ML20081A729

Rev 39 to QA Policy for Ccnpp

ML20081A729
Person / Time
Site:	Calvert Cliffs
Issue date:	10/29/1993
From:	Denton R BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20081A726	List: ML20081A725 ML20081A729 ML20081A730 ML20081A733 ML20081A738
References
NUDOCS 9503150265
Download: ML20081A729 (59)

Text

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QUALITY ASSURANCE POLICY Revision 39

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IIALTIMORE GAS AND ELECTRIC COMPANY l.

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Quality Assurance Policy

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Calvert Cliffs Nuclear Power Plant (Appendix IB of the Calvert Cliffs Updated Final Safety Analysis Report) i l

Approved Date /0!Z*/!73_(1) j R. E. Denton '

- ( Vice President .

Nuclear Energy Division i

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l 9503150265 950309 PDR ADDCK 05000317 P PDR

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.k QUALITY ASSURANCE POLICY ' l C .

Revision 39  :'

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APPENDIX IB OUALITY ASSURANCE PROGRAM FOR THE OPERATIONS PHASE  !

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Section - i s  !

1 B.1 ORGANIZATION AND RESPONSIIllLITIES.. ........ . . . . . . . . . ..............5 l t

i B.2 OU ALITY ASSU RAN CE P ROG R AM ... .................. ... . .... ... . . ... . .. . ..... 14  ;

' 1B.3 DESIGN CONTROL ........................................ . . .. .. .... . ... 19 i a

1B.4 PROCUREMENT DOCUM ENT CONTROL (5) ....... .... ... .. ..... .. . . ..... ...... 21 1 B.5 1NSTRUCTIONS, PROCEDU RES. AND DRAW 1NOS . . ..... ....... ... . . ....... ... ... .. 24 {

1B.6 DOCU MENT CONTROL .... .. ... . . . . . . . . . . .........................24 1B.7 CONTROL OF PURCilASED M ATERIAL EQUIPMENT, AND . .. .. . . .. . 26. 5 SERVICES (5) l i

b 1B.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND .. ... .... . 29 ,

COMPONEN'IS (5) i 1 B.9 CONTROL OF SPECI AL PROCESSES ...... ....... .... ... . ... .... .. ...... ... . .. .. ... ...... .. 30  :

1B.10 1NSPECTION ... ..... . ...................................................................32 iB.11 TEST CONTROL.. ........................................................ . ... 33 1 B.12 CONTROL OF MEASURING AND TEST EQUIPMENT.. . . .. .............. . . . . .. 34 j 1B.13 1I ANDL1NG, STORAG E, AN D SH I PP1 NG... .. ..... . . ... ......... ......-... ... .......... .... 36 t

1B.14 INSPECflON, TEST, AND OPERATING STATUS... .. - . . . . ....-... . . 3 6  ;

1B.15 NONCONFORMING M ATERI ALS, PAR'13. AND COMPONENTS.. . . ... ... ...... 57 iB.16 CORR ECTI V E ACri ON .. .... .... . ... . . . . . . . ............ .. .. . . ... . ...- . . . 37 i i

iB.17 OU ALITY ASSURANCE RECORDS... .. .. . . . .. ........ . . . .. . .. .- . . . 3 8 t 1B.18 AU Dris ...... ... .. . . ... ..........................~........................................39 j 1

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' QUALITY ASSURANCE POLICY Revision 39 -

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- LIST OF TABLES L

T_ abic No. Pace-1 B.1 BALTIMORE GAS AND ELECTRIC COMPANY'S POSITION ON.... ..... .. .. . ... 40 i

. OUIDANCE CONTAINED IN ANSI STANDARDS .

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I,1STOF ATTACilMEN'13 r t

Attachment -

1.ctter [,

A BASES FOR OA POLICY REVISIONS (I) ..... . ............................-..57 ,

LIST OF FIOURES Figure No.  ;

I B.1 BALTIMORE GAS AND ELECTRIC COMPANY CORPORATE ORGANIZATION b

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QUALITY ASSURANCE POLICY Revision 39 1B.1 ORGANIZATION AND RESPONSIHil.lTIES All levels of organization have definite and unique responsibilities in assuring safe, economical, and icliable opeintion of Calvert Cliffs Nuclear Power Plant (CCNPP). Top level management is <

responsible for ensuring that policies are established, resources are authorized, management philosophy and commitments are communicated to lower levels of the organization, independent verification of management controls are performed, results are reviewed, and appropriate actions taken when necessary.

Middle level management is responsible for translating management policies, philosophy, commitments, and goals; applicable federal, state, and k> cal rules and regulations; Operating Licenses, Technical Specifications (TS), and the Updated Final Safety Analysis Report (UFSAH) into contlol progratus for activhics such as design, procurement, construction, testing, operation, refueling, maintenance, repair, modification, training, plant security, fire protection, records, independent verification, and corrective action. Middle levci management is also responsible for defining, measuring, and modifying the overall efTectiveness of control programs; taking appropriate action on the results; and keeping top management informed of the status, adequacy, and effectiveness of control programs, and matters which could have an impact on nuclear safety.

First line craft and non-craft supervisors are individually responsible for ensuring that appropriate procedures are understood and used to implement cach activity described in the control programs; identifying piob1 cms, secking solutions, verifying implementation of solutions; investigating soot causes of problems and taking preventive actions; ensuring that conditions adverse to plant and personnel safety are promptly identified, reported, and corrected; detecting trends which may not be apparent to a day-to-day observer, recommending generic solutions for adverse trends to management, and taking appropriate actions, to achieve desired results: ensuring that employces assigned to do a job are properly qualified through appropriate training and experience; have properly qualified procedures, tools, equipment, and parts to do the job, and, ensuring that mdependent inspections of work are conducted in accordance with preestablished requirements.

First line non-craft supcivisors are responsible to ensure that procedures are written, reviewed, and approved; fin,t line craft supervisors may not have this responsibility. Non-supervisory personnel

_ acting as job directors are responsible for ensuring that properly qualitied procedures are understood and used; and ensuring that tools, equipment, and parts are on hand to do the job.

Adherence to procedures is vital to the safe and reliabic operation of the Calvert Cliffs Nuclear Power Plant. Personnel are responsibic for adhering to established procedurcs, interpreting them conservatively in case of doubt, and recommending changes when necessary. Procedures with the potential to affect nuclear or personnel safety shall be strictly adhered to. When an activity controlled by such procedures cannot be accomplished as described or accomplishment of such activity would result in an undesirable situation, the work shall be stopped arid the plant placed in a safe condition. Work shall not resume until the procedure is changed to reflect correct work practices. (1)

Procedures may be deviated from during emergencies to prevent or minimize injury to personnel or damage to plant equipment. Any such deviations should be thoroughly documented. (1) i l

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Corporate Organization and Specific Responsibilitics

. The Corporate Organization Chart of the Baltimore Gas and Electric Company (BG&E)is shown in' s '.' Figure 1B-1. Persons responsible for the principal elements of the Company's Quality Assurance (OA) Program are as follows:(1)

Chairman of the Board President and Chief Operating Officer  ;

Senior Vice President Generation Vice President-Nuclear Energy Division (NED)

Plant General Manager-Calvert Cliffs Nuclear Power Plant Department (CCNPPD)

Manager-Nuclear Engineering Department (NED) l, Manager-Nuclear Quality Assurance Department (NOAD)'

Manager-Nuclear Safety & Planning Department (NSPD)

Manager-Nuclear Support Scavices Department (NSSD)

Manager-Nuclear Outage & Project Management Department (NOPMD)

In addition to these individuals, the Vice Presidents of Corporate Affairs (CA), Fossil Energy Division (FED), Electric Interconnection and Transmission Division (EITD), General Services Division (GSD), and the Management Services Division (MSD), as well as the Managers of the Electric System Operation and Maintenance Department (ESOMD), Purchasing & Materials Management Department (PMMD), Information Systems Department (ISD), Facilitics Management Department (FMD), Fossil Engineering & Maintenance Department (FEMD), Fossil Support Services Department (FSSD), and the Safety and Medical Services Department (SMSD) are assigned support responsibilities. (I) The above Managers constitute the Nuclear Program

< Managers who are assigned responsibilitics within the OA Program. Other departments performing any maintenance / modification activities at CCNPP are responsible for performing these activitics in -

accordance with applicable OA Program requirements. This can be accomplished by either developing their own OA Program procedures or hy working to the OA Program through appropriate Nuclear Energy Division personnel using CCNPP procedures. (15)

Also, two advisory groups perform quality related functions for plant operations. These are the Plant Operations and Safety Review Committee (POSRC) and the Off-Site Safety Review Committee (OSSRC) whose makeup and responsibilitics are described in the TSs for CCNPP. j Chairman of the Board. President and Chief Oncratine Officer. and Senior Vice President.

Generation BG&E's OA Program for nuclear power plants is established under the authority of the Chairman of the Board, President and Chief Operating Officer, and Senior Vice President-Generation, who are responsible for establishing the overall OA Policy. They assign project responsibilitics to the [

organizations shown in heavy lined boxes in Figure 1B-1. (1)

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The Chairman of the Board assigns authority through the President and Chief Operating Officer and W -

Senior ' Vice - President-Ocneration to? the Vice c President-Nucicar . Energy Division,- Primary responsibilities for developing.' implementing, and maintaining the QA Program are assigned to Department Managers by the Vice President-Nucicar Energy Division.1 Managers delegate theirc j.:  : authority as required to implement their responsibilitica. (1) m' Quality assurance matters that cannot be resolved by the Managers or Vice Presidents are brought to

.the attention of the Senior Vice President-Generation; President and Chief Operating Officer, or the Chairman of the Board for resolution.

p Vice President Nuclear Encrev Division The Vice President Nuclear Energy Division, is responsible to the Senior Vice President-Ocncration -

for ensuring that the OA Program is developed and implemented. he authority to develop OA :

Program Documents is assigned to designated Nuclear Program Managers.: nc Vice President--

' Nuclear Energy Division, is also responsible for ensuring that the requirements of the OA Program that relate to the design, operation, and maintenance of the plant are implemented. This responsibility is carried out through Nuclear Program Managers.

Manager-Nuclear Ouality Assurance Denartment

, 'the Manager-NOAD, is responsible for assuring an appropriate QA Program is established and effectively executed for CCNPP. lie is responsihic for auditing, quality verification, and '

the vendor evaluation functions for CCNPP. These responsibilitics include:

1. Developing, and revising the OA Policy.

2. Ensuring that OA Compliance reviews are completed for program acceptability of

, Control Programs (OAPs and Directives) and their revisions before they are approved.

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3. Taking necessary corrective action, which can include the stoppage of work when manufacturing, maintenance, or modification activitics fail to comply with approved specifications, plans, or procedures. Such corrective' action is arranged through. ,

appropriate channels and is delegated when necessary. When a unit is operating, the

• Manager-NOAD, may recommend to the Plant General Manager that the plant he shut '  :

down. The Plant General Manager has the final responsibility for the overall evaluation . i of all aspects and implications of shutting down an operating unit.- i j

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NOAD personnel who report to thc Manager-NOAD, arc independent of departments, sections, and employees responsihic for performing specific activities, and have sufficient  !

autherity and organizational freedom to identify quality problems: to initiate, recommend,.or  !

provide solutions through designated channels: and Io verify implementation of solutions.

BG&E has established that the Manager NOAD,'should have at icast six years oI rcsponsible i experience in engineering, design, manufacturing, construction, quality assurance, or power  ;

plant operation, as well as a knowledge of regulations and standards related to nuclear power i plants. i

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- I f Th$ organization' of NOAD is shown in Chapter 12 of the UFSAR.' The Manager NOAD, i L delegates tho ufollowing; responsibilitics for ! accomplishing required quality 3 assurance -

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o M .  : Planning and scheduling evaluations of vendor quality assurance programs.

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.  ? Reviewing : proposed changes to. QA- Program EdocumentsL for_ compliance Lwith; ,

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regulations and licensing documents. .;

e Q =, Planning, scheduling, and performing internal audits and evaluations of on site and off l l site functions performed under the nuclear OA Program.

. Supporting maintenance and operations activides by pciforming inspections and : -

surveillances. (II)

Plant General Manancr-Calvert Cliffs Nuclear Power Plant Denartment O r ,

ne Plant General Manager is responsible for operations, chemistry, radiation safety,- l maintenance, and systems and performance engineering activitics at CCNPP. He must .

ensure that these activitics are conducted in accordance with the plant operating license and .,

TSs, the UFSAR, the OA Program, and procedures. The Plant General Manager fulfills the: ~j

, position and requirements of the Plant Manager, as dcilned in ANSI N18.1 (1971). He,or -a  ;

. , one of his designated principal alternates, shall have acquired the exterience and training ,

r normally required for examination for a senior reactor operator's license. 1 The organization of CCNPPD is shown in Chapter 12 of the UFSAR. The Plant General; ,

Manager, delegates responsibilitics for accomplishing required activitics as follows: 'f

1. The Superintendent. Nuclear Operations (S-NO) is responsihte to the Plant General ,

Manager, for the operation of the plant, including the general supervision of all shift: l operating personnel and prioritization of maintenance activities to support operations. j This responsibility covers the safely of plant personnel and equipment, all fuel handling q and refueling activitics, and adherence to .' applicabic license and 1 regulatory j

- requirements. The S-NO fulfills the position and requirements of the Operations- -

Manager as defined in ANSI N18.1 (1971) with the exception taken in Tabic 1B.1. q l

The S NO delegates primary management responsibility to the Shift Supervisor (SS) on i duty to ensure the safe operation of the plant under all conditions. The SS maintains the broadest possible perspective on operational conditions that affect the safety of the plant. As the senint member of plant management on cach shift, he exerciscs the  :

command hathority of his position to take whatever steps he deems necessary during {

cmergency situations to place and maintain in a safe configuration any unit that may be  ;

affected. 1 I

2. The Superintendent-Nuclear Maintenance (S-NM) is responsible to the Plant General Manager for managing and directing activitics of the Nuclear Maintenance Section to provide high quality maintenance programs, plans and schedules, and qualified personnel to perform maintenance functions necessary to assure the safe, reliable, and economic operation of the plant to generate power within applicabic laws, standards, codes, and regulatory requirements.

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1 a. ' The General Supetvisor Electrical and Controls (GS-E&C), is responsible to the?

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. Superintendent Nuclear? Maintenance, for 7 the . conduct f of ' cicctrical ' and ;

"' instrument maintenance, repairiand nmdifications needed to keep the plant and E its facilitics, systems, and equipmem in safe and efficient wo king condition.- He' is responsible for planning and supervising or controlling the electrical ~and -

. instrument maintenance activitics conducted by plant maintenance personnel,'

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and for ensuring that work is performed in accordance with 'applicabic Codes and; y Standards and that required maintenance records are developed and kept. He is :

V responsible for controlling tools and equipment used for electrical and instrument - -e, maintenance, repair and modifications activities.-

p E b. ' The General Supervisor-Mechanical Maintenance (GS-MM),'is responsible tor the Superintendent,-Nuclear Maintenance,- for the : conduct of mechanical :

maintenance, repair, and modifications needed to keep the plant and its facilitics, systems, and equipment in safe and efficient working condition.- He is responsible -

. for planning and supervising or controlling the mechanical maintenance activitiesi

conducted by plant

maintenance personnel,'and 'for ensuring that work is-performed in accordance with applicable Codes and Standards and that required maintenance records are developed and kept. i He is responsible for controlling tools and equipment used for mechanical maintenance, repair, and modifications

activitics.

3. The Superintendent-Technical Support'(S-TS) is responsible- to'ahe Plant General Manager for managing and directing the activitics of the Technical Support Section to provide systems and performance engineering. surveillance testing > administration, chemistry and radiation safety support necessary to assure the safe reliabic, economic' operation of the plant, inservice inspection. and to establish appropriate standards for ^

the fire protection program. The S 'IS is also responsible to the Plant General Manager :

for overall direction and coordination' of activitics to ensure complianm with the.

Radiokyical Effluent Technical Specifications. This responsibility is= carried out through. the General Supervisor Chemistry;with support from. the 1 Director- -

., Environmental Programs and the Manager-FSSD.

' a. The General Supervisor-Chemistry (GS-C) is responsibic to the Superinic'ndent-

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Technical Support for the chemistry and radio chemistry of the primary and secondary systems and for maintaining- radioactive 'cffluents within specified:

limits. Additionally, the GS-C provides program management oversight of the -

Radiological Environmental Monitoring Program to ensure compliance with the Radiological Effluent Technical Specifications.

b. The General Supervisor Radiation Safety '(GS-RS) under .the nuclear QA m , Program, is responsible to the Superintendent-Technical Support for: c .

. Ensuring the radiation protection of personnel at CCNPP.

. Complying with radioactive material transport regulations.

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c. LThe l General: Supervisor. Plant Engineering"- (GS.PE)L is? responsible! to the t  !

Superintendent-Technical Suppo'rt for providing field engineering and technical: Y o m 1 '

cvaluation of plant systems and to evaluate and coordinate resolution of system -  !

y and component probicms > with operations,E maintenance,1and ' engineering : 1

- personnel for the Calvert Cliffs Nuclear Power Plant. : Additionally, the GS.PE is x l 1

10 responsible _to the S-75 for providing plant reliability /a'vailability testing and-

' cvaluation, : plant performance ' improvement, and. administration 1of 7 the _ c; SurveillanceTest Program. '

"A d. - The Principal Engineer-Nuclear Inspection Services 'is = responsible Lto Lthe1 i i

c , Superintendent Technical Support for providing inservice inspection services fora j the Calvert Cliffs Nuclear Power Plant.

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Manaccr-Nucicar Enrineerine Department )]

The Manager-NED,'is responsible for directing the efforts of perst nnel and providing l l resources necessary to support design. modification and engineering activitics covered by the .

, OA Program for.CCNPP. These activitics include nuclear, mechanical, civil, reliability,  :

instrument and c(mtrols, and electrical engineering; nuclear fuel management; configuration y management; life cycle. management; plant design support; fire protection documentation; ..

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q and engineering planning. ,

o. The organization of NED is shown in Chapter 12 of the UFSAR'. The Manager-NEDl '!

delegates responsibilitics for accomplishing the following activities: q

. Providing conceptual and detailed engineering, design and drawing? and data' base; l

L configuration control for the power and control systems for the Calvert Cliffs Nuclear j Power Plant. j Directing and performing safety evaluations, preparation and review of nuclear safetyi j accident and transient analysis, fuel management, nucicar engineering related to core  !

physics, reactor engineering and external fuel cycic management for the Calvert Cliffs Nuclear Power Plant.

Providing plant design support, and engineering planning and scheduling for the power -

and control systems for the Calvert Cliffs Nuclear Power Plant.'

Development and integration of programs necessary to operate Calvert Cliffs Nuclear - 1 Power Plant up to and beyond its current licensed lifetime; reliability engineering; and l

documentation and maintenance of plant design bases.- _j

,, Manaccr-Nuclear Outanc and Proiect Mananement Dcoartment ,,

1 The Mnnuger-NOPMD is responsible for directing the efforts of personnel and providing i resources necessary to support site integrated scheduling, outage management and project ,

management for assigned projects. The organization of NOPMD is shown in Chapter 12 of "

the UFSAR. The Manager-NOPMD delegates responsibilitics for accomplishing the folk) wing activitics: 1 Developing, implementing and maintaining a site integrated schedule which schedules ' j allsignificant plant related activitics at CCNPP. .j i

Managing the planning. scheduling and performing of all outages at CCNPP. j s

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- Providing overall project management for engineering, procurement, construction 'and

/, , testing of nuclear power plant modincation for CCNPP. 1 Manaccr-Nuclear Safety and Plannine Denartment

• The Manager-NSPD is responsible for directing licensing activities, independent safety [

evaluation activitics, cmcrgency planning, and industrial safety.'

P The organization of NSPD is shown in Chapter 12 of the UFSAR. The Manager-NSPD delegates responsibilitics for accomplishing the following activities:

- Providing Ilcensing services: coordination and operation of various industry information -

exchange systems: cvaluation of plant events and conditions adverse to quality for reportability to the NRC and other agencies, assisting in the investigatian and evaluation of cvents, and preparation of the reports; coordination of tracking and '

resolution of company commitments to the NRC; research and preparation of responses to NRC letters, bulletins, circulars and information notices: UFSAR research and revision control; maintenance and revision of the current licensing basis fut nuclear power plants; coordination of all compliance-related communications with external agencies including assistance in ensuring their consistency with existing licensing basis commitments; and coordination of regulatory inspections and visits and company presentations to the NRC.

Directing investigations of significant events to determine root cause, recommending  !

corrective action, and generating appropriate reports to document the investigation l results: directing a program for identifying trends within the corrective action syuems.

• Directing revice of the operating experience of other plants of similar design to determine the applicability of significant events with respect to CCNPP. (14)

Directing the efforts of BG&E personnel involved in emergency planning activities.

Directing the efforts of personnel under the Nuc! car OA Program to. develop, .

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implement and coordinate the industrial salcty and fire protection program for the CCNPP, and to plan, schedule, and monitor activitics directly related to safety, fire q protection, and prevention.

Manacer-Nuclear Sunnort Services Denartment  !

'the Manager-NSSD is responsible for training, nucicar security, onsite procurnment coordination, procurement engineering, procedures upgrade, state reguletory matters, strategic planning, and staff services functions for CCNPP. -

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L ,  ; , LThe organization of NSSD isIshown in Chapter 12 of the UFSAR. The Manager-NSSD, 'I

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delegates responsibilitics for accomplishing the following activitics:. , j i

, V iProviding: support to Managers inithe Nuclear' Energy Division toiensuretthcar-R, personnel are properly trained and qualified to perform their assigned duties, including) those dutics which implement the nuclear,OA Program. Training required by special'

, work - forces and contracton would L be performed by the3 appropriate- BG&E -

2 Department, and/or Host Company (vendor). '

o> w . i C Distributing, . and ~ coordinating- the preparation ; of revisions' to' the - QA Program ,

documents; collecting, storing, maintaining, and retrieving OA' records for nuclear - 1

power plants; maintaining, controlling, and distributing drawings and technical manuals > ' r!

m related to equipment, materials. Land services for nuclear powc_r plants; coordinating; l

. investigations concerning state regulatory matters; coordinating the efTorts of Nuclear _,

Energy Division personnel involved in the procurement of, structures, systems.

components, parts, ' and 'setvices - related L to the design,; constructionA fueling, maintenance, and modifications of CCNPP. <: ,

Establishing procedures to assure that SR and DNSR procurement documents identify ' I' technical and quality requirements; procurement (SR and DNSR) documents receive' independent review and approval for the proper inclusion of technical and quality ,.

requirements; ensuring spare and replacement parts are suitable for their intended; i

.t., application (s); specification of critical characteristics. and . acceptance criterier for  ;

dedication of commercial grade items: specification of special storage requirements for j age sensitive stems.

n Performing receipt inspection functions including 'special . receipt inspections" and-. j coordinating testing performed to accept commercial grade items, des;gnated NSR j items or upgrade NSR items for use in SR applications. (5)'  ;

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< Ensuring that the operational, maintenance, licensing, and training activities associated j with plant security are effectively implemented, and that nucicar security provisions '.

provide protection for personnel, equipment,' and facilitics at CCNPP against potential security threats. 1 1

Directing the efforts of personnel responsible'for the storage and issuance of items for : 1

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CCNPP.-

Development of the annual Strategic plan for the Nuclear Energy Division including the Nuclear Program Plan.

Individuals supporting the CCNPP QA Program are designated as follows: . -

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Vice President Fossil Fnerev Division l 1

The Vice President-FED, is responsible to the Senior Vice President-Generation for ensuring that . j c the activitics of FED personnel involved in CCNPP maintenance and modifications; Materials  !

Engineering and Analysis; and radiological environmental monitoring, meet the requirements of the  ;

.OA Program. 'this responsibility is carried out through the Manager-FEMD, and the Manager-~ :j FSSD. j

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/ A jManamer Fossil Fmincerinn & Maintenance Denartment <  :

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• The. banger-FEMD, is responsible for directing the efforts of FEMD personnel involved in > .

l maintenance and modification activitier at CCNPP _

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E' M Manaccr Fossil Support Services Denartment i

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, 1The Manager FSSD. is ressmsible' for dirdcting the efforts of FSSD personnel involved in' l j .' .'(1): maintaining and operating Radiological- Environmental; Monitoring' equipment and : .

% performing sampic collection and analysis,'(2) ensuring materials engineering and analysis _  ;

relating to SR structures, systems, and components are' completed .in accordance with-

-i i Company and regulatory requirements. ,

J Vice President Electric Interconnection and Transmission Division L . j 9

.The Vice President-EITD. is responsible for ensuring that the requirements of the OA Program that ; .

- relate to the calibration of test equipment and the testing of protective relaying, and metering . - l controls for SR clectrical power equipment are implemented. .This responsibility is carried out 1

through the Manager-ESOMD.  :

y-Manaccr Electric System Operation and Mritenance Department ,

. . . The Manager-ESOMD, is ressmsible for directing the efforts' of personnel involv'ed in thc:

,,..- testing of electrical power cguipment, the calibration of test equipment and the testing of +

protective relaying and metermg controls for the electrical power equipment of CCNPP. -  ;

Vice President-General Services Division - -

The Vice President-GSD is responsible for ensuring , implementation z of the O'A Program rcquirements that relate' to: 'the procurement of SR or designated NSR structures, systems, .  ;;

components, and services; the construction, maintenance, and operation of facilitiest and support-j semces for computer software and hardware.

These respmsibilitics are carried out through the Manager-PMMD, Muneger-ISD, and Manager , i FM D.

Manancr-Purchasine and Materials Management Department  !

The Manager-PMMD. is responsible for directing the efforts of personnel involved in the1 l purchasing ofitems and rcrvices for CCNPP and for the issuance of Contracts for Fitness for Duty Activities. -

Mananer-Information Systems Denartment ~i J

The Manager ISD, is responsible for directing the efforts of ISD personnel involved inD  !

acquiring and supporting computer software and hardware. l

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Manaccr-Facilitics Manancment Denartment ,

The Manager FMD, is responsible for directing the efforis of FMD personnel involved in the -[

, planning. design, construction, maintenance, and operation of facilities and related systems  ;

directly supporting or impacting power plant operations. '

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5 Vice President.Mananement Services Division f

. The Vice President-MSD, is respcmsible for ensuring that the activitics of MSD personnel involved  ;

with medical examinations for CCNPP operators, Nuclear Security Officers, and respirator users, meet the requirements of the regulations. The responsibility is carried out through the Manager-SMSD.

Manaecr-Safety and Medical Services Denartment The Manager-SMSD, is raponsible for directing the efforts of SMSD personnel involved with medical examinations for CCNPP operators (10CFR55), Nuclear Security Officen; (10CFR73), respirator users (10CFP.20), and with the Fitness for Duty rule (10CFR26).

Vice President-Cornorate Affairs The Vice President CA is resp (msible for ensuring that _OA Program requirements related to the Radiological Effluent Technical Specifications are implemented. This responsibility is carried out through the Director Environmental Programs.

1 H.2 OUALITY ASSURANCE PROGRAM General Controls -

The OA Program consists of the Updated Final Safety Analysis Report (UFSAR) Appendix IB, OA ,

Policy. Ouulity' Assurance Procedurcs, certain Nuclear Program Directives and their implementing procedures. The UFSAR Appendix 1B and OA Policy are the same document except for the way changes arc incorporated. The OA Policy is updated when cach change is approved. Revisions to the OA Policy are controlled by OA Program documents which are written to ensure compliance with 10 CFR 50.54(a)(3). %c UFSAR Appendix IB is updated annually. All OA Policy changes approved during the previous year arc incorporated during that update.  ;

The OA Policy identifics NRC regulatory requirements, indust y standards, and specific codes applicable to the eighteen criteria contained in 10 CFR 50, Appendix B. The OA Policy also -

indicates action that will be taken by BG&E in respons.c to these documents and to commitments made in the UFSAR and Tds for CCNPP. >

Ouality Assurance Procedures (OAPs) describe controls for the actions identified in the OA Policy. l OAPs cover major activitics related to operating a nuclear power plant, such as plant operation, plant maintenance, training, purchase of itemt, and services, calibrations, etc.

Nuclear Program Directives address actions identified in UFSAR Appendix 1B. Directives identify.

regulatory commitments, management requirements, and assign responsibilities for cach business function (i.e., design, maintenance, operations, etc.) within the BO&E Nuclear Program. As directives are written and implemented, they will systematically replace OAPs.

BG&E's OA Program for CCNPP is applied to structurcs, systems, components, and activities that ,

have been designated SR because they prevent accidents or mitigate the consequences of postulated accidents that could cause undue risk to the health or safety of the public. The OA Program is also applicabic to designated NSR structures, systems, components, activities, and servicca as required by in regulations. Designated NSR program requirements are based on a graded approach to Ouality Assurance required to meet applicable regulatory designated requirements aad guidance. The level

. of OA Program controls placed on designated NSR items are defined in OA Program documents Page 14 of 59 j

OUALITY ASSURANCE POLICY Revision 39 and/or implementing procedures. The controls from other sections of this OA Policy are selected as necessary to meet the particular regulations being implemented.

Controls have been established for specifying on a Quality List (O-List) all SR structures, systems.

componuits, and activities that are subject to the requirements of the OA Program.

The Statement of Authority,in the Ouality Assurance Manual for Ntelear Power Plants. signed by the Chairman of the Board, establishes the overall OA Policy of BG&E. This Statement sets the goal of safe and reliable operation of CCNPP; commits the Company to a OA Program designed to ensure the plant's compliance with regulatory requirements, BG&E commitments, and established practices for reliable plant operation; and requires every person involved in OA Program activitics to comply with the provisions of the Program.

The Pcaicy is approved by the Vice President-NED and implemented by Nuclear Program Managers.

(1)

The OA Program has established controls for BG&E and its contractors es required to ensure that the criteria of 10 CFR 50, Appendix B. will be met throughout the operations phase of the plant; i.e.,

during activitics of testing, operation, maintenance, repair, modification, and refueling.

The OA Program has also established controe to ensure that the construction, operational, and deco:nmissioning phases for the Independent Spent Fuel Storage Jnstallation (ISFSI) are conducted g in compliance with 10 CFR 72 Activities asso iated with the operational and decommissioning phase shall be controlled under the CCNPP 10 CJR 50 Appendix B OA Program; existing policies, programs, directives, and procedures stated as applicable for CCNPP are also applicable for tne ISFSI. (16)

Changes to the OA Program documents are issued with a transmittal notice, which is completed by the recipient and returned to indicate that the documents listed on the transmittal have been received and incorporated into the recipient's Manual. Nuclear Program Managers ensure OA Program documents are revised as regulations, standards, results, or experience dictate. (1) The

, Manager NOAD cvaluates the degree of compliance with the requirements of OA Program documents and procedures. Audits are conducted regularly to ensure compliance with established requirements, and the results of these audits are reported to responsible management personnel.

l The Vice President NED, ensures that activities of the NOAD are audited regularly by personnel iMependent of the Department. These auditors assess the effectiveness of the Department's nnplementation of appropriate portions of BG&E's OA Program. The Vice President-Nuclear Energy Division, evaluates the report of the independent audit to determine if changes are required to the OA Program. lie is responsibic for negotiating such changes with the appropriate level of management and for sending to the Chairman of the Board a copy of the audit report and an account of the corrective action taken.

If a difference of opinion arises between NOAD personnel and those of other Sections or Departments, the dispute is resolved as follows: The Supervisor / General Supervisor of the OA Unit /Section invohcd first trics to resolve the matter with the organization responsible for conducting the activity. If a resolution cannot be obtained, the matter is referred up through the following raanagement personnel until it is resolved: (3)

1. The Manager-NQAD, and the Manager responsible for performing the activity.

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if the dispute is with another Unit /Section in NOAD. the issue will be settled by the Vice President-Nuclear Energy Division. (3) = j l

2." The Vice President-Nuclear Energy Division. (1)

. 3. The Senior Vice' President-Generation, President and Chief Operating Officer, or the '

Chairman of the Board.

i To ensure that important activities are performed correctly, BG&E conducts formal training .  ;

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. programs for Company personne with significant responsibilities. _ These programs include both j o initial and continuing training and arc. conducted in accordance with written procedures. or instructions. Department Managers are responsible for ensuring that the training needs of personnel -

in their Departments arc identified. formal training programs to satisfy.those needs are developed,-  ;

and the training programs arc implemented in accordance with the requirements of the QA Program  ;

documents.

l The QA Program was developed to meet the requirements of the Regulations, Regulatory Guides, . l and Industry Standards of the Nuclear Regulatory Commission (N.7C) listed below. Exceptions taken to guidance contained in these documents and equivalent BG&E alternatives arc stated in  ;

. Tabic IB-1. 3 7

REGULATIONS i 10 CFR 50 55a Codes and Standards.  !

10 CFR 50.59 - Changes. Tests, and Experiments.

I" 10 CFR 55 - Operators' License.s j

1 10 CFR 50, Appendix H - Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.  ;

10 CFR 72, Subpart G - Quality Assurance (ISFSI)  !

i i

REGUI,ATORY GUIDES i

- 1.5 -' Personnel Selection and Training (September 1975)**. this endorses ANSI N18.1 I (03/08/71)"*. .

t I.16 Reporting of Operating information (as specified in Calvert Clifts Technical Specifications). 'l 1.30 - QA Requirements for Installation. Inspcelion, and Testing of Instrumentation and Electric.  !

Equipment (08/11D2)*. This endorses ANSI N45.2.4 (03/01/72). [

l 1.33 - OA Program Requirements (Operation. Rev. 2. 02n8)**. This endorses ANSI N18.7- i 1976/ANS 3.2 (02/19n6)'".  !

i l

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OUALITY ASSURANCE POLICY on 39 1.37 - OA Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (03/16n3)". This endo;;es ANSI N45.2.1 (02/26n3)*".

1.38 - OA Requirements for Packaging, Shipping. Receiving. Storage. and Handling of items for Water-Cooled Nuclear Power Plants (Rev. 2,0507)* *. This endorses ANSI N45.2.2 (12/2002)*".

1.39 llousekeeping Requirements for Water-Cooled Nuclear Power Plants (03/1603)*. This i endorses ANSI N45.2.3 (03/1503)"*.

I.54 - OA Requirements for Protective Coatings Applied to Water-Cooled NucIcar Power Plants (06/73)". This endorses ANSI N101.4 (11/28n2)*".

1.58 - Qualification of Nuclear Power Plant inspection Examination, and Testing PersonncI (09/80)". This endorses ANSI N45.2.6 (1978)*".

1.64 ' OA Requirements for the Design of Nuclear Power Plants (10n3)*. This endorses ANSI-N45.2.11, Draft 3, Rev.1 (0703).

1.68 - Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors (1193)".

1.144 - Auditing of Ouality Assurance Programs for Nuclear Power Plants, Rev.1 (09/80)**. This codorses ANSI N45.2.12 (1977).

1.146 - Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Aug.  ;

1980).*. This endorses ANSI N45.2.23 (1978)"*.

INDUSTRY STANDARDS ANSI N45.2.5 - Supplementary OA Requirements for Installation, inspection, and Testing of Structural Concrete and Structural Steel During the Condruction Phase of Nuclear Power Plants; Draft 3. Rev.1 (1103).

ANSI N45.2.8 - Supplementary OA Requirements for Installation. Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants: Draft 3.

Rev. 2 (09n3).

ANSI N45.2.9 - Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants; Draft (10n6)"*, j ANSI N45.2.13 - OA Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants: Draft 2, Rev. 2, (1093)"*.

r NOTATIONS FOR REGUI.ATORY GUIDES AND INDUSTRY STANDARDS i

i NRC cndorses an Industry Standard or draft without reservation.

" I NRC takes exception to or provides additional guidance in a regulatory position statement.

LIG&E takes exception to guidance offered and states alternatives.

i Page 17 of 59 t

OUALITY ASSURANCE POLICY Revision 39 Procedural Controls The OA Policy and revisions thereto are reviewed by Nuclear Program Managers. 'OA Policy revisions are reviewed by NOAD personnel to determine if they constitute a reduction in commitments prcViously made to the NRC. If so. the revisions are r,cnt to NRC for approval prior to implementation. De Manager-NOAD reviews revisions to the OA Policy and recommends approval to the Vice President-Nuclear Energy Division. The Vice President-NED approves the OA Policy and revisions thereto.

Each Ouality Assurance Procedure (OAP) is prepared by one or more of the Departments responsible for conducting the activity. The OAP and revisions thereto are reviewed by NED x Managers and affected Department Managers. The Manager-NOAD cnsures OAP revisions are reviewed by the Quality Assurance organization and recommends approval to the Vice President-NED. The Vice President-NED approves all OAPs and revisions thereto. The Manager-NSSD ensures issuance of all OAPs and revisions thereto. (1) OA Program documents control the -

distribution and revision of the OA Policy and other OAPs.

Nuclear Program Directives are repared under the direction of the Department Manager assigned by the Vice President-NED as the Program Sponsor. Each directive and revisions thereto are 6 reviewed by affected Department Managers. The Manager-NOAD cnsures directive revisions are reviewed by the Ouality Assurance organization and approval recommended to the Program Sponsor. The Program Sponsor approves the directive and sevisions thereto. The Managcr-NSSD

... casures issuance of all directives and revisions thereto.

OA Program documents ensure that:

~

1. The need for special controls processes, test equipment, tools, and skills is specified when necessary to ensure that required quality is attained in performance of the activity.

2. Quality is verified by inspections and tests.

3. Penonnel who perform activitics affecting quality achieve and maintain suitable proficiency through appropriate training and experience.

Administrative or Technical Procedures are prepared as needed. They establish the processes used to implement directive or OAP requirements. The controls for review and issue of procedures arc discussed in Sections iB.5 and 1B.6.

Review of Oncrations Pnicedures require that CCNPP shall be operated and maintained in accordance with the plant TSs and operating license. The following organizations review plant operations to ensure that these procedures are followed:

1. The Manager-NOAD provides independent verification that the requirements contained in the Plant's operating license. UFSAR, TSs, and plant procedurcs are met. This is accomplished through quality assurance audits.

2. The OSSRC provides independent verification by review that CCNPP is ope ated in accordance with established requirements. The OSSRC. which functions under a written Charter approved by the Vice President. Nuclear Energy Division, is composed of on-site and off-site personnel knowledgeable of in-plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, radiological safety. instrumentation and control systems, mechanical and electrical systems, quality assurance, and environmental factors. The Page 1M of 59

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- proceedings of all mcetings are documented and sent to the Vice President-Nuclear Energy

1. ~

i Division, Committee membes, and others designated by the Committee Chairman.

c3. The on-site.POSRC reviews matters pertaining to nuclear plant safety. ' This Committee >

l  ; screens subjects of potential concern to the OSSRC and performs preliminary investigations :

L under the direction of the Plant General Manager. POSRC membership and functions arc governed by Technical Specifications and written procedurcs. The results of all meetings are documented and sent to the members of the OSSRC and others designated by the Committee L

. Chairman.

The maintenance and repair of systems, structures, and components subject to the OA Program are performed by personnel under the direction of the Ocncrat Supervisors of Electrical and Controls,'

4- Radiation Safety, and Mechanical Maintenance, according to written procedures and instructions as '

prepared by the maintenance force and approved as stated in OA Program documents. Thesc :

Procedures:

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'~'

1. Ensure that quality.rclated activitics, such as inspections and tests, are performed with appropriate equipment and under suitable enviromnental conditions.

t

2. Indicate inspections and checks that must be made and records and data that must be kept.

3. Show where independent verifications of inspections m checks should be performed'.by-

~

.. specified personnel other than those performing the work. .

When necessary, non. plant Company personnel or outside contractors are brought in to supplement the plant wrwk force. In such instances, the approval of work procedures and the tagging of.3

, equipment are coordinated by a member of the BG&E organization responsible for the performance of thework.

Controls arc established in OA Program documents to ensure that materials and parts used in the :

repair, maintenance, and modincation of SR und designated NSR portions of,the plant arc -

.. appropriate for the service intended. Written procedurcs are prepared for the. storage and-identification of materials and parts to ensure that they do not detenorate in storage and can.be correctly identified before it.stallation or use.

Equipment manufacturers and contractors used for the repair, maintenance, and modification of SR and designated NSR structures, systems, and components. are required to have quality assurance programs consistent with the importance ofihe end-prmiuct to safety.

1 B.3 DESION CONTROL Control Plant changes which affect the design. function, or method of performing the function of a structure, system, or component described in the UFSAR and are controlled by OA Program documents which are written to ensure compliance with Regulatory Guide 1.64 and 10 CFR 50.59.

Controls for changes, tests, and experiments conducted at CCNPP vary according to the following:

1. As the item or activity affected is or is not described in the UFSAR.

2. A* the item or activity affected has been classified SR or NSR.

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OUALITY ASSURANCE POLICY Rcvision 39

3. As the item or activity affects or does not affect nuclear safety.

4. As the proposed change, test, or experiment does or does not constitute an Unreviewed Safety Question or require a change to the TSs.

To ensure compliance with 10 CFR 50.59 the process for controlling changes, tests, or experiments has been divided into classifications. Procedures required by QA Program documents describe and control the method for determining the appropriate process classification. The process classificationr control the preparation and reporting of safety evaluations. Three methods of treatment are allowabic:

1. Implementing the change, test, or experiment in accordance with Company practice for operating power plants, or in accordance with Procedures required by OA Psogram documents.

2. Impicmenting the change, test, or experiment in accordance with Procedures required by QA Program documents but controlling the change, test, or experiment with a process classification.

3. Controlling the change, test, or experiment with a process classification and not allowing the implementing activity to begin until the review requirements of 10 CFR 50.59 and 10 CFR 50, Appendix B, have been met.

Changes, tests, or experiments which require approval by the NRC are approved by the POSRC and by Ihe OSSRC.

Controls have been established to ensure that design changes to SR structures, systems, and components are reviews.d either by the organization that made the original design or by a Responsible Design Org; nization (RDO) that mccts requirements specified in ANSI N45.2.11, Section 8.0.

Resnonsible Desien O.canizations RDOs, either on contract or within BG&E, ensure that:

1. Applicable regulatory requirements and design bases requirements are correctly translated into specifications, drawings, written procedures, and instructions.

2. Appropriate standards for quality are specified in design documents, and deviations and changes from such standards are controlled.

3. Suitable design controls are used in applying principles of reactor physics; making scismic, stress, thermal, hydraulic, radiation, and accident analyses: ensuring compatibility of materials; and providing accessibility for in.scrvice inspection.

4. Designs are reviewed to ensure that design characteristics can be controlled, inspected, and tested, and that inspection and test criteria are identified.

5. Interfaces, both external and internal, are controlled for the activitics of all participating organizations.

6. Methods for verifying or checking, such as design reviews, alternative calculations, and qualification testing are properly chosen and f(&wed; the most adverse dcxign conditions are specified for test programs used to verify the adequacy of designs.

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7. .

.indNiduals or groups responsible for desigr. verification are other than_ the original designer d K .and the designer's immediate supervisor. '!

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M. ': Design and specification changes are subject to design controls and approvals applicable to the l originaldesign. :1

'I

. 9.~ - Design documents and - revisions thereto are distributed .to responsible individuals and - y' controlled to prevent inadvertent use of superseded material.  !

10. - Design errors and. deficiencies that adversely affect SR structures, systems, and components J

, . arc documented, and appropriate corrective action is taken.

<g 11. Design documents and ' reviews, records, and changes thereto are collected, stored, maintained,1 j

- 1 and controlled systematically.- a

12. Standard off-the-shelf commercial or previously ' approved materials, parts, and equipment c j essential to theJSR functions of: structures, systems. and components are reviewed = for i

_ suitability of application before they are selected. ,

,+,- 13. The persons or groups responsihie for design reviews and other design verification activitics . l and their authority and responsibilities are identified.

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E

14. Design changes to NSR items initiated and approved at the plant are contmlled to ensure  !

compliance with 10 CFR 50.59. _ j

. . i

15. Processes used to select suitable materials, parts, equipment, and pmcesses for SR structures,- 4 systems, anl components includes the application .of pertinent industry stanlardsDand l specifications, material and pmtatype hardware testing programs, and design reviews.~ j

. 16. Computer programs used in design are subject to design controls and program verification. -

18.4 PROCUREMENTDOCUMENTCONTROL(5) '

- Controls have been establashed to specify the requirements and sequence of actions for: requesting j items or services; review of the requested item or service to establish the necessary technical and y quality requirements; preparation, review and control of procurement documents; cvaluation and j selection of vendors and; control of deviations from the pmcurement tkicument requirements, j The degree to which these ctmtrols are imposed on the purchase of items and services by BG&E for l CCNPP depends on: ,

, , 1. The functional (safety) classification of each item or service as SR or NSR according to j ctmtrols established by the RDO and  :

2. The Procurement Category of the _ item within it's functional classification as a basic component, commercial grade item, designated non-safety related item (DNSR) or NSR item:

a. Commercial Grade - An item satisfying all three of the following criteria: .l t

1. Not subject to design or specification requirements that are unique to nuclear j facilitics; and '

2. Used in applications other than nuclear facilitics: and l

i

)

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~ 3. - Is to be ordered from the manufacturer / vendor on the basis of specifications set  ;

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forth in the vendor's published product description (for exampic, a catalog).; y

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b. Basic Component - An hem either procured as a safety related item or as a commercial -

grade item which has been accepted and dedicated for safety related application. . This !

term is synonymous with " Safety-Related Component".-

l} >

c.. l Designated Non-Safety Related - A NSR item which BG&E has made a regulatory or - .f design basis commitment;.or, for plant availability reasons. BG&E has impicmented >j special controls to assure reliability. These NSR items arc included within the quality ~

F , assurance process. :j i

d. Non-Safety Related 'An item that does not perform a safety related function.. j i

3. The procurement method to be used for the item or service:  !

l

' Purchase Orders placed by BG&E personnel for items or services intended for safety related -I applications and DNSR items and services fall into two categories, Nuclear Grade Method procurement and Commercial Grade Method procurement.

,q

a. Nucicar Grade - Purchases that arc designated to be placed with vendors . that maintam ? 'j a 10CFR50 Appendix B quality program and supply items that meet the definition-of j

s. Basic Component.' The requirements of 10CFR21 will be invoked on the vendor under  ;

this method. ,t i

h. Commercial Grade Purchases that are designated to be placed with commercial grade

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j vendors that supply items or services that meet the definition of Commercial Grade.  !

These items must he dedicated for SR use by BG&E.- i Items and/or services classified as DNSR will be purchased using the Commercial Grade - 'l Method with technical requirements established by an RDO. j 1

Qualified NSSD/NED. personnel trained in quality assurance program requirements with RDO [

authority review safety-rclated and designated non-safety related procurement documents for proper 1 inclusion of technical and quality requirements. Personnel in NSSD/NED review safety-related and ; j designated non-safety related procurement documents to ensure that the requirements stated therein  !

are correct, inspectahic, controllable, contain adequate acceptance and rejection criteria, and comply  !

with the requirements of the procurement program. These reviews and approvals are documented .I prior to placement of the purchase order. .!

t All changes made to procurement skicuments. including specifications and other' technical- .. ;

. , . attachments, are subject to the same levels of review, approval and control that were applied in; f preparing and processing the original documents.

Bids submitled to supply safety related items or services receive the same review and approval cycle as used for safety-related procurement requisitions.  :

Vendor Selection a

Personnel in NOAD cvaluate vendors who provide SR and designated NSR items and services to -

j

{ verify they can provide acceptable items and setvices.

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E ,  : Controis for Nuclear Grade Purchases .

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Controls have been established to ensure that, before placement of a purchase order under the.

Nuclear Grade method of purchase, there is evidence ofIhe following:

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1. Mc vendor has been evaluated as stated in Section IB.7for this policy and found to have a

- satisfactory OA program. .

'2. .The item to be purchased is manufactured under the requirements of the' evaluated and ~

approved program.

Controls for Commercial Grade Purchases

. Controls have been established to ensure that items or scavices available to general industry di bc -

sufficiently controlled to perform their SR and designated NSR function. NSSD/NED personnel will specify the acceptance methods to be used to verify the critical characteristics identified in.the procurement document (s).

Procurement Document Reauirements Procedures require that procurement documents shall':'

,, 1. Reference part numbers or descriptions, and additionni requirements to ensure that items' ordered can he identiGed and verification can be made~ that each item received is the item:

ordered.

2. Contain/ reference technical requirements for the basis of design, by including the applicabic regulatory requirements, component and material identiGcation, RDO approved drawing'and i specification, codes, industrial standards, test and inspection requirements, and special process instructions such as welding, heat treating, nondestructive testing, and cicanmg.'

3. Identify the requirements of 10 CFR 50, Appendix B, which must he complied with and described in the vendor's OA program, for Nuclear Grade Purchases.

4. Require that major contractors designated as BGAE agents to purchase SR and designated ^

NSR items or services must have procurement controls to ensure they purchase or acqoire these items or services in compliance with the necessary sections of ANSI N45.2.13.

5. Identify required documentation (i.e., drawings, specifications, procedurcs, inspection and fabrication plans, inspection und test records, personnel and procedure qualifications, and material chemical and physical test resuhs) to be prepared, maintained, and submitted to BG&E or the purchaser for review and approval. +

6. Identify records which must he retained, controlled, maintained, or delivered to BG&E or the purchaser before use or installation of hardware.

7. Specify BG&E or its agent's right of access to vendor facilities and records for source inspection, surveillance, verification and audits.

R Identify requirements of the vendor's quality control process which must be implemented when providing a commercial grade item.

9. Reference or specify the critical characteristics that a commercial grade item must possess to ensure that the item received is the item specified.

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OUALITY ASStJRANCE POLICY Revision 39

10. Incorporate the requirements of 10 CFR 21 for Nuclear Grade procurements.

. I 1. Include requirements for OA program elements to be passed on to sub-vendors.

18.5 INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS Controls delineate the sequence of actions to be performed in the preparation, review, approval, and control ofinstructions, procedures, and drawings.

Controls acquire that:

< l. Methods for complying with each of the applicable criteria of 10 CFR 50, Appendix B, must be speciGed in instructions, procedures, and drawings.

2. Instructions, procedures, and drawings must specify appropriate quantitative (such as dimensions, tolerances, and operating limits) and qualitative (such as workmanship samples) acceptance criteria for verifying that important activitics have been satisfactorily accomplished.

Controls ensure that:

1. The OA Policy is approved by the Vice President. Nuclear Energy Division. (1)

2. OAPs are developed by Departments responsible for conducting particular activities, reviewed by the managers of the responsible department (s) for that particular activity, and approved by the Vice President-Nuclear Energy Division. (1)

3. Nuclear Program Directives are prepared under the direction of the Department Manager assigned as the Program Sponsor. Affected Department Managers review directives and their revisions. The Manager.NOAD ensures directives are reviewed by the Quality Assurance organization and approval recommended to the Program Sponsor. The responsible Program Sponsor approves directives and their revisions. Directives are prepared, reviewed, approved, and periodically reviewed according to an appendix to the Nuc! car Program Directives Manual.

4. Procedures are prepared, approved and controlled according to the Control Procedures.

Control Procedures establish review, approval, revision. change, and periodic review requirements for applicable paredures. If format and content requirements are not contained in Control Procedures, they shall specify the document to be used to determine format and content requirements. Control Procedures are reviewed by the Quality Assurance Organization. Other procedures arc reviewed by Quality Assurance on a reuuested basis.

5. Basis ite ms added during procedure revisions or changes will be recorded. (1) 1 11.6 DOCUMENT CONTRO!.

Requirements have been established to control the documentation of activitics controlled by the QA '

Program. OA Program controlled documents include the UFSAR: Operating License, including the Technical Specifications; Emergency Response Plan; Security Plan: OA Policy; the ISFSI updated Safety Analysis Report (SAR) and Materials License,includingTechnical SpeciGcations; procedures; specifications; and drawings.

1 Revisions to the OA Policy are controlled by OA Program documents which are written to ensure compliance with 10 CFR 50.54(a)(3).

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. Alterations to the UFSAR are controlled by OA Program documents which are written to ensure-compliance with 10 CFR 50.71. 1 1

Alterations to the ISFS! updated SAR are controlled by OA Program documents which are written

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to ensure compliance with 10 CFR 72.70. .j 1

- Alterations to the Operating License, including' the Technical Specifications, are controlled by OA l

. Program documents which are written to ensure compliance with.10 CFR 50.59(c) 10 CFR 50.90 l and 10 CFR 50.92.

. Alterations to the ISFSI Materials License, including & technical specifications, are controlled by ,

OA Program documents which are written to ensure compliance with 10 CFR 72.48(c),10 CFR0 72.56, and 10 CFR 72.58.

~

. Alterations to the Emergency Response Plan are controlled by OA Program documents which arc.

written to ensure compliance with 10 CFR 50.54(q), and with 10 CFR 72.44(f) for the ISFSt. I L

Ahcrations to the Security Plan are controlled by OA Program documents which are written to  !

casure compliance with 10 CFR 50.54 (p), and with 10 CFR 72.44(c) for the ISFSI. q OAPs are required to: i

, . . 1. Establish controls to ensure that regulatory requirements and BG&E commitments wilt 4e; _h implemented.  !

2. Describe interdepartmental interfaces and establish controls for interdepartmental activities.

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3. Specify how important activities, such as plant maintenance or in-service inspection, are to bc l performed, and give sufficient detail to control the performance of the activity or to ensure  ;

that requirements for kwer. level procedures are clearly specified.  ;

4. Be prepared and controlled in accordance with QA Ptogram documents that describe the- f format, sequence of topics, contents, review and approval, issue and distribution, and j requirements for revision and record retention.  :

'l During the review of each OAP, compliance with applicable criteria speciried in 10 CFR 50  !

Appendix B, is verified and documented.  !

The Manager-NSSD,is responsible for issuing, revising, and controlling OAPs.

~ OAPs are developed by one of the departments responsible for the subject activitics. Each  !

procedure is given a compliance review by a member of the Ouality Assurance Organization, and-  !

technical review by a member of one of the responsible departments. Each OAP is reviewed -hy i department manager (s) who have responsibilitics for activitics governed by that OAP, and the  !

Managers of the Nuclear Energy Division. (1) Each OAP is approved by the Vice President Nuclear  !

Energy Division and issued by the Manager-NSSD. (1)  !,

Directives are required to: 'I

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1. Establish controls to ensure that regulatory requirements and BG&E commitments will hc  ;

impicmented. 1 l

2. Establish ccmtrois to ensure that management requirements will be implemented. ,j l

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QUALITY ASSURANCE POLICY Revision 39

3. Assign responsibilitics and interfaces within the program.

.,,< ' 4. ' Be prepared and controlled in accordance with an appendix to the Nuclear Program Directives Manual that describes the format. contents, review and approval, revisions, and periodic review requirements. .

' Nuclear Program Directives are prepared and technically reviewed under the direction of the Department Manager assigned as the Program Sponsor. Each directive is reviewed by affected Department Managers. - Each directive is given a compliance review by a member of the Qualny Assurance organization. Nuclear Program Directives are approved by the sponsoring Manager after ensuring resolution and incorporation of OA compliance review comments. (9) The Manager-NSSD ensures issuance of each directive.

Administrative and Technical Procedures are prepared when needed to implement OA Program ,

document requirements according to a Control Procedure. Individual organizations are responsible for preparing, revising. issuing, and controlling procedures. Each procedure is given a technical review under the direction of the sponsoring organization. The Quality Assurance organization performs compliance reviews on Control Procedures. Other procedures are reviewed by Ouality Assurance on a sequested basis.

Organizations that issue instructions. procedures, specifications, or drawings are required to establish controls that ensure the following: e

1. Changes to a document are reviewed and approved by the organization that performed the original review an0 approval unless the control procedure designates another qualified respansihic organization.

2. Approved changes are promptly incorporated into instructions, procedures, drawings, and other documents, associated with the change.

3. Obsolete or superseded documents are cont olled to reduce the possibility of inadvertent use.

, Superseded documents retained for reference are marked and stored in separate files. Other superseded documents are removed from the files. ,

When changes to drawings or specifications are required, change requests are prepared by the.

organization that desires the change. Requests are reviewed and approved by BG&E RDOs.

1 B.7 CONTROL OF PURCil ASED MATERIAL EOUIPMENT. AND SERVICES (5)  ;

NOAD, NSSD, NED, and PMMD pery.onnel are res]xmsible for the control of purchased items and services for SR and designated NSR applications at CCNPP. l The controls include: ,

Accepting iten. , r services only from vendors who have been evaluated and selected in

• accordance with this , olicy.

Procurement docun. :nts for spare or replacement parts of structurcs, systems, and ,

components as desigri ted under the QA Program subject to controls at Icast equivalent to those applied to the original equipment, or an evaluationijustification shall be documented  !

when less stringent controls are involved.

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Vendor surveillance, veriGcation' and audit activitics, and receipt verification are conducted ;

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. to ensure the vendors comply with specified technical and quality requirements, and ensure =  ;

' items are identified, stored, handled and shipped in accordance with procurement document .

requiremems.  !

? Vendor Evaluation ' ,

1The vendor evaluation is conducted to determine acceptability of a vendor to provide the requested item or service, to determine what vendor programs, procedures and documents need to be invoked :  :

. by the procurement document, determining the vendor's performance history for supplying items to L

.CCNPP and assessing the need to impose source surveillances andAir. verifications during the Emanufacture of items or performance of services for BG&E. Vendor evaluations depend on the. '

l procurement classification of the item (s) Icing supplied,  !

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The National Institute of Standards and Technology (NIST), by virtue of its being the nationally; q j

recognized standard, is an acceptahic provider of calibration masters, standards or services. Utilitics

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holdmg an NRC Construction Permit or Operating License are acceptable suppliers of all items cxcept for those items 'to be used in' an ASME Boiler- and Pressure Vessel Code Section Ill' l application. = Neither of the above are required to bc listed on the Approved Vendors List (AVL).

J Nuclear Grade ,

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~i NOAD performs evaluations and audits to verify that' the vendor has developed,and5 l impicmented an acceptable quality assurance program that complies with'the requirements j; specified in the procurement speciGcation or proposed procurement specification. These-

. cvaluations and audits are conducted and documented using written procedures or checklists '}

that identify the OA requirements applicabic to the items supplied. l Commercial Grade Since BG&E accepts the responsibility of verifying the conformance of dommercial grade' d items and/or service, they may be procured from vendors with no formal quality assurance - .

program. In this instance. BG&E dedicates the commercial grade item and/or service for SR use.  :

A survey may be performed of commercial vendors to assess what, if any documented - i controls arc implemented in the manufacture ofitems or performance of services for HG&E. .

. Vendor controls evaluated to be satisfactory may be invoked as requirements within the 'j purchase order and may te used as part of the basis for acceptance of the item.

1 The depth of vendor evaluation varies according to the complexity and function of the item  :

mvolved and to the role of the vendor in acceptance of the item. y

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, Upon completion of the evaluation, satisfactory vendors are added to BG&E's AVL The vendors on this list are evaluated on an annual basis and subject to re-audit _or commercial grade survey on a -  :

triennial basis to verify continued compliance whh BG&E's requirements. .j

An auditing organization such as NUPIC, another utility, a contractor to BG&E, etc., may be used to j verify that the vendor has developed and impicmented a OA program that complies with 10 CFR 50,  !

Appendix B or a commercial grade program that complies with the requirements of BG&E's i procurement requirements or similar requirements.

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Revision 39 j When required by operational considerations, an order may' be placed with a vendor prior to'- l completion of the evaluation and approval process only after obtaining the Manager-NSSD's'  ;

y d approval. BG&E's acceptance of basic component items or services provided by an unapproved  ;

vendor is contingent on the suinequent NQAD cvaluation and approval of the vendor as stated  !

above.  !

. VeriGcation of Vendor Activitics .f it - . .

%, Vendor surveillance, and source verification activities are conducted by qualified NOAD personnel..

in accordance with written procedures or checklists. These procedures or checklists, along with the e procurement documents, specify the characteristics or processes to bc witnessed, inspected or.-

verified. Personnel performing these activities are qualiGed to establish whether or not a vendor is, 1f capable of providing r.roducts of acceptable quality. ~{,

The depth and frequency of vendor surveillances, verifications and audits is commensurate with the . -

complexity and function of the item or service and the ability of the vendor to provide the necessary ,

assurance of acceptability. .,

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When a vendor's certificates orconformance are used as part of the acceptance of an item or service,  !

, .- the validity of these documents is periodically evaluated and documented by the above mentioned 1 processes l Reccint j NSSD is responsible for receiving and storing materials parts, and components.  :

q Additionally, NSSD is responsible for performing standard and special receipt inspections and j coordinating testing necessary to accept SR items, designated NSR items and commercial grade items  !

for SR use.  ;

1 Standard receiving inspection of items is performed to assure the following: l i

1. The item is properly identified and that this identification corresponds with the documentation {

received. i i

2. Stated packaging, shipping and handling requirements have been maintained. -!

3. Items have not been damaged, workmanship is of adequate quality, and the items are  !

adequately clean in accordance with procurement document requirements. ,i

4. Documentation required by the Purchase Order has been received and is reviewed to assure  !

. that the item conforms to the purchase order requirements. .l 1

Special receiving inspection may be required if the item was not inspected at the source; when i requested by the RDO or; as part of the acceptance basis for commercial grade items.  !

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A written record of the results of the NSSD receipt inspection and the disposition of received items is maintained as part of permanent plant records.

All SR and designated NSR items accepted and released for issue to a controlled storage area or -

released for installation or further work bear an acceptance tag and have documentation to support their acceptability. If traceability is lost or the documentation review is unsatisfactory, an item becomes subject to the controls established for non-conforming items.  ;

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r OUALITY ASSURANCE POLICY Revision 39 Non-conforming items are identified and handled in accordance with Section IB.15 of this policy and, when practicable, are placed in a s:gregated area to prevem inadvertent installation or use until proper disposition is made.

Documentation BG&E procurement documents require vendors to provide documentation identifying the purchased item and the specific procurement requirements that are met by the item.

Vendor inspection records or certificates of conformance attesting to acceptance must be in the possession of BG&E before the item may be released for installation or use. However, an unacceptable item may be given a " Conditional Release" if there is reasonable assurance that it can be made accepot% after installation but before the system that contains it is considered operational.

L Items released under

• Conditional Release" must be controlled under the Non Conformance Report (NCR) system.

Vendor requested deviations from procurement document requirements, including nonconformances dispositioned "use.as-is" or " repair" must be submitted to BG&E for evaluation and approval of the deviation or a recommended disposition prior to shipment.

1 B.8 IDENTIFICATION AND CONTROL OF MATERIALS. PAR %. AND COMPONENTS (5)

NSSD/NED personnel ensure that procurement documents require that SR and designated NSR items, including partially fabricated sub.assemblics, are identified and controlled to prevent the u.*e ofincorrect or defective material. ,

Requirements for identification by use of heat number, part number, or serial number, or by other means, are referenced or stated in procurement documents. These documents reqmre the identification to be placed on the item or in records traccable to the item so that the function and quality of the item are not affected. This identification is required to be maintained throughout fabrication, storage, crection, installation. and use. NSSD personnel ensure traccability information is correctly transferred to subdivided materials stored in the Warehouse. User organizations ensure traceability information is correctly transferred to subdivided materials after issuance from the Warchouse. NOAD is responsible for performing periodic inspections or surveillances to verify program adherence.

Assigned NSSD personnel purchase identify, store, and issue items as specified by procurement controls and provide for maintaining the integrity of items and their traccability to associated documents during storage und issue.

BG&E contractors and their sub-contractors (who are approved to work on. site under their own OA program) are responsible for establishing and implementing programs in accordance with specified requirements for identifying and controlling materials, parts, and components under their jurisdiction.

Identification of items important to the function of SR and designated NSR structures, systems, and components can be traced to appropriate documentation such as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and chemical mill-test reports.

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i OUALITY ASSURANCE POLICY Revision 39 Receipt SR and designated NSR items received at CCNPP are rcccipt inspected to verify that all requirements of the procurement documents have been met. If a discrepancy is observed, such as damage or missing documentation, infotmation to the effect is recorded on the receiving inspection

. report, and the discrepant item is identified as such and placed in a separate " hold" area when practicable. If the item is acceptable,it is ider tified to indicate acceptance and that it is approved for storage or installation and use. When groups of items in storage are subdivided, each subgroup is separately identified.

If an item is found to be or is made discrepant during processing, it is identified as such and placed in a separate area when practicabic.

Acceptance documentation is required to be traceable to a purchase order, drawing, specification, requisition number, or assembly. As individual items are assembled, installed, and inspected, their acceptance tag numbers are recorded in plant maintenance or operation records.

After completion of tests and inspectiores, records that document test results and traceability are kent as part of the plant records.

1 B.9 CONTROL OF SPEC 1 AL PROCESSES Controls Controls have been established for writing, qualifying, approving, and issuing procedures to control such special processes as welding, heat treating, and nondestructive testing used during the operation of CCNPP. Special Process Procedures:

1. Arc prepared in accordance with applicabic codes, standards, specifications, criteria, and of her special requirements.

2. Ensure that special processes are performed by qualified personnel according to qualified procedures that comply with applicabic regulatory requirements.

a 3. Specify requirements for control, parameters in he considered, Occeptable methods of documentation, and the codes, standards, specifications, or crite ia which govern the qualification.

4. Define the necessary qualification of personnel, procedures, or equipment when special processes are not covered by existing codes or standards or when quality requirements for an item execed the requirements of established codes or standards.

BGkE contractors and their sub. contractors are responsible for controlling special processes used by them and for maintaining records to verify that special processes are performed in accordance with requirements established by the portions of their OA programs that apply to special processes.

Qualification of Methods Procedurcs, equipment, and personnel connected with special processes are qualified in accordance with applicable codes, standards, specifications, or supplementary requirements as follows:

1. Welding activitics conducted by BG&E are performed according to welding procedurc ,

specifications qualified in accordance with applicable welding requirements of the ASME l Code. Each welding procedure specification is written, qualified, and approved in accordance j I

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, widt a controlling documen'ted procedure. Copics of welding proosdure speciGcations'are ..

I A fmade available to welders and, when required, to . Sorized Inspectors. Before contracting :

. for welding. the Principal Metallurgist reviews and approves non-BG&E welding' procedurc ,

!(f p-specifications and procedure qualification records in accordance with a written procedure. - .j 3

2.= Heat-treating requirements included in welding procedure specifications are established is . I conformance with heat treating requirements of the applicahic ASME Code. j

, 3. Nondestructive. Examinations. are , performed : to written procedures; proved ; by actual .  !

demonstration, when practicable, to the satisfaction of the Principal Metallurgist and, when " .i

r* required, the Authorized Inspector.

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These procedures are prepared according to appropriate $cctions of the ASME Code for particular/ j examination methods._ Procedures, personnel qualifications, and the" records that verify theu 3 ~!

Performance of Nondestructive Examinations are kept as nuclear, plant records. Nondestructive - .,

' Examination Procedures describing methods not described in' the ASME Code and/or SNT-TC 1A j and its Supplements ;are at least equivalent to those recognized by the. American Society' of' Mcchanical Engineers and the American Society for Non-destructive Testing. : Training programs d acceptable to the Principal Metallurgist are developed to complement these alternative methods and y' to establish the capabihty of personnel to perform the required examination according to BG&E' procedures and to the level of performance to which the individual will be certifiedJ

s. . Methods of Nondestructive Examination include, but are not restricted.to, radiographic, .

uhrasonic, liquid-penetrant,' magnetic-particic, cddy-current, visual, and " leak-testing -

examinations. Procedures are prepared to c(wer these examinations in accordance with a ; 3 OAP that details the specific examination, requirements for approval, and content of the r i procedure, such as certification level, accept / reject criteria, examination coverage and a

sequence, surface preparation, test equipment, . records required,Kpermissible marking, cleanup requirements and reference to applicable sections of the ASME Code.'  ;

Oualification of Personnel f

'i Special processes are performed by certified personnel using written process sheets,C shhp procedures, checklists, and travelers (or equivalent), with recorded evidence of verification as -

follows:

1. BG&E wclders, and welders under contract to BG&E, are qualified and certified Ein .. i accordance with the requirements of Section IX of the ASME Code and the: welding ,

procedure specifications they .will be using when . welding. The Principal: Metallurgist - j maintains records of the weldmg procedure specifications, including essential variables under which the wclders are examined, and the results of the examinations. : A welder is not-  !

. permitted to weld SR and designated NSR items until an appropriate: performance  ;

qualification record, a letter of certification,'or, in an cmergency, . verbal cicarance from the - .

Principal Metallurgist, is on file at CCNPP. Each ' welder is required to be requalified as  !

specified in the applicabic code. .

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2. Non.BG&E wclders are not permitted to weld SR and designated NSR items until they are :  ;

qualified and. certified in accordance with Section IX of the ASME Code to the welding; .. ;

procedure rpecification Ihey will be usmg.

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OUALITY' ASSURANCE POLICYJ '

Revision 395 3.; - Nondestrtictive Examination personnel empkiycd by or responsible to BG&E are certified 1 i

. according to applicable sections of the ASME Code and/or SNT-TC-1 A and its Supplements. j

- BG&E cmployecs are trained and certified in accordance with a written procedure. Non - ,

HG&E personnel are qualified to procedures approved by BG&E, and their qualifications and l certifications of penonnel arc verified according to written procedurcs. j Qualification records of procedures, equipment, and personnel associated with special processes!'

conducted by BGAE are filed and kept current by the Principal Metallurgist. l The Manager NOAD provides independent verification that special processes are performed by

. qualified personnel.  ;

i B.10 ~ INSPECTION -;

Activitics that affect the quality of SR and designated NSR items are inspected as speciGed in d approved instructions, procedures, and plans _which set forth requirements and acceptance criteria to'  ;

casure that work is done in conformance wilh' particular requirements.

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Controls exercised during inspections ensure that:

1. Penonnel who perform quality verification inspections are independent of the personnel who - t performed the activity being inspected, j i

'2. Inspection procedures or instructions, with necessary drawings and specifications for use, are j available before inspection operations are performed. 3 r

3. In the case of special pmcesses, inspectors are qualified, and their qualifications comply with applicable codes and standards. jl i

4. - Test and measuring equipment is calibrated within required limits. j

< ,.. 5. Inspection procedures, as applicahic, specify objective acceptance criteria, prerequisites for performing inspections, limiting conditions, requirements for special equipment and Ouality . 1 Verification (OV) hold points at which inspections are to be witnessed. ]

6. Appropriate inspection requirements arc established for nedification, repair, and .j replacement. 1 1

7. Personnel who perform quality verification inspections are qualified in accordance with i}

appropriate codes, standards, and Company training programs, and their qualifications and  !

certifications are kept current.

8. Procedures for maintenance and modification are reviewed by OV personnel to determine the ' i need for independent inspection and the degree and method if such an inspection is required,- l and to ensure the identiGcation of inspection personnel and the documentation of inspection '

results. i

9. Procedures for Nondestructive Examination, excluding visual examination procedures  ;

performed on nuclear fuel, are reviewed by qualified personnel in FliD. Procedures for  !

nuclear fuel inspection and visual examination on nuclear fuel are reviewed by qualified l personnel in NED. Review is to determine the adequacy of procedural controls and of inspection criteria, the need for independent inspection. and the degrec and method,-if such  :

inspection is required; and to ensure the identification of qualiGed inspection personnel and  !

the documentation of inspection results. l l

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10. . Inspection results are recorded, evaluated, and retnined.-

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. l Inspection procedures, instructions, and checklists used by QV personnel provide the folkiwing:

l c 1. Identification of characteristics to be inspected.- ,

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27 Identification ofindividuals or groups responsible for performing the inspectionc . l

! 3. ~ Acceptance and rejection criteria. .;

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4. Description of the method ofinspection.. j

. 5. - Identification (includmg revmon number) oficquised proceduies, drawings and specifications. d

6. Identification ofinspector or data recorder. -

7. Verification of completion and certification of inspection. .;

R Record of results ofinspection. < i i

9. Provision for identifying mandatory inspection hold. points for witness for an authorized -l inspector or BO&E inspection personnel. .;

1

10. Provision for indirect control by monitoring processing methods, equipment, and personnel if -l j

direct inspection is not possible. ' c y

11. Specification of necessary measuring and test equipment including requirements for accuracy, +

0 The Ocncral Supervisor-Quality- Verification (GS-OV)'is responsible for. the preparation and-  :

implementation of procedures for activities conducted by Ouality Verification personnel. (II) j 1,. Other inspections are conducted randomly to verify that overall plant operations-are being -)

conducted according to approved procedures _and to ensure that the use of jumpers is properly 1  !

documented; that equiper.cnt is returned to operating status after test, modification, or repair; that '

l instruments are properly calibrated: and that personnel who perform tests are properly trained and. 1 qualified. j o

in-scivice inspections are performed on pressure-containing components within the reactor coolant ~l system boundary according to requirements of the TSs.

In-service inspections and examinations on components designated Class I or Class 11 by the! ASME -

Code are witnessed or otherwise verified by an authorized Code Inspector who is responsible for ensuring that the work is performed by qualified personnel according to written qualified procedures.

Records of in-service inspections, results, corrective action required and taken inspection standards l s .!

required for repair, and results of inspection of repairs are maintained and compared with the results 9 of subsequent examination.  !

18.11 TEST CONTROI,  !

~l

~ To demonstrate the ability of SR and' designated NSR structures, systems, and components to l function as designed, they are subjected to a program of surveillance and operational testing.  !

Procedures specify the systematic development, review, approval, and conduct of tests and review of' I test results. Conditions ~ such as failures, malfunctions, deficiencies, deviations, and non-  :

conformances discovered during testing are documented and evaluated. j t

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OUAIJIY ASSURANCE POLICY Rcvision 39 Whenever testing is required to demonstrate that SR and designed NSR material, parts, components, or systems will perform satisfactorily in scrsicc, a test program is established and procedures are used that have been written and approved in accordance with basic requirements.

Nuclear Engineering Department, and CCNPPD conduct tests to verify that plant behavior conforms to design criteria, ensure that failure and substandard performance arc identified and controlled, and demonstrate satisfactory performance after plant modification and maintenance activities.

l Written test procedures are developed, reviewed, and approved before testing is performed. They specify instructions for testing, methods of test, test equipment, and instrumentation; and for the following as applicable:

1. Adequate and appropriate equipment.

2. Preparation, condition, and completeness ofitem to be tested.

~4. Suitable and controlled environmental conditions.

4. Mandatory inspection hold-points for witness by BG&E inspection or authorized inspector personnel.

5. Provision for data collection and storage.

6. Acceptance and rejection criteria.

7. Methods of documenting or recording test data and results.

R Provision for ensuring that test prerequisites have been met.

Test results are documented and evaluated; they are accepted or rejected by a qualified, responsible individuat or group.

Results of completed tests on SR and designated NSR structures, systems and components (per Q-List) that identify a malfunction or were out of specification are reviewed and evaluated by the POSRC and accepted and approved by the Plant General Manager. Test records are kept in sufficient detail to make possible an evaluation of test results and to show how individual tests demonstrate that SR and designated NSR structures, systems, and components and the plant as a unit can operate safely and as designed. SR and designated NSR test records are retained as plant history records.

Results of testing performed as part of receipt inspection are evaluated, accepted and approved by qualified NSSD personnel. (S) 111.12 CONTROL OF MEASURING AND TF.ST FOUIPMENT Calibration controls have been established to prescribe the technique and frequency of celibration, maintenance, and control of measuring and test instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive test equipment used in measuring. inspecting, and monitoring SR and designated NSR components, systems, and structures during the operations phase of CCNPP.

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1 i Personnel of 'thh following functional organizations control, calibratef and adjust measuring and test '

? qs ~ ,; equipment:

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-i < ' Electric System Operation and Maintenance Department Calvert Cliffs Nucicar Power: -- ' Radiation Safety l Plant Department; - Performance Enginbering Unit ' a

. Mechanical Maintenance i

- Electrical and Controls <

- Nuclear Operations - I u ,

- Chemistry '

- Calibration controls require cach group to identify measuring and tcat equipment and calibration test M data related to it.

'j Written procedures are prepared and implemented to en.<ure that tools, gauges, instruments, and-

' related test and measurmg devices are of proper accuracy to verify conformance to established - i requirements. ,

Y Manufacturer's Procedures are used for calibration or a procedure is prepared for cach category of,  !

measuring and test equipment as necessary? These Calibration Procedures contain the following - ~

1 information:

L Identification of the item to be calibrated and its period of calibration.

2. Standards to he used, specil~u: test. points, and checks. tests, and measurements to be made. Q

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3. Acceptance criteria to be used and special precautions lo be taken when necessary.  ;

. Measuring and test equipment that require calibration ' arc assigned an identifying serial . number. j Instruments are calibrated at specified intervals according to the required accuracy, purjose, degir.c .

.., of usage, stability characteristics, and other conditions that affcet the measurement.  ;

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When equipment is found out of calibration, an evaluation is made by the supervisor responsible for .  :

that equipment to determine any adverse effect on items previously accepted on the basis of using i that equipment. i Test and measuring equipment that cannot he adjusted to required tolerances during calibration is .,

identGed and placed in a designated segregated arca; if the equipment can be used in limited l

- apdications, the limitations are identified.- j The status of each item controlled under the calibration system is recorded and maintained.  !

. Equipment is marked or records of calibrations are maintained to indicate calibration statusiE An  !

interval of calibration is established for each item of measuring and test equipment and recorded on a "i master record of calibrations prepared as a calibration schedule. -

Measuring and test equipment is controlled to prevent the use' of uncalibrated or defective equipment, the spread of radioactive contamination, the introduction of impurities into high-purity j systems, and damage to or loss of equipment. Identification tags are placed on measuring and test j equipment to indicate such special conditions as radioactive cleanliness, special limitations, or failure .. ;

lo meet established calibration requirements. j I

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Measuring and test equipment is calibrated and adjusted at specified intervals, or before use, against #

-certified standards. Reference and transfer standards are traccable to nationally recognized standards; or, where national standards do not exist, provisions are established to document the basis ~- i for calihratlon.

1B.13 HANDLING. STORAGE. ANDSHIPPING Appropriate and special requirements for handling, preservation, storage, cleaning, packaging, and shipping of SR and designated NSR items are specified in procurement documents.

t Procedures have been established to ensure that the handling, preservation, storage, cleaning, packaging, and shipping of SR and designated NSR items are performed in accordance with specified -

requirements to reduce the likelihood of damage, loss, or deterioration by such environmental '

conditions as temperature or humidity. i

Special handling, preservation, storage, cleaning, packaging, and shipping activitics associated with ,

SR and designated NSR items are performed by suitably trained personnel in accordance with j specific written procedures.

g Controls have been established for the safe storage of hazardous materials. Items with a limited a shelf life are controlled to ensure that they will not be used in SR and designated NSR applications-  :

af ter expiration of designated shelf life periods.

I B.14 1NSPECTION. TEST. AND OPERATING STATUS l Controls have been established for the application and removal of status indicators such as tags,-  ;

markings, labels, and stamps to ensure that the inspection, test, and operating status of SR' and  !

designated NSR structures, systems, and comjxments is clearly indicated at all times.  ;

Procedurcs/ instructions are prepared to identify and control inspection, testing, and operating status a by the use of logs, forms, and tags that identify the inspection, test, and operating status of structures, . ,

.. systems, and components: control the use of indicators, including the authority for their application and removal; control bypassing operations, such as jumping or temporary removal of electrical leads; and identify non conforming, inoperative, or malfunctiomng structures, systems, or components.

Seninr shift personnel are responsible for aligning, isolating, and appropriately tagging installed j equipment and systems so that activitics affecting quality can be performed.

The Manager NOAD is responsible for the performance of surveillances to verify that the i inspection, testing, and operating status of structures, systems, and components are properly identified and controlled during operation, maintenance, and testing of the plant.  ;

The bypassing of required inspections, tests, and other critical operations is controlled to ensure that l bypassed inspections or tests are properly documented and that the elTect of hypassing the inspection or test is evaluated by the organization responsible for specifying the inspection or test. Controls have been established to ensure that the status of non-conforming, inoperative, or malfunctioning l SR and designated NSR structures. systems, or components is identified to prevent inadvertent use.

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~ IB.15 NONCONFORMING M ATERI ALS. PARTS. OR COMPONENTS (6)

1. - . Controls have been established for identifying, documenting, segregating, reviewing, dispositioning, j

~ and notifying alTected organizations of lasues affecting materials, parts, or components (i.e., items). j issues affecting nuclear plant items are referred to as nonconformances. ' Nonconformances are ~  !

p - hardware deficiencies which render the quality of an item unacceptable or indeterminate. t

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Any individual identifying an actual or suspected nonconforming item is responsible for documenting :

and reporting such. nonconforming. item promptly to supcavisory or Nuclear Quality Assurance' '?

Department personnel.~

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, Nonconforming items are umtrolled 'hy documenlution. marking, logging, tagging, or physical?

segregation to prevent inadvertent installation or use. .l l;

Nonconformance ' control documents arc submitted to responsible _ departments. for resolution. .

Designated personnel have the responsibility and authority for approving the resolution of -

nonconformances. Nonconformance control documents are not closed until corrective actions have been completed. .;

Nonconforming items are dispositioned as rework, repair, reject, or accept-as-in.' The disposition of a 'l repair or accept as is nonconformance is treated as a design change and is evaluated and approved or-rejected by the RDO.  ;

Reworked, repaired,'and replacement items are inspected and/or tested in accordance with the $

original inspection and/or test requirements or . acceptable alternatives to ensure that ' critical t characteristics possibly affected by the nonconformance remain acceptabic.- '

l Nonconforming items may be conditionally released for 1 installation, test,x energization, pressurization, or use if the conditional release will not adversely affect nor preclude' identification ,

and correction of the nonconformance. Nonconforming items required for Technical Specification j operability may be released for use following verification that the nonconforming item meets all operability requirements specific to its function and is approved for use by authorized Operations - .

personnel. Conditionally released items will be resolved in accordance with this Section. Conditional u release evaluations are documented, reviewed, and approved prior to implementation. j I B.16 ' CORRECTIVE ACTION (6) -

Controls have been established to ensure that Issues are identified, documented, reviewed,: and corrected. These controls are applied to deliciencies associated with the programmatic content, r process, and implementati m of the Ouality Assurance Program as well as nonconformances (ref y '

Section 1 B.15).

Corrective actions arc implemented by responsible personnel and may include immediate actions, remedial actions and/or actions to prevent recurrence, based on the significance and extent of the Issue. .l t

issues identified as potentially impacting the safe production of nuclear power are evaluated for.  ;

Technical Specification Operability, NRC Reportability, Nuclear Safety Significance. and_if the; activity should be stopped. The VP-NED, or designated alternate, is informed of issues which .

require NRC notification.  !

Corrective action verification is performed for Significant Issues prior to the close-out of the corrective action document. Verification is performed and documented by individuals not directly.

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I involved with impicmenting the corrective action (s). Unacceptable corrective action (s) are reported' .l' to supervisory or management personnel directly -responsibic. for resolving the issue and to progressively higher levels of management until the Issue is resolved. l

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Significant issues require a root cause analysis and the impicmentation of corrective actions to prevent recurrence and are reported to management for review and assessment.

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! Issues are periodically analyzed for the identification of adverse quality trends. The existence of an L adverse quality trend is resolved in accordance with this section. A Trend Report is issued to j management at intervals specified in approved procedures. , j p .;

. ' I B.17 OUALITY ASSURANCE RECORDS  ;

Controls have been established to ensure that quality assurance records are maintained to' provide :I documentary evidence of the' quality of SR and designated NSR items and activitics. Applicable  :

, ' design specifications, procurement documents, test procedures, operational procedures, OAPs, TSs, j and other documents specify records that should be generated, supplied, or maintained by and for.

• BG&E.  :

- Quality assurance records are classified as lifetime or non. permanent.  ;

Lifetime records, maintained for particular items for the life of CCNPP, for particular items have j significant value in relation to demonstrating capability for safe operation; maintaining, reworking, ,

repairing, replacing, or modifying an item; determining the cause of an accident or malfunction of an -  ;

item; and providing required baseline data for in-service inspection.

Non-permanent records, which show evidence that a SR and designated NSR activity was performed +

in accordance with applicable requirements, are retained for periods sufficient to ensure BO&E's ability to reconstruct significant events and to satisfy applicable regulatory requirements. Retention ,

periods are based on requirements specilled in OA Program documents. Retention periods shall bc -

documented.

Procurement documents specify venckir responsibilities for the generation, retention, and submission j to BG&E of quality assurance documentation related to the fabrication, inspection, and test of SR -

and designated NSR items and services. _

Inspection and test records contain the folh> wing as appropriate:  ;

1. Description of the type of observation.

1

2. Date and resuhs ofinspection or test. .j

3. Information related to noted discrepancies, including action taken to resolve them. f 1

4. Identification of inspector or recorder of data.  !

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5. Statement as to acceptability of results.  !

Controls have been provided to ensure that records are protected from possible destruction. l Within established time-intervals, completed lifetime records are transmitted to the Records .l Management Unit for incorporation into the leng Term Records Storage and Retrieval System.

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' Internal audits are performed by BG&E's Quality Audits Unit to ensure that activities and -

procedurcs established to implement the requirements of 10 CFR 50, Appendix B, comply.with, '

= BG&E's overall OA Program. ..These audits provide a comprehensive independent verification and '

- cvaluation of quality-related activitics and procedures. Audits ensure the eficctive and proper ,

implementation of BG&E's OA Program. They are scheduled on the basis of the importance to

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- safety of activitics being performed.  !

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- Vendor audits are performed to evaluate OA programs, procedures, and activitics. Audits of major.-

vendors are made early enough to ensure compliance with all aspects' of BG&E's procurement

, documents. Additional audits are performed as required to ensure that all requirements of BG&E's - ,

OA Program are properly implemented according to piocurement skicuments.

Audits of designated activitics as required by the TSs are performed under cognizance of the - < -6

. OSSRC.

Audits are performed in accordance with preestablished written procedures or checklists by'qualified '

NOAD personnel who have no direct responsibility for the work being audited. Technical specialists  :

from other BG&E departments and outside consultants may assist as necessary in performing audits. 1 Audits include objective evaluation of quality-related practices, procedures, instructions, activities, ,

and items, as well as review of documents and records.- -

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- Reports of audits are analyzed and documented. Results that indicate the OA~ Program to bc -  ;

inadequate, ineffective, or improperly impicmented, including the need for re-audit of deficient - -l' areas, are reported to the Manager and Supervisor of the audited activity. Controls have been established for verifying that corrective action is taken promptly to correct noted deficiencies. i To ensure that BO&E's NOAD complies with the requirements of BG&E's OA Program, an independent management audit of NOAD activitics is performed annually by a Joint Utility Management Audit (JUMA) Team. D I

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- QUALITY ASSURANCE POLICY Revision 39 TAllLE 111-1 ItALTIMORE GAS AND ELECTRIC COMPANPS POSITION ON GUIDANCE CONTAINEli IN ANSI STANDARDS ,

Revision ofIndustry Standards Annlicable to the  ;

Haltimore Gas and Electric Ouality Assurance Program Rcouirement Some of the Industry Standards listed in Section 1H.2 identify other Standards that are required, and .r some Regulatory Guides define the revisions of those Standards that arc acceptabic to the NRC. ,

Response

. BG&E's OA Program was developed to respond to the specific revision of the documents listed in Section 1B.2 and is not necessarily responsive to other documents listed in the referenced Industry Standards.

ANS 3.2 - 1976 Item 1

, Reagirement ,

Section 5.2.15 requires that plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure every two years to determine if changes are necessary or desirabic. ,

Resmmse BG&E applics this requirement of a two-year review to all plant procedures except test procedures performed less often than every two ycan or at unspecified frequencies. These are reviewed no .

more than 60 days before performance.

Reason Engineering Test Procedurcs (ETPs) and others like them are written for a one-time-only performance and kept for reference for future similar tests. If they are used again, they are reviewed '

and modified to meet conditions existing at the time of performance.

Some Surveillance Test Procedures (STPs) are performed cycry three to five years. They too are reviewed before cach performance to ensure that they are compatible with existing conditions and ,

responsive to current needs. ,

Item 2 00)

Rcouirement Section 5.2.2 specifies that temporary procedure changes that cicarly do not change the intent of the approved procedure shall as a minimum be approved by two members of the plant staff Page 40 of 59 i

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, knowledgeable in the areas affected by the procedure; and at least one of these lndividuals shall bc  ;

the supervisor in charge of the shift and hold a senior operators' license on the unit affected. .

Response

l BO&E does not require the Shift Supervisor to be the Senior Reactor Operator (SRO) approving '

- temporan changes to procedures; any active SRO (cither on-shift or on-staff) may provide the SRO ..

approval for procedure changes.

Reason  ;

'Many proposed _ temporary procedure changes do. not require the Shift Supervisor's immediate

- attention or knowledge of the change since they do not affect plant safety. Other SROs are available .  ;

and qualified to perform this task since the Shift Supervisor's detailed review of the proposed change ;  ;

. is not necessary to ensure plant safety. ,

Requiring the Shift Supervisor to review all changes is hurdensome and contrary to plant safety in  :

light of the total number of procedures that exist and the time the Shift Supervisor must dedicate to .l ensuring the plant is safely operated and maintained. Additionally, our Technical Specification- .

requires this approval' hc from someone holding an SROLiicense (not' necessarily thcL Shift Supervisor).  ;

ANSI N18.1 - 3/8/71

l QUALITY ASSURANCE POLICY ,

1 Revision 39 Reason The S.NO will hol'dor have held an SRO license, as opposed to having a license at the time of appointment to the position. He will have an excellent understanding of plant operations. The GS .

NPO will not only hold an SRO_ license at the time of appointment to the position, but he will maintain the license. The GS.NPO directly supervises the operating shift organization, whereas the  :

S.NO is also responsible for operations procedure development, modifications acceptance, and operations / maintenance coordinations. The S.NO's level of supervision does not require current  ;

in-depth and plant specific knowledge which results from maintaining an SRO license.

i ANSI N45.2.1 - 1973 Reauirement Subsection 3.2 outlines requirements for dcmineralized water.

Resoonse .

BG&E specifications for demineralized water are different than the specifications outlined in the standard ~ ,

Reason i

BG&E specifications for demineralized water are consistent with guidelines provided by the Nuclear

,. Steam Supply System supplier. BG&E specifications are generally more restrictive than those specified by ANSI N45.2.1.

t ANSI N45.2.2 - 1972 i

P ltem 1  ;

Reauirement Subsection 2.4 could be interpreted to mean that on-site and off-site personnel who perform any inspection, examination, or testing activitics related to the packing, shipping, receiving, storage, and handling ofitems for nuclear power plants shall be qualified in accordance with ANSI N45.2.6. .

Resminse BG&E requires that only persons who are responsible for approving items for acceptance shall be qualified in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6) and that personnel who verify that storage areas meet requirements will be qualified to either Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or ANSI N45.2.23.

Reason i Our reccipt inspection procedures require persons who approve items for acceptance to be qualified in accordance with Regulatory Guide 1.5H (which endorses ANSI N45.2.6). OV technicians. .;

inspectors or QA auditors verify that storage areas meet requirements. All other inspection, .i l

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examination, and testing activities are subject to review by persons qualified to Regulatory Guide . 1

.1.58 (which endorses ANSI N45.2.6).

1 3

, j leess2 Rcouirement ,

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%c second sentence of Subsection 2.4 requires that: -l q

' OIT-site inspection ' examination. .or testing shall be audited and monitored by -

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personnel who are qualified in accordance with ANSI N45.2.6.

'l Hesponst-  ;

BG&E uses personnel qualified in accordance with ANSI N45.2.23 to perform' auditing and :l monitoring functions.

j h' BEMo_0 The qualification requirements for auditors cannot always be met by persons qualified to Regulatory j!

Guide 1.58 (which endorses ANSI N45.2.6).

Item 3 l.I Reauirement  !

Subsection 2.7 requirca that activitics covered by the Standard shall be divided into four levels, .

though recognizing that within the scope of cach level there may be a range of controls depending on i the importance of the item to safety and reliability. 1 i

Rennonse l j

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1. The level of protective measures defined by Subsection 2.7 are applied to ? sic Component purchases.

2. Personnel of BGAE's Nucicar Enginecting Department (NED) will determine the level of 1 protective measures to be applied to Commercial Grade purchases.. j

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OUA1.lTY ASSURANCE POLICY Revision 39 Reason BG&E's position is as follows:

1. For Commercial Grade items. it is not always possible to assign a' level of classification in accordance with ANSI N45.2.2, as many items are purchased after they have been packaged by the manufacturer and shipped to his local agent, the wholesaler.

2. Experience has shown that the level of protection assigned to Commercial Grade items by vendors is adequate.

Ikm4 Recuirement Subsection 3.0 specifies detailed requirements for packing items for cach level defined in Subsection 2.7.

Response

BG&E has replaced Section 3.0 with the following:

1. Packaging for Shipment to BG&E Personnel of BG&E's NED or NSSD shall ensure that procurement documenti for Basic Component and Commercial Grade item purchases either indicate that the normal methods of packaging and shipment used by industry in general are acceptabic for the item being

, procured or specify the level of protection assigned to the item and the requirement that the vendor conform to applicable requirements for items in that classification defined in Regulatory Guide 1.38 Rev. 2 - March 1977.

2. The normal methods of packaging used by the industry in general are acceptable for items being procured as Commercial Grade.

3. Packaging for Storage by BG&E in general the packaging used by the vendor to ship items for all types of purchases to BG&E need not be retained after the item is received by BO&E, provided that the item is ss sted in an arca that meets the requirements for a storage area for the level of protection assigned to the item. Special or unique items, however, may require special protective measures. For such unusual items, the Department that initiated the purchase, together with NED, or NSSD s. hall identify if any of the requirements of Section 6.4.2 of ANSI N45.2.2 - 1972 apply.

Remon

1. This substitution will ensure that the item will rcccive adequate protection during shipment and storage, thus climinating unnecessary restrictions and enabling BG&E to use commercial sources to the utmost.

2. Experience shows that industrial practices for packaging Commercial Grade items are adequate for most applications.

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QUALrrY ASSURANCE POLICY Revision 39 item 5 Recuirement Section 4.0 defines shipping requirements related to the protection levels assigned to items.

Ilesponse BU&E has replaced Section 4.0 with the following:

1. Shipping to Baltimore Gas and Electric BG&E will invoke the requirements for shipping specified in Section 4.0 of ANSI N45.2.2 -

1972 on Basic Component purchases only when NED or NSSD personnel have specified in procurement documents that the item shall be packaged in conformance with ANSI N45.2.2,

. Section 3.0.

BG&E will not invoke the requirements of ANSI N45.2.2 1972, Section 4.0, on Commercial Grade item purchases.

2. Shipping from Baltimore Gas and Electric

,.. Items shipped Imm BG&E need not conform to any of the requirements of ANSI N45.2 2,. hut the organization that packs and handles the item shall provide roughly the same level of protection that the item was given during shipment to BG&E.

Reason if engineering personnel have determined that the vendor's methods of packaging are acceptabic, they have already determined that the supplicr's methods of shipping are adequate. As items are shipped from BG&E only for repair, the detailed requirements specified in Section 4.0 of ANSI N45.2.2 are not necessasy.

Item 6 i

Reatirement Subsection 6.4 gives detailed requirements for care of items in storage, according to the protection levels assigned to the items.

Response

BG&E does not require items to be stored in the packing used for shipment if the storage levelin the area provides the same protection as the level of packing assigned to the items. Caps, covers, etc.,

will be required only if specified by NED or NSSD personne'.during the procurement process. If an item is taken from one storage area to another, however, the persons who move it are responsible for ensuring, as applicab!c. that additional packing is supplied to give adequate protection during transportation.

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OUALITY ASSURANCE POLICY Revision 39 Reason The degree of protection given an item during str, rage should be tailored to the importance of the item to safety and the probability of deterioration during storage; to base storage requirements purely on the categories in Subsection 2.7 of ANSI N45.2.2 - 1972 is impractical. BG&E requires NED or NSSD personnel to specify requirements more closely related to the actual function ofitems and to storage conditions.

Item 7 R_couirement i Subsection 733 requires compliance with a r. cries of ANSI documents.

Resoonse BG&E controls for the use of hoisting equipment are compatible with the Standards listed in Subsection 7.3.3 of ANSI N45.2.2. although at the discretion of the Plant General Manager, they need not he compatibic with documents referred to in these documents.

Reason y.

Lower-level documents referred to in the documents listed in Subparagraph 7.3.3 will not necessarily affect the ability of BG&E personnel to properly handle SR items and could lead to confusion.

ANSI N45.23 - 1973 lit m 1 Reauirement Subsection 2.1 outlines housekeeping cleanliness requirements for live designated zones.

Response

BG&E has established three classes for cleanliness requirements. There is no class equivalent to the ANSI 2Mnc 1. Requirements of ANSI Zones 4 and 5 have been consolidated into DG&E's class 3.

Reason

1. ANSI Zone I level of cleanliness applies to new construction activities.

2. Where required, smoking restrictions are posted for DG&E's class 3 areas.

Item 2 Reovirement Subsection 2.1 requires for Zones 1.11. and 111, that a written record of the entry and exit of all personnel and material shall be established and maintained.

Page 46 of 59

y, OUALITY ASSURANCE POLICY Revision 39 Ecsponse i-BG&E has established the following methods for personnel and material accountability:

1. . Written accountability.

2. ~ Where possible lethering of tools and materials to permanent plant structures or persons.

' 3. Post maintenance closcout inspections.

Reason BG&E's three methods of accountability offer the same level of control as that required by the r.tandard.

ANSI N45.2.6 - 1978 Item i Reauirement Subsection 1.2 states in part, The requirements of this standard apply to personnel who perform inspection, examination, and tests during fabrication prior to and during receipt of items at the ccmstruction site, during construction, during preoperational and startup testing, and during operational phases of nuc! car power plants.

Restense-A Personnel of BG&E's Ouality Assurance organizations within the NOAD who perform inspections, examinations, and tests at the plant site during operational phases of the nuclear power plant are requhed to be qualified in amudance with Regulatory Guide 1.58 (which endon.cs ANSI N45.2.6).

All other BG&E personnel who perform inspection, examination, and losting functions associated with normal operations of the plant are qualified either to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) car to ANSI N18.1 - 1971.

Reason A

1. The individuals who perform inspection, examination, and testing functions associated with normal operation of the plant, se ch as maintenance and certain technical reviews, are normally qualified to ANSI N18.1 - 1971.

2. Some testing activitics conducted during normal operation of the plant, such as surveillance testing, do not require that test personnel meet the requirements specified in Paragraph 4.5.2 of ANSI N18.1 for technicians. Personnel qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) are adequately qualified to conduct such testing.

Page 47 of 59

OUALITY ASSURANCE POLICY Mdon 39 e Resnonse-B s

BG&E does not always require vendor personnel performing inspection or test activities to comply with the requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) but evaluates the need for invoking Regulatory Guide 1.5fi (which endorses ANSI N45.2.6) on the vendor during the review of procurement documents. The requirements are not applied to procurement classified as Qimmercial Grade.

Reason-H BG&E's position is as follows:

1. For replacement items purchased as Commercial Grade items. the purchaner may not impose nuclear unique requirements on the vendor. Additionally, items may be manufactured before placement of the purchase order and the vendor may not be required to maintain records of the performance of inspections or tests.

2. For Basic Component Purchases, the qualification requirements for inspection, examination, and test personnel are determined by:

a. Item status (new or replacement).

b. Complexity and importance ofitem.

c. Manufacturer's OA program approval level (Appendix B, ANSI N45.2, etc.).

Resoonse-C BG&E does not require persannel who perform specific limited and repetitious inspection functions, such as inspection for removal or replacement of snubbers, to be trained as required by Regulatory Guide 1.58 (which endorr.cs ANSI N45.2.6).

Reason-C Inspections, examinations, or tests that are repetitious or of limited scope need not be performed by individuals qualified to the requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) provided that they receive instruction in the following:

1. Activities to be verified.

2. Acceptance critci n.

3. Method of documenting results.

4. Method of reporting deliciencies.

The person responsible for the inspection activity ensures that such instruction is given to inspectors ,

before they perform specific inspection functions, and that both this training and the acceptability of the results of the inspection are documented.

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OUALITY ASSURANCE POLICY Revision 39 p

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- Resoonsc-D When it is necessary to monitor the activiit cs of a vendor, BG&E uses personnel qualified as auditors in accordance with ANSI N45.2.23 or inspectors in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6).

Reason-D Both Regulatory Guide 1.58 (which endorses ANSI N45.2.6) and ANSI N45.2.23 establish training requirements suitable for monitoring vendor activities.

Item 2 Recuirement Table I specifics that level 111 personnel shall be capable of qualifying lxvel 111 penionnel.

Responte When there is only one level 111 position or when a new level 111 position is created, BG&E personnel with the title General Supervisor, or higher, qualify Level 111 personnel.

Reason

. BG&E personnel in these grades are capable of certifying Ixvel 111 personnel without being trained as level 111 inspectors.

NOTE:

Regulatory Guide 1.58 (which endonees ANSI N45.2.6-1978) states in part, under item 6 of Regulatory Position, that..."In addition to the recommendations listed under Section 3.5 (of ANSI N45.2.6-1978) for level I,11, and til personnel, the candidate should be a high school graduate or have carned the General Education Development equivalent of a high school diploma...." Based on the NRC letter dated January 17,1985 from Thomas T. Martin to A. E. Lundvall, Jr.,

the above educational requirements will be implemented . for inspection, examination, and testing permnnel hired or assigned after November 27.1984. in addition to the present commitment to ANSI N45.2.6-1978 for the qualification of such personnel.

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ANSI N45.2.9 - 1976' t

4 Items I , '!

F Reauirement - '

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. Section 4.0 titled " Receipt" gives instructions for receipt controls.-

' Resnonse - ,

HG&E applies these requirements only to the reccipt of records by the Plant History File.'

.l Rear.on +

i Most records received by such organizations as Receiving Inspection. Engineering, etc., are not j shipped in a manner that makes these requirements applicable. These requirements are applicable, however, when the records are finally turned over to the Plant History Filc.

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Reauirement l

. t Subsection 5.6.1 reads as follows, " Design and construction of a single record storage facility shall .

meet the following criteria:" Items a) and b) of the subsection state that: 1

_j "a) Reinforced concrctc. concrete block, masonry, or equal com.tr uction."

"h) A floor and roof with drainage control. If a Door drain is provided, a check valve )

(or equal) shall be included."  ;

t-Besnonse/ Reason  :

l llem a  !!

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The intent of this requirement is both structural integrity and fire resistance. This vauh is' entirely j enveloped by a structurally sound, fire resistive building. Second, the vault rests on a reinforced slah  !

on grade and its walls extend fully to the underside of the structural deck. Third, the walls of the i vault are constructed of gypsum wallboard on metal studs per Underwriters Laboratory Test Number j U412, assuring the equivalent of 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire resistive ccmstruction. This is equal construction to ' l concrete bkxk in terms of fire protection. The walls carry ng structural load; hence, they provide l equivalent structural integrity to that needed of concrete block. (Sce footnote following page).- j Resoonse/ Reason l

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Item b f

Again, the vault is con i or need for Door drain.jained withinfollowing (See footnote an environmentally page). protected building. As such, it has no roof, l

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Item 3 - ]

L . Reauirement e  ;

Subsection 5.6 allows only the dual facility defined in Subsection 5.6.2 as an alternative to the single. I facility defined in Subsection 5.6.1. l i

Response j BG&E allows.the following alternative storage requirements for organizations other than the l Records Management Unit:  ;

Organie.ations that originate records and do not transfer them to the Records Management '!

Unit within 30 days of completion shall estahtish one of the following three controls as j alternatives to the requirements specified for ihe Records Management Unit: i

1. Duplicate Storage l Either A or B. f i

A. Within 30 days of completion of a record, a duplicate record file shall be established.  !

This activity shall be controlled by procedures which provide for the following:

1. Assignment of responsibility for records. l i

2. Description of storage area. l

3. Description of filing system.  ;

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4. An index of the filing system.  !

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5. Rules governing access to and control of files.  ;

6. Methods for maintaining control of and accountability for records removed from the file.

7. Method for filing supplemental. information and disposing of superseded or f obsolete records. ,

I R Method for preserving records to prevent deterioration. [

9. Method for maintaining specially processed records that are sensitive to light, i pressure, or temperature. $

i These responses have been forwarded to the NRC by the BG&E letter dated 02/11/83 from l

Robert G. Nichols, Sr. Facilitics Project Administrator, Real Estate and OITice Services .

Department, to Terry L Harpster, Chief OA Branch. Division of OA, Safeguards and l Inspection Programs, IE, USNRC. These responses have also been accepted by the NRC in  ;

their letter dated 04/22/R3 from Walter P. Haass, Deputy Chief, OA Branch, Division of Quality Assurance, Safeguards, and Inspections Programs, Office of Inspcetion and {

Enforcement.  !

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10. ' Transfer of duplicates to the Records Management Unit within two years of completion of records.

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B. . Make arrangements with at least one other department that receives a copy of cach

- ' document to subject this other copy to the controls specified above. .

2. Fire-resistant Building Storage l Records shall be stored in steel cabincts hicated in a fire-resistant building or a non- I combustible building with a Hre suppression system. '!

t The procedural controls defined for duplicate storage shall be applied.

c 3. Non-fire-resistant Building Storage

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! Within non-fire resistant facilities, records shall be stored in UL one-hour minimum fire rated storage cabinets and be subject to the procedural controls defined for duplicate storage. ,

HG&E defines a Fire-resistant Building as follows: l A facility constructed to resist the initiation or spreading of fire; non-combustible

, and/or fire-suppressive materiak used; building certified as fire-resistant by the Risk Management Unit of BG&E's Cbrporate Finance Group. .l Reason Although these alternatives are compatible with standard methods of handling records, they do not  ;

materially decrease the level of protection afforded to the records. '!

ANSI N45.2.23 - 1978 l

Item I  !

i Reauirement .

2.3 Qualification of Lead Auditors l Section 2.3.1 requires prospective Lead Auditors to obtain a minimum of ten credits under the j scoring system defined in paragraphs 2.3.1.1-2.3.1.4.

1 Resnonse ],

i BG&E has revised the scoring system as follows:  ;

Fducation and Experience  !

The prospective Izad Auditor shall have accumulated a minimum of ten credits under the 'l following scoring system:

i 1.0 Education (4 credits maximum) l l

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QUALITY ASSURANCE POLICY Revision 39 1.1 For the Associate degree for an accredited institution, score one credit, if the degree is in engineering, physical sciences, mathematics, or quality assurance, score two credits. Or, for the Bachelor degree from an accredited institution, score two credits;if the degree is in engineering, physical sciences, mathematics, or quality assurance, score three credits.

1.2 For the Master degree in enginecting, physical sciences, business management, or t quality assurance from an accredited institution, score one credit.

1.3 For the successful completion of part of the required curriculum for an Associate.

Bachelor, or Master degrec, score a corresponding percentage of the credits specified above for the degree.

1.4 For the successful completion of Navy Nuclear Training, its equivalent in another armed service, or the training required for becoming a licensed operator in a commercial nuclear power plant, score two credits.

2.0 Experience (9 credits maximum) 2.1 Technical Experience (5 ciedits maximum)

For experience in engineering, manufacturing, construction, operation, ,or

7. , maintenance, score one credit for each full year. .*

2.2 Nuclear Experience If two years of technical experience have been in the nuclear field, score one addilional credit.

2.3 Quality Assurance Experience if two or more years of the technical experience have been in quality assurance or quality control, score two additional credits. Persons whose work activitics are controlled by the QA Program but who are not full time members of the QA organization may be awarded half the credits that would be given to a person with specific quality assurance experience.

2.4 Audit Experience if two or more years of the technical expesience have been in auditing, score one additional credit.

2.5 Supplemental Experience Persons who have a proportion of the experience specified in 2.1-2.4 may be awarded a corresponding percentage of the credits specified.

2.6 Time exclusively spent in training does not apply as credit toward experience requirements for lead auditors.

3.0 Training (2 credits maximum)

Persons who have successfully completed the training requirements of ANSI N45.2.23 may be given two credits.

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QUALITY ASSURANCE POLICY -

Revision 39 4.0 Rights of Management (2 credits maximum)

The Manager-NOAD, may grant additional credits for other performance factors applicabic to auditing as follows:

6 4.1 For certification of competence in engineering or science related to nuclear power plants, or in quality assurance specialtics, issued and approved by a State t Agency or National Professional or Technical Society, score two credits, 4.2 For nuclear experience in excess of 2 years, score one credit for each two years  ;

experience.

4.3 For practical experience that can be related to powcr plants,in excess of 5 years, score one credit for each two years of experience. ,

Rcason .;

BG&E is in agreement with the basic purpose of ANSI N45.2.23..that is, to establish mimmum educational or experience requirements for lead Auditors. We think, however, that the system of  ;

- credits outlined in ANSI N45.2.23 tends to reduce the size of the pool of potential replacement auditors without making redeeming improvement in the capabilitics of persons selected.

We calculated the credit score of 11 of our present Lead Auditors at the time they were appointed

.b.,

lead Auditors. Six had completed Navy Nuclear Training and spent several years in the Navy Nuclear Program. Four of these scored only H credits total, including 2 credits allowed by paragraph 2.3.1.4 of ANSI N45.2.23 for rights of management based on their having completed the BG&E QA training programs for lead Auditors. ,

One of our auditors, with neither nuclear nor power plant experience, had a credit score of 12 because he held a Bachelor's degree in engineering and was a professional engineer with over 5 years  ;

design experience.

Because all of these individuals have acted as lead Auditors satisfactorily for several years,it appears ,

that the credit system should be revised slightly to allow.for the differences in education and' -l 2 experienrx of prospective lead Auditor candidates. ,

We consider the Oaw in the current system to be the emphasis on educational requirements that will nilow a person with a Master's degrec and no nuclear or power plant experience to become a Lead Auditor, but will exclude a person who has no degree, even though he may have 20 years' experience in operating or maintaining nuciens or power plant syntems.

?

The practical balance between education and experience will vary with individuals and particular-work assignments. Any attempt to establish rigid requirements is likely to allow some unsuitahic candidates to meet the qualification requirements while excluding some acceptable candidates.

For these reasons, we think that the supervision of prospective Audit Team leaders should be given  ;

more Ocxibility in determining whether, for a particular individual, educational or professional j qualifications are more significant and valuable than past experience.

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! OUALITY ASSURANCE POLICY Revision 39 The present credit system, while recognizing the Associate degree, gives no credit for completion of

< the nuclear training programs. We think that someone who has taken Navy Nuclear Training or its equivalent in another armed service, or someone who has completed the training required to become a licensed operator in a commercial nuclear power plant, should receive the same etedit as a pctson who has an Associate degree from an accredited institution in engineering, physical sciences, mathematics, or quality assurance.

The points now awarded for education are related to the effect that formal courses might have on the ability of individuals to comprehend the regulations or the technical aspects of activities being audited. The point system makes no allowance for the fact that such knowledge comes gradually and not upon receipt of a degrec. Persons who have completed part of a degree course should receive a percentage of the credits allowed for that course.

The requirements for training specified in ANSI N45.2.23, paragraph 2.3.2, would seem to ensure that prospective Lead Auditors will meet the requirements of paragraph 2.3.1.4 dealing with the rights of management. We think, therefore, that all prospective Irad Auditors should qualify for these two credits.

Similarly, the present system recognizes the effect that working in a OA Program will have on the

' ability of a person to comprehend regulations and technical requirements. Persons who are not assigned as full. lime members of the OA Organization, however, receive similar exposure if they perform activitics controlled by a OA Program. We therefore allow such persons half the cicdits specified for quality assurance experienec.

Ikm._2 Requirement 3.3 Requalification lead Auditors who fail to maintain their proficiency for a period of two years or more shall be required to requalify. Requalification shall include retraining in accordance with the requirements of paragraph 2.3.3, reexamination in accordance with paragraph 2.3.5, and participation as an Auditor in at least one nuclear quality assurance audit.

Jigptmse BG&E requalifies Lead Auditors on the basis of the satisfactory performance of one audit, as observed by a qualified Lead Auditor.

Reason The purpose of the training specified in paragraph 2.3.3 of the Standard is to ensure that candidates understand the fundamentals of auditing and the requirements for activitics to be audited. The fact that persons have not maintained their proficiency does not mean that they need complete re-training; it means only that they have not been able to review and study the applicable Codes, Standards, Procedures, instructions, and other documents related to OA Programs and program auditing. BG&E considers that the satisfactory performance of an audit under the observation and guidance of a qualified lead Auditor should ensure that persons with lapsed ccatification will review and understand the pertinent documents.

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7 OUAl.lTY ASSURANCE POLICY  !

Revision 39 l l

ANSI N101.4 - 1972 -

l Mequirement .

Section 1.2 specifies applicability requirements for the Standard.

Resnonse BG&E requires that only activities performed inside containment structures and related to protective  !

coatings applied to ferritic steels, aluminum, stainless steel, zine-coated (galvanized) steel, concrete,  ;

or masonry surfaces shall conform to applicable Sections of ANSI N101.4.  :

Reason .

Deterioration of protective coatings applied to surfaces outside ccmtainment structures would have ,

no detrimental effects on the safe operation of the plant.

ANSI N45.2.13 - 1973 Reanirement ANSI N45.2.13 could be interpreted to mean that all requirements of this standard are applicable to all safety-related items or serv ces.

l llesnonse BGkE has two approaches for safety-related and designated non-safety related procurement as described in Sections, lH 4 and 18.7. Controls established for Basic Component Purchases ~t correspond to the requiri oa ots of ANSI N45.2.13. The extent to which the individual requirements . ,

of ANSI N45.2.13 are applied to Commercial Grade Purchases depends on the nature and scope of -  ;

the work to be performed and the importance to nuclear safety and the items or services purchased. ,

This approach is consistent with the introductory discussion in Section 1.3 of ANSI N45.2.13 - 1973.

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I OUAll'iY ASSURANCE POLICY V ucvision 39

. ATTACHMENT A 1 '

ItASES FOR QA POLICY REVISIONS (1)

Entry PRF-O No. No. Bases for Revisinn(s)

1. 771 Procedure Uncrade Action Plan (PUAP).stLARmelUencL130-89.

2. 783 10 CFR Part 21 reauirements.

'3. 797 NRC Inspection #H9-16M9-17 (Letter from R. E. Denton to R. P. Ileibel dated July 13.1989.)

4. H24 NRC letter from M. W. Hodces to G. C. Crect dated March 13.1990. This letter approved a one-time exemption 1o the periodic review recuirements for procedures scheduled to be uncraded by the Procedures Uncrade ProipSL This exemption was discontinual and semovert by PRF-O 954. -

. 5. 844 Procurement Procram Proiect ungrade. Performance Imnrovement Plan (PIP) Action Plan #5.3.1 and_QAU AustitFindinc 8713-01'

6. 844 IB.15 and 111.16 revised to clearly establish procram annlicability and controls. conshtent terminoloev. orcanizational responsibilitics and focused annroach towards develoninc and implementine an intecrated Management System.

7. 891 PIP Action Plan 5.3.1 Follow-On Activity.

M. H94 1 B.15 and I B.16 revised to clarify recuirements which will ocrmit imniementation of the 1smes Mnnagement System - PIP item 4.10.0.

9. H54/907 G. C. Creel letter to the NRC dated 7126/91 which discussed modifications to.

and accentance of. chances to the OA Policy iDynlying._QA_ compliance reviews of OAPs and Directives.

10. HI5 G. C. Creel letter to ihe NRC dated 10/3/90 discussine temporary chances not affectine "An. proved Procedure Intent" and the relievine of the Administrative Burden on Shift Suncivisors.

Page 57 of 59

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b ~OUALITY ASSURANCE POLICY-Revision 39  ;

A1TACllMENT A-2 ,

~

HASES FOR QA POLICY RINISIONS (1) .

Entry PRFO No. No. Bases for Revnion(s)

F .. .

E 11. RR7 Audit Findine No. 9026-01 (Imniementation of Surveillance Reauirements).

12. 954 G. C. Creel letter to the NRC dated 7/3/91 discontinuine the one-time .,

f temporary chance to the periodic review interval annroved in Basis (4) above.

13. 957 PIP Action Plan follow-on activity (5.3.11.

14. 953 PIP Actian Plan 4.1 and NUREG-0737 (TMI Action Plan Reauirements)

Item I.C.S. " Procedure for Feedback of Operatine Exocrience to Pinnt Staff? {

15. 990 OAU Surveillance S-92 28" Interface Between Facilities Manacement f Denartment and Nuclear Enercy Division on Proiccts at Calvert Cliffs.'

+ .

F Recommendation 4.2.

l

16. 998 OA Audit Recommendation 92 04-R03 (ISFSI onerational phase). ,

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