ML20072T969
| ML20072T969 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/10/1991 |
| From: | NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20072T958 | List: |
| References | |
| NUDOCS 9104180351 | |
| Download: ML20072T969 (104) | |
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Q A POLICY DOCUMENT REVISION 7
.3UMMARY OF Cil ANGES Page QA Program A
Reduction Summary of Changes 13 No Clarified statement on training requirements.
1 10 No Clarified title and definition.
1-11 No Clarified titles.
1-12 No Clarified definition.
1 17 No Corrected reference.
2-3 No Added statement to identify that 'lable I is not considered all inclusive.
2 13 No Corrected title.
2 15 No Added definition of document hierarchy.
2 20 No Corrected typographical error. Added clarification.
2-21 No Corrected grammatical error.
3-3 No Corrected punctuation.
36 No Deleted reference.
38 No Clarified title.
3 12 No Corrected reference.
3-13 No Corrected references. Corrected title.
3 14 No Corrected references.
4-1 No Corrected title.
4-5 No Added clarifying information.
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Page 2 of 2 Page QA Program A
Reduct10D Summary of Changes 4-6 No Added clarifying informatiot 47 No Added clarifying information.
5-1 No Corrected reference.
93 No Added the Instrument Air System to those covered by QA Program.
95 No Corrected titles.
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s NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION OUALITY ASSURANCE PROGRAM FOR OPERAILOR POLICY DOCUMENT TABLE OF CONTENTS Corporate Policy Statement.............................. v 1.0 PROGR A M DEFINITION............................
1 1 1.1 Purpose...................................12 1.2 Pol ic y....................................
1 2 1.3 Objectives
.................................15 1.4 Scope
....................................17 1.5 Definition of Terms........................
1 8 2.0
SUMMARY
DESCRIPTION
..........................21 2.1 Organization
...............................21 2.2 Quality Assurance Program...,............,,.....
2 2 2.3 Design Control 2-5 2.4 Procurement Document Control 2 12 2.5 Instructions, Procedures & Drawings 2 15 2.6 Document Control 2-17 i
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TABLE OF CONTENTS (Cont'd)
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I 2.7 Control of Purchased hiaterial, Equipment, and Services...............................
2-19 2.8 Identification and Control of Parts, hinterials, 2 20 and Components 2.9 Control of Special Processes 2 21 2.10 Inspection 2 22 2.11 Test Control 2 24 2.12 Control of hicasuring and Test Equipment 2 25 2.13 liandlint., Storage, and Shipping 2 26 2.14 Inspection, Testing, and Operating Status 2-28 2.15 Nonconforming hiaterials, Parts, or Components 2-29 2.16 Corrective Action............................. 2 31 2.17 Quality Amrance Records 2 33 2.18 Aud its...................................
2-34 2,19 Additional ANSI Standards 2 35 3.0 ORGANIZATION AND RESPONSIBILITIES
...............31 3.1 General...................................
3-1 3.2 Nuclear Power Group hianagement
.............,....32 3.2.1 Vice-President - Power Production
.............32 3.2.2 Nuclear Power Group hianager
...............32 il Revision 7
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TABLE OF CONTENTS (Cont'd) 3.2.3 Division Manager, Quality Assurance............
3-3 3.2.4 Quality Assurance Manager CNS
.............35 3.2.5 Quality Assurance Manager CGO
,...........36 3.2.6 Quality Assurance Supervisors
...............38 3.2.7 Quality Assurance Staff
....................38 3.2.8 Division Manager Nuclear Engineering and Construction 3 10 3.2.9 Division Manager Nuclear Operations 3 11 3.2.10 Division Manager - Nuclear Support 3 11 3.2.11 CGO Department Managers 3 12 3.2.12 CNS Department Managers 3 12 3.3 Cooper Nuclear Station Personnel....,.............. 3-12 3.4 COO Personnel 3 13 3.5 Safety Review and Audit Board (SRAB) 3-13 3.6 Station Operations Review Committee (SORC) 3 14 3.7 Outside Suppliers, Contractors, Subcontractors, and Consultants 3 14 ill Revision 7
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TABLE OF CONTENTS (Cont'd) 4.0 QUALITY ASSURANCE DOCUMENTS 41 4.1 NPPD Internal Documents 4-1 4.1.1 Quality Control Inspection
..................42 4.1.2 Quality Assurance Instructions (QAI)............
4-4 4.1.3 Quality Assurance Plans (QAP) 4-4 5.0 METHOD OF IMPLEMENTATION
.....................51 6.0 RECORDS RLTENTION AND DISPOSITION 6-1 7.0 R EF E R EN C ES...................................
7 1 8.0 FI G U RES......................................
8 1 8.1 Quality Assurance Organizational Chart (Figure 1).........
81 9.0 TABLES 91 9.1 Systems and Components Within Scope of the CNS QA Program (Table 1)
............................91 9.2 Three Leve! QA Program (Table 2)..................
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s CORPORATE POLICY STATEMENT This document establishes and. describes the policies and practices of the Quality Assurance Program applicable to the operation of the Cooper Nuclear Station and the support activities of all NPPD Nuclear Divisions. The District's policy with respect to nuclear safety and quality assurance is detailed in Section 1.2 of this document.
Each Nuclear Division is responsible for the development of policies and procedures which implement this Quality Assurance Program. Other divisions and departments at NPPD may also have esponsibilities under this program and shall comply as described in appropriate implementing procedures.
The Quality Assurance Division and established Safety Committees shall monitor the District's nuclear program and provide management with evaluations and assessments regarding the effectiveness of the implementation of the program. When evaluations and assessments identify a concern, management shall take expeditious action to correct any undesirable condition (s) including, where appropriate, action to preclude repetition of such condition (s).
District personnel shall have the organizational freedom to identify concerns and propose corrective and preventive action necessary to enhance the District's nuclear program.
The assurance of safe and reliable operation of Cooper Nuclear Station is everyone's duty. Quality shall be everyone's responsibility.
APPROVED:.
President
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~'W u 'l s, Nuclear Power Group Manager G
lEW'
] n5&
sA Vice Piesidsnt - Power Production Division Manager - Quality Assurance v
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COOPER NMCLEAR STATION OUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT 1,0 PROGRAM DEFINITION in accordance with the conditions of the Nuclear Regulatory Commission construction permit and operating lleense for the Cooper Nuclear Station, the management of Nebraska Public Power District recognlics its responsibility for assuring that the Cooper Nuclear Station is designed, constructed, and operated in such a manner as to provide for the safety of the public. The importance of Quality Assurance in contributing to this f.afety as well as contributing to station reliability is also recognized.
The initial phases of the overall Quality Assurance Program, implemented during design and construction, provided an independent check for the work performed on components, structures, and systems of the station to assure that the design, analysis, materials of construction, manufacture, installation, erection, and construction met quality standards required to assure reliable and safe operation. The CNS Quality Assurance Program for Operation, as described herein, is implemented to provide an independent quality check on all phases of station operation, maintenance, and modification, I
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1.1 PurLet The purpose of this policy document is to provide a description of the Quality Assurance Program to be followed during Cooper Nuclear Station operational phase and to provide guidelines for implementation of the policies and procedures described herein. This CNS Quality Assurance Program for Operation was developed by Nebraska Public Power District in response to the requirements of 10CFR$0, Appendix 11. This policy document provides a general description of the Quality Assurance Program for Operation and requires that detailed Quality Assurance Documents be set forth in writing and carried out by each of the responsible organizations or individuals within the District, 1.2 Enlicy It is the policy of Nebraska Public Power District (NPPD) to use its best efforts to assure that the Cooper Nuclear Station is designed, constructed, maintained, and operated in a manner that will provide the highest practical degree of safety and reliability. Structures, components, and systems are designed, fabricated, crected, maintained, and modified to quality standards appropriate to their importance in the safety function. The Quality Assurance Documents will identify those structures, systems, and major components to be covered by the Quality Assurance Program in order to provide continuing compliance with these standards throughout the operating life of the station. Additionally, it is the policy of NPPD that activities affecting quality shall be documented by approved instructions, procedures, or drawings and such activities shall be implemented as 12 Revision 7
documented. And further, such documentation shall contain adequate qualitative and/or quantitative acceptance criteria to provide a measure of accomplishment.
It is the policy of Nebraska Public Power District (NPPD) to staff the Nuclear Power Group (NPG) with properly trained personnel in all responsible positions and job assignments. Suf6cient numbers of licensed and senior lleensed operating personnel will be available to assure proper operation of the station under all reasonably foreseeable circumstances of personnel turnover, vacations, disability, and the like.
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All District personnel, as well as non District personnel who work indbpendently under NPPD's QA Program hijdlare responsible for operating, maintaining, or designing safety related systems and equipment shall receive formal instruction in Quality Assurance, including basic principles,10CFR$0, Appendix B, the contents of this policy document, and Quality Assurance Documents as applicable, Trained technical, engineering, and Quality Assurance Personnel shall be assigned l
surveillance and audit tasks to ensure compliance with the requirements of the documents -
which control station operation, such as the NRC license, Safety Analysis Report, Technical Specl6 cations, Operating Manual, QA Program for Operation, and other such controlling documents. During the time personnel are performing QA functions, they shall be responsible to the QA Division to maintain the organizational independence required by the QA Program.
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It is the policy of Nebraska Public Power District to maintain quality standards for Cooper Nuclear Station which will ensure the high degree of reliability and safety needed to meet the overall objectives of supplying dependable electric service to its customers.
The CNS QA Program for Plant Operations will utilire the guidance provided by NRC publicationsWASil-1283(5 24 74),WAsib1284(10 26 73),andWASil.1309(510-74)
(" rainbow" series) except where specific exceptions and clarifications are noted within this document. Where specific requirements included in the standards are in confilet with original design requirements set forth in the USAR and other appropriate design documents, the original design requirements shall govern.
Later revisions may be specifically invoked by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than ori ;inal" l
condition, in summary, NPPD is committed to the continuous development of a Quality Assurance Program which will meet the requirements of 10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and other applicable regulations as may be promulgated by the Nuclear Regulatory Commission. This commitment applies to all NPPD organizations to assure that a high standard of quality will be maintained during nuclear plant operation, Section 2 of this document presents a summary discussion of the QA Program as applicable to the 18 criteria of 10CFR50, Appendix B, 14 Revision 7
1.3 Objectives In accordance with the policy statements above, the overall objective of the CNS Quality Assurance Program for Operation, as defined in Quality Assurance Instructions (QAls) and Quality Assurance Plans (QAPs), is to set forth the Quality Assurance organizational structure and personnel responsibilities and to set forth general requirernents for the preparation of written procedures and controls necessary for quality surveillance and auditing to verify the following:
a)
Regulatory criteria, codes and standards, and desi n bases for safety related E
l systems (as defined in the CNS QA Program) are incorporated into the test, operating, modifications, and maintenance procedures and instructions to meet all requirements for nuclear safety and station reliability; b)
Results of all preoperational and operational tests of safety related systems and components conform to the requirements of the drawings, specifications, procedures, and instructions, and that appropriate reports are prepared to document that all results of tests meet prescribed acceptance criteria; c)
Nuclear Fuct is purchased, designed, manufactured, inspected, packaged, shipped, received, installed, and operated in the reactor in accordance with approved procedures, insttuctions, regulatory requirements, and license stipulations; l-5 Revision 7
d)
The Station is operated, maintained, tested, refueled, repaired, and modined, in accordance with approved procedures, instructions, regulatory requirements, and i
licent.e stipulations, consistent with quality standards equal to or better than those in effect during design and construction; 1
c)
A system is established and maintained to control, safeguard, and permit ready retrieval of quality rnlated documentation generated for materials and components during the design, fabrication, modincation, maintenance, and operation of CNS; i
f)
Appropriate and complete reports, records, and logs are established and maintained so as to provide a continuing record of quality related activities associated with station safety and reliability throughout the life of the station; g)
The NPG personnel are subjected to periodic training, retraining, requalineation, and examination such as to maintain and improve their job skills which are essential to safe and reliable operation of the station; h)
Station security and nuclear fuel accountability and safeguards are maintained in accordance with approved procedures and instructions; i)
Nonconformance reports are to be properly resolved and filed in the quality related record Bles; j)
Inspection reports issued by the NRC are properly resolved and documented; l-6 Revision 7
k)
Spent fuel shipment activities are to be accomplished in accordance with regulatory requirements (10CFR Part 71).
1.4 Steps The QA Program for Operation applies to those nuclear station structures, systems, and g
components that are designed to prevent or mitigate the consequences of postulated accidents which could cause undue risk to the health and safety of the put>lic, and to other selected systems and programs as denned in implementing QA Plans.
The requirements of this program apply to all activities which affect the safety related functions of those structures, systems, and components, including designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-ervice inspection, and modifying.
This program specifically applies to, but is not necessarily limited to the nuclear fuel, the reactor coolant system and its auxiliaries and controls, the reactor protection and enginected safety systems, the reactor containment system, portions of the radioactive waste disposal system, and other systems and components required for safe, efficient, and reliable operation of the plant. A tabulation of those structures, systems, ana components which are covered by the QA Program is given in Table 1.
The Quality Assurance activities governing those structures, systen.s, and major components shall be performed as described in the Quality Assurance Plans (QAPs) (see Section 4.1.3).
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The Quality Assurance Criteria in 10CFR50, Appendix 11, are oriented primarily toward engineering, manufacturing, and construction activities. Therefore, it is necessary to define, by specific Quality Assurance Documents, the manner in which the NRC Quality Assurance Criteria are to be applic41 to the station operating activities. Such Quality Assurance Documents shall be prepared in accordance with the requirements specified in Sections 2.0 and 4.0 of this policy document.
The specifications, principles, and procedures which controlled the original procurement, fabrication, and construction have been carried over into the QA aspects of station operation to the greatest extent practicable, it is the intent of NPPD management to maintain, as a minimum, the quality level achieved in the original design and construction.
1.5 Dsfinition of Terms Key words and phrases used to characterize this QA Program are defined herein to establish a basis for uniform and consistent interpretation of the Quality Assurance requirements. Definitions of these terms are based upon documents and standards issued by the American National Standards Institute (ANSI), NRC Safety and Regulatory Guides, professional societics involved in standards work (ANS, ASME, IEEE, et al.),
and on the basis of contemporary usage in the nuclear power industry; or shall be defined specifically to convey the intent of this particular program. Specific to the related ANSI Standard for this subject, the following commitment applies:
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1.
ANSI N45.2.101973 ' Quality Assurance Terms and Definitions," and the associated Regulatory Guide 1.74, are applicable to the CNS Operational QA Program, with the following cluification:
There may be instances where existing procedures contain definitions that may not be in strict accordance with those provided by this standard. As existing procedures are revised, however, such definitions shall be evaluated to assure that all definitions meet those provided by this standard.
To facilitate review and understanding of this policy document, the following basic terms are defined below along with appropriate QA Program requirements.
Can For piping and valves, CLASS is determined by the applicable ASME Code. For seismic considerations, CLASS is determined by the USAR.
(See also Essential, Non Essential, and Essential Commercial Grade.)
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Documents issued by qualified organizations which contain standardized requirements for particular equipment or applications (c,g., ASTM Material Standards, ASMB Pressure Vestel Code, etc.),
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(Refer also to ANSI N45.2.10 for definition of ' Standard".)
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Controllittglkamem:
All those drawings, specifications, procedures, instructions, manuals, data books, Updated Safety Analysis Reports (US AR). Technical Specifications, and the like, which have been approved and issued by the appropriate authorities, and which prescribe the conditions and limitations under which work is to be performed.
(Refer also to ANSI N45.2.10 for def' ition of Documentation".)
m DesitiLChuge A design change (generic application) is considered to be any change to a component, equipment, or structure that changes the design criteria, configurstion, or margin of safety for a system or component which could impact nucicar safety, equipment and system integrity, or personnel safety. I?or the piirposes of definition.1" design chnnge!
includes Desig' Changes, Equipment Specification Chimges, etc.
n limergency Procetntes (Operating, Maintenance, or Repair) i Those activities which riust be performe..ithout delay in order to:
a)
Avoid furtner degradation of off normal conditions whleh, in themselves, do not constitute an accident, but which could lead to an accident if not corrected promptly; 1-10 Revision 7
b)
Reduce the consequences of an accident or harardous condition which has already occurred; c)
Implement an emergency plan; d)
Prepare for an anticipated act of nature.
Esiential For purposes of applying and implementing this Quality Assumnce Program, the term
'lissential" shall apply to the following:
a)
All systems, structures, equipment, and components which are identified in the USAR as having been designed and built to Seismic Class I requirements; b)
All systems, structures, equipment, components, instruments, and controls which are identified in the USAR as being required to shut down the plant and maintain it in a safe shutdown condition; c)
All other systems, structures, equipment, components, instruments, and controls which are placed in the ' Essential" category by NPPD.
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O Essential Commercial Grade Are items dow end usells; considered ~enentiall that are not subject to design or specification requirements which are unique to nuclear facilities or activities, are used in applications other than nuclear facilities or activities, and are to be ordered from the manufacturer's published product description, e.g., catalog, as off-the shelf items.
Examples include, but are not limited to:
a)
Mechanical components, belts, screws, nuts, seals, washers, and gaskets which have been accepted for use in essential assemblies, b)
Electrical components, resistors, diodes,. capacitors, transistors, wire, fuses, terminal blocks, and lights which have been accepted for use in essential assemblics.
Functional Organiration Chart A pictorial description of the organization as it actually works showing actual lines of direction, supe vision, responsibility, authority, and communication. Such functional l
lines may or rnay not coincide with regular administrative channels.
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Inspettlen The dett:rmination that physical characteristics meet predetermined requirements by visual checks or by other techniques such as X ray, ultrasonic or dye penetrant examination, etc. (See also Quality Control).
(Refer also to ANSI N45.2.10 for dermition of
- Inspection *.)
Licensed _Stallen A nuclear station which is designed and constructed so as to meet requirements of applicable regulatory criteria and is thereby eligible to receive a construction permit and operating license from the U.S. Nuclear Regulatory Commission, biaintenanct_hocedittts Written instructions which define a preplanned maintenance program and prescribe the methods, materials, and processes to be used to assure continuing quality and continuing operation of equipment within required performance characteristics.
Major Maintenance. Repair. or Modification Those maintenance, repair, or modification activities performed on nuclear safety related structures, systems, or components which involve:
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a)
Special craft or procedure qualifications to meet Code, Standard, or Regulatory requirements; b)
Alterations which affect overall structural integrity, essential performance characteristics, or margins of safety in design for nuclear safety related structures, systems, or components; c)
Any permanent chrnge to the facility that requires a Technical Speellication change or creation of an unreviewed safety question.
hlih00.hialDienance. Repair. or Modincation Those maintenance or repair activities which are within a journeyman craftsman's capability, and which:
a)
Are prescribed in the equipment manufacturer's instruction books as necessary or desirable for most effective operation; b)
Are prescribed as part of a preplanned and approved routine or preventative maintenance program; c)
Any permanent change to the facility judged significant enough to warrant documentation that does not require a change in Technical Specification or present an unreviewed safety question.
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Monitor Periodically observe on a formal or informal basis whether work is being performed according to the requirements of the controlling documents (see also Surveillance).
Heatixatial Any structures, equipment, and components which may be important to reactor operation, but are not required for preventing an accident which would endanger the public health and safety, and are not required for the mitigation of the consequences of these accidents.
A Nonessential designated item shall not degrade the integrity of any item designated 11ssential.
Station Permanent Record File The file which is established for the purpose of accumulating and storing all documents and records pertaining to quality related activities throughout the life of the nuclear plant.
Off Normal Condition A condition which results when an operating variable departs from its normal range. To restore normal operating conditions following such a perturbation, action is taken under off-normal procedures so as to correct the condition which, if not corrected, could degenerate into a condition requiring action under an emergency procedure, 1 15 Revision 7
l Operatine Procedsgs Written instructions which define the normal method, means, and limits of operation, in all modes, of a nuclear power station, a system or systems within the station, or station processes.
Quality Assurance All those planned and systematic actions performed for the purpose of establishing a high level of confidence that:
a)
Work performed on the project conforms with the requirements of the applicable codes, standards license stipulations, safety analyses, design drawings, specifications, procedures, and instructions; b)
A structure, system, or component will perform satisfactorily in service; and 1
c)
Appropriate records, documentation and/or drawings are maintained to show compliance with a) and b) above.
Quality Assurance Documents Those documents inclusive of the QA Policy Document, QA Plans, QA Instructions, Procedures (and associated data sheets), logs, etc., which have been approved for use, 1 16 Revision 7
and whose intended function is to provide direction, verification, or documentation for activities affecting quality.
Ouality Assurance Instructions i
Quality Assurance Instructions define the responsibilities for implementation of the QA Program in accordance with policies and practices herein defined, in addition, they provide guidance for surveillance and audit activities to be performed by the QA Staff.
Ouality Assurance Plans Quality Assurance Plans are those documents specifically designed to provide detailed quality requirements for a given functional area. The plans are generated by applying the 18 criteria of 10CFR50, Appendix II, to each functional area and then deriving the speelfic quality requirements for that area.
Ouality Assurance Records Those quality related records (see Reference 7.9) which have been completed and furnish documentary evidence of the quality of items and/or activities affecting quality.
A document becomes a Quality Assurance Record when the activity related to the document becomes part of the operating condition of the plant.
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Ouality Control Those activities which deal directly with the measurement, observation, or verification of physical characteristics of materials, components, or systems which provide a basis for controlling quality to within predetermined limits, or requirements, including adequate quantitative and/or qualliative acceptance criteria by which an activity can be measured.
Quality Requirements Those factors which define limits which must be met so that the product will perform its intended function reliably throughout its design life. They include, but are not limited to, conditions important to pioper material selection, manufacture, construction, and inspectioni substantiation that material or parts conform to all specification requirements,
- esting to demonstrate adequacy of performance; protection of finished parts to prevent deterioration; and conditions for operation, maintenance, and repair which enable continuing operation within prewribed margins of safety and. ithin prescribed performance limits.
l Regulatory criteria That body of NRC publications which define the conditions which must be met to obtain and hold an NRC Construction Ferrnit, Operating License, and Licenses for individual operators.
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Review A deliberately critical examination. The term includes the routine monitoring of station operation performed b.y the Division Manager of Nuclear Operations and his staff as a normal management Amction, and the formal independent evaluations of certain contemplated actions and after the-fact investigation of araomalics conducted by a duly constituted review and audit group, Safeguard (of Nucleat Material)
Measure taken to prevent diversion of nuclear materials into unauthorized or illegal uses I
(see also Accountability).
Safety Related (Sec " Essential")
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Significant Conditions Adverse To Ouality i
Any conditions that could affect safety related structures, systems, or components ability to function within design requirements or adversely alter performance characteristics, l
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Supplier Evaluation Those activities which determine the effectiveness of implementation of the supplier's Quality Assurance Program. A variety of methods may be used to perform a supplier evaluation and are described in QA Instructions.
Surveillance Surveillance is the QA Audit function consist;ng of formal and informal observations to determine that work is being performed in accordance with the requirements of the controlling documents and drawings (see also Audit and Monitor), Surveillance activities shall be performed in accardance with requirements specified in QAPs and QAls, Surveillance Testing Periodic testing of structures, components, and systems related to nuclear safety, for the purpose of verifying that such safety-related structures, components, and systems continue to function or are in a state of readiness to perform their safety functions, 1-20 Revision 7
Testing The determination or verification of the capability of an item to meet specified requirements by sub#cting the item to a set of physical, chemical, environmental, or operatin~g conditions.
(Refer also to ANSI N45.2.10 for definition of " Testing".)
Traceability The capability to identify a particular component or material and to discover its entire history, bacl. through the written records of its material formulation (heat r, umber),
manufacture, inspection, instal'ation, test, operation, maintenance, repair, and replacement.
Witness Formal observation by a knowledgeable person of a particular, prescheduled event during manufacturing, inspection, installation, testing, operation, maintenance, or repair. The purpose of witnessina, is to provide direct observation and evaluation of an event, independent of the group performing the particular operation.
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Desienated Representatives An individual or organization autnorized by the purchaser to perform function in procurement process.
Lower Tier Procurement Procurement by a supplier from a subnpplier of items or services.
hirchaser The organization responsible for issuance or administration or both of procurement documents.
(Refer also to ANSI N45.2.10 for definition of " Purchaser".)
Richt of Access The right of the purchaser or designated representative to enter the premises of a supplier for the purpose of inspection, surveillance, or quality assurance audits.
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Senices The performance by a supplier of activities such as design, fabrication, inspection, nondestructive examination, repairs, installation, or training.
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2.0
SUMMARY
DESCRIPTION This section defines the NPPD commitment for compliance to 10CFR50, Appendix B, as applied to safety-related structures, systems, and components associated with Cooper Nuclear Station.
In addition to describing commitments to 10CFR50, Appendix B, this Section also identifies NPPD's commitment to selected ANSI Standards and their associated Regulatory Guides.
2.1 Organization The President and Chief Executive Officer (C.E.O.) (Figure 1) represents the highest level of management responsible for establishment of Quality Assurance policies, goals, and objectives. The responsibility and authority for nuclear facility and Genecal Office support activities (including QA) has been delegated to the Nuclear Power Group Manager through the Vice-President - Power Production. This authority includes the
-ight to direct, enforce, and perform any action required to ensure all activities conducted at Cooper Nuclear Station are in compliance with 10CFR50, Appendix B. In addition, the personnel assigned to the Quality Assurance Division shall have complete independence to perform audits, surveillances, inspections, verifications and shall be independent of those groups performing, designing, purchasing, fabricating, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service inspecting, and modifying. Figure 1 of this document 2-1 Revision 7
t outlines the QA Division functional organization. Quality Assurance Personnel shall have sufficient authority and organizational freedom to:
(1)
Identify quality problems; (2)
Initiate, recommend, or provide solutions for conditions adverse to quality; and, (3)
Verify implementation of solutions.
2.2 Ouality Assurance Program The program shall be implemented in accordance with written, approved Quality Assurance Plans and Instructions developed by the Quality Assurance Division. The District's QA Program will comply with the Quality Assurance Guidelines contained in the Orange Book - WASH, 1284-10-26-73. Design Control, Procurement Control, Quality Control, and Quality Assurance activities associated with plant modifications will similarly conform to the guidances provided within the Gray Book - WASH,1283-Rev.-l and the Green Book - WASH, 1309-5-10-74. Procedures will be prepared for each important activity of station operation which will clearly define the work to be performed on a step by-step basis and will identify, where appropriate, the results to be achieved. Mandatory QC Inspections or Tests will be performed on an independent basis to verify that procedures are being followed (correct results obtained) and will be incorporated into the work procedures directly or by attachment. QA Aud!! activities will verify that the Quality Control Program is implemented.
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Specific to the related ANSI Standards for this criterion, the following commitments apply:
1.
ANSI N18.1 1971 " Selection and Training of Nuclear Power Plant Personnel,"
shall provide direction for se'ecting and training of personnel for the Nuclear Power Group.
2.
ANSI N18.7-1972 "American National Standard for Administrative Controls for Nuclear Power Plants," and the associated Regulatory Guide 1.33, apply to the CNS Operational QA Program with the same exceptions as those taken in other sections of this Policy Document to ANSI N45.2-13.
3Property "ANSI code" (as page type) with input value "ANSI N45.2-13.</br></br>3" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
ANSI N45.21977 " Quality Assurance Program Requirements for Nuclear Facilities," and associated Regulatory Guides 1.28 and 1.33, shall apply to the CNS Operational QA Program, with the following exceptions:
(a)
Where Section 11 " Inspection" identifies the reporting relationship between the inspector and the "immediate supervisors who are responsible for the work being inspected," the CNS QC Program only requires that the individual performing the verification function shall not perform or directly supervise the work being inspected.
Table 1 identifies the structures, systems, and major components associated with Cooper Nuclear Station covered by this program. Jabisfifii6tiliiteiidedgbeisll]incitisive) 2-3 Revision 7
j The Nuclear Operations and Nuclear Engineering and Construction Divisions, with the assistance of the QA Division, willidentify essential structures, systems, and components to be included within the scope of the QA Program. The Quality Assurance Program is designed to provide control over all activities affecting quality of essential items to a degree consistent with their safety related importance. These activities will be governed by approved plans and instructions and these documents shall be followed under controlled conditions. The Quality Assurance Plans and Instructions will be reviewed periodically to assure that the requirements of the program are being met and new requirements are being incorporated, in addition to essential structures, systems, and components, applicable portions of this program shall be applied to selected nonessential structures, systems, and components important to station reliability and performance. Specific application will be identified in dedicated Quality Assurance Plans.
Special process controls, test equipment, tools, skills (training, if required) shall be used during the conduct of inspection, verification and checking activities to assure a high standard of quality and reliability has been obtained on safety-related items covered by the Quality Assurance Program. Test equipment and special tools will be calibrated against a specified secondary standard.
Experienced individuals (which may include personnel from other divisions of the Nuclear Power Group (NPG), and/or outside qualified individuals) may be requested to assist in performing audits and inspections of certain CNS quality-related activities at the l
2-4 Revision 7
direction of the Division Manager of Quality Assurance. During these assignments, these individuals will have sufficient organizational freedom to identify and recommend corrections for quall_ty deficiencies noted,
- The Nuclear Training Department, in addition to QA Staff t>crsonnel, provides QA indoctrination for NPG cmployees as described in nuclear training program descriptions. In addition, QA Staff members will attend a minimum of one training seminar per year sponsored by a qualified agency and/or school For the purposes of 1
- meeting this requirement, activities such as attendance at national conventions,
)
- participation in owners group committee's activities, and other such related items may.
be considered equivalent to seminar. Such instances shall be specifically approved by j
the Division Manager of Quality Assurance. Ongoing QA trainir.g for personne1 with nuclear plant responsibilities will be provided. Training activities will be audited J
periodically by the QA Staff to verify its scope and effectiveness.
i
. 2.3 -
Rulan Control i
Implementing procedures outline the method for identifying, controlling, and j
implementinE esign changes within the Cooper Nuclear Station. The procedures. provide d
_the mechanism for correctly translating the design changes and regulatory requirements into specifications,- drawings, procedures, and instructions. They also-establish the method of reviews, interface requirements (with original design organization, if required), approvals, and the organizations delegated the authority to implement the
= design change, i
2-5 Revision 7 m.
Design control measures shall include the review for suitability of application of items that are essential to the safety related function of the system involved. A necessary part of this review concerns the safety classification of items to be procured, in those instances where the normal methods of Section 2.7 cannot be applied and it is necessary to purchase " commercial-grade" off the-shelf items for use in essential applications, veri 6 cation will be performed to ensure that the part utilized is functionally acceptable for the essential application. This verification may include dedication upon receipt, analysis, or other definitive method.
All design changes initiated for Cooper Nuclear Station will be forwarded to the QA Division for review and independent evaluation. These reviews shall verify the compatibility of the design change with applicable codes, standards, and regulatory requirements. Items to consider include reactor physics, stress, thermal hydraulic and accident analyses, compatibility of materials, accessibility for in service inspection, maintenance, repairs, and delineation of acceptance criteria for inspection and tests.
Final acceptance of the design change will require an independent verification or check of the design adequacy such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
Specific to the related ANSI Standards for this criterion, the following commitments apply:
2-6 Revision 7
1.
ANSI N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants," and the associated Regulatory Guide 1.64, shall be applied to design activities involving safety related modification work and the revision or development of plant design documents occurring during the operational phase of CNS. However, where codes, standards, or design requirements are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the Updated Safety Analysis Report (USAR), the USAR commitments shall govern.
later revisions of applicable codes and standards may be specifically invoked by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.
2.
ANSI N45.2.4-1972 " Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations," and its associated Regulatory Guide 1.30, shall be applicable to the CNS Operational QA Program for safety-related modification work, with the following exceptions / clarifications:
(a)
The definition of Class I and Class IE electrical equipment set forth by this standard does not conform to the equipment categories of CNS, Electrical items upon which the Operational QA Program is based are included in Table 1 of this policy document and the CNS "Q" List. The scope and applicability of this standard shall necessarily be limited to these defined areas.
I 2-7 Revision 7
(b)
Appropriate requirements for installation, inspection, and tests are denned in job specifications and work instructions developed as a part of the I
modification work package, it is not intended that separate procedures be established which specifically address the various areas of this standard. During the development of work packages, consideration will be given to the areas outlined in Section 2.3, as appropriate.
(c)
The requirements for installation, inspections, verifications, and tests shall i'
be included in the work instructions.
In the development of these f
instructions, consideration will be given to the guidance provided by Sections 4.0,5.0, and 6.0 of this standard, and appropriate requirements will be incorporated into the instructions. It is not intended that separate procedures be established to specifically address all of the areas referenced.
(d)
Application of the guidance provided by the additional codes and standards listed in Appendix B will be considered to the extent that such codes and standards provide useful and practical guidance for the work being performed. Commitments to the guidance of N45.2.4 shall not include commitments to the guidance of referenced standards.
3.
ANSI N45.2.5-1974 " Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants," and its associated 2-8 Revision 7
Regulatory Guide 1.94, shall be applicable to the CNS Operational QA Program for safety related modification work, with the following exceptions / clarifications:
NOTE With respect to structural concrete, acceptability shall be documented in accordance with the District's Dedication Procedures, which will be verified by independent QA audit.
(a)
Appropriate requirements for installation, inspect.;n, and tests will be set i
forth by job specifications and work instructions developed as a part of the modification work package.
It is not intended that separate procedures be established which specifically address the various areas of this standard.
However, in the development of the work package, consideration will be given to the areas outlined in Section 2.2, as appropriate.
(b)
The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied to all measuring and test equipment used by NPPD or their agents, test laboratories, and contractors.
Such requirements, however, will not be imposed on commercial batch plant facilities. Instrumentation at commercial batch plant facilities will be evaluated by NPG construction management 29 Revision 7
personnel, or their designated representative, to determine that sufficient accuracy can be obtained.
(c)
For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch plants. For these small quantities of concrete, it is unreasonable to expect commercial facilities to shut down normal operations to provide certified aggregate, cement, admixtures, fly ash, water, etc. In this respect the qualification tests required by Table A for aggregate; cement, admixtures, fly ash, and pozzolans; water and ice will not be required. Appropriate evaluations will be made to determine that good quality and generally acceptable materials are used. NPG construction management evaluation, coupled with slump tests, air entrainment tests, and concrete cylinder strengths, will provide adequate control and qualification of the concrete.
(d)
Design mixes consistent with, or equivalent to, original requirements will be specified and the results of the cylinder tests will be evaluated by NPG construction management based on the acceptance criteria associated with the original design mix requirements.
(e)
The inspection requirements of Section 4.2 will not generally be performed as the small quantities of concrete involved in modification work will no doubt be mixed using materials already in the batch plant bins. Control of storage of materials would not be practicable.
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(f)
If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the requirements of ACl 304, ASTM C 94. Where certifications are not available, two concrete test cylinders representing the first and last one-third of truck mixer contents shall be taken for evaluation of the mixer truck, over and above the normal concrete cylinders taken to evaluate the in-place l
concrete. The concrete batch plant facility shall be inspected by NPG construction management and the CNS QA Staff to assure that reasonable controls are being exercised with reference to the inspection guidelines set forth by Section 4.3(1) and (2).
(g)
Inspection of fills and carthwork will meet the general requirements set forth. The extent to which individual inspection requirements are met will depend upon the nature and scope of the work to be performed.
(h)
Except for normal batch qualification tests (slump, air content, temperature, and compressive strength) and initial reinforcing steel certifications, the in process tests required by Table B are generally applicable to the periodic control which must be exercised with reference to long-term construction type programs. The in process test requirement of Table B are not considered applicable to short-term modification work as would be required by QA at CNS.
l 2-11 Revision 7
4.
ANSI N45.2.81975 ' Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems fer the Construction Phase of Nuclear Power Plants," shall be applicable to the CNS Operational QA Program for safety related modification work, with the following clarification:
(a)
Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requiremerits set forth in the USAR and other appropriate design documents, the original design requirements shall govern.
2.4 Procurement Document Control Cooper Nuclear Station Procedures, Nuclear Engineering and Construction Department Procedures, and Quality Assurance Plans and Instructions are required to define the applicable requirements, design basis methods, and procedures for procurement of spare parts, materials, equipment, and services for essential nuclear systems.
These instructions and procedures shall also include provisions for assuring that the necessary quality requirements are incorporated directly into the procurement documents for essential spare parts, material, equipment, and services.
These instructions and procedures shall also include provision for assuring that the necessary records are specified and provided to the District by the supplier.
=
1 2-12 Revision 7
Tre basic principles and practices included in these procedures are expected to be applicable to any purchasing activity necessary for operation of the station; however, additional special controls may be necessary for major modification or repair activities.
Procedures covering procurement provide for independent Quality Assurance review of the essential and essential commercial grade purchasing documents; review and approval of suppliers; and QA Audit of contractor and supplier activities.
Change Orders issued on any procurement document will be subjected to the same review and approval as the original order.
All procurement documents issued to suppliers of safety-related items or services require that the supplier implement a Quality Assurance Pro 3 ram that meets the intent of 10CFR50, Appendix B (with the exception of those suppliers performing all work at Cooper Nuclear Station or in the Columbus General Offices under the District's QA Program). The Quality Assurance Program submitted by the supplier will be evaluated by NPPD QA to ascertain that they meet the criteria established in 10CFR50, Appendix B. All safety-related suppliers shall appear c,o the applicable section of the
,NPPD'Siippliefs List.
To the maximum extent practicable, the as-built drawings and specifications for Cooper Nuclear Station will be used in procurement of spare parts, material, and replacement parts.
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Where necessary, because of design modifications, or where it is necessary or desirable to upgrade quality in replacement parts or material, necessary modifications will be made to drawings and specifications to incorporate requirements for currently appropriate quality level.
These modifications or upgrading of replacement parts will be accomplished in accordance with approved instructions, procedures, and drawings.
These documents will be subject to required reviews before being implemented.
Specific to the ANSI Standard related to this criterion, the following commitment applies:
1.
ANSI N45.2.131976 " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants," is applicable to the CNS Operational QA Program, with the following clarification:
(a)
It must be acknowledged that equipment and components purchased during the design and construction phase were not purchased on the basis l
of present-day standards, especially with reference to supplier approval and supplier Quality Assurance Programs. In this respect, replacement j
parts and spare parts for existing equipment are often limited to sole source suppliers.
Such replacement parts or spare parts are purchased to appropriate quality standards, verified by NPPD QA, to maintain an " equal to or better than" condition but it is not considered l
practicable to backfit the requirements of this standard to all such l-l sppliers.
2 14 Revision 7 l
l 1
2.5 Instructions. Procedures. and Drawings Quality Assurance activities and other activities which have nuclear safety significance will be prescribed by documented instructions, drawings, and procedures as appropriate and shall be accomplished in accordance with these instructions, procedures and drawings. These instructions will be sufficiently detailed and explicit so that any supervisor, inspector, or auditor can, by observation, determine whether or not activitics are being satisfactorily accomplished and documented, These documents shall include the qualitative and quantitative acceptance criteria necessary to assure satisfactory completion of the test procedure. Those acceptance criteria shall, where appropriate, require post installation testing prior to returning the component or system to service.
Repair maintenance activities on essential systems are performed in accordance with the Maintenance Work Request process The required documentation for special processes are forwarded to the CNS QA Staff for review along with special test procedures and special maintenance precedures, QMy!@ii[Hidsish'jlshill(b6Wfoll6pisj KeMC1ZC31:06nsNsiM6bliniedts Pl2Techilijalisggirica;tl6ns G
[Chiatlhgfib&ish 2-15 Revision 7
[ '-
^ 7Shfet [ Analysis Report";
I
't Ujklated Safety (knalysis Report
[
iN.RC Corresponden6e[(CunimitmentslandlSERs)
.Q6alitp]^ssbrsnEe Polley;Docuinent LevelII(f" ;*T LDesign;S}scifichtions and Drav:ings LejslilII F fe7,' EProceddies p
!'Administraltive Procedures E, T-Operationhl Pib6edsres
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,' )Vork':Pr6dedurds Level IVi Te' 1;Policiss'hhdlGhideli.nes e-LNnclear Powef;Gronp' Directives 2-16 Revision 7
I 2.6 Document Control Administrative control procedures shall be established by the Columbus General Office (CGO) and Cooper Nuclear Station (CNS) to control the identification, indexing, filing, retention, retrieval, and distribution of quality-related records and documents. Control procedures shall be reviewed and approved by authorized personnel and are distributed to and used at the site of the activity. These procedures shall also ensure that changes to quality related records and documents receive the same level of review and approval as the original document.
The overall objectives of NPPD document control are to:
a)
Identify those records and documents which are used to _ control, maintain, modify, or document quality related activities both at the CGO and at CNS.
b)
. Establish an index of quality related records located at the CGO and at CNS to enable personnel involved in safety related activities to determine the proper
- documents to be used in the activity.
c)
Establish a filing system.-
l d)
Establish periods of retention, c)
Establish measures to control distribution and revisions.
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The CGO Manager of Office Systems Services, CNS station management, and the Quality Assurance Division will jointly establish lines of specific responsibility, interfaces, and document control procedures.
Specific to the ANSI Standard related to this criterion, the following commitment applies:
1.
ANSI N45.2,9-1974 " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," and its associated Regulatory Guide 1.88 shall be applicable to the CNS Operational QA Program, with the following exception / clarification:
(a)
For those design, manufacturing, construction, and operating records generated prior to implementation of this standard, it is not our intent to backfit the detailed requirements of this standard to those records. All such records, however, have been initially designated for lifetime storage, until specific review dictates otherwise, and will be stored in the record storage facility. Record indexes and filing systems shall be established to permit reasonable identification and retrieval. The records will be stored and preserved per the requirements of Section 6.0 of this standard.
2-18 Revision 7
1 I
i 2.7 fontrol of Purchased Material. Eauinment. and Services NPPD receiving inspection instructions provide for determining that all purchased I
materials, equipment, and services purchased directly or through a contractor, supplier, or subcontractor meet the requirements specined on the original procurement specifications, such as code, standards, specifications, dedication, material identification, etc. The completed receipt inspection report will become part of the purchase order package. Procurement documents shall be available at the receiving area to identify the receiving inspections required.
Quality Assurance Instructions provide for evaluation of supplier's quality program to determine effectiveness and compliance to the applicable 10CFR50 criteria as part of the supplier selection process. These instructions shall describe the methods and techniques used to evaluate the supplier's Quality Assurance Program.
The QA Division shall re-evaluate the supplier's quality program at intervals consistent with the importance, complexity, and quantity of the item or services to effectively maintain control of quality. Procurement documentation will specify mandatory hold points for witnessing or inspection of purchased materials, equipment, or services, if required by NPPD.
Upon receipt at the statica, material, parts, and equipment purchased and identified as
" Essential" or " Essential-Commercial Grade" will be placed in a segregated storage area 2-19 Revision 7
until all inspections are complete and all required certifications and documentation is received.
Items in segregated areas will not be issued, by the Warehouse, without the written permission of the Division Manager of Nuclear Operations or designec and }hbri only after proper arrangements have been made to assure that necessary steps will be taken to bring all aspects of the particular item into conformance with normal requirements prior to the system containing components in " Hold" status being returned to service.
Suppliers of essential equipment, if'ajiirb;sistg shall be required to provide certified l
documentary evidence that the material supplied conforms to the purchase document requirements such as material test report, code required test and inspection, documentation, etc. A complete set of documentation required by the procurement document for all essential materials, equipment, and services will be filed at Cooper Nuclear Station.
2.8 Identincation and Control of Parts. Materials. and Comnonents To the maximum extent practicable, activities carried out during operation of the Cooper Nuclear Station will comply with the requirements for identification and control of materials, parts, and components as set forth in the as-built drawings and specifications for the station. Where special measures are required to assure proper identification of materials, parts, and components, such requirements will be incorporated directly into the procurement documents for such parts and assemblies. Such identifications which 2-20 Revision 7
may include heat numbers, serial numbers, or other means of identification of the item will be incorporated into the procurement documents to provide means of traceability.
Material received at the station (which has not been properly identined) will be segregated and tagged to indicate a " Hold" status. Except as indicated in Section 2.7 above, such parts will not be issued or used prior to final acceptance. CNS procedures will incorporate requirements necessary to assure that the identification measures are properly carried out at the station, that unacceptable items will not be used in essential systems, and that the components to be used in essential systems receive independent verification of component identity prior to installation.
2.9 Control of Soecial Processes General maintenance procedures provide for performance of special processes by quallGed personnel using qualified and approved procedures. Control procedures provide for QA review, inspection, documentation of activities, and for proper integration of QA/QC Inspection. In most cases, the procedures will be prepared only when a specific process is required in the maintenance, repair, or modification of essential equipment at CNS. These procedures shall also require special processes, such as welding, heat treating, and NDE, liitis!5biitibiled and performed by qualified personnel in accordance with qualified procedures.
Maintenance modification control methods and Station Operating procedures are reviewed by CNS QA personnel.
This review includes verification that necessary codes, 2-21 Revision 7
i standards, quality requirements, and acceptance criteria are incorporated to control l
special processes within established limits, i
2.10 Inspection Quality Control inspections have been assigned in this policy document to the organization basically responsible for the performance of the activity. A Peer QC Program will be utilized in which QC inspections are normally performed by QC Inspectors who have been selected from within the Nuclear Power Group, and who are many times just as qualified to perform the work as they are to inspect the work. QC personnel will be qualified / certified, and will conduct the QC Program, in accordance with NPPD's commitment to ANSI N45.2.6. This conduct of the QC Program will be within the detail established in the CNS Operations Manual, Volume 12.
Quality Assurance Audits and Surveillance of activities such as maintenance, repair and modifications will include direct observation; whereas operating functions will be monitored indirectly by observation and examination of individual operating personnel and documentation at intervals consistent with the importance of the activity. Direct QA or QC inspection will also be conducted for activities such as refueling, radiochemistry, and environmental monitoring. Special inspections, such as those requiring qualification to ASNT-TC-1A, will be contracted to approved -suppliers. If direct inspection is impossible, indirect control methods will be specified in the instructions to provide a method of monitoring process methods and equipment. The results of allinspections will be placed in permanent record storage.
2-22 Revision 7
Controlling documents pertaining to quality related activities receive Station Operations Review Committee (SORC) approval to ensure incorporation of appropriate quality requirements, QA is a non voting member of SORC.
l l^
Specific to the ANSI Standard related to this criterion, the following commitment applies:
I 1.
ANSI N45,2,61978 " Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants," and its associated Regulatory Guide 1.58 is applicable to the CNS Operational QA Program, with the following exceptions /clari0 cations:
(a)
It has always been the belief of NPPD that, in order to be effective, Quality Control must be built into the operation of the plant, With this in mind, Quality Control and test functions performed at CNS are incorporated directly into the station procedures. Inspection points are then performed and signed off by qualined personnel not directly 1
performing or supervising the step (s) being inspected.
Selection of QC candidates for certification is a function of Station Management.
Actual certification of QC inspectors is the responsibility of the QA Division.
l (b)
CNS does not have the in house capability to perform nondestructive examinations in accordance with SNT-TC-1A, These services are 2 23 Revision 7
e currently contracted to an approved supplier.
Any required nondestructive examinations will be performed by personnel who are qualified and certified per SNT-TC-1 A.
2.11 Test Control Each type of test program performed by the station operating group will be defined by written procedures and instructions. These test programs include the preoperational tests, start-up test instructions, operational testing and surveillance testing of structures, systems, and components to demonstrate their capability to perform satisfactorily as a i
part of an integrated system. Acceptance tests will be developed for structures, systems, and components to demonstrate their capability to perform satisfactorily following repairs or modification prior to returning to service. Test procedures will identify the inspector, test performer, date, and data recorder. Each type of acceptance test has individual test procedures which include Quality Control provisions, acceptance criteria, and check points for observation or checking of important aspects.
These test procedure-prerequisites will include the test instrumentation requirements and environmental conditions. All Special Test Procedures, Special Maintenance Procedures, and Station Operating Procedures are routinely reviewed by SORC, of which QA is a member.
Quality Assurance Audit and Surveillance activities will be performed by the Quality Assurance Staff members to assure that tests are being performed in accordance with the requirements of the procedures, that results are evaluated and compared to the specified acceptance criteria, and that tests are being performed by appropriately trained personnel, 2-24 Revision 7
In addition, test procedures shall spedfy test requirements and quantitative and qualitative acceptance criteria where appropriate.
2.12 Control of Measuring and Test Equipment Procedures shall define the requiicments of inspection, maintenance, repair and calibration of all tools, gauges, instruments, and other measuring and testing devices which are used in activities which affect quality of safety related equipment.
Each permanent or temporary installed plant instrument perfotming an essential function has been identified and placed on a regularly-scheduled program of inspection, test, and recalibration. All test and measuring equipment required for calibration of the above equipment will also be placed on a regular program of inspection, test, and recalibration and will be appropriately tagged. Documented calibration records are reviewed, as required, to evaluate calibration performance and frequency, and changes are made as may be necessary.
A Quality Assurance Plan will prescribe the QA functions to be performed relative to the calibration program.
Quality Control and Quality Assurance practices require independent checks of calibration activities. Quality Assurance Surveillance performed by the QA Staff members will verify that procedures are being properly followed; that adequate records of calibration and testing of measuring and test equipment are being generated, maintained, and that regularly scheduled adjustments are made to maintain necessary accuracy. For equipment used to calibrate process equipment, procedures will l
2-25 Revision 7
define action to be taken should regularly scheduled calt'ation checks reveal an out of specification condition exists. When inspection, measuring, and test equipment are found to be out of calibration, an evaluation shall be made, and doeurnented, of the validity of previous inspection or test results and of the acceptability of items previously inspected or tested. Should the evaluation determine that previous inspection or test results obtained with the affected instrument are unacceptable, a Nonconformance Report (NCR) will be issued. Reference and transfer standards, traceable to the National Institute of Standards and Technology (formerly Nils) will be maintained at CNS.
Scheduled and/or unannounced audits or surveillances by the Quality Assurance Staff, the Safety Review and Audit 11oard, or NPPD management will include review of the calibration program, i
2.13 Handling. Storageand Shipping The procedures for procurement and control of essential spare parts, materials, replacement parts, and equipment include the requirements for the control, handling, cleaning, shipping, receiving, and storage of essential parts and material.
Quality Assurance Plans and Instructions provide for surveillance and audit to assure that procedures are followed and that essential parts and materials are received, inspected, stored, and controlled in such a manner so as to prevent degradation.
Specific to the ANSI Standard relating to this criterion, the following commitment applies:
2 26 Revision 7 l
i 1.
ANSI N45.2.2 1972 ' Packaging, Shipping, Receiving, Storage, and llandling of items for Nuclear Power Plants,* and its associated Regulatory Guide 1,38 is l
applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
1 (a)
Our program is structured to identify safety related equipment and i
provide for designation of packaging, shipping, receiving, storage, and handling requirements for purchased parts and materials.
The classifications of this standard cannot be applied directly to individual spare parts or subassemblies of the parent equipment. Due to difference in volume, complexity, inspectability, etc., the packaging, shipping, handling, and storage requirements of spare parts and subassemblics will necessarily be different from the requirements which may be imposed on
- the entire component or piece of parent equipment.
(b)
The majority of items purchased for an operating plant consist of components, subasserablics, and individual spare parts which could be used in a multitude of different applications. Such items are purchased to the most stringent requirement for their intended use. The volume and characteristics of procurement during the operational phase differ significantly from those purchases rnade during the design - and construction phase, items requiring special storage protection will be identified on the purchasir:g documents.
Items that must be stored outdoors (equivalent of Level D) and items that must be stored in covered 1-l 2 27 Revision 7 i-
k 1
but unheated conditions (equivalent of Level C) will be evaluated on an individual case basis.
Ilowever, it is not considered practicable to preclassify individual parts by levels as required by Section 2.7 of this standard.
Shipping and packaging requirements for such items will i
likewise be handled in the procurement documents, as appropriate.
(c)
QA Audits and Surveillance are performed to verify that the requirements of N45.2.2 are met except as noted in (a) and (b) above.
2.14 lasnection. Test; and Oncrating Statn The NPPD status tagging procedure, already in use throughout the system, has been adapted for use in the Cooper Nuclear Station. Where practical, particular emphasis shall be placed on tagging to prevent unauthorized operation or adjustment which could endanger the safety of personnel, damage equipment, or invalidate the results of tests already performed. These tags shall indicate abnormal equipment test and inspection status and reference special instructions for equipment located throughout the Cooper Nuclear Station.
Tagging procedures, where necessary, will require that equipment be tagged and that the associated power supplies, starters, switches and controls on the main control panel are l
tagged as well, to warn against operation. In some cases, power supplies will be disconnected and tagged to prevent inadvertent operation. Tagging will be controlled by the Shift Supervisor by requiring that serially-numbered tags, obtained from the Control l
2 28 Revision 7
Room, be used for all tagging purposes. Records will be maintained in the Control Room to enable operators and Shift Supervisors to determine the status of the equipment tagged.
A Temporary Modifications Control Program will be maintained to provide a method for recording the installation and removal of jumpers, fuses, or wire terminal disconnections.
This record will include the location, reason, name of person authorizing action, and name of person performing the installation.
Requirements for tagging are included in the applicable procedures. Status tagging will be verified by audit and surveillance.
2.15 Nonconforming Materials. Parts. or Comoonents Warehouse and maintenance procedures include requirements for the identification and tagging of nonconforming materials, parts, or components, (See Section 2.8).
The Nonconformance Reporting Program shall be used by all persons performing operation, maintenance, modification, and qua"'y related functions to record and report:
a)
Deviations from approved procedures; b)
Nonconforming materials, parts, or components received from outside suppliers on essential purchase orders; 2 29 Revision 7
c)
Nonconforming materials, parts, or components within the plant; d)
Nonconforming materials brought on site without following estabilshed receiving and inspection procedures; c)
Orders or recommendations to stop work; f)
Reportable occurrences; g)
Any other deficiency which violates the intent of the Quality Assurance Program and which could have a significant adverse effect on quality; h)
Deviations which could be reportable under 10CFR21.
A separate report shall be prepared for each nonconformance. The intent of this separate report requirement is to simplify follow up, corrective action, and record keeping, t
Deficiencies and/or deviations identified by QA Staff personnel shall be reported on a Quality Assurance finding fonn, Nonconforming items will be controlled in such a way as to prevent their inadvertent use or installation. Such parts will be reinspected and reviewed for adequacy prior to returning them to the manufacturer, scrapping them, or arranging for them to be reworked to conform. Disposition of a nonconforming item will be determined by the responsible supervisor in conjunction with the QA Staff, Written reports of decisions to t
t j
2-30 Revision 7
4 repair or rework essential items will be reviewed and approved in accordance with maintenance and/or design control procedures.
Any decision to reduce requirements to permit use of nonconforming parts, materials, or components in essential systems, will be documented as a nonconformance report and will be subject to Station Operations Review Committee (SORC) review and approval.
Appropriate design modification documentation will be completed if required.
Approved Procedures will be utilized for repair and rework of essential parts and equipment. All such rework will be thoroughly documented, including Quality Control and Quality Assurance Surveillance activities, to assure conformance with the requirements of the specincations, procedures, and other controlling documents.
Essential equipment classified as scrap will be identified and segregated in such a manner to prevent inadvertent use or installation in an essential system.
The CGO QA Department will issue a quarterly trend report to the Nuclear Power Group Manager which may identify adverse trends that require corrective action.
2.16 Corrective Action NRC Regulations which require formal reporting to the NRC of failures, malfunctions, deficiencies, unusual operatbg experiences, and deviations which may have a significant effect on quality or safety will be reviewed and evaluated by the Station Operations 2 31 Revision 7
j j
Review Committee and, where appropriate, by the Safety Review and Audit Board. It will be the responsibility of the Nuclear Group personnel to identify and promptly correct all such deficiencies or malfunctions either by improved maintenance, repairs, replacements, or modification. In all cases, the objective and the corrective action will not only be to correct the existing defect or denelency, but also to include measures to determine cause and prevent recurrence of similar failures. Quality Assurance activities will verify that corrective action is performed in accordance with approved written procedures and that the details of the corrective action are properly documented for the permanent station records.
A monthly status report of open NCR's shall be prepared and distributed to:
4 Vice President Power Production Nuclear Power Group Manager SRAI) Administrator Division Manager Nuclear Operations Division Manager Nuclear Engineering and Construction Division Manager - Quality Assurance Division Manager Nuclear Support CGO Quality Assurance Manager CNS Regulatory Compliance Specialist CNS Department Managers l
2 32 Revision 7
2.17 Ounlity Assurance Records All activities having a significant effect on quality and safety will be thoroughly documented, and all such documentation will be incorporated into the record storage system. Procedures will require appropriate physical storage and personnel to maintain these files. Record identincation, storage, retrieval, access, control, retention, and safeguarding of all quality related records associated with CNS will be in accordance with approved procedures. Records to be maintained include all records accumulated during ergineering and construction and those records generated during station operation, maintenance, and modification as def.ned in the CNS Technical Specl0 cations. These records shall also include qualification of personnel, equipment, and procedures.
Inspection and test records shall identify the inspector, data recorder, method of observation, results, acceptance, and all nonconformance reports issued to document noted denciencies.
CNS and/or Columbus Ocneral OfDce personnel will be allowed to maintain active working files at their work stations.. The time frame for submitting these records to record storage facilities will be determined by their respective administrative procedures.
Administrative procedures shall provide for methods for changing records that provide clear identification of the change and must be initialed and dated by the person making the change and by persons authorized to approve the changes.
2-33 Revision 7
l The program willinclude Audits of record storage facilities to assure that the procedures and controls are properly implemented. The CGO Manhger of Office Systems Services and CNS station management will prepare detailed procedures for receiving records into the facilities and for making decisions on removal and disposal of outdated or superseded
- records, Refer to Section 2.6 " Document Control" for the commitment to ANSI N45,2.9, 2.18 Audits Scheduled and unscheduled audits will be performed to verify compliance to CNS QA Program requirements and to determine the effectiveness of the area audited, Quality Assurance Plans for each functional area of station operating activities have been or will be prepared These QA Plans identify the nature and extent of Quality Assurance audit activities to be performed by QA Personnel or under the direction of management. Audit responsibilities are assigned to the Division Manager of Quality Assurance. Audits performed under this direction (working with the Safety Review and Audit Board (SRAB) as referenced in Section 3.4) will be conducted according to the QA Plans to verify compliance with the Quality Assurance Program.
Audits shall be performed in accordance with written instructions or checklists and conducted by trained personnel not directly responsible for areas being audited. NPPD Management may request audits of specific activities of particular concern to them. However, all such internal audits will be coordinated to avoid interference with the operating activities at the station. Upon completion of the audit, a formal report will be prepared and transmitted to the organization audited which will include an evaluation statement regarding the program's 2 34 Revision 7
effectiveness. All audit findings identified will be documented and appropriate follow up action will be taken to assure that corrective action has been implemented. Follow-up action, including reaudits to verify corrective action, shall be fully documented.
Specine to the ANSI Standards relating to this criterion, the following commitments apply:
1.
ANSI N45.2.121977 " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants,* and its associated Regulatory Guide 1.144, is applicable to the CNS Operational QA Program, and to the Supplier Audit Program.
2.
Section 4.0 of ANSI N18.7-1972 " Administrative Controls for Nuclear Power Plants," will be used as a guide for scheduling and conducting audits.
2.19 Additional ANSI Standards ANSI Standards applicable to the CNS QA Program for Operation, not directly related to the preceding sections, are discussed in this section:
1.
ANSI N45.2.1-1973 " Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants,' and its associated Regulatory Guide 1.37, is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
2-35 Revision 7
(a)
Cleaning requirements for almost all maintenance, repair, tnd modification work will be considered as a part of the overall job requirements.
In this respect, detailed cleaning procedures will not generally be prepared as separate documents. Necessary requirements, consistent with the scope of the work, will be included as a part of the overall work instructions. System cleanness is controlled at CNS by the following methods:
(1)
Parts and components are checked for cleanness during receipt inspection and stored in a manner that will ensure adequate levels of cleanness are being maintained.
(2)
Work instruction will be reviewed by Quality Control to assure that adequate cleaning and access controls are incorporated into work instruction and associated safety-related activities.
(3)
Parts and components are inspected for cleanness prior to installation in accordance with CNS maintenance procedures.
(4)
Work areas are maintained at a cleanliness level appropriate to the maintenance or modification activity being performed.
(5)
Quality Control or Engineering Inspections before, during, and after safety related maintenance or modification activities address system cleanness.
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(6)
Random QA Audit and Surveillance of safety related maintenance or modification activitics requires verification of part, component, and system cleanness.
(b)
For cleanness classl6 cations where the scope of plant modincation work is such as to make application of the guidance provided by this standard practicable, the cleanness classifications and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work requirements.
(c)
For most modification or maintenance work, however, involving only small portions or individual components of larger systems, it is not considered practkable to conduct cleanness tests with ASTM Ell 70 Series. Appropriate cleanness wi!! be maintained during the work and preoperational flushing will be conducted, consistent with the scope of the work peiformed and the original design requirements. Controlling the parts and components and the work area has provided CNS with reasonable levels of assurance that system cleanness will be maintained.
In addition to the above, the Water Chemistry Department routinely samples and tests for system c!antiness, corrosion, crud buildup, etc.
2.
ANSI N45.2.3-1973 " Housekeeping During the Constructico Phase of Nuclear Power Plants," and its associated Regulatory Guide 1.39, is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
l 2 37 Revision 7
(a)
The plant has been divided in zones for fire protection and security purposes. The zone designated for cleanness in the ANSI Standard are primarily intended for control or work during construction of the plant.
Therefore, the CNS facilities will not be classified by the zones designated in the Standard general housekeeping rules. Lim!tations on eating, drinking, and smoking are already provided in existing CNS procedures.
Where special cleanliness controls, tool, and material accountability are required for particular typr.: of work, temporary clean areas will be designated and defined in the procedures for accomplishing the work.
(b)
Fire protection and prevention will be provided in accordance with NPPD evaluation of the CNS fire protection system as required by NRC regulations.
(c)
Station procedures have been reviewed to determine the need for particular cleanness, housekeeping, and control provisions.
Where indicated, procedures have been revised to incorporate such provisions, using the guidance of ANSI N45.2.3.
1Property "ANSI code" (as page type) with input value "ANSI N45.2.3.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 2-38 Revision 7
3.0 ORGANIZATION AND RESPONSIBILITIES Nebraska Public Power District is solely responsible for the operation of the Cooper Nuclear Station and will fulfill the objectives set forth in the Quality Assurance Program for Operation through its own organization and by contract with qualified contractors and consultants.
3.1 Ocarral The overall Quality Assurance Program for Operation shall be conducted in accordance with the three divisions of responsibility which provides for Quality Control, l
independent Quality Assurance Surveillance, and Quality Assurance Audits.
Table 2 defines the three levels of QA as they are to be implemented for station operation and also shows the comparison with similar principles which shall apply to nuclear fuel procurement and any future major engineering and construction activities for the Cooper Nuclear Station, it is intended that clearly separate lines of responsibility be maintained between those responsible for the operation of Cooper Nuclear Station and those responsible for auditing to verify that all quality and licensing requirements are consistently being met.
QA responsibilities will vary depending upon the type of activity involved (See Sectica 4.1.3). Additional details on individual QA responsibilities are given in the 31 Revision 7
paragraphs which follow, together with additional explanation of the interrelationships between the various supervisors and managers involved.
3.2 Nuclear Power Group Management 3.2.1 Vice President - Power Production The Vice President - Power Production is the responsible executive of0cer for all CNS Quality Assurance-related activities, lie may delegate responsibility to the Nuclear Power Group Manager as in 3.2.2 below.
3.2.2 Nuclear Power Group Manager As delegated by the Vice President Power Production, this responsibility includes the Quality Assurance requirements governing those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. Pertinent activities include designing, purchasing, fabrication, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in service inspection and modifications that are associated with Cooper Nuclear Station.
The responsibility and authority over the Safety Review and Audit Board has been delegated to the Nuclear Power Group Manager. The Nuclear Power Group Manager reserves the authority to conduct, or order the auditing or monitoring of any operations 32 Revision 7
activity, at any time, to ascertain the effectiveness of the overall QA Program and to determine that all aspects of the QA Program are being complied with.
3.2.3 Division Manager. Ouality Assurance The Division Manager of Quality Assurance, a member of the executive staff, reporting to the Nuclear power Group Manager, shall have the responsibility and authority for administrating and maintaining a Quality Assurance Program for Operation which is in accordance with 10CFR50, Appendix 13.
Inherent in this responsibility is the authority to accept or reject any or all work, materials or equipment associated with Cooper Nuclear Station and Columbus CGOf The Division Manager of Quality Assurance shall direct the preparation of plans and instructions for denning the Quality Assurance functions associated with Cooper Nuclear Station to ensure that such activities are conducted in accordance with the Operating License and appended Technical Specifications. He shall also approve all plans and instructions for defining and auditing the safety related activities within the Cooper Nuclear Station and General Office. The actual audil functions to be performed are defined more completely by the body of Quality Assurance Instructions and Plans required by Section 4.0 of this policy document. He shall also have direct tesponsibility for evaluating suppliers of nuclear safety related equipment, materials, and spare parts and for auditing the QA/QC activities of such suppliers.
l The Division Manager of Quality Assurance and Staff shall have the necessary organizational freedom and access within Columbus CGO and Cooper Nuclear Station l
l 33 Revision 7
to institute the necessary Quality Assurance requirements, identify problems, and pursue prompt corrective action.
Figure 1 outlines the QA Division functional organization.
The Division Manager of Quality Assurance shall monitor the Quality Assurance activities to the extent necessary for assuring compliance with the program lie shall review the effectiveness of the Quality Assurance Program with the Nuclear Power Group Manager on a regular basis, in addition, the Division Manager of QA has a direct line of communication with the President and C.E.O.
lie shall serve as a member of the Safety Review and Audit Board and provide additional QA Personnel to participate in SRAB activities when requested.
4 NPPD Quality Assurance Staff, under the direction of the Division Manager of Quality Assurance, shall have the responsibility and authority for implementation and ongoing development of the Quality Assurance Program for Operations, in addition, it shall be the responsibility of the Quality Assurance Division to monitor the interface between the Nuclear Operations and Nuclear Engineering and Construction Division to ensure that plant modification and repairs receive the proper design reviews and approvals.
As shown in Table 2, he shall have responsibility for accomplishment cf third level QA Audits and shall obtain assistance and special expertise when necessary to complete such audits effectively.
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t
1 3.2.4 Ouality Assurance bignager - CNS The CNS Quality Assurance hianager, reporting administratively to the Division hianager of Quality Assurance, shall have the responsibility and authority for implementing and maintaining the Quality Assurance Program for Operation at CNS.
lie shall also be responsible and have the authority to perform, direct, or coordinate QA Surveillance and Audit activities within Cooper Nuclear Station to determine if conformance with NPPD Quality Assurance hianual and applicable federal regulations as defined in the NPPD QA hianual a c being maintained. The CNS QA hianager shall advise and assist the Division hianager of Nuclear Operations in all matters which affect the quality of the station. Similarly, he shall advise and assist all station personnel in matters regarding Quality Assurance and Quality Control. The CNS QA hianager shall designate members of the CNS QA Staff upon request to provide training and instruction programs to enable CNS personnel to effectively execute the District QA Program. The CNS QA hianager is also responsible for monitoring of open audit items and interface with NRC during mspections at CNS. In addition, he shall aleo be responsible to verify that schitions to safety related problems have been implemented and to perform scheduled audits of those activities listed in Section 4.1.3 on an announced basis. Additional specific duties shall be defined in the Quality Assurance Instructions and Plans issued in accordance with Section 4.0 of this Policy Document. The CNS QA hianager or designec shall also serve as a non voting member of the Station Operating Review Committec (SORC).
l l
l 3-5 Revision 7 1
The CNS QA Manager and Staff will observe operations, maintenance, in service inspection, special processes, repair or modifications, and other safety related activities covered by the Quality Assurance Program, and to recommend that work stop when such activity, in their opinion, does not comply with approved controlling document.s, The Division Manager of Nuclear Operation or designec is responsible to act on that recommendation and actually stop work unless he has determined such stoppage would result in a violation of the Technical Specification or other approved documents governing station operation or whether there are overriding considerations of safety involved.
The CNS QA Manager will provide for a coordination function for QC activities at CNS. This includes reviews of inspector certifications and performance and the establishment of a training program.
The function will also provide the communication path for the resolution of QC Inspector concerns.
During absence of the CNS QA Manager, an individual from his staff will be designated to act on his behalf and serve as the nonvoting member of SORC.
3.2.5 Ouality Assurance Manager - CGO The General Office Quality Assurance Manager, reporting administratively to the Division Manager of Quality Assurance, shall have the responsibility and authority for implementing and maintaining the Quality Assurance Program within the CGO.
1 36 Revision 7 l
4 The General Of6ce Quality Assurance Manager shall have the responsibility and authority for the controlling, administrating, distributing, and coordinating changes and additions to the Quality Assurance Program for Operation, subject to the requirements of Section 4.0 of the policy Document. The General Office Quality Assurance Staff shall support the CNS QA Staff in quality matters such as internal audits and outage coverage upon request, as agreed between the General Office Quality Assurance Manager and the CNS QA Manager. The General Office QA Manager and Saff shall have the responsibility for providing guidance to the CGO Nuclear Divisions in all matters affecting quality. They shall also establish and implement the program for evaluating supplicts for safety related equipment, materials, spare parts, and services.
They shall also be responsible to perform scheduled surveillances within the General Of6cc and verify that corrective action has been implemented.
The CGO QA Manager shall establish a program for QA review of the design / engineering function in the CGO, including configuration management.
Additional duties are denned in the Quality Assurance Instructions and Plans.
The General OfSce Quality Assurance Manager is responsible for interface, along with the Division Manager of QA, with NRC inspections at the General OfSee, in addition, he shall also provide for training and instruction programs to enable General Of6ce personnel to effectively execute the District Quality Assurance Program.
Unless otherwise provided for in writing, the General OfGce Quality Assurance Manager shall act for the Division Manager of Quality Assurance in his absence.
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l 3.2.6 Ouality Anurance Senervisors The Quality Assurance Supervisors report to the applicable QA Manager and are responsible for the performance of work activities assigned. They are responsible to direct the performance of QA activities, and to identify any condition adverse to quality to the appropriate QA Manager. The QA Supervisors are responsible for the -
continued maintenance and upgrading of QA Program Documents.
3.2,7 Ouality Assurance Staff General Office Ouality Assurance Staff The General Office Quality Assurance Staff shall be responsible to assist and advise J
the General Office Quality Assurance Manager in all matters which could affect the
- Quality Assurance activities within the General Office. This includes advising and assisting General Office personnel in all matters.regarding -Quality Assurance, verification that solutions to safety related problems have been implemented, and for i
the performance.'of audits and surveillances~of work activities within the General-Office on an announced or unannounced basis.
- The CGO QA Manager has designated the CGO QA BiiN@ Supervisor responsibility.
for the ongoing development and implementation of the supplier evaluation program; review of procurement speelfications and associated drawings to determine if special I
requirements such as codes, standards, materials, tools, and inspections, etc., are l'
38 Revision 7-m.
properly included; and development and implementation of the QA engineering function.
CNS Ouality Assurance Staff The CNS Quality Assurance Staff shall be responsible to assist and advise the CNS Quality Assurance Supervisors in all matters affecting the quality of the station. These duties include procedure preparation, performing QA activities within the station, advise and assist all station personnel in all matters regarding Quality Assurance and Quality Control, verify that solutions to safety related problems have been implemented, perform audits and surveillances of work activities within CNS on an announced or unannounced basis. Additional duties shall be as defined in the Quality Assurance Plans and Instructions issued in accordance with Section 4.0 of this policy document.
Disagreements or differences of opinion on Quality Assurance rnatters are expected to be documented and resolved jointly by both the CNS and General Office Quality Assurance Staff and appropriate CNS or General Office supervisory personnel. Where such resolution is not achieved within a reasonable period of time, unresolyc4 i
differences shall be promptly reported to the appropriate Quality Assurance Manager for resolution jointly with the Division Manager of Quality Assurance and the other respective Division Manager.
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Secretary to the Division Manager of OA The Secretary to the Division Manager of QA shall be responsible for administering and documenting the controlled QA program document distribution.
Additional specinc duties shall be as defined in the Quality Assurance Instructions and Quality Assurance Plans issued in accordance with Section 4.0 of this policy document.
3.2.8 Division Manager Nuclear Engineerinc and Construction The Division Manager of Nuclear Engineering and Construction under the direction of the Nuclear Power Group Manager shall provide technical assistance for plant modification activities at Cooper Nuclear Station. Those Quality Assurance activities associated with such modifications will be conducted in accordance with the CNS Quality Assurance Program for Operations, These activities will be audited periodically by Quality Assurance Staff and quality related problems shall be identified and reported to appropriate levels of management for resolution.
The Quality Assurance Staff will perform the necessary follow up action to assure that corrective action is implemented in a timely manner.
Nuclear Fuel Manager For those aspects of Fuel Management QA covered by the QA Program, the Nuclear Fuel Manager, under the direction of the Division Manager of Nuclear Engineering and Construction, shall be responsible to furnish technical assistance as required to the 3 10 Revision 7
Division Manager - Nuclear Operation and the QA Staff. Such reviews shall not replace or supersede the formal audits.
3.2.9 Division Manacer - Nuclear Operations The Division Manager of Nuclear Operations, under the direction of the Nuclear Power Group Manager, shall be responsible and have the authority for assuring that Quality Assurance activities, as defined by this and other approved QA Program documents are complied with Some of these responsibilities are delegated to CNS management personnel and include Quality Control and Inspection functions as defined in Table 2.
The actual functions to be performed shall be defined in lower tier documents such as QAPs, NPG Directives, etc.
The Division Manager of Nuclear Operations shall regularly review station activities for the purpose of keeping abreast of significant quality activities.
3.2.10 Division Manager - Nuclear Support l
The Division Manager of Nuclear Support, under the direction of the Nuclear Power Group Manager, shall be responsible and have the authority for assuring that activitics under his control are conducted in accordance with this QA Program. This includes but is not limited to timely responses to QA Division Audit and Surveillance findings I
and implementation of appropriate corrective actions.
i 3-11 Revision 7 L
3.2.11 CGO Department Managers CGO Departmental hianagers report to either the Division hianager - Nuclear Engineering and Construction or the Division hianager - Nuclear Support as described in the USAR and are responsible for implementation of QA Program objectives within their area of responsibility.
3.2.12 CNS Department Managm CNS departmental managers report to the Division hianager - Nuclear Operations as described in the CNS USAR and are responsible for implementation of QA Program objectives within their area of responsibility.
3.3 Cooner Nuclear Station Personnel The operational duties and responsibilities of the Cooper Nuclear Station personnel are described in the CNS Procedures hianual, Reference 7.5. In addition, the Cooper Nuclear Station personnel are assigned Quality Control and inspection functions.
Station personnel, under the direction of the Division hianager Nuclear Operation, are responsible for assuring that the station is tested, operated, maintained, and modified in accordance with approved plans and procedures, l
1 3-12 Revision 7
t t
3,4 -
CGO Personnel The duties and responsibilities of CGO personnel are described herein and in the appropriate implementing documents.
These documents address the CGO responsibility for such items as design, procurement, modification, and licensing.
Reporting through department and division managers described previously, theirs is the first line responsibility for implementing this pmgram in the CGO -
3.5 Safety Review and Audit Board j
The board must: verify that operation of the plant is consistent with company policy and rules, approved operating procedures, and operating license provisions; review important proposed plant changes, tests, and procedures; verify th'at lleensee events are promptly investigated and corrected in a manner which reduces the probability of i
recurrence of such events; and detect trends which may not be apparent to a day to day
- observer,-
' Specific duties and-responsibilities of SRAB, including auditing, are identified in
}
p
- Reference Q, CNS.--Radiological Technical Specifications, and in-the SRAB NES$ N M-1 L
l 3 13 Revision 7 j
L
.- u...
.a m
..m..
3.6 Station Oncrations Review Committee The Station Operations Review Committec (SORC) has been established to advise the Division Manager Nuclear Operation in all matters regarding operational safety.
Specific duties and responsibilities of SORC are identified in Reference 7.14, CNS Radiological Technical Specifications.
3.7 Outside Suppliers. Contractors. Subcontractors. and consultants During the life of Cooper Nuclear Station, it will be occasionally necessary to obtain assistance from outside suppliers and contractors. At all times, these outside suppliers, contractors, and consultants will work under the direction of the NPPD organization having primary responsibility for the particular work being performed, in those instances in which outside suppliers or contractors merely furnish personnel to augment the normal station or CGO staff for particular activitics, such outside contractor personnel shall be required to perform their work in accordance with the CNS Quality Assurance Documents and other appropriate CNS procedures and instructions.
In those instances in which outside suppliers, contractors, and subcontractors are assigned primary responsibility for a particular activity, such outside contractor shall be required to maintain a Quality Assurance and Quality Control Program and organization appropriate to the work to be performed. All suppliers, contractors, and consultants performing work classified as essential shall be maintained on the appropriate section of the CNS Approved Suppliers List. Selection of outside 3 14 Revision 7
suppliers or contractors shall require the active participation of the Quality Assurance Department in evaluating and approving their Quality Assurance Program and reviewing the procurement documents prior to awarding the contract.
In every instance in which outside contractors have responsibility for work on safety related nuclear systems, they shall be contractually required to work to procedures previously approved by the NPPD organization having primary responsibility for the particular work being performed. in addition, they shall be i
contractually required to prepare, prior to performing the work, QA/QC Procedures specific to the work to be performed for the Cooper Nuclear Station. Recognized standards or existing proprietary procedures may be used, but they must be specifically invoked in writing and clearly identified as to their applicability to the CNS work.
If any portion of work on safety-related nuclear systems is to be subcontracted, the prime contractor shall impose the appropriate QA requirements on the subcontractor.
NPPD QA shall have drect access to and communication with the contractor's personnel at all levels, both a. their home office and in the field.
Prior to performing work at Cooper Nuclear Station, outside suppliers,-contractors, consultants, and selected representatives from the NPPD Nuclear Operation and Nuclear Engineering and Construction Divisions shall jointly develop and enforce written agreements and procedures which clearly define the limits of the work; interface between contractor and station personnel; status and custody tagging procedures; contractor personne; dosimetry; and any other aspects which bear on 3-15 Revision 7
j station or personnel security and safety, Such agreements shall be reviewed by the Quality Assurance Department to ensure compliance with applicable Quality Assurance
- Program, At all times when outside suppliers, contractors, and consultants are obtained to assist in the execution of this QA program, the responsibility for effectiveness of these support organizations activities will remain with NPPD, 3-16 Revision 7
4.0 OUALITY ASSURANCE DOCUMENTS The CNS Quality Assurance Program is defined by written policies, plahs and instructions which shall be implemented throughout the operating life of the station.
4.1 NPPD Internal Documents Work procedures are based on the requirements of the Quality Assurance Program.
Preparation and maintenance of basic work procedures is performed by engineering and operating groups, separately from the QA Plans and Instructions. Mandatory QA/QC checkpoints shall be incorporated directly in or attached to, the work procedures to facilitate coordination between the specific work activity and the Quality Control function.
It is not the intent to include the preparation of basic work procedures under the responsibility of QA, nor is it the intent to incorporate basic work procedures into the QA Program Documents. Work procedures, however, shall be reviewed by Quality Assurance for proper implementation of the QA Program objectives.
The format and content of QAPs and QAls shall be as specified by a Quality Assurance Instruction. Significant changes shall be reviewed and approved by the same levels of management hs for the original document.
Each change, when approved and issued, shall be distributed through a controlled distribution system.
4-1 Revision 7 L
Particular circumstances may occur while some work is in progress, which necessitates a change to an approved work procedure. When such circumstances arise, the changes must be authorized per procedure. The written record shall clearly show the nature and extent of the change and the reason for requiring such change.
4.1.1 Ouality Control Insocction The Quality Control Inspection function shall be performed by individual (s) other than those who are actually performing the step (s) being inspected or who are providing direct, hands-on, at-the-job supervision. The Cooper Nuclear Station management, as part of their normal management function, are responsible for preparation of the Quality Control requirements of the Peer QC program; however, the CNS QA Manager is responsible to review and accept control methods prior to implementation.
The CNS Quality Assurance Manager, working with the CNS station management, shall verify that adequate Quality Control inspections are incorporated directly in, or attached to, the work procedures and shall periodically inspect work performance to assure that the procedures containing Quality Control inspections are being followed.
The QC Program shall identify the specific work which is to be subjected to inspection or verification and shall provide in detail the elements of work to be inspected which include:
1.
Identity of the inspector or data recorder.
4-2 Revision 7
l 2.
Type of inspection or verification.
l 3.
Results (data to be recorded).
4.
Acceptance (qualitative or quantitative) criteria.
5.
Method of disposition of unsatisfactory inspection results.
6, Reporting requirements.
In addition, clear instructions shall be given regarding the timing, frequency or scheduling, and notification requirements for such inspections so as to obtain maximum effectiveness and to minimize delays in completion of the work.
It must be recognized that certain work, particularly in nonroutine maintenance or repair, cannot be anticipated. Therefore, procedures and Quality Control Inspection requirements cannot be prepared until a particular problem has been detected and evaluated.
Routine maintenance and repair of essential systems and components generally requires performance of a complete or partial Surveillance Procedure prior to placing the system back in service. This type of QC (actual performance or functional testing) following completion of work is considered a unique advantage on an operating facility. Such surveillance testing may be performed by the individuals who performed 4-3 Revision 7
l the maintenance activity. Records of the surveillance will be reviewed by the system engineer or other supervisory / management personnel, 4.1.2 Quality Assurance Instructions (OAll The Quality Assurance Staff shall prepare QAls approved by the Division Manager of Quality Assurance. As previously described in Section 1.5 of this document, QAls define QA division work activities. When approved, QAls shall become a part of the CNS Quality Assurance Program for Operation.
4.1.3 Ouality Assurance Plans (OAP)
Concurrent with the preparation of work procedures, and during operations or maintenance activities, Quality Assurance Staff shall develop QAPs as needed. As described in Section 1.5 of this document, these QA Plans will outline specific Quality Assurance activities and shall become a part of the CNS Quality Assurance Program for Operation. Distribution of these Plans will be to those individuals who are responsible for that particular activity. A QAP shall be developed for each functional area defining the scope of the QA program.
The format and content of QAPs shall be specified in a QAI to provide uniformity and to assure that each plan is complete and adequate for the intended purpose.
44 Revision 7
The QAPs shall be prepared by the Quality Assurance Staff and shall be reviewed and approved by the Division Manager of Quality Assurance. In addition, when signincant changes have been made to these documents, the QAP will be routed to the following for review and comment:
Division Manager - Nuclear Operations Division Manager - Nuclear Engineering and Construction Division Manager - Nuclear Support The QAPs shall define the specific work which is to be subjected to Quality Assurance review, surveillance, and audit, and the manner in which such review, surveillance, and audit is to be implemented.
Checklists shall be prepared Es"desdribul bypAli after reviewing the work procedures describing the QA Surveillance or QA Audit buidelines, a)
Ouality Assurance Surveillance The Quality Assurance Surveillance function is intended to provide an independent verification, on a continuing basis, that work is being performed in accordance with the requirements of the controlling documents.
pieli siihfeillhiidsfriis9}sydif6fiiiEEe;bisedlof c2ifi1plisn6Eoilefiisd'depeiidthf6iitthe 45 Revision 7
i MWyfi@I!s@ll6(MMiejil6A$l The Quality Assurance Surveillance activities are not-intended to duplicate QC Inspection activities, however,
- duplication may occur, in the effort to satisfy both Quality Assurance Surveillance and Quality Control requirements.
The objectives of Quality Assurance Surveillance are to verify that the Quality Control Inspection Program is being effectively implemented; that personnel performing Quality functions are properly qualified; that adequate information is recorded to provide a complete and accurate quality history; and that deficiencies -
are identified, corrected, recorded, and corrective action is taken to prevent
- recurrence.
This philosophy shall be taken into account in developing the checklists jij y@d@@ilf6E!M@l#@l@[j[6f Quality Assurance Surveillance activities.
QA Surveillance shall be as prescribed in QAPs and QAls.
The QA checklists shall identify the area of work to be. subjected to surveillance y
and shall provide necessary instructions. The timing, frequency, or schedule for the surveillance shall be coordinated with the work being evaluated to ensure maximum effectiveness with minimum impact on the progress of the work, 1
b)- Ouality Assurance Audits 4-6 Revision 7 4
A comprehensive system of planned and periodic audits shall be implemented to verify compliance with all aspects of the Quality Assurance Program and to determine the effectiveness of the program. The audits shall be performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities for the work being audited.
Degnding)rijhsMtWQfLthe ftihetiohlbeitig hydit6d;th6lsddits a elBonddi't6d
[hylisfoYniah6bhb'assdiniaiisMio"ths;issihis'ni]Menlyractical) The audits are supplemented by ' &fofmanc6 based!ahdl6olnipllinis"orishtixi surveillances, the p
results of which become part of the fmal audit package. The General Office Quality Assurance Manager and CNS Quality Assurance Manager shall have the responsibility and authority for planning and executing Quality Assurance Audits identified by approved QAPs. However, the SRAB, or any manager or executive in the chain of organization above the Division Manager - Nuclear Operations, or above the Quality Assurance Supervisors and Managers may initiate and carry out special Quality Assurance Audits within the guidelines provided by this Quality Assurance Program. Audit results shall be reported in writing to the NPG Management in accordance with the requirements of QAI 5 and the results shall be reviewed with the Management responsible for the area of activity audited. Appropriate follow up action shall be taken and documented as directed by the appropriate Quality Assurance Manager or Supervisor.
Internal instructions Ehdjdidslih6s include descriptions and timing of types of audits to be performed; infdiihatl6hlfoKihiliat.dEahd performing audits, and i
ihf6fhiili5h for preparing audit reports.
4-7 Revision 7
4 Each QAP will be implemented through the use of the appropriate checklist. On the basis that some Quality Assurance Audits are to be conducted or directed by management, it is essential to maintain a high degree of flexibility in the manner of conducting an audit. It is intended that the QAPs provide audit guidelines to assure that areas to be audited are sufficiently defined in advance and that audit personnel are adequately prepared to make a meaningful audit with a minimum of interference with the progress of the work. Also, flexibility is required to permit the auditor to adapt his procedures to the conditions existing at the time the audit is made.
4-8 Revision 7
4 5.0 METHOD OF IMPLEMENTATION The CNS QA Program for Plant Operations will utilize the guidance provided by NRC publications WASH-1283 (5-24 74), WASH 1284 (10-26-73), and WASH 1309 (510-74) (" rainbow" series) except as noted in the " Specific Exceptions" of this section.
The existing operational QA Program does not address all of the detailed requirements set forth in the " rainbow books." A detailed review has been made; to determine where the CNS QA Program differs from the ANSI Standards cited in the " rainbow books "
With respect to the applicability of the " rainbow books" and the associated standards, it is impracticabic to apply all of the requirements set forth by these documents to a plant for. which important, and (in some respects) irreversible commitments, were made at the start of commercial operation (1974) It is also impracticable to apply requirements to an operating plant which were intended solely for the design and construction phase in the event that construction activities are undertaken, the District will commit to compliance with the applicable portions of the WASH Series ANSI Standards, it is NPPD's intent to apply quality standards to maintenance, repair, and modification activities which will provide results which are equal to or better than the original construction.
5-1 Revision 7
The detailed methods of implementation shall be as provided for in QAls and QAPs prepared in accordance with Section 4.0.
The Quality Assurance Managers or designees shall review and comment on the NPG procedures to ascertain that necessary quality requirements are included. Procedure changes will be incorporated as necessary to correct identified control deficiencies or needs. Differences of opinion on QA comments shall be resolved as indicated in Section 3.2.3.
After review of the various NPG procedures and manuals, the Quality Assurance Mhnager shall review the appropriate QAls and QAPs for the purpose of assuring that the overall QA Program objectives continue to be accomplished in each segment of the work to which this QA Program applies.
Quality Assurance activities shall be coordinated with the SRAB and SORC.
QA activities shall be conducted in a manner and on a schedule to assure organization, supervision, communications, and technical and administrative practices clearly provide for smooth, orderly, controlled, and safe execution of all safety related functions.
Written reports of all QA activities, including descriptions of deficiencies and resolution thereof, shall be incorporated into the of0cial QA file. Corrective action on deficiencies shall include resolution of the specific deficiency and verification that corrective action has been implemented to prevent occurrence of similar deficiencies i
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a,
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In the'. future. A report 'of QA Audits performed (internal and external) shall be submitted.to the Vice President - Power Production by the Division Manager of
-i
.l Quality Assurance annually.
The Quality Assurance Staff shall maintain an up to-date summary of the CNS Quality l
Assurance Policies, Instructions, and-Plans, showing-how.this QA Program for
. Operation implements the NRC guidelines contained in 10CFR50, Appendix B.
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6.0 RECORDS RETENTION AND DISPOSITION Instructions have been prepared by the responsible organizations to provide guidelines for CNS and CGO record retention and disposition in accordance with this policy document and applicable regulatory criteria. As a minimum, these proccoures cover g
the following:
a)
Records content and location; b)
Principal location from which records are to be controlled; c)
Complete records inventory and master index; d)
Conditions of storage, access, and security; e)
System of records identification, retrieval, and control; t)
System of records transfer and disposal.
Quality Assurance records (reference 7.9) will be entered into the controlled records system after they have been dedicated. This dedication occurs when the activity to the document becomes part of the operating condition of the plant.
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7.0 REFERENCES
The following documents were used in the preparation of the Quality Assurance Program for Operation of the Cooper Nuclear Station. It is intended that these documents be used on a continuing basis in the performance of Quality Assurance activities for station operation since they offer measurement criteria against which the QA Program car, be evaluated.
7.1 Quality Assurance Criteria for Nuclear Power Plants 10CFR50, Appendix B (USNRC).
7.2 Standard of Administrative Controls for Nuclear Power Plants, American National Standard ANSI 18.7 - 1972.
7Property "ANSI code" (as page type) with input value "ANSI 18.7 - 1972.</br></br>7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..3 Updated Safety Analysis Report, Cooper Nuclear Station, Nebraska Public Power District (NRC Docket 50-298).
7.4 Environmental Report--Operating License Stage, Cooper Nuclear Station, Nebraska Public Power District (NRC Docket 50-298).
7.5 Cooper Nuclear Station Procedures Manual.
7.6 Safety Rules, Nebraska Public Power District.
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7.7
_ Safety Guides for Water-Cooled Nuclear Power Plants (USNRC), as appropriate. -
' 7. 8 '
Quality Assurance Requirements for Nuclear Power Plants ANSI N45.2 - 1977.
l 7.9 -
Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants ANSI N45.2.9 - 1974.
1
- 7.10-Quality' Assurance Terms and Definitions ANSI N45.2.10 - 1973.
t 7.11 cQuality Assurance Requirements 'for the Design of Nuclear Power Plants ANSI N45.2.11?- 1974 7.12 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants.
ANSI' N45.2.12 - l'977. -
L7.13 Supplementary Quality.? Assurance : Requirements : for Control-of Procurement of -
Equipment, Materials, and Services for Nuclear Power Plants ANSI N45.2.13 - 1976.
17.14 )
' CNS Radiological Technical Specifications.
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FIGURE 1 Nebraska Public Power District NUCLEAR POWER GROUP QUALITY ASSURANCE DIVISION QA QA Engineer
- Engineering (3)
Supervisor President and Yk:e-President Chief Execut!ve Production Quality S*"IC' M
- Office Assurence ManagerGO.
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Nuclear Pcwor Secretary QA Suppfw
- QA Engiw
- O'ocPManage' Supervisor (3) i.
i Administrative Secretary 11
[
Divlelon Manager g
g,,
M Specianst
- Assurance og Supervisor (4)
Queiny Assursnee QuelMy Manager-CNS Control C--d..sh Audit end
~'-
Responsible for QA Second Leret Secretary gg g OA S ecistM
- P Surveillences and Third Level QA (2)
Audits QA Enginew
- Direct Communications st= Secretary (2) 8-1 Rev.7 QA Engineer *
(1) -Yecant
4 O
IdlEli.1 SYSTEMS AND MAJOR COMPONENTS COVERED BY THE OUALITY ASSURANCE PROGRAM I.
NUCLEAR STEAM SUPPLY SYSTIiM A.
Reactor Primary Vessel B.
Reactor Primary Vessel Supports C.
Control Rods and Drive System Equipment Necessary for Scram Operation D.
Control Rod Drive Housing E.
Fuel Assemblies F.
Core Shroud -
G.
Steam Dryer H.
Steam Separator II.
. ADS - Automatic Depressurization System
.B.
HPCI - High Pressure Coolant Injection System C.
LPCI - Low Pressure Coolant Injection System D.
-CS - Core Spray System E.
RCIC - Reactor Core Isolation Cooling -
III.
REACTOR PROTECTION AND ENGINEERED SAFEGUARD SYSTEMS A.
Rod Sequence Control System l-C.
Standby Gas Treatment E.
Dies:1 Generators l
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Table 1 (Cont'd.)
F.
Electrical Aux Power 1.
Critical 4i60 V Equipment 2.
Critical 480 V Equipment G.
Neutron Monitoring Systems 1.
APRM 2.
IRM 3.
LPRM 4.
RBM 5.
SRM 6.
TIP H.
DC Power Supply I.
Nuclear System Leak Detection J.
Containment Isolation System K.
Nuclear Boiler and Related Instrumentation L.
Rod Position Indicator IV.
NUCLEAR FUEL SYSTEMS A.
Refueling Interlocks for Fuel Handling and Vessel Servicing Equipment B.
Fuel Pool Liner and Gates C.
Fuel Pool Cooling and Cleanup i
9-2 Revision 7
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3 Table 1 (Cont'd.):
V_,
_ RADIOACTIVE WASTE DISPOS AL SYSTEMS j
- A.
Process Radiation Monitoring System 1,
_Off Gas Vent Pipe Radiation Monitoring 2.
Off Gas Monitoring l
3.-
Aug Off Gas Monitoring i
4.-
Main Steam Line Monitoring 5.
Reactor Building Vent Monitoring (GE) 6.
Drywell and Suppression System Leak Rate 7.
Liquid Process Radiation Monitoring VI.
OTHER SUPPORT' SYSTEMS A. :-
Reactor Equipment Cooling B...
LService Water lC.
- Emergency Bypass Function on Control Room Heating, Vent, and AC D. --
Reactor Recirculating (Pressure Retaining Parts Only)
E.
Class I, II, and III Code Items
' F.
Reactor Feed Pumps (Pressure Retaining Parts Only).
- G.
-Reactor Building H&V
- H.
. Fire Protection I.-
' Security
!FitTMMire!
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Table 1 (Cont'd.)
VII.
STRUCTURPR (SEISMICS)
A.
Reactor Building B.
Control Building ~
C.
Elevated Release Point D.
Intake Structure E. -
Diesel Generator Building.
F.
Radwaste Building (Below Grade) 0
- Note -
1, This listing is not intended to be all inclusive.
2.
Application of the QA Program to these systems and components shall bc consistent with the safety related significance of the system or component.
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I Table 2 THREE LEVEL QUALITY ASSURANCE PROGRAM EXPLANATION OF FIRST, SECOND, AND THIRD LEVEL QA RESPONSIBILITIES a)
EIRST LEVEL-Work Performance at CNS and the CGO to assure that and Ouality Control.
Quality Control and inspection programs are being implemented and Each person performing work for that quality requirements are in fact CNS is charged with the first-line being met. This includes verification responsibility for adherence to that activities are properly performed quality practices and procedures. An and procedures are adequate for the individual other than the one doing activity they prescribe, the work (not to include immediate supervisor) will have primary c)
THIRD LEVEL-Ouality Assurance responsibility for Quality Control.
Mtdit.
Personnel at this level are charged with the responsibility for direct Persons performing these audits are inspection, witnessing, and sign off, not directly involved in the attesting that - work has been day to-day inspection or Quality performed in accordance with the Control functions.
Audits and/or quality requirements of the surveillances will normally be controlling documents, performed by or under the direction of the appropriate QA Manager, in b)
SECOND LEVEL-Surveillance /
addition, SRAB shall be responsible
- Mtdit, for reviewing the results of audits and follow-up audits as described in Supervision and management Technical Specifications.
The personnel are responsible for Quality Assurance Staff is also providing workers and QC people responsible for the evaluation of with the proper procedures and audit results and for verifying that guidance for performing quality identified corrective action work.
These Managers and requirements have been Supervisors are then responsible for implemented.
second level surveillance / audit as appropriate for work involved. The CNS Quality Assurance Manager and CGO QA Msigg are responsible for assuring that controlling documents for safety-related activities include appropriate quality requirements.
QA Staff is responsible for maintaining surveillance and audits of the work 9-5 Revision 7