifications outlined in the standard.
Page 44 of 60
QUALITY ASSURANCE POLIW Revision 25 Peason BG&E specifications for demineralized water are consistent with guidelines provided by the Nuclear Steam Supply System supplier. _ BG&E specifications 1 are generally more restrictive than those specified by ANSI N45.2.1.
ANSI N45.2.2 - 1972 Item 1 Recuirement Subsection 2.4 could be interpreted to mean chat on site and off site personnel who perform any inspection, examination, or testing activities related to the packing, shipping, receiving, storage, and handling of items for nuclear l:
power plants shall be qualified in accordance with ANSI N45.2.6.
1Property "ANSI code" (as page type) with input value "ANSI N45.2.6.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. Resoonse BG6E requires that only persons who are responsible for approving items for acceptance - shall' be - qualified in' accordance with' Regulatory Gutde 1. 5 8 -- (which endorses ANSI N45.2.6) and that personnel who verify that storage areas meet l
. requirements will be qualified to either Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or ANSI N45.2.23.
Reason our receipt inspection procedures require persons who approve items for acceptance to be qualified in accordance with Regd atory ' Guide 1,58 (which endorses ANSI N45. 2. 6).
QV technicians, inspectors or QA auditors verify that storage areas meet requirements.
All other inspection, examination, and testing activities are subj ect -to review by persons. qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6).
i l
Item 2 Recuirement The second sentence-of Subse.: tion 2.4 requires that:
Off site inspection, examination, or testing shall be audited'and monitored by perconnel who are qualified in accordance with ANSI N45.2.6.
Resoonse I
BG6E uses personnel qualified in accordance with ANSI N45.2.23 to perform auditing and monitoring functions.
l l^
l l
Page 45 of 60 l
o-QUALITY ASSURANCE POLICY Revision 25 Reason The qualification requirements for auditors cannot always be met by persons qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6).
Item 3 Recuirement Subsection 2.7 requires that activities covered by the Standard shall be divided into four levels, though recognizing that-within the scope of each level there may be a range of controls depending on the importance of the item to safety and reliability.-
Response
1, The level of protective measures defined by Subsection 2.7 are applied to Basic Component purchases.
2.
Personnel of BG&E's Nuclear Engineering Department (NED) vill determine the level of protective measures to be applied to Commercial Grade purchases.
Reason BG&E's position is as follows:
1.
For Commercial Grade items, it is not always possible to assign-a level of classification in accordance with ANSI N45.2.2, as many items are purchased after they have been packaged by the raanufacturer and
-shipped to his local agent, the wholesaler.
2.
Experience has shown that the level of protection assigned to Commercial Grade items by vendors is adequate.
Item 4-
-Egouirement Subsection 3.0. specifies detailed requirements for packing items for each level defined in Subsection 2.7, f
Page 46 of 60 l
l l
l r
. QUALITY ASSURANCE POLICY Revision 25 Resoonse BC6E has' replaced Section 3.0 with the following:
1.
Packaging for Shipment to BG6E Personnel of BG6E's NED or NSSD shall ensure that procurement documents for Basic Component and Commercial Grade item purchases either indicate that the normal methods of packaging and shipment used by industry in general are acceptable for the items being procured or specify the level of protection assigned to the item and the
' requirement that the vendor conform to applicable requirements for items in that. classification defined in Regulatory Guide 1.30, Rev. 2
- March 1977.
2.
The normal _ methods of packaging used by the industry in general are acceptable for items being procured as Commercial Grade.
3.
Packaging for Storage by B06E In general the packaging used by the vendor to ship items for all types of purchases to BG6E need not be retained after the item is received by BC6E, provided that the item is stored in an area that meets the requirements for a storage area for the level of protection assigned to the. item.
Spe:ial or unique items, however, may require special protective measures.
For such unusual items, the Department that initiated the purchase, together with NED, or NSSD shall identify if any of the requirements of Section 6.4.2 of ANSI N45.2,2 1972 apply.
Reason 1.
This substitution will ensure that the item will receive adequate
-protection during shipment and storage, thus eliminating unnecessary restrictions and enabling BG6E to use commercial sources to the
- utmost, 2.
Experience shows that industrial practices for packaging Commercial Grade items are adequate for most applications.
Page 47 of 60
- i l
QUALITY ASSURANCE POLICY Revision 25 Item 5 Recuirement Section 4.0 defines shipping requirements related to the protection levels assigned to items.
Response
BG6E has replaced Section 4.0 with the following:
1.
Shipping to Baltimore Gas and Electric BG&E will-invoke the requirements for shipping specified in Section 4.0 of ANSI N45.2.2 - 1972 on Basic Component purchases only when NED or NSSD personnel have specified in procurement documents that the item shall be packaged in conformance with ANSI N45.2.2, Section 3.0.
BG6E will not invoke the requirements of ANSI N45.2.2 - 1972, Section 4.0, on Commercial Grade item purchases.
2.
Shipping from Baltimore Gas and Electric Items shipped from BG6E need not conform to any of the requirements of ANSI N45.2.2, but the organization that packs and handles the item shall provide roughly the same level of protection that the item was given during shipment to BG6E.
Reason If engineering personnel have determined that the vendor's methods of packaging are acceptable.
they have already determined that the supplier's methods of shipping are adequate.
As items are shipped from BG6E only for repair, the detailed requirements specified in Section 4.0 of ANSI N45,2.2 are not necessary.
Item 6 Recuirement Subsection 6.4 gives detailed requirements for care of items in storage,
according to the protection levels assigned to the items.
Resoonse BG6E does not require items to be stored in the packing used for shipment if the storage level in the area provides the same protect. ion as the level of packinE assigned to. the items.
Caps, covers, etc., wtil be required only if specified by NED or NSSD personnel during the procurement process.
If an item is taken from one storage area to another, however, the persons who move it are responsible for ensuring, as applicable, th it additional packing is supplied to give adequate protection during transportation.
4 Page 48 of 60
e QUALITY ASSURANCE POLICY Revision 25 Reason The degree of protection given an item during storage should be tailored to the importance of the item to safety and the probability of deterioration durt g storage; to base storage requirements purely on the categories in Subsection 2.7 of ANS1 N45.2.2 l')72 is impractical.
BG6E requires NED or NSSD personnel to specify requirements more closely related to the actual function of items and to storage conditions.
Trea 7 Recuirerent Subsection 7.3.3 requires compliance with a series of ANSI documents.
Rescense BC6E controls for the uae of hoisting equipment are compatible with the Standards listed in Subsecti 7.3.3 of ANSI N45.2.2, although at the discretion of the Plant General Manac r, they need not be compatible with documents referred to in these document..
Reason Lower level documents referred to in the documents listed in Subparagraph 7.3.3 will not necessarily affect the ability of BG6E personnel to properly handle SR items and could lead to confusion.
ANSI N45.2.3 - 1973 Item 1 Recuirement i
Subsection 2.1 outlines housekeeping cleanliness requirements for five designated zones.
Resoonse BG6E has established three classes for cleanliness requirements.
There is no class equivalent to the ANSI Zone 1.
Requirements of ANSI Zones 4 and 5 have been consolidated into BC6E's class 3.
Reason 1.
ANSI Zone 1
level of cleanliness applier, to new construction activities.
2.
k'he re required, smoking restrictions are posted for BC6E's class 3 areas.
Page 49 of 60
i QUALITY ASSUMNCE POLICY Revision 25 I, tem 2 Recuirercent Subsection 2.1 requires for Zones I, II, and 111, that a written record of the entry and exit of all personnel and material shall be established and maintained.
Response
BG6E has ettablished the following methods for personnel and material accountability:
1.
Written tc: countability.
2.
Where possible tethering of tools and materials to permanent plant structures or persons.
3.
Post maintenance closecut inspections.
Reason BG6E's three methods of accountability of fer the same level of control as that required by the standard.
ANSI N45.7.6 - 1978 Item 1 Recutrement Subsection 1.2 states in part, The requirements of this standard apply to personnel who perform inspection, examination, and tests during fabrication prior to and during receipt of items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.
Response A Personnel of BG6E's Quality Assurance organizations within the NQAD who perform inspections, examinations, and tests at the plant site during operational phases of the nuclear power plant are required to be qualified in accordance with Regulatory Guide 1.58 (which endorses ANSI Nw5.2.6).
All other BG6E - personnel who perform inspection, examination, and testing functions associated with normal operations of the plant are qualified either to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1 - 1971.
Page 50 of 60
i QUALITY ASSURANCE POLICY Revision 25 Reason A 1.
The individuals who perform inspection, examination, and testing functions associated with normal operation of the plant, such as maintenance and certain technical reviews, are normally qualified to ANSI N18.1 1971.
2Property "ANSI code" (as page type) with input value "ANSI N18.1 1971.</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Some testing activities conducted during normal operation of the plant,. such as surveillance
- testing, do not require that test personnel meet the requirements specified in Paragraph 4.5.2 of ANSI N18.1 for technicians.
Personnel qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) are adequately qualified to conduct such f
testing.
Response B.
BC&E does not always require vendor personnel performing inspection or test activities to comply with the requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) but evaluates the need for invoking Regulatory Guide 1.58
-(which endorses ANSI N45.2.6) on the vendor during the review of procurement documents.
The requirements are not applied to procurement classified as Commercial. Grade.
Reason B BG&E's position'is as follows:
1.
For replacement items purchased as Commercial Grade Items, the purchaser may not-impose nuclear unique requirements on the vendor.
Additionally, items may be manufactured before placement of the purchase order and the vendor may not be required to maintain records of the performance of inspections or tests.
2.
For-Basic Component Purchases, the qualification requirements for
. inspection, examination, and test personnel are determined by:
a.
Item status (new or repla ament).
b.'
Complexity and importance of item, c.-
Manufacturer's QA program approval 1cvel (Appendix B, ANSI N45.2, etc.).
Response C P
BC&E does not require-personnel who. perform specific limited and repetitious inspection functions, such as inspection for removal.or replacement of snubbers, to be trained as required by Regulatory Guide 1.58 (which endorses ANSI N45.2.6).
l Page 51 of 60
QUALITY ASSURANCE POLICY Revision 25 Reason C Inspe c tion:;, examinations, or tests that are repetitious or of limited scope need _not be performed by individuals qualified to the requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) pro C :9 that they receive instruction in the following:
1.
Activities to be verified.
2.
Acceptance criteria.
3.
Method of documenting results.
4.
Method of reporting deficiencies.
The person responsib1:
for the inspection activity ensures that such instruction is given to 1tspectors before they perform specific inspection functions, and that both this training and the acceptability of the results of the inspection are documented.
Response-D k'he n - i t is necessary to monitor the activities of a vendor BC&E uses personnel qualified as auditors in accordance with ANSI N45.2,23 or.nspectors in accordance with Regulatory Guide 1,58 (which endorses ANSI N45.2.6).
Reason D Both Regulatory Guide 1.58 (which endorses ANSI N45.2.6) and ANSI N45.2.23 establish training requirements suitable for monitoring vendor activities.
Item"2 Recu irerrent Table' 1 specifies that Level III personnel shall L capable of qualifying-Level III personnel.
Response
k' hen there is'only one Level III position or when a new Level III. position is created. BC&E personnel with the title General Supervisor, or higher, qualify Level III personnel.
Reason BG&E personnel in these grades are capable of certifying Level III personnel without being trained as Level III inspectors.
Page 52 of 60
i QUALITY ASSURANCE POLICY Revision 25 EQTI Regulatory Guide 1.58 (which endorses ANSI N45.2.6 1978) states in part, under item 6 of Regulatory Position, that..."In addition to the recommendations listed under Section 3.5 (of ANSI N45.2.6 1978) for Levei I,
II, and III personnel, the candidate should be a high school graduate or have earned the General Education Development equivalent of a high school diploma...."
Based on the NRC letter dated January 17, 1985 from Thomas T. Martin to A.
E.
- Lundvall, Jr.,
the above educational requirements will be implemented for inspection, examination, and testing personnel hired or assigned after November 27, 1984, in addition'to the present commitment to ANSI N45.2.6~1978 for the qualification of such pesonnel.
ANSI N45.2.9 - 1976 Item 1 Recuirement Section 4.0 titled " Receipt" gives instructions for receipt' controls.
Resconse BG6E applies these requirements only to the receipt of records by the Plant History File.
Reason Most records received by such organizations as Receiving Inspection, (Engineering, etc.,
are not shipped in a manner that makes these requirements applicable.
These requirements are applicable, however, when the records are finally turned over to the Plant History File.
Item 2 Recuiremer.:
Subsection 5.6.1 reads as follows, " Design and construction of a single record storage facility shall meet the following criteria:"
Items a) and b) of the subsection state that:
"a)
Reinforced
- concrete, concrete
- block, masonry, or equal construction."
"b)
A floor and roof with drainage control.
If a floor drain is provided, a check valve (or equal) shall be included."
l Page 53 of 60
QUALITY ASSURANCE POLICY Revision 25 Re s pons e /Re a s sn 1.E.tLa The intent of this requirement is both structural integrity and fire resistance. This vault is entirely enveloped by a structurally sound, fire resistive building, Second, the vault rests on a reinforced slab on grade and its valls extend fully to the underside of the structural deck.
- Third, the valls of the vault are constructed of gypsum va11 board on metal studs per Underwriters Laboratcry Tesc Number U412, assuring the equivalent of 2 hout fire resistive construction.
This is equal construction to concrete block in terms of fire protection.
The valls carry no structural load; hence, they prpvide equivalent structural integrity to that needed of concrete block Egs oons e /Re a s on Item b Again, the vault is contained within an environmentpily protected
- building, As such, it has no roof, or need for floor drain lleL3 Recuirement Subsection 5.6 allows only the dual facility defined in Subsection 5.6.2 as an alternative to the single facility defined in Subsection 5.6.1.
Response
BC&E allows the following alternative storage requirements for organizations other than the Plant History File:
Organizations that originate records and do not transfer them to the Plant History File within 30 days of completion shall establish one of the following three controls as-alternatives to the requirements specified for the Plant History File:
1.
Duplicate Storage Either A or B.
1These responses have been forwarded to the NRC by_the BCLE letter dated 02/11/83 from Robert G. Nichols, Sr. Facilities Project Administrator, Real Estate and Office Services Department, to Terry L.
Harpster, Chief QA Branch, - Division of QA, Safeguards and Inspection Programs, IE, USNRC, These responses have also been accepted by the NRC in their letter dated 04/22/83 from Walter P. Haass, Deputy Chief, QA Branch, civision of Quality Assurance, Safeguards, and Inspect'
.s Programs, Office of Inspection and Enforcement.
Page 54 of 60 l
QUALITY ASSURANCE POLICY
' Revision 25 A.
Within 30 days-of completion of a record, a duplicate - record 1 file shall be established.
This activity shall be controlled by procedures
.which provide for the following:
1.
Assignment of responsibility for records.
-2.
Description of storage area.
3.
Description of filing system.
4.
An index of the filing system.
5.
Rules governing access to and control of files.
6.
Methods for maintaining control of_ and accountability for records removed from the file.
7.
Method for filing supplemental information and disposing of superseded or obsolete records.
8.
Method for preserving records to prevent de t e rio r,a t ion.
9.
Method for maintaining specially processed records that are
. sensitive to light, pressure, or temperature.
10.
Transfer of duplicates to the Nuclear Plant Document Control Unit within two years of completion of records.
B.
Make arrangements with at least one other department that receives a copy of. each document to subj ec t this -other copy to the controls specified above.
2.
Fire-resistant Building Storage Records shall be stored. in steel cabinets located in a fire resistant L
building or a non combustibic building with a fire suppression system.
l The procedural controls defined for duplicate storage-shall be applied.
_3.
Non-fire-resistant-Building Storage l.
Within non fire resistant facilities, records shall be stored in UL one hour-minimum fire rated storage cabinets and be subj e c t - to the
-procedural controls defined for duplicate storage.
BC6E defines a Fire resistant Building as follows:
A~ facility constructed to resist the initiation or spreading of
' fire; non-combustible and/or fire suppressive. materials used; building certified as fire resistant by the Risk Management Unit of BC6E's Corporate Finance Group.
i I
Page 55 of 60
QUALITY ASSURANCE POLICY Revision 25 Reason Although these alternatives are compatible with standard methods of handling records, they do not materially decrease the level of protection afforded to the records.
ANSI N45.2.23 - 1978 Item 1
- Recuirement 2.3 Qualification of Lead Auditors Section 2.3.1 requires prospective Lead Auditors to obtain a minimum of ten credits under the scoring system defined in paragraphs 2.3.1.12.3.1.4
Response
BC&E has revised the scoring system as follows:
Education and Experience The prospective Lead Auditor shall have accumulated a
'nimum of ren credits under the following scoring system:
1.0 Education (4 credits maximum) 1.1 For the Associate degree for an accredited institution, score one
- credit, if the degree is in engineering, physical :ciences, mathematics, or quality assurance, score two credits, Or, for the Bachelor degree from an accredited institution, score two credits; if the degree is in engineering, physical sciences, mathematics, or quality assurance, score el.ree credits.
1.2 For the Master degree in engineering, physical sciences, business management, or quality asr"~.nce from an accredited institution, score one credit.
1.3 For the successful completion of part of the required curriculum for an Associate,
. Bachelor, or Master
- degree, score a
corresponding' percentage of the credits specified above for the degree.
1.4 For the - successful completion of Navy Nuclear Training, its equivalent in another armed service, or the training required for becoming a licensed operator in a commercial nuclear power plant, score two credits.
Page 56 of 60
QUALITY-ASSUp*NCE POLICY-Revision 25 2. 0.
Experierte (9 credits maximum) 2.1 Technical Experience (5 credits maximum)
For experiance in engineering, manufacturing, construction, operation, o maintenance, score one credit for each full year.
2,2 Nuclear Experience If two yea'.s of technical experience have been in the nuclear field, score one additional credit..
2.3 Quality Assurance Experience If two or more years of the technical experience have been in quality assurance or quality-control, score two additional =
- credits, Persons whose work activities are controlled by the QA Program but who are not full time members of the QA organization may be awarded half the credits that would be given to a persoti with specific quality assurance experience.
l 2.4 Audit Experience If two or more years of the technical experience have been in j
auditing, score one additional credit.
2,5 Supplemental Experience Persons who have a proportion of the experience specified in 2,1 2.4 may be awarded a corresponding percentage of the credits specified.
2,6 Time exclusively spent in training does not app'.y as credit toward experience requirements for lead auditors.
3.0 Training (2 credits maximum)
-Persons who have successfully completed the training requirements of ANSI N45,2,23 may be given two credits.
l 4.0 Rights of Management (2 credits maximum)
{
The Manager NQAD, may grant additional credits for other performanco factors applicable to auditing as follows:
4.1 For certification of competence in engineering or science related to nuclear power plants, or in quality assurance specialties, issued and approved by a State Agency or National Professional or Technical Society, score two credits.
i 4.2 For nuclear experience in excess of 2 years, score one credit for each two years experience.
Page 57 of 60
... " '. ~
QUALM MSURANCE POLICY Revision 25 4.3_ -.For. practical expu Jat ce that can be related to power plants, in exceos _ of 5 yean score ene credit for each two years of experience.
Reason-
.BG&E is in agreement with the buic purpose of ANSI N45.2.23..that is, to establish minimum educational or_ nqwdence requirements for Lead Auditors.
We think, however, that the system el redits outlined in ANSI N45.2.23 tends to reduce the site of the pool of pountial replacement auditors without making redeemin6 improvement in the capab m tles of persons selected.
We calculated the, credit score of 11 of 'our. present Lead Auditors at the time they were appointed Lead Auditoto,
$tx had completed Navy Nuclear Training and spent several years in the Navy Nuclear Program.
Four of these scored only 8 credits total, including 2 credits allowed by paragraph 2.3.1.4 of ANSI N45.2.23 for. rights of management based on their having completed the BG&E QA training programs for Lead Auditors.
e one of our auditors, with neither nuclear nor power plant experience, had a credit score of 12 because he held a Bachelor's degree in engineering and was a professional engineer with over 5 years design experience.
Because all of these individuals have acted as Lead Auditors satisfactorily for several years, it appears that the credit system should be revised slightly_
to - allow for the differences in, education and experience of prospective Lead
-Auditor canoidates.
We consider the. flaw in the current system to be -the emphasis on
= educational requirements that vill allow a person with a Master's degree and no nuclear or power. plant experience to become a --Lead Auditor, but will exclude a
- person who has no degree,- even though he may have 20 years' experience in operating or-maintaining nucicar or power plant systems.
The oractical balance between education and experience will vary with Lindividuals-and particular. Work ' assignments.
Any attempt -to establish rigid requirements: is-likely to allow some unsuitable candidates to meet-the
. qualification requirements _while excluding'some acceptable candidates.
For these reasons,_we think that the supervision of proopective Audit Team Leaders should'- be given more. flexibility in determining whether, for a particular individual, educational or professional qualifications are more j
significant and valuable than past experience.
The. present credit system, -while recognizing the Associate degree, gives _ no credit' for completion of the' nuclear training programs.
We = think _ that someone who has taken Navy Nuclear Training or its equivalent in another armed service,-
or.someone who has-completed the training required to become a licensed operator in a commercial-nuclear power plant, should receive the same credit as a-person who. has an_ Associate degree from an accredited -institution in engineering, physical-sciences,-mathematics, or quality assurance.
The points now awarded for education are related to the of feet that formal courses might have-on the ability of individuals to compreht nd the regulations Page 58 of 60 f
.4 QUALITY ASSUpANCE POLICY Revision 25 or the technical aspects of activities being audited.
The point system makes no allowance for the fact that such knowledge comes gradually and not upon receipt of a degree.
Persons who have completed part of a degree course should receive a percentage of the credits allow (d for that course.
The requirements for training specified in ANSI N45.2.23, paragraph 2.3.2, would seem s s ensure that prospective Lead Auditors will meet the requirements of para 6raph 2.3.1.4 dealing with the rights of management.
We
- think, the;efore, that all prospective Lead Auditors should qualify for these two credits.
- Similar4, le present system recognizes th effect that working in a QA Program will t.
e on the ability of a person to comprehend regulations and technical requirements.
Persons who are not assigned as full time members of the QA Organizaticn,
- however, receive similar exposure if they perform activities controlled by a QA Program. We therefore allow such persons half the credits specified for quality assurance experience.
Item 2 Recuirement.
3.3 Recualification Lead Auditors who fail to maintain their proficiency for a period of two years or more shall be required to requalify.
Requalification shall include retraining in accordance with the requirements of paragraph 2.3.3, reexaminacion in accordance with paragraph 2.3.5, and participation as an Auditor in at least one nuclear quality assurance audit.
l Response BGSE requalifies Lead Auditors en the basis of the satisfactory performance of one audit, as observed by a qualified Lead Auditor.
Reason The purpose of the training specified in paragraph 2.3.3 of the Standard is to ensur that-candidates understand the fundamentals of auditing and the requirements for activities to be audited.
The fact that persons have not maintained their proficiency does not mean that they need complete re training; it means only that they have not been able to review and study the applicable Codes, Standards, Procedures, instructions,and other documents related to QA Programs and program auditing.
BC&E considers that the satisfactory performance of an audit under the obse rvation and guidance of a qualifted Lead Auditor should ensure that persons with lapsed certification will review and understand the pertinent documents.
4 o
Page 59 of 60 l
QUALITY ASSURANCE POLICY Revision 25 ANSI N101.4 1972 Recuirenent l
Section 1.2 specifies applicability requirements for the Standard.
Resoonse BC&E requires that only activities performed inside containment structures and related to protective coatings applied to ferritic steels,
- aluminum, stainless steel, zine coated (galvanized) steel,-concrete, or masonry surfaces
.:.c.11 conform to applicable Sections of ANSI N101.4.
Reason Deterioration of protactive coatings applied to surfaces outside consainment structures would have no d( < cimental effects on the safe operation of the plant.
ANS1 N45.2.13 - 1973 Reautrement ANSI N45.2.13 could be interpreted to mean that all requirentnts of ais standard are applicable to all safety.related items or services.
Resoonte BC6E has two approaches for safety related and desig.ated non safety related procurement as described in Sections, 1B.4 and 1B.7.
Controls established for Basic Component Purchases correspond to the requirements of ANSI N45.2.13.
The extent to which the individual requirements of ANSI N45.2.13 are applied to Commercial Grade Purchases depends on the nature and scope of the work to be performed and the importance to nuclear safety and the items or se rvices purchased.
This approach is consistent with the introductory discussion in Section 1.3 of ANSI N45.2.13 1973.
4 Page 60 of 60 1
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QUALITY ASSURANCE POLICY g, vision 25 l ATTACHMENT A EASES IVR OA POLICY REVISIONS (1) Entry PRF-Q No. No. Basis For Revision (s) 1. 771 Procedure Uccrade Action Plan (P.!!AP). cer L.B. Russell letter 1 20 89 _ 2, 783 10 CFR Part 21 roouirements. 3, 797 NRC Insdeetion #89 16/89 17 (Letter from R. E. Denton to R. P. Heibel dated July 13. 1989.) 4, 824 NRC letter from M. V. Hodres to C. C. Creel dated March 13. 1990. 5, 844 Procurament Procram Proieet uncrede. Performance Imorovement Plan (PIPl Action Plan #5.3.1 and OAU Audit Findinc 87 13 01 6. 844 111) and 1h16 revised to clearly establish crocram ncolicability and pontrols. consistent strginolocv. orcanizational responsibilities and a focused aceroach towards developine and imolementinr an int 2rrated Manatement Svetem. 7. 8. 9. 10. 11. 12, 13. 14, 15. 16. 17. 18. p..-- ,--#3 m..q, ---.--.7 -7,e v -.T-My 7-* .-mi. ..m9 s}}