ML20079C939

Updated VEP-1-5A, Operational QA Program Topical Rept

ML20079C939
Person / Time
Site:	Surry, North Anna
Issue date:	04/30/1991
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18151A498	List: ML18151A497 ML20079C939
References
VEP-1-5A, VEP-1-5A-01, VEP-1-5A-1, NUDOCS 9106260367
Download: ML20079C939 (105)

Text

,

i VIRGINIA ELECTRIC AND f

POWPR COMPANY 1

OPERATIONAL QUALITY ASSURANCE PROGRAM TOPICAL REPORT VEP-1-5A (UPDATED)

Amendment Five June, 1986 (Updated 4/91) 9106260367 910620 PDR ADOCK 0500028v_.

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TABLE OF CONTENTS Section No.

Title Pace Table of Contents 17.2-1 List of Tables 17.2-111

-List of Amendments 17.2-111 17.2 Quality Assurance During the Operations Phase 17.2-1 17.'.0 General 17.2-1

.1 Topical Report 17.2-1

.2 Quality Ar,surance Standards and Go! des 17.2-1 17.2.1 Organization 17.2-54 17.2.1.1 General Description - Organization 17.2-54

.2 Management of Operational Quality Assurance 17.2-54

.3 Organization 17.2-62 17.2.2 Quality Assurance Program 17.2-63

.1 General Description - Quality Assurance Program 17.2-63

.2 Quality Assurance Program 17.2-64

.3 Identification of Structures, Systems, and Components 17.2-67 i

.4 Periodic Review of the Operational Quality 17.2-67 Assurance Program

.5 Qualification of Quality Assurance Organization 17.2-67 Personnel

.6 Certification of Quality Assurance Organitc' ion 17.2-68 Personnel

.7 Certification of Other Support Personnel 17.2-68 l

17.2.3 Design Control 17.2-69

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l 17.2.4 Procurement Document Control 17.2-71 l

17.2.5 Instructions,' Procedures, and Drawings 17.2-72 17.2.6 Document Control 17.2-73 17.2-1 June, 1986

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Section No.1

. Title Pace 17.2.7 Control of Purchased Material. Equipment. and 17.2-74 l'

Services i

17.2.8-Identification and Control of Materials, Parts, an.o 17.?-76

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Components 17.2.9 Control of Special Process 17.2-77 17.2;10 Inspection 17.2-78

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17.2'11 Test Control 17.2-80 17.2.12 Control of Measuring and Test Equipment 17.2-81 17.2.13:

_ Handling, Storage, and Shipping 17.2-82 17.2.14; Inspection,-Test, and Operating Status 17.2-83

.17.2.-151 Nonconforming Materials, Parts, and Components 17.2-84

.17.2.16 Corrective Action 17.2-86'

.1 Authority to Stop Work 17.2-87

. 21.

~ Imposition of "Stop Work" 17.2 17.2.17-Quality Assurance Records l'7.2-89

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17.2.18

' Audits 17.2-90 I

.17.2-11

_ June, 1986

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LIST OF TABLES Table No.

Title Page 17.2.0' Conformance of the Company's Operational 17.2-2 Quality Assurance Program to NRC Regulatory Guides and-ANSI Standards 17.2.2 Relationship of the Company's Operational 17.2-65 Quality-Assurance Program to Appendix B, 10 CFR 50 LIST OF-AMENDMENTS AMENDMENT

-Amendment No.

TITLE

-DATE

' Original 07-01-75 One 12-30-75 Two 09-27-76

.Three 03-01-77 Four-10-01-82 Four (Updated)_

08-30-85

[

Five 06-30-86 Five (Updated) 03-23-87 1 ;-

Five (Updated)'

06-21-88 Five-(Updated) 06-21-89L Five (Updated)1 06-21-901 I

Five (Updated).

06-28-91 17.2-111 June, 1966

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ABSTRACT This topical report describes Virginia Electric and Power Company's, hereafter referred to as the Company. quality assurance program for the i

operational -phase of its nuclear power stations. The report is organized as, Quality Assurance l

and is generically used for. Chapter 17 part

?

of the Company's l'pdated Final Safety Analysis Reports. The (Operations)

Cornpany quality assurance program conforms to applicable regulatory requirements such an 10_CFR 50 Appendix B and to approved industry standards I

as endorsed therein.

Included is a point-by-point comparison of the procram with the 18 criteria of 10 CFR 50. Appendix H.

This topical report is intended to,be a comprehensive up-to-date description of the Company's Operational Qii311ty Assurance program for nucleaf power generating stations.

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17.2 OUALITY ASSURANCE DURING THE OPTRATIONS PHASE 17.2.0 General i

lt is the policy of the Company to establish and maintain a formal quality assurance program for the operational phase of nucicar power generating stations.

This program is described by written policies.

standards, and procedures.

T1.

application of this program accomplishes two important objectives (1) to provide orderly, uniform administrative and managerial procedures to assure safe reliable, and economic operation of nuclear power _ stations and (2) to assure compliance with regulations promulgated-by the U.S. Nucient Reputatory Commission.

17.2.0.1 Topical Report f

This topical. report in written in the f orma t of a Safety Analysis Report (SAR) Chapter. 17. part 2 " Quality Assurance During the Operations phase", in accordance with the NRC's " Standard Format and Content of Safety

-Analysis Reports for Nuclear Power Plants" (Nov. 1975) and subsequent NRC wuidelines. Tho quality assurance program described herein is applicable to all Company nucleat power stations as referenced by Chapter 17 of the stations' UFSARs.

1 Subsequent changes to the Company's operational Quality Assurance Program will be incorporated as applicable in this topical report.

The topical report is intended to be a comprehensive description of the

-l Company's Operational Quality Assurance Program for nuclear power stations.

17.2.0.2 Quality Assurance Standards and Guiden 1he Company Operational Quality Assurance Program conforms to Appendix B of 10 CFR 50 as amended and complies with the regulatory positions of the Regulatory. Guides indicated in table 17.2.0, as modified or clarified in that table, i

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1 17.2-1 June, 1986

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i TABLE 17.2.0 Conformance of the Company's operational Quality Assurance Procram To NRC Regulatory Gulden and ANSI Standards The ANSI standards, and other documents (i.e., other standards,

codes, regulations, or appendices) that are required to be included as a part of this quality assurance program are either identified in' Table 17.2.0 or they are described herein.

Although this table includes references to ANSI Standards and Regulatory Guides that are required to be a part of this

-quality assurance program, the table is not intended to be a complete list of all NRC Regulatory Guides (etc.) to which the Company is committed.

The specific applicability or acceptability of these listed standards, codes, regulations, or appendices is-either covered in 'this program or -such documents are not considered as quality assurance program requiremental although.they may be used as guidance. When sections of ANSI Standards and other documents are referenced within this program, it is understood that the Company will comply with the referenced sections as clarified in Table 17.2.0, 4

GENERIC STATEMENTS WITH REGARDS TO TABLE 17.2.0 AND THE OPERATIONAL OUALITY ASSURANCE PROGRAM Tor operations phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the l

construction phase, the Company shall control these activities under this Operational. Quality Assurance Program.

When _this Operational Quality Assurance Program is-

used, the Company shall comply with-the i

Regulatory Position established in the guides. listed herein in that quality assurance programmatic / administrative requirements included therein (subject to the clarification in this table) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated'with the maintenance or modification shall be the original requirements or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection. requirements).

Definitions in the referenced standards in this table which are not included in ANSI N45.2.10 -will be-used-as ' clarified in the Company's commitment to Regulatory Guide 1.74.

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17.2-2 June, 1986 1

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Standard, Requirement or Guide Regulatory Guide 1.8

" Personnel Qualifications and Training" (Second Proposed Revision 2, 9/80) Endorses ANSI /ANS-3.1 (Draft 12/79)

The applicability of this guide / standard to other personnel in the Company organization is addressed in other sections of the UFSAR and the Technical Specifications of the individual nuclear facility.

The Company's Position Conformance Status Justification Conforms to Regulatory Guide 1.8 with one (1)

Clarification and Alternative For Exception: NRC License Amendrent enception, one (1) clarification and three (3) meet or exceed applicable guides Nos. 142 and 125 dated December 4, 1990 alternatives. They are:

and standards.

for North Anna and NRC License Amendment Nos. 151 and 148 dated (1) Exception: With regard to Section 4.2.2 December 31, 1990 for Surry approved of ANS 3.1 (Draft 12/79) titled Operations revisions to the Technical Specifi-Manager, Paragraph C Training: The Operations cations granting relief from Section Manager will have or have hels senior operator 4.2.2 of ANS 3.1 (Draft 12/79). The license.

exception allows the Superintendent -

Operations to hold or have previously (2) Clcrification: With regard to the term held a Senior Reactor Operator License

" Bachelor's Degree" as used in the draf t the for the facility or a sinflar designed following qualifications may be considered Pressurized Water Reactor plant.

The equivalent to a Bachelor's Degree:

Supervisor Shif t Operations will fulfill the Operations Manager requirerents of A.

6 years of applied engineering ANS 3.1 (Draft 12/79). This chanze experience at a nuclear facility in the area for allows the Superintendent Operations which qualification is sought, to perform nananenent functions and examint training programs.

B.

6 years of operational or technical experience / training related to engineering in For Clarification: ANSI /ANS - 3.1 nuclear power, and (Draft 12/79) does not provide a clear alternative to formal C.

In addition, experience and training educational requirements, but does i

requirements shall be met as delineated.

provide guidance. This guidance was utilized to develop clarification to qualify non-denree holding persnnnel.

17.2-3 Jure, 1956

Standard, Requirement or Guide Justification Conformance Status The Company's Position l

(3) Alternative: ' With regard to Section For Alternative: Assi/ANS-3.1 1978.

l 4.4.5 of ANSI /ANS 3.1 (Draft 12/79) titled Paragraph 4.4.5 (b) is considered l

Quality Assurance.

to be consistent with the Company experience requirements which are The Company will comply with Paragraph 4.4.5 delineated in other areas of this as originally stated in ANSI /ANS-3.1 - 1978.

report.

Further, the 1978 requirerent is considered more conservat ive than the Draft 12/79 ANSI /ANS Requirement.

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Standard, Requirement or Guide The Company's Position Confornance Status Justification 1

For alternat ive: ANSI Section 4.3.2; (4) Alternative: With regard to Section l

4.3.2, Supervisors Not Requiring NRC License.

Individuals having the specified Paragraph b.;

Experience: At the time of alternate experience possess a working

appointment to the position; the supervisor knowledge of plant activities (e.g.

shall have 4 years experience in the craft operations, maintenance. I & C. health 1

or discipline he supervises or an equivalent physics, etc.) sufficient to perforn a number of years nuclear plant experience in a broad range of supervisory functions.

The individual's day-to-day interaction supervisory position with a Senior Reactor Operator's License.

with the various plant activities has provided hin with an understanding of (5) Alternative: With regard to Section how each activity is integrated into 5.3.3 of ANSI /ANS 3.1 (Draft 12/79) titled safe and effective plant operatiens.

His combination of SRO training and Training for Shif t Technical Advisor with Bachelor Degree without an NRC Senior Operator plant experience is adequate to assure License, Sect

• 1 3).

The Shift Technical that actions performed by individuals Advisors will >bserve control manipulations under his supervision are both on the simul. tor as appropriate.

technically correct and consistent with approved prograns and procedures.

For alternative: ANSI section 4.3.2

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(draft 12/79): The perforning of control nanipulations is not considered a Shift Technical Advisnr task.

The primary objective of Shift Technical Advisor sinulator instruction is to demonstrate plant and operator response to given conditions or events, not to develop expertise in control manipulations.

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Standard, Requirement or Guide Regulatory Guide 1.26

" Quality Group Classification and Standards for Water, Steam, ani Radioactive Waste Co,tainine Components of Nuclear Power Plants." (Rmv. 3, 2/76).

The Company's Position Conf ormance Status Justification The Operational Quality Assurance Program compiles Clarification meets or exceeds The Nuclear Design Centrol Procram with this guide with the following clarification:

applicable guides and standards.

standards provides the methodology and procedures f or determining the quality The Company does not use the specific A, B, C, classification of components.

A and D level classification system set forth in specific listing of these enmponents this guide-

!!owever, the Company followed the is natntained in a document called requirements of this guide in developing the list the Q-List.

of structures, systems, and components for which the program is applicable. The specific listing of items to which the Operational Quality Assurance Program applies is described in the UFSAR for each facility, and described in more detail in the Q-List for Surry and North Anna Power Stations.

The Company also followed the requirements of this guide in developing the ASME Section XI Class I, 2 and 3 boundaries for the inse rv i ce inspection and testing program. These classes and boundaries are updated for each 10 year inspection interval.

17.2-5 June. ToPh

1' Standard Requirement or Guide I Regulatory Guide 1.29

" Seismic Design Classification" (Rev. 3, 9/78) i -

The Company's Position

.Conformance Status Justification 1-The Operational Quality ssurance Program complies.

Clarification meets or exceeds Regulatory Guide 1.29 is primarily

-with this guide with the following: clarification:

_ applicable guides and standards.

concerned with the design and con-struction phase of nuclear power 4

I See Generic Statement which prefaces this table plants. The company's clarification has been formulated to provide a j with regard.to construction related guides, i standards and instructions.

means of translating design and con-struction criteria into guidance applicable to operating nuclear power facilities.

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Standard, Requirement or Guide Inspection, and Testing of Inst rumentation Installation, 1.30

" Quality Assurance Requirements for the Regulatory Guide and Electric Equipment" (8/72). Endorses ANSI N45.2.4 - 1972.

Justification Conformance Status The Company's Position These clarifications to ANSI N45.2.4 -

Clarifications and alternatives The Operational Quality Assurance Program complies or exceed applicable guides 1972 are required to ensure that CA meet In with this guide with the following clarifications program continuity is maintained.

and standards.

actuality these clarifications have and alternatives:

been extracted from other standards See Generic Statement which prefaces this and guides and are considered more (1) table with regard to construction related guides, conservative. These clarifications standards, and instructions.

also insure that only one standard or guide is comnitted to for its (2) Section 2.1 - Planning requirements, as applicable circumstance.

will be incorpo-determined by station management, rated into maintenance and modification procedures.

(3) Section 3 - Preconstruction Verification:

(a) verification is required only for the modification (s) (b) will be implemented with the 7

clarification that " approved instruction manuals" i

interpreted to mean the manuals provided shall be by the supplier as required by the procurecent These manuals will not be reviewed and order-(c) no approved, per se, by the Company; special checks will be made by the person with-drawing a replacement part from the warehouse-equivalent controls are assured by compliance with ANSI N45.2.2 as set forth in this table; and (d) will be complied with, as determined by station management as part of the maintenance /

modification program.

17.2-7 June. 1G86

Standard, Requirement or Guide Justification Conformance Status The Company's Position Section 4 - Installation: Instructions

'mplemented by inclusion, as determined will be by station management, in the appropriate main-tenance or modification procedure for safety related items.

Standard Company maintenance practices require that care be exercised in the six areas listed whether a procedure is required or not.

Section 5.1 - Inspections: including sub-sections 5.1.1, 5.1.2, and the first sentence in 5.1.3, will be implemented as set forth in Section The 17.2.10 of the Operational QA Program.

inspection program will incorporate, as determined those items listed in these by station management, subsections. The remaining sentence in 5.1.3 is covered in equivalent detail-in the Company's to ANSI N18.7. section 5.2.6; the commitment requirements as set forth in that commitment will be implemented in addition to the requirements stated here.

i Section 5.2 - Tests: including subsections

' 5.2.1 through 5.2.3, will be implemented as set 17.2.3 and.11 of the Operational forth in Sections The test program will consider the QA Program.

elements outlined in this Section, as determined by station management, when developing test require-ments for inclusion in maintenance and modification In some cases, testing requirements may procedures.

by post-installation surveillance testing in be met Where lieu of a special post-installation test.

elements of Section 5.2 are not being met they shall l

be documented and justified.

17.2-8

. Tune. 1956

i-Standard, Requirement or Guide The Company's Position Conformance Status Justification i

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Section 6 - Post Construction Verifica-l tion: is not generally considered applicable at

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operating facilities because of the scope of work i

and the relatively short interval between instal-i lation and operation. Where considered necessary l

by station management, the elements described in this section will be used in the development and implementation of inspection and testing programs as described in Sections 17.2.3,.10, and.11 of the Operational QA Program.

Section 6.2.1 - Equipment Tests: The l

last paragraph of this section deals with tagging and labeling. The Company will comply with an alternate last paragraph which reads: "Each safety-related item of process instrumentation is identifled with a unique number. This number is j

utilizen in instrument maintenance records so

-that c*n rent calibration status, including data such as the date of the calibration and identity of the person that performed the calibration, can

'be readily determined. Such information may also be contained on tags or labels which may be attached to installed instrumentation".

Section 7 - Data Analysis and Evaluation:

will be implemented as stated herein after adding-l the clarifying phrase "when determined by station management" at the beginning of that paragraph.

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Standard, Requirement er Guide Regulatory cuide 1.33

." Quality Assurance Requirements (Operation)" (Rev. 2, 2/78)

Endorses ANSI N18.7 - 1976.

The Company's' Position Conformance Status Justification The Operational Quality Assurance Program Clarifications and alternatives These clarifications are required complies with this guide with the'following meet or exceed applicable guides to ensure that QA program conti-clarifications and alternatives:-

and standards.

nuity is maintained; i.e.,

that only one standard or~ guide is 1)' Paragraph C.3 of Regulatory Guide 1.33 (and cenmitted to for a particular

'Section 4.3.4 of ANSI: N18.7 which it

. topic.

references) will.be implemented as required by the. applicable' nuclear facility Technical Specifications which' define " Subjects Requiring Independent Review."

..2)

Paragraph C.4.a of Regulatory Guide 1.33 j

(and Section 4.5 of ANSI.N18.7 which it l.

references) will be. implemented as required

(

by the applicable nuclear facility Technical Specifications.which define the " Audit Program" to be conducted. The audit program is further defined and will be implemented 9

as required by.the commitment to ANSI W45.2.12 as stated in Table 17.2.0 of the operational quality assurance program.

3) Paragraph C.Sa of Regulatory Guide 1.33 (and

+

Section 4.4 of ANSI N18.7 which it references) will be implemented with the clarification that the Station Nuclear Safety and Operating Committee may perform this activity.

4) Paragraph C.S.d of' Regulatory Guide 1.33 1

(and Section 5.2.7.1~'of' ANSI N18.7 which it references) will be implemented by adding the clarifying phrase "When determined by 17.2-10 June, 1986 i

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Standard, Requirement or. Guide ts Conformance Status Justification The Company's Position 4

station management in front of the-fourth

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sentence' of the fif th paragraph. - For modi-fications where these requirements are not considered practicable,La review in accordance with the provisions ofl10CFR50.59 shall be conducted and documented.

5) Paragraph C.S.e of' Regulatory Guide 1.33 -

(and Section 5.2.13.4.of ANSI N18.7 which it 4-references) will be implemented subject to the same clarifications made for ANSI j

.M45.2.2 elsewhere in Table 17.2.0 of.the i

Operational QA Program.

6) Paragraph' C.S.f of ' Regulatory Guide 1.33 (and Section 5.2.19.(2) of ANSI Nf8.7'which 4

it references) will be; implemented when j.

determined by station management.

i 7) Paragraph C.S.g of' Regulatory G'uide 1.33 i

(and Section 5.2.19.1 of ANSI N18.7 which it references) will be implemented with the

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addition of the modif.ier "normally" af ter j

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each of the verbs'(should) which the.

Regulatory Guide converts to "shall."

It is the Company's intent to fully comply with the requirements of this paragraph, _rd any l

l conditions which do not fully comply will be documented and approved Ey itation : -

ement 3

l personnel.. In these caser. the ren or the

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exception shall also be documen eu e

l-documentation shall be retained for n: same i

j period of time.as the affected preoperational l-test.

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i The Company's Position

Conformance ' Status Justification f

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8) With regard to Section 4.2-of ANSI N18.7 -

1976Property "ANSI code" (as page type) with input value "ANSI N18.7 -</br></br>1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Program

Description:

.Two aspects are addressed in this Section: audits and independent reviews.. The independent review program is implemented as required by the-Technical Specifications of the individual nuclear 1 facility. ?The Company audit program will be described in accordance with and to meet the requirements of ANSI N45.2.12 as endorsed in' Table 17.2.0 of the Operational QA Program, the requirements of the individual nuclear facility Technical Specifications, and Sections'17.2.16'and 17.2.18 of the Operational QA Program.

L9) With regard to Section 4.3 of ANSI N18.7 -

1976Property "ANSI code" (as page type) with input value "ANSI N18.7 -</br></br>1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Independent Review Process: The requirements.of this Section, including all of ita subparts, shall be' met by compliance with the Technical Specification require-ments of the individual nuclear facility.

10) With regard.to Section 5.2.7 of ANSI N18.7 -

1976Property "ANSI code" (as page type) with input value "ANSI N18.7 -</br></br>1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Maintenance and Modification:

Since some emergency situations could arise which might preclude preplanning of all activities, the Company will comply with-an alternate to the first sentence in the second paragraph which reads: "Except in emergency or abnormal operating conditions where immediate actions are required to protect the health and safety of the public,-

to protect equipment or personnel or to prevent.the deterioration of plant condi -

tions to a possibly unsafe or unstable level, maintenance.or modification of equipment 17.2-12 Jtm e, 1986

Standard, Ecquirement or Guide Justification Conformance Status The Company's Position shall be preplanned and performed in Where accordance with written procedures.

written procedures would be required and are not used, the activities that were accomplished shall be documented after-the-and receive the same degree of review fact as if they had been preplanned."

11) With regard to Section 5.2.7.1 of ANSI N18.7 - 1976 titled Maintenance Programs:

The Company will comply with the require-ments of the first sentence of the fifth paragraph, when determined by station manage-This clarification is needed since it ment.

is not always possible to promptly determine the cause of the malfunction.

In all cases, The Company will initiate proceedings to determine the cause, and will make such determinations promptly, when determined by station management.

12) With regard to Section 5.2.8 of ANSI N18.7 -

1976Property "ANSI code" (as page type) with input value "ANSI N18.7 -</br></br>1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Surveillance Testing and Inspection Schedule:

In lieu of a " master surveillance schedule," the following requirement shall be complied with:

"A surveillance testing schedule (s) shall be all established reflecting the status et in-plant surveillance tests and inspections."

13) With regard to Section 5.2.13.1 of ANSI N18.7 - 1976 titled Procurement Document Control: The words "the same degree of control" in the last sentence are replaced 17.2-I3 with " Engineering review."

.f une, 1986

Standard, Requirement or Guide The Company's Position Conformance Status Justification

14) With regard to Sectinn 5.2.15 of ANSI N18.7 -

The biennial review require ent is deleted.

1976 titled Review. Approval and Control of The procedures upgrade progran provides a e

Procedures: The third sentence in paracraph systematic and effective process for three is interpreted to mean: Applicable de eloping and revising procedures which procedures, as determined by Station Manage-encoepasses the intent of the biennial I

ment, shall be re~iewed following an accident, review. Periodic reviews will still be j

an utraxpected transient, significant operator conducted by extending the period to up to error or equipment malfunction.

four years in accordance with administrative l

procedures. See North Anna sa ety l

f The first sentence of the fourth paragraph is evaluation 91-SE-0T-028 Revision I and considered to be met via periodic reviews as Surry safety evaluation 91-128.

described by administrative procedures

13) With regard to Section 5.2.17 of ANSI NIB.7 -

1976 titled Inspections: Not all inspections will regoire generation of a separate inspec-tion report.

Inspection requirements may be integrated into appropriate procedures or other documents with the procedure or document se rving as the record. However, records of inspections will be identifiable and retrieve-able.

16) with regard to Section 5.3.9 of ANSI NIR.7 -

1976 titled Emergency Procedure: As directed by the NRC, the dompany follows a format j

for energency procedures which is " symptom" based as opposed to " event" based as stipulated in Section 5.3.9.1.

Since the Ceepany has these " symptom" based procedures; " event" based procedures are not norma"ly provided.

17.2-14 June. 1986 l

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The Company's Position Conformance Status.

Justification l

17) With regard'to Section 5.3.9.2 of ANSI N18.7 -

.1976 titled. Events of' Potential Emergency:

j The Company'will interpret item (11) to mean.

j' the natural occurrences which have been evaluated.in the UFSAR for. the individual j.

nuclear. facility.

18) With regard to Section 5.3.9.3 of ANSI N18.7 -

1976Property "ANSI code" (as page type) with input value "ANSI N18.7 -</br></br>1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Procedures for Implementing i.

Emergency Plan: The Company's NRC accepted Emergency. Plan for each nuclear facility will be implemented in lieu of the requirements in L

this Section.

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!"RRC Reaulatory Guide 'I.37

" Quality Assurance Requirements for Cleaning of Fluid Systems ' and Associated Components of Water-

Cooled. Nuclear Power Plants" (3/73) - Endorses ANSI N45.2.1 - 1973.

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The Company's Position Canformance Status Justification i

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s The Operational Quality Assurance Program

' Clarifications meet or exceed The four clarifications listed complies with this guide with the following' applicable guides and standards.

were generated to translate clarifications:

general guidance into exact commitments, and to provide j

alternate ocans to perform 4

,; 1). The-guide and standard are applicable to i-those areas of the Quality Assurance. Program routine tasks.

-addressing on-site cleaning of materials and components, cleanness' control, and preopera-

. tion cleaning and layup of fluid systems.

I; 2) With regard to Paragraph C.3 of Regulatory Guide 1.37: The water quality for final l

flushing of fluid systems and associated I

components shall be at least equivalent to the quality of the operating system water except for the oxygen and nitrogen content;

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but this does not infer that chromates or i

other additives, normally in the system l

water, will be added to.the flush water.

- 3) With regard to Paragraph C.4 of Regulatory Guide 1.37: Expendable materials such as l

inks and related products, temperature indicating stick, tapes, gummed labels, wrapping materials -(other than polyethylene),

l-water soluble dam materials, lubricants, NDE

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i penetrant materials and'couplants,. desiccants, and like materials which contact stainless.

steel or nickel. alloy. surfaces; shall not contain lead,- zinc, copper. mercury, cadm.ium and other low melting point metals,'their

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17.2-16 June. 1986 1

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. Standard, Requirement or Guide t

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The Company's Position Conformance Status Justification 3

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' alloys or compounds as basic and essential chemical constituents. No more than 0.1 per-

?.

cent (1,000 ppm) halogens vill be allowed I

where'such elements are leachable or where they could be released by breakdown of the.

compounds under expected environmental conditions.

) 4)' With' regard to Section 5 of ANSI N45.2.1 -

1973Property "ANSI code" (as page type) with input value "ANSI N45.2.1 -</br></br>1973" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Installation Cleaning:- The l

recommendation that local rusting on corrosion i

resistant alloys be removed by mechanical I.

methods is interpreted to mean that local l

rusting may be removed mechanically, but the use of other. removal means is not precluded l

as determined by Engineering.

t i

5 e

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17.2-17 l

June. 1986 c.,.

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4 4

F Standard, Requirement or Guide i

i

,~NRC'Regulatorv Guide 1.38

" Quality Assurance Requirements for Packaging. Shipping. Receiving Storage, and Handling of Items.for Water-Cooled Nuclear Power Plants" (Rev. 2, 5/77) - Endorses ANSI N45.2.2 - 1972.

1 l

The Company's Position' Conformance Status Justification i

~

Clarifications and alternatives The clarifications in this section l;The operational quality assurance program complies j with this guide with the following c1&rifications meet or exceed applicable guides.

are proposed only to translate j and alternatives:

and standards.

general guidance into specific requirements.

1) _Hith. regard to Section 2.1 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Planning:

(First sentence.).The The proposed alternatives are j.

specific items to be governed by the Standard provided to reflect current l

shall be identified in Administrative Procedures.

Company practices which are

. distilled f rom over ten years of I'

experience gained at operational nuclear facilities.

2). With regard to Section 2.3 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Results: The specific methods for performing and documenting tests and inspec-tions are given in Sections 17.2.10 and 17.2.11

?

of the Operational QA Program. The require--

ments in these Sections vill be implemented in lieu'of the general requirements here.

4; 3) With regard to Section 2.7 of ANSI N45.2.7 -

1Property "ANSI code" (as page type) with input value "ANSI N45.2.7 -</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 1972 titled Clarification of Items: The l

Company may choose not to explicitly use the l

four level classification system. However, j

,the specific requirements of the Standard i

that are appropriate to each class are j

applied to the items suggested in each class-i ification and to similar items as determined by station management.

4) With regard to Section 3.2.1 of' ANSI N45.2.2 -

1976Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Level A Items: As an alternate to rehe requirements for' packaging and container.

[

]

izing items in storage to control contaminants 17.2-18 l

[

(Items (4) and (5)), the Company may chocse June. 1986

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e i

4 1

) ^

Standard, Requirement or Cuide i

4 l

The Company's Position-

'Conformance Status Justification L

a storage. atmosphere which is free of harm-ful contaminants in concentrations that could

[

produce damage to stored items as determined j

by station management. Similarly (for Item (7))

the. Company may obviate the need for caps j

and plugs, as determined by station management.

l with an appropriate storage atmosphere, and may j

choose to protect veld-end preparations and

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threads.by controlling the manner in which j

the items are stored. =These clarifications l

apply wheneveriitems (4),-(5) or (7) are j'

subsequently referenced and to Section 3.5.1 l

titled Caps and Plugs and Section 3.4 titled j-Methods of Preservation.

l

' '5)

With ' regard to Section 3.2.3 of ANSI N45.2.2

[

1972 titled Level C Items:

(Subpart 2) states

" Items'shall be packaged with a waterproof enclosure...." as an alternative, the company may choose appropriate packaging when

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the storage environment prevents harmful _.

I contaminants in concentrations that could l

produce damage. to : stored items as determined by Station egmt.

l

6) With regard to Section 3.3 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Cleaning:

(Third sentence) the Company interprets " documented cleaning methods" to allow generic cleaning procedures to be written which are implemented, as neces-sary, by trained personnel.

Each particular

[

cleaning operation shall have an individual l'

> cleaning procedure or reference a generic pro-cedure. The generic procedures will specify methods of cleaning or.which type (s) of solvent may be used'in a particular applica-17.2-19 tion.

June, 1986 O'ndated t /on)

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i

}.

Standard, Requirement or Guide 4

I~

Justification i

Conformance Status The Company's Position I J 7) : With regard'to Section 3.4 of ANSI N45.2.2.-

~

j 1972 titled Methods of Preservation:

(First i-sentence) the Company vill comply vith

.these requirements subject to the clarifica-

-tions of Section 3.2.1, (4) and (5) above,

. and the definition of the phrase " deleterious

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corrosion" to mean that corrosion which cannot be subsequently removed and which adversely

~

'affects form, fit or function.

8) With regard to Section.3.6 of ANSI N45.2.2 -

4Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 1972 titled Barrier and Wrap Material and i

1 Desiccants: This section requires the use of F

nonhalogenated materials in contact with austenitic stainless. steel. JRefer to Regula-tory Guide 1.37 above for.the Company position.

4 9). With regard to Section 3.7.1 of ANSI,N45.2.2 -

1972 titled Containers:. CIeated, sheathed boxes may be used up to 1,000 lbs. rather.than

[

500 lbs. as specified in 3.7.1(1).

This type of box is safe for, and has been tested for, loads up to 1,000 lbs.- Other national standards allow this (see Federal: Specification PPP-B-601). Special qualifications testing shall be I

required for loads above 1,000 lbs.

10) With regard to Section 3.7.2.of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Crates and Skids:= Skids or runners will normally be used on containers with a-I gross weight of 100 lbs. or more.

Skids or runner will normally be fabricated from 4 x 4 inch nominal-lumber size, minimum, and laid j

flat except where this is impractical because i

of the small dimensions of the container.

If 4

forklift handling is required, minimum floor-17.2-20 i

clearance for forklift tines will be provided.

June. 19M6

. ~.

4 J

Standard, Requirement or Guide i

i t-Conformance Status.

Justification l

The' Company's Position i

s j '11)'With regard to Sections 4.3, 4.4 and 4.5 of

~ ANSI N45.2.2 - 1972. titled, respectively, 4

l Precautions During Loading and Transit, Identification and Marking, and Shipment from Countries Outside the United States:

the Company will comply with the require-ments of these Sections subject to the J-clarifications taken to other Sections which are referenced herein.

1 l 12) With regard to Section 5.2.1 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Shipping Damage Inspection:

l Warehouse personnel will normally visually scrutinize incoming shipments for damage of 4-I the types listed in this Section; this activity is not necessarily_ performed prior

]

to unloading. Since all required items receive the Item Inspection of Section 5.2.2, separate documentation of the Shipping Damage Inspection is not necessary. Release of the

~

transport-agent af ter unloading and signing.

j for receipt of the shipment may be all of the action taken to document completion of the 3

i Shipping Damage Inspection. Any nonconform-f ance noted will be documented nnd disposi-b tiened as required by Section 17.2.15 of the Operational QA Program.

i The person performing the visual scrutiny during unloading is not considered to be per-forming an inspection function as defined under' Regulatory Guide 1.74; therefore, while he will be trained to perform this function he may not necessarily be certified (N45.2.6)-

as an Inspector.

17.2-21 June, 1986

.._..,_..,c

Standard, Requirement or Guide Justification Conformance Status The Company's Position

13) With regard to Section 5.2.2 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Item Inspection: The second l

division of this subsection requires six additional inspection activities if an item was not inspected or examined at the source.

Procurement Engineering shall determine and document the extent of receipt inspection based on consideration of Paragraph 5.2.2.

14) With regard to Section 5.4 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Status Indicating System:

The Section states in part " Tags shall be securely affixed to the items and displayed in an area that is readily accessible." As an alternative, the company may choose to use Labels or Tags to identify itens.

15) With regard to Section 6.1.2 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Levels of Storage: Subpart (2) is replaced with the following:

(2) Level B items shall be stored within a fire resistant, weather-tight, and weII ventilated building or equivalent en-closure in which measures have been taken against vandalism. This building shall be situated and constructed so that it will not normally be subject to flooding; the floor shall be paved or equal, and well drained.

If any outside waters should come in contact with stored equipment, such equipment will be labeled or tagged nonconforming, and then the conconformance document will be processed and evaluated in accordance with Section 17.2-22 June, 1986 l

Standard, Requirement or Guide Justification Conformance Status The Company's Position l

I 1

17.2.15.

Items shall be placed on pillets, shoring or shelves to permit air ci ;ula-tion.

The building shall be provided with uniform heating and temperature control or its equivalent to prevent condensation and corrosion. Minimum temperature shall be 40*F and maximum temperature shall be 140*F I

or less if so stipulated by a manufacturer.

16) With regard to Section 6.2.1 of ANSI N45.2.2 -

Items 1972 titled Access to Storage Areas:

which fall within the Level D classification of the standard will be stored in an area which may be posted to Ifmit access, but other positive controls such as fencing or guards will not normally be provided.

17) With regard to Section 6.2.4 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Storage of Food and Associated The sentence is replaced with the Items:

following:

"The use or storage of food, drinks and salt tablet dispensers In any storage area shall be controIIed and shall be limited to designated areas where such use or storage is not deleterious to stored items where station management deems appropriate.

18) With regard to Section 6.2.5 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Measures to Prevent Entrance of Animals: The sentence is replaced with the

" Exterminators or other appropri-following:

ate measures shall be used to control animals to minimize possible contamination and mechanical damage to stored material."

17.2-23 June. 1986

I Standard, Requirement or Guide i'

i' The Company's Position Conformance Status.

Justification 3

4 f.19) With regard to Section 6.3.4 of ANSI N45.2.2 --

. titled Identification: The section states "All items and their containers shall be plainly i

marked so1that they are easily identified

}

without excessive handling or unnecessary opening of crates and boxes."

The company shall substitute "All item 3.(or, if in containers, their containers) l shall be plainly marked so that they are easily l

identified without excessive handling or unnecessary opening of crates and_ boxes."

20) With regard to Section 6.4.2 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Care of. Items: The following I'

alternatives are provided for the indicated subpart:

(5) " Space heaters in electrical equipment l

shall be energized unless a documented engineering evaluation determines that j

such. space heaters are not required."

j (6) "Large (greater than or equal to 50HP) rotating electrical. equipment shall be.

given insulation resistance. tests on a scheduled basis unless a documented engineering evaluation determines that.

l such tests are not required."'

j (7) Within thirty days of having been placed in storage, rotating equipment weighing

~

over approximately 50 pounds shall be i

evaluated by-engineering personnel to determine.if shaft rotation in storage.

17.2-24 is required: The results of the evalua-tion shall be documented. If rotation June. 1986 l

i Standard, Requirement or Guide.

Conformance Status Justification i.

j.

The Company's Position-i

)

is required, it shall be performed at specific intervals, be documented, and i

j be conducted so that parts receive'a coating of lubrication where applicable and so that the shaft does not come to j

. rest in the same position occupied prior 1to rotation. For long shaf ts or heavy

. equipment subject to undesirable' bowing, shaft orientation af ter rotation shall be'specified and obtained.

j21)WithregardtoSection6.5ofANSIN45.2.2-1 1972 titled Removal of Items from Storage:

The Company does not consider the last j

sentence of this ' etion to be applicable to the operations phase due to the relatively short-period of time between installation and use.

The first sentence of the Section is replaced with:

"the Company will develop, issue, and implement a procedure (s) which i

cover (s) the removal of items from storage.

The procedure (s) will assure'that the inspection ststus of all material issued i

is known, controlled and apprapriately dispositioned."

22) With regard to Section 6.6 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Storage Records:

The. Company

]

will comply with the. requirements of this j

Section with the clarification that, for record purposes, only the access of personne1' not specifically authorized such by station I-management into indoor storage areas shall be recorded. Unioading-or/ pick-up of material

,[

shall not be considered " access," nor shall inspection by QA/QC personnel, authorized 1 7.2-25 i

contractors, NRC or.other regulatory agents,.

June, 1986 l

nor shall_ tours:by.non-employees who are L

-aar hv enmnnnv emninvees.

=...

Standard, Requirement or Guide Justification Conformance Status The Company's Position

23) With regard to Section 7.3 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Hoisting Equipment:

Rerating of hoisting equipment will be considered only when absolutely necessary. Prior to perform-ing any lift above the load rating, the equipment manufacturer must be contacted for his approval and direction. The manufacturer must be requested to supply a document grant-ing approval for a limited number of lifts at i

the new rating and any restrictions involved, such as modifications to be made to the i

f equipment, the number lifts to be made at the new rating, and the test lift load. At all times, the codes governing rerating of hoisting equipment must be observed.

If rerating hoisting equipment is necessary and the Company cannot or aoes not contact the equipment manufacturer as described above, the test weight used in temporarily rerating hoisting equipment for special lifts will be least equal to 110% of the lift weight.

atA dynamic load test over the full range of the lift using a weight at least equal to the lift weight shall be performed.

24) With regard to Section A3.9 of ANSI N45.2.2 -

1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Marking:

As an alternative to the requirements in Subpart 4, the Company may choose to mark containers with waterproof ink Additionally, or paint with legible characters.

the requirements of Subpart 6 shall only apply to shipment of items.

Items in storage shall 17.2-26 be affixed with labels or tags with sufficient June, 1956 information to preserve the item's identity.

Standard, Requirement or Guide 2, 9/77) - Endorses ANSI N45.2.3 NRC Regulatory Guide 1.39

" Housekeeping Requirements for Water-Cooled Power Plants" (Fev.

- 1973.

Justification Conformance Statut The Company's Position These clarifications are proposed Clarifications meet or exceed The Operational Quality Assurance program complies applicable guides and standards.

to perform a twofold function.

with this guide with the following clarifications:

A) To translate construction criteria to operating See Generic Statement which prefaces this plant oriented table.

requirements.

1) Additional clarifications for ANSI B) To reflect experience N45.2.3 - 1973 are indicated belov for gained at operational specific Sections.

nuclear facilities.

Section 2.1 Planning: The Company It shoulv

- ea that where l

may choose not to utilize the five-level the Compai.

_es not specifi-l zone designation system, but will utilize cs'_ly implement requirements as standard janitorial and work practices delineated herein, the proposed to maintain a level of cleanliness as alternatives are reflected in delineated in the Company's Accident written procedures and policy and c

jl-Prevention Manual which is equivalent to contain all necessary elements to the requirements contained in the assure quality is naintained.

3 referenced section.

[.

1:

Cleanliness will be maintained, consistent I!

with the work being performed, so as to prevent the entry of foreign material into e

safety-related systems. This will include, as a minimum, documented cleanliness inspections which will be performed prior to system closure.

As determined by station management, (e.g.,

ntry of the size of the opening would permit e

the tools being used) control of personnel, 17.2-27 June, 1986

y l

' Standard, Requirement or= Guide The Company's Position

'Conformance Status Justification tools, equipment, and supplies will be established when the reactor system is opened for inspection, maintenance or repair.

Additional housekeeping requirements will be implemented as required for control of radioactive contamination.

Section 2.2 Procedures'and Instructions:

Appropriate procedures will be written and implemented.

Section 3.2 - Control of Facilities:

The Company may choose not to utilize the five-level zone designation system, but will utilize'the Com'pany's Accident Prevention Manual policies and procedures to maintain a level of cleanliness commensurate with the requirements of this section.

Cleanliness will be maintained, consistent with the work being. performed, so as to prevent the entry of foreign material into safety-related systems. This will include, as a minimum,' documented cleanli-i ness inspections which will be performed prior to system-closure. As necessary, (e.g., the. size of the opening would l

permit entry of the tools being'used) control of personnel, tools equipment, and supplies will be' established when major portions of the reactor system are opened.for inspection, maintenance or 17.2-28 repair.

June, 1986

Standard, Requirement or Guide Justification Conf ormance Status The Company's Position Additional. housekeeping requirements will be implemented as required for control of radioactive contamination.

See Section 3.3 - Materials and Equipment:

Generic Statement which prtfaces this table.

Section 3.4 - Construction Tools, Supplies See Generic Stctement which and Equipment:

prefaces this table.

Section 3.5 - Surve111ance, Inspections and Examination; Subparagraph (1) See Generic Statemeiit which prefaces this table.

I 1

17.2-29 June, 1086

(

Scandcrd, Requirement or Guide NRC Regulatory Guide 1.58 - Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel" (Rev. 1, 9/80) - Endorses ANSI N45.2.6 - 19?8.

The Company's' Position Conformance Status Justification The Operational QA Program complies with this Clarifications meet or exceed The proposed clarifications guide with the following clarifications:

applicable guides and standards.

reflect Company practices and are provided here to assure

1) With regard to Section 1.2'of ANSI N45.2.6 -

that QA program continuity with 1978 titled Applicability: The third other delineated standards and paragraph requires that the Standard be useo guides is maintained.

in conjunction with ANSI N45.2; the Company no longer specifically commits to ANSI N45.2

.in the Operational QA Program..The fourth paragraph requires that the Standard be imposed on personnel other than Company employees; the applicability of the Standard to suppliers will be documented and applied, as appropriate, in the procurement documents for such suppliers.

~

2) With regard to Section 1.4 of ANSI N45.2.6 -

1978Property "ANSI code" (as page type) with input value "ANSI N45.2.6 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Definitions: Definitions in,this Reg. Guide 1.58 which are not included in ANSI N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in the Company's' commitment to Regulatory Guide 1.74.

3) With regard to Section 2.5 of ANSI N45.2.6 -

1978Property "ANSI code" (as page type) with input value "ANSI N45.2.6 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Physical: The Company will.

implement the requirements of.this Section with the stipulation that, where no.special physical characteristics are required, none will be specified. The converse is also true:

If no special physical requirements are stipulated by the Company, none are con-sidered necessary.

17.2-30 June, 1986

Standard, Requirement or Guide Justification Conformance Status The Company's Position

4) With regard to Section 3.1 of ANSI N45.2.6 -

1978Property "ANSI code" (as page type) with input value "ANSI N45.2.6 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled General: The Company will implement the requirements of this Section with the stipulation that, Level III inspectors are not a specific requirement of the Company's inspection program.

l I

l l

l 1

17.2-30a June, 1986

l Standard, Requirement or Guide for the Design of Nuclear Power Plants" (Rev. 2, 6/76) -

NRC Regulatory Guide 1.64

" Quality Assurance Requirements Endorses ANSI M45.2.ll - 1974.

Justification Conformance Status The Company's Position Clarification meets or exceeds Clarification is considered an The Operational Quality Assurance Program complies with this guide with the following clarification:

applicable guides and standards.

acceptable alternative to that proposed in the referenced standard in that all quality See Generic Statement which prefaces this table.

elements have been maintained.

1) With regard to Paragraph C.2(1) of Regulatory Guide 1.64:

If in an exceptional circumstance the designer's immediate Supervisor is the only technically qualified individual available, this review may be conducted by the Supervisor, providing that:

(a) the other provisions of the Regulatory Guide are satisfied, and (b) the justification is individually documented and approved in advance by the Supervisor's management, and (c) quality assurance audits cover frequency and effectiveness of use of Supervisors as design verifiers to guard against abuse.

17.2-31 June, 1986 l

Standard,-Requirement or Guide NRC Regulatory Guide 1.74

" Quality Assurance Terms and Definitions" (2/74)f-Endorses ANSI N45.2.10 - 1973.

The Company's Position-Conformance Status Justitication-The Operational Quality Assurance Program complies-Clarification meets or exceeds The clarifications illuminate

~

with this guide with the following clarification:

applicable guides-and-standards.

actual Company QA program practices and are considered to 1)- The Company' reserves the right to define enhance the Company's commitment additional words or phrases which are not to quality practices.

includedJin this Standard.

Such additional definitions will be documented in appropriate procedures and/or in attachments / appendices to a quality assurance procedures manual or.in sections of the Operational QA Program.

2)' The Company intends for inspections and tests to be performed in accordance with the Operational QA Program by personnel certified as required-by that program and for detivities defined by

" Inspection" and " Testing" in ANSI N45.2.10.

Appropriate references to the organization which will perform the activity or quality procedures

-to be used for performing the activity will be made.

If such references are NOT made, inspections or tests are to be considered under the following definition:

" Inspection" (when used to refer to activi-ties that are NOT performed by certified personnel) - Examining.. viewing closely, scrutinizing, looking over or otherwise checking activities. Personne1' performing these-functions are_not necessarily certified to ANSI N45.2.6.

However, station management through prior procedure review shall determine the appropriate personnel qualifications and reporting relationships.

17.2-32 June, 1986 t

Standard, Requirement or Guide NRC Regulatory Guide 1.74

" Quality Assurance Terms and Definitions" (2/74) - Endorses ANSI N45.2.10 - 1973.

The Company's Position Conformance Status Justification

" Testing" (when used to refer to activities that are not performed by certified personnel) - completion of predetermined procedure steps which determine or verify the capability of an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions. Personnel performing these steps may not necessarily be certified to ANSI N45.2.6.

If the completion of the procedural steps utilizes skills and knowledge which they have already obtained from applicable training and' experience based programs or formal education programs.

Station management through prior procedure review shall determine the appropriate personnel qualifications and reporting relationships.

17.2-32a June, 1986

I' Standard, Requirement or Guide Justification Conformance Status The Company's Position 1

l In addition to the' Standard's definition of l

3) documents," The Company will

" procurement utilize the definitions given in ANSI N45.2.13

]

j and in Regulatory Guide 1.74.

The compound l

definition is given as follows: Procurement documents - Contractually binding documents that identify and define the requirements in order which items or services must meet to be considered acceptable by the purchaser.

They include documents which authorize the seller to perform services or supply equip-material or facilities on behalf of

ment, letters of the purchaser (e.g., contracts, intent, work orders, purchase orders or proposals and their acceptance, drawings, electronic procurement system documents, specifications or instructions which define requirements for purchase).

4) " Program Deficiencies" (Not defined in ANSI N45.2.10, but used and defined differently in ANSI N45.2.12) - Failure to develop, document or implement effectively any applicable element of the Operational QA Program.

" Quality Assurance Program Requirements" 5)

(Not defined in ANSI N45.2.10 but used and defined differently in ANSI N45.2.13) - Those individual requirements of the Operational QA Program which, when invoked in total or in establish the requirements of the

part, quality assurance program for the activity being controlled. Although not specially used in the Operational QA Program, ANSI I7.2-33 N45.2 may be imposed upon the Company's June, 1986 suppliers.

Standard, Requirement or Guide Justification Conformance Status The Company's Position

6) With the exception of the time intervals defined by the station Technical Speciff-cations, the following definitions shall be applied when defining time intervals for other activities:

Weekly: at least once per 7 days Monthly: at least once per 31 days l

at least once Quarterly or every 3 acgil g:

per 92 days at least Semiannually or every 6 months:

once per 184 days Every 9 months:

at least once per 276 days Yearly or annually: at least once per 366 days Biennial (2 years): at least once per 732 days Triennial (3 yeari): at least once per 1098 days The above time intervals may be extended by up 17.2-33a fone. -986 to 25%.

(UjJs:ed 4/88)

l Standard, Requirement or Guide f

NRC Regulatory Guide 1.88 -'" Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records" (Rev. 2, l

10/76 - Endorses ANSI N45.2.9'- 1974).

The' Company's Position Conformance Sta'ns Justification The Operational Quality Assurance Program complies Clarifications and alternatives These proposals are the results with this guide with the'following clarifications meet or exceed. applicable guides of experience gained at operating and alternatives:

and standards.

nuclear facilities for over a decade. As with all guides and standards, additional clarity is

1) With regard to Section 3.2.2 of ANSI N45.2.9 -

1974Property "ANSI code" (as page type) with input value "ANSI N45.2.9 -</br></br>1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Index: The phrase'"an index" is sometimes required. Further the alternative (6) presented herein clarified to mean a collection of documents or reflects the "as-built" condition i

indices which,-when taken together, supply the information attributed to "an index" in the of the Company's records storage facilities. These facilities standard.

were constructed prior to any The specific location of a record."within a regulatcry position being defined, and, at the time of construction, storage area" may not be delineated (e.g.,

were' considered more than adequ-The specific location within a computer record file may not be constant.

Further, the Company ate to assure permanent records retention. The discrepancies may utilize a computer assisted random access-filing system where such location could not be which might exist between current readily " documented", nor would such a location guides and standards and "as-built" conditions are more than be " relevant"). The storage location will be delineated, but where file locations change compensated for by other more within time, the specific location of a record stringent measures such as, within that file may not always be documented.

a) constant surveillance of the

2) With regard to Section 4.2 of ANSI N45.2.9 -

facility both by monitoring 1974 titled Timeliness: The Company's con-devices, security patrols, and fire inspections, and tractural agreement with its contractors and suppliers will constitute fulfillment of the b)

Permanently installed requirements of this Section.

dedicated fire suppression apparatus.

'17.2-34 June, 1986

l l

Standard, Requirement or Guide The Company's Position-Conformance Status

' Justification

- 3) With regard to Section 5.4 of. ANSI N45.2.9 -

1974Property "ANSI code" (as page type) with input value "ANSI N45.2.9 -</br></br>1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Preservation: The following clarification is substituted'for the current subsection 5.4.2: '" Records'shall' be stored in enclosed containers, cabinets or other compar-able document storage. hardware".

17.2-35 June, 1986

e 4

' Standard, Requirement or Guide.

The Company's Position' Conformance Status Justification

~

a The following clarification is substituted for the current subsection 5.4.3 " Provisions shall be made for special processed records (such as radiographs, photographs, negatives, j.

microfilm and magnetic media) to prevent damage as appropriate to the record type and will i

i address the manufacturer's recommendations."

i 4) With regard to Section 5.5 of ANSI N45.2.9 -

t 1974 titled Safekeeping: Routine general office and nuclear site security systems and access controls are provided.

5) With regard to Section 5.6 of ANSI N45.2.9 -

1974Property "ANSI code" (as page type) with input value "ANSI N45.2.9 -</br></br>1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Facility: - Records'shall be for--

warded to the appropriate records storage facility promptly after completion when-required processing and reviews'have been completed.

Paragraph 4, subsection 3 is clarified to require a two-hour. minimum fire rating to be i

consistent with the 1979 version of the Standard and NRC Criteria for Record Storage i

Facilities.(Cuidance - ANSI N45.2.9 Section 5.6) issued 7/15/79.

i Paragraph 4, subsection 9 is clarified to read:

"No pipes or penetrations except those providing fire protection, lighting, temperature / humidity control, or communica-tions are to be located within the facility i

and they shall comply with a minimum two-hour fire protection rating.

i 17.2.

i June, 1986 i

(Updated 4/88)

F i

Standard, Requirement.or Guide The Company's Position Conformance' Status Justification t

6) The Surry Power Station facility conforms to ANSI N45.2.9 -'1974 as clarified in this Table except that it is rated at approximately.2

[

hours; concrete floor has no slope; doors, frames, and hardware are three-hour rated; forced-air ducting is not equipped with auto-1 matic fire stops; conduit and wiring exist for interior' lighting security alarms, and fire protection. 'This facility is considered to meet the intent of ANSI N45.2.9 and pro-vides adequate protection for records.

?

The North Anna Power Station Records Vault meets

[

the intent of Chapter 3 of NFPA No. 232-1975, subject to the following prcvisions:

a) The file room is constructed with a minimum fire rating of two (2) hours.

't b) Heating, cooling and ventilation for the file room is by means of a forced air system, with all fans, filters, and heat-ing and cooling elements located in an equipment room which is external to the:

file room. Ducts for this system ar-r located on the ceiling of the file room and are provided with the standard door dampers with a minimum rating of two (2) l s

hours where they penetrate the file room barrier to other areas of the building.

c) The file room is provided with an'early warning fire detection system and auto-matic fire suppression system. A protective I

(

17.2

• June,.1986 i

i

1 r

. Standard, Requirement or' Guide 4

5

.The Company's Position' Conformance Status

-Justification signaling system is provided, with a remote' alarm located at a constantly-attended station.

d) Telephone service is provided to the i

file room, with"the wire-penetration

~

j constructed and sealed in accordance with NFPA No.- 232-1975..

i e) All records stored in the file room are stored in metal' cabinets, which are arranged to provide adequate access and aisleways. Work _not directly related to the storage, retrieval or auditing of records is not allowed in the file. room.

4

~

. Smoking, eating, and drinking is pro-hibited in the file room.

f) A wall' divides the file room into two sections,'with one'section used as a' file room and the other section used'for micro-filming of records. The dividing wall has a minimum fire rating of two (2) hours, including the fire door ' dampers in the duct penetrating the wall.

The North Anna Power Station Training Center: (ault meets the intent of Chapter 3rof NFPA No. 232-1975, subject to the following provisions:

a) The file room is constructed with a

-minimum fire rating of two (2) hours'.

17.2-38 June, 1986 (Updated 4/90).

s'*l'

'"'e u

---

a

---

L-:----u.1.---.-

Standard, Requirement or Guide :

1 The Company's. Position Conformance Status Justificatien j

i.

b) 11 eating,; cooling and ventilation. for the file room is1by means of a. forced air system, with all1 fans, filters, and heating and cooling elements located in an equip-ment room which is external to the file room. Ducts for this syttem'are located above the ceiling of.the file room and are provided with' accordion dampers'with

~

.a minimum rating of two (2)? hours where they penetrate the. file. room barrier to other areas of'thel building.

~

s c) The file room is provided with an early

_ warning fire detection' system and auto -

'matic fire' suppression system. A protective signaling systemiis provided,

.with a remote alarm located at a constantly attended station.

d) Telephone service.is.provided'to the-file room, with the wire penetration constructed and sealed in accordance-with NFPA No. 232-1975.

e) All records stored in'the' file room ~are stored in meta 1' cabinets, which are" arranged to provide' adequate' access and aisleways..' Work not directly related to the storage, retrieval or auditing of records is not allowed in the file room.

17.2-38a Smoking, eating,'and drinking:is: pro-June, 1986 hibited 'in the ' file xxxnn.

(Updated 4/90) 1 T F

Standard, Requirement or Guide The Company's Position Conformance Status Justification The Innsbrook Technical Center's Vital Records Vault for nuclear records conforms to the requirements of Section 5.6 of ANSI N45.2.9-1974 without exceptions.

The Surry Traini.'g Center training records vault (Main Building) conforms to the requireeents of section 5.6 ANSI N45.2.9-1974 without exceptions.

The Surry Training Center' training records vault (Simulator Building) conforms to the requirements of section 5.6 ANSI N45.2.9-1974 with the following exceptions:

a) The door is a UL-rated three-hour fire door.

b) The records storage vault is constructed with a minimum fire rating of two (2) hours.

17.2-38b June, 1986 (Updated 4/88)

Standard, Requirement or Guide NRC Regulatory Guide 1.94 "Qur'ity Assurance Requirements for Installation, Inspection, and Test f rg o f st ructural Concrete and Structural Steel during the.onstruction Phase of !!uclear Power Plants" (Rev.

1, 4/76) - Endorses ANSI 545.2.5 - 1974 The Company's Position Confernance Status Justification The Operational cuality Assurance Program complies Clarification meets or exceeds The proposed clarification is used with this guide with the following clarification:

applicable guides and standards.

to translate construction oriented documents to cperational regulations.

See Generic Statenent which prefaces this table.

1) With regard to Section 2.5.1 of ANSI N45.2.5

- 1974Property "ANSI code" (as page type) with input value "ANSI N45.2.5</br></br>- 1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Selection: The Company cocplies with the requirement set forth in the first paragraph of this Section for selection of measuring and test equipment on the basis of sufficient accuracy to determine conformance to the standard's requirements:

This is accomplished without the use of calibrated balances or voltreetric buckets.

17.2-39 June, 1986

Standard, Requirement or Guide NRC Regulatory Guide 1.116

" Quality Assurance Requirements ier Installation, Inspection and Testing of Mechanical Equipment and Systems" (Rev. 0-R, 6/76) - Endorses A'iSI N45.2.8 - 1975.

The Company's' Position Conformance Status Justification The Operational Quality Assurance Program complies Clarification meets or exceeds This clarification is proposed.as a with this guide with the following clarification:

applicable guides and standards.

construction to operations device.

See Generic Statecent which prefaces this table.

I 17.2-40 June, 1986

Standard, Requirement or Guide NRC Regulatory Guide 1.123

" Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" (Rev.

1, 7/77) - Endorses ANSI N 45.2.13 - 1976.

The Company's Position Conformance Status Justification The Operational Quality Assurance Program corplies Clarifications meet er exceed Clarifications contained herein reflect with this guide with the following clarifications:

applicable guides and standards.

actual Compan:. QA Program practices.

Further. these proposals assure

1) With regard to Section 1.3 of ANSI N45.2.13 -

continuity with the QA Program and 1976 titled Definitions: With two exceptions other regulations or guides, and are (Procurement Document and Quality Assurance considered to enhance the aforemen-Program Requirements) definitions in this tioned program.

Standard which are not included in ANSI N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as cla;ified in the Company's cammitment to Regulatory Guide 1.74.

The two exceptions are defined in Table 17.2.0 under Regulatory Guide 1.74.

2) With regard to Section 1.2.2 of ANSI N45.2.13 - 1976 titled Purchaser's Responsi-bilities:

Item c is modified as follows:

" Evaluation of the supplier's QA program shall be conducted as determined by the QA Department based on the complexity and use of the procurement."

3) With regard to Section 3.1 of ANSI N45.2.13

- 1976Property "ANSI code" (as page type) with input value "ANSI N45.2.13</br></br>- 1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Procurement Document Preparation, Review and Change Control:

The phrase "the same degree of control" is stipulated to mean " equivalent level of review and approval." The changed document may not always be rereviewed by the origin-ator; however, at least an equivalent level 17.2-41 June, 1986

Standard, Requirement or Guide The Company's Position Conformance Status Justification supervisor shall review and approve any changes.

4) With regard to Section 3.4 of ANSI N45.2.13

- 1976Property "ANSI code" (as page type) with input value "ANSI N45.2.13</br></br>- 1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Procurement Document Control:

The Company will meet the requirements of Sections 17.2.4 and 17.2.7 of the Operational QA Program in lieu of the requirements specified in this Section.

5) With regard to Section 5.3 of ANSI N45.2.13

- 1976Property "ANSI code" (as page type) with input value "ANSI N45.2.13</br></br>- 1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Preaward Evaluation: The Company will comply with an alternate paragraph which reads: "Except in unusual circunstances as deternfr.ed and documented by station manage-ment (e.g., replacement parts are needed to preclude the development of some unsafe or undesirable condition at a' nuclear facility),

and except in those cases where dedication techniques that do not rely on the supplier's QA program are necessary (e.g. the sole use of special tests and inspections to verify the quality of certain commercial grade items where the supplier has no formal QA program), a preaward evaluation of the Supplier shall be performed as required by the Operational QA Program."

17.2-42 June, 198C

Standard, Requirement or Guide The Company's Position Conformance Status Justification

6) With regard to Section 6.4 of ANSI N45.2.13

- 1976Property "ANSI code" (as page type) with input value "ANSI N45.2.13</br></br>- 1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Control of Changes in Items of Service: The phrase "the Operational QA Program" will be inserted in lieu of "AN11 N55.2, Section 7."

7) With regard to Section 8.2 of ANSI N45.2.13

- 1976Property "ANSI code" (as page type) with input value "ANSI N45.2.13</br></br>- 1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., titled Disposition: The third sen-tence of item b is revised to read:

Nonconfo rmances to the contractual procurement requirements or Purchaser approved documents and which consist of one or more of the fol-loving shall be subriitted to the Purchaser for approval of the recommended disposition prior 17.2-42a June, 1986

Standard, Requirement or Guide The Company's Position ormance Status Justification to shipment when the nonconformance could adversely affect the end use of a module or shippable component relative to safety, interchangeability, operability, reliability, integrity, or maintainability:

1) Technical or material requirement is violated;

2) Requirement in Supplier documents, which have been approved by the Purchaser, is violated;

3) Nonconformance cannot be corrected by continuation of the original manufactur-ing process or by rework; and/or 4)

The item does not ccnform to the original requirement even though the item can be restored to a condition such that the capability of the item to function is unimpaired.

• A module is an assembled device, instrument, or p.iace of equipment identified by serial number or other identification code, having been evaluated by inspection and/or test for conform-ance to procurement requirements regarding end use.

A shippable component is a part of a sub-assembly of a device, instrument, or a piece of equipment which is shipped as an indivicual item and which has been evaluated by inspection and/or test for conformance to procurement requirements regarding end use.

17.2-43 June, 1986

Standard, Requirement or Guide NRC Regulatory Guide 1.144

" Auditing of Quality Assurance Programs for Nuclear Power Plants" (Rev. 1, 9/80) - Endorses l

ANSI N45.2.12 - 1977.

Justification Conformance Status The Company's Position The Operational Quality Assurance Program complies Clarifications meet or exceed These clarifications have been pro-with this guide with the following clarifications:

applicable guides and standards.

posed to maintain program continuity with other referenced standards and guides committed to in Table 17.2.0'

1) With regard to Section 1.4 of ANSI N45.2.12 -

1977Property "ANSI code" (as page type) with input value "ANSI N45.2.12 -</br></br>1977" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Definitions: With one exception Further, where alternatives have been (Program Deficiencies) the definitions in this proposed they reflect Company QA Standard which are not included in ANSI Program practices and are considered N45.2.10 will be used as clarified in the to enhance the referenced program.

Company's commitment to Regulatory Guide 1.74 The one excepted definition and clarified Not all standards, guides and regula-definition relevant to this standard are tions can be considered programmatical-defined in Table 17.2.0 under Regulatory ly error-free, therefore, operational Guide 1.74.

experience utilizing these documents l

and the proposed alternatives must be

2) With regard to Section 2.2 of ANSI N45.2.12 -

taken into consideration.

1977 titled Personnel Qualifications: The qualification of Company audit personnel will be accomplished as described to meet the requirements of ANSI N45.2.23 - 1978 as et.dorsed in Table 17.2.0 and Sections 17.2.2 j

and 17.2.18 of the Operational QA Program.

3) With regard to Section 2.3 (and subsections 2.3.1 through 2.3.3) of ANSI N45.2.12 - 1977 titled Training: The training of Company audit personnel will be accamplished as described to meet the requirements of ANSI N45.2.23 - 1978 as endorsed in Tabic 17.2.0 and Sections 17.2.2 and 17.2.18 of the Opera-tional QA Program.

17.2-44 June, 1986

Standard, Requirement or Guide The Company's Position Conformance Status Justification

4) With regard to Section 2.4 of ANSI N45.2.12

- 1977Property "ANSI code" (as page type) with input value "ANSI N45.2.12</br></br>- 1977" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Maintenance of Proficiency:

The maintenance of proficiency of the Company audit personnel will be accomplished as described to meet the requirement of ANSI N45.2.23 - 1978 as endorsed in Table 17.2.0 and Sections 17.2.2 and 17.2.18 of the Operational QA Program.

5) With regard to Section 3.3 of ANSI N45.2.12

- 1977Property "ANSI code" (as page type) with input value "ANSI N45.2.12</br></br>- 1977" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Essential. Elements of the Audit System:

The Company will comply with subsection 3.6.5 as it was originally written (subsection 3.2.5) in ANSI N45.2.12, Draft 3, Revision 4:

" Provisions for reporting on the effectiveness of the Quality Assurance Program to the responsible management." For the audit-ing organization (The Company), effective-is reported as required by the individual ness nuclear facility Technical Specifications.

Other than audit reports, the Company may not directly report on the effectiveness of the quality assurance programs to the audited organization when such organizations are out-side of the Cottpany.

Subsection 3.3.6 requirements are considered to be fulfilled by compliance with the organi-zation and reporting measures outlined in the Operational QA Program and the Technical Spec-ifications of the individual nuclear facility.

Subsection 3.3.7 requires verification of effective corrective action on a " timely 17.2-45 June, 1986

I Standard, Requirement'or. Guide Justification Conformance~ Status' The, Company's. Position

~

' basis." Timely basis is interpreted to m san :

,within the f ramework or Lperiod of time, for-completion of corrective action that is-accepted.byuthe QA Organization.'.Each finding

-requires a response and's corrective action

~

.completioi date; these dates are' subject to revision (with the approval of the QA Depart-ment) and'must be escalated to higher authority when there is disagreement between the audited 2and the auditing organization.on what constitutes-

" timely corrective action."

6) With regard to Section 3.5 of ANSI N45.2.12'-

1977 titled Scheduling:

Subsection 3.5.3.1 is interpreted.to,mean that the Company may procedurally review qualification of a' con-

. tractor's or supplier's' quality assurance program prior to awarding a contract or purchase order by meanslother than audit.

7) With regard to Section-4.3.1 of ANSI N45.2.12

- 1977Property "ANSI code" (as page type) with input value "ANSI N45.2.12</br></br>- 1977" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Pre-Audit' Conference: The Company will comply with. requirements of this Section by inserting the. word "Normally".at L

This the beginning of the-first sentence.

clarification is required because in the case of certain unannounced audits or audits of a particular operation or work activity, a pre-audit conference might interfere-with the-

-spontaneity of the operation or activity being audited. In other cases, persons-who should be present at a pre-audit conference mayLnot Such lack'of availability always be-available..

to beginning an should not be an impediment audit. Even in the.above' examples..which'are 17.2-46 June, 1986

L l

Standard, Requirement or Guide The Company's Position Conformance Status Justification not intended to be all inclusive, the material set forth in Section 4.3.1 will normally be covered during the course of the audit.

-8)

With regard to Section 4.3.2 of ANSI N45.2.12 - 1977 titled Audit Process:

a) Subsection 4.3.2.2 could be interpreted to limit auditors to the review of only objective evidence; sometimes and for some program elements, no' objective evidence may be available or subjective evidence may be more appropriate. The Company will comply with an alternate sentence which reads:

"When available, objective evidence shall be examined for compliance with Quality Assurance Program requirements.

When subjective evidence is used (e.g.,

personnel interviews, direct observations by the auditor), then the audit report must indicate how the evidence was obtained."

b)

Subsection 4.3.2.4 is modified as fol-lows to take into account the fact that some nonconformances_are virtually

" obvious" with respect to the needed corrective action:

"When a nonconformance or quality as-surance program deficiency is identified as a result of an audit, unless the apparent cause, extent and corrective action are readily evident, further in-vestigation shall be conducted by the audited organizatica in an effort to 17.2-47 June, 1986

Standard, Requirement or Guide Justification Conformance Status The Company's Position identify the cause and effect and to determine the extent of the corrective action required."

c)

Subsection 4.3.2.5 contains a recommen-dation which is clarified with the defini-tion of " acknowledged by a member of the audited organizar.ica" to mean that a

" member of the audited organization has been iaformed of the findings and/or j

observation." Agreement.or disagreement with a finding and/or observation may be expressed in the response from the audited organization.

9) k'ith regard to Section 4.3.3 of ANSI 45.2.12

- 1977Property "ANSI code" (as page type) with input value "ANSI 45.2.12</br></br>- 1977" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Post-Audit Conference:

The Company will substitute and comply with the following paragraph:

"For all external audits, a post-audit conference shall be held with management of the audited organization to pre-sent audit findings or observations and clarify misunderstandings; where no adverse findings or observations exist, this conference may be of the audited organization:

waived by management such waiver shall be documented in the audit report.

Unic unusual operating or maintenance concitions preclude attendance by appropri-ate managers / supervisors, a post-audit conference shall be held with managers /

supervisors for all internal audits for the same reasons as above. Again, if there are l

no adverse findings or observations, manage-of the int ernal audited organization may ment 17.2-48 waive the June, 1986

x

!j.

i Standard, Requirement or Guide

- The Company's Position Conformance Status Justification

-post-audit'confertace: ' such'valver shall be documented in-the audit report."

10) With regard to Section' 4.4. of ANSI M45.2.12 -

1977Property "ANSI code" (as page type) with input value "ANSI M45.2.12 -</br></br>1977" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Reporting:

a) -This Section~ requires that the audit re-port shall be signed by the audit team leader;,this.is not always the most expe-ditious" route to take to assure that'the audit-report is issued as soon as practical.

The Company. vill' comply.vith'Section 4.4 as clarified in the following opening statement:

"An audit report, which shall be signed by the audit team leader, or his supervisor in his absence, shall provide":

In cases.where'the audit report is not signed j

I by the' Audit Team Leader due to his' absence, one record copy of the report must be signed by the Aedit Team Leader upon his return. The report shall not. require the Audit Team Leader's review /

concurrence / signature if the Audit Team Leader is no longer empicyed by the Company _QA Department at the time the audit report. is issued.

b) The-Company will comply with subsection 4.4.3' clarified to read:. " Supervisory

. level personnel with whom significant dis-

.cussions were held during the course of pre-audit?(where conducted), audit, end post-audit (where conducted)Lactivities.

c) _ Subsection,4.4.6 requires audit reports to include. recommendations for corrective-actions; the Company may chooseLnot te 17.2-49 June, 1986

.m

Standard, Requirerent or Guide The Company's Positien Conformance Status Justification comply with this requirement.

Instead, Audit Team Leaders are required to document all adverse findirgs and observations on an audit finding and observation forms.

The procedure for processing audit find-ings allows the Audit Team Leader to document actions which are considered necessary to correct the finding; the Audit Team Leader may also document actions which are considered unacceptable for correcting the finding:

the audit finding with these " Recommendations" is then transmitted to the audited organiza-tion.

In addition, the Audit Team Leader is required to review the response to the audit finding and determine if it is acceptable. Any disagreetents must be escalated to higher management for resolution.

i

11) With regard to Section 4.5.1 of ANSI N45.2.12 i

- 1977 titled By Audited Orcanization:

The Company will comply with the following clarification of this Section: " Management of the audited organization or activity shall review and investigate all adverse findings, and observations as necessary.

(e.g., wheie the cause is not already known, another organization has not already investigated and found the cause, etc.) to determine and schedule appropriate corrective action including action to prevent recurrence. They shall respond, in writing, within thirty days after the date of issuance 17.2-30 June, 1986

i i

Standard, Requirement <nr Guide i.

'The Company's Position Conformance Status Justification of the. audit report. The response shall clearly-state the corrective action taken or l-planned to prevent: recurrence and the results i-of the investigation if' conducted.

In the event"that corrective action is not completed by the time the response is submitted, the audited organization's response shall include a scheduled date for. completion of planned corrective action:- a followup response shall be provided. stating the corrective action taken and.the date'that the action was completed.

If corrective actions are verified as satis-factorily completed by the quality organiza-tion prior to the scheduled completion date, no follovup response is required. The audit-ed organization shall.take the appropriate action to assure that corrective action is accomplished as. scheduled.".The Manager-Quality Assurance may, at his discretion, j

waive the requirements for supplementary.

I response.

i l

i 17.2-51 June, 1986

i i

I Standard, Requirement or. Guide i.

NRC Regulatory Guide 1.146

" Qualification of Quality Assurance Program. Audit Personnel for Nuclear Power Plants" (Rev. O,

8/80) - Endorses ANSI N45.2.23 - 1978.

The Company'c Position Conformance Status Justification 4

j The Operational Quality Assurance Program complies Clarifications and alternatives The clarifications and alternatives j with this guide with the following clarifications meet or exceed applicable guides reflect experience gained at opera-

-and alternatives

and standards.

tional nuclear facilities and are i

intended to enhance and provide l

1) With respect to Sectin 1.4 of ANSI N45.2.23 additional guidance in the areas of

- 1978 titled Definitions: Definitions in auditing as delineated herein.

q

,this Standard which are not included.in ANSI i

' N45.2;10 will be.used; " AUDIT" which is i

included in ANSI N45.2.10 vill he used as

~

addressed in the-Company's commitment to.

Regulatory Gaide.l.74.

i j' 2) With respect to Section 2.2 of ANSI N45.2.23 i

- 1978. titled Qualification of Auditors:

j Subsection 2.2.1 references ANSI N45.2 i

therefore, the Company will comply with an alternate subsection 2.2.1 which reads:

i Orientation to provide a working know-ledge and understanding of the Operational QA Program, including the ANSI standards j

and Regulatory Guides included in Table 17.2.0 of the Program, and the Company's procedures for implementing audits ar*

l reporting.results.

1

3) With respect.to Section 3.2 of ANSI N45.2.23

- 1978Property "ANSI code" (as page type) with input value "ANSI N45.2.23</br></br>- 1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Maintenance of Proficiency:

The Company will comply with the require-ments of this Section by defining " annual

.j

]

assessment" as one which. takes place every 12 4

months or less and which uses the initial date of certification (not the calendar year) as 17.2-52 June, 1986 1

s

~-

j

.4

Standard, Requirecent or Guide Conformance Status Justification Tle Company's Position the starting date for determining when such annual assessment is due.

4) With respect to Section 4.1 of ANSI N45.2.23

)

- 1978 titled Organizational Responsibility:

The Company will conply with this Section with the substitution of the following sentence in place of the last sentence in the Section.

The Manager-Quality Assurance. Su pe rvi so r-Quality or Audit Team Leader shall, prior to commencing the audit, assign personnel who collectively have experience or training commensurate with the scope, complexity, er special rature of activities to be audited.

5) With respect to Section 5.3 of ANSI N45.2.23

- 1978Property "ANSI code" (as page type) with input value "ANSI N45.2.23</br></br>- 1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. titled Updating of Lead Auditor's Records: The Company will substitute the following sentence for this Section:

Records for each Lead Auditor shall be maintained and updated during the peried of the annual nanagement assessnent as defined in Section 3.2 (as clarified).

17.2-53 June, 1986

l 17.2.1 ORGANIZATION 17.2.1.1 General Description A.

Senior Vice President - Nuclear Nuclear is divided into five distinct groups; Nuclear Operations, Nuclear Engineering Services, Nuclear Services, Nuclear Administrative Services, and Nuclear Quality Assurance.

Nuclear Operations, Nuclear Services, Nuclear Administrative Services, and Nuclear Engineering Services are responsible for licensing, operation, and support of the nuclea. power stations. Nuclear Quality Assurance has the responsibility to monitor comp 1tance with the Operational Quality Assurance Program.

17.2.1.2 Management of Operational Quality Assurance.

The specific responsibilities for operational quality assurance are outlined below.

A.

NUCLEAR OPLRATIONS - The Vice President-Nuclear Operations is responsible to the Senior Vice President-Nucicar and has corporate responsibility for the operation of nuclear power stations.

As such, he has overall responsibility for the implementation of the requirements established by the Operational Quality Assurance Program for the operational phase of the nutlear power stations.

1.

, Assistant Vice President - Nuclear Operations Responsible to the Vice President - Nuclear Operations and provides assistance in the day-to-day operation of the nuc1 car power stations.

2.

Station Manager Responsible to the Vice President-Nuclear Operations f or the overall safety and efficient operation of the station, and for the implementation of quality assurance requirements in the areas specified by the Operational Quality Assurance Program, n.

Assistant Statica Manager (Operations and Maintenance)

Responsible to the Station Manager for directing operation, maintenance and for support and enforcement of the company's policies.

In the Station Manager's absence, he assumes the authority and responsibilities of the Manager, including implementation of the Operational Quality Assurance Program.

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h.

Assistant Station Manager (Nuclear Safety and Licensing)

Responsible to the Station Manager for ensuring cornpliance with station technical specifications, managing licensing activities within the station.

Interfacing with the Manager-Nuclear Licensing and Programs on operating experience and safety and Ifcensing issues, managing station procedures and managing station emergency plan activities.

c.

Superintendent-Operations / Superintendent-Maintenance /

Superintendent-Radiological Protection Responsible to the Station Manager, either directly or through the Assistant Station Manager (0&M) for the safe and efficient operation and maintenance of the station within their respective areas of responsibility, including quality assurance requirements specified in the Operational Quality Assurance Program.

d.

St at ton Supervisor,v, Personnel Responsible directly to the Station Manager through their respective superintendents, for implementing the Operational Quality Assurance Program requirements applicable to their respective areas of responsibility.

e.

St9 tion Staff It is the responsibility of each member of the station staff to adhere to the provisionn contained in the Operational Quality Assurance Program when performing their work tasks to assure quality workmanship.

Personne] with unescorted access status shall receive training (General Employee Training) in the use of and adherence to the Operational Quality Assurance Program, f.

Station Nuclear Safety and Operating Committee Serves in an advisory capacity to the Station Manager.

The. technical specifications of each station define the responsibilities of this committee.

The Station Nuclear Safety and Operating Committee is separate from operational quality assurance activities in that its authority and responsibilities are not established by the l

Operational Quality Assurance Program.

However.

I since the prime responsibility of this committee is l

to provide a continuing review of the operational and safety aspects of the station.

it does perform a quality assurance function.

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g.

Superintendent-Site Servief s Responsible to Station Manager for managing all aspects of the assigned projects including interface with station management, engineering, construction and support activities such an accounting, procurement planning, scheduling and cost control.

B.

NUCLEAR SERVICES - The Vice President - Nuclear Services is responsible to the Senior Vice President - Nuclear and has corporate responsibility for long-term nuclear operations support activities.

As such, he has responsibility for the system level implementation of the requirements established by the Operational Quality Assurance Program for the nuclear power stations.

1.

Manager-Nuclear Operations Support Responsible to the Vice President-Nuclear Services to manage the system level support involving maintenance, health physics, chemistry and outage management services for the operating nuclent power stations, a.

Director-liealth Physics / Chemist ry Responsible to the Manager-Nuclear Operations Support for providing health physics and chemistry support services for nuclear stations.

l b.

Director-Maintenance Support Responsible to the Manager-Nuclear Operations Support for providing and assessing maintenance programs coordinating major equipment repair or replacement, for reviewing, station efficiency, and for making recommendations for improvement.

c.

Director-Methods and Procedures Responsible to the Manager - Nuclear Operations Support for the production and maintenance of corporate and station standards and administrative procedures and for coordinating station production and maintenance of station technical procedures.

2.

Manager-Nuclear Licensing and Programs Responsible to the Vice President-Nuclear Services to manage the Industry Operational Event Review Sections, and to manage review,l l

the system level support involving Ifeensing, safety l

interface with industry, coordination with the Institute for Nuclear Power Operations, and other programs which may be assigned.

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a.

Supervisor-Licensing Responsible to the Manager - Nuclear Licensing and Programs for providing support for the stationn in the areas of safety review; NRC issues and actions; and technical and strategic support for licensing and regulatory agency submittals,

hearings, and conferences.

b.

Supervisor-Corporate Nuclear Safety Responsible to the Manager-Nuclear Licensing and Programs to provide an independent review of matters relating to the activities of the Station Nuclear Safety and Operating Committee, the Operating License and Technical Specifications, changes and modifications, Technical Specification departures, investigations,

tests, abno rmal performance, and incidents reportable as required by applicable federal codes; and maken recommendations on these matters.

Corporate Nuclear Safety also acts as the technical body of the Management Safety Review Committee.

The Technical Specifications for each station further define these responsibilities.

3.

Director-Emargency Preparedness Responsible to the Vice President-Nuclear Services for managing the overall scheduling and coordination of emergency testing and training exercises with Federal, State, and local agencies.

Works with corporate and nuclear station managers and personnel to ensure emergency plans meet all the requirements and commitments.

4.

Manager-Nuclear Training Responsible to the Vice President-Nuclear Services for training l

of personnel who operate or support the nuclear power stations.

including Quality Assurance personnel.

Included in this process are determining the need for training based on information provided by the Nuclear Group, developing performance-based training programs, implementing training programs to support employee and station needs, and evaluating training programs.

5.

Mananer-Nuclear Business Services l

Reports directly to the Vice President-Nuclear Services and is responsible for programs supporting budgeting-management reporting, document control-records management, and the l

publication design and graphic support for the Nuclear Department.

In addition, Nuclear Business Services is responsible for assessment of the programs performance and follow-up actions to ensure program objectives are accomplished.

17.2-57

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Director Nuclear Document Control Reports directly to the Manager-Nuclear Business Services and is responsible for development, implementation, maintenance and routine assensment of the Nuclear Document Management Program.

6.

Manager-Nuclear Materials i

kesponsibic to the Vice President-Nuclear Services for ensuring 1

that necessary parts and materials meeting quality and/or design requirements are available when needed.

7.

Management Safety Review Committee (MSRC)

The MSRC is the body which performs the offnite safety review function.

It reports to the Senior Vice President - Nuclear and provides an independent review in the areas of station eperations, maintenance, reactivity management, engineering, chemistry and radiochemistry, radiological safety, quality assurance practices, and emergency preparedness.

The Technical Specifications of each station further define the function, composition, alternates, consultants, meeting frequency,

quorum, reviews, audits, authority and records of this committee.

l C.

NUCLEAR ENGINEERING SERVICES - The Vice President-Nuclear Engineering Services is responsible to the Senior Vice President-Nuclear for civil, electrien1, mechanical, and nuclear engineering, including establishment, implementation and maintenance of programs to control design input, final design, design output, internal and external design interface, and design authority.

Also responsible for procurement engineering. l inservice inspection and nondestructive examination programs and for s nuclear core design, safety analysis, reactor performance evaluation, spent fuel disposition, fuel inspection, and fuel surveillance.

1.

Manager-Nuclear Engineering Responsible to the Vice President - Nuclear Engineering Services for implementing the Operational Quality Assurance Program in the following areas:

Implementation of engineering standards for nuclear design control.

Engineering evaluation of generic industry issues.

Management of engineering resources for specific tasks.

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a.

Superintendent-Station Engineering (One at each statlon)

Responsibic to the Manager-Nuclear Ingineering for the implementation of the Operational Quality Assurance Program in the following areas:

Implementation of the design change progratn at the site includJng initiating field changes as required.

Providing engineering disposition to Deviation Reports as required.

Managing the drawing update program.

Managing engineering services as requested by station managettient.

2.

_ Man 2ger-Nuclear Analysis and Fuel _

Responsible to the Vice President-Nuclear Engineering Services for the development and implementation of the Operational Quality Assurance Program in the following areas:

Nuclear fuel management and core design Core and system thermal hydraulic analysis Fuel performance analysis Reload safety evaluation Engineering support for spent fuel disposition Radiation protection engineering Reactor performance evaluation Special nuclear material accountability Inspection and surveillance of nuclear fuel and related items at the stations and vendors Engineering evaluation of fuel vendors Site reactor engineering

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1 3.

Manager ISI/NDE and Encineering Programs l

Responsible to the Vice President-Nuclear Engineering Services for the Inservice Inspection Program and the Nondestructive Examination Services Program and other engineering programs in the following areas:

Direction of the Inservice Inspection Program relative to sound judgement, company requirements, and regulatory and enforcement authority requirements.

Management and assessment of the effectiveness of the Inservice Inspection Program through reviews, evaluations, and updates.

Development of the inservice inspection programs, plans, and schedules.

Development, maintenance.

snd implementation of the Nondestructive Examination Services Program.

Performance and the technical aspects of nondestructive examinntions.

Qualification and certification of Virginia Power NDE

,ersonnel.

Management and assessment of the effectiveness of procurement engineering.

Control and implementation of General Engineering standards for nuclear design control.

Engineering programs to maintain compliance with regulatory issues.

Reviewing procurement documents.

Managing the commercial grade procurement / dedication process.

Vendor manual control Managing the Equipment Data System (SDS) and Hill of Material System (BOM).

Managing the Q-list and equipment end component safety classification programs.

Development and Maintenance of the Corporate Welding Manual.

l Provides material and metallurgical assessments and recommendations for existing and proposed new equipment.

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Provide material failure analysis and evaluations.

Weldinp/ corrosion engineering and fabrication support on in-house and AE/ contractor designed material.

4.

Managers - (Civil / Mechanical, Flectrical) Encineering Responsible to the Vice President-Nuclear Engineering Services.

Provide engineering services through a project matrix organfration to the Manager-Nuclear Engineering.

Activities include preparation of design enange packages and engineering evaluations, corporate administration of design engineering programs, centrol and implementation of discipline specific engineering standards for nuclear design control, development of procurement specifications, construction drawings, technical reviews, calculations, etc.

5.

Project Manacer - Conficurntton Manarement Responnible to the Vice President Nuclear Engineering Services f or the Design huis Documentation program.

D.

PROCUREMENT - The Vice President-Procuremeat is responsible to the Senior Vice President-Corporate Services for the acquisition of all f uels, materials, supplien, services, and transpcrtation.

1.

Manager-Contracts is the responsible to the Vice President Procurement for performing contract administration functions in support of the Operational Quality Assurance Program for the nuclent power stations, except for fuel and fuel related services.

2.

Manager-Fuel Procurement is responsible to the Vice Prenident Procurement for the purchasing of nuclear fuel and related services, and to adhere to the provisions contained in the Operational Quality Assurance Program applicable to his respective area of responsibility.

3.

Manager-Purchasing is responsible to Vice President Procurement to procure the equipment, materials, supplies and general and technical services in support of the Operational Quality Assurance Program at the nuclear stations.

E.

NUCI. EAR QUALITY ASSURANCE The Manager-Nuclear Quality Assurance is responsible to the Senior Vice President - Nuclear for the establishment of, and monitoring compliance with, the quality assurance program for engineering, construction, and operation activities of Nuclear Operations.

The Manager Nuclear Quality Assurance may make recommendations to the Vice President - Nuclear Operations, the Vice President Nuclear Services, or other levels of management.

If he disagrees with any action taken by the Nuclear group, and is unable to obtain resolution, he shall bring the matter to the attention of the Senior Vice President Nuclear who will determine the final disposition.

17.2-61

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The Manager-Quality Assurance (Station) (one at ench site) is responsible to the Manager - Nuclear Quality Assurance for monitoring compliance with the Operational Quality Assurance Program for the nuclear power stations and the technical support of the quality assurance effort associated with the inodification, operation, and maintenance of the nuclear stations.

The Manarer - Quality Assurance (Station) may make recottmendations to the Station Manager or other levels of management.

If he disagrees with any quality assurance actions taken by the Station Manager, he shall notify the Nuclear Quality Assurance and the Vice Prenident Manager Nuclear Operations.

2.

The Manager-Quality Assurance (Corporate) is responsible to Nuclear Quality Assurance for monitoring the Manager compliance with the quality assurance program for ucheduling and conducting internal audits, inspection and audit of vendors and contractors, preparation and maintenance of the Safe:y-Related Vendors List, quality review of safety related procurement documentation, and those areau cf the Operational l

Quality Assurance as may be assigned to his area of responsibility.

T.

Nuclear Administrative Services - The Director - Nuclear Administrative Services is responsible to the Senior Vice President - Nuclear for Personnel /Iluman kesources. Management In f o rma t i on and Planning and Fitness for Duty.

Other responsibilities include:

provide staff Nuclear and coordinating support to the Senior Vice President international information exchange activities, l

17.2.1.3 Organization Each nuclear power station's Technical Specifications contain the company's organizational requirements j

for facility operation and corporate management, j

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17.2.2 QUALITY ASSitRANCE PROGRAM 17.2.2.1 General Description The objective of the Con:pany Qualit y Assurance program for operating nuclear power stat ions is to cortply with the criteria as expressed in 10 CIR 50, Appendix B as amended, and with the quality assurance procram requirernent s for nuclear power plants as referenced in the Regulatory Guides and ANSI Standards as listed in table 17.2.0.

This program, itr policies and procedures are described herein:

the Topical Report (VEp-1-5A)

(entitled Operational Quality Assurance procram); the Quality Assurance Organizat ion Standards (QAOS); the Nuclear Operations Department Standards (NODS);

and the corporate and station procedures.

This program applies to those quality-related activities that involve the functions of safety-related structures,

systems, and c omponent s associated with the operation, maintenance and modification of nuclear power stations and those nonsaf ety-related component s described in the I rSAR.

The goal of this program is to assure the safe, reliable and efficient operation of the nuclear power station in accordance with cound engineering principles.

The program provides written

policies, standards, procedures, and instructions covering engineering,

design, procur(ment, modifications, periodic curveillante, testing, and maintenance after the systems have been installed, checked and turned over to the Corapany for operation.

Nuclear Optrations Department (NOD) policies and standards establich commitments to the Operational Quality Assurance program.

Detailed procedures and instructions are issued by the station in accordance with and to meet the requirements of their Technical Specifications for administrative, normal operation, periodic tenting, abnormal and emergency conditions. An audit and inspection program has been implemented to provide assurance that these procedures are being correctly applied.

The Company quality assurance personnel, both station and corporate, report through a line of management completely separate from operational and production management and influences, and fulfill the following three-part role:

1.

Audit and inspect to ensure that the overall operation of the nuclear power station is carried out in accordance with Technical Specifications, applicable codes and standards, NRC guides and regulations, company policies and commitments.

2.

Serve as a management tool for st ation and system management personnel, illuminating problem areas, detecting

trends, and providing recommendations regarding solution of problem areas when applicable.

3.

Provide all levels of management with an independent source of information regarding the quality aspect of station operations, mt.intenance and modification activitles.

17.2-63

Differences of opinion between quality assurance personnel and other departments are resolved either at the tun nage r level by the cognizant Manager and the Manager - Quality Ar.surance or are forwarded through normal ndministrative chains of both individuals for resolution at the corporate

level, Final decision-making authority rests with the Senior Vice president-Nuclear.

The Quality Ar,surance Organization conductn audits and inspections in accordance with the Opet at ional Onnlity Assurance program and performs other duties as directed by the individual Supervisors-Ouality.

'I b e Ouality Assurance Organization reprenentatives have access to all areas of the station at any t itne de etne d necessary for inspections, audits, and observations related to quality.

They have access to station records required for in-depth auditing of station operations, including confidential personnel records (but only to the extent necessary to verJfy personnel qualifications or other inf orrnation related to quality.)

17.2.2.2 Quality Assuranic program The Company Operational Quality Assurance program is displayed in a point-by-point cornparison to Appendix 13, 10 ClR 50 in Tabic 17.2.2 which f0110ws.

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TAliLE 17.2.2 Appendix 11 Topical 10 CFR 50 Report criterion Section Title Abstract I

17.2.1 Organiration Defines the relationship of departments to the quality asrurance effort associated with the operation of the nuclear power station, 11 17.2.2 Quality Assurance Defines the Operational Program Quality Assurance Program, its overall responsibility and provisions.

111 17.2.3 Design Control Defines the policy. responsi-ibility and procedures for exercising design control.

IV 17.2.4 Procurenent Establishes policy applic-Document Control able to plant operation and maintenance.

V 17.2.5 Instructions.

Establishes guidelines for Procedures and preparing instructions, Drawings procedures and drawings.

VI 17.2.6 Document Control Establishes policy for the control of procedures and instructions.

VII 17.2.7 Control of Purchased Establishes.acthods f or Material, Equipment assuring that purchased and Services items conform to the speci-fled quality requirements.

VIII 17.2.F Identification and Establishes procedures for Control of Material, the identification and Parts and Components control of material, parts and components.

IX 17.2.9 Control of Special Establishes procedures which Processes assure that special procesr.cs are controlled and accomplished by qualified personnel.

1/ 2-65

Appendix 11 Topical 10 CFR 50 Report Criterion Section Title Absttact X

17.2.10 Inspection Establishes a program for inspection of activitien affecting quality.

XI 17.2.11 Test Control Establishes policy for power stations test progrann.

XII 17.2.12 Control of Measuring Establishes policy for cen-and Test Equipment trol and calibration of test and measuring equipment.

XIII 17.2.13 Handling, Storage Establishes policy for thin and Shipping function as related to material and equipment.

XIV 17.2.14 Inspection. Test, Makes refercace to appro-and Operating Status priate administrative procedures which govern this function.

XV 17.2.15 Non-Conforming Establishen policy for Material, Parts, or reporting and controlling Components non-conf orming tuaterials, parts, or components.

XVI 17.2.16 Corrective Action Establishes policy for identifying, documenting, notifying, determinir.g causts and preventing defects from recurring.

XVII 17.2.17 Quality Assurance Assures maintenance, identi-Records fication and tetrievnbility of records.

XVIII 17.2.18 Audits Defines policy and procedures for audit programs, i

17.2-66

17.2.2.3 Identification of Structurca. Systems, and Components Safety related structures, systems, and components are identified in the lfFSAR.

The portlens of these structures, systems, and componetits that are within the scope of the Operational Quality Asrurance Program are further identified in the respective Q-List for North Anna and Surry Power Station.

17.2.2.4 Periodic Review of the Operational Quality Assurance Program Audits of activities required by the Operationni Quality Anr.urance Program will be conducted at least once per 24 months.

Ther.e audits are perforned under the cognizance of the Management Safety Review Committee.

17.2.2.5 Qualification of Quality Assurance Organization Personnel The Manager - Quality Assurance (Corporate) shall have a four-year accredited engineering or science degree or equivalent with a minimum of ten years experience related to electric power generating facilities.

At leant five years of overall experience shall have been in a supervisory capacity, two years of which should have involved quality assurance related matters.

The Manager - Quality Assurance (Station) shall have a four-year accredited engineering or science degree or equivalent with a minimum of eight years experience related to electric power generation facilities, two years of which involve experience in nuclear power stations.

At lenst four years of overall experience shall have been in a supervisory capacity, two years of which should hcve involved quality assurance related matters.

The Supervisors - Quality shall have a four-year accredited engineerine or science degree, or equivalent. A minimum of two years overall experience or equivalent training in power plant operations is a prerequisite with at least one year of this experience involved in nuclear power station quality assurance program implementation.

Replacement personnel in the key posit ions listed will meet or exceed the applicable requirements of ANSI /ANS 3.1 (Draft 12/79) as clarified in l

Table 17.2.0.

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17.2.2.6 Certification of Quality Assurance Organization l'ersonnel The certification of Quality Assurance Organization personnel is accomplished in accordance with the Quality Assurance Certification Program.

This program provides for the certification and recertification of Level 1

Level Il and 1.evel til inspectors, and for auditors and lead auditors.

The program outlines the qualification and certification requirements for personnel and requires the individual to be certified prior to performing specified inspection or audit functions.

'"h e Supervisor -

Quality has the responsibility to certify / qualify inspection / audit personnel.

17.2.2.7 Certification of Other Support Personnel The certification of Quality Maintenance Team (QMT) personnel, Material l

Dedication lnspection Personnel.

Puel Accountability and luspection l personnel, and Inservice Testing personnel is accomplished in accordance with the approved certification programs.

These programs outline the qualification and certification requirements of personnel and require the individual to be certified prict to performing speelffed fuoctionn.

The Supervisor - Quality has the responsibility to certify / qualify Quality Maintenance Tenn (QMT) personnel.

17.2-68

17.2.3 DESIGN CONTROL Nuclear Standards describe the design control program. Measures are established to assure that applicabic regulatory requirements and the nuclear power station design bases are correctly translated into the Company specifications, drawings, procedures, and instructions applicable to design changes and/or modifications for the operating nuclear power station.

All desigc changes and/or modifications to safety-related structures.

-equipment, systems and components described in the UFSAR are reviewed, approved, and acted upon by the Station Nuclear Safety and Operating Committee in accordance with their retponsibilities and functions as referenced in the Technical Specifiestions.

Design-changes to these structures, equipment, systems and components approved by the Station Nuclear Safety and Operating Committee are forwarded to the Nuclear Licensing and Programs Staff for an independent review.

This review may be performed by Nuc1 car Licensing and Programs Staff personnel, the staff of other company departments, qualified outside contrattors, or consultants.

The responsibility for the development. -identification of requirements, monitoring, and implementation of an effective design control program is delegated to the Vice President - Nucient Engineering Services with input as appropriate from the Station Hanager and operations personnel.

The Nuc1 car Design Control Program (NDCp), delineates procedures that assure design changes, including field changes, are subject to design control measures commensurato uith those applied to the original design and the applicable specified design requirements.

These procedures assure that design basis, regulatory requirements, codes and standards are correctly translated into specifications, drawings, procedures, or instructions for those structures, systems and components classified as safety-related in the UFSAR and Q-List.

The NDCp provides for verifying or checking the adequacy of-design, such as by the performance of design reviews, by the use of alternate -or simplified calculational methods, or by the perxormance of a suitable testing program. When a testing program is solely used to test the adegnacy of a -design, the test 'will be conducted under adverse design conditions. The provisions of this section assure that the verifying or

-checking process is performed:by individuals other than those who performed-the original design.- These individuals are identified and their authority and responsibility is described.-

The NDCp also identifies the design documents that are_ required to be reviewed and the personnel responsible for their-review -and revisions, to-assure that design characteristics can be controlled, inspected and tested, and that inspection and test criteria are identified.

Design change documents >and revisions thereto are distributed to responsible supervisors to determine whether: revisions to-controlled design and operating documents are necessary.

Design documents and reviews, records and changes thereto -are-collected, stored and maintained in-a r

systematic'and controlled manner.

L The NDCP establishes measures for.-the selection and review for suitability of application of materials, parts, equipment and processes that are essential to the safety-related functions of the systems, structures and components.

These measures include the use of valid and applicable industry standards -and ; specifications, materials and prototype hardware testing-programs,'and design reviews.

In the-event of a design modification to a system which is safety related, engineering studies 17.2-69 a.

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are initiated to evaluate parts, equipment. processes, and material suitability for repair of such equipment or components; previously approved items are used without further review.

Previously approved materials, parts or components used for a different application are reviewed for suitability prior to approval for their new application.

Quality measures are assured through all levels of the design control program by the design control orFanization, the Design Control

Engineer, Engineering Supervisors, Superintendent

- Station Engineering, Manager - l Nuclear Licensino, and Programs, and the Station Nuclear Safety and Operating Committee.

Any errors or deficiencies noted in the design process are documented on the design change forms and subsequently corrected.

Procedures for design controls, analysis, and reviews have as their basis the applicable portions of documents referenced in the Nuclear Design Control Manual, and include ANSI N45.2.11

- 1974Property "ANSI code" (as page type) with input value "ANSI N45.2.11</br></br>- 1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. as modified in Table 17.2.0.

The Nuclear Design Control Program Instruction Manuni for Architect / Engineers establishes procedures to describe the design interface between the Company and contractors for the review, approval, release, distribution, and revision of documents involving design interfaces.

Suitable design controls are applied to such disciplines as reactor physics; seismic

stress, thermal, hydraulic, radiation and accident analysis; compatibility of materials; and access!bility for inse rvice inspection, maintenance and repair.

Designs are reviewed to assure that (1) design characteristics can be controlled, inspected, and tested, and (2) inspection and test criteria are identified.

Changes to nonsafety-related structures, systems, and cumponents will be controlled in accordance with applicable procedures and to meet the requirements, where applicable, of 10 CFR 50.59.

The Quality Assurance Organization reviews the implementation of the design control measures through inspections and audits.

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17.2.4 PROCUREMENT DOCUMENT CONTROL i

Nuclear Operations Department Standards and their supporting procedures describe the program for completing procurement documents including review, l

approval, document control, and change control.

In addition, references to procedures that govern the actiour of the Quality Assurance (Corporate) are made which include provisions for access to the suppliers facilities and i

records, for source inspection and audit by quality assurance personnel, and qualification of vendors prior to the initiation of quality related actions when the need for such inspection and/or audit has been determined.

This program also provides for records to be prepared, maintained, made available for review, or delivered to the Company prior to use or installation of the

hardware, such as. drawings, specifications, procedures, procurement documents, inspection and test

records, personnel and procedure qualifications, material, chemical and physical tests results, and the identification of quality assurance requirements applicable to the items or services purchased.

Including sub-tier procurement requirements when required.

Policies and standards are established in the Nuclear Department

-Standards Manual to ensure that procurement documents reference all actions required by a

supplier in accordance with the applicable codes, specifications, and drawings.

Procurement documents incorporate the design basis technical and quality requirements including the applicable regulatory requirements, component

.and material identification requirements,

drawings, specifications, codes _ and industrial standards, test and inspection requirements, and special instructions for special procedures such as welding, heat treating, nondestructive testing and cleaning as applicable.

Procurement documents for spare or replacement parts of safety-related

-structurcs, systems and components are subject to technien1 and quality controls'at least equivalent to those used on the original equipment.

The procurement document, a copy of which is flied and available for

-review, is prepared by the cognizant supervisor-and then undergoes -the review and approval routing as determined by the Procurement and Materials Management Process Manual. These reviews and approvals are documented.

The Quality Assurance Organization periodically audits the control-of procurement documents.

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17.2.5 INSTRI?CTIONS, PROCEDURTS AND DRAWINGS g

As required by the individual unit's Technical Specifications, detailed written procedures are established, approved, implemented, and maintained.

Other activitics affecting quality of structures,

systems, and components within the scope of the 10 CFR 50 Appendix B nre prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.

These activities are accomplished in accordance with these instructions, procedures, or drawings.

Applicable instructions, procedures, or drawings include for reference appropriate qualitative and/or cuantitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Administrative procedures describe the requirements for developing, reviewing, approving, and controlling procedures used for testing as well as corrective maintenance, operating, administrative, and other activities performed at the power station.

These requirements include references, prerequisites, precautions, limitations, manufacturer's specifications, check-off lists, and acceptance criteria (as appropriate).

. hen applicable the acceptance limits and requirements contained in Se design and portion of the acceptance criteria procurement documents constitute a referenced and contained in written testing procedures.

The Quality Assur6nce Department periodically reviews the documents to ensure revisions are made promptly and that obsolete material is deleted.

They Lave the authority to recommend changes and to require the addition / deletion of inspection hold / verification points.

7hrough their stop work authority they can prohibit the use of inappropriate documents until correct documents can be obtained, l

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17.2.6 DOCUMENT CONTROL Measures are established and documented within the operating nucicar power stations and at Innsbrook Technical Center _ describing the control of documents, such as procedures, instructions, and drawings, to provide for their review, approval, and issue, and changes thereto, prior to release and to assure they are adequate and the quality requirements are stated, Provisions call for, among other things. (1) the periodic review of approved nuclear safety-related station procedures, the review and approval-of all new station procedures and design changes prior to release, the review and approval of all changes / revisions to station procedures and deafgn changes by the Station Nuclear Safety and Operating Conmittee, (2) policy and procedures for issuance of and changes to station drawings and approval of changes.- and (J) the maintenance and distribution of these procedures.

Normally changes to documents are 1 reviewed and approved by-the same organizations that performed the original review and approval; however, this responsibility may be delegated to other. qualified responsible organizations.

Approved changes are incorporated into procedures and t

drawings and other appropriate documents-associated with the change.

- Procedures and drawings and changes thereto_are processed, distributed and controlled.- The station maintains a record of all holders of procedures and drawings and an index of all procedures and drawings, listing the current revision date.

Instructions require that a copy of the _ appropriate procedure be available at the activity location prior to the commencement of that activity.. These measures are addressed in the Technical Specifications t

and Administrative Procedures for each station.

Individual station administrative -procedures list certain documents taat require strict cdministrative control for distributien,. revision, and routing.

These documents are categorized as " Controlled Derumenta."

Examples of controlled documents are: Station Procedures, Station Drawings, and the Precautions. Limitations, and Setpoints Document. Also set forth are the distribution and controlling procedures for design-and procurement documents._

The Quality Assurance Organization makes periodic inspections and audits of documents to verify-their status, using a current master copy.

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l 17.2.7 CONTROL OF PURCllASED MATERIAL, EOUIpMENT, AND SERVICES An evaluation of suppliers is performed prior to contract award, except in emergency situations where an item or service is needed to preclude development or deterioration of an unsafe condition at the plant, by one or more of the following:

(1) A review of the supplier's capability to comply with the elements of 10 CFR 50, Appendix B that are applicable to the type of material, equipment, or service being procured. (2) A review or previous records and performances of suppliers who have-provided similar articles of the type being procured. (3) A survey of the supplier's facilities _and quality assurance program to determine his capability to supply a product or service which meets the design, manufacturing, and quality requirements, or (4) A review of qualification information supplied by another utility or outside organization.

Surveillance of suppliers during fabrication, inspection, testing, and shipment of materials, equipment, and components is planned and performed in accordance with written procedures -to assure conformance to the purchase order requirements as applicable.

These procedures provide fort a._

Instructions that specify'the characteristics or processes to be witnessed, inspected or verified, and accepted; the method of surveillavice and the extent of documentation required; and-those responsible for implementing these instructions.

Surveillance shall be performed on those items where verification of procurement requirements cannot be determined on receipt.

b.

' Audits and/or inspections which assure that the supplier complies with.all quality requirements.

These evaluations are performed under the supervision of the Manager -

Quality Assurance (Corporate),

except for surveillance of nucient fuel related suppliers.

The surveillance of suppliers of ouclear fuel and related items is performed under the supervision of the Manager - Nuclear Analysis and Fuel. The results of these actions are documented and filed.

Individual station administrative procedures describe the requirements for controlling purchased material, equipment, and services-including commercial grade items for. use on safety-related structures, systems, equipment, and components.

The requirements applied to spare and replacement parts are at_least equivalent to those applied to the original

. parts._

Periodic inspections by the Quality Assurance Department are made for assuring _that applicable material and equipment received at-the station meet the requirements of the specifications, purchase orders, code.

drawings, or other purchasing documents.

This assurance includes the review of -documentation received, physical inspection, cleanliness, packaging, marking.or functionr.1 testing as required.- Purchased items are normally

under' the-contro'.

of-the "on-site" organization. This organization-is-l authorized to corxact system organizations and NSSS, _ A/E contractors _ and l'

subcontractorr through the auspices of system representatives.for assistance-as 7equirea.

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L Periodic evaluations or monitoring o f-procurement history of the suppliers are performed to verify continued supplier capability.

17.2-74 D _,

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Documentation concerning the quality of material, cornponents, and equipinent received is periodically reviewed by the power station Quality Assurance representative for conformance with the Purchase Requisition and Purchase Order.

T The-procurement of nuclear fuel is controlled in accordance with procedures that have been developed by the Engineering and Procurement Organizatiotis to address the requisite quality attributes of this function.

Monitoring and verification of this activity is performed under the supervision of'the Manager - Quality Assurance (Corporate).

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17.2.8 IDENTIFICATION AND CONTROL OF_ MATERIALS, PARTS. _AND COMPONFNTS Installed components at the nuclear power station are adequately identified and substantiated with documented records by the Architect -

Engineer and the NSSS Vendor during the construction phase of the station.

' i These identifications and records are maintained in the station files.

Replacement materials, parts, and c on.ponents including partially fabricated subassemblies are adequately and properly identified to allow control and traceability to pertinent quality assurance records sach as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and chemical mill test reports.

The identification system is consistent, as practical, with that used during the construction of the station, with similar identificatian used during design change activities.

The location and method of identification do not affect the function or quality of_the item being identified.

Verification of correct identification of safety-related materials,_ parts, and conponents is required and documented prior to the release for fabrication, assembling, shipping, or installation.-

The Quality Araurance Organization periodically performs inspections and audits of this activity.

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l 17.2.9 CONTROL OF SPECIAL PROCESSES The control of special processes is maintained and implemented through the use of procedures, technique sheets, travelers and inspection verification reports, and personnel qualified in accordance with the applicable codes, specifications, and standards for the specific work.

In instances where the Company assigns such work to contractors, the contractor must submit their procedures and personnel qualifications to the Company for approval prior to the start of work.

Special processes include, for example, those involving welding, heat

treating, nondestructive testing, cadwelding, removal of undesirable substances during shop and site cleaning, degreasing and flushing, and verification of wall thickness of salves and other cast components important to nuclear safety.

The Company conducts inspections of work involving special processes to assure that procedures and personnel are properly qualified and their workmanship is in compliance with applicable specifications, codes, and standards.

ecords of procedures, equipment, and personnel qualification are maint ined and kept current in accordance with the provisione of Section 17.2.

herein.

Monitoring and verification is performed by the Quality Assurance Department.

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17.2-77

17.2.10 INSPECTION Inspection procedures for those activities affecting quality have been established. These procedures govern the inspection and documentation of activities relating to repairs, modifications, and changes made to safety related systems, structures, and components. Written maintenance procedures are provided which include it.spection hold points.

Examinations, measurements, or tests of materials or components associated with safety-related equipment and systems are performed for each work operation, where necessary, to assure quality.

If inspection is impossible or inappropriate, indirect control by monitoring

methods, equipment, and personnel is provided.

Both methods are provided when control is inadequate without both.

The station safety-related maintenance procedures (including modification procedures) are reviewed by the Supervisor-Quality or designee (Inspections) to determine the need for an independent inspection and the degree and method if such an inspection

's requi red.

Examinations, measurements, or tests that require witnessing are identified as " inspection hold" points in procedures.

The inspection performed at a hold point is specific in nature; quality characteristics and acceptance /rejectio.

criteria are included or qualitative criteria such as operability cheeks, compliance with procedural steps, or cleanliness instructions are spec'fied.

The inspection is documented by signature or initials on the uritten procedure form.

Quali;y Assurance Department performs physical inspections at random intervals to ensure quality requirements are met.

These checks are performed as the conditions of the maintenance warrant. These personnel and other inspectors are qualified in accordance with codes and standards as applicabic to the function they are performing.

The inspection program requires that inspectors be assigned as appropriate for the activity being inspected. An inspector may be a member of the organization performing the activity.

However, they must be qualified and shall not be the person performing the activity or the supervisor directly responsible for the activity.

For example, Quality Maintenance Team personnel when performing Quality Control inspections are under the direction of the Supervisor - Quality (Inspection).

Personnel so assigned shall become familiar with the procedure being used and other pertinent documents such as technical manuals and drawings prior to performing the inspection.

Personnel responsible solely for the conduct of nondestructive examination are qualified to SNT-TC-1A, 1980 Edition, except as amended by IWA-2300.

Audits and reviews of their findings and associated corrective actions are periodically conducted by quality assurance personnel to assure that these procedures are being carried out in a quality manner.

The inspectors qualifications are p'riodically reviewed for recertification.

17.2-78

-l Generally,:all' physical inspections are under the control of the-1 on-site organization. - However, the Station Manager is authorized to. request assistanceins required through the Manager'- Nuclear Operations Support as

'does the Supervisor - Quality via the Manager - Quality Assurance (Station).

-Thn inspection of nuclear fuel and related. items is controlled in accordance witn procedures that have.been developed by Nuclear Analysis.and Fuel to address the requisite quality attributes of this function.

Monitoring and-verification of this activity is performed under the direction of the. Manager - Quality Assurance (Corporate).

Additionally, inspection activities pertaining to Design Control

- (Section '17.2.3);

Procurement Document Cor.t rol. '(Section 17.2.4);

Test Control- (Section 17.2,11); Nonconforming Materials, Parts, or Components (Section 17.2.15);

and Corrective Action (Section 17.2.16) shall be controlled in accordance ~with provisions established for this function in the referenced sections contained herein.

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a 17.2-79

17.2.11 TEST CONTROL The test program described in the Technical Specifications assures that safety-related structures, systems, and components will perform satisfacto-rily when required. Written "Peciodic Test" procedures for this program are reviewed and approved as specified in the individual unit's Technical Specifications. These test procedures include or reference:

(1) The requirements and acceptance limits contained in applicable design and procurement documents.

(2) Test prerequisites such as the availability of adequate and appropriate equipment and calibrated instrumentation;

trained, qualified, and licensed or certified personnel; the completeness of the item to be tested; suitable and controlled environmental conditions; provisions for data collection and storage.

(3)

Instructions for performing the test.

(4)

Inspection points as appropriate.

(5) Acceptance and rejection criteria.

(6) Methods of documenting or recording test data and results.

The Periodic Test Program provides for testing of instrumentation and electrical equipment in the categories of (1) instruments installed as listed in the Technical Specifications, (2) installed instrumentation used to verify Technical Specification parameters, and (3) installed safety-related instruments and electrical equipment that provide an active function during operation, shutdown, or abnormal conditions (i.e.,

vice being designated safety-related solely because the instrument is an integral part of a pressure retaining boundary).

This instrumentation shall be in a calibration program. This program provides, by the use of equipment history data, status, records, and performance schedules, for the date that calibration is due and indicates the status of calibration. The identity of person (s) performing calibration is provided on the calibration documents.

Testing of modifications is done in accordance with procedures developed within the Design Change Program described in Section 17.2.3 of this report.

Testing upon completion of maintenance is done in accordance with Maintenance Procedures developed as described in Section 17.2.16 of this report.

Monitoring and verification is performed by the Ouality Assurance Department.

1 17.2-80

l 17.2.l?

CONTROL OF MEASURING AND TEST EQUIPMENT A program has been established and documented in station administrative procedures that describes the calibration technique and frequency, maintenance, and control of all " Measuring and Test Equipment" (portable instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive test equipment) which are used in the measurement, inspection, maintenance, and monitoring of safety-related components, systems, and structures.

Measuring and test equipment does not include:

measuring equipment used for preliminary checks or utility troubleshooting where accuracy is not required.

There is also no intention to imply a need f or special calibration and control measures of rulers, tape measures, levels, and other basic tools if normal commercial practices provide adequate accuracy. Controls for measuring and test equipment include the transportation,

storage, and protection of the equipment; the handling of associated documents giving the status of all items undar the calibration system such as maintenance history, calibration test data, and individual log sheets assigned to each device; and the permanent marking of each device by a unique number.

The maintenance, calibration technique, and frequency of calibration of measuring and test equipment utilized in activitics affecting quality at the power station are normally performed as specified in the manufacturer's instruction manual or in approved written procedures.

In some cases the calibration interval may be assigned or changed based on accumulated experience by trained technicians.

The recall system may include provisions for the temporary extension of the calibration due date under certain conditions specified in approved procedur s.

If ctandards are not available or there is some special reason that procedures cannot be followed, the modified procedures and/or interval are documented, including justification.

In other cases, rather than require calibration at specified intervals, requirements may specify the device be calibrated prior to use, as in the case of torque wrenches or micrometers. Where permitted by commercially available state of the art equipment, reference standards are no more than 1/4 the error allowed in the measuring and test equipment calibrated by that standard. Measuring and test equipment used on safety-related systems or equipment are calibrated utilizing reference standards whose calibration has a known valid relationship to nationally recognized standards, such as the National Institute of Standards and Technology (NIST), or accepted values of natural physical constants.

If no national standard exists, the basis for calibration is documented.

Whether the device is enlibrated at the power station or at an NIST traceable outside laboratory, one or more stickers are conspicuous surface identifying, but not limited to, date of affixed on a calibration and next calibration due date.

When measuring and test equipment utilized in activities affecting quality are found to be out of calibration an evaluation will be performed and documented concerning the validity of previous tests and the acceptability of devices previously tested.

All previous tests and measurements performed during the current or proceeding calibration cycle shall be redone if the evaluation so indicates.

Implementation of these procedures is assured through routine inspections or audits by the station Quality Assurance Department.

17.2-81

17.2.13 HANDLING, STORAGE, AND SHIpplNG Measures have been established in i ation administrative procedures to provide adequate methods by qualified personnel for the classification, packaging, cicaning, p r e se rv at ion,

shipping, storage, and handling of material and equipment received at the station.

These measures, prepared in accordance with design and specification requirements, define responsibility, levels of essentia11ty, degree of receipt inspection, tagging, categories of inspection and their definition, and storage levels for categorized items.

The procedures also control cleaning, handling, storage, packaging, shipping, and preservation of materials, components, and systems to preclude

damage, loss, or deterioration by environmental conditions such as temperature or humidity.

Implementation of these measures is verified by audits and inspections.

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17.2.14 INSPECTION, TEST, AND OPERATING STATUS I

"easures for the identification und documentation of the inspection and test statue for items to prevent inadvertent bypassing of specified inspections and tests are established in station administrative procedures and in station operating procedures.

These measures define the three general categories of inspection and test status for items: Accept, Reject, or llol d.

They provide for status identification through the use of stickers, tags, record cards, test records, check-off lists, or logs.

The operating status of items and/or equipment is identified through records, checklists, or operational tagging systems that are maintained to indicate the status and authority to operate the item and/or equipment.

Operating status to additionally controlled thtuugh the normal station operating procedures.

The application and removal of the various status tags, stickers, and other indicators is controlled by Station Procedures.

Implementation of these measures is verified through audits and inspections conducted in accordance with the Operational cuality Assurance Program.

These activities assure that the required inspections, tests, and other critical operations are controlled.

17.2-83

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17.2.15 NONCONFORMING MATERIALS. PARTS, AND COMPONENTS A documented system for controlling nonconformances observed dur'ing receipt inspection, storage,_ fabrication and erection, installation, initial and/or acceptance testing, or initial operation is established and provides for the preparation, issuing, and distribution of Station Deviation Reports in accordance with prescribed procedures.

These procedures apply to new or reworked materials, parts, or components which possess manufacturer / supplier caused nonconformances.

The identification, documentation, segregation, review, disposition, and notification to affected organizations of nonconforming material, parts, or. components are

-described or.-

referenced-in station Technical Specifications,- ' Administrative procedures, and/or station. operating procedures..Nonconformance of purchased -services are controlled under Section 17.2.7 -Control of Purchased Material, Equipment, and Services; Section 17.2.10-Inspection; and station administrative procedures.

Specifically,; instructions require that the individual discovering a-nonconformance identifies, describes, and documents the nonconformance on a Station Deviation Report.

-!Ihen~ a nonconforming item is,1dentified, it is placed in the hold area l established in the storeroom or other segregated location, if-practical, and identified with a hold tag to prevent its inadvertent use.

If material is dispositioned -as

' reject,'

the Quality Control Hold Tag shall remain

-attached to the material / component until loaded for departure from site and-t shall only be removed by Quality Assurance at tnat time.

Hold items may be : released on a risk basis following the documented approval of such risk release by the Station Manager on a Release on-a Risk

Basis Form. Each risk release is handled on a case basis and depends-on'the nature of the hold status.

The basis and' conditions of the release are.

described on the' form, including the criteria for clearing the original hold status.

Rejected material is not risk released.

A Station Deviation Report. of-a nonconforming material, part.: o r.

component.dispositioned " accept as is" requires an engineering analysis and

-approval. The results of this review and approval are documented and become a part of station records.-

Should the disposition of a nonconformcuce. require the rework or' repair of materials.. parts, components, systems,_ or structures, 'such-rework Lor repair is. reinspected or. retested by_a method which is at least equal to the original inspection or test: method. The inspection requirements and _the inspection, rework, or repair procedures are

'cumented and become a part of station records.

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17.2-84 i,

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The disposition and approval of nonconformances are the responsibility-of the on-site organization.

However, the-Station Manager has the authority to request assistance as appropriate from-off-site organizations 'such as:

Nuclear. - Operations Support, other engineering groups, or the. Quality Assurance Department.

The Station Deviation Reports trends are periodically reviewed for conditions adverse to quality by~ station management.

In

-service failures

.of materials.. parts, and components are dispositioned by -the use of Deviation Reports and/or Work Orders as described in Section 17.2.16 of this report.

Implementation and verification 'of the procedures for-the contro11of nonconformances are assured through audits and inspections by the -Quality Assurance Department.

The nonconformances observed during the inspection of nuclear fuel and related items and the disposition of those nonconformaaces is controlled in

-accordance with procedures that have been-developed by Nuclear Analysis and Fuel to address the requisite quality attributes. of-this-function.

' Monitoring and verification of this activity is performed under the direction of the Manager - Quality Assurance (Corporate).

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17.2-85 i

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17.2.16 CORRECTIVE ACTION Corrective action measures are established as an integral part of the processing and resolving of noncon f o rma nce s and failures in service.

Through these measures, assurance is confirmed that significant adverse quality conditions are identified, documented, their cause determined, and the corrective actions have been taken that preclude repetition of the adverse quality conditions.

Verification of the proper implementation of corrective action measures and closcout of corrective action documentation is assured through the monitoring effort of the station staff and the follow-up reviews and audits conducted by the Quality Assurance Department.

Adverse conditions significant to quality, the cause of the conditions, and the initiation of corrective action are reported to appropriate levels of both offsite and onsite management by use of Deviation Reports and audit findings.

If further corrective action is required the appropriate management program for performing, tracking and closing the issue will be used.

Nuclear Engineering Services maintains a program to evaluate complex design concerns that may lead to adverse quality conditions at the Nuclear stations.

The Potential Problem Reporting (PPR) system allows for detailed, multidiscipline reviews of complex design concerns that may yield station deviation reports. Many design concerns cannot be determined to be adverse to quality until a detailed design review is performed.

The PpR process controls this activity as part of the Nuclear Design Control Program.

The procedures for processing a Deviation Report require that each adverse condition significant to quality be categorized as either requiring a Licensee Event Report, Specia)

Report or NRC Notification or as a nonreportable deviation.

Nonreportable deviation refers to deviations not reportable to the Nuclear Regulatory Commission.

The reporting requirements differ for each of the categories of deviation but require the appropriate levels of management be notified in each case.

The Quality Assurance Department periodically audits the deviation reporting process.

Procedures require that corrective maintenance of nuclear safety related material, parts, or components be documented on a Work Order.

The Quality Assurance Department is notified prior to the commencement of safety related maintenance.

The Quality Assurance Department may then initiate a surveillance program as necessary.

Example s of areas subj ec t to surveillance are (1) the use of approved maintenance procedures, (2) the existence of Radiation Work Permits and proper tagout, if applicable, (3) the existence of required plant conditions, and (4) documentation of Technical Specification requirements.

If the Quality Assurance Department elects to inspect the work, the surveillance does not have to be per f o rmed prior to commencement of work.

Also, the Quality Assurance Department monitors completed Work Orders to assure maintenance performed is properly documented, maintenance procedures are properly signed off and check lists are completed if applicable, Technical Specification limits were met if applicable, materials used are documented, and Work Orders are being adequately reviewed by appropriate supervisory personnel.

17.2-86

Station Technical Specifications require that rework or repair of nuclear safety-related materials, parts, coinponents, systems, and structures be accomplished in accordance with approved written procedures.

The procedures for rework or ra;. air of safety-related equipment are approved by the Station Nuclear Safety and Operating Committee to ensure provisions for en adequate inspection of the completed rework or repair and that this inspection is a method at least equal to the method originally used for inspection or an acceptable alternative. The cognizant supervisor reviews the completed procedures to insure the acceptance criteria have been satisfied and for the completeness of the post-maintenance check-out.

The station Quality Assurance Department monitors completed procedures to assure adequate supervisory review.

The Supervisor - Quality determines the scope of the required quality assurance effort on the basis of the extent of modifications or repair to safety-related equipment, systems, or components. When this determination is made, the station Quality Assurance Department reviews the proposed procedures to be used for the modification or repair activities to ensure hold points are included, the procedure complies with the operational quality assurance program.

and the applicable codes and standards are referenced.

For some repair efforts, briefings of quality assurance personnel by the Supervisor - Quality are conducted.

For major evolutions, such as refueling, steam generator modifications, etc., a series of seminars covering all aspects of the activity (e.g., radiation control, personnel hazards, stop work procedures, inspection criteria) may be held.

17.2.16.1 Authority to Stop Work The Quality Assurance Organization has the authority, and the responsibility, to stop work in progress which is not being done in accordance with approved procedures or where safety or equipment integrity may be jeopardized.

This extends to off-site work performed by vendors furnishing safety-related materials and services to the Company.

17.2.16.2 Imposition of "Stop Work"

~

A.

Station Quality Control Staff - The station Quality Assurance Department represa-tative advises the cognizant supervisor or supervisory personnel to stop t. ark in progress whenever he determines that it is not being conducted in accordance with applicable procedures, instructions, guides, or standards or may jeopardize the safe operation of the station.

The Supe rvisor-Qualit y immediately notifies the Station Manager of the decision to stop work because of adverse quality conditions.

He shall also notify the Manager-Quality Assurance (Station).

B.

Station Manacer - The Station Manager evaluates the Quality Assurance Department's determination of the necessity to stop work.

1.

If he concurs with the decision to stop work, he initiates the necessary corrective action. Only after the discrepancy has been corrected and the corrective action approved by the Quality Assurance Department does work resume.

17.2-87

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-In-the event the Station Manager does not concur with the Quality Assurance Department's decision to'stop work, he may

order work 'to resume by notifying the-Manager-Quality

Assurance and the appropriate station supervisory personnel in his organization of his decision.' He shall also refer-the issue to the_Vice President-Nuclear Operations for review and=

approval.

- C.

Vice President-Nuclear Operations The Vice President-Nuclear Operations 1s-responsible for -approving or disapproving the Station Manager's decision'in those cases where the Station Manager does not concur with the stop work and orders work to resume.

D. _ Manager-Quality Assurance - The Manager-Quality Assurance (Station) may refer any-concerns he may have concerning the handling of "stop work" to the Vice President-Nuclear Operations or to the Manager-Nuclear Quality Assurance.

He may direct imposition of "stop work" whenever -he deems such action to be appropriate.

E.

Imposition of =offsite work performed by vendors shall be controlled by appropriate department procedures.

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17.2.17 OUALITY ASSURANCE RECORDS The requirements and responsibilities for quality assurance records transmittal, retention, and maintenance subsequent to completion of work at the power station have been established and are documented in station administrative procedures.

Quality Assurance records relating to the operating status of the station and documentary evidence of the quality of items and activities affecting quality are maintained in accordance with the Technical Specifications and station administrative procedures.

These records include plant history; operating logs; principal maintenance and modification activities; Licensee Event Reports; results of reviews, inspections,

tests, audits, and material analysis; monitoring of work performance, qualification of personnel, procedures, and equipment; and other documentation such as

drawings, specifications, procurement documents, calibration procedures and reports, deviation reports, and corrective action reports.

Identification and retrievability of these records is facilitated through proper indices and an established basic filing system.

Record storage facilities are constructed, located, and secured to prevent the destruction of records by fire, flooding, theft, and deterioration throngh environmental conditions such as temperature and humidity.

The Quality Assurance Department monitors these records to assure thei-completeness, adequacy, retrievability, and protection.

They periodicall, audit these records to verify implementation of established policies and procedures.

The record storage facilities conform to Regulatory Guide 1.88, Rev. 2 October 1976, as stated in Table 17. '. 0.

i 17.2-89

17.2.18 AUDITS The system of audits devised to verify compliance with quality related aspects of the power station is described in the station Technical Specifications. Additional audits may be performed as deemed necessary by company management.

The general audit policy specifies that quality assurance audits be conducted in accordance with a formal preplanned and scheduled system to ensure an adequate and meaningful quality assurance / control program is in effect.

l The Quality Assurance organization is delegated the responsibility for conducting periodic audits to determine the adequacy of the station's programs and procedures, that they are meaningful, and comply with the overall Quality Assurance Program.

An audit includes an objective evaluation of quality related practices, procedures, and instructions; the effectiveness of implementation; and the conformance with policy and directives. An audit also includes the evaluation of work area, activitica, processes, and items and the review of documents and records.

Provisions are established requiring that audits be performed in those areas where the requirements of Appendix B to 10 CFR 50 ate being implemented.

These areas include as a minimum, but are not limited to, those activities associated with operation, maintenance, modification, and repair controls; the preparation, review, approval, and control of design changes, procurement documents, instructions, procedures, and drawings; receiving and plant inspections; indoctrination and training programs; the implementation of the operating and test procedures; and the remaining criteria in Appendix B to 10 CFR 50.

l The Supervisor - Quality or designee directs audits to be conducted.

The audits are regularly scheduled on a formal pre-planned audit schedule; the scope and frequency are determined by quality status and safety importance of the activities being performed.

Additional audits may be performed as deemed necesscry by the Management Safety Review Committee, Manager - Quality Assurance or the Supervisor - Quality as conditions warrant. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with prepared and approved audit plans or checklists.

The results of each audit are reported in writing to the distribution delineated in accordance with station Technical Specifications.

Additional internal distribution is made to other concerned management levels in accordance with approved procedures.

Management responds to all audits and initiates corrective action where indicated. Where corrective action measures are indicated, documented follow-up of-applicable areas through inspections, review, re-audits, or other appropriate means is conducted to verify implementation of asnigned corrective action.

I'/.2-90

If the Supervisor - Quality determines the response to an audit is unacceptable or if a response is not received in the time allotted or if corrective action is not accomplished as indicated on the response, the matter is brought to the attention of the Manager - Quality Assurance who notifies the Station Manager or appropriate Corporate Manager for resolution.

If the Manager - Quality Assurance does not agree with the resolution proposed, he notifies the Manager - Nuclear Quality Assurance for referral to appropriate levels of management in accordance with established escalation procedures.

The responsibility for analyzing audit reports for trends and effectiveness lies with the Manager - Quality Assurance.

As trends are discovered or if the effectiveness of the program is in question, the analysis of the Manager - Quality Assurance is forwarded to the management level consistent with the seriousness of the problem.

17.2-9l

Discussion of' Revision to Biennial Procedure Review Requirement t

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REVISION TO BIENNIAL PROCEDURE REVIEWS ANSI Standard N18.7 requires that all safety related procedures be reviewed on a biennial basis. The intent of a biennial procedure review requirement is to provide a systematic program for ensuring the best possible procedures. Our OA Topical Report currently commits us to follow ANSI N18.7. However, the ANSI standard is flexible enough to allow the modification of this requirement based on the following:

ANSI N18.7 states that the frequency of reviews may vary depending on the type and complexity of the activity involved and may vary with time as a given plant reaches operational maturity.

ANSI N18.7 also states that the procedures in current use provide the best possible instructions for portormance of the work involved, systematic review and feedback of infctmation based on use is required.

Therefore, it is our interpretation that ANSI N18.7 was set up to require new plants to review procedures more often than a plant which has reached operational maturity (as our plants have), the requirement then focus on maintaining the best possible procedures through systematic feedback.

We are currently implementing a procedure upgrade program. The upgrade program provides a systematic and effective process for developing and revising procedures which encompasses the intent of the biennial procedure review requirement.

The procedure upgrade program provides for a more thorough review than that currently available through the biennial review. The procedure upgrade program review includes consideration of factors such as technical issues, human factor concerns and vendor recommendations. Procedures that have been through the upgrade program are quality documents. Given this, it is clear that the sooner the program can be completed, the sooner we have much higher quality safety-related procedures in use. Therefore, management has decided that the best use of available resources is to direct them in support of the upgrade program.

Based on the guidance provided in ANSI N18.7 and the intent of the procedure upgrade program we are revising the current biennial procedure review requirement to be a periodic procedure review requirement. The period will be established as four years. This change to a periodic procedure review will permit the maximum utilization of existing resources in support of the procedure upgrade program. However, to assure that the periodic review is not adversely affecting procedure quality and that the upgrade program is maintaining high quality, we will periodically assess a sample of procedures (both non-upgraded and upgraded) to verify that more frequent procedure reviews are not necessary. Changing the OA Topical Report as shown in Attachment 2 page 17.2-14 will allow the flexibility to revise the period for procedure reviews if need be, without further OA Topical Report changes, based on the results of those assessments.

_ _ _ _ _ _ _ _ _ _ _ _