ML20070W163
| ML20070W163 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/14/1983 |
| From: | Killpack V PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| Shared Package | |
| ML20070W155 | List: |
| References | |
| NUDOCS 8302180314 | |
| Download: ML20070W163 (3) | |
Text
. _.
AFFIDAVIT OF V. LEWIS KILLPACK ON NECNP II.B.1, II.B.3 II.B.4, AND II.B.5 V. LEWIS KILLPACK, being on oath, deposes and says as follows:
i 1.
I am the Nuclear Quality Manager, employed by the Public Service Company of New Hampshire. My professional qualifications appear in the Operating License Application (FSAR - Chapter 13).
2.
The Seabrook Station Operating License Application (FSAR) in Sections 17.2 and 13.1 addresses the following:
The 18 Criteria of 10 CFR 50, Appendix B are addressed in detail, a.
as shown in Figure I.
Sufficient detail is provided in each of the PSAR Sections and Subsections to allow an independent reviewer to determine whether or how all of the requirements of Appendix B and the guidance in all applicable regulatory guides will be satisfied.
b.
The organization of the Quality Assurance Department is addressed in FSAR Section 17.2.1 and provides the independence required by 10 CFR 50, Appendix B, Criterion I.
The Quality Assurance reporting alignment is in agreement with Figure II of NUREG-0731, " Guidelines for Utility Management Structure and Technical Resources", which shows the Quality Asurance Department reporting to the Vice President - Nuclear Production.
The various sections of the FSAR, as shown in Figure I, address c.
the controls that assure that replacement materials and replacement parts incorporated into structures, systems, or components impor-tant to safety will be equivalent to the original equipment; installed in accordance with proper procedures and requirements, and are otherwise adequate to protect the public health and safety.
Similarly, it is assured and demonstrated that repaired or reworked structures, systems, or components will be adequately inspected and tested during and after the repair or rework, and will be docu-mented in "as-built" drawings.
In addition, Appendix 17B of the FSAR provides a matrix of 10 CFR 50, Appendix B criteria versus procedures. These procedures are presently being developed and reviewed; will be available prior to fuel load; and will provide i
the implementation of the Quality Assurance Program.
d.
The organization of the Quality Assurance Department that assures the presence of an adequate number of qualified QA/QC personnel on the operating staff, including the offshift period, is addressed in FSAR Sections 17.2.1.3.a.1, 17.2.1.3.b.1, and 17.2.1.3.b.2.
Additionally, FSAR Sections 13.1.1 and 13.1.1.3 address the involvement of the Yankee Nuclear Services Division of Yankee Atomic Electric Company.
8302180314 830214 PDR ADOCK 05000443 G
AFFIDAVIT OF V. LEWIS KILLPACK ON NECNP II.B.1, II.B.3, II.B.4, AND II.B.5 Page 2.
l Based on the above, I believe there are no issues relative to NECNP Contentions II.B.1, II.B.3, II.B.4, and II.B.5 on which factual hearings are warranted.
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COMMONWEALTH OF MASSACHUSETTS SUFFOLK, ss.
February 14, 1983 Then appeared the above subscribed V. Lewis Killpack and made oath that he was the author of the foregoing affidavit and the statements set forth therein are true to the best of his knowledge.
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WY lb Notary Publicf /
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FIGURE I Comparison of 10 CFR 50, Appendix B to Seabrook Station FSAR, Section 17.
10 CFR FSAR CRITERION TITLE SECTION TITLE I
Organization 17.2.1 Organization II Quality Assurance Program 17.2.2 Quality Assurance Program III Design Control 17.2.3 Design Control IV Procurement Document Control 17.2.4 Procurement Document Control V
Instructions, Procedures and 17.2.5 Instructions, Procedures and Drawings Drawings VI Document Control 17.2.6 Doument Control VII Control of Purchased Material, 17.2.7 Control of Purchased Material, Equipment, and Services Equipment, and Services VIII Identification and Control of 17.2.8 Identification and Control of Materials, Parts, and Materials, Parts and Components Components IX Coctrol of Special Processes 17.2.9 Control of Special Processes i
X Inspection 17.2.10 Inspection XI Test Control 17.2.11 Test Control XII Control of Measuring and Test 17.2.12 Control of Measuring and Tect Equipment Equipment XIII Handling, Storage and Shipping 17.2.13 Handling, Storage and Shipping XIV Inspection, Test and Operating 17.2.14 Inspection, Test and Operating Status Status XV, Nonconforming Materials, Parts 17.2.15 Nonconforming Materials, Parts or Components or Components XVI Corrective Action 17.2.16 Corrective Action XVII Quality Assurance Records 17.2.17 Quality Assurance Records XVIII Audits 17.2.18 Audits y-r-
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PUBLIC CERVICE stamm
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December 21, 1982 SEN-410 T.F. 57.1.2 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Mr. George W. Enighton, Chief Licensing Branch No. 3 Division of Licensing
References:
(a) Construction Fermits CPPR-135 and CFFR-136',~1WeYet Nos. 50-443 and 50-444 (b) PSNN Letter, dated November 15,1982, *Draf t SER Section 17.2,* J. DeVincentis to C. W. Entshton
Subject:
Revisions to FSAR Section 17.2; (fluelity Assurance Branch)
Deer Sir:
In Reference (b), a revised version of FSAR Section 17.2 was submitted in response to a Stality Assurance Branch open item.
We have again revised FSAR Section 17.2 as delf nested f n the enclosure to this letter in response to F df tiona) d concerns of the S.nalfty Assuranee Branch.
Note that the right margins have been barred to highlight revisions to the previous subaitta2.
The enclosed version of FSAR Sece. ion 17.2 wf 32 be included in OL Application Ammndment 48 i
Very truly ymirs, ANKEE ATDMIC ELECTRIC COMPANY b
t J. DeVJneentis Project Manager ALL/fsf i
Atomic Safety and Licessf ag Board Seruf ee Lis!
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17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE It is the policy of Public Service Company of New Hampshire to operate Seabrook Station in a manner that reflects an emphasis on quality and pro-fessionalism.
The Chief Executive Officer has issued the following state-l ment which is published in the Operational Quality Assurance Program:
A fundamental cosmitment of Public Service Company of New Hampshire is to provide safe, reliable and economic energy services with a minimum effect on the environment. To implement this policy, proper attention to the quality of work activities and materials which,go into the design, construction, and operation of Seabrook Station is essential.
Control of quality is exercised through the Seabrook Station Operational Quality Assurance Program.
Adherence to the Program and its supporting administrative and opera-tional procedures and controls is mandatory for all personnel per-forming activities within the scope of the Program.
To thic end, the Operational Quality Assurance Program described below pre-i sents the outline of assignments, actions, and procedures that will result in compliance with this policy and the requirements of the Code of Federal Regulations Title 10, Part 50, Appendix B.
17.2.1 Oraanization 17.2.1.1 Program Responsibility The ultimate responsibility for operation, including maintenance, modifica-tion and refueling, of Seabrook Station rests with Public Service Company of New Hampshire (PSNH).
The Executive Vice President - Engineering and Production has been designated as the responsible corporate officer. As i
such, he has the authority and responsibility to develop and implement the Operstional Quality Assurance Program, hereinaf ter referred to as the Program or OQAP.
The Program, which is presented in this and the following sections, is expressed as an outline of the assignments, actions and procedures that, taken together, will result in proper management and operation of activi-ties at Seabrook Station.
Through the established organization, verification of conformance to established quality requirements is implemented by individuals or groups not having direct responsibilities for the work being verified.
Those individuals performing the verifications and other quality related func-tions have direct access to management levels in the organization which assures the ability to:
o Identify quality problems 17.2-1.
D o
SB 1 & 2 FSAR Initiate, recommend, or provide solutions through designated o
channels o
Verify implementation of solutions The Vice President - Nuclear Production will mediate disputes arising within the OQAP. Where disagreement persists, the matter may be appealed to the Executive Vice President - Engineering and Production for final resolution.
17.2.1.2 Delegation of Authority and Assignment of Responsibility The Executive Vice President - Engineering and Production, a.
whil'e retaining full' responsibility and the overall' authority, has delegated the necessary authority and has assigned respon-sibility for the Program to the Vice President - Nuclear Production. He has assigned the Nuclear Quality Manager the responsibility to manage the prograsmaatic aspects of the OQAP.
b.
Various services and support activities required for opera-tional support have been contracted from the Nuclear Services Division (YNSD) of Yankee Atomic Electric Company (YAEC). YNSD has been assigned specific authority and responsibility to per-form these contracted functions.
YNSD' remains independent of PSNH but reports to and is responsible to PSNH in accordance with Figure 13.1-2.
The scope of work and functional responsibilities for YNSD are generically defined in a formal agreement between YNSD and PSNH.
In exercising ultimate responsibility for the above contract, PSNH does the following:
1.
Requires the submittal and approval of generic program documents prior to use to assure conformance with the com-mitments of the Program, FSAR and Technical Specifications.
2.
Performs audits of selected activities on a preestablished schedule to evaluate YNSD ' performance.
Results are l
reported to PSNH senior management.
1 l
3.
Performs an annual' independent evaluation of YNSD services using audit reports, trend data, follow reports, and dispo-sition of unsatisfactory items.
4.
Assigns a responsible organizational element to assure the quality of YNSD work.
l l
17.2.1.3 Ornanizational Structure l
17.2-2
_=
1 551&2 FSAR l
PSNH Organization The PSNH organizational structure discussed below is shown on Figure 13.1-1.
a.
Nuclear Production (NP)
The Vice President - Nuclear Production is responsible for the operation and operational support of Seabrook Station. To assist him in the acomplishment of these responsibilities, the Vice President - Nuclear Production has the Seabrook Station Manager, the Training Canter Manager, and the Nuclear Production Staff reporting directly to him.
The Nuclear Production Staff contains the necessary expertise and authority to provide support for three basic functions.
They are an operations function under the Nuclear Services Manager and associated support group, an engineering function under a Nuclear Engineering Manager and associated group, and a quality assurance function under the Nuclear Quality Manager and associated group.
I 1.
Quality Assurance (QA)
The Nuclear Quality Manager has overall responsibility for assuring that the Seabrook Operational Quality Assurance Program is effectively implemented by all organizations performing work on systems and equipment important to safety at Seabrook Station.
7he Nuclear Quality Manager reports to the Vice President - Nuclear Production.
The Nuclear Quality Group has the freedom and authority to perform independent reviews of quality related work and request work stoppages or remedial actions if conditions adverse to quality are encountered.
Functions to be performed by the Nuclear Quality Group are matched with available manpower resources on a short and long term basis. For each functional category, specific quality assurance activities are identified and man hours required to accomplish the tasks are estimated. Based on these estimates, the number and types of personnel required to support the activities are determined. The program audits are scheduled up to a year in advance and specific person-nel are tentatively assigned. For short term inspection planning, specific work packages are developed and person-nel are tentatively assigned.
Due to the time required to recruit and train personnel and other variables in the work load, certain tasks may be assigned to Yankee Atomic Electric Company and consultants as needed. At present, the QA/QC staff planned is approximately 18 recognizing that this number will vary dependent on work activities, 17.2-3
~
schedules, and ability to contract QA/QC work assignments outside. Their authority extends over the Nuclear Production Staff, the Seabrook Station Staff, the Training Center Staff, YNSD and any other organization performing quality-related work for Seabrook Station. The Nuclear Quality Manager has a direct line of communication with the managers of the above staffs to assure a timely resolution of quality assurance problems, audit findings, corrective actions, etc.
The qualifications and experience of the Nuclear Quality Manager are as defined in ANSI /ANS 3.1 -
1978 for Professional-Technical.
The NQ Mgr. directs and supervises quality activities such that he:
Approves the Program and all changes to the Program.
o Maintains open communications with PSNH Managers, YNSD o
QA Director and other appropriate personnel, as required, to maintain cognizance of matters relating to implementation of the program.
Has authority to assign quality assurance functions to o
YAEC Quality Assurance in accordance with the Second Memorandum of Agrerzent, which is described in Sections 13.1.1 and 13.1.1.3.
Directs the Seabrook Station Quality Assurance o
Department Supervisor in the verification and inspection of on-site implementation of the OQAP.
Develops a training program for quality assurance and o
quality control personnel, and provides for their certification.
Identifies quality problems and evaluates their extent o
and safety implications.
Recommends, provides or initiates solutions to iden-o tified quality problems.
Verifies Laplementation of approved solutions to such o
problems.
Administers the audit, inspection and surveillance o
programs of site, TNSD, and Nuclear Production staff functions.
Evaluates and reports the effectiveness of Program o
trends in quality performance.
17.2-4
SB 1 & 2 FSAR Refers to the Vice President - Nuclear Production for o
mediation, cases where he is unable to establish mutual agreement with, or between, other organizations involved in the implementation of the Program.
Is Chairman of the Nuclear Safety Audit and Review o
Committee.
(a) Quality Assurance Department Supervisor The Quality Assurance Department Supervisor reports directly to the NQ Mgr. and receives from him corporate guidance, management, and professional and technical direction and training.
The Quality l
Assurance Department Supervisor and his staff pro-vide on site verification'and assessment of the program implementation.
The communicacion inter-face with the Station is depicted on Fig. 17.2-1.
i A representative of the Quality Assurance Department shall receive prict notification of SORC meetings and will participata on a regular basis.
The Quality Assurance Department is on distribution for pertinent meeting notices, correspondence and information and will attend any meeting which appears appropriate.
The Quality Assurance / Quality Control staff routinely attend and participate in work schedule and status meetings to assure that they are kept abreast of day-to-day work l
assignmenes throu hout the plant and that there is o
adequate QA/QC coverage relative to procedural and inspection controls, acceptance criteria, and QA/QC staffing and qualification of personnel to carry out QA/QC assignments.
(b) Quality Assurance Department The Quality Assurance Department consists of the Quality Control Section and the Quality Assurance Section. The Quality Assurance section consists of expertise in the areas of quality engineering, training, and auditing.
The Quality Control Section consists of expertise in the areas of electrical, mechanical, and instrumentation and control. Both Sections report directly to the Quality Assurance Department Supervisor.
The Quality Assurance Department Supervise and his staff embody the necessary technical and pro-fessiona?. qualifications and expertise, and are responsible to:
17.2-5 l
SB 1 & 2 FSAR (1) Assist the Training Manager in providing basic and advanced general QA Training for Station personnel.
(2) Train, retrain, qualify and certify personnel in the specific QA and QC skills and tech-niques required to review, inspect and assure quality and the quality control ~ of Station operations, maintenance and other activities within the scope of the Program.
(3) Monitor and review the conduct of quality control activities and the performance of inspections.
(4) Perform QC inspection functions..
(5) Perform audit and surveillance of Station programs and activities within the scope of the OQAP.
(6) Review and audit to assure that contractors or service agencies performing on-site work, within the scope of the OQAP, amploy approved procedures.
(7) Exercise stop-work authority.
2 2.
The Nuclear Services Group functions in direct support of the station in the areas of licensing, health physics, -sergency planning, training, operations and operations assessment.
The group will also maintain commnunications with YNSD's operations personne1' on station activities.
3.
The Nuclear Engineering ~ Croup has a wide range of responsibilities, including reviews of design changes, and supervision of large backfit projects.
The group maintains close coordination with the YNSD Project and Licensing activities.
4.
Seabrook Training Center (TC) is headed by the Training Center Manager who reports directly to the Vice President - Nuclear Production and is respon-sible to him for the activities of the TC as described in Subsection 13.1.1.2.
5.
Seabrook Station is headed by the Station Manager who reports directly to the Vice President -
Nuclear Production and is responsible to him for 17.2-6 y
s-
SB 1 & 2 FSAR the operation and administration of Seabrook Station.
To carry out this assignment the Station Manager has the staff and organization shown in Figure 13.1-5.
The various parts of this organiza-tion Laplement their assigned aspects of the Program as follows:
(a) Station Manager 1.
Overall responsibility for implementation aspects of the Program at Seabrook Station.
2.
Is Chairman of the Station Operations Review Committee (SORC).
(b) Assistant Station Manager The Assistant Station Manager reports directly to the Station Manager and is re*ponsible to:
1.
Supervise the Technical Services, Training, and Operations Managers.
2.
Is a member of the Station Operations Review Committee (SORC).
3.
Assume's the responsibilities of the Station Manager in his absence.
(c) Compliance Manaaer The Compliance Manager reports to the Station Manager and is responsible to him to:
1.
Maintain communications with the Nuclear Quality Manager and the Quality Assurance Department Supervisor on site on matters related to the implementation of the l
program within the station.
2.
Represent the Station Manager in matters relating to regulatory compliance and quality assurance activities within the station.
(d) The Administrative Services Manaaer reports directly to the Station Manager and is respon-sible to:
17.2-7
-e---
Maintain a staff of administrative, security, fire protection, and safety personnel who are trained and qualified to perform the duties required to implement the Program.
2.
Administer and monitor performance of Station security services.
3.
Coordinate all Station drills related to security, fire protection and safety.
4.
Supervise the procurement, receipt, handling, storage, issue and records asso-ciated with material ~ and services that are encompassed by the Program.
(e) The Trainina Manager reports directly to the
~ Assistant Station Manager and is responsible to:
a 1.
' Develop and maintain, for nonlicensed per-sonnel, the program needed to train indi-viduals in their assigned tasks and functions.
2.
Conduct non-licensed training for each designated person, evaluate the perfor-mance and capabilities of each person and report their readiness to be assigned aduinistrative or operational responsibilities.
3.
Coordinate, with the Department Supervisors, the selection and timing of personnel to be assigned to initial training and retraining courses.
4.
Provide quality assurance and quality control training under the technical direction of the Nuclear Quality Manager.
l (f) The Technical Services Minaaer reports directly to the Assistant Station Manager and is responsible tot 1.
Perform the support functions that include chemistry sampling and analysis; radiation monitoring and Health Physics controls and exposure records; reactor engineering; 17.2-8
SB 1 & 2 FSAR computer operation and engineering; and general engineering services. Also included are the preventive maintenance program, corrective maintenance program, and Station modification and repair actions.
2.
Prepare the required procedures for per-formance of the above functions.
Schedule the performance of work and control the material, personnel and processes involved.
3.
Direct actions, within the realm of the Technical Services Group, to fulfill sur-veillance testing program requirements.
i (g) The Operations Manager reports directly to the Assistant Station Manager and is responsible tot 1.
Operate equipment at the Station in compliance with Technical Specifications and other license requirements.
2.
Assist in the training of operations per-sonnel to assure an adequate number of qualified employees for each task.
T l
3.
Prepare, review, approve and implement the operating procedures to be used for Station operations.
4.
Direct actions, within the realm of the Operations Group, to perform the balance of the surveillance testing program required by the Station license.
b.
Yankee Atomic Electric Company - Nuclear Services Division (YNSD) 1.
Ornanization The YNSD organization, and its interface with PSNH to accomplish support activities, is shown in Figure 13.1-2 and 17.2-1.
1 The YNSD organization consists of a variety of disciplines.
l The two that provide the direct interface with PSNH are the Quality Assurance Department and the Projects Department.
The Projects Department draws upon the other YNSD technical disciplines to furnish the specific support services as they are needed.
17.2-9
Responsibilities YNSD responsibilities in support of Seabrook Station are:
(a)
Quality Assurance Department (1) Assure that YNSD' activities comply with requirements of the OQAP.
(2) Provide evaluation, inspection and/or sur-veillance of vendor services for Seabrook Station.
This includes evaluation of QA programs and procedures, the examination of vendors selected to fabricate or furnish material, equipment and services and maintenance of an updated list of such approved vendors.
(3) Provide the YNSD interface with the PSNH NQ Mgr. and carry out functions in accordance with the Second Memorandum of' Agreement, described in Section 13.1.1 and 13.1.1.3, and with other procedures and agreements between YNSD and PSNH.
(b)
Projects Department Draw upon the varied technical expertise within YNSD, and coordinate activities in support of Seabrook Station.
(c)
Technical Discipline Departments j
Provide the technical expert: se required by the l
Projects Department in the areas of Plant l
Engineering, Licensing, Environmental Engineering, Fuel Cycle and Nuclear Engineering.
c.
Nuclear Safety 'AGdit and Review Couanittee (NSARC)
NSARC is an executive body that is responsible for conducting a critical examinatf.on of Station activities, including Station operation, evaluation of procedures, investigations of abnormal conditions, and ftnctioning of the OQAP. Technical Specifications define the responsibilities and authority of NSARC. A written charter, approved by the Executive Vice President - Engineering and Production, designates the men-bership, authority and rules for conduct of activities.
d.
Station Operation Review Committee (SORC) 17.2-10
,,.,,----,7 r
SB 1 & 2 FSAR SORC is an advisory group, composed of Station management and supervisory personnel, constituted for the purpose of reviewing activities and determining the effect on operational current safety.
SORC recommends to the Station Manager approval or disapproval of proposals considered by the Committee.
Technical Specifications define the responsibilities and authority of SORC.
A written charter, approved by the Vice President - Nuclear Production and the Station Manager, designates membership, authority and rules for conduct of activities.
e.
PSNH Purchasing Division The PSNH Purchasing Division is headed by the Director of Purchasing who reports to the Vice President - Employee Relations and Purchasing and, in turn, to the Executive Vice President - Operations and Services, as shown on Figure 13.1-1.
The Purchasing Division is minimally involved in the implemen-tation of the Program, since quality aspects concerned with procurement of materials and services that are within the scope of the Program are performed at Seabrook Station under the administrative direction and control of the Administrative Services Manager and other personne1~ at Seabrook Station.
Specific functions and responsibilities of the Director of Purchasing, which interface with Station activities, are:
1.
Issue PSNH Purchase Orders in response to Material Purchase t
Requests that are generated and approved at Seabrook l
Station.
i 2.
Maintain current the commercial status of Purchase Orders.
17.2.1.4 Authority to Stop Work a.
PSNH The NQ Mgr., the Quality Assurance Department Supervisor, and their designated alternates have the responsibility and written authority to stop work or other activities that are not in compliance with the Program.
b.
YNSD The YNSD QA Manager and, through him, personnel of the YNSD-QAD have the responsibility and authority to stop work, if required, on activities delegated to YNSD.'
17.2.1.5 Responsibility to Report 17.2-11
SB 1 & 2 FSAR Included in the corporate policy, and an essential ~part of this Program, is the responsibility of all Seabrook Station, YNSD, Training Center and Nuclear Production Staff personne1~ working within the scope of this Program, to report to their supervisor any equipment, work or other seti-vity that is not in compliance with this Program.
Should the circumstances warrant such action, particularly when a substantial safety hazard or when the public health and safety is involved, the situation is to be further reported to the Station Quality Assurance Department Supervisor, the Compliance Manager or to the NQ Manager, or to other increasingly higher levels of Seabrook Station or PSNH Management until' appropriate action is observed to be undertaken.
17.2.2 Quality Assurance Program 17.2.2.1 Outline The commitments outlined in each section form the basis for preparation of procedures, instructions and other administrative controls.
This ensures that activities affecting the testing, repair, and design af the applicable structures or systems are controlled and documented in a quality manner.
To assure the effectiveness of th'e OQAP, the commitments of each section and their implementing controls are audited as described in Subsection 17.2.18.
l The Program is implemented. at least 90 days prior to fuel loading.
The i
administrative controls, which implement the OQAP, are mandatory on struc-tures or systems of Seabrook Station at the time of fina1' acceptance by the Operating Organization (Station Management).
Each section of the DQAP focuses on the Seabrook Staff activities, however, where a major portion of an activity is performed by a group other than the Seabrook Staff, the group or organization is identified and discussed.
17.2.2.2 Scope l
a.
Structures, Systems, and Components The OQAP applies to the systems, structures, and components designated safety class 1, 2, 3, lei Seismic Category 1, and certain systems, structures, and components necessary to imple-ment the Fire Protection Program.
In addition certain balance of plant items are to be included in the scope of the OQAP. A document listing the specific systems, structures, and comp-nents, to which the OQAP applies, is written, reviewed, approved, and controlled in accordance with Section 17.2.6 of this Program. The listing which identifies those systems, structures, and components under the contro1~ of the quality assurance program will be reviewed and concurred with by the engineering and quality assurance organizations.
This listing will be a controlled document subject to the controls of 17.2-12
,,r,,.._.,--.---,e...,,--
Section 3 and 17.2.2.4 of the FSAR provide guidance for generation of this list. The Seabrook Station Fire Protection System Evaluation and Comparison to BTP APCSB 9.5-1. Appendix A described in Section 9.5.1.2.4 provides details of the Lsplementation and the extent of application of the quality assurance program to the fire protection program.
Exceptions taken to specific components shall be included in the above document.
b.
Computer Programs Computer programs which form a basis for design, modification or operation of the structures, systems, and components iden-tified above require administrative controls. Procedures spe-cify the development, approval, certification, control and use of these programs to assure that assumptions, processing and i
application of results are consistent with Station design com-mitments.
c.
Activities Activities affecting designated structures, system and com-ponents are subject to the applicable controls of the 0QAP.
If these activities require special equipment, controlled environ-mental conditions, skills or processes, they are provided and controlled.
l d.
Expendable and Consumable Items The following items are considered to be within the scope of the OQAP when used in safety-related activities:
Reactor Fuel Boric acid Diesel fuel oil Weld rod Hydrogen Nitrogen Morpholine Hydrazine Resins Reagents (used in performance of analyses required by Technical Specifications)
Snubber fluid e.
Health Physics Program The Health Physics Program will be audited as described in Section 12.5.3.8.
17.2-13
-.. -. -. - ~
SB 1 & 2 FSAR 17.2.2.3 Program Implementation It is recognized that the degree of quality assurance and Program applica-bil'ity varies with different systems and activities.
The degree to which the requirements of this Program and its implementing procedures are applied are based upon the following:
The importance to safety of a malfunction or failbre of an item o
or activity.
The design and fabrication complexity or uniqueness of the o
item.
L o
The need for special contral's and surveillance or monitoring of processes, equipment and operational activities.
The degree to which functional' compliance can be demonstrated o
by inspection or test.
o The quality history and degree of standardization of the item or activity.
A three-level approach is defined to assure program implementation to the degree necessary, s.
Level 1 This level includes independent inspections and tests performed during routine and non-routine activities by appropriately trained personnel.
b.
Level 2 This level includes surveillance and monitoring activities that are performed by the Quality Assurance Department.
Such activities include observation of tests and inspections, significant activities, review of records, procedures, and verification of test reports.
Records of surveill'ance and monitoring activities are maintained.
c.
Level 3 This. level includes a comprehensive audit and eva-lustion program initiated by the NQ Mgr. to assure proper functioning of Levels 1 and 2.
This level includes measures performed to verify that activi-ties required by the OQAP are established, imple-mented and satisfy regulatory requirements.
17.2.2.4 Program Standards i
17.2-14
i I
SB 1 & 2 FSAR PSNH maintains a working knowledge of applicable industry codes, standards, federal regulations and guides.
The OQAP, complies with the following references and the regulatory position of the Regulatory Guides:
10 CFR, Part 50, Appendix A - Genera'l Design Criteria For a.
Nuclear Power Plants, b.
10 CFR, Part'50, Appendix B - Quality Assurance Criteria For Nuclear Power Plants and Fuel Reprocessing Plants.
c.
10 CFR, Part 50.55a - Codes and Standards.
d.
10 CFR, Part 50.59 - Codes, Tests and Experiments.
10 CFR, Part 71, Appendix E - Quality Assurance Criteria For e.
Shipping Packages Fo'r Radioactive Material.
f.
10 CFR, Part 50.34 (b.6.ii) Final Safety Analysis Report.
g.
Regulatory Guide 1.8, May 1977, Personnel Selection and Training (endorses ANSI-N18.1-1971).
h.
Regulatory Guide 1.26, Rev. 3, February 1976, Quality Group Classification, and Standards For Water, Steam, and Radioactive Waste Containing Components of Nuclear Power Plants.
i.
Regulatory Guide 1.29, Rev. 3, September 1978, Seismic Design Classification.
j.
Regulatory Guide 1.30, August, 1972, Quality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Electrical Equipment, (endorses ANSI-N.45.2.4-1972).
l k.
Regulatory Guide 1.33, February 1978, Quality Assurance Program Requirements (Operation), (endorses ANSI-N18.7-1976/ANS-3.2).
1.
Regulatory Guide 1.37, March 1973, Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants, (endorses ANSI-N45.2.1-1973).
Regulatory Guide 1.38, May 1977, Quality Assurance Requirements m.
l for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-cooled Nuclear Power Plants, (endorses ANSI N45.2.2-1972).
Regulatory Guide 1.39, September 1977, Housekeeping n.
Requirements for Water-Cooled Nuclear Power Plants, (endorses ANSI-N45.2.3-1973).
17.2-15
Regulatory Guide 1.58, September 1980, Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel, (endorses ANSI-N45.2.6-1978).
p.
Regulatory Guide 1.64, June 1976, Quality Assurance Requirements for the Design of Nuclear Power Plants, (endorses ANSI-N45.2.11-1974).
q.
Regulatory Guide 1.74, February 1974, Quality Assurance Teram and Definitions, (endorses ANSI-N45.2.10-1973).
r.
Regulatory Guide 1.88, October 1976, Collection, Storate and Maintenance of Nuclear Power Plant Quality Assurance Records, (endorses ANSI-N45.2.9-1974).
s.
Regulatory Guide 1.94, April 1976, Quality Assurance Requirements for Installation, Inspection, and Testina of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, (endorses ANSI-N45.2.5-1974).
t.
Regulatory Guide 1.116, May 1977, Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Sys tems, (endorses ANSI-N45.2.8-1975).
Regulatory Guide 1.123, July 1977, Quality Assurance u.
Requirements for Control of Procurement of Items and Services for Nuclear Power Plants, (endorses ANSI-N45.2.13-1976).
j v.
Regulatory Guide 1.144, September 1980, Auditing of Quality l
Assurance Programmed for Nuclear Power Plants, (endorses ANSI N45.2.12-1977).
v.
Regulatory Guide 1.146, August 1980, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants, (endorses ANSI N45.2.23-1978).
x.
Branch Technical Position (BTP) APCSB 9.5-1, Appendix A.
The Technical Specifications shall be the governing document in case of conflict between the Technical Specifications and the above references.
Exceptions, Alternatives and clarifications to the referenced standards are noted in Appendix 17A.
17.2.2.5 Program Revision The NQ Mgr. is responsible to maintain the OQAP current. All proposed changes, whether reflecting editorial coussents or major program policy revisions, are forwarded to the NQ Manager for' approval and control.
17.2-16
-,..n-
s SB 1 & 2 FSAR Procedural controls exist to assure that prior to making any change to this OQAP, a written evaluation shall be prepared to identify the change, the reason it is needed, and the basis for concluding that the change results in an OQAP that continues to meet the criteria of Appendix B of 10 CFR 50.
For changes that, (1) affect the authority, independence or management reporting levels previously established for organizations or persons per-forming QA functions or (2) affect the controls previously established over activities within the scope of the OQAP, the evaluation described above shall be submitted to NRC within 30 days of making such changes.
17.2.2.6, Procedure s a.
PSNH i
To Laplement the quality assurance policies identified in the OQAP, and to assure compliance with the 10 CFR 50 Appendix B t
(
criteria, procedures are prepared, reviewed, and approved in accordance with OQAP requirements.
Qualified individuals in the Nuclear Quality Group either onsite or offsite will be responsible for performing reviews of documents affecting quality and safety, including changes thereto. The QA/AC review is to assure that the necessary QA/QC requirements are properly and correctly stated and that the procedures meet the FSAR requirements. A matrix in Appendix 17B reflects the indi-vidual 10 CFR 50 Appendix B criteria met by documented proce-dures.
b.
YNSD The NQ Mgr. reviews procedures for YNSD activities within the t
scope of the OQAP to assure that documented controls are in effect and adequate to meet the requirements identified in the OQAP.
c.
On-Site Contractors The Nuclear Quality Group approves the QA Programs of contrac-tors and service agencies which are engaged in on-site work activities.
17.2.2.7 Management Evaluation a.
In addition to any major quality problems, which are imme-distely brought to the attention of upper management, the NQ Mgr. conducts quarterly meetings which give upper management an ongoing cognizance of the implementation and adequacy of the OQAP. The meetings address areas of audit and inspection results, quality trends, significant problems and interactions with the regulatory agencies.
17.2-17
SB 1 & 2 i
FSAR b.
The Executive Vice President - Engineering and Production has directed the NSARC to perform and doctament at least an annual assessment.
This provides upper management an impartial view of implementation of, and compliance with, the OQAP.
The NSARC identifies and tracks any corrective action required.
1 17.2.2.8 Indoctrination and Trainins The Quality Assurance portion of the non-licensed training program consists l
t of introductory and specialized training.
The introductory training segment instru:ts new or transferred employees, who may perform quality related activities, in the purpose, scope and method of implementation of quality-related manuals, instructions and pr' -
o cedures.
This segment also describes the company organization, interface with regulatory bodies and other topics pertinent to the employees job description.
Specialized training in areas of inspection, test, auditing, l
etc. leads to certification or qualification of individuals.
The scope, technical content, and frequency of quality assurance and quality control training is determined by the Nuclear Quality Manager.
This training is initiated as early as practical to meet OQAP objectives.
For the formal training programs documentation includes the objective, content of the program, attendees, and dates of attendance.
Proficiency tests are given to those personnel performing and verifying i
activities affecting quality, and acceptance c'riteria are developed to determine if individuals are properly trained and qualified.
Proficiency of personnel performing and verifying activities affecting quality is main-tained by retraining, reexamining, or rscertifying.
The licensed training program, discussed in Subsection 17.2.1.3.a.4, assures that a sufficient number of appropriately trained and licensed individuals are available to operate Seabrook Station.
17.2.3 Desian Control 17.2.3.1 Scope
(
Design control is exercised on design activities related to structures, systems and components described in para. 17.2.2.2.
Design control is applied to activities such as field engineering; core physics, seismic, stress, thermal, hydraulic, and accident analyses; associated computer programs; compatibility of materials; accessibility for inservice inspec-tion, maintenance and repair, and the inspection criteria for tests and ins pec tions.
17.2.3.2 Design Document Preparation, Review and Approval l
17.2-18 l
l
S s
SB 1 & 2 FSAR The preparation, review and approval of design documents such as design criteria, design drawings, computer programs, specifications, and proce-dures raquire the interface of PSNH, YNSD, and vendors / contractors.
Procedures are established which include requirements for a documented check to verify the completeness of design drawings and specifications.
The organizational elements involved with the design document preparation, review and approval are the Engineering Services Department of the Seabrook Staff, the Nuclear Engineerin5 Group, Nuclear Quality Group and YNSD engi-ner'ing.
The Nuclear Quality review is to assure that the necessary QA/QC requirements are properly and correctly stated and that the proc' edures meet the FSAR requirements and applicable procedures.
The interface between organizations is procedurally defined to assure proper control and to main-l tain design activity awareness of those activities of reviews, app
- oval, release and distribution of the documents.
Criteria and methods used by vendors / contractors which may affect the design of Seabrook are evaluated and approved prior to use.
17.2.3.3 Desian Verification The assigned lead design group or organization (i.e., PSNH, YNSD, supplier, architect engineer) assures that the designs and materials are suitable and that they comply with the design criteria, quality standards and regulatory requirements. Design verification is performed by individuals other than those who performed the original design.
The extent of design verification is determined by the complexity of the system, the safety function to be performed and the applicability of regulatory requirements, codes, stan-dards, FSAR coasniements and QA requirements. The lead design group or organization identifies the method of verification (i.e., design review, alternative calculation or test).
If testing is chosen, the most adverse design conditions are stipulated and demons tra ted.
Procedures provide criteria for determining when verifica-tion may be by testing. Prototype, component, or feature testing will be performed as early as practicable prior to installation, but will always be performed before the component, system, or structure is relied upon to per-form its safety function. The timeliness of the verification will be dependent upon the nature of the finding and the type of documents. The l
Nuclear Quality Group, and engineering groups will evaluate each case in accordance with approved procedures and indicate the time periods such that they are traceable and auditable.
Procedures which control the design verification activities include inter-nal and external interfaces, the timing and documentation of reviews, and the responsibilities and methods used by the verifier.
For computer programs, verification activities include the certification and specifica-tion of use. Procedures assure that design verification must be complete prior to relying upon the component, system, or structure to perform its function.
17.2-19
s SB 1 & 2 FSAR Procedural control is established for design documents that reflect the comitments of the FSAR; this control differenti tes between doctaments that receive formal design verification by interdisciplinary or multi-organizational teams and those which can be reviewed by a single individual (a signature and date is acceptable documentation for personnel certification).
Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, FSAR when used as a design document, and drawings including piping and insertmient diagrams, control logic diagrams, and electrical single line diagrams. Specialized reviews will be used when uniqueness or special design considerations warrant. Procedures specify the responsibilities of the verifier, the areas and features to be verified, the pertinent con-l' siderations to be verified, and the extent of doctamentation.
17.2.3.4 Design Changes l
Changes to the design of Seabrook Station require the same design control measures that were applicable to the original design. YNSD Engineering reviews and approves changes to the design, unless approval responsibility i
is specifically delegated to another organization.
SORC will review modi-1 fications: which are safety related and related changes in Station proce-
+
dures resulting from design changes to assure that there are no unreviewed safety questions. Design changes affect a wide range of design doctments which must be reconciled. Administrative procedures ensure that the responsible Station personnel are aware of the changes which may affect their duties.
Station design changes and related changes to station proce-j dures are controlled and incorporated in the licensed training program.
17.2.3.5 Deviations Procedures exist to doctament and control deviations from approved design documents, including design standards that could adversely affect struc-tures, systems and components. Also included, is the control of deviations from specified quality standards.
In the case of errors or deficiencies, action is taken to determine the cause and to initiate appropriate changes based on the significance or recurrence of the error / deficiency.
Errors / deficiencies may ie revealed by verification measures, use of the l
doctament, audit, tests, actual failure, or other means.
I 17.2.4 Procurement Document Control 17.2.4.1 Procurement Planning The Seabrook Staff is the organizational element responsible for procure-ment activities.
In this effort, they identify tasks and assign respon-sibilities to execute an integrated procurement plan.
17.2.4.2 Procurement Document Preparation and Review The Seabrook Staff has the primary responsibility for preparation and i
17.2-20
l s
SB 1 & 2 FSAR review of procurement initiating documents e.g., Mate ial Purchase Request (MPR). The content and routing within the staff are procedurally defined.
The MPR content includes, as appropriate:
a.
Scope of Procurement b.
Technical Requirements c.
Quality Assurance Requirements l
d.
Documentation Requirements e.
Rights of Access Provisions f.
Nonconformance Reporting Provisions g.
Administrative and reporting requirements h.
Required drawings i.
Required specifications l
j.
Required codes and industrial standards k.
Test and inspection requirements 1.
Special process instructions The routing within the staff consists of a technical and a quality review.
The technical review, based on written guidelines, assures that appropriate technical, regulatory and special requirements of the order are included and properly identified.
The quality review is based on the program described in this Safety Analysis Report and is performed by Quality Assurance personnel to assure the quality requirements are properly spe-cifi ed.
The criteria for proper specifications are documented and include:
Quality requirements - correctly stated, inspectable and a.
controllable.
b.
Acceptance and/or rejection criteria.
c.
Preparation, review and approval of the procurement document meets the OQAP requirements.
For commercial "off-the-shelf" items where specific quality assurance controls appropriate for nuclear applications cannot be imposed in a prac-ticable manner, special quality verification requirements will be established to provide the necessary assurance of an acceptable item.
Upon completion of the~Seabrook Staff activities, the Purchasing Division transcribes the MPR information on a PSNH purchase order (P.O.).
The 17.2-21
l 2162 FSAR Purchasing Division cannot waive or change any noncommercial requirements of a procurement document without proper authorization from the Seabrook Staff.
Copies of the MPR and executed P.O. are maintained at Seabrook Station as quality records and for subsequent receipt inspection functions.
During the procurement document preparation and review cycle, non-commercial changes or revisions to documents are subject to the same review and approval requirements as the original documents. Procurement of spara and replacement parts will be subject to the controls of the current Operations Quality Assurance Program.
For procurement of spare parts, changes which affect design bases, safety evaluation, regulatory conformance, functional design, structural integrity and testing require-ments require technical assessment and documented approval.
17.2.4.3 Selection of Procurement Sources YNSD-QA has the assigned responsibility to generate and maintain an Approved Vendors List (AVL) which identifies those vendors able to meet PSNH requirements for a given scope of supply.
Each vendor evaluation is based on one or more of the following:
Historical data representative of current capability.
a.
b.
Status of the vendor's current quality program - review of pro-cedures, QA manual, audits, etc.
i Review of objective evidence which demonstrates adequacy of,
c.
the,ir QA program.
Evaluations are documented and provide objective evidence of the approval basis.
The Seabrook Staff and the Purchasing Division maintain a current copy of the AVL for procurement source information. Seabrook Staff personnel may delete or request addition of vendors as experience dictates.
The NQ Manager maintains cognizance of the YNSD activities and is ultimately responsible for the evaluation and selection of procurement sources.
17.2.4.4 Bid Evaluation and Award Bid evaluations are performed by the requisitioning organization to assure that the bids received conform to the procurement document requirements.
Appropriately trained personnel in the technical and quality disciplines are used as needed to complete the evaluation consisting of, as applicable:
a.
Technical considerations.
b.
Quality Assurance requirements.
Supplier capability and performance record.
c.
17.2-22 1
9
-_.._,.m.
I d.
Alternatives / exceptions to the procurement document requirements.
Any unacceptable conditions resulting from the bid evaluation are resolved i
i or an appropriate commitment is obtained from the vendor prior to contract award.
l 17.2.4.5 Surveillance, Inspection and Audit During the technical and quality reviews, the scope of vendor verification activities is determined.
This determination is based on the complexity, relative importance to safety, quantity of the item and supplier quality performance and results in an assignment of activities for which source and site surveillance, inspection or audit is deemed necessary.
The source surveillance, inspection and audit functions may be delegated to YNSD-QA upon written notification from the NQ Mgr.
Receiving inspection activities are delegated to the Station Staff.
17.2.4.6 Acceptance Methods used to accept items are dependent on the scope of purchase and i
include one or more of the following:
a.
Source verification b.
Receiving Inspection c.
Supplier Certificate of Conformance d.
Post Installation Test 17.2.5 Instructions, Procedures and Drawings 17.2.5.1 PSNH PSNH controls and performs all activities, such as design, procurement and l
operation, through a series of instructions, procedures, drawings and other l
documents which define the methods for complying with the eighteen criteria of 10CFR50 Appendix B and the guidelines of Regulatory Guide 1.33.
The Vice President - Nuclear Production is responsible for the preparation of procedures which define the NP Organiza'tional relationships in a manner that assures compliance to the quality requirements delineated in the OQAP.
[
Each NP Group Mgr. and the Seabrook Station Manager is responsible for pre-paring procedures consistent with PSNH quality philosophy, this OQAP, and their assigned work activities.
The Seabrook Station departments prepare and maintain procedures for admi-nistrative control and technical support of the safe and efficient opera-17.2-23
s SB 1 & a FSAR tion of the Station. These procedures establish the system for off-site interfaces, conduct of operations and operating status.
The procedures provide instructions for performing activities in areas of Station admi-nistration, operations, refueling, maintenance, and other specialized tech-nical support functions.
The Training Center Manager prepares and maintains procedures necessary to provide instructions to administer and document the licensed training program and keep abreast of design changes which impact the use of the simulator.
The Purchasing Division provides instructions for accomplishing routine activities within the division which define the interfaces with other PSNH departments that initiate procurement or contract documents.
All instructions, procedures and drawings contain applicable quantitative l
and qualitative acceptance criteria, as warranted, to enable determination of satisf actory accomplishment. System procedures contain checklists or reference documents that contain checklists.
Procedures are established for the preparation of as-built drawings and related documentation in a timely manner which will accurately reflect the actual plant design. As-builts are made available to staff who need the information.
The timeliness of the as-builts will be dependent upon the type of documents as established by the Nuclear Engineering Group in accordance with approved procedures.
If as-built drawings are not available, either interim or final design configuration documents will be available to Station staff and Nuclear Quality staff prior to the operation of the affected item.
17.2.5.2 YNSD YNSD performs various support services for PSNH such as zuditing, vendor evaluation, licensing and engineering. Such activities are prescribed by documents appropriate to the circumstances and are internally reviewed to assure the inclusion of qualitative and quantitative requirements. The NQ Group maintains cognisance of the YNSD procedural Luplementation through audit and surveillance.
17.2.5.3 contractors / vendors Prior to performing work or inspection on safety related structures, systems and components, contractors / vendors (except those which work as an integral part of PSNH) are required to develop and submit for approval pro-cedures which define the scope and Laplementation of the task.
The proce-dures reference applicable drawings, specifications, codes and standards, 17.2-24
~
s SB 1 & 2 FSAR and include appropriate acceptance criteria. The contractors / vendors are required to perform all work in accordance with the approved documents which also form a basis for monitoring and control of the activities assigned.
17.2.6 Document Control 17.2.6.1 Scope The PSNH document control program applies to the issuance and control of documents which affect the quality of structures, systems and components.
The controlled documents include, but are not limited to the following:
Operational Quality Assurance Program.
a.
b.
Procurement documents and specifications.
c.
Specifications and drawings.
d.
Administrative and operating procedures.
e.
Nonconformance reports.
f.
FSAR and Technical Specifications.
17.2.6.2 Issuance The revi,ew, approval and subsequent issue of documents is prescribed in procedures.
The review and approval cycle includes a review to assure technical adequacy and inclusion of appropriate quality requirements prior to implementation. The quality review of maintenance, modification and
, inspection procedures includes:
- 1) a determination of the need for inspec-tion, 2) identification of inspection personnel, 3) identifiction of the inspection requirements, methods, and acceptance criteria, and 4) documen-l tation of inspection results.
Documents are reviewed by SORC in accordance with Subsection 13.4.1.3.
Similar controls are implemented at other locations by those organizations which perform work using documents that pertain to Seabrook Station.
17.2.6.3 Control The Seabrook Station Document Control Center (DCC) maintains a system to identify and control the current revision of instructions, procedures, spe-cifications, drawings and procurement documents. As new or revised docu-ments are approved, DCC enters these into the system. The controlled distribution of new and revised documents is limited to those which are required for standard activities.
Other documents are issued on a request basis. This system assures that the most current revision of a document is available for use at the required locations. Where appropriate, procedures 17.2-25 k
-=n-
SB 1 & 2 FSAR include requirements to verify the revision status of documents.
17.2.6.4 Channes Precedures exist to assure that changes to documents are reviewed and approved by the same organizations that performed the initial review and approval or by other qualified responsible organizations designated by PSNH.
In either case, the reviewing organizations have access to pertinent background information upon which to base their review, and have an ade-quate understanding of the requirements and intent of the original docu-ment. This includes design and procurement document changes identified in other sections af the OQAP.
Documents that are made obsolete or are superseded as a result of changes are removed from the controlled distribution when replaced by the new revi-sion.
For those documents which are not on controlled distribution, the required verification of revision status prior to each use results in purging outdated documents from the work areas. Audits of document control assure the proper implementation and control.
Station procedures are reviewed by an individual knowledgeable in the pro-cedure every two years to determine if changes are necessary or desirable.
Reviews are documented and are at least as rigorous as the initial proce-dure review.
17.2.7 Control of Purchased Material, Equipment and Services 17.2.7.1 Planning The Seabrook Staff has the responsibility to Laplement appropriate measures to assure that purchased material, equipment and services conform to pro-curement documents. Appropriate measures may include source evaluation and selection, source inspection, surveillance or audit, or receipt inspection.
During the review of procurement documents, the staff, following written procedures and guidelines, identifies those charscteristics and/or pro-cesses important to the quality of the item or service and specifies inspection, audit or surveillance activities commensurate with the procure-ment scope.
17.2.7.2 Source Activities Inspection, surveillance and audit activities at the source are identified l
in accordance with the plan developed for procurement.
These activities are normally performed by YNSD-QAD personnel.
Qualified personnel perform the activities using written procedures / checklists and formally report to I
the Station Staff on their quality findings, including problem areas of the procurement. Personnel assigned these activities have the delegated authority to stop work if necessary.
The NQ Group maintains cognizance of and audits the activities of YNSD to assure proper implementation of source activities.
I 17.2-26 i
SB 1 & 2 FSAR 17.2.7.3 Receiving Inspection Receiving inspection is performed by qualified Seabrook Staff members using pre planned written procedurer/ checklists which define those charac-teristics to be inspected. Personnel performing receiving inspection will be qualified by the Nuclear Quality Group to Regulatory Guide 1.58 (ANSI N45.2.6).
The personnel verify that the items are undamaged, that they conform to procurement requirements (when not verified by source sur-veillance, inspection or audij), and that the required doctamentation is available. Where sampling inspection is specified, the plan is based on nationally recognized standards.
Quality Assurance Department personnel perform random surveillance of receipt inspection activities.
17.2.7.4 Documentation Documented evidence that the items meet procurement requirements, such as receiving inspection reports, physical and chemical test reports, and cer-tification of conformance, must be available at the Station prior to placing the affected item into service which relies on it for a safety function. Written guidelines are used by the receipt inspection personnel to evaluate and accept the submitted documentation. Measures exist to periodically evaluate Certificates of Conformance to assure validity.
17.2.7.5 Status The status of procurement action is maintained through reports and inspec-tions at the source and upon receipt.
The documentation submitted by YNSD-QAD or the supplier, or that which was internally generated during the course of procurement and receipt, identifies the requirements that have and have not been met.
For those items delivered which deviate from pro-curement requirements, a nonconformance report is prepared for tracking and disposition.
Tagging and/or physical segregation where possible is used to identify the inspection status of individual items or orders prior to assignment to controlled storage facilities or use in the Station.
17.2.8 Identification and Control of Materials, Parts and Components 17.2.8.1 Identification Procurement doctaments contain appropriate requirements for identification of materials, parts and components.
Compliance to the specific procurement requirements is the responsibility of the supplier.
The Seabrook Staff personnel assure, if not already verified and doctanented during source verification activities, that identification of items meets the procurement requirements upon receipt.
Station procedures covering the identification of items are prepared by the Seabrook Staff and approved as noted in sub-section 17.2.6.2.
Identification by physical means is maintained where l
possible and through documentation when not physically practical.
Materials, parts and components are traceable to appropriate documentation, such as procurement or inspection documents.
17.2-27 l
l
[
17.2.8.2 Control i
Subsequent to the receiving functions at the Station, identification and control of items is maintained in accordance with technical and administra-tive procedures. At storeroom issue, an item is verified by the user for correct identification, and acceptability.
During the various phases of fabrication, installation, repair or modification of items, in process sur-veillance may be performed by Station and contractor personnel to verify the continuity of identification. When an item is subdivided, traceability of the item, when required, is controlled by transcribing information to the subdivided pieces.- The identification markings are placed on the item or on records traceable to the item. If required identification is missing, obliterated or hidden, the item is considered nonconforming and is tagged and, where practical, placed in a segregated area pending resolution.
17.2.9 Control of Special Processes 17.2.9.1 Prpcess Qualification Welding, heat treatment, nondestructive testing, chemical cleaning, plating and other special processes, where the required level of quality cannot be, or is disadvantageous to be, measured by direct visual inspection, require qualification.
The Seabrook Staff has the responsibility to qualify spe-cial processes, equipment, and personnel, as appropriate, in accordance with approved procedures to assure subsequent accomplishment under i
controlled conditions in accordance with applicable codes, standards and specifications. Process, equipment, and personnel qualification records are maintained and updated as required. For special processes not covered by existing codes or standards, the qualification criteria is defined and documented. The Nuclear Quality Group performs a review and surveillance function of special processes.
l Qualification includes allowable control parameters of the process i
variables, specified equipment and personnel proficiency which are docu-mented in special process procedures and approved as noted in Subsection 17.2.6.2 and reviewed by the Quality Assurance Staff.
Special process pro-cedures contain the necessary prerequisites, personnel and equipment requirements, qualification data, limitations, acceptance criteria, results interpretation and records, as applicable. When special processes are to be performed by vendors / subcontractors on site, prior approval of their procedures by the Station Staff and review by the Quality Assurance Staff is required to assure conformance to applicable specifications codes and standards. Provision for approval is defined in the procurement documents.
17.2.9.2 Personnel Qualification PSNH, YNSD and vendor / contractor personnel responsible for the performance of special processes are que.lified in accordance with applicable codes, standards and specifications. Training and eve-inations are adsinistered 17.2-28
..- m-
l SB 1 & 2 FSAR to determine the capability of each individual.
Qualification records of on-site personnel associated with special processes are established, filed and kept current.
The period of validity and criteria for requalification are in accordance with the applicable codes, specification and standards.
17.2.9.3 Process Performance Special processes are accomplished using written process sheets, proce-dures, checklists, travelers or equivalent. These documents provide for recording of evidence to indicate acceptance in accordance with the process requirements. Acceptance of the results is performed by personnel qualified for acceptance of the special process. Records which verify that the required activities were accomplished in accordance with qualified pro-i cedures by qualified personnel are maintained and filed.
17.2.10 Inspection 17.2.10.1 General Inspections associated with normal operations of the plant, such as main-tenance, surveillance, and tests, are performed by the Quality Control Section of the Nuclear Quality Group. These inspectors are trained and certified to meet the requirements of ANSI N45.2.6 by the Nuclear Quality Manager or Quality Assurance Department Supervisor prior to performing inspections. The inspectors are responsible for the following:
Preparing inspection plans and checklists a.
b.
Filling out, signing, and dating inspection plans and checklists c.
Performing required inspections l
17.2.10.2 Station Equirment Surveillance The Station Manager directs the preparation of a surveillance program. The program requires that surveillance be performed to assure that the station equipment operates in accordance with documented procedures, Technical Specifications, FSAR and OQAP requirements. The original and subsequent revisions of the surveillance program require review by SORC and approval of the Station Manager. The Nuclear Quality Group monitors this program.
I 17.2.10.3 Maintenance and Modification Inspection l
l Maintenance, modification, repair or replacement activities are inspected I
in accordance with the original inspection requirements or engineering approved alternatives.
Documents which provide instructions for performing the activities specify the inspection requirements and are reviewed by the l
Nuclear Quality Group.
Inspection points are designated in the procedures when deemed necessary to control the quality of the item.
17.2-29
SB 1 & 2 PSAR 17.2.10.4 Receiving Inspection The scope of this inspection activity is described in Subsection 17.2.7.3.
17.2.10.5 Inservice Inspection Base line data for Inservice Inspection (ISI) is collected during Station construction.
This data is ~used as standards for periodic inspections of items to comply with Technical Specifications. ASME Section II, " Rules for Inservice Inspection of Nuclear Power Plant Components" and Station proce-dures.
The development of the overall program for inspection is assigned to YNSD, while implementation rests with the Seabrook Staff. Records of ISI activities are maintained and used for comparison with the results of subsequent inspections.
l 17.2.10.6 Contractor and Vendor Inspections The Seabrook Staff assures that inspection requirements are included as necessary in procurement documents which apply to contractors on-site and to vendors at their facilities (including service agencies such as non-destructive examination (NDE) specialists).
17.2.10.7 Qualification of Inspectors l
The organization responsible for work at Seabrook Station normally per-forms the inspections.
The personnel performing inspections, including NDE, have the necessary qualifications and are independent of the super-visor directly responsible for performing the work being inspected.
Personnel requiring special training are trained and qualified in accor-dance with the applicable documents covering the function.
The training is accomplished and documented in accordance with station procedures or approved suppliers procedures.
Reevaluation of personnel is performed at periodic intervals. The NQ Manager is responsible for the review and I
acceptance of inspection procedures and for personnel qualification cri-l teria and independence, prior to initiation of inspection activity.
17.2.10.8 Inspection Documents Inspection procedures, instructions and checklists used by personnel per-forming inspection functions include the following, as appropriate:
Identification of characteristics to be inspected.
a.
b.
Description of the method of inspection.
Identification of individuals or groups responsible for per-c.
forming the inspection.
d.
Acceptance and rejection criteria.
l 17.2-30 1
1 i
~
SB 1 & 2 FSAR Identification of inspection hold points.
e.
f.
Requirements for indirect control by monitoring process methods, equipment and personnel, if direct inspection is not possible. Both inspection and process monitoring shall be pro-vided when inadequate without both.
g.
Identification of the inspector or data recorder and the results of the inspcetion operation.
h.
Specifying necessary measuring and test equipment, including accuracy requirements.
i.
Identification of required procedures, drawings and opecifica-tions, including revision status.
Sampling techniques, if used, are based on recognized standards, and justi-fication is provided for sample size and selection process.
17.2.10.9 Results/ Records Inspection results are documented and traceable to the item inspected. The responsible individual, or a group qualified in the inspection technique, evaluates the acceptability of the results.
Inspection records are sano-tated with any deviations encountered and, if necessary, subsequent correc-tive action.
17.2.11 Test Control 17.2.11.1 Types of Tests The Station Manager is responsible for the conduct of testing pertinent to the operation of Seabrook, such as:
Start up Tests:
Precriticality tests, criticality tests, low power tests and power ascension tests performed af ter initial fuel loading and af ter each refueling.
NOTE:
During the preoperational phase, the Joint Test Group (JTG) supervises, reviews and approves procedures and practices of the preoperational testing activities. A member
)
of the Seabrook Staff serves as a permanent member of the JTG.
An alternate is appointed for each permanent member. The JTG exists I
until the start of initial fuel loading, at which time its function is replaced by SORC.
Surveillance Tests: Periodic tests performed on Station systems and com-ponents to verify system and/or equipment operability requirements.
17.2-31 1
---.m
1 SB 1 & 2 FSAR Modification Tests:
Tests performed on structures, systems and components by the Seabrook Staff or contractors after modification to assure compliance to operating requirements, codes and standards prior to returning the system to service.
17.2.11.2 Test Procedures Start-up, surveillance, and modifications test procedures are reviewed by SORC and approved by the Station Manager (see Note in Subsection 17.2.11.1).
In the case of contractor involvement, test procedures are i
submitted for approval as required by procurement documents.
Any proposed test or experiment which involves an unreviewed safety question, as defined in 10CFR50.59, is reviewed by SORC and NSARC.
Test procedures contain or provide the following, as required:
Prerequisites, including environmental conditions, and test a.
instrumentation requirements and accuracy.
b.
Provision for assuring that test prerequisites have been met.
Instructions for performing the test.
c.
d.
Incorporation or reference to appropriate requirements and acceptance limits contained in the applicable design and pro-curement documents.
e.
Acceptance criteria.
f.
Inspection points, where applicable.
Methods of documenting or recording test data and results.
g.
17.2.11.3 Conduct of Tests /Results j
Tests are performed by suitably trained, qualified or licensed personnel according to the written procedures. Nonconformances or test anomalies discovered during testing are resolved before structures, systems or com-ponents are required to perform an intended safety function.
testing are documented and evaluated for acceptability by qualified person Results of nel to assure that test requirements have been satisfactorily completed.
Documented test results are retained for record.
17.2.12 Control of Measurina and Test Equipment 17.2.12.1 Measurina and Test Equipment Lists Lists of measuring and test equipment required for Stati
, opera-part-17.2-32
s l
SB 1 & 3 i
FSAR ments of the Seabrook Staff.
Each list identifies the type of measuring i
and test equipment, corresponding identification numbers, and other infor-nation pertinent to control and calibration activities.
Normal commercial items such as rulers, tapes and levels are excluded from the lists.
The list approval, revision, addition or deletion requirements are procedurally centro 11ed. The procedures are reviewed by the Quality Assurance Staff and regular surveillance and audits of the calibration program are conducted to assure the effectiveness of the program.
17.2.12.2 Identification Each item on the measuring and test equipment lists is assigned a unique designation to assure positive control.
The designation is permanently affixed to the item in a manner to afford proper identification without interfering with the item's function. Tags, labels and records traceable to the item, or other identifying means, doctssent the calibration status of f
each item. A schedule is maintained which provides positive recall when recalibration is required and indicates the current status of all' items.
17.2.12.3 Calibration Calibration is based on the manufacturer's recommended interval, however, the required accuracy, purpose, degree of usage, stability characteristics and other conditions affecting measurement wy modify the frequency.
Calibration activities are also initiated when the accuracy of 'an item is suspect.
Procedures identify the recomme' ded calibration interval, calibration tech-n niques, required tools and standards, methods to doctment and evaluate the results and required record maintenance.
Items are calibrated to standards which have an recuracy of at least four times the required accuracy of the item being calibrated.
Less accurate standards may be acceptable when the use of such standards and the basis of calibration acceptance is authorized and documented.
17.2.12.4 Standards Standards used for calibration purposes within the program are traceable to nationally recognized standards such as the National Bureau of Standards (NBS). Where national standards do not exist, the standard used for calibration is justified and doctmented.
Calibrating standards have l
greater accuracy than standards being calibrated, unless authorized and documented for specific use.
17.2.12.5 Control Measuring and test equipment, including insertssents, tools, gages, fir-tures, reference and transfer standards and non-destructive test equipmen t, that is used in the measurement, inspection, testing and monitoring of structuras, systems and components is traceable to that activity.
To i
17.2-33 l
control and document the use of measuring and test equipment, the issue records or inspection / test documents contain appropriate information to identify the unique measuring and test equipment, calibration status, dates used, and specify the activity for which the ites was used.
Through this technique, the validity of inspection or tests that utilised i
nonconforming measuring and test equipment can be determined and docu-mented.
Reinspection or retest may be performed depending upon disposition of the nonconforming ites.
All records of calibration and control activi-ties are maintained as required.
17.2.13 Han_dlina, Storage and Shipping 17.2.13.1 Procurement Provisions Requirements for special handling and storage, including cleaning, preser-vation, packaging and shipment of materials, spare parts and equipment are conditions of procurement documents, as applicable.
Shipping requirements concerning the shipment method, container cleanliness, pressurization, j
dessication, labelling and others, are specified and reviewed during the procurement process.
When requested, the supplier prepares written proce-i dures which specify handling, shipping and storage processes, and submits them to the Seabrook Staff for approval and Quality Assurance review.
Sour,ce inspection by YNSD-QAD personnel may be employed to assure proper implementation of supplier activities.
17.2.13.i Receipt and Storane Upon delivery of items to the Station, receiving activities commence.
The receiving actions are documented by procedure, and require inspection of the special provisions incorporated by suppliers to control cleanliness, labelling, marking, shipping characteristics, etc.
The inspection is docu-mented and the itse is assigned a storage location.
Locations are established with regard to environmental conditions and limitations, cleanliness, physical restrictions, handling requirements, manufacturers reconsendations, and other pertinent data applicable to the item.
Items which require preventive maintenance, special protective environ-ments, special coverings or other particular activities to maintain and preserve the item in storage, are controlled and inspected through docu-mented procedures. Procedures for the storage and control of consumable materials, such as chemicals, reagents, lubricants and film, are provided to assure proper identification and use with regard for special environmen-tal conditions and shelf-life considerations.
The Quality Assurance Staff conducts review and surveillance of receipt and storage activities.
17.2.13.3 Handlina 17.2-34
l Detailed handling procedures and instructions are prepared for items that require special handling due to factors such as weight, size, suscep-tibility to shock and other conditions which warrant special controls.
l Station procedures require the use of special handling procedures and instructions when required. Special handling equipment and tools are main-tained, inspected and documented, at intervals consistent with their appli-cation to assure their availability for use.
17.2.13.4 Packazina and Shippinz Packaging and shipping activities originating on-site are controlled by administrative procedures.
Packaging requirements are divided into classi-fication levels dependent upon the sensitivity of the item, transportation mode, itse destination and other factors which may affect the integrity and i
function of the item.
Items returned to a supplier are returned in the original container, when possible, or repackaged to equivalent standards.
Shipping requirements which are consistent with the mode of protection are specified.
For special nuclear material and sources, shipping is performed in accordance with the NRC and DOT regulations.
17.2.13.5 Personnel Personnel responsible for any phase of receiving, storage, handling, packaging or shipment of items are suitably trained and certified, where necessary, to assure proper implementation of the specified activities and l
controls.
l 17.2.14 Inspection. Test and Operatinz Status l
17.2.14.1 Status Indicators The operating status of structures, systems and components during station operation, maintenance, testing and modification is indicated by devices such as tags, stamps or markings. These devices are identified, described and controlled through administrative procedures.
Inoperative or malfunc-tioning items are also documented and highlighted through the use of varisus devices to prevent inadvertent use.
The responsibility for appli-cation and removal of tags, stamps and other status indicators is defined to assure positive control and to preclude inadvertant operation.
I The test and inspection status of items is indicated by devices such as I
documentation, tags, stamps, or markings.
Nonconforming items are also documented and highlighted through the use of j
various devices to prevent inadvertent use.
1 17.2.14.2 Sequence of Operations Tests, inspections and operations are controlled by documented procedures.
l Any alteration of the intent of a planned sequence is subject to the same I
17.2-35 L
__ - ~
SB1&2 FSAR I
review and approval controls as applied to the original. The authority and responsibility of personnel and methods to re-sequence actions are proce-durally stated.
Tests, inspections or other operations which are bypassed are properly documented and the effect of bypassing is evaluated and approved by the organisation responsible for specifying the test, inspec-tion, or operation.
17.2.15 Nonconforming Materials Parts or Componects 17.2.15.1 Identification and control Materials, parts or components, which are deficient in characteristic, documentation or procedure which render the quality unacceptable or inde-terminate are identified as nonconformances. The Supervisor of a technical area or activity that is within the scope of the OQAP is responsible for documenting the nonconformance in accordance with established procedures, and assuring proper control to prevent inadvertent use or installation.
i Controls may include marking, tagging or physical segregation. Affected organizations.are notified of the nonconformance and subsequent actions taken through distribution of a nonconformance report (NCR).
17.2.15.2 Disposition and Resolution
.The Station Manager is responsible for assignment of technically qualified personnel to evaluate the extent and impact of the nonconformance to deter-mine a disposition for the item; (i.e., repair, rework, scrap or use-as-is) and to take appropriate action, when necessary, to prevent recurrence. For nonconformances involving repair or use as-is dispositions, which may affect the scope or intent of the material item or function, YNSD Engineering is responsible for the performance of an independent review function. All dispositions are documented and signed by responsible parties.
Acceptability of rework or repair of material parts and components is verified by qualified personnel reinspecting or retesting the item as ori-ginally specified or by siternate means approved for the application.
The Station Manager is responsible to administer the nonconformance reporting system. The Nuclear Quality Group reviews and concurs in each NCR to verify that the deficiency was properly and correctly stated, that the disposition and corrective action are acceptable, and to assess the effectiveness of the steps to prevent recurrence.
17.2.15.3 Trend Analysis The NQ Mgr. maintains a system to recognize, evaluate, document, and assess quality trends.
The system provides for periodic analysis of nonconfor-mance reports, maintenance work requests, etc., and the submittal of signi-ficant results to the VP - Nuclear Production for review and appropriate action.
17.2-36 w w
SB 1 & 2 FSAR 17.2.16 Corrective Action l
17.2.16.1 Initiation Corrective action is that action taken to identify, correct and preclude recurrence of conditions adverse to the quality of activities or equip-ment. Station procedures identify those conditions for which corrective action may be warranted including:
Failure of a structure, system or component important to a.
safety.
b.
Defect of an item or service that could, if uncorrected, lead to failure or malfunction.
c.
Operation outside of specified limits.
d.
Repetitive minor problems which may be symptomatic of a larger problem.
Reportable occurrences as defined by the Technical e.
Specification.
f.
Loss or apparent loss of special nuclear material (SNM).
g.
Significant deficiencies identified by the NRC, SORC, NSARC or audit program.
Corrective action is normally documented through appropriate procedures.
In the case of significant conditions adverse to safety, the corrective action includes an evaluation of the cause of the condition, the recom-mended action to prevent or reduce the probability of recurrence, and veri-fication of completion of corrective action.
A special report may be prepared when a significant condition adverse to safety is identified.
This report identifies root causes and documents action taken to preclude recurrence.
17.2.16.2 Assessment l
Procedures require that corrective action associated with nonconformance reports, special corrective action reports and reportable occurrences are reviewed for adequacy and timeliness.
The NQ Mgr. periodically reports to i
the VP - Nuclear Production on the effectiveness of the corrective action process and status of incomplete items.
Corrective action reporting is included in the trend analysis program.
17.2.17 Quality Assurance Records 17.2.17.1 Identification l
17.2-37 l
=-
SB 1 & 2 FSAR The NQ Mgr. and other cognizant managers have the joint responsibility for determining and identifying quality assurance records that are to be retained and their retention period. Examples of the types of records retained include procurement documents, procedures, NDE results; inspec-tion, audit and test results; material analyses; equipment, process and personnel qualifications; calibration records, nonconformances and corree-tive action results and station operating records.
Inspection records, where applicable, identify the inspector or data recorder, type of obser-vation, results, accepta*oility and action taken in connection with any i
deficiencies noted. The compilation of records generated is forwarded to the Administrative Services Department for inclusion into the St5 tion records management system. The system is compatible with the design and construction phase records system.
i 17.2.17.2 Receipt. Storare and Retrieval l
Station procedures identify the responsibility of personnel and actions required to control the receipt, storage and retrieval of quality assurance j
records. A suitable storage facility, designed to prevent loss or deterioration of quality assurance records, is permanently located on-site.
Records, whether original or copies, are indexed, filed and maintained to aid in the retrieval process.
17.2.17.3 Supolier Racords Principal suppliers, their sub-tier suppliers and other suppliers are required to identify quality assurance records generated throughout the life of the contract in accordance with the appropriate provisions of the PSNH procurement documents.
The suppliers are required to maintain a record system and, upon completion of the contract, either continue main-taining the records or forward them to PSNH for incorporation into the PSNK records management system.
Internal procedures identify the receipt, ins?ection and transmittal activities and responsibilities associated with supplier records.
l 17.2.18 Audits 17.2.18.1 Plannina The NQ Mgr. is responsible for development and management of an audit program pertaining to activities associated with operation and operational support at Seabrook Station. Formal reports are distributed by the NQ Mgr.
to other management positions as required by established procedures. A plan, which identifies the audits to be performed and their frequency, is prepared by the responsible parties and approved by the NQ Mgr. The audit plan is based on the status and safety significance of activities being j
performed and ensures that an audit of all functions is completed within a l
two year period.
1 Audits of certain activities such as staff training and qualification, and i
l 17.2-38
l SB 1 & 2 FSAR conformance to technical specifications have specific minimum frequencies.
These are identified and included in the plan which is updated semi-annually. Additional audits may be scheduled when conditions warrant, i.e., extensive reorganization, quality becomes suspect, or the need to determine supplier capabilities prior to contract award.
17.2.18.2 Performance Audits, based on the pre-established schedule, are performed by trained and qualified personnel using appropriate procedures, instructions and checklists. The procedures, instructions and checklists provide a basis for performance of audits including pre-audit and post-audit conferences and the mechanics of the audit process. The mechanics of the process include an objective evaluation of practices, procedures, instructions; activities and items; and review of documents and records to determine the that the quality assurance program is effective and is properly extent Usplemented. Auditors do not have direct responsibility in the area being audited.
Their qualifications, as a minimum, are based on prior pertinent experience, specialized training and education in accordance with appli-cable procedures. Most of the audits conducted onsite are performed under the direction of the Quality Assurance Department Supervisor, who is l
located onsite but reports to the Nuclear Quality Manager.
In addition the i
NSARC may request audits, which may be performed by the onsite or offsite quality assurance staffs or YAEC, or contracted to outside professionals.
The Operational Quality Assurance Program will receive independent eva-lustions under the direction of the NSARC. These evaluations will be conducted in accordance with the NSARC charter and may involve contracting outside professionals.
17.2.18.3 Reportinz and Follow-Up An audit report is generated at the completion of each audit and submitted to the NQ Mgr. and to other appropriate management personnel, including management of the audited organization.
NSARC also receives a copy for their review and assessment of the audit program.. Follow up is required by both the audited and auditing organizations when deficiencies are iden-tified. The audited organization is responsible to review and investigate the nature and cause of the deficiency and to provide appropriate correc-tive action. The NQ Mgr. is responsible for evaluation or proposed or completed corrective action and confinascion of satisfactory accomplishment.
17.2.18.4 Audit Program Review An independent review of the audit program effectiveness and appropriate-ness is initiated at least annually by NSARC.
17.2-39
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l APPENDIX 17A l
EXCEPTIONS, ALTERNATIVES, AND CLARIFICATIONS TO PROGRAM STANDARDS, INDUSTRY CODES, i
FEDERAL REGULATIONS, AND CUIDES l
l l
l
't
~
SB 1 & 2 FSAR General This Appendix lists the exceptions, alternatives, and clarifications to the Program standards which are referenced in Section 17.2.2.4.
a.
For each of the Reg. Guides and standards noted in this sec-tion, there are clarifications, alternatives and exceptions that primarily pertain to the design, construction and pre-operational testing phases of the plant life.
These are pre-sented in section 1.8 and other referenced sections of the
(
FSAR. What follows here are clarifications, alternatives and exceptions that primarily apply to the operational phase and i
the Operational QA Program and are in addition to those pre-sented elsewhere in the FSAR.
b.
In each of the ANSI standards, other documents (i.e. other standards, codes, regulations or appendices) required to be i
included as a part of the standard are either identified at the point of reference or are described in a special section of the standard. The specific applicability of acceptability of these listed standards, codes, regulations or appendices is covered in other specific areas in the FSAR or the Operational QA Program.
t For Operations phase maintenance and modification activities c.
which are comparable in nature and extent to sLailar activities conducted during the construction phase, PSNH shall control these activities under the Operational QA Program.
d.
Where strict conformance to the requirements or guidelines or Regulatory Guides or standards would conflict with reasonable compliance to the ALARA guidelines of Regulatory Guide 8.8, the degree of such conformance will be determined by appropriate levels of management.
e.
In the event of an emergency condition which could likely affect the health and safety of the public, if not promptly corrected, the Vice President - Nuclear Production or his designated alternatives may authorize emergency repairs and activities that deviate from written procedures. When such an l
emergency deviation is undertaken the nature of the emergency, l
its cause, the emergency corrective action and justification l
therefore shall be documented and submitted for review and approval as required for temporary procedures.
Regulatory Guide 1.8 Personnel Selection and Training l
(Rev. 1-R, 9/75; i
reissued 5/77 l
l 17A-1 l
SB 1 & 2 FSAR Endorses ANS 3.1/ ANSI N18.1-1971 During the Operations phase, the Operational Quality Assurance Program includes and complies with this guide except that ANSI /ANS 3.1 - 1978 will be used as the standard in lieu of the 1971 revision.
The following additional clarification applies to the '1978 a.
revision of the standard:
1.
With regard to Section 4 of ANS 3.1-1978.
Individuals other than the Nuclear Quality Manager who do not possess the formal educational or experience requirements specified in this section shall not be automatically eliminated where other factors provide sufficient demonstration of their abilities.
These factors shall be evaluated on a case by case basis, documented and approved by appropriate company management when found to satisfy the requirements.
The Nuclear Quality Manager will comply with the requirements.
b.
For further clarifications and alternatives, see discussion in Sections 1.8, 13.1, 13.2, 16.6.3 and 16.6.4 of the Seabrook FSAR and in Reg. Guides 1.58 and 1.146 appearing later in this Section.
Regulatory Guide 1.26 Quality Group Classifications and Standards (Rev. 3, 2/76) for water, steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants The component classification system defined in ANSI N18.2-1975 " Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants" and ANSI N18.2a has been employed as an alternate method for meeting the intent of Regulatory Guide 1.26, Rev. 3.
. Refer to Section 3.2 for further discussion on this subject.
Regulatory Guide 1.30 Quality Assurance Requirements for the (Rev. O, 8/72)
Installation, Inspection and Testing of Instrumentation and Electric Equipment Endorses ANSI N45.2.4 - 1972 During the Operational phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a.
With regard to Section 3 of ANSI N45.2.4 - 1972 titled -
Preconstruction Verification: Will be implemented as follows:
(1) is not considered applicable; (2) will be implemented with the clarification that " approved instruction manuals" shall be l
interpreted to mean the manuals supplied by the vendor as required by the procurement order. These manuals may be i
1 17A-2
SB 1 & 2 FSAR reviewed by PSNH in part or in total to assure proper opera-tional sequence and adequacy of acceptance criteria.
(3) No special checks will be made by the person withdrawing a replacement part from the warehouse - equivalent controls are assured by compliance with ANSI N45.2.2 as set forth in the Operational Quality Assurance Program; and, (4) will be com-plied with, as stated, by individual technicians as part of the maintenance / modification process.
b.
With regard to Section 4 of ANSI N45.2.4 - 1972 titled -
Installation: Will be implemented by inclusion, as necessary, in the appropriate maintenance or modification procedure, where such procedures are used.
Standard PSNH maintenance practices require that care be exercised in the six areas listed whether i
a procedure is required or not.
With regard to Section 6.2.1 of ANSI N45.2.4 - 1972 titled c.
Equipment Tests: The last paragraph of this Section deals with tagging and labeling. PSNH will comply with an alternate last paragraph which reads:
"Each safety-related ites of process instrumentation is identified with a unique number. This number is utilized in instrument maintenance records so that current calibration status, including data such as the date of the calibration and the person performing the calibration, can t
be readily determined.
Such information may also be contained on tags or labels which may be attached to installed instrumentation."
Regulatory Guide 1.33 Quality Assurance Program Requirements (Rev. 2, 2/78)
(Operations)
Endorses ANSI N18.7 - 1976/ANS 3.2 During the Operational phase, the Quality Assurance Program includes and l
complies with this guide with the following clarification:
a.
Paragraph C.5.a of Regulatory Guide 1.33 (and Section 4.4 of j
ANSI N18.7 which it references) will be implemented with the l
clarification that " periodically" (as used in the second i
paragraph, first sentence) shall not require a set frequency, l
and " documented" (as used in the second paragraph, second sentence) shall not require typed minutes, but may mean hand written notes or memoranda.
b.
Paragraph C.S.d of Regulatory Guide 1.33 (and Section 5.2.7.1 of ANSI N18.7 which it references) will be implemented by I
adding the clarifying phrase "Where practicable" in front of the fourth sentence of the fifth paragraph.
The Regulatory Guide's changing of the two uses of the word "should" in this sentence to "shall" unnecessarily restricts PSNH's options on repair or replacement parts.
It is not always practicable to 17A-3 1
i
i test parts prior to use. For modifications where these requirements are not considered practicable, a review in accor-j dance with the provisions of 10CFR50.59 will be conducted and documented.
c.
Paragraph C.5.f of Regulatory Guide 1.33 (and Section 5.2.19 (2) of ANSI N18.7 which it references) will be implemented with the substitution of the word " feasible" for the word "possible" in the last sentence.
d.
With regard to Section 5.2.7 of ANSI N18.7 - 1976 titled:
Maintenance and Modification:
Since some emergency situations could arise which might preclude preplanning of all activities, PSNH will comply with an alternate to the first sentence in the second paragraph which reads:
"Except in emergency or abnormal operating conditions where immediate actions are required to protect the health and safety of the public, to protect equip-ment or personnel, or to prevent the deterioration of plant conditions to possible unsafe or unstable level, maintenante and modification of equipment shall be preplanned and performed in accordance with written procedures. Where written proce-dures would be required and are not used, the activities that were accomplished shall be documented af ter-the-fact and receive the same degree of review as required for temporary procedure s."
With regard to Section 5.2.7.1 of ANSI N18.7 - 1976 titled e.
Maintenance Programs:
PSNH will comply with the requirements of this Section with the clarification obtained by adding the phrase "Where feasible" before the first sentence of the fif th paragra ph.
It is not always possible to promptly determine the cause of a malfunction.
In all cases, PSNH will initiate pro-ceedings to determine the cause, and will make such deter-minations promptly, where it is feasible.
f.
With regard to Section 5 2.16 of ANSI N18.7 - 1976 titled Measuring and Test Equipment:
PSNH will comply with the requirements of this section with the clarification that the first paragraph delineates the requirements for installed instrument and control devices.
These installed Instrument &
Control devices will be calibrated by the use of a transfer standard which meets the requirements of this section.
3 With regard to Section 5.3.9.3 of ANSI N18.7 - 1976 titled Procedures for Implementina Emeraency Plan:
PSNH has an NRC accepted Emergency Plan for the nuclear facility which will be implemented in lieu of the requirements in this Section.
l 17A-4 l
l
SB 1 & 2 FSAR Regulatory Guide 1.37 Quality Assurance Requirements for (Rev. O, 3/73)
Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants Endorses ANSI N45.2.1 - 1973 During the Operational Phase, the Operational QA Program includes and complies with this guide with the following clarification:
Section 2.3 of ANSI N45.2.1 - 1973, last sentence, is revised a.
to read, " Test reports shall include an evaluation of the acceptability of inspection and test results and identify the individual who performed the evaluation."
b.
Section 7.1 of ANSI N45.2.1 - 1973 requires, in the last sen-tence of the second subparagraph, that " Loose tools should be attached.... with a lanyard." PSNH will control loose tools by procedures or work permits.
Precautionary measures such as barriers between work areas, and tool check-in and check-out controls may obviate the need for lanyards.
Where not obviated, the standard will apply.
Regulatory Guide 1.38 Quality Assurance Requirements for (Rev. 2, 5/77)
Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Plants l
Endorses ANSI N45.2.2 - 1972 During the Operational Phase, the Operational' QA Program includes and complies with this guide with the following clarification:
a.
With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Planning:
(First sentence).
The specific items to be governed by the Standard may not be identified. However, the Standard is part of the PSNH Operational' Quality Assurance Program and will, therefore, be applied to those structures, systems, and I
components which are referenced in section 17.2.2.2 of this document.
b.
With regard to Section 3.1 ANSI N45.2.2 - 1972 titled General:
(Last sentence). Many of the requirements of Appendix A-3 are unnecessarily restrictive and prescriptive.
Therefore, those requirements may be neither the best nor the most effective l
methods to achieve the desired quality goals. PSNH will con-sider all items in Appendix A-3 during the development of our own criteria.
Controlled reviews will be conducted by Technical and Nuclear Quality staffs to determine and identify the appropriate controls or alternatives for the specific 17A-5 l
SB 1 & 2 FSAR structure, system, or component and activity.
This clarifica-tion applies whenever Appendix A-3 or its subparts is re ferenced.
With regard to Section 3.2.1 of ANSI N45.2.2 - 1972 titled c.
Level A Items:
In subsection (1) tesperature and humidity control considerations for packaging of Level A items are not considered applicable to nuclear fuel assemblies unless recom-mended otherwise by the nuclear fuel manufacturer. PSP.H will abide by the Manuf acturer's recommendation. As an alternate to the requirements for packaging and containerizing items in storage to control contaminants, Subsections (4) and (5), PSNH may choose a storage atmosphere which is free of harmful con-taminants in concentrations that could produce damage to stored items.
Similarly PSNH may obviate the need for caps and plugs with an appropriate storage atmosphere, and may choose to pro-tect weld end preparations and threads by controlling the manner in which the items are stored.
The clarifications apply whe-never items (4), (5) or (7) are subsequently referenced and to Section 3.5.1 titled Caps and Pluss and Section 3.4 titled Methods of Preservation.
d.
With regard to Section 3.5.2 of ANSI N45.2.2 - 1972: The last j
sentence is revised to read:
" Tapes used for identification l
rather than sealing which are not near a welding operation may remain idefinitely (see also Appendix Section 3.5.2 for addi-tional requirements)."
e.
With regard to Section 3.7.1 of ANSI N45.2.2 - 1972 titled Containers:
Cleated, sheathed boxes may be used up to 1000 lbs. rather than 500 lbs. as specified in 3.7.1 (1).
This type of box is safe for, and has been tested for, loads up to 1000 lbs.
Other national standards allow this (see Federal l
Specification PPP-B-602).
Special qualification testing may be l
required for loads above 1000 lbs.
f.
With regard to Section 3.7.2 of ANSI M45.2.2 - 1972 titled Crates and Skids: Skids or runners will normally be used on containers with a gross weight of 100 lbs. or more.
If forklif t handling is required, minimum floor clearance for forklift eines will be provided.
g.
With regard to Sections 4.3, 4.4, and 4.5 of ANSI N45.2.2 -
1972:
PSNH will comply with the requirements of these Sections, subject to the clarifications taken to other Sections which are referenced therein, if shipments are from PSNH to another nuclear facility. Alternatively, since PSNH will not normally be a " shipper", PSNH might be subject to the require-ments of this Section for shipments frae Seabrook to another nuclear facility. Seabrook, when involved in such shipments, 17A-6 l
t
r SB 1 & 2 FSAR will comply with the requirements imposed by the receiving plant in their procurement document covering the shipment.
h.
With regard to Section 5.2.1 of ANSI N45.2.2 - 1972 titled Shippina Damage Inspection: Warehouse personnel will normally visually scrutinine incoming shipments for damage of the types listed in this Section; this activity may not be performed prior to unloading. The person performing an inspection func-tion as defined under Regulatory Guide 1.74; therefore, while he will be trained to perform this function, he may not be cer-tified (N45.2.6) as an Inspector.
i.
With regard to Section 5.2.2 - Item Inspection: In lieu of the requirement that "The inspections shall be performed in an area equivalent to the level of storage requirements for the ites",
PSNH shall perform receiving inspections in a manner and in an environment which does not endanger the requisite quality of the item. Receiving crea environmental controls, however, may be less stringent than storage environmental controls for that item. This determination shall be doctmented and approved by the Engineering Services Department.
Quality Assurance will review procedures to assure proper controls are incorporated.
When inspections are performed in receiving areas with environ-mental controls less stringent than storage area environmental controls, a time limit shall be established on a case basis for retention of items in the receiving area. Retention time shall be such that det;erioration is prevented and applicable manufac-turer recommendations are addressed.
This approach is justified since receipt inspection activities are for a much shorter duration and therefore should not be subjected to the same stringent requirements as required for l-storage.
j.
With regard to Section 5 2.3 - Special Inspection: PSNH takes exception to the requirement that "Special Inspection" proce-dures shall be attached to the item. The "Special Inspection" procedure shall be readily available to inspectica personnel and may be attached to the item or containers.
The procedure being used will be traceable to the item or lot.
k.
With regard to Section 6.1.2 (1) of ANSI N45.2.2 - 1972:
Temperature and humidity controls required for the storage of Level A items are not considered applicable for nuclear fuel l
assertlies unless recommended otherwise by the nuclear fuel manuf a curer. PS!El will abide by the manuf acturer's recommen-dation.
See remarks under Section 3.2.1 above.
1.
With regard to Section 6.2.1 of ANSI N45.2.2 - 1972 titled Access to Storate Areas:
Items which fall within the Level D
- 74-7
-w m-
,__.,--m.
classification of the Standard will be stored in an area which may be posted to limit access, but other positive controls such as fencing or guards will not normally be provided.
With regard to Section 6.2.4 of ANSI N4.2.2 - 1972 titled m.
Storage of Food and Associated Items: The sentence is clarified to read; "The use or storage of food, drinks, and salt tablet dispensers in any storage area shall be controlled and shall be limited to designated areas where such use or storage is not deleterious to stored items."
With regard to Section 6.4.2 of ANSI N45.2.2 - 1972 titled care n.
of Items: The following alternatives are provided for indi-cated subsections:
(5)
" Space heaters enclosed in electrical items shall be energized unless a doctmented engineering evaluation determines that such space heaters are not required."
(6)
"Large (over 50 h.p.) rotating electrical equipment shall be given insulation resistance tests on a sche-duled basis unless a documented engineering evaluation determines that such tests are not required."
(7)
" Prior to being placed in storage, rotating equipment weighing over approximately 50 pounds shall be evaluated by engineering personnel, with due regard for the manufacturer's recoseendation, to determine if shaf t rotation in storage is required; the results of the eva-luation shall be doctasented.
If rotation is required, it shall be performed at specified intervals, be docu-mented, and be conducted so that parts receive a coating of lubrication where applicable, and so that the shaf t does not come to rest in the same position occupied prior to rotation.
For long shafts or heavy equipment subject to undesireable bowing, shaf t orientation af ter rota-tion shall be specified and obtained."
o.
With regard to section 6.5 of ANSI N45.2-1972 titled Removal of Items from Storage:
PSNH will' comply with this section except for those items installed and used without additional storage in a temporary holding area.
p.
With regard to Section A3.4.1 of the Appendix ANSI N45.2.2 -
1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Contact Preservatives: During printing of the standard a transposition occurred between the last sentence of A3.4.1 (4) and A3.4.1 (5).
The correct requirements are:
SB 1 & 2 FSAR (4) "However, the preservatives for inaccessible inside sur-faces of pumps, valves and pipe systems containing reactor coolant water shall be water flushable type."
(5) "The name of the preservative used shall be indicated to facilitate touch-up."
q.
With regard to Section A3.5.1 (1) of the Appendix to ANSI N45.2 2 - 1972 titled Caps and Pluas In lieu of the require-ment that nonmetallic plu;s and caps shall be brightly colored, PSNH shall require the non-metallic plugs and caps be of a contrasting color.
With regard to Section A3.6.2 of the Appendix to ANSI N45.2.2 -
r.
1972 titled vapor Barrier Material: The last sentence is con-sidered unnecessary guidance and not an appropriate requirement. Vapor barrier materials will be of a contrasting color to prevent loss in a system.
With regard to Section A3.7.1 of the Appendix to ANSI N45.2.2 -
s.
1972 titled Fiberboard Bdxes:
In lieu of the specific require-ments for containers, PSNH will require that containers shall be of suitable construction to assure that material is received undamaged.
Since this is the intent of this section, its con-tent will be considered as general guidance and adapted to accomplish the intended purpose with due regard for the actual condition of shipment and design of containers and sealing devices.
With regard to Section A3.9 to the Appendix of ANSI N45.2.2 -
t.
1972 titled Markina:
In lieu of the specific requirements of Subsections (1), (4), and (6) of the reviewed group, PSNH shall use this information as general guidance and shall ensure that markings on the outside of container's are as numerous as necessary for identification, traceability and instructions for special handling.
Regulatory Guide 1.39 Housekeeping Requirements for (Rev. 2, 9/77)
Water-Cooled Nuclear Power Plants Endorses ANSI N45.2.3 - 1973 During the Operations Phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
With regard to Section 2.1 and 3.2 of ANSI N45.2.3 - 1973 titled respectively, Planning and Control of Facilities:
17A-9 l
t SB 1 & 2 FSAR The zone designations and the requirements associated with each sone are not consistent with the requirements for an operating plant. While the zones used are not defined or utilised during the operations phase, the intent of the controls in paragraph 3.2 will be complied with.
Procedures or instructions for housekeeping activities, which include the applicable requirements outlined in Section 2.1. and which take into account radiation control considerations, security considerations, cleanliness requirements and personnel considerations are developed on a case basis for maintenance and modification work to be performed.
As necessary, control of personnel, tools, equipment, and supplies will be established when major portions of safety-related systems are opened for inspection, maintenance, or repair.
Regulatory Guide 1.58 Qualification of Nuclear Power Plant (Rev. 1, 9/80)
Inspection, Examination and Testing Personnel Endorses ANSI N45.2.6 - 1978 During the Operations phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarifications PSNH may choose not to apply the requirements of this guide to a.
those personnel who are involved in day-to-day operations, sur-veillance, maintenance and certain technical and support ser-vices whose qualifications are controlled by Regulatory Guide 1.8 Rev. 1-R.
t l
b.
With regard to Position C1 and Section 1.2 of ANSI N45.2.6 -
1978:
Personnel who approve operational test procedures and test results and who direct such test activities will be qualified in accordance with the requirements of Regulatory t
Guide 1.8 with ANS 3.1 - 1978 used in lieu of ANSI N18.1 -
1971Property "ANSI code" (as page type) with input value "ANSI N18.1 -</br></br>1971" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
c.
With regard to Section 2.5 of ANSI N45.2.6 - 1978; PSNH will implement the requirements of this Section with the stipulation that, where no special physical characteristics are required, none will be specified.
The converse is also true:
if no spe-cial physical requirements are stipulated by PSNH, none are considered necessary.
d.
With regard to position C.8 of the Regulatory Guide, the ALARA guidelines of Regulatory Guide 8.8 will be followed as discussed in FSAR Section 12.1.
Regulatory Guide 1.64 Quality Assurance Requirement for the (Rev. 2, 6/76)
Design of Nuclear Power Plants Endorses ANSI N45.2.11 - 1974 I
i 17A-10 i
i
SB 1 & 2 FSAR During ths Operations phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
With regard to paragraph C.2 (1) of Regulatory Guide 1.64: If a.
in an exceptional circumstance the designer's immediate Supervisor is the only technically qualified individual available, this review may be conducted by the Supervisor, pro-viding thst:
(a) the justification is individually doctmented and approved in advance by the Supervisor's management, and (b) i quality assurance audits ccver frequency and effectiveness of l
use of Supervisors as design verifiers to guard against abuse.
Regulatoy Guide 1.74 Quality Assurance Terms and Definitions (Rev. O, 2/74)
Endorses ANSI N45.2.10 - 1973 l
During the Operational Phase, the Operational Quality Assurance Program includes and complies with this guide with the clarification presented in t
Section 1.8 of this FSAR.
Regulatory Guide 1.88 Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records Endorses ANSI N45.2.9 - 1974 t
l During the Operational Phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a)
With regard to Section 3.2.1 of ANSI N45.2.9 - 1974 titled Generation of Quality Assurance Records: The phrase
" completely filled out" is clarified to mean that sufficient information is recorded to fulfill the intended purpose of this record.
b)
With regard to Section 3.2.2 of ANSI N45.2.9 - 1974 titled Index: The phrase of "an index" is clarified to mean a collec-tion of documents or indices which, when taken together, supply the information attributed to "an index" in the standard.
The specific location of a record "within a storage area" may i
not be delineated (e.g. The specific location within a computer record file may not be constant.
Further, PSNH may utilize a computer assisted random access filing system where such loca-tion could not be readily "doctmented", nor would such a loca-tion be " relevant".) The storage location will be delineated, but where file locations change with time, the specific loca-tion of a record within that file may not always be doctmented.
c)
With regard to Section 3.2.6 of ANSI N45.2.9 - 1974 titled Supplemental Information to Records:
The first sentence is clarified to read as follows:
" Records may be corrected or supplemented in accordance with procedures which provide for appropriate review or approval by the originating organization or other organizations specifically designated."
d)
With regard to Section 4.2 of ANSI N45.2.9 - 1974 titled Timeliness:
PSNR's contractual agreement with its contractors and suppliers will constitute fulfillment of the requirements of this Section.
i e)
With regard to Section 5.4 of ANSI N45.2.9 - 1974 titled Preservation: The following clarification is substituted for the current subsection 2:
" Records shall not be stored loosely.
They shall be secured for storage in file cabinets or on shelving in containers."
The following clarification is substituted for the current sub-section 3:
" Provisions shall be made for special processed records (such as radiographs, photographs, negatives, microfilm and magnetic media) to prevent damage from excessive light, stocking, electromagnetic fields, temperature and humidity as recommended by the manufacturer of these materials."
f)
With regard to Section 5.5 of ANSI N45.2.9 - 1974 titled l
Safekeeping: Routine general office and nuclear site security i
systems and access controls are provided.
No special security systems shall be established for record storage areas.
g)
With regard to Section 5.6 of ANSI N45.2.9 - 1974 titled Facility: This Section provides no distinction between ten-porary and permanent facilities.
To cover temporary storage, the following clarification is added:
" Active records (permanent and/or temporary) will be stored in one-hour fire rated file cabinets.
In ge'neral, records shall not be main-tained in such temporary storage for more than six months af ter completion."
Subsection 3 is clarified to require a two-hour minimum fire rating to be consistent with the 1979 version of the Standard and NRC Criteria for Record Storate Facilities, NRC Guidance on ANSI N45.2.9, Section 5.6 issued 7/1/80).
Subsection 9 is clarified to read:
"No pipes or penetrations except those providing fire protection, lighting, temperature / humidity control, or communications are to be located within the facility. All such penetrations shall be sealed or dampened to comply with a minimum two-hour fire pro-tection rating."
17A-12 l
With regard to Section 5.7 of ANSI N45.2.9 - 1974 titled Audits: The audit of " location within the file" is subject to the clarification of a similar phrase in Section 3.2.2.
Regulatory Guide 1.94 Quality Assurance Requirements for (Rev. 1, 4/76)
Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants Endorses ANSI N45.2.5 - 1974 The reconsendations of this guide have been complied with, except as indi-cated below.
Where pumped concrete is sampled for testing at a point other than the pla-cement point, correlation testing in accordance with Section 6.11 of the 1978 edition of ANSI N45.2.5 is performed.
In addition the concrete at the placement point is inspected for segregation, placement and proper corr-solidation in accordance with approved procedures.
Certain bolt holes in structural steel are burnt, according to th'e following practice:
Round holes are punched or drilled, according to the thickness a.
of the material.
b.
Long and short slotted holes are either singly punched to finished dimensions or double punched or drilled and flame cut to approximately finished dimensions, depending on the thickness of the material. All flase cut edges are ground to remove all slag, roughness and heat-affected area.
Anchor bolt holes in base plates are made either by punching, c.
drilling cr flame cutting.
Flase cutting is permitted only for those holes in which lateral bearing loads are not transferred through the burnt surface.
For further discussion, refer to Subsections 3.8.1.6, 3.8.3.6 and 1.8.
l Regulatory Guide 1.116 Quality Assurance Requirements for (Rev. O-R, 6/76, 5/77)
Installation Inspection and Testing of Mechanical Equipment and Systems Endorses ANSI N45.2.8 - 1975 During the Operational phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
l 17A-13 l
l
SB 1 & 2 FSAR With regard to Section 2.3 of ANSI N45.2.8 - 1975: Last sen-a.
tence is revised to read, " Test reports shall include an eva-luation of the acceptability of inspection and test results and identify the individual who performed the evaluation."
b.
With regard to Section 2.8.2 of ANSI N4.2.8 - 1975 which states:
" Records of calibration shall be included in inspec-tion and test results:" PSNH may not include calibration records in inspection and test results.
Instead, the calibra-tion records will be maintained in separate file.
With regard to Section 2 9e (6) of ANSI N45.2.8 - 1975 which c.
states:
" Evidence that engineering or design changes are docu-mented and approved prior to installation:" PSNH may permit installation of an item prior to approval of the related engi-neering or design change provided procedural controls are l
instituted which require evidence of engineering or design change approval prior to placing the affected item into service which relies on it for a safety function.
d.
With regard to Section 3 2 of ANSI N45.2.8 - 1975:
In the second sentence, PSNE will check identification of an ites prior to release for installation; however, option is main-tained to knowledgeably install equipment lacking full iden-tification providing deficiencies are resolved prior to its use in service which relies on it for a safety function.
Such action is recorded in quality control documents.
Regulatory Guide 1.123 Quality Assurance Requirements for (Rev. 1, 7/77)
Control of Procurement of Items and Services for Nuclear Power Plants l
Endorses ANSI N45.2.13 - 1976 During the Operational Phase, the Operational' Quality Assurance Program includes and complies with this guide with the following clarification:
a..
With regard to Section 1.2.2 of ANSI M45.2.13 - 1976 titled Purchaser's Responsibilities:
(a) Itse d is interpreted to l
mean that PSNH will assure that the appropriate requirements of l
the Operational Quality Assurance Program will be implemented.
ANSI N45.2 (refe.enced by this item) is not included in the PSNH Operational QA Program, although equivalent controls are established by way of the Program's comitments to other ANSI standards and regulatory Guides.
b.
With regard to Section 1.3 of ANSI N45.2.13 - 1976 titled Definitions:
(a) The definition of " procurement document" given in ANSI N45.2.10 - 1973 will be used in lieu of the defi-nition of the same words given in this Section.
17A-14 i
m
SB 1 & 2 FSAR With regard to Section 3.2.2 of ANSI N45.2.13 - 1976 titled c.
Technical Requirements: The first sentence is revised to read:
" Technical Requirements shall be specified in the procurement documents and/or, where appropriate, by reference to or inclu-sion of the specific drawings, specifications, codes, regula-tions, procedures or instructions including revisions thereto that describe the items or services to be furnished."
l Reaulatory Guide 1.144 Auditing or Quality Assurance Programs l
(Rev. 1, 9/80) for Nuclear Power Plants Endorses ANSI N45.2.12 - 1977
- During the Operations phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
With regard to Section 3.3 of ANSI N45.2.12 - 1977 titled a.
Essential Elements of the Audit System: PSNH will comply with subsection 3.3.5 revised to read:
" Provisions for reporting on the effectiveness of the quality assurance program to the responsible management." Other than audit reports, PSNH may not directly report the effectiveness of the quality assurance programs to the audited organization when such organizations are outside of PSNE.
b.
With regard to Section 3.5 of ANSI N45.2.12 - 1977 titled Schedulina:
Subsection 3.5.3.1 is interpreted to mean that PSNH may procedurally control qualification of contractor's or vendor's quality assurance program, prior to awarding a contract or purchase order, by means other than audit.
c.
With regard to Section 4.3.1 of ANSI N45.2.12 - 1977 titled Pre-Audit Conference:
PSNH will comply with the requirements of this Section by inserting the word "Normally" at the beginning of the first sentence.
This clarification is required because, in the case of certain unannounced audits or audits of a particular operational or work activity, a pre-audit conference might interfere with the spontaneity of the operation or activity being audited.
In other cases, persons who shculd be present at a pre audit conference may not always be available; such lack of availability should not be an impediment to beginning an audit. Even in the above examples, which are not intended to be all incusive, the material set forth in Section 4.3.1 will be covered (if considered necessary or desireable) during the course of the audit.
d.
With regard to Section 4.4 of ANSI M45.2.12 - 1977 titled Reportina: PSNH will comply with Subsection 4.4.3 clarified to read:
" Supervisory level personnel with whom major interactions or significant discussions were held during the 17A-15 yx r.
SB 1 & 2 FSAR course of pre-audit (where conducted), audit, and post-audit (where conducted) activities."
Regulatory Guide 1.146 Qualification of Quality Assurance (Rev. 9, 8/80)
Program Audit Personnel for Nuclear Power Plants Endorses ANSI N45.2.23 - 1978
- During the Operations phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
With regard to Section 3.2 of ANSI N45.2.23 - 1978 titled a.
Maintenance of Proficiency: PSNH will comply with the require-ments of this Section by defining " annual assessment" as one which takes place every 12+3 months and which used the initial date of certification (not the calendar year) as the starting dr.te for determining when such annual assessments are due.
b.
With regard to Section 4.1 of ANSI N45.2.23 - 1978 titled 1
Ormanizational Responsibility: PSNH will comply with this Section with the substitution of the following sentence in place of the last sentence in the Section:
"The Nuclear Quality Manager, Quality Assurance Department Supervisor, or Lead Auditor shall, prior to commencing the audit, assign per-sonnel who collectively have experience or training commen-surate with the scope, complexity, or special nature of the activities to be audited."
With regard to Section 5.3 of ANSI N45.2.23 - 1978 titled c.
Updatina of Lead Auditor's Records:
PSNR will substitute the following sentence for this Section:
" Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Section 3.2 (as clarified).
i I
l 17A-16 ar--
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=
w APPENDIX 17 B MATRIX OF 10 CFR 50 APPENDIX B CRITERIA V
S. PROCEDURE
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PROCEDURE TITLE MATERIAL / CONTROL /STORACE REQUEST MATERIAL / SHIPPING / RETURN X
X MATERIAL INVENTORY X
MATERIAL ISSUE X
X MATERIAL START-UP/ TURN-OVER/ ISSUE X
X DESIGN CHANGE PREPARATION X
DESIGN IMPLEMENTATION X
XX ENGINEERING CALCULATIONS X
DESIGN VERIFICATION X
X MEASURING AND TEST EQUIPMENT PROCEDURE X
l CONTROL OF SPARE PARTS DATA FORMS X
X CONTROL OF NON-CONFORMANCES X
BID EVALUATION X
ASSICNMENT OF PROCUREMENT LEVEL
'X RECEIVING X
X RECEIPT INSPECTION X
~
ASSIGNMENT OF PROCUREMENT CLAUSES X
~
PREPARATION AND REVIEW OF SPECIFICATIONS X
MATERIAL PURCHASE REQUEST PROCEDURE X
COhAERCIAL ITEMS LIST X
X VERIFICATION ITEMS LIST X
X CERTIFICATION OF STATION INSPECTORS X
X SOURCE SURVEILLANCE X
X OPERATION OF THE RECORDS CENTER X
X HARD COPY FILES MAINTENANCE X
X FIRE PROTECTION PLAN X
X CORRESPONDENCE CONTROL X
RECORDS RETENTION X
X RECORDS STORAGE X
X DRAWING CONTROL DISTRIBUTION XX X
PROCEDURES DISTRIBUTION AND CONTROL X
MANUALS DISTRIBUTION AND CONTROL X
EQUIPMENT CONTROL X
IN PLANT AUDITS X
X DOCUMENT INDEXING X
STATION MANUAL PROCEDURE X
DOCUMENT MICRO-FILMING X
173-1
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s o = - z v e PROCEDURE TITLE QUALITY CONTROL INSPECTIONS PLANT HOUSEKEEPING PROGRAM 4XX CORRECTIVE ACTION X
SATELLITE STATION FILE MAINTENANCE X
TURN-OVER AND TRANSMITTAL OF NUCLEAR RECORDS X
MAINTENANCE PROGRAM X
PREVENTIVE MAINTENANCE PROGRAM X
CORRECTIVE MAINTENANCE PROGRAM X
MAINTENANCE RECORD AND SCHEDULING SYSTEM X
GENERAL LIFTING AND HANDLING PROCEDURE X
N. PROCEDURE
FOR CONTROL OF MAINTENANCE X
DEPARTMENT MEASURIUG AND TESTING EQUIPMENT X
X CONTROL OF TECH SPEC RELATED TESTING X
CONTROL OF IN-SERVICE INSPECTION TESTING X
TEST CONTROL PROCEDURE X
LICENSEE EVENT REPORTS X
X SITE OPERATIONS REVIEW COMMITTEE RESPON.
XX SWITCHING AND TAGGING OF PLANT EQUIPMENT XXXXXX)<XXXXXXXXXX BYPASS OF SAFETY FUNCTION AND JUMPER CONTROL XX X
X QUALIFICATION AND TRAINING OF PERSONNEL XX GENERAL EMPLOYEE TRAINING FIRE PROTECTION TRAINING kNX EMERGENCY PLAN TRAINING HOUSEKEEPING FOR MAINTENANCE NUCLEAR SAFETY AUDIT AND REVIEW COMMITTEE XX 17B-2
,w-s -
CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr.,
one of the attorneys for the Applicants herein, hereby certify that on February 14, 1983, I made service of the within " Applicants' Eighteenth Motion for Summary Disposition (Contentions NECNP II.B.1,
.3,
.4 and
.5)," by mailing copies thereof, postage prepaid, to:
Helen Hoyt, Chairperson Rep. Beve"ly Hollingworth Atomic Safety and. Licensing Coastal Cnamber of Commerce Board Panel 209 Winnacunnet Road U.S. Nuclear Regulatory Commission Hampton, NH 03842 Washington, DC 20555 Dr. Emmeth A. Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 1725 I Street, N.W.
U.S. Nuclear Regulatory Commission Suite 506 Washington, DC 20555 Washington, DC 20006 Dr. Jerry Harbour E. Tupper Kinder, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Office of the Attorney General U.S. Nuclear Regulatory Commission 208 State House Annex Washington, DC 20555 Concord, NH 03301 Atomic Safety and Licensing Roy P. Lessy, Jr., Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Commission Director i
Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Robert A. Bar--:a, Esquire Board Panel 116 Lowell $rrisc U.S. Nuclear Regulatory Commission P.O.
Boy l
Washington, DC 20555 Manchesso., by C3105 -
O
~
Philip Ahrens, Esquire Edward J. McDermott, Esquire Assistant Attorney General Sanders and McDermott Department of the Attorney Professional Association General 408 Lafayette Road Augusta, ME 04333 Hampton, NH 03842 David L.
Lewis Jo Ann Shotwell, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission Department of the Attorney General Rm. E/W-439 One Ashburton Place, 19th Floor Washington, DC 20555 Boston, MA 02108 Mr. John B. Tanzer Ms. Olive L. Tash Designated Representative of Designated Representative of the Town of Hampton the Town of Brentwood 5 Morningside Drive R.F.D.
1, Dalton Road Hampton, NH 03842 Brentwood, NH 03833 Roberta C.
Pevear Edward F. Meany Designated Representative of Designated Representative of the Town of Hampton Falls the Town of Rye Drinkwater Road 155 Washington Road Hampton Falls, NH 03844 Rye, NH 03870 Mrs. Sandra Gavutis Calvin A. Canney Designated Representative of City Manager the Town of Kensington City Hall RED 1 126 Daniel Street East Kingston, NH 03827 Portsmouth, NH 03801 f)
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Th M Dign
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- - - - - - -