ML20079B916
| ML20079B916 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/11/1991 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9106180172 | |
| Download: ML20079B916 (19) | |
Text
_ _ _ _
,4 D ALTIMORC OAS AND ELECTRIC CHARLES CEN1ER e P.O. DOX 1475
- DALTIMORE. M ARYLAND 21203-1475 Gronor C CottL we t P, i or o.,
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June 11,1W1 U. S. Nuclear Regulatory Commission Washington, DC 20535 ATITINTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318 Twposed Change to Ouality Assurance Program Gentlemen:
In accordance with to CFR 50.54(a)(3), Baltimore Oas and Electric (BOkli) Company herchy requests approval of a proposed change to the Ouality Assurance (OA) Program for Calvert Cliffs Units 1 & 2. The proposed change introduces Nuclear Program Directives (Directives) to replace the existing Quality Assurance Procedures (OAPs). As part of the change, a sponsoring hianager will approve cach Directive whereas the Vice President Nuclear Energy Division (NED) approves all OAPs. The changes result from program improvements developed through the Procedures Upgrade Project.
We propose to change the program as shown on the attached markup. Nuclear Regulatory Commission approval is requested prior to implementation of this change since part of the change could be deemed to constitute a reduction in commitments in the quality assurance program description previously accepted. The quality assurance program is also described in Section 1.B of the Calvert Cliffs Updated Final Safety Analysis Report (UFSAR). He UFSAR is updated annually in accordance with 10 CFR 50.71.
Presently, the OA Program is documented and implemented in the OAPs. Each OAP and revision is prepared by Department; responsible for conducting the activity, and reviewed by NED hianagers and other affected hianagers. The hianager-Nuclear Quality Assurance Department (NOAD) ensures an independent quality assurance compliance review is completed, coordinates comment resolution, and recommends approval. The Vice President-NED approves all OAPs and revisions.
Under the proposed change, Directives will replace OAPs in a systematic transition. Each Directive and revision is prepared under the direction of the sponsoring hianager assigned by the Vice President NED. Each is reviewed by affected hianagers. The sponsoring hinnager resolves comments and the hianager NOAD ensures an independent quality assurance compliance review is completed. The sponsoring hinager approves the Directive and revisions.
t 9106190172 010611 PDR ADOC F: OSOOO317 P
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Document Control Desk Jtme11,1991 Page 2 Presently and under the proposed change, the Vice President NED resohes issues that cannot be settled at the hianager level and is ultimately responsible for the OA Program.
'the primary objective of this change is to increase accountability for OA Program acthities Under the pro 30 sed change, ownership and responsibility for activities are ernphaslied by assigning approva authority to the sponsoring hianager and reducing the administrative role of NOAD.
htmimizing Vice President NED and hinnager NOAD involvement climinates any appearance of shared responsibility. Consequently, the sponsoring hianager clearly owns cach activity and is accountable for the results.
Although not a reduction in commitment Directive processing in the proposed change relieves the hianager NOAD of some responsibilities held under the OAP review and approval process.
Distancing NOAD from the process promotes the organization's independence and focuses resources on independent veriGeation of the QA Program.
The introduction of Directives owned by sponsoring hianagers is part of a larger effon t involving the Proced ires tJpgrade Project to improve OA Program accountability, communications, and interface controls through the creation of a Nuclear Procedures liierarchy. The hierarchy offers numerous advantages that, in effect, raise the commitment to implement a well defined OA Program that protects public health and safety, Plant operation in accordance with the proposed change would continue to satisfy the requirements of 10 CFR Part 50, Appendix IL Criterion 6, ' Document Control,' states in part, "... that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel,.." hinna;ers have the requisite authority and organizational freedom to approve Directives and effective y implement the OA Program at the direction of the Vice President NED.
Furthermore, plant operations benent because of the increased accountability of sponsoring hianagers and the increased ability of NOAD to focus resources on independent veriGeation of the OA Program.
Considering the atxwe information, we conclude that the proposed change will maintain the effectiveness of management control of our QA Program.
We respectfully request your approval within 45 days in order to support Procedures Upgrade Project objectives. Should you have any questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, s
G.
. Creel l
l Vice President Nuclear r iergy l
GCC/JJS/jjs/ dim
Attachment:
htarkup of OA Policy, Revision 26
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D. A.13 rune, Esquire J. IL Silberg, Esquire R. A. Capra, NRC i
l D. O. Mcdonald, Jr., NRC T. T. Martin, NRC L IL Nicholson, NRC R.1. Mclean, DNR J.11. Walter, PSC i
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Ethout At!!!dultu!!
J. A. Tiernan/A. J. Slusark ht. J. hilernick!
W. R. Corcoran C 11. Cruse /P. E. Katz R. C DeYoung R. hi, Douglass/R. F. Ash R. P.11cibel/r. N. Pritchett C. P. Johnson C. C. Lawrence. Ill/A. R.1hornton R. B. Pond, Jr./S. R. Buxbaum L B. Russell /R. E. Denton/J. R. Lemons W. A.1hornton/E.1. Bauereis G.L Adams A. B. Anuje J. E. Baum P. G. Chabot J. J. Connolly G. L Detter G. J. Falibota J. C. Foote L D. Oraber D. V. Graf R. C. Johnson (2)
W. J. Lippold R. E. Nagel R. C. L Olson P. A. Pieringer i
R. II. Waskey, J r.
L O. Wenger D. L Shaw J. J. Sinclair With Attachment G. C. Creel T.N. Pritchett l
B.S. hiontgomcq' A.E. Edwards l
File 60.23.02 NRC 91 143
1B.1 pitQAJULATION AND ESPONSIDJhl,TJIM
' 9tn,ef al RespeasAjjiMes n
All levels of organization have definite and unique responsibilities in assuring safe, economical, and reliable operation of Calvert Cliffs Nuclear Power Plant (CCNPP). Top level management is responsible for ensuring that policies are established, resources are authorized, management philosophy and commitments are communicated to lower levels of the organir.ation, independent verification of management controls are performed, results are reviewed, and appropriate actions taken when necessary.
Middle level management is responsible for translating management policies, philosophy, commitments, and goals; applicable federal, state, and loi.al rules and regulations; Operating Licensas Technical Specifications (TS), and the Final Safety Analysis Report (FSAR) into control programs for activities such as design,,arocurement, construction, testing, operation, refueling, maintenance, repair, modification, training, plant security, fire protection, records, independent verification, and correctivo action.
Middle level management is also responsible for defining, measuring, and modifying the overall ef fectiveness of control programs; taking appropriate action on the results; and keeping top management informed of the status, adequacy, and effectiveness of
-Q control programs, and matters which could have an impact on nuclear safety.
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First line craft and non-craft supervisors are individually responsible for ensuring that appropriate procedures are understood and used to implement each activity described in the control programs; identifying problems, seeking solutions, verifying implementation of solutions; investigating root causes of problems and taking preventive actions; ensuring that conditions adverse to plant and personnel safety are promptly identified, reported, and corrected; detecting trends which may not be apparent to a day-to-day observer, recommending generic solutions for adverse trends to management, and taking appropriate actions, to achieve desired results; ensuring that employees assigned to do a job are properly qualified through appropriate training and experience; have properly qualified procedures, tools, equipment, and parts to do the job, and, ensuring that indapendent inspectfona of work are conducted in accordance with praestablished requirements.
First line non craft supervisors are responsible to ensure that proceduren are written, reviewed, and approved; first line craft supervisors mas not havn this t e=pannihil i t y.
Nnn-supervisory personnel acting as job directors are responsible for ensuring that properly qualified procedures are understood and used; and en=nring that tools, equipment, and parts are on hand to do the job.
Adherence to procedures is vital to the safe a.nd reliable operation of the Calvert Cliffs Nuclear Power Plant.
Personnel are responsible for adhering to established procedures, interpreting them conservatively in case of doubt, and recommending changes when necessary.
Procedures with the potential to affect nuclear or personnel safety shall be strictly adhered to.
When an activity controlled by such procedures cannot be accomplished as described or l
accomplishment of such activity would result in an undesirable situation, the work shall be stopped and the plant placed in a safe condition.
Work shall not i
resume until the procedure is changed to reflect correct work practices. (1) l
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These control programs are designated as Quality Assurance Procedures (QAP as contained in tiie Quality Assurance Manual, or as Nuclear Program Direc Ds implementation of the new procedures hierarchy. The transition of QAPs into NPDs wD1 be systematicaDy controDed.
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' Quality ossurence matters that cannot ba resoned by the llenagers or Vico Presidents are brought to the attention of thn Vice Chairman or the Chair ;n of
. the Board for resolution.
y_f,se President Nuclear Ener.gy Divisi_op The Vice President-Nuclear Energy Division, is responsible for ensuring that the QA Program is developed and administered. The authority to develop and administer the QA Program is assigned to the Hanaget NQAD.
The Vice President-Nuclear Energy Division, is also responsible for ensuring that the requirements of the QA Program that relate to the design, operation, and maintenance of the plant are implemented. This responsibility is carried out through the Plant General Manager CCNPPD; the Manager NEDt the Manager +NQAD; the Manager NSPD the Hanager-NSSD; and the Manager-NOPMD.
M an a geJ.,bu c l e a LQu a l jly. As s u r a n c e,De pay _t me p.t 7
The !!anager-NQAD, in responsible for the detailed-development direction./
and overall coordination of the QA Program for CCNPP.
He is also responsible for auditing, quality verification, and the vendor
]
evaluation functions for CCNPp.
These responsfbilitles include:
(
1.
Developing, revising the QA Hannat for Nuclear Power Plants.
C P.%
Reviewinyan!$n 4 r o lopprovinghra,*bs.ty-Assurance-Procedutaa4QAF) and 4
2.
revisions before they are issued for use.
3.
Taking necessary corrective action, which can include the stoppage of work when manuf acturing, maintenance, or inodification activities f ail to corrply with approved specifications, plans, or procedures.
Such corrective action is stranged through appropriate channels and is delegated when necessary.
When a unit ir. operating, the Manager-NQAD, may recommend to the Plant Ganeral Manager that the plant be shut dnwn.
Thn Plant General flanager has the final responsibility for the overall evaluntion of all aspects and implications of shutting down an operating unit.
NQAD personnel who report to the flanager-NQAD, are independent of departments, sections, and employans responsible for pnrforming specific activities, and have suf ficient authority and organir.ational f reedom to identify quality problems; to inttlate, recommend, or provide solutions through designated channels; and to verify implementation of solutions.
EG&E has established the*. she Manager-NQAD, should have at least six years of responsible experience in engineering, design, manufacturing, construction, quality assurance, or power plant operation, as well as a knowledge of regulations and standards relatad to nuclear power plants.
The organization of NQAD is shown in Chapter 12 of the FSAR.
The Manager-NQAD, delegates the following responsibilities for accomplishing required quality assurance activities:
PNge 6 of 61 l
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U BOEm W Planning and scheduling evsluations of vendor quality assuranco
- programs, Performing receipt inspection functions including special receipt inspections and coordinating testing performed to accept commercial grade items, designated NSR (tems or upgrade NSR ftems for una in SR applications.
(5) 2 Reviewing proposed changes to QA Program documents for compliance with regulations and licensing documents.
Planning, scheduling, and performing internal audits and evaluations of on site and off site functions performed under the nuclear QA Program.
Supporting maintenance ated operations activities by pntforming inspections and surveillances.
Plant General Lianajter Cajte.r1.C.l.i((p Ju_ clear _ Power.flant Dep.gr_ttnelt.t The Plant General Manager is responsible for operations, chemistry, radiation safety, maintenance, and systems and perfmmance engineering activities at CCNPP, lie must ensure that thnse activities are conducted in accordance with the plant operating license and TSs, 9 TSAR, and.the~
tN implementing b
$g pinHty-Assurance-Hanual-for-f4nclent-Power-PleM, an<The Plant General Manager fulfills procedures.
requirements of the Plant Hanager, as defined in ANSI N18.1 (1971).
The organization of CCNPPD is shown in Chapter 12 of the FSAR.
The Plant General Manager, delegates responsibilities for accomplishing required activities as follows:
1.
The Superintendent-Nuclear Operations (S NO) is responsible to the Plant General Manager, for the operation of the plant, including the general supervision of all shift operating personnel and prioritization of maintenance activities to support operations.
This responsibility covers the safety of plant personnel and equipment, all fuel-handling and refueling activition, and adhnrenen to applicable license and Tegulatory requirement s.
The S NO fulfills the position and requirements of the Operattons Manager as defined in ANS1 N18.1 (1971) with the exception taken in Tahle ID.I.
The S-No delegates primary managemant responsibility to the Shift Supervisor (SS) on duty to ensure the safe operation of the plant undar all conditions.
The SS maintains the broadest possible...
perspective on operational conditions that affect the safety of the plant.
As the senior member of plant management. on each shift, he exercises the command authority of his position to take whatever steps he deems necessary during emargency situations to place and maintain in a safe configuration any unit that may be af fected.
page 7 o f 61
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Revision 26 geneger-Information_S.y_st ems _Demaf t men,1 The Hanagar-ISD, is responsible for directing the efforts of ISD personnel involved in acquiring and supporting computer sof twarn and hardwarn.
Vice Presidrnt Hanap,ement Servicis_ Division 0
i The Vice President-MSD, is responsible for ensuring that the activities of NSD
(
personnel involved with medical examinations for CCNPP operators, Nuclear Security Officers, and respirator users, meet the requirements of the regulations.
The responsibility is carried out through the Manager-SMSD.
f tianage_L Safety _and MedicaJ Services Depa_r_tment The Hanager-SMSD, is responsiblo for directing thn efforts of SMSD personnal involved with medical examinations for CCNPP operators (10CFR$5),
)
Nuclear Security Officers (10CFP73), respirator users (10CFR20), and with the Fitnens for Duty rule (10CFR26).
1B.2 OUALITY ASSURANCE PROGRAM General Controls BG6E's QA Program for CCNPP is applied to structures. systems, components, and i
activities that have been designated SR hecausn they prevent accidents or mitigste the consequences of postulated accidents that could causa undue risk to the health or safety of the public.
The QA Program in also applicable to designated NSR structures, systems, components, and activities as committed to in regulations.
Designated NSR program requitements are based on a graded approach to Quality Assurance required to meet applicable regulatory requirements or guidanen.
The level of QA Program controls placed on NSR items are defined inJ)APy Amkol Wr$ce)
Gh C &d finram This Program is governed by -tko-Quality-Assurance 41amial-4or-NuclearJower_.
J44nW which specif,65s ass,ignment of rn=ponsibilities for implementation of the 4
Program and establishes responsibilf t ins for controlling nnd ensuring the quality of the Program's activities.
l Controls have been established for spec.!fying on a Qun11t y 1.ist (Q-l.ist) all SR structures, systems, components, and nr.t.ivitins that. are subject to thn requiremants of the QA Program.
1 The Statement of Authority, in-the-Qualit-y-Assurance-Hanual-for-Nuclear-Power 41.antw signed by the Chairr,ian of the Board, establishes the overall QA Policy of BG5E. This Statement sets the goal of safe and rnliabin operation of CCNPP; commits the Company to a QA Program designed to ensurn the plant's compliance with regulatory requirements, BG&E commitments, and established practices for reliable plant operation; cad requires overy person involvod in QA Program activities to comply with the provisions of thn Program.
I The Policy 1.4 approved by the Vice President-NED and irepicmented by the Managers of NQAD, bT.D. NOPMD, NSPD, NSSD, CCNPPD, ETD, FESD, GMD, PMMD, ISD, and SMSD.
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'Th3 QA Progrcm hco octablished controln for BG6E and ite contractors as rcquired to ehauta that the criteria of 10 CFR 50 Appendix B, will bn met throughout the operations phase of the plants 1.c.,
during activitten of testing, opetation, maintenance, repair, modifiqation, and refueling.
Tha QA Program has also established controls to ensure that the construction and operation of designated NSR structuren, systemn, components and activitien for the Independent Spent Fuel Storage installation (ISFSI) are conducted in compliance with 10 CFR 72.
D e Manager-NQAD, coordinates the development of the QA Program and the Hanager-NSSD controls the issue and revision of the Quality Assurance Manual for j
Nuclear Power Plants.
Each change to the Manual is issued with a transmittal j
notico, which is completed by tha recipient and returned to NSSD to indicate
)
that the documents listed on tha trannmittal have been received and incerporated into the recipient's Manual.
The Manager NQAD, ensuren that the Pengram is revised as regulations, standards, results, or experience dictate. (1) The Hanager also determines and evaluntam the degree of complianen ot GA Program
'i activities with the requirements of.thn_I)uality-Assurnoca-Hanual-for-Nuclear-
)qPower-Plentir and jdfhplementing Froceduras.
Audits are conducted regularly to ent:ure compliance with catablished requiraments, and the results of these audits are reported to responsible management pntsonnel.
The Vice President-NED, ensures that activities of tha NQAD are audited regularly by personnel independent of the Department.
Theme auditors anness the ef fectiveness of the Section's implementation of approprinta portions nf ItG6E's QA Program.
The Vice President-Nucinar Energy Division, evaluaten thn report of the independent audit to determinn if changes are required to the QA Program, lie is responsible for negotiating such changes with the approprinto invel of management and for sending to the Chairman of the Board a copy of the audit report and an account of the corrective action talten.
If a difference of opinion arinen betwacn NQAD personnel and those of other Sections or Departments, thn disputa in resolved as rollows:
The Supervisor / General Supervisor of the QA Unit /Section involved first tries to resolve the mattar with the organir.at.fon responnihin for conducting tha activity.
If a resolution cannot be obt ained, the matter is referred up through the fnllowing management personnni nntil it in risolved:
(3) 1.
The Hanager-NQAD, and thn Hnnager responsible for performing the activity.
NOTE:
If the dispute is with another Unit / Sect ton in NQAD, the ismun will be nattled by the Vice President Nuclear Energy Division.
(3) 2.
The Vice President-Nuclear Ennrgy Division. (1) 3.
The Vice Chairman or the Chairman of the Board.
To ensure that important activition are performed correctly, BG6E conducts l
formal training programs for Company peinonnel with significent responsibilitian.
Thcee programm incloda both initial and enntinuing training Page 14 of 61
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' The QA Program is documented, in-thef}oality-Asaurence-Manual-for-Nuclear-Power-(
Plentr. Thie-Hanue)containsaQAPolicythatidentifiestheNRCregulatory requi renieTils, industry standards, and specific codes applicable to the eighteen criteria contained in 10 CFR 50, Appendix B.
The QA Policy also indicates action that will be taken by BG;,E in response to these documents and to commitments made in the TSAR and TSs for CCNPP. The' Policy is approved by the Vice President-Nuclear Energy Division. (1)
The He'nni alsv contains a series of individual QAPs that imp?cment actions id tified in the QA Policy.
QAPs cover the major activities related to op era' *ag a nuclest power plant, such as plant operation, plant maintenance.
.rs.
ig, purcleso cf items and services, calibrations, etc.
Each QAP is
...1 1,) o~e or.aors. of thu..epartments responsible for conducting the si.i<ity
,b QAP.md revi ew is thereto are reviewed by the manager (s) of the ret,ormWr departmncs (tt en 6,o rtments responalble for the QAP activity, and the P.;neigeri. ' Nucler. S..ury bi
.lon). (1) The Vicn President-Nuclear Energy Livisi n, ar.
n al? QA e.snd..wis tona thereto.
Tim tlanager-NQAD reviews ch::nges to Q,.', end tee ur. mends rapproval to the Vice President 4NED, and the
..anager fSF. issuee. c'QAPconJrevisionsthereto.f1) g j}
4 ae % ct e Ny... (b O. 3 s-i QAPsgs e i.y Interdepr wental relationships and departmental responsibilities as thny slate to particular activities, regulatory requiramants, and flG&E commitments.
One QAP controls the dist ribution and revistou of the'Hanual.
I-Othem ensure that M
Oh?s wk A/Jdrar fecg, % X/nhn'd 1.
The need for special controls, processes, tent equipment, tools, and skills is spe.if t-when necessary to annure that required quality is attained in performance of the activity.
2.
Quality is verified by inspections and tests.
3.
Personnal who perform activitica af fecting quality nchievn and maintain suitable proficiency through appropriate trnining and expnrience.
Department or lower-leval implementing Procedures ara ).repared either by Departments such an ETD and Pt1HD or by groups within Departments.
The controls for review and issue of implemnnting proceduren nrn dfacumsed in Sections 1B.5 and IB.6.
Revi+Lof Onetqtioj)s Procedures require that CCNPP shall be operat ed and aiaint eined in accordance with the plant TSs and operating 11cnnan. Tim following organizations review plant operations to ensure that these proceduren nro followed 9
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t These OAPs (Control Programs) will be symmatically repbced by Nuclear Pregram Directives (also Control Programs) which accomplish the same objective as QAPs but have a differentlevelof a royal. The Procedures Dire::tive defines the resiew and approval requirements for gw M
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Qevision 26
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The Manager NQAD provides independent verification that the requirements
' contained in the Plant's operating license, FSAR, TSs, and plant procedures are met.
This is accomplished through quality assurance audits.
2.
The OSSRC provides independent verification by review that CCNPP is operated in accordance with established requirements.
The OSSRC, which functions under a written Charter approved by the Vice President-Nuclear Energy Division, is composed of on-site and off-site personnel knowledgeable of in-plant operations, nucicar engineering, chemistry and radiochemistry, metallurgy, radiological safety, instruntentation and cor. trol systems, mechanical and electrical systems, quality assurance, and environmental factors. The proceedings of all meetings are documented and sent to the Vice President-Nuclear Energy Division, Committee members, and others designated by the Committee Chairman.
3.
The on-site POSRC reviews matters pertaining to nuclear plant safety. 1his Committee screens subjectn of potential concern to the OSSRC and performs preliminary investigations under the direction of the Plant General Manager. The POSRC, which is chaired by the Plant General Manager, functions under a written Procedure which is approved by the Plant General Manager. The results of all meetings are documented and sent to the l
members of the OSSRC, and others designated by the Committee Chairman.
The maintenance and repair of systems, structures, and components subject to the QA Program are performed by personnel under the direction of the General Supervisors of Electrical and Controls, Radiation Safety, and Mechanical Maintenance, according to written procedures and instructions as prepared by the meintenance force and approved as stated in' the+=11t-y_ Assuranc.oJianuaMor-
-Nuclear P=e-P44nts, These Procedures:
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Ensure.that quality-related activities, such as inspections and tests, are performed with appropriate equipment and under suitabla environmental conditions.
2, Indicate inspections and checks that must be made and records and data that must be kept.
3.
Show where ~ adependent verifications of inspe.ctions or checks should be performed by specified personnel other than thosa performing the work.
When necessary, non-plant Company parsonnel or outsida cont ractors are brought in to supplement the plant work force.
In such instances, the approval of work procedures and the tagging of equipment ore coordinated by a member of the BG&E organization responsible for the performance of the work.
6 loodrol fr Controls are established 4rbha-Qua44thco-S o
Assuranc eManuel-for Naclear Powar.
3 4 Plants to ensure that materials and parts used in the repair, maintenance, and modification of SR and designated NSR portions of the plant are appropriate for the service intented.
Written procedures are prepared for the storage and identification of materials and parts to ensure that they do not deteriorate in storage and can be correctly identified before installation or use.
Pagn 19 of 61 3
- Equipment manufacturers and contractors used for the repair, mainter.ance, and modification of SR and designated NSR structures, systems, and components are required to have quality assurance programs consistent with thn importance of the end product to safety.
IB.3 ILES1_GN. CORTROL Cont rol (cn47g poyac Plant modifications descr ibed in the FSAR and considered significant for nuclear safety are controlled by1 the-Quality. Assurance-Hanual-for-Nuclear-Power-Planter which is written to ensurn compliance with Regulatory Guido 1.64 and 10 CFR 50.59.
Alterations to the Operating License, including TSs, the FSAR and the Emergency Response Plan (ERP) are subject. to the same controls as are altnrations to changes, tests, and experiments definnd in 10 CFR 50.59 Oc.d.rols for changes, tests, and experiments conducted at CCNPP vary according to the following:
1.
Am thn item or activity af fected is or is not descr lhnd in the FSAR.
2.
As the item or activity affected hns been classified SR or NSR.
3.
As a safnty analysis is or is not required.
4.
As the proposed change, test, or experiment does or does not constituto an Unreviewed Safnty Question or require a chango to the TSs.
To ensure compliance with 10 CFR 50.59, changes, tests, or experiments have been divided into catagorins.
Three methods of treatmant are allowed:
1.
Implementing the change, test, or experimnnt ncccrdinr. to Compariy practice for operating power plants, or according to Procedures required hy'the 00ji' *
-Qua l4t y-Annu rance-Manua l-fon - Nun l aa r-Power-P l ant *.
On ld 2.
Implementing the changn, test, or nxperiment accotding to Company pract ice for operating power plants by using Procedures required by the-Quality-6 fro (( gram V
--Assurance-Hanuel-for-Nucleer-Power Plaats. hnt control 1Ing thn change, test, or experiment with a Facility Chnngo Rnquest. (FCR) so thnt the preparation and reporting of safety annlysnn are controlled.
3.
Controlling the changn, test. or experiment with a FCR and not allowing the l
implementing activity to begin until the review requirements of 10 CFR 50.59 and 10 CFR 50, Appendix B, hnvc been met.
Chnnges, tescs, or experiments which require approvn1 by t hn NRC are approved by the POSRC and by the OSSRC.
ihyem Contro1pghave been established to ensure that design changes to SR structures, i
systems, and components are reviewed either by the organization that made the or.iginal design or by a Responsibio Design Organization (RDO) thnt meets t
requiraments specified in ANSI N45.2.11. Section 8.0.
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' 10.
Incorporate the requiramants of 10 CFR 21 for Nuclear Grade procuramants.
11.
Include requirements for QA program elements to be passed on to sub-vendors.
IB.5 INSTRUCTION
S. PROCEDURE
S. AND DRAWINGS Controls delineate the sequence of actions to be performed in the preparation, review, approval, and control of instructions, procedur,s, and drawings.
Controls require that:
1.
Methods for complying with each of the applicable criteria of 10 CFR 50, Appendix B, must be specified,in instructions, procedures, and drawings.
2.
Instructions, procedures, and drawings must specify appropriate quantitative (such as dimensions, tolerances, and operating limits) and qualitative (such as workmanship samples) occeptance criteria for verifying that important activities have been satisfactorily accomplished.
Controls ensure that:
1.
The QA Policy is approved by the Vice Presidnnt-Nuclear Energy Division.
(1)
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2.
.QAPg are developed by Departmonts responsible for conducting particular activities, reviewed by the managers of thn responsible department (s) for that particular activity, and approved by the Vica President-Nuclear Energy Divisio((1) h the.;p n>Nh Aq^"9)'#-
or 3.
Department Procedu es are approved and controlled by the responsible Departments and control procedures are reviewed by the Quality Audits Unit (QAU).
4.
Plant, saction, and unit procedures that control the topics, contents, review, approval, issue, distribution, and revision of plant, section, and unit procedures that specify hnw activities are to be performed are reviewed by a member of QAU.
5.
Other plant, section, or unit procedures that specify how activities are to be performed are controlled by the responsibin organization and reviewed and approved within the resp'nsibin nrganization.
6.
The basis for changes to all procedures will be recorded. (1)
IB.6 DOCUMENT CORTROL Requirements have been established to control the documentation of activities controlled by the QA Program.
Controlled documents include the FSAR for CCNPP; QAPs in the BGGE Quality Assurance Manual for Nuclear Power Plants;4 department, section, unit, and plant procedures that implement the QAPs; specifitations; and drawings.
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-QAPqare required tot l.
Establish controls to ensure that regulatory requirements and BG&E commitments will be implemented.
2.
Describe interdepartmental Interfaces and establish controls for interdepartmental activities.
3.
Specify how important activities, such as plant maintenance or in-service inspection, are to be performed, and give sufficient detail to control the performance of the activity or to ensure that requirements for lower-level procedures are clearly specified.
(nuhurs 4.
Be prepared and controlled in accordance with.onn-QAP that describes,the format, sequence of topics, contents, review and approval, issue and distribution, and requirements for revision and record retention.
Con 4 rol Dv3r *~
During the revieu of each.QAM compliance with applicable criteria specified in 10 CFR 50 Appendix B, is verified and documented.
The Manager-NSSD, is responsible for issuing, revising, and controlling QAps.
O,e W Ytgra.e QAPe are developed by one of the departments responsible for the subject 3
activities.
Each procedure is given a compliance review by a member of the QAU, and technical review by a member of one of the responsible departments. Each Con (nl
,QAf' f s reviewed by department manager (s) who have responsibilities for i
Prope activities governed by that.QAP, and the Managers of the Nuclear Energy Division.
(1)
Each QAP is approved by the Vice president-Nuc1 car Energy Division and issued by the Hang (ger-NSSD. (1)W #w.6 &e3raen D,rn hm m aggrond ly
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& p,w. n., c ry 44 <. o Department procedures are prepared when interfaces or activities within a department are not defined in a,QAP'or when they are needed to specify the content of plant, section, or unit" procedures.
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- I h oy w a4 As needed, dspartment procedures describe how rec uiremants delineated in 0 Ce M QAP"'will be implemented at the department level.
Tsey describe the interfaces trop between groups or units within a department and spec ify requirements to be met by lower-level documents.
When two or more departments are closely involved in performing.an activity that requires more detaO nd instructions than are contained in a QAF, the activity is controlled by* a common department level a
procedure provJ ded that the managers, or their dnsignen, of the affected departments agree to use this procedure, and managers or their designee, review revisions to those portions of the procedure that affect their department.
Asin,\\ %ym Individual departments are responsible for preparing, issuing, revising, and controlling dspartment procedures.
These are prepared and controlled according to a department procedure that describes format, sequence of topics, cc. tents, review and approval, issue and distribution, and reouirements for revision aad record retention.
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'Ecch dspartesnt procedure to give. a technical review by a esubsr of the scas J
department.
QAU is required to perform compliance reviews of controlling i
procedures.
Other procedures are reviewed by QAU on a requested basis, cGnWI Npm j.n4redc(ubt.dd, Plant, section, or unit procedures are prepared to\\deceribe how requirements delineated for subgroups within a department will bbirnplemented when these requirements are not delineated in sufficient detail inkQAPs' or department procedures.
When two or more departments are closely involved in performing plant activities that require more detailed instructions than are contained in a
.QAP or department procedure, the activity is contrelled by a common plant rocedure provided that the managers, or their designee, of the effected departments agree to use this procedure.
Managers, or their desigriee, review tevisions to those portions of the procedures that affect their department.
C4e 1 VNyam,, Ae, bepor kmM, Functional groups within dapartments prepare, issue, revisa, and control the procedures that control their work.
Group procedures must be reviewed by a member of the group, and may be reviewed by QAU.
Group procedures are prepared and controlled according to control procedures that describe format, sequence of topics, contents, review and approval, issue and distribution, and requirements for revision and record retention.
Control procedures are reviewed by a member of QAU.
Organizations that issue instructions, proceduras, specifications, or drawings are required to establish controls that ensure the following:
1.
Changes to a document are reviewed and approved by the organization that performed the original review and approval unless th e. control proce. dure designates another qualified rc.sponsible organization.
2.
Approved changes are promptly incorporated inte ins t ruct ions, procedures, drawings, and other documents associated with the change.
3.
Obsolete or superseded documents are controlled to reduce the possibility of inadvertent use.
Superseded documants retained for reference are marked and stored in separate files.
Other superseded documents are removed from the files.
When changes to drawings or specifications are required, change requests are
[
prepared by the organization that desires the change.
Requests are reviewed and j
approved by BG&E RD0s.
1B.7 C0h_ TROL OF PURCHASED MA_TERI AL,_ EQUIPMENT, _AND_ SERVICES (5) i l
NQAD, NSSD, NED, and PMMD personnel are responsible for the control of purchased /y items and services for SR and designated NSR applications at CCNPp.
I The controls include:
Accepting items or services :nly from vendors who have been evaluated and selected in accordance with dis polic.y.
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'Theso proceduros cro prepared cccording to approprinta sections of the ASME Cods for.particular examination methods.
Procedures, personnol quclifications, cnd the records that verify the Performance of Nondestructive Examinations are kept as nuclear plant records.
Nondestructive Examination Precedures describing methods not described in the ASME Code and/or SNT-TC-1A and its Supplements are at least equivalent to those recognized by the American Society of Mechanical Engineers and the American Society for Non-destructive Testing.
Training programs acceptable to the Principal Metallurgist are developed to complement these alternative methods and to establish the capability of personnel to perform the required examination according to BG&E procedures and to the level of performance to which the individual will be certified.
Co n N ( Ny m nht restricted to, Methods of Nondestructive Examination include, but are radiographic, ultrasonic, liquid-penetrant, gagnetic particle, eddy-current,
- visual, and leak-testing examinations. 1 Procedures ars prepared to cover these examinations in accordance with a"-4AP that detaih the specific examination, requirements for approval, and content of the procedure, such as certification level, accept /teject criteria, examination coverage and
- sequence, surface preparation, test equipment, records required, permissible marking, cleanup requirements, and reference to applicable sections of the ASME Code.
Qualification of Personnel Special processes are performed by cert ified personnel using written process
- sheets, shop procedures, checklists, and travelers (or equivalent), with recorded evidence of verification as follows:
1.
BG&E welders, and welders under contract to BG&E, are qualified and certified in accordance with the requirements of Section IX of the ASME Code and the welding procedure specifications they will be using when welding.
The Principal Metallurgist maintains records of the welding procedure specifications, including essential variables under which the welders are examined, and the results of the cxaminations.
A welder is not permitted to weld SR and dnsignated NSR items until an appropriate performance qualification record, a letter of certification, or, in an emergency, verbal clearance from the Principal Mntallurgist, is on file at CCNPP.
Each welder is required to be requalified as specified in the applicable code.
2.
Non-BG6E welders are not permitted to weld SR end designated NSR items until they are qualified and certified in accordnnen with Section IX of the ASME Code to the welding procedure specification they will be using.
3.
Nondt.structive Examination personnel employed by or responsible to BG&E are certified according to applicable sections of the ASME Code and/or SNT-TC-1A and its Supplements. BG&E employees are trained and certified in accordance with a written procedure.
Non-BG&E personnel are qualified to procedures approved by BG/,E, and their qualifications and certifications of personnel are verified according to written procedures.
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' the corrective action (s).
Unacceptable corrective action (s) are reported to sup'e rvisory or management personnel directly responsible for resolving the adverse condition with progressive escalation to higher levsls of management occurring until the adverse condition is resolved.
Significant Conditions Adverse to Quality require the initiation of root cause analysis and the implementation of corrective actions to prevent recurrence and ate reported to management for review and assessment.
Conditions Adverse to Quality are periodically analyzed for the identification of adverse quality trends.
The existence of an adverse quality trend is resolved in accordance with this section.
A Trend Report is issued to management at intervals specified in approved procedures.
1B.17 00ALITY ASSURANCE RECOR_D_S gg Controls have been estabitshed to ensure that quality' assurance records are maintained to provide documentary evidence of the qual ty of SR and designated NSR items and activities.
Applicable design spacyfications, procurement documents, test procedures, operational procedures,*-QAPs. TSs, and other documents specify records that should be generated, supplied, or maintained by and for BG&E, Quality assurance records are classified as lifetime or non permanent.
Lifetime records, maintained for particular items for the life of CCNpp, for particular items have significant value in relation to demonstrating capability for safe operation; maintaining, reworking, repairing, replacing, or modifying an item; determining the cause of an accident or malfunction of an item; and providing required baseline data for in-service inspection.
Non-permanent records, which show evidence that a SR nnd designated NSR activity was performed in accordance with applicable requirements, are retnined for i
periods sufficient to ensure BG&E's ability to reconstruct significant events and to satisfy applicable regulatory requirements.
Ratention periods are specified in the TSs or in procedures that con t.rol the performance of activities.
procurerent documents specify vendor responsibilitles for the generation, retention, and submission to BG&E of quality assurance documentation related to the fabrication, inspection, and test of SR and designated NSR items and services.
(
Inspection and test records'contain the following an appropriate:
1.
Description of the type of observation.
2.
Date and results of inspection or test.
3.
Information related to noted discrepancies, including action taken to resolve them.
4.
Identification of inspector or racorder of data.
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