ML20079G939
| ML20079G939 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/30/1983 |
| From: | BOSTON EDISON CO. |
| To: | |
| Shared Package | |
| ML20079G937 | List: |
| References | |
| NUDOCS 8401230237 | |
| Download: ML20079G939 (44) | |
Text
_.
, 1 ORGANIZATION 1.0 PURPOSE This section describes the Nuclear Organization and other organizational units of Boston Edison Company (BEco) involved in the operation of Pilgrim Nuclear Power Station (PNPS). In addition, it describes the responsibilities governed by the Quality Assurance Program.
1.1 Oraanization The BEco Nuclear Organization is depicted in Figure No. 11-1-1, and the BECo Nuclear Quality Assurance Organization is depicted in Figure No. 11-1-2. The organization for Pilgrim Nuclear Power Station is further detailed in the Technical Specifications.
Changes in Boston Edison's Nuclear Organization are reported to the Nuclear Regulatory Commission in accordance with the Technical Specification requirements. Quality related activities associated with the operational phase of ..uclear power plants are performed primarily by the Nuclear Organization. These operational phase activities are governed by the requirements established in the Boston Edison Quality Assurance Manual (BEQAM) for Operation of Nuclear Power Plants. Other Departments within Ecston Edison that are subject te certain requirements of the BEQAM are:
(a) Purchasing Department (b) Stores Department (c) Engineering, Planning and Research Department, Testing and Standards Section Boston Edison has established the following committees which arform quality related functions:
Nuclear Safety Review and Audit Committee (NSRAC)
Operations Review Committee (ORC)
The makeup, qualifications, and responsibilities of tliese committees are described in the Technical Specifications for the nuclear power NSRAC members are appointed by plant and/or in Committee charters.
the Senior Vice President (Nuclear).
The coroorate organization is more fully described in Boston Edison's Bulletin Book, Section A. Revisions or additions to the Bulletin Book are controlled by the Chief Executive Officer of
- Boston Edison Co9pany.
Rev. 9 11-1-1 Date: 12/30/E E401230237 840112 PDR ADOCK 05000293 PINT l
' a
., 1 1.2 Kev Manaaement Responsibilities and Authority 1.2.1 Executive Office The Chief Executive Officer is the Chairman of the Board of Directors. He is subject to the direction of the Board, and he supervises the administration of the business and affairs of the corporation. He is k member of the Executive i Committee of the Board of Directors.
The President has such powers and duties as may from time to time be prescribed by the Board of Directors or the Chief Executive Officer. During the absence or inability of the CEO, the President shall possess all the powers and performs all the duties of the CEO. The President is also a member of the Executive Committee of the Board of Directors.
The Senior Vice President is a senior corporate officer responsible for the administration and conduct of Company business relating to specific areas es assigned within the Executive Office.
1.2.2 Senior Vice President - Nuclear The Board of Directors has designated a Senior Vice President as the corporate officer with responsibility and authority to manage and direct the Nuclear Organization. He is responsible for all activities related to the operation of PNPS and reports to the Chief Executive Officer. He is responsible to establish overall policies and to assure ,
effective implementation of those policies. Boston Edison has established a Quality Assurance Program to implement the requirements in Appendix B to 10 CFR Part 50 and the Senior Vice President is assigned responsibility for assuring that the Program is aggressively implemented. He has delegated responsibilities and authorities to accomplish required activities according to his written policies.
l The Senior Vice President - Nuclear is designated as the officer to whom defects and non-compliances relating to nuclear safety hazards are to be reported and is designated as the officer responsible for notifying NRC of defects and non-compliances when required by 10 CFR Part 21. The assignment of corporate responsibilities for implementation of 10 CFR Part 21 is more fully described in Boston Edison Company's Bulletin Book, Bulletin B-2. .
(
11-1-2 Rev. 9 Date: 12/30/83
_-,---.%--,,----*v,--- - , ,me.r. , - . - _w , . - - - . . m , . - . , - , . - _ _ - . - y,- r . - , , - _ , - - - - , _ - - -_ _ _ _ _ _ _ _ _ - .
The following Vice President, Dir6ctors, and Managers report to the Senior Vice President:
-(1) Vice President-Nuclear Engineering and Quality Assurance (2) Director of Nuclear Operations (3) Director, Nuclear Operations Review (4) Director Outage Management (5) Planning, Scheduling and Cost Control Management 1.2.3 Director of Nuclear ODerations The Director of Nuclear Operations is responsible for all activities related to operation and maintenance of FNPS. He is responsible for establishing procedures and controls to aasure that requirements of the BEQAM are effectively implemented by Departments within his organization.
The Director of Nuclear Operations is responsible to develop, l maintain and control interdepartmental Nuclear Operations Procedures (NOP'S). The QA Manager reviews each NOP to assure that the described quality-related activities meet the requirements of the BEQAM.
The following departments report to the Director of Nuclear Operations:
(1) Nuclear Operations Department (2) Nuclear Operat?ons Support Department (3) Nuclear Management Services Department
! (4) Nuclear Training Department 1.2.4 Vice President-Nuclear Engineerina and Quality Assurance The Vice President-Nuclear Engineering and Quality Assurance
(. is responsible for all activities related to engineering and design for PNFS, including design changes and plant modifications. He is also responsible to oversee implementation of those quality assurance and quality control activities assigned to the Quality Assurance Department by the Senior Vice President (Nuclear). ,
11-1-3 Rev. 9 Date: 12/30/82
The following departments report to the Vice President-Nuclear Engineering and Quality Assurance:
(1) Nuclear Engineering Department (2) Quality Assurance Department 1.2.5 Qualitv-Related Responsibilities Common to All Department Manaaers and Directors Each of the Department Managers and Directors identified have certain quality-related responsibilities in common, as follows:
- Provide and implement policies and procedures for all quality-related activities which fulfill the requirements of this manual; ensure policies and procedures applicable to quality-related activities are approved by the QAD.
- Choose qualified, corpetent personnel to maintain a staff adequate to perform all quality-related activities. Identify indoctrination and training needs and ensure they are fulfilled; coordinate training with the Nuclear Training Department. Evaluate the performance of personnel and take required actions.
- Provide the means and conditions (e.g., facilities, tool:,
supplies, etc.) to allow personnel to carry out quality-related activities within the constraints of corporate budget controls. 1 Ensure coordination of activities acrcss the interfaces with other departments and organizations.
- Be cognizant and maintain departmental awareness of applicable regulatory requirements, as well as BECo commitments and related industry codes and standards.
i
- Recognize, obtain, evaluate, and act upon feedback information, from internal and external sources, to improve management controls and personnel performance. Apprise upper management of activities and potential and actual problems.
Communicate and resolve problems with other departments.
Take corrective action when it is warranted, including measures to prevent problem recurrence.
The furctional roles and responsibilities of departments and organizational units that implement tne QA program are more fully described in Nuclea Operations Procedures, department pnocedures, or charters approved by appropriate levels of management.
11-1-4 Rev. 9 Date: 12/30/83
1.2.6 Director of Outaae Manaaement The Director of Outage Management is responsible to coordinate planning and to direct scheduled plant outages .
necessary to maintain, modify, and refuel the plant. -
1.2.7 Plannina. Schedulina and Cost Control (PS&CC) Manager Tiie PS&CC Manager is responsible for plaqaing, scheduling, and cost control services and for coordinating procurement interfaces between the Nuclear Organization and the Purchasing Department. ,
1.2.8 Nuclear Operations Department (N00)
The Pilgrim Station Manager is head of the Nuclear Operations Department and is responsible for the overall safe, relicble, and economic operation of PNPS in accordance with corporate poli:1es and regulatory requirements.
1.E.9 Nuclear Operations Support Department (NOSD)
, The Nuclear Operations Support Department is responsible for certain on-site activities which support the Pilgrim Station Manager and the Vice President-Nuclear Operations.
1.2.10 Nuclear Manaaement Services Department (HMSD)
The Nuclear Management Services Department is responsible for certain on and off-site activities which support the Pilgrim Station Manager ar.d the Vice President-Nuclear Operations.
The Department is responsible for maintenance and control of the Facility Operating License and the PNPS Final Safety Analysis Report, and for Records Management / Document Control activities for the Nuclear Organization.
1.2.11 Nuclear Trainino Department (NTO)
The Nuclear Training Department is responsible to establish and corrdinate implementation of a training progran, for all Boston Edison personnel who perform quality-related I activities. This overall program shall indoctrinate all ,
personnel in the Boston Edison Quality Assurance Program for '
PNPS arid other management co'ntrols, and provide suitable training to permit personnel to perform their assigned ,
activities. It includes special gealification training and certification activities, as required. Training !
responsibilities assigned to other managers are carried out l within the framework established by this program., l 11-1-5 Rev. 9 Date: 12/30/83 ;
6 l
.1.2.12 Nuclear Encineerine Department (NED) t The Nuclear Engineering Department is responsibic for engineering and design activities and construction associated with plant design changes and modifications, including safety evaluations required by 10CFR50.59. It is also responsible for all engineering evaluations (e.g., studies, analyses, reviews) to support PNPS operation, maintenance, and refueling. These responsibilities include establishment and maintenance of a system to incorporate approved design changes into engineering documents.
1.2.13 Quality Assuragee Department (OAD)
The Senior Vict President (Nuclear) has delegated suthority and responsibi;L'y for directing and administering the Quality Assurance Program to the Manager of the Quality Assurance Department. Specifically, the Quality Assurance Department is accountable for:
- Establishing, maintaining, and assuring the implementation of a Quality Assurance Program, which effe tively complies with 10CFR50, Appendix B, Nuclear Organization's policies.
- Providing feedback to responsible management on compliance to and effectiveness of the Quality Assurance Program; in addition, making an oral report to the Chief Executive Officer approximately every 6 months, and providing summary reports of internal audits (Section 16) and trend analysis reports (Section 16) to the CEO.
- Establishing, maintaining, and implementing an effective quality control function for the Nuclear Organizations.
- Assuring that all operational phase activities falling within the scope of the QA Program are prescribed by and implemented according to detailed, approved precedures, and that these i
procedures provide effective management controls.
- Preparation, revision, and control of the Boston Edison Quality Assurance Manual (BEQAN), which is the primary quality assurance document.
In order to implement these responsibilities, the Quality Assurcnce Manager is provided with "Stop Work" authority whereby he can
' suspend any quality related activity or process which may, in his opinion, adversely affect the safe operation of Pilgrim Nuclear Power Station. .
11-1-6 Rev. 5 Date: 12/30/83
-m-.,,._ _.. _, ,, , _ . . . . - . -, ,-,.--_-...._..,.,,.____,_.._,,_.,_,,,,,,.,,__._,-m,-_~ m,,,.,.,_.mmmm,c,,--,,y ..,-r.
QAD personnel have sufficient authority and organizational freedom ,
to identify quality problems; initiate, recommend, or provide solutions through designated channels; and verify implementation of solutions. The QA Manager and his cubordinates communicate directly with cognizant Department Managers and responsible personnel for the identification and resolution of deficiencies, i
! The QAD-Manager is responsible for the review, evaluation and .
approval of selected contractor, supplier, and engineering service organization quality assurance programs prior to the issuance of
- BECo Purchase Orders / Contracts. After award of BECo Purchase Orders / Contracts, he is responsible for performance of audits and source / surveillance inspections, as appropriate, at contractor,
! supplier, and engineering service organization facilities to assure l compliance with BECo Purchase Order / Contract requirements.
The Quality Assurance Manager is responsible to review all procuremeret requirements, including technicd1 and quality assurance requirements of specifications, preliminary procurement documents, l
and supplier exception / deviations, to en;ure proper consideration and incorporation of quality assurance and quality control requirements.
The QAD is responsible to establish and maintain the Inscrvice Inspection and Test Program required by ASME Section XI and the PNPS Technical Specifications.
1.2.14 Purchasina Department
- The Purchasing Department is responsible to coordinate l
procurement of items and services required for PNPS including approval of commercial conditions associated with procurement activities. The Purchasing Department is not authorized to
' change technical and quality assuranca requirements specified by the department requesting procurement action. The Purchasing Department is responsible to implement procedural controls according to requirements established in the BEQAM.
i 1.2.15 Stores Department The Stores Department is responsible to coordinate preparation of purchase orders for material based on approved preliminary procurement documents and is also responsible to receive, store, and control purchased material before it is released to PNPS. The Stores Department is not authorized to ,
change technical and quality assurance requirements specified by the department requesting the procurement action. The
' Stwes Department is responsible to implement procedural controls according to requirements established in'the BEQAM.
1 11-1-7 Rev 9 Da:e: 12/30/8:
1.2.16 Engineerina. Planning and Research DeDartment. Testing and Standards Division The Testing and Standards Division is responsible to direct and coordinate the activities within the Testing and Standards Section and to implement the requirements of the BEQAM related thereto.
11-1-9 Rev. 9 Date: 12/30/83
.v- --'
g e- ?e -- - - e--r- -e - -- --
- - -, -'m w - --
I g e
n
, CHIEF EXECUTIVE ' BOSTON EDISON COM'ANY '
OFFICER NUCLEAP ORGANIZATION l
c .
1 '
I e PRESIDENT
. i e
- I '.
I e l SENIOR s i
e VICE '
' EXECUTIVE NUCLEAR PRESIDENT NUCLEAR e OFFICE SAFETY y .
- H REVIEW :
AND AUDIT
J l h t's COW 4tTTEE 1
w s Y I I g
I VICE PRESIDENT H DIRECTOR DIRECTOR NUCLEAR OF PLANNING SCHEDULING & DIRECTOR NUCLEAR ENGINEERitG &
NUCLEAR COST OUTAGE OPERATIONS QUALITY OPERATIONS MANAGEMENT REVIEW ASSURANCE CONTROL MANAGER '
a I I
- i i i NUCLEAR QUAllTY NUCLEAR NUCLEAR ENGINEERING ASSURANCE NUCLEAR OPERATIONS NUCLEAR i MANAGEMENT DEPARTMENT DEPARTMENT SERVICES OPERATIONS SUPPORT TRAINifG DEPARTMENT DEPARTMENT DEPARTMENT DEPARTE NT l
E OPERATIONS i EE REVIEW COW 4lTTEE E.. .i 1
3 i R l 0
4 Organizaffon Chart NUCLEAR QUALITY ASSURANCE -
1 I
NUCLEAR QU ALITY l
ASSURANCE MANAGER
. l I
Cont. Secretary Clerk til l
]
0
_ _ _ _ _ . . . - . l____ y _
l m ISI Group Leader
- Quality Engineering Audit Group Operations Quality l l Cnntrol Group Leader ,
Le Group Leader Leader l
g 1
Sr. OA Engineer 3r OA Enqineer office Assistest VI St OC Engineer uptt.,an,, ,,i E ng,ree, e Sr OA Engineer Sr OA Engineer l OA Enqineer St OC Enqincer St. OC Engineer S. Mr.r ti i nn, G A E ngineer OA Engineer OC Engineer Sr. OC Engineer ISI En pneer Sr Rel. Assur Engt. l OC Enqincer Sr OC Engineer On Engineer Sr OA Enqineer l
OC Enepncer OC Ennincer ,
[$
r* 4 Sr OA Engineer l
8 ,
- f. *
- Sr GA Engineer OC Enginer e w* Sr OC Inipneer i Q u
l '
O
% t G i l
W l e I
a a . . . . , n e- e- ret nnefut
OUALITY ASSURANCE PROGR_AM 2.1 PURPOSE This section establishes requirements for the Boston Edison Quality Assurance Program for operation of PNPS, the app ~icability of the i program, and the indoctrination and training program to ensure its proper implementation and offectiveness.
2.2 POLICY A Statement of Policy, which was signed by the President, establishes the overall quality assurance policy of the Boston Edison Company (BECo). This statement sets the goal of safe and reliable operation of PNPS: commits the Company to a quality assurance program designed to ensure compliance with regulatory requirements, Compar.y commitments, and established practices for efficient plant operation; and requires every person involved in quality assurance program related activities to comply with the provisions of the program. Employees should refer to Boston Edison Company Bulletin B-5 for specific details of this corporate quality assurance policy.
2.3 PROGRAM REQUIREMENTS 2.3.1 The Boston Edison Quality Assurance Manual (BEQAM) for Operation of Nuclear Power Plants establishes the Quality Assurance Program applicable to operation of Pilgrim Nuclear Power
, Station. The requirements in the BEQAM were established to comply with the requirements of Title 10, Code Federal Regulations, Part 50, (10 CFR 50), Appendix B, " Quality Assurance Criteria for Nuclear Power Plants" and are structured
-in accordance with its eighteen criteria.
This program requires implementing procedures to be written.
These procedures may be prepared as Nuclear Operations Procedures (NOP's), Department Procedures, or Group
! procedures / instructions. Specific assignment of responsibilities for executing and controlling activities j related to the program are identified in these procedures.
Operational phase activities falling within the scope of the QA l Program categorically include: designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, training, and modifying.
Changes to the BEQAM era controlled in accordance with the *
, requirements of 10 CFR 50.54(a).
I 11-2-1 Rev: 12 Date: 12/30/83
1 Operational phase activities are also centro 11cd in accordance
- with the requirements of the Facility Operating License No.
- OPR-35 for the Pilgrim Nuclear Power Station and 10 CFR 50.59 requirements.
2.3.2 This QA Program conforms to the following NRC Regulatory Guides and associated ANSI Standards to the extent that they are ,
applicable to operational phase activities: ,
Regulatory Guide 1.8 Personnel Selection Rev. IR,1975 and Training ,
(ANSI N18.1-1971/ANS3.1)
Regulatory Guide 1.33, Rev. 2 QA Program Requirements 1978 (Operational) !
(ANSI N18.7-1976/ANS 3.2)
Regulatory Guide 1.64 QA Program Requirements Rev. 1, 1975 for the Design of Nuclear
( ANSI N45.2.11-1974) Power Plants Regulatory Guide 1.88 Collection, Storage and Rev. 2, 1976 Maintenance of Nuclear Plant
( ANSI N45.2.9-1974 Quality Assurance Records Regulatory Guide 1.123 QA Requirements for Control of Rev. 1, 1977 Procurement of Equipment,
( ANSI N45.2.13-1976 Materials and Services for Nuclear Power Plants Regulatory Control 1.144 QA Program Auditing Rev. 1, 1980 Requirements for (ANSI N45.2.12-1977) Nuclear Power Plants i ANSI N45.2.1E Requirements for the (IEEE Std. 498-1975) Calibration and Control of Measuring and Test Equipment used in the Construction and Maintenance of Nuclear Power Generating Stations Regulatory Guide 1.146 Qualification of Quality 1980 Assurance Program Audit
( ANSI N45.2.23-1978) Personnel for Nuclear Power Plants l
l i .
11-2-2 Rev. 12 Date: 12/30/83 l
-_.._n._ _ _ _ - , _ _ . . - _ _ . ~ _ _ . _ - . . - _ . - . . . . _ . , . _ . _ . _ . . . . , _ . - - _ , _ _ _ _ , _ _ . , , , ._ ____ _
Regulatory Guide 1.58 Qualification of Nuclear Power Rev.1 (9/80) Plant lidpection, Examination (ANSI N45.2.6-1978 and and Testing Personnel ASNT-SNT-TC-1 A-1975) 2.3.3 Certain plant modification work can be expected to be comparable in. nature and extent to related activities during the initial design and construction of the plant. The requirements of this manual and the current implementing procedures may need to be supplemented or replaced for such work. The Quality Assurance Manag( r will review upcoming modification work and shall determine whether a Project Quality Plan is needed for a specific modification.
When needed, the Project Quality Plan is developed before modification work begins at the plant. The Project Quality Plan is prepared with appropriate input assistance from other managers. It describes the activities included in the work, and identifies requirements which differ from, or are in addition to, the requirements in this manual. It identifies participating organizations and their interfaces, and the governing procedures which implement the QA Program. Each Project Quality Plan is approved by the Quality Assurance Manager.
2.3.4 The following Regulatory Guides and Standards, in addition to those listed in paragraph 2.3.2, contain requirements which will be applied to those construction related activities associated with nejor modifications during the operaticnal phase that are comparable in nature and extent to related activities occurring during initial plant design and construction:
Regulatory Guide 1.28 QA Program Requirements Rev. 2,1979 (Design and Construction)
Regulatory Guide 1.30 QA Requirements for the Rev. O, 1973 Installation, Inspection and
( ANSI N45.2.4-1972) Testing of Instrumentation and Electric Equipment Regulatory Guide 1.37 QA Requirements for Cleaning Rev. O, 1973 of Fluid Systems and (ANSI M45.2.1-1973) Associated Components of Water Cooled Nuclear Power Plants Regulatory Guide 1.38 QA Requirements for Packaging Rev. 2, 1977 Shipping, Receiving, Storage (ANSI N45.2.2-1972) and Handling of Items for Water-Cooled NucJear Power Plants 11-2-3 Rev. 12 Date: 12/30/83
l l
l Regulatory Guide 1.39 Housekeeping Requirements for l Rev. 2, 1977 h ter-Cooled Nuclear Power (ANSI N45.2.3-1973) Plants Regulatory Guide 1.54 QA Requirements for Protective Rev. 0, 1973 Coatings Applied to Water- !
(ANSI N101.4-1972) Cooled Nuclear Power Plants '
Regulatory Guide 1.55 Concrete Placement in Rev. 9,1973 Category I Structures Regulatory Guide 1.'ir QA Terms and Definitions Rev. O, 1973 (ANSI N45.2.10-1973)
Reguistory Guide 1.94 QA Requirements for Rev. 1, 1976 Installation, Inspection ind (ANSI N45.2.5-1974) Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants Regulatory Guide 1.116 Quality Assurance Requirements Rev. 0-R, 1977 for Installation, Inspection (ANSI N45.2.8-1975) and Testing of Mechanical Equipment and Systems 2.4 PROGRAM APPLICATION 2.4.1 The BEQAM is applied to activities affecting structures, systems, and components which have been designated safety related because they prevent or mitigate the consequences of postulated accidents which could cause undue risk to the health or safety of the public. Structures, systems, and components which are designated as safety related are identified on the Q-Li e (in Sections II and III).
2.4.2 In addition, the Q-List includes (in Section IV) other structures, systems, and components for which the Director of Nuclear Operations and the Vice President-Nuclear Engineering and Quality Assurance have agreed to use the management controls and implementing procedures of this QA Program for the control of selected work activities, i
2.4.3 The BEQAM is also applied to activities affecting fire protection systems and equipment required to limit fire damage to safety related structures, systems, ar.d components so that the capability to safely shut down the plant is ensured.
Applicable fire protection systems and equipment are. identified on the Fire Protection List, Specification M-504. -
11-2-4 Rev. 12 <
Date: 12/30/83
,-+-y-,-- - -----w.,. e w. - , - - ...-e v - em,w w- - - - -- , - .
r----+-----,--we-----,-c.-rw-,--e--ww,- e w e wgt-- ea w---sm-- m- m e- w e ,-- n-v
4 2.4.4 In acCordance with the requirements of 10 CFR 71.51, the BEQAM is also applied to Boston Edison activities, including procurement activities, related to delivery of licensed material to a carrier for transport under the license provisions of 10 !
CFR 71.12. Applicable : hipping containers or transport packages are identified on the 10 CFR 71.12 Licensed Shipping Container
. List. l 2.4.5 Those structures, systems, and components and related activities :
to which this BEQAM applies, as identified above, are commonly referred to as "Q'.
2.4.6 Provisions have been made for establishing and maintaining the Q-list and the Fire Protection List under the control of the Nuclear Engineering Manager.
2.4.7 Provisions have been made for establishing and maintaining the 10 CFR 71.12 Licensed Shipping Container List under the control <
of the Pilgrim Station Man:ger.
2.4.8 To thS extent necessary to ensure the quality procured items and services, suppliers and subsuppliers are required to provide i quality assurance programs which implement the pertinent provisions of 10 CFR 50, Appendix B. Specification of this 1
requirement and evaluation of supplier quality assurance ;
i programs by the QAD are covered in Section 4.
2.5 PROGRAM CONTROL 2.5.1 The Quality Assurance Manager is responsible for establishing and maintaining the BEQAM and for assuring the implementation of a Quality Assurance Program which effectively complies with 10
' CFR 50 Appendix B, 6pplicable codes and standards, and corporate policies.
i 2.5.2 Proposed revisions to the Boston Edison Quality Assurance Manual are prepared by BEco personnel based on predetermined need and ',
NRC reguistory requirements and guides using a Boston Edison Quality Assurance Manual Change Request, Exhibit 11-2-1. .
The Quality Assurance Department is responsible to review each :
Change Request to verify conformance with QA Program requirements and to control BEQAM changes in accordance with the requirements of 10 CFR 50.54(a). The resulting Change Requests are approved for implementation by both the Vice President -
Nuclear Engineering and Quality Assurance and the Director of Nuclear Operations after approval by the Quality Assurance Manager. .
f 11-2-5 Rev. 12 Date: 12/30/83
(
Holders of controlled Boston Edison Quality Assurance Manuals
~
are responsible tor insertion of the latest revisions in their assigned Manuals, and are required to sign 6nd retura the revision transmittal form thereby acknowledging receipt.
2.5.3 The Quality Assurance Program is implemented using procedures prepared and controlled according to BEQAM Section 5. Review and approval by the QA Department is required to assure compliance with BEQAM requirements and for ensuring that such procedures are approved by the QAD prior to use. ;
2.5.4 The Nuclear Training Department is responsible to establish and i coordinate implementation of a training program for all Boston ,
Edison nuclear persannel who perform quality-related i activities. This overall program shall indoctrinate all personnel in the Boston Edison Quality Assurance Prcaram for PNPS and other management controls, and provide suitable training to permit personnel to perform their assigned activities. It includes special qualification training and certification activities, as required. Training responsibilities assigned to other managers are carried out within the framework established by this program.
Department Managers and Directors are responsible for assuring that their personnel are adequately trained and proficient in the use of department procedures approved by the Quality i Assurance Manager and that training is perforned and scheduled in compliance with the requirements of the Boston Edison Training Program.
2.5.5 Implementation of an aggressive Quality Assurance Program is essential to achieve the goal of continued safe and reliable operation of the Pilgrim Nuclear Power Station. Each person involved in quality related activities concerning design, construction, preoperational testing, operation and maintenance of PNPS is responsible for attaining quality in his/her work and 4 for compliance with the requirements of the applicable quality assurance approved procedures. Each person is also responsible for promptly reporting to his/her supervisor whenever a noncompliance with a QAD approved procedure occurs and whenever j a potential unsafe condition is recognized. i i
2.5.6 Audits are conducted by QAD on a regularly scheduled basis to assure compliance with established BEQAM requirements, and the results of these audits are reported to responsible ranagement personnel.
11-2-6 Rev. 12 Date: 12/30/83 l
- - . = = . -- . - -
Surveillance monitoring of PNPS operational phase activities is conducted by QAD on a planned and scheduled basis to assure compliance to OA program and procedure requirements, and to assess the effectiveness of performance.
Periodic trend analysis of identified conditions adverse to quality is performed by QAD to determine if significant adverse trends exist, and to initiate appropriate corrective action.
If a differer.ce of opinion arises between Quality Assurance personnel and those of another department, resolution is first attempted by the Quality Assurance Manager and the other
! cognizant manager. If a solution acceptable to the QA Manager cannot be obtained, the matter shall be promptly referred by the
- QA Manager to the Vice President-Nuclear Engineering and Quality '
Assurance for resolution. If a resolution acceptable to the QA Manager is not obtained after it has been referred to the Vice President, the matter shall be promptly referred by the QA Manager to the Senior Vice President (Nuclear) and, if necessary, to the President, for resolution.
2.5.7 The scope, implementation, and effectiveness of the Boston 4
Edison Quality Assurance Program is assessed at least biennially, the results are reported to the NSRAC and to upper l
+ management (vice presidents and above).
2.5.8 Conditions adverse to quality are evaluated for significance 1 according to criteria contained in Sections 16 of this manual.
Significant trends adverse to quality are identified by trend :
analysis. Significant conditions adverse to quality are !
dispositioned according to Sections 16 and 18. !
i L i 4
11-2-7 Rev. 12 Date: 12/30/83
- - - - - , -- -. - - - , . - . - . - . . - . . . -.w.--.---4 -.--...--,.---.wm- .,,-e_,----..-,,,..---w
--- . - . . - - . , - ~ - - _ - - . + - < . ~ , - - - . .
BOS1DN
~
l EDISON QUALITY ASSURANCE MANUAL CHANGE REQUEST VOLUME SECTION PARAGRAPH NO. PAGE N0. REV. NO.
REVISION (Exact Wording)
PURPOSE OF REVISION ORIGINATOR DATE APPROVAL SIGNATURES:
QUALITY ASSURANCE MANAGER DATE VICE PRESIDENT-NUCLEAR ENGINEERING & QA DATE DIRECTOR OF NUCLEAR OPERATIONS DATE Exhibit 11-2-1 Rev. 12 Date: 12/30/83
m
'(QAl-A43)~
PROCUREMENT DOCUMENT CONTROL 4.1 ~ PURPOSE-
-This section establishes the requirements for preparation. - review,
. approval and control of procurement documents for items and services to
' assure applicable technical' requirements and quality assurance require-
--ments are included and that spare or replacement. parts are subject to controls at least equivalent to' those used for the original equipment.
'4.2: PROCUREMENT' PROCESS 4.2.1 . Preliminary procurement documents prepared for equipment, parts and services shall include appropriate technical requirements, and QAD-approved quality assurance requirements. In addition, these documents shall specify when quality category Q applies and identify any other specific or special requirements; in particular, storage level, shelf life, and storage maintenance requirements. Additional infonnation to be provided shculd in-E clude as appropriate:
a) Applicable Specifications and Drawings b) Regulatory Requirements
-c) Componeit Identification Requirements (including Q List No.)
d) Applicable Codes and Standards e) Test and Inspection Requirements f) Documentation Requirements (See Paragraph 4.2.2) g) Special packaging, shipping, and handling requirements.
h)- Installation, Operating and Maintenance manuals, including Preventive Maintenance -Instructions i) Suggested Suppliers based on QAD's Approved Suppliers List
> 4.2.2 The originator of the preliminary procurement documents shall identify any documentation required to be submitted by the
~
supplier, including documentation to be submitted to SECo. for
- ' review and approval and documentation to be submitted for i acceptance of the items or service. Required documentation
' shall also include documents to be provided to BECo. for records retention purposes.
For-quality category Q items and services, supplier documenta-
- tion for acceptance may be a Certificate of Conformance, unless requirements of the applicable Codes and Standards preclude this option (i.e. , more specific documentation is called for).
If a Certificate of. Conformance is required, the procurement >
documents shall also specify that the Certificate of Confor-mance must meet the requirements given in Exhibit 11-4-1. In addition, the originator shall determine if additional docu-mentation is required from the supplier to support the Certifi-cate of Conformance; and identify any suc'i documentation in the procurement documents.
Rev. : 11 II-4-1 Date: 12/30/83
r ,
2 (AQl-A44) l 4.2.3 Preliminary procurement documents shall be reviewed to ensure proper !ientification of items and inclusion of appropriate technical requirements for items and/or services balng procured.
This review shall verify the quality catt
- and the completeness of the requirements.
4.2.4 Preliminary procurement documents for all items and services shall be submitted to QAD for review to ensure inclusion of appropriate quality assurance requirements.
4.2.4.1 li the praliminery procuremant documents require the supplier to submit a Certificate of Conformance, and BECo QA/QC will not perform source inspection (off-site),
surveillance inspection (on-sita), or audits, the QA reviewer shall identify acceptance inspections or tests by BECo, OQC which will verify the validity of the supplier's certificate and the effectiveness of his certification system.
4.2.5 The procurement' documents for spare or replacement parts are subject to controls at least equivalent to those applied for original equipment.
4.3 PURCHASE ORDERS /CONTPACTS 4.3.1 The procurement documents (Purchase Order and accompanying documents) shall be issued according to corporate policies and procedures and shall contain all the technical requirements and QA requirements specified by the Nuclear Organization. Added technical or quality assurance requirements and any changes to the issue Purchase Order /
Contract are subject to the same review, and approval as the origir.al preliminary precurement documents.
4.4 SUPPLIER QUALITY ASSURANCE PROGRAM EVALUATION AND APPROVAL
, 4.4.1 Evaluaticn of the Quality Assurance Programs of potential sucpliers of Q items and ser.icos shall be perforned by QAC or ty ctners wnen authorized by the QA Manager. For fire prctection systems and components, evidence of UL or FM approval will be accepted in lieu of supplier evaluation. An evaluation includes review of the supplier's QA Program Description and a survey of his implementation of that program before the supplier Initiates any activities af fected by the progran under a BECo P0. The supplier's QA Program Description is reviewed to ensure inclusior, of pertinent requirements of the BEQAM and 10 CFR 50, Appendix 8. The evaluation must be completed and the
, suoplier coproved by QAD. The names of approved suppliers are placed on the BECo QA-Approved Suppliers List which is maintained by QAD.
4.4.2 Q iteme and services may be procured from a supplier vrose quality assurance program has not been fully approved by BEco Ouality Assurance BECo Purchase Orders / Contracts to such a supplier must, however contain detailed supplementary quality assurance requirements to ensure the items and services meet the Purchase Order / Contract requirements.
These additional quality requirements are intended to address the reasons for no::-approval of the supplier, and may impose specific actions by the supplier or by BECo. The preliminary procurement documents are reviewed by QAD to assure additional actions are identi-fled as necessary to provide the required assurance the quality standards have been met, and to permit planning for QAD actions, such as source inspection and augmented receipt inspection.
Rev: 11 11-4-2 Date: 12/30/83
E n
(QAl-A45) 4.4.3 Certain Q items and services may be procured from a supplier without BEco Quality Assurance approval of the supplier's quality assurance program. Such items and services shall be designated " commercial quality control items". NED shall evaluate candidate items and services and justify the conclusion that, with no reliance on supplier quality assurance activities, BECo can establish the nonconformance of the item or service to the physical and functional requirements it must meet in use. The detailed requirements for BECo activities and acceptance criteria to assure the item or service meets the specified technical requirements must accompany the Purchase Order / Contract for internal BECo use. Such activities may include source and receipt inspection and physical and functional :
testing. The praliminary procurement documents are reviewed by QAD toi assure BECo actions are identified which will assure the acceptance {
criteria are met and to permit planning for QAD actions. Items and !
services designated " commercial quality control items" are identified by NED in the Q-List Manual,Section V, or the Fire Protection List, Specification M-504.
4.5 DEVIATION REQUESTS FROM BECo PURCHASE ORDER / CONTRACT REQUIREMENTS 4.5.1 When a Deviation Request is submitted by a supplier to BECo Purchasing, the cognizant BECo Purchasing Agent shall forward the Deviation Request to the Nuclear Organization for initial action. The Deviation Request, after it is approved / disapproved by the cognizant BECo Manager and reviewed by QA, is returned to the 3ECo Purchasing Depart- '
ment which notifies the supplier. The BECo Purchasing Department issues a change to the Purchase Order / Contract based on approved procurement documents revised to reflect the approved Deviation Request.
11-4-3 Rev: 11 Date: 12/30/83
m:
, (QAl-A48)
Requirements fac a Certificate of Conformance When a , Certificate of Conformance is required by the procurement documents to be submitted by the Supplier. .it shall:
- 1. Identify the purchased item or services by BEco's purchase order number.
- 2. Identify the specific procurement requirements met by the item or service, either by verbatim quotation of the requirements, or by specific reference to the document (s), and location (s) with the document (s), where the requirements are specified. The requirements identified must include any changes, waivers, or deviations, apprcved by BECo, which apply to the item or service.
- 3. Identify any procurement requirements that have not been met, and refer to the document (s) which record BECo's approval of the disposition of such nonconformances.
- 4. Be attested to by the person responsible for assuring the quality of the item er service, as described in the supplier's BECo - approved Quality Assurance "anual.
The supplier's Quality Assurance Manual, as approved by BECo's QA Department, shall describe the system to control Certificates of Conformance, including a procedure for ccmpleting the certificates which meetsthe above requirements, and a procedure for review and approval of certificates.
Rev.: 11 EXHIBIT 11-4-1 Date: 12/30/83
('QAl-A52)
INSTRUCTIONS.' PROCEDURES, AND DRAWINGS 5.I': PURPOSE This:section establishes .the requirements to assure that activities af fecting the quality of safety-related systems, structures, and components are delineated, controlled, and implemented.through usa of written Instructions, procedures, or drawings.
5.2 BECO QUALITY ASSURANCE PROGRAM-RELATED PRDCEDURES
~5.2.1 The requirements of this QA Program shall be implemented by Nuclear Operations Procedures (NOP's), issued by the VP-Nuclear Operations, and Procedures Department Procedures,the required to implement issued byleach BEQAM Department l are Manager.
called quality assurance program related. The QAD shall establish and maintain a controlled document, "BECe Procedures which implement the EEQAM 11 and ANSI 18.7-1976,"
which shall identify these quality assurance program related procedures.
5.2.2 Each quality-related activity shall be governed by an appropriate combination of procedures, instructions, and drawings. Requirements pertaining to drawings, including sketches, diagrams, schematics, and similar terms, are in Section 3. Detailed instructions may be provided in various ways controlled by quality assurance prcg am related NCP's or Department Procedures. This appropriate comoination of procedures, instructions, and drawings shall be identified in tre work authorizing documents and, in all cases, the management controls specified in approved NOP's and Department Procedures shall be imolemented.
5.2.3 Procedures, instructions, and drawings shall include appropriate quantitative and qualitative acceptance critaris, appropriate methods for' documenting or recording data obtained during the performance
- of the activity, sopropriate requirements for equipnent and instrumentaticn to be used, and suitable control fer environmental conditions.
5.2.4 Every new NOP and Departnent Procedure, unless exemoted by Paragrech 5.2.5, shall be submitted to the Quality Assurance Manager to determine if-the precedure is cuality assurance program related. if so, the Quality Assurance Department shall review The crocecure and all subseauent- revisions to assure the requirements of the Boston Edison Quality Assurance Manual are met. After review, the Quality Assurance Manager shall approve. If the procedure is determined to be not quality assurance program related, review by QAD and approval by the Quality. Assurance Manager is not required, and the procedure will be so marked by QAD. However, any major revisions (additions) to such a procedure will require the revised procedure to be submitted to the Quality Assurance Manager for review to determine if the revision makes the procedure quality assurance program related.
5.2.5 For PNPS Procedures,.all of tne procedures in Section I of the PNPS Procedures Manual ana selected Section 3 procedures shall be reviewed by the Quality Assurance Department and approved by the Quality Assurance Manager. The applicable procedures in Section 3 are listed in Exhibit 11-5-1. Although all of the PNPS Procedures in Sections 2-8 are quality assurance program related, only the selected procedures, which describe the overal.l implementation of the quality assurance program at PNPS will be reviewed by tho QAD and approved by the
-Quality Assurance Manager. .
Rev: 10-11-5-1 Date: 12/30/83
4, 5.2.6 Changes to procedures are' reviewed, approved, controlled, and distributed in the same manner as the original issue.
5.2.7 All maintenance and modification activities effecting Station structures, systems and components are controlled by the Maintenance Request system. All Maintenance Requests are reviewed by the Quality Assurance Department to assure that appropriate requirements are specified fcr quality relcted activities and to incorporate appropriate-quality control hold points.
5.3 SUPPLIER PROCEDURES 5.3.1 When the procurement documents require the supplier to submit precedures for BECo approval, the department which originated the procurement documents shall ensure the appropriate reviews and approvals are obtained. Reviews and approvals are required from those departments which would review and approve sinitar BECo procedures. In.particular, procedures for quality assurance '
and quality control activities'shall be reviewed by the QAD.
J Z
4 Rev: 10 ll-5-2 Date: 12/30/83
. I.
t .*
PNPS-l VOLUME lil QUALITY ASSURANCE PROGRAM RELATED STATION MAINTENANCE AND CALIBRATION PP00E0ucES 3.M.! GENERAL 3.M.l-l PREVENTIVE MAINTENANCE 3.M.1-l.1 Instrument and Control 3.M.1-l.2 Electrical 3.M.l-l.3 Mechanical 3.M.1-5 PROCUREMENT OF ITEMS AND SERVICES 3.M.1-5.1 Preparation of the Quality Verification Documentation List 3.M.l-7.1 Handling and Storagc of Material, Equipment, and Parts 3.M.l-7.2 Removal and/or Return of Inventoried Material, Equipment, Parts From Warehouse 3.M.1-8 DISPOSITION OF NONCONFORMING MATERIAL 3.M.!-10 Call 2 RATION AND CONTROL OF MAINTENANCE TOOLS AND EOUIPMENT 3.M.l-10.1 Torque Wrench Calibration 3.M.1-10.2- ' Linear f.'easurement Equipment Calibration 3.M.1-lO.3 Calibration of Non-Controlled Lab Equipment 3.M.2 INSTRU'.iENT AND CONTPOL 3.M.2-8.2 Pressure Working Standards Calibration 3.M.4 MECHANICAL 3.M.4-15 WELDING PROCEDURES 3.M.4-15.1 Welding Filler Material Control Exhibit.ll-5-1 Rev. 10 Page I of I Date: 12/30/83
CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICE
. 7.I PURPOSE This section establishes the requirements for control of purchased material and equipment (hereafter called items) and services to assurs conformance,to specified technical and quality assurance requirements. Measures to obtain objective evidence of quality
- furnished by suppliers include supplier evaluation and selection, audits and inspections av the source, and inspections and tests upon receipt.
7.2 _ GENERAL REQUIREMENTS 7.2.1 The quality of purchased items and services is assured by an appropriate combination of supplier and BECo activities which is decided during preparation and review of procurement documents as specified by the requirements of Section 4. When quality assurance activities by the supplier are specified, including provision of documentation, the BECo QAD evaluates the supplier's quality assurance program and its implementation to ensure the pertinent provisions of 10 CFR 50, Appendix B will be met by the supplier. Quality assurance activities by BECo include, as a mimimum, acceptance of the item or service upon receipt or completion; methods include final inspection at the source, receipt inspection, review of supplier-i provided documentation, and tests. Other quality assurance activities by BECo may include audits, surveillance inspections, in-process inspections, witnessing supplier
- activities, and review of supplier documents, such as
- engineering doucments and procedures, before use.
7.2.2 The QAD maintains an Approved Suppliers List (QA-ASL) which identifies suppliers for whom QAD has evaluated and approved as satisfactory quality assurance programs and implementation.
This list permits the ese of certain suppliers on an ongoing basis. The QAD reviews supplier documentation of his quality assurance program and performs,or obtains evidence of, a '
survey which assures its implementation. At least annually, QAD performs an evaluation of a supplier's quality performance, and at least triennially, re-surveys or audits the supplier to continue the approved status. Supplier surveys may be by BECo or by others under contract to BECo for this service, or obtained via the Coordinating Agency for Supplier Evaluation l
(CASE). In addition, ASME Certiilcates are used as evidence l of supplier quality assurance program implementation,- for the l- items and services covered by the certificates.
l Re'v: 7
! ll-7-1 Date: 12/30/83 l
I
7.2.3 Certain items used in fire pr:1 cti n sy;tems, which Ero UL er FM coproved,cra purchas:d without the supplier ovaluaticn described above. In oeneral, receipt inspection and test upon receipt are performed to accept these items.
7.2.4 Certain items designated " commercial quality control item ." in accordance with Section 4, may be purchased with assurance These of quality by receipt inspection and eclective testing.
" commercial quality control items" are identified in the Q-List Manual,Section V, and the Fire Protection List. found in Specification H-504. Requirements for such items include pre-established receipt inspection criteria supplemented by tett requirements, when applicable. Suppliers of such items are not relied upon to implement any quality assurance program requirements.
7.2.5 Certain services performe: Dy su: pliers at FMPS or in c her BECo facilities may be performe: accorcino to BECo's On Program. Suppliers of such services are governed by EE;o procedures and BECo quality assurance reouirements.
7.2.6 honconformance to crocurerer.t re aire-eats c# EECo a:Orove: -
supclier occueer.Ts, wnic: is icer.;1iic: t; Tne sv r.ie-by SECo source / surveillance inspection, and which consists of one or more of the following,must De suor.itted with Tecnnical justifi:stion to EECo for aceroval of recommenced dis:oslTicn as proviced ice in Section 15:
(1) Technical or material re:uirements are /iolated.
(2) Supplicr documents accroved by EECo are violate .
(3) Nonconformance cannct be corrected by continuation of the original manuf acturing process or Dy rework.
(4) The item does not conform to the original requirements even though it can be restored to a condition in which its capability to f uretion is unimpaired. ,
7.3 SUPPLIER EVALUATION AND SELECTION 7.3.1 Supplier evaluation and selection is an integrated action which involves Nuclear Organization Departments, Purchasing, and 0AD. This cooperative ef fort ensures that items and i.e.,
services are purchased from qualified suppliers, suppliers capable to provide items and services which meet technical, quality, and commercial requirements, 7.3.2 The department which originates the procurement and Ptentifies f
the technical requirements is responsible to determine the caDability of the selected Suoplier to meet the technical rc:uirements.
f Rev: 7 ll-7-2 Date: 12/30/83 f a l
., .. . i 7.3.3 The QAD is resp:nsibts to detcrmine the cipobility of the selected supplier to meet the quality assurance requirements imposed, if any.
7.4 SUPPLIER AUDITS When warranted by the complexity or duration of the supplier's activities, the QAD performs aud]ts of the supplier's quality assurance program implementation and effectiveness, according to Section 18.
7.5 SOURCE INSPECTION 7.5.1 Source inspection includes surveillance inspection, in-process inspection (hold points), witnessing supplier's activities (often requiring notification points), and final Inspection (hold point). QAD determines what source inspection is necessary, based on the nature, complexity, and importance of supplier activities, and performs it to ensure procurement document requirements are met and purchased items and services are acceptable.
7.5.2 Specific hold points and notification points are included in procurement document requirements.
7.5.3 Surveillance inspections are performed by QAD If conformance with the requirements of the procurement docunents for a particular item cannot be determined when the item is received or when known problems exist during the procurement phase. The purpose of such surveillance is to provide a selective review of tne implementation of the supplier's quality assurance orogram or of the conformance of his product to requirements of the procurement documents. Quality Assurance determines the degree of supplier surveillance Inspection to be performed.
7.5.4 Source inspections may not be necessary when the quality of the item can be verified by review of supplier documents, or inspection or test upon receipt. Results of source inspections are documented and maintained by BECo.
7.6 RECElPT AND INSPECTION AND TESTS 7.6.1 Upon receipt at PNPS, purchased items are separated f rom already processed items until performance of receipt inspection.
7.6.2 Except fer nuclear fuel assemblies, the QAD performs receipt inspections. The NOD performs receipt inspection for nuclear fuel assemblies. Receipt inspection is done according to the requirements of the BECo Puichase Order / Contract and pre-established inspection instructions. .
Rev =. 7 11-7-3 Date: 12/30/83
~
ureinew requirements shall be tvallablo ct the PNPS sita beforo Installaticn.cnd/cr us3 of such items to tssura that:
(I) The item is properly identificd End that its identification corresponds with the docamentation received.
(2) Stated packaging and shipping requirements have been maintained. -
(3) All procurement requirements have been met.
(4) Documentation records are acceptable in accordance with predetermined inspection instructions.
7.6.3 After identification per Section 8, accepted items are located in a controlled storage area.
7.6.4 When document deficiencies or nonconforming items are identified,itens are held in a segregated area, and identified and handled according to Section 15.
7.6.5 A written record of the results of receipt inspection and the disposition of received items is maintained as part of the permanent plant records. All items issued bear a conformance tag and have documentation to. support their acceptability, i f traceability is lost or the documentation review is unsatisfactory, an item becomes subject to the controls established'for nonconforming items.
7.6.6 Acceptance of items may rcquire testing by BECo or by another qualified supplier. Tests are controlled according to Section 11.
Rev: 7 11-7-4 Date: 12/30/83
__.._..-4 ., . - __
INSPECTION 10.1 PURPOSE This section establishes requirements for inspection activities related to operation, maintenance, modification, replacement, additions, altera-tions and refueling of systems, structures and components to assure compliance with associated instructions, procedures and drawings.
10.2 INSTALI.ATION INSPECTIONS 10.2.1 Installation inspections are required at PNPS to assure that work associated with maintenance, modification, and refueling of safety related systems, structures and components is properly performed.
10.2.2 Installations inspections are performed at PNPS by QAD per-sonnel, other qualified individuals designated by QAD, or contractors having a BECo accepted QA Program. Individuals assigned to perform installation inspections shall not be directly involved in the performance of the work being in-spected and shall have the cualifications necessary to perform the inspection.
10.2.3 Installation inspection results should indicate, as appro-priate, the inspection procedure used, the applicable accept /
reject criteria, any qualitative and quantitative data obtained ,
during the inspection, the inspection status, identification of the inspector, date the inspection was performed and any other information pertinent to the inspection.
10.2.4 Installation Inspection Reports and associated documentation
- including copies of the Maintenance Requests are maintained in the Quality Assurance Department File.
10.3 INSERVICE INSPECTIONS Inservice inspections are performed under the cognizance of QAD in accor-dance with Section XI, ASME Boiler and Pressure Vessel Code, and the PNPS Technical Specifications.
10.4 INSPECTION CONTROLS Controls exercised during inspection assure that:
10.4.1 When direct inspection is either impossible or not feasible.
l l
indirect control shall be provided by monitoring processing, operational tests, methods, equipment and personnel.
l i
f ~
11-10-1 - Rev: 9 l
~
Date: 12/30/83
1 10.4.2 Proc:dur:s fcr maintcn:nco, modificcticn, cnd/cr eltsrctions
-cr3 r;vinv;d by QAD perecnn21 to datsrmina tha nasd fer indspandtnt
. installation inspections snd incorporation of " hold points".
10.4.3 Inspection procedures or instructions are available with necessary drawings and specifications before inspection activities are performed.
Inspection controls require that objective acceptance criteria, prerequisites for performing inspections, limiting conditions, and special equipment requirements be prescribed as appropriate to the inspection activity.
- 10. 4.4 Test and measuring equipment is calibrated within required limits, according to Section 12.
- 10. 4.5 Test and inspection results are recorded, evaluated and retained in accordance with the requirements of Section 17.
11-10-2 Rev: 9 Date: 12/30/83
(QA2-A4)
TEST CONTROL 11.1 PURPOSE
-This section establishes the requirements for testing systems, atructures and components to assure that they will perform satisfactorily during operation of PNF3.
11.2 GENERAL REQUIREMENTS The Boston Edison Company has overall responsibility for test activities performed on safety related structures, systems, and components during operation, surveillance, maintenance, and modification activities.
Tests are performed to verify that plant behavior conforms to design criteria, to assure that failure and substandard performance are identified and controlled, and to demonstrate satisfactory performance after plant modification and maintenance activities.
Documentation of test activities are maintained by BECo in accordance with requirements of Section 17. Deficiencies identified during tests are controlled in accordance with requirements of Section 15. Tests performed are classified as Proof Tests Post Work Tests, and Surveillance e
Tests and controlled as described below.
11.3 PROOF TESTS 11.3.1 The originator of procurement documents specifies appropriate requirements for proof tests associated with the purchase of material, equipment and parts.
11.3.2 QAD assures that selected proof tests are witnessed at supplier facilities, or are selectively witnessed at PNPS when these l
proof tests are not performed at supplier facilities. Proof tests are witnessed by qualified personnel using approved procedures or checklists.
11.3.3 Proof Test Data Reports, subnitted by suppliers, are reviewed by QAD during receipt inspection of material, equipment, and parts at PNPS and are considered a requirement for satisfactory acceptance of the material, equipment, and parts at receipt inspection.
11.3.4 Deficiencies identified during proof testing are controlled according to Section 15. !
11.4 POST WORK TESTS 11.4.1 Post Work Tests are performed at PNPS after satisfactory completion of installation inspections associated with maintenanPce, modification and refueling of systems, structures, and components'.
Rev: 8 11-11-1 Date: 12/30/83
. - -. . . . ~. . -. - _ . _ . . . . . .-
TQA2-A5) 11.4.2 Post-Work Tests are performed by qualified personnel in accordance with written, approved test procedures. These procedures identify all test prerequisites and environmental conditions which must be satisfied before performance of the Post Work Test. The Watch Engineer, or his designee, reviews and approves the post-work test data results and signs off and approves the test data sheets.
11.4.3- Deficiencies identified during the performance of Pest Work Tests I
are" controlled according to Section 15.
~
11.~S PERIODIC SURVE1LLANCE TESTS 11.5.1 Periodf.c surveillance' tests are tests required by the Technical Specifications or other commitments which are performed to demonstrste that systems, structures and components perform satisfactorily during
- operation of the nuclear power plant.
11.5.2 All periodic surveillance tests are identified ou a Master
- Surveillance Test List which is controlled by NOD. This Master Streveillance Test List identifies the type of test activity, frequency interval and cognizant NOD Manager renponsible for performing the periodic surveillanen tests. Special . handling tools and equipment are included in tise scope of periodic aurveillance tests to assure that they are adequately maintained.
11.5.3 Periodic surveillance tests are conducted by qualified personnel according to written, approved test procedures. Personnel assure that equipment and instrumentation utilized in performing the periodic surveillance tests is calibrated within the specified interval. These procedures identify all test prerequisites and environmental conditions i which must be satisfied before the performance of the periodic surveillance tests.
11.5.4 -The NOD Manager is responsible to assure that surveillance tests are performed when required, test results are evaluated, and test requirements are satisfied.
i 11.5.5 Deficiencies identified during the performance of periodic surveillance tests are controlled according to Section 15. l 4
l Rev: 8 11-11-2 Date: 12/30/83 l
L r
=n-, as ,.-- ,,,.. ww.-,,.ww.~
NONCONFORNING MATERIAL. PARTS OR COMPONENTS 15.1 PORPOSE This section establishes the requirements and methods used within the Boston Edison Company to document and control nonconforming materials, parts, and components to prevent their inadvertent installation or use. Included are requirements and methods to identify and segregate nonconforming items, provide for their disposition, and notify affected organizations.
This section also establishes requirements and methods to document and control conditions adverse to quality other than nonconf9rming itemt (hardware). Such conditions include deficiencies noted by QAD during audits, reviews, and inspections; and program, procedure, and documentation problems identified by any BECo personnel for any activity governed by this QA Program. Conditions noted during normal, in-process review or monitoring before final approval / acceptance of a document or activity are considered part of the process, and are not subject to the reporting requiremerits herein. However, problems identified af ter completion of the specified process shall be included.
P-15.2 ,REQUIRFMENTS 15.2.1 All materials, parts, or components which do not conform to specified requirements shall be documented as follows: l 15.2.la. All nonconforming materials, parts, or
-- components identified at receipt inspection er installation inspection shall be documented on Nonconformance Reports (NCR) except as noted l in b. below. I A Document Deficiency Notice (DDN) shall be l used when documentation is found to be incomplete, incorrect, or inadequate during receipt inspection, thereby making it indeterminate that the item conforms to specified requirements. If an item with an !
open DDN is withdrawn for use, an NCR shall be initiated. ;
Nonconforming items identified on an NCR or l items on an NCR or items for which DON has l been initiated shall be clearly identified 1 with a Nonconformance Tag.
~
15.2.lb Nonconforming materials, parts, or components l 1
11-15-1 Rev. 8
! Date: 22/30/83 i
l l
I i
l.-.--.- , - - - - - , , - , - - . _ . - , , - - - , - - - - - , - . , . , . . . . - . . . . ------ - -----_ _ _ _ _ --
, .u -
identified during operation, maintenance, or surveillance testing are documented and reported via a Failure and Malfunction Report (F6MR).
Documentation in the Control Room Log and on Shift 4
Turnover Sheets, and tagging, shall be performed as appropriate to ensure effective control.
15.2.2 Other conditions adverse to quality shall be documented as follows:
15.2.2a. Deficiencies identified by QAD shall be ider.tified on Deficiency Reports (DR), which shall be processed according to Section 18.
15.2.2b. All other problems shall be identified on F&MR's.
15.2.3 Nonconforming items identified on an NCR shall be physically segregated from conforming items and controlled to prevent inadvertent installation or use. Installed nonconforming items shall be identified and the status of the system shall be controlled to prevent inadvertent installation or use. Installed nonconforming items shall be identified and the status of the system shall be controlled to prsvent inadvertent use. Any system, component, or structure may not be declared operable in accordance with the definition of the PNPS Technical 2
Specifications until the NCR disposition is approved,
, implemented, and verified by QAD, and the Nonconformance Tag is removed.
15.2.3a. Tagged nonconforming items not yet installed i shall be placed in a segregated and controlled storage area designated for this purpose.
When physical segregation is not practical, !
l for example with large items which are stored in place, suitable means, such as roping off the area, shall be used to clearly indicate the nonconforming status.
15.2.3b. Nonconforming items which, because of their i l
L makeup and intended use, cannot readily be l
returned to a conforming state (such as chemicals, weld rod, concrete, etc.) shall not be released for installation. If the l nonconformance can be corrected after installation, the item may be released for l
l 11-15-2 Rev. 8 Date: 12/30/83 l l
l l l
l
=
installation. Technit.a1 justification for the installation, including the limits on examination, testing, or inspection activities that can be perforwed on the structure, system, or component with the nonconforming item installed, shall be prepared and made part of the NCR documentation.
The Maintenance Request process shall provide l the necessary controls, including review by the Quality Assurance Department, to prevent inadvertent instalittion and inadvertent use 4
of the structure, system, or compon6nt before the Nonconforwance Tag is removed.
15.2.3c Nonconformance Tags shall only be removed by Quality Assurance personnel, and only after satisfactory resolution of the NCR or DDP; 15.2.3d. The Quality Assurance !?partment shall ke(p l records of all unresolved nonconformances and monitor Station activities to assure that:
- 1. Tags have not been removed or altered on items still classified as nonconforming.
- 2. Unauthorized personnel have not modified the segregation or use requirements on tags.
- 3. Activities have not been conducted that violate requirements specified on tags or in this program. l 15.2.4 Nonconforming items identified on an F&MR shall be further identified and the status of the system controlled by appropriate log entries, shift turnover information, and tags. PNPS Technical Specifications shall govern operation.
15.2.5 All nonconforming items identified on an NCR shall be l reviewed for acceptance (use-as-is), rejection (scrap, salvage, or return-to-vendor), repair, or rework according to appropriate department procedures. Repaired and reworked items shall be re-inspected for acceptability using the original or equivalent criteria. All rework or repair shall be performed using approved procedures. All dispositions of nonconforming items shall be properly documented.
II-15-3 Rev. 8 Date: 12/30/83 l
. -. - _. - -- -- .- . -. =-- _ _ -
- 15. 2. 5a . The Nuclear Engineering and Nuclear Operations l Departments, as appropriate, are responsible for the evaluation and disposition of identified nonconformances. The Nuclear Engineering Department must approve and I document their evaluation of and justification
! for " accept" or " repair" dispositions; and the Quality Assur' ice Department must approve
" accept" or " repair" dispositions which affect the quality assurance requirements associated with the nonconforming item.
15.2.5b. When required by Purchase Order, or contract l suppliers working under their own BEco approved QA Programs shall submit nonconformances with the disposition " accept as is" or " repair" to BECo for approval. The cognizant NED discipline group shall review the supplier's disposition and its justification; this review and approval may be documented directly on the supplier's report.
NED shall assign a 8Eco control number to each such report. As an alternative, NED may request QAD to issue a BECo NCR to cover the report. NED shall notify the supplier of 8Eco's approval.
- 15. 2. 5c . The Quality Assurance Department is responsible for assuring NCR dispositions are f implemented and inspected for acceptability of rework and repair actions.
15.2.6 All nonconforming items identified on an F&MR shall be reviewed and a disposition provided according to ,
appropriate N00 procedures. The Maintenance Request (MR) process shall provide the necessary controls to ensure PNPS Technical Specifications are met. Actions taken shall be recorded on the FbMR with reference to the related MR's.
15.2.7 Ex:ept for hardware nonconformances, discussed above, conditions identified on F&MR's shall be reviewed by the originating department to determine what immediate corrective action is necessary or to verify that immediate corrective action was taken; the required action or action taken shall be documented on the F&MR. Further FbMR review is described in Section 16.
t 11-15-4 Rev. 8 Date: 12/30/83
CORRECTIVE ACTION ;
i 16.1 PURPOSE This section establishes the requirements to be met by the Boston Edison Company to identify, document, and correct items or conditions adverse t0 quality and to ensure these items or conditions are evaluated to determine causes and appropriate action is taken to prevent recurrence. '
Conditions adverse to quality include failures, malfunctions, j deficiencies, defective material and equipment, abnormal occurrences, l and nonconformances.
In addition, the corrective action program ensures that the Pilgrim Nut. lear Power Station cperates in a safe and reliable manner, minimizes down-time, and optimizes the use of available resources by providing for a team of fort in resolving problems. The preventive action portion of the program provides a cost-effective way of reducing the frequency and severity of problems.
16.2 REQUIREMENTS 16.2.1 All Nuclear Organization personnel shall perform their normal activities in a manner which will avoid or minimize quality-related problems by adhering to approved procedures, inst 1ctions, and work methods.
16.2.2 Each Vice President, Manager, or Director is responsible for the effective implementation of the BECo corrective action program within his organization.
16.2.2a. Each Department shall continually assess its operations to assure that mechanisms are in place to identify deviations f rom specified requirements or conditions adverse to quality which might result in potential problems.
16.2.2b Each Manager, Assistant or Deputy Manager, Group Leader, or Supervisor will ensure that all affected personnel within the Department / Group are fully aware of the corrective action program and of the Department implementing procedures. When necessary, personnel shall be trained (or retrained) in proper
- procedures and work methods.
11-16-1 .
Rev: 13 Date: 12/30/83
, .s .
l l
16.2.3 It is the responsibility of all Nuclear Organization personnel to make sure that any incipient, suspected, or actual ,
conditions adverse to quality, such as failures, malfunctions, i deficiencies, defective material and equipment, and l )
nonconforshances are promptly identified.
16.2.3a. All identified items or conditions adverse to quality will be documented and reported in accordance with Section 15 and the appropriate !
procedures.
16.2.3b. All Technical Specifications or FSAR deviations shall be promptly ovaluated and reported to the NRC, .i as appropriate, in accordance with procedures. I 16.2.3c. The Nuclear Safety Review and Audit Committee (NSRA'C) shall review reported conditions adverse to quality as required by the PNPS Technical Specifications.
16.2.4 All identified wonditions adverse to quality shall be corrected and reported to appropriate levels of management. Section 15 provides requirements for disposition of nonconformances reported on NCRs and F8ARs, and for resolution of other conditions reported on F8MRs. Section 18 contains requirements for resolution of deficiencies reported by QAD on DRs. In addition:
16.2.4a. Each Manager is responsible for taking prompt and effective corrective action to satisfactorily resolve any items or conditions adverse to quality discovered within or assigned for action to the Department.
16.2.4b. Corrective action (s) in response to reported problems will be described in writing, and procedures shall provide for appropriate review and approval before the action is taken.
16.2.4c. Legs shall be maintained by each Department to sufficiently account for reported conditions and the corrective action (s) taken.
16.2.4d. Appropriate reports of status will be submitted to the cognizant Managers and Vice Presidents on a regular and timely basis. In any case, this interval will not exceed six months.
11-16-2 Rev: 13 Date: 12/30/83
16.2.5 All resolved items or conditions will be further C.wluated by the department which originated the NCR, FMR, or DR.
16.2.5a. For those conditions adverse to quality deemed significant during the evaluation process, inmediate action will be taken to determine the cause(s) and appropriate preventive action (s).
The term "significant" applies to a condition adverse to quality which warrants further evaluation for cause(s) and requires manage;aent attention / action because it represents:
e a breakdown in any portion of the Quality Assurance Program conducted in accordance with the requirements of Appendix B to'10CFR50; e a deficiency in design such that the design does not conform to the criteria and bases stated in the final safety analysis report; e damage to a structure, system, or component which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in the final safety analysis report, or to otherwise establish the adequacy of the structure, system, or component to perform its intended safety function; e a deviation from performance specifications or
+ design drawings which will require extensive evaluation, extensive redesign, or extensive repair to establish the adequacy of structure, system, or component to meet the criteria and bases stated in the final safety analysis report or to otherwise establish the adequacy of the structure, system, or component to perform its intended safety function;
, e the failure or malfunction of, or use of nonconforming material in a structure, system, or component which will require extensive evaluation, extensive redesign, or extensive repair to establish the adequacy of a structure, system, or component to meet the criteria and
, bases stated in the safety analysis report or to otherwise establish the adequacy of the structure, system, or compunent to perform its intended safety function. .
~
g a the repetitive recurrence of a deficiency not covered by the items above. ,
II-16-3 Rev: 13 s Date: 12/30/83 s
. _ C. . . _ ~ _ . . _ . _ _ , _ _ - . . . , . _ _ , _ _ _ , . . . . . _ . , . . _ . _ . . . . _ _ _ _ . . ~ . . _ . _ _ . . . ~ . . . _ , _ - . - . _ . _ - , . _ . , , - - - , . . . . - _ _ _ . _ , -
I .. .
16.2.5c. The recommendations for preventive action will be forwarded to the responsible Department Manager.
16.2.6 For those items or conditions not deemed significant during the evaluation, periodic trend analysis will be performed by the (
QAD to identify adverse trends or recurring problems. Problems identified will be evaluated for cause(s) and recommended preventive action (s) transmitted to the responsible Department Manager.
16.2.7 Corporate policy' requires that a significant condition adverse to quality is promptly reported by the responsible Department Manager to the appropriate higher levels of BEco management with a description of the condition, the apparent cause of the condition, and the immediate corrective action taken or planned. Management shall be kept informed as information is developed about cause and preventive action.
11-16-4 Rev. 13 1 Date: 12/30/83 4
, . - - , . - - ,, , . , . , . . - - - - - . - - - , , , . , ,- . . , , ~ , - . , . . - - , - - .
, , c. . .
AUDITS 18.1 PURPOSE This section establishes requirements for an auditing program to verify the implementation and to assess the effectiveness of the Bostor Edison Quality Assurance Program.
18.2 PERFORMANCEQFAUDITS 18.2.1 QAD performs internal audits cf all quality-related '
activities associated with operation of PNPS. The frequency intervals are based on the requirements of regu1ations, Regulatory Guides, and ANSI Standards identified in Paragraphs 2.3.2 and 2.3.4 of Section 2; audits are also done when significant changes or problems arise, and upon '
management request. A specific scope for each audit is prepared by the QAD before performance of the audit.
18.2.2 When suppliers perforid work related to operation, maintenance, modification and refueling of PNPS, QAD may perf um audits at PNPS and at the suppl 9r's facilities to verify impicmentation of their quality assurance programs as -
determined necessary by QAD.
18.2.3 Audits required by Section 6.0 of PNPS Technical Specifications wiil be performed under the cognizance of the Nuclear Safety P.eview and Audit Comittee by Quality
- Assurance Depart:nent personnel.
10.2.4 QAD performs audits / surveillance inspections, as necessary, to verify that corrective action resulting from identified deficiencies have been properly implemented and are effective.
18.2.5 Audits are performed by qualified personnel using checklists or marked up written procedures to effectively evaluats l conformance to specified requirements. Auditors shall not have direct responsibility in the areas being audited.
18.3 EEPORTING OF AUDIT FINDINGS 18.3.1 After reviewing audit findings with the cognizant manager of each organizational unit which has been audited, an audit report is prepared by QAD.
18.3.2 As a mir.imum, audit report shall include:
Description of the audit scope. .'
1.
11-18-1 Rev. 9 Date: 12/30/83 i
I
- 2. Identification of the auditors.
- 3. Persons contacted.
- 4. Summary of audit results including an evaluation statement of the effectiveness of the QA Program elements which were audited.
- 5. Details of audit findings.
- 6. Recommendations for correcting deficiencies or improving the QA Program, as appropriate.
18.3.3 Audit deficiencies are recorded on a Deficiency Report and are entered into the Deficiency Follow Program to be dispositioned.
18.4 DISPOSITIONING OF AUDIT DEFICIENCIES 18.4.1 Audit deficiencies recorded on Deficiency Reports shall be reviewed by QAD to determine whether a significant (see Paragraph 16.2.5b) condition adverse to quality exists.
18.4.2 A deficiency deamed to be significant is designated "immediate" and corrective action must be initiated promptly by the responsible Manager and appropriate levels of higher management notified. A response shall be submitted to the QA Manager within one week and a copy of the Deficiency Report and the response shall be forwarded to the appropriate Vice President.
18.4.3 all other Deticiency Reports require that a written response be forwarded to the QA Manager within thirty (30) days.
18.4.4 For each Deficiency Report, the official start of the time clock for the initiation, implementation, and completion of the required corrective action shall be the date of the QA Manager's signature.
18.4.5 In the event corrective action cannot be completed by the j initial response due date, a schedule for corrective action completion shall be indicated on the DR. This date shall j
not exc.eed 90 days from the DR issue date unless a written request for extension, including justification, is submitted
' to, and approved by, the appropriate Vice President. Copies ;
of the approved extension request shall be provided to the 1 Senior VP-Nuclear and QAD Manager.
18.4.6 Should Quality Assurance not concur with actual / proposed corrective action, and be unable to obtain satisfactory ;
resolution directly with the responsible Manager, a formal i l
11-18-2 Rev. 9 4 Date: 12/30/83 .
sci + .
request for a second response shall be forwarded to the appropriate Vice Presidant. The Quality Assurance Manager may, if ddemed appropriate, implement the requirements of Paragraph 2.5.6 of this Manual. ,
18.4.7 Upon completion of planned corrective action, the recipient of the Deficiency Report shall provide timely written notice ,
to the QA Manager, stating the actual corrective action (s) !
taken and the completion date(s) thereof.
18.4.8 Quality Assurance should verify corrective action within 30 calendar days of the receipt of the notification of completion. Verification shall also assure effe:tiveness of corrective action.
' 18.4.9 For those Deficiency Reports that are issued to suppliers :
who are performing on-site safety-related activities in l accordance with their approved QA Programs, the process in Section 18.4 shall apply. Interface shall be directly with he supplier's site manager with a copy of the Deficiency Report forwarded to the applicable BEco Manager for information only.
18.4.10 Corrective actions for deficiencies identified during inspections / audits of suppliers et their facilities are documented and resolved on a Deficiency Report, and the process defined in Section 18.4 is used, were practicable.
Interface shall be directly with the supplier's OA manager.
18.4.11 The status of dispositions audit deficiencies recorded on Deficiency Reports shall be reported periodically to Department Managers and to higher levels of management.
18.5 PERFORMANCE FOR SURVEILLANCE MONITORING 18.5.1 QAD performs surveillance monitoring of Nuclear Operations Activities to assess compliance with established Quality Assurance Program requirements, written policies, l
procedures, instructions, directives, codes, standards, specifications, and control documents. Surveillances can be performed by direct observation or records review.
Surveillances shall be planned and unplanned, selectively and randomly, and with ,ufficient detail to effectively r
monitor and report the conditions at the Pilgrim Nuclear Power Station.
18.5.2 The surveillance monitoring schedule shall be based upon the following:
e the quantity and difficulty of work / tests in progress, and the activities' importance to safety.
11-18-3 Rev. 9 Date: 12/30/83
, - - ----,-----mr. r-e,- ,w~,em--- -+,,r, - _- , - - -----,,-mv m,--,-,,--,-w am ,, w- ,.ee- --e n w- ge---e--ve---->ne--v v n
,, , f e - ',
e changing plant operating conditions, e trends observed during previous surveillances and other activities such as audit results, LER's, INPO reports, and reports of outside agencies such as the U.S. Nuclear Regulatory Commission.
18.5.3 Surveillance monitoring shall be performed by certified Lead Auditors using approved checklists when applicable.
18.5.4 Discrepancies noted during surveillance monitoring shall be recorded on a surveillance finding sheet and reviewed to determine whether a significant condition adverse to quality exists. If a significant condition adverse to quality exists, a Deficiency Paport will be issued to document the condition and the corrective action. A surveillance report and finding sheets shall be distributed to responsible supervision.
18.5.5 Recommended corrective action shall be proposed by QAD. ,
Final corrective action to be taken shall be concurred with by both the cognizant department manager and the CA Manager / designee. If a difference of opinion arises between Quality Assurance personnel and those of another department, resolution h first attempted by the Quality Assurance Manager and the other cognizant manager. If a solution acceptable to the QA Manager cannot be obtained, the catter shall be promptly referred by the QA Manager to the appropriate upper levels of management.
18.5.6 Quality Assurance shall verify that timely corrective action has been taken by cognizant departments. Verification shall be accomplished by re-monitoring of the deficient areas.
18.S.7 The Quality Assurance Department shall prepare and distribute to management Quarterly Reports of the Surveillance Program to summarize surveillance results and
! to assess problem trends and effectiveness of corrective actions.
18.6 RECORDS / REPORTS OF AUDITS l
18.6.1 QA audit records, reports and associated documentation pertinent to the audits are maintained in the QAD file and l the Nuclear Records Management System.
.~
11-18-4 Rev. 9 Date: 12/30/83 l
.