ML20081A730

Rev 40 to QA Policy for Ccnpp

ML20081A730
Person / Time
Site:	Calvert Cliffs
Issue date:	02/01/1994
From:	Denton R BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20081A726	List: ML20081A725 ML20081A729 ML20081A730 ML20081A733 ML20081A738
References
NUDOCS 9503150266
Download: ML20081A730 (59)

Text

{{#Wiki_filter:.- OUALITY ASSURANCEPOLICY Revision 40 i BALTIMORE GAS AND ELECTRIC COMPANY Ouality Assurance Policy for the Calvert Cliffs Nuclear Power Plant (Appendix 1B of the Calvert Cliffs Updated Final Safety Analysis Report) Approved Date 1 / (1) 8 R. E. Denton i Vice President Nuclear Energy Division Page 1 of 59 I 9503150266 950309 PDR ADOCK 05000317 P PDR

m I i OUALITY ASSURANCE POLICY l Revision 40 G i TABIE OF CONTENTS i l 1 APPENDIX 1B OUALITY ASSURANCE PROGRAM FOR THF OPERATIONS PHASE Sedion

f. age 1B.1 ORGANIZATION AND RESPONSIBILITIES 5

IB.2 OUALITY ASSURANCE PROGRAM 14 18.3 DESIGN CONTROL 19 IB.4 PROCUREMENTDOCUMENTCONTROL(5) 21 I 1B.5 INSTRUCDONS, PROCEDURES, AND DRAWINGS ... 24 1B.6 DOCUMENT CONTROL.. . 24 1B.7 CONTROL OFPURCHASED MATERIAL, EQUIPMENT, AND .... 26 i SERVICES (5) t IB.8 IDENTIFICATION AND CONTROL OFMATERIALS, PARTS, AND 29 l COMPONEN'IS (5) IB.9 CONTROLOFSPECIALPROCESSES 30 1B.10 INSPECHON. 32 1B.11 TEST CONTROL 34 1B.12 CONTROLOFMEASURING ANDTESTEQUIPMENT... . 35 1B.13 IIANDLING, STORAGE, AND SHIPPING . 36 i 1B.14 INSPECTION, TEST, AND OPERATING STATUS. 36 1 IB.15 NONCONFORMING MATERIALS, PARTS, AND COMPONENTS. 37 I I 1B.16 CORRECDVE ACTION.... 37 1B.17 OUALITY ASSURANCE RECORDS. 38 IB.18 AUDITS 39 i 1 I \\ l 1 l 1 l 1 Page 2 cf 59 l

7 QUALITY ASSURANCE POLICY Revision 40 t i T TRTOF TABI m V [ Tabic No. EAge L 1 1B.I BALTIMORE GAS AND ELECTRICCOMPANY'S POSITION ON. 40 OU1 DANCE CONTAINED IN ANSI STANDARDS t i L]ST OF ATTACHMEN'IS Attachment ' Irtter A BASES FOR OA POLICY REVISIONS (1). 57 i h a I LISTOF FIGURPS 1 Firure No. 1B.1 BAL'I1MORE GAS AND ELECTRIC COMPANY CORPORATE ORGANIZATION... 59 4 i 1 6 s i 1 l Pagc 3 of 59 I

~.. _ ~ s,- 1 QUAUTY ASSURANCE POLICY ' . Revision 40 USTOF EFFECTNEPAGES i Latest revision number is lated for pages revised after revision'38. 1 Page Last Revision Page-Last Revision. Page Last Revision. 1 24 '47 2-25 48-l 3 26. 49. j t 4 39 27 50 I 5 28 51 i 6 29 39 52 t 7 30 53' 'i 8 31 40 54 l t 9 32 40' 55l l-10 40 33 - 56' l 11 40 34 57 l- [ t 12 35 58 13 36 59 \\l 14 37 i 15 38 16 39 i i 17 40 l t 18 41 i 19 42 l 20 43 i 21 44 t 22 45 ) 23 46 l t i i Page 4 of 59 l J

nm f QUAUTY ASSURANCE POllCY L 1 + Revision 40 : q 1B.1-ORGANIZATION AND RESPONSIBILITIES [ All levels of organization have defimte and unique responsibilitics in assuring safe, economical, and - 1 ' reliable operation of Calvert Cliffs Nuclear. Power Plant (CCNPP). Top level management is- 'l responsible for ensuring that policies are-estabbshed, resources.are authorized, management. phdosophy and commitments are communicated to lower levels of the orgamzation, independent ' j veriScation of management controls are performed, resuhs are iaM and appropriate actions j taken when -= y.. 1 Middle level management is responsible for transisting managessent policies,. philosop,hy, l commitments, and goals; applicable federal, atste, and local rules and regulations; Operateg1 Ucenses, Technical SpaciGratians (IS), and the Updated Final Safety Analysis Report (UPSAR) ; Into control programs for activities such as design, ptocurement, construction, testing, operation,' 1 refueling, maintaa-n repair, modincation, traimng, plant security, fire protection, records,. . independent venfication,'and corrective action. Middle level management is also responsible for 3 defining, measuring, and modifying the overall effectiveness of control programs; taking appropriate action on the results; and keeping top management informed of the status, adequacy, and 1 effectiveness of control programs, and matters which could have an impact on nuclear safety.- First line craft and non< raft supervisors are individually responsible for ensuring that appropriate y procedures are understood and used to implement each activity described in the control programs; identifying problems, seeking solutions,7 verifying implementation of solutions; investigating root. causes of problems and taking preventive actions; ensuring that conditions adverse to plant and. personnel safety are promptly adentified, reported, and corrected; detecting trends which may not be. d apparent - to a day-to-day observer, recommending generic solutions for adverse trends to ' management, and taking appropriate actions, to achieve desired sesults; ensuring that employees j assigned to do a job are properly qualified through appmpriate training and ycriesce;-have a woperly qualified procedures, tools, equipment,' and parts to do the job, and, ensuring that - nhaa=%t inspections of work are conducted in accordance with preestablished requirements. i First"line non craft supervisors are responsible to ensure that procedures are written, ratwed, and -l approved; first line craft supervisors may not have this responsibility. Non supervisory personnel 1 actmg as job directors are responsible for ensuring that properly qualified procedures are understood - and used; and ensuring that tools, equipment, and parts are on hand to do the job. I Adherence to procedares is vital to the safe and reliable ' peration of the Calvert Cliffs Nuclear' o Power Plant. Personnel are responsible for adhering to established procedures, interpreting them conservatfvely in case of doubt, and recommending changes when naraamary. Pmcedures 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 and 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) j -l Page 5 cf 59 l t:

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,g b 7-N ' QUAIIIY ASSURANCE POLICY - .j '~ Revision 40 l u 1 o l Corpgate Organization and Speggic Responsibilities he Corporate Organization Chart of the Baltimore Gas and Electrie Company (BG&E) is shown in ? Figure IB-L Persons responsable for the principal elesments of the Company's Quality Assurance (QA) Program are as follows:(1) li 1 Chairman of the Board y President and Chief Operating Officer - 1 1 SeniorVice President-Generation- 'i Vice President-Nuclear Energy Division (NED) la E4 Plant Genera 1 Manager-Cahert Cliffs. Nuclear Power Plant Department (OCNPPD) O Manager-Nuclear Engineering Department (NED). l 1 Manager-Nuclear Quality Assurance Department (NOAD) Manager-Nuclear Safety & Planning Department (NSPD) y Manager-Nuclear Support Services Department (NSSD) - i i Manager-Nuclear Outage & Project Management Department (NOPMD) ; j In addition to these individuals, the Vice Presidents of Corporate Affairs (CA), Fossil Energy 1 Division (FED), Electric Interconnection and Tran==iamian Division (EFID), General Services _ Division (OSD), and the eat Services DMsion (MSD), as well as the Managers of the j Electric System Operation Maintenance Dcf.4 c.at:(ESOMD),' Purchasing & Materials j Maa,=r:t Department (PMMD),- Information-Qm Department (ISD), Facilitaes j

m. Management Department (FMD), Fossil Apa-ing & Maintenance Department (FEMD), Fossil

' Support Services Department (PSSD), and the Safety and Madied Services Ds m s.t (SMSD) are j. assigned support responsibilities. (1) ne above Managers constitute tse Nuclear Program j L Managers who are nasagned responsibilities within the QA Program.' Other departments performing any maintenance / modification activities at CCNPP are responsible for performing these activities in j! accordance with ' apphcable OA Program requirements. - His. can be-aceoaptished by either developing their own QA Program procedures' or by ' working to the QA ' Program through

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. appropriate Nuclear Energy Division personnel using CCNPP procedures. (15) - ~ 1 Also, two advisory groups perform quality-related functions for plant operations. Dese are the Plant i Operations and Safety Review Committee (POSRC) and the Off-Site Safety Review Committee j (OSSRC) whose makeup and responsibilities are described in the TSs for CCNPP. -l + ek=6% of the Board. Pre =Wat and Chief Oser h= Oft-w. and hsr Vice Prc=W at-' c Generation 4 BG&E's QA Program for nuclear power plants is established under the authority of the Chairman of l the Board, President and Chief Operating Officer, and Senior Vice President-Generation, who are - responsible for establishing the overall QA Policy. Dcy assign project responsibilities to the - orgamzations shown in heavy-lined boxes in Pigure 1B-1. (1) t - i i i Page6of59 l l I

7:IM i e>>, QUAUTYASSURANCEPOIJCY l ah Osirman of the Boasd assigns authority through the President and Gief Operating Officer and - I Senior Vice Prmidant-Generation to the Vice President-Nuclear Energy Division. Primary j responsibilities for. implementing, and maintaining the QA Program are assigned to - l Department Managers the Vice Preawat-Nuclear Energy Division. Managers delegate their -i authority as required to implement their responsibilities. (1) { Quality assurance matters that cannot be resolved by the Managers or Vice Presidents are brought to. i the attention of the Senior Vice President-Generation, President and Chief Operating CfBeer, or : 1 i the Chairman of the Board for resolution. -l Vice Pra=Wat-Naelame Faarmy Division The Vice President-Nuclear Energy Division, is responsible to the Senior Vice President-Generation, l for ensuring that the QA Program is developed and implemented.; h authority to QA 1 Program Documents is assigned to designated Nuclear Program Managers, h Vice Pres t-Nuclear Energy Division, is also responsible for ensuring that the requirements of the QA Program that relate to the design, operation, and maintenance of the plaat are implemented; responsibility is carried out through Nuclear Program Managers. This 1 l M====ar-Naetaar Oa-H*v A=.-==<* Dan =re- ^ h Manager-NQAD, is responsible for assuring an appropriate OA. Program is. established and effectively czecuted for CCNPP. He is responsible for auditing, quality verification, and i the vendor evaluation functions for CCNPP. These responsibilities include-1. Developing, and revising the QA Policy. -l 2. Ensuring that QA Compliance reviews are completed for program acceptability of Control Programs (QAPs and Directives) and their revisions before they are approved. j (9) i 3. Taking necessary, corrective action, which can include the stoppage of work when - l manufacturing, maintenance, or modification activities fail to comply pd specifications, plans, or procedures.. Such corrective action is arranged 1 appropriate channels and is delegated when nar===ry. When a unit is operating, the -l 4 Manager-NOAD, may recommend to the Plant General Manager that the plant be shut down. The Plant General Manager has the final responsibility for the overall evaluation of all aspects and implications of shutting down an operating unit. j i NOAD sections, personnel who report to the Manager-NOAD, are independent of departmel and employees responsible for performing specific activities, and have sufficient . authority and organizational freedom to identify quality problems; to initiate, recommend, or l provide solutions through designated channels; and to verify implementation of solutions. L BG&E has established that the Manager-NOAD, should have at least six years of responsible 1 i cxperience in engineering, design, manufacturing, construction, quality assurance,:or power 1 plant operation, as well as a knowledge of regulations and standards related to nuclear power plants. { i i i Page 7of 59

n ... ~. 3 G ,1 - i 7," QUAUTYASSURANCE POLICY Revision 40 ' i De organization of NOAD is shown in Chapter 12 of the UFSAR.!%e Manager-NOAD, delegates the following responsibilities for accomplishing required quality assuranceL activities: ~ l i Planning and scheduling evaluations of vendor quality assurance programs. Reviewing proposed changes to QA Program documents ' for compliance 'with-q regulations and licensing documents. Planning, scheduling, and pwim Lg internal audits and evaluations of on-site and off-' l site functions performed under the nuclear QA Program. 1 Supporting maintenance and operations activities by performing inspections and i surveillances. (11) Plant General M===er-Calvert f'lin Nuclame Power Plant Danar*==amt -i he Plant General Manager is responsible for operations, chemistry, radiation safety, j maintenance, and systems and performance engineering activities at CCNPP. He must ensure that these activities are conducted in accordance with the plant operating license and 3 'ISs, the UFSAR, the QA Program, and procedures. - Re Plant General Manager fulfills the ~ position and requirements of the Plant Manager, as defined in ANSI N18.1 (1971). He, or one of his.designatext principal alternates, shall have acquired the experience and training normally required for examination for a senior reactor operator's license. 3 1 The organization of CCNPPD is shown in Chapter 12 of the UPSAR.' De Plant General Manager, delegates responsibilities for accomplishing required activities as follows: i 1. De Superintendent-Nuclear Operations (S-NO) is responsible to the Plant General. I Manager, for the operation of the plant, including the general supervision of all shift 1 operating penonnel and prioritization of maintenance activities to support operations. . This res masibility covers the safety of plant personnel and equipment, all fuel-handling ' t and reseling ' activities, and adherence to applicable : bcense and regulatory - a requirements. De S-NO fulfills the position and requirements of the Operations. Manager as defined in ANSI N18.1 (1971) with the exception taken in Table 1B.I. The S-NO delegates primary management responsibility to the Shift Supervisor (SS) on l duty to ensure the safe operation of the plant under all conditions. The SS maintains - the broadest possible perspective on operational conditions that aNect the safety of the plant. As the senior member of plant' management on each shift, he exercises the - ,i command authority of his position to take whatever steps he deems necessary during 1 emergency situations to place and maintain in a safe configuration any unit that may be aNected. 1 2. The Superintendent-Nuclear Maintenance (S-NM) is responsible to the Plant General Manager for managing and directing activities-of the Nuclear Maintenance 4 dan to i provide high quality maintenance programs, plans and schedules, and ' qualified - personnel to perform maintenance functions necessary,to assure the safe, reliabic, and 3 economic operation of the plant to generate power within applicable laws, standards, codes, and regulatory requirements. I L l Page 8 of 59 l .a

g72 .. ~ ~ ~ m 1 f iQUAUTY ASSURANCE POUCY l ~ ,_,p Revision 40 .i y j t

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' a.; The General Supervisor-Electrical and Controis (GS-E&C), is responsible to thei j Superintendent-Nuclear ' Maineanan, forL the' conduct of - electrical" and. instrument maintenance, repair, and modiacations n~M to keep the plant and-1 its facilities, systems,' and equipment in safe and efficient working condition. He j is' responsible for planning-and supervising-or: controlling >the electrical:and ' instrument maintenance activities' conducted-by_ plant maintenaam personnel, and for ensuring that work is performed in accordance with applicable Codes and -

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Standards and that required maintenance records are developed and kept. He is. -i

responsible for controlling tools and equipment used for electrical and instrument :

i mantenmace, repair and modi 6 cations activities. - r b. De General Su -Mechanical Maintenance (OS-MM), is responsible to Lthe Superin t-Nuclear Maintenance,: for the conduct of mechanical 1 maintenance, repair, and modifications needed to keep the plant and its facilities,-

systems, and equipment in safe and efficient working condition. He is responsible ;

j for planning and supervising or controlling the mechanical maintenance activities. . conducted by plant maintenance personnel, and for.onsuring that : work is performed in accordance with applicable Codes and Standards and that required maintenance records are developed and kept.1 He is responsible for controlling

l tools and equipment used for mechanical maintenance, repair, and modifications.

j activities. 3. De Superintendent-Technical ^ Support (S.'IS[is responsible to-the Pc General j 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 - y to assure the safe, reliable, economic - 1 operation of the plant, insemce inspection, and to establish' appropriate standards for the fire protection program.' De S-TS is also responsible to the Plant General Manager -i for overall direction and coordination of activities to ensure compliance with the! 1 Radiological EfBuent Technical Specifications.- Dis. responsibility is carried out i through 'the General 1 Supervisor-Chemistry ' with ' support. from the. Director-a Environmental Programs and the Manager-PSSD. a. he General Supervisor-Chemistry (GS-C) is responsible to the Superintendent-: .i Technical Support for the chemistry and radio-chemistry of the primary and! q secondary systems and for maintaining radioactive effluents within'specified j limits. Additionally, the GS-C provides program management oversight of the - Radiological Environmental Monitoring Program to ensure compliance with the ; j Radiological Etnuent Technical Specifications. l 1 b. De General Supervisor-Radiation Safety-(OS-RS) under the - nuclear:OA 1 Program, is responsible to the Superintendent-Technical Support for: Ensuring the radiation protection of personnel at CCNPP. Complying with radioactive material transport regulations. 1l 1 l Page 9 of 59 - i

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Revision 40'-

~ y 4 f m ' c.i He General Supervisor-PlantP=pming (OS-PE),' is responsible-to.the' Superintendent-Technical Support for providing field ~ and technical t evaluation of plant systems and to e-aluate and coordinate r of system. f n , and component - lems with! operations, maintenance, and-engineering 'j N personnel for the Cliffs Nuclear Power Plant. ' Additionally, the GS-PE is responsible to the S'IS for'providing plant reliability / availability testing and z evaluation, t t performance ' improvement, and. administration ! of the : ]j Surveillance t Program.

d. ' ~ He Principal J Rapw-Nuclear. Inspection Services ' is ' responsible to; thel Superintendent Technical Support for providing inservice inspection services for L

j the Calvert Cliffs Nuclear Power Plant. -

htan==cr-Near R==i=~rine DanMment j The Manager-NED, is responsible for directing the efforts of personnel andlproviding resources necessary to support design, modification and engineering activitica covered by the' t QA Program for CCNPP. These activities include nuclear, mechanical,' civil, reliability,- 3 instrument and controls, and electrical engineering; nuclear fuel management; configuration management; life cycle management; plant design l support; fire protection program development; and engineering planning. De organization'of FED as shown in Chapter 12 of the _UFSAR. The Manager-NED ' j delegates responsibilities for accomplishing the following activities: 1 s Providing conceptual and detailed engineering, design'and drawing, fire protection' . program Wpment, and data base configuration control for the power and control systems for the Calvert Cliffs Nuclear Power Plant. Directing and performing safety evaluations, preparation and review of nuclear safety i accident and transient analysis, fuel management, nuclear engineering related to core L P ysics, reactor engineering and external fuel cycle management for the Calvert Cliffs 1 h Nuclear Power Plant. -l t Providing plant design support, and engineering planning and scheduling for the power ' I and control systems for the Calvert Cliffs Nuclear Power Plant. : Development and integration of programs nac==ry to operate Calvert Chifs Nuclear l t Power Plant up to and beyond its current licensed lifetime; reliability engineering; and j documentation and maintenance of plant design bases. Man==er-Nuclear On**=e and Proiect Maa wt Denart==t L The Manager-NOPMD is responsible for directing the efforts of personnel and providing resources necessary to support site integrated scheduling, outage management and project i management for assigned projects, ne orgasu'zation of NOPMD is shown in Chapter 42-of 1 the UFSAR. The Manager-NOPMD delegates' responsibilitips for-accomplishing the following activities: L Developing, implementing and maintaining a site integrated schedule which schedules .I all significant plant related activities at CCNPP. Managing the planning, scheduling and performing of all outages at CCNPP. l i Page 10 of 59 i

~i c ? l' QUALITY ASSURANCE POLICY. - Revision 40 ( = Providing overall project management for engineering, procurement, construbtion 'andi T testing of nuclear power plant modiGcation for CCNPP. ~ y ~ Manamer-Nuclear Safety and Plannine Decartawmt l The Manager-NSPD is responsible for directing licensing activities, independent safetyj l evaluation activities, emergency planning, and industrial safety. q he organization of NSPD is shown in Chapter 12 of the UFSAR. - He Manager-NSPD

delegates responsibilities for accomplishing the following activities:

~' , Providing licensing ' services; coordination and operation of various industry information ' exchange systems; evaluation of plant events and conditions' adverse to quality.for reportability to the NRC and 'other agencies, assisting in -the investigation and. evaluation of events, and preparation of the reports; coordination of tracLing and resolution of companycommitments to the NRC; research and preparation of responses to.NRC letters, bulletins, circulars and information notices;..UFSAR rescarch and-revision control; maintenance and revision of the current licensing basis for nuclear power plants; coordination.of all compliance-related communications with external' agencies including assistance in ensuring their consistency with existing licensing basis L commitments; and coordination of regulatory inspections and visits and company presentations to the NRC. n Directing investigations of signiGcant events to determine root cause, recommending corrective action, and generating appropriate reports to document the investigation results; directing a program for identifying trends within the corrective action systems. Directing reviews of the operating experience of other plants'of similar design to ' i determine the applicability of significant events with respect to CCNPP. (14) 1 I Directing the efforts of BG&E personnel involved in emergency planning activities. Directing the efforts of personnel under the Nuclear QA Program to develop, implement and coordinate the industrial safety program; implement the fire prevention and fire fighting programs for the CCNPP; and to plan, schedule, and monitor activities directly related to safety, fire protection, and preventionc. Manamer-Nuclear Suonort Services Department The Manager-NSSD la responsible for training, nuclear security, onsite procurement - coordination, procurement engineering, procedures upgrade, state regulatory matters,- strategic planning, and staff services functions for CCNPP. A b f 5 Page 11 of 59

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- QUAUTY ASSURANCEPOUCY 'j' 1 Revision 40 - s K q l The organleation of NSSD is shown in Chapter 12 of the UPSAR. The Manager-NSSD ,i g cc delegates responsibilities for accomplishing the following activities: 1 .Providing support to. Managers in the. Nuclear Energy Division to ensure their ~j personnel are properly trained and qualified to perform their assigned duties, including. . those duties which implement the nuclear QA.Program. Training required by special -l work forces and - contractors would be p4w ! by the appropnate BO&E. .i Department, and/or Host Company (vendor). i . Distributing, and coordinating the tion of, revisions to the.QA Program p documents; colMap storing, maint and retiAg.QA records for nuclear .t power plants; maintaming, controlh'ng, and' distributing drawings and technical manuals 3 related to equipment, materials, and services for nixlear power plants; coordinating { investigations concerning state regulatory matters; coordinating the efforts of Nuclear Energy Division personnel involved in the ps, sa t of structures,. systems,; components, parts, and. services related to the design, ' construction,L fueling,- maintenance, and modifications of CCNPPi -{ + 9 Establishing procedures to assure that SR and DNSR p-cnt documents identify j 7~

• haical and quality requirements; procurement (SR and DNSR) documents receive independent review and approval for the regarements; ensuring spare and rep'=== proper inclusion of tachniemi and qua!

et parts are suitable for their intended j . application (s); specification of critical ' characteristics and: acceptance criteria for. j dedication of commercial grade items; specification of special storage requirements for i age sensitive items. i .j f . Performing receipt inspection functions. including special: receipt inspections and - coordinating testing performed to accept commercial grade items, desgnated NSR items or upgrade NSR items for use in SR apptestions. (5) 1 Ensuring that the operational, maintenance, licensing, and training activities associated ' with plant security are effectively implemented,~and that nuclear security provisions provide protection for personnel, equipment, and facilities at CCNPP against potential l security threats. 'l Directing the efforts of personnel responsible for the storage and issuance of items for CCNPP. Development of the annual Strategic plan for the Nuclear Energy Dmsion including the - Nuclear Program Plan. l s Individuals supporting the CCNPP QA Program are designated as follows: 1 i. Vice Premident.FM Faernv Dividnn I The Vice President-FED, is responsible to the Senior Vice President-Generation for ensuring that . the activities of FED personnel involved in CCNPP maintenance and modifications; Materials' Engineering and Analysis; and rW;cel environmental monitoring, meet the requirements of the ' OA Program. This responsibility is carried out through the Manager-FEMD, and the Manager-- 1

FSSD, i

Page 12 of 59

~ - - q m l n, ' l o QUAUTY ASSURANCE POUCY ; 1 Revision 401 - l l Managar-Eassil Engineering & Maintenancy Department j s The Manager-PEMD, is responsible for the efforts of FEMD gw..u N involved in ' maintenance and modification activities at P. + lw Manager-Fossil Supnart Services Denartment f

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De Manager-PSSD, is responsible for directing the e5 orts'of PSSD p -.cl involved in: 1 . (1)' maintaining.and operating Radelogical Environmental M-O-iiug equipment. and a perfonning sample collection and analysis, (2) ensuring materials.=7- /-g and me%

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

Company andi ' ^ ry requirements. ' \\ ~ Vice Fi= '-w: N ic Int-anaae*ia-==d Tr====%n Divimian a v 4 De Vice President-EITD,is responsible for ensuring that the requirements of the QS Program that ' relate to the calibration of test equipment and the testing of protective relaying, and metering g j controls for SR ekh;c.el power equipment are implemes si nis responsibility is carried out j e through the Manager-ESOMD. l --- e g-Manager-Electric Svstem Onoratiqn and Maintae---- Dw= : l s De Manager-ESOMD, is responsible for directag the efforts of personnel involved in the testing of electrical power equipment the calibration of test eqmpment and the testing of. j protective relaying and metermg controls for the electrical power equipment of OCNPP. ' - Vice President thaaral Se vices Division ne Vice President-OSD is responsible for ensuring implementation of the' QA Program requirements that relate to: the procurement of SR or designatexi NSR structures, systems, components, and services; the construction, maintenance, and operation of facilities; and support ' services for computer software and hardware. Dese responsibilities are carried out through the Manager-PMMD, Manager-ISD, and' Manager-FMD.' t Ma===er-Purch-laa and Materials M=a====t Dqe= ..=.t ne Manager-PMMD, is responsible for directing the efforts of precanel involved in the - purchasing of items and services for CCNPP and for the issuance of Contracts for Fitness for 'j Duty Activities. M---eer-Infor===*ian Sv=ta== D=ar*==t l The Manager-ISD, is responsible for directing the efforts of ISD pemonnel involved in y, acquiring and supporting computer software and hardware.- . u ----r.F cisiet-, um,4= r.: D =.2. --- =e ne Manager-FMD, is responsible for directing the efforts of FMD personnelinvolved in the planning, design, construction, maintenance, and operation of facilities and related systems directly supporting or impacting power plant operations. ] s 1 Page 13 of 59 l

g .i - QUALITY ASSURANCE POLICY I ' ~ ~ ' Revision 40 i I i ' Vice Pra< Mane.u=== ant Services Division j i The Vice President-MSD, is responsible for ensuring that the activities of MSD personnel involved - j - with medical czaminations for CCNPP operators, Nuclear Security Officers, and respirator users, j SMSD. ' 'quirements of the regulations. De responsibility is carried out through the Manager-j meet the re .t .6 .$g(gg assA Ma,Wal Services Wn- ^ -W De Manager-SMSD, is responsible for directing the efforts of SMSD personnel involved t with medical examinations for CCNPP operators (10CFR55), Nuclear Security Officers ~ (10CFR73), respirator users (10CFR20), and with the Fitness for Duty rule (10CFR26).% I i n . Vice President-Cornorate Affairs -l De Vice President-CA is responsible for ensuring that OA Program requirements related to the Radiological Emuent Technical Specifications are implemenad. his responsibility is carried out .l through the Director - Environmental Programs. l 1B.2 OUALITY ASSURANCE PROGRAM Genera! Controls .i %e OA Program consists of the Updated Final Safety Analysis Report (UPSAR) Appendix 1B, OA Policy, Quality Assurance Procedures, certain Nuclear Program Directives and their implementing -l procedures. %e UFSAR Appendix 1B and QA Policy are the same document except for the way. changes are incorporated. h OA Policy is updated when each change is appmJ Revisions to j the OA Policy are controlled by OA Program documents which are written to ensure compliance with 10 CFR 50.54(a)(3). The UPSAR Appendix 1B is updated annually.. All OA Policy changes

l approved during the previous year are incorporated during that update.

1 h OA Policy identifies NRC regulatory requirements, industry standards, and speedic codes I applicable to the eighteen criteria contained in 10 CFR 50, Apr+= B. h OA Policy also. 1 indicates action that will be taken by BG&E in response to these documents and to commitments. i made in the UFSAR and TSs for CCNPP. j QuMity Assurance Procedures (OAPs) describe controls for the actions identified in the OA Policy. OAPs cover major activities related to operating a nuclear mwer plant, such as plant operation, plant maintenance, training, purchase ofitems and services, ca ibrations, etc. ~ Nuclear Program Directives address actions identified in UFSAR Appendix 1B. - Directives identify j regulatory commitments, management requirements, and assign responsibilities for each business function directives (are written and implemes.ted, they will systematically replace OAi j i BO&E's CA Program for CCNPP is applied to structures, systerns, 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 pablic, h OA Program is also applicable to designated NSR structures, systems, components, activities, and senices as required by 1 t in regulations. Designated NSR program requirements are based on a graded roach to Quality j Assurance required to meet applicable regulatory designated requirements and ance. He level of QA Pmgram controls placed on designated NSR ltems are defined in OA rogram documents Par,c 14 of 59 ~ , *. e c %.y--[ ,e, -yc. w c

y g' jl a - QUALITY ASSURANCEPOIJCY l g Revision 40 l, 4 4 and/or implementing procedures. h controis from other sections of this OA Policy are selected as j -- y to meet the particular regulations being implemented. -l s 4 Controis have been estabhshed for specifying on a Quality IJst (Q-List) all SR structures, systems,

i components, and activities that are su> ject to the requirements of the QA Program.

l h Statement of Authority, in the Quality Assurance Manual for Nuclear Power Plants, signed by - i the Chairman of the Board, establishes the overall QA Policy of BG&E. ' This Statessent sets the goal of safe and reliable cperation of CCNPP; commits the Company to a OA Program designed to' ensure the plant's compliance with regulatory require =*=es BG&E commitments, and established -i practices for reliable plant operation; and requires every person involved in OA Program activities to i comply with the provisions of the Program. De Policy is approved by the Vice President-NED and implemented by Nuclear Program Managers. e (1) i ne QA Program has established controis for BG&E and its contractors as required to ensure that I the criteria of 10 CFR 50, Appendix B, will be met throughout the operations phase of the plant; Le., during activities of testing, operation, maintenana, repair, modification, and sefueling. he QA Program has also established controls to ensure that the construction, operational, and - l decommissioning phases for the Indepand-at. Spent Fuel StorageJastallation (ISFSI) are conducted .in compliance with-10 CFR 72. Activities associated with the operational and.decommi sloning - phase shall be controlled under the CCNPP 10 CPR 50 Appendix B QA Program; existing policies,. programs, directives, and procedures stated as applicable for CCNPP are also applicable for the'. j ISPSI. (16) Changes to the QA Program documents are issued with a transmittal notice, which is completed by '{ the recipient and returned to indicate that the documents hsted on the transmittal have been l received and incorporated into the recipient's Manual. Nuclear Program Managers ensure QA Program document. are revised as regulations, standards, results, or experience dictate.~ (1) The Manager-NOAD evaluates the degree of compliance with the requirements of QA Program documents and procedures. Audits are conducted regularly to ensure compliance with established 'j requirements, and the results of these audits are reported to responsible management personnel. j The Vice President-NED, ensures that activities of the NOAD are audited regularly by personnel independent of the Department. These auditors assess the effectiveness of the Department's j implementation of appropriate portions of BO&E's OA Program. The Vice President-Nuclear i Energy Division, evaluates the report of the independent audit to determine if changes are required to the QA Program. He is responsible 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 ' j of the corrective action taken. If a difference of opinion arises between NOAD personnel at those of other Sections or j Departments, the dispute is resolved as follows: The Suped.g=4eneral Supervisor of the QA i Unit /Section involved first tries to resolve the matter with the organization responsible for conducting the activity. If a resolution cannot be obtained, the me"er is referred up through the following management personnel until it is resolved: (3) 1. 'Ihe Manager-NGAD, and the Manager responsible for performing the activity. Page 15 of 59

+ d QUAUTYASSURANCEPOUCYJ Revision 40 .i i q . NOTE: ~ l 7If the dispute is with another Unit /Section in NQAD, the usue will be settled by the Vice President-Nuclear Energy Division. (3) i i - 2. . He Vice President-Nuclear Energy Division. (1) J 3. The Senior Vice Praidait-Generation,l President and Chief Operating Officer, or. the - Chairman of theBoard. 1 1 To ensme-that importantiactivities are performed correctly, BO&E conducts fonnal training 1 , programs for Company pesc etwith signi6 cant responsibilities. nese programs include beth j initial. and continuing _ training and are conducted in accordance with written procedores or J instructions.' Department Managers are responsible for ensuring that the training needs'of personnel 1 in their Departments are identi6ed, formal training programs to satisfy those needs are devcisped,. i and the traming programs are implemented in accordance with the requirements of the QA Program. documents. t Re QA Program was developed to meet the requirements of the Regulations, Regulatory Guides, and Industry Standards of the Nuclear Regulatory Commission (NRC) listed below. Exceptions j taken to guidance contained in these documents and equivalent BO&E alternatives are stated in - r Table IB-1. l REGULATIONS le CFR 50.55a-Codes and Standards. le CFR 50.59 - Changes, Tests, and Experiments. le CFR 55 - Operators' Licenses. ] t le CFR 54, Appendix B - Quality Assurance Criteria for. Nuclear Power. Plants and Fuel - l Reprocessing Plants. 10 CFR 72, Subpart G - Quality Assurance (ISFSI) il REGULATORYGUIDES 1.8 - Personnel Selection and Training.(September 1975)**. This' endorses ANSI N18.1 I (03/0801)** *. l 1.16 - Reporting of Operating Information (as syihi in Calvert Cliffs Technical Specifications).' 1.30 - QA Requirements for Installation, Inspection, and Testing of Insinamentation and Elecinc Equipment (08/11n2)*. his endorses ANSI N45.2.4 (03A)1n2). ~ 1.33 - OA Program Requirements (O mration, Rev. 2, 02n8)**. His endorses ANSI N18.7-I 1976/ANS 3.2 (02/1996)* **. I i I t l l Page 16 of 59 { l

QUAllTY ASSURANCE POLICY Revision 40 L- -1.37 - OA Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (03/16n3)". His endorses ANSI N45.2.1 (02/2693)*". 1.38 - QA Requirements fcr Packaging, Shipping. Receiving, Storage, and Handling of items for Water-Cooled Nuclear Power Plants (Rev. 2,05n7)". This endorses ANSI N45.2.2 (12/2002)"*. 1.39 - Housekeeping Requirements for Water-Cooled Nuclear Power Plants (03/16n3)*. His endorses ANSI N45.2.3 (03/15n3)"*. 1.54 - QA Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants (06n3)* *. This endorses ANSI N101.4 (11/28R2)*". 1.58 - Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel (09/80)". His endorses ANSI N45.2.6 (1978)"*. 1.64 - QA Requirements for the Design of Nuclear Power Plants (10R3)*. This endorses ANSI N45.2.11, Draft 3, Rev.1 (07#3). i 1.68 - Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors (1193)". 1.144 - Auditing of Quality Assurance Programs for Nuclear Power Plants, Rev.1 (09/80)". His endorses ANSI N45.2.12 (1977). 1.146 - Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Aug. 1980).*. His endorses ANSI N45.2.23 (1978)"*. INDUSTR,y STANDARDS ANSI N45.2.5 - Supplementary QA Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, 1 Draft 3, Rev.1 (1193). l ANSI N45.2.8 - Supplementary QA Requirements for Installation, Inspection, and Testing of i Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants; Draft 3, Rev. 2 (0993). ANSI N45.2.9 - Requirements for Collection,' Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants; Draft (1096)"*. ANSI N45.2.13 - QA Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants; Draft 2, Rev. 2, (1093)"*. NOTATIONS FOR REGULATORY GUIDES AND INDUSTRY STANDARDS NRC endorses an Industry Standard or draft without reservation. NRC takes exception to or provides additional guidance in a regulatory position statement. BG&E takes exception to guidance offered and states alternatives. j Page 17 of 59

- i' QUAUTY ASSURANCE POLICY l o Revision 40; j Procedural Controls I - De QA Policy and revisions 'thereto.are reviewed by Nuclear Program Managers. QA Policy revisions are reviewed by NOAD personnel to determine;if they constitute a reduction in commitments previously made to the NRC. If so, the revisions are sent to NRC for approval prior to implementation. De Manager-NOAD reviews revisions to the QA Policy and reco==eads i approval to the Vice President-Nuclear Energy Division. The Vice President-NED approves the QA j Policy and revisions thereto. I Each Quah'ty Assurance Procedure (QAP) is prepared by one or more of the Departments : l responsible for conducting the activity. The QAP and revisions thereto are reviewed by NED ' e Managers and affected Department Managers. The Manager-NQAD ensures QAP revisions are reviewed by the Quality Assurance organization and recommends royal to the Vice President- - i NED. De Vice President-NED approves all QAPs and revisions . De Manager-NSSD ( ensures issuance of all QAPs and revisions thereto. (1).- QA Program documents control the i distribution and revision of the QA Polig and other QAPs. t Nuclear Program Directives are prepared under the direction of the Department Manager assigned l by the Vice President.NED as the Program Sponsor. Each directive and revisions thereto are j reviewed by affected Department Managers. The Manager-NQAD ensures directive revisions are i reviewed by the Quality Assurance organization and approval recommended to the Program i Sponsor. The Program Sponsor approves the directive and revisions thereto. He Manager-NSSD 3 ensures issuance of all directives and revisions thereto. 7 QA Program documents ensure that: 1. De 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 activities affecting quality achieve and maintain suitable proficiency through appropriate training and expenence. l: Administrative or Technical Procedures are prepared as needed. They establish the prorence used ' to implement directive or QAP requirements. He controls for review and issue of procedures are - 1 discussed in Sections 1B.5 and 1B.6. i \\ c ReviewofOneratioris i e Procedures require that CCNPP shall be operated and maintamed in accordance with the 11 ant 'I3s - and operating license. De following organizations review plant operations to ensure tsat these procedures are followed: 1. The Manager-NQAD provides independent verification that the requirements contained in the Plant's operating license, UFSAR, '13s, and plant procedures are met.'. H is is .i accomplished through quality assurance audits. -i 2. De OSSRC provides independent venfication by' review that CCNPP is operated in l accordance with established requirements. He OSSRC, which functions under a written i Charter approved by the Vice President-Nuclear Energy Division, is composed of on-site and j off-site personnel knowledgeable of in-plant operations, nuclear engineermg, chemistry and j radiochemistry, metallurgy, radiological safety, instrumentation and control systems, j + mechanical and electrical systems, quality assurance, and environmental factors. The 1 Page 18 of 59 l T d n er i < ww w -- + - = - -re- --- * + - ~ > * +-'v-+ +e we --s

q e, 3- - QUAIJTY ASSURANCE POIJCY L e, Revision 40. l wc-O" of all meet

• are documented and sent to the Vice President-Nuclear Energy a

N Nvision, Committee , and othen designated by the Committee Chairman.

3..

'Ihe on-site POSRC reviews matters port ' to nuclear plant safety. This' Committee screens subjects of potential concern to the C and performs w h-y investigations-j r-

under the direction of the Plant General Manager. POSRC membership and functions are :

, governed by Technical Speci5 cations and written prr-imes. 'Ibe results of all meetings are L dr = rated and sent to the members of tbc OSSRC, and others designated by the Committee. i LChairman. a y

I

" Ihe maintenance and repair of systems, structures, and components subject to the QA Program aref M performed by personnel under the direction of the General Supervisors of Electrical and Controls,:-. , Radiation Safety, and Mechanical Main -aa , according to written procedures and instructions as 1 e .j prepared by the maintenance force and approved as stated in QA Program documents. These - Procedures: 1. Ensure that quality-related activities, such as inspections and tests, are performed with ] appropriate equipment and under suitable environmental conditions. - 2. Indicate inspections and checks that must be made and records and data that must be kept. ' 3. Show where indepenrient verifications. of inspections or checks should be performed by. 1 .. spW personnel other than those perto' rming the work. the plant work force. plant Company personnel or outside contractors are brought in to su i When -- y, non-In such instances, the approval of work procedures and the tagging of j equipment are coordinated by a member of the BO&E organization responsible for the performance. l of thework. <4 Controls are established in OA Program documents to ensure that materials and parts used in the. repair, maintenance, and moddication of SR and designated NSR portions of the plant-are j appsopriate -for the service-intended. Written procedures are prepared for the. storage rand-1 identification of materials and parts to ensure that they do not dca .te in storage and can be i correctly identined before installation or use. I Equipment manufacturers and contractors used for the repair, maintenance, and modification of SR j i an! designated NSR structures, systems, and components are required to have quality assurance-i programs consistent with the importance of the end-product to safety. i ~! 1B.3 DESIGN CONTROL 4 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 QA Program documents which are written to ensure compliance with Regulatory Guide 1.64 and 10 CFR 50.59. 3o 1 Controls for changen, 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. i 2. As the item or activity affected has been classified SR or NSR. Page 19 of 59

QUALITY ASSURANCE POLICY Revision 40 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 classifications control the preparation and reporting of safety evaluations. Three methods of treatment are allowable: 1. Implementing the change, test, or experiment in 'accordance with Company practice for operating p-wer plants, or in accordance with Procedures required by OA Program documents. 2. Implementing 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. r Changes, tests, or experiments which require approval by the NRC are approved by the POSRC and by the OSSRC. Controls have been established to ensure that design changes to SR structures, systems, and components are reviewed either by the organization that made the original design or by a Responsible Design Organization (RDO) that meets requirements specified in ANSI N45.2.11, Section RO. Responsible Design Oreanizations 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 seismic, stress, thermal, hydraulic, radiation, and accident analyses; ensuring compatibility of materials; and providing accessibility for in-service 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 activities of all participating organizations. 6. Methods for verifying or checking, such as design reviews, alternative calculations, and qualification testing are properly chosen and followed; the most adverse design conditions are 1 specified for test programs used to verify the adequacy of designs. Page 20 of 59

j 4 7 a h q l v QUAllTY ASSURANCE POIJCY 1 Revision 40 - l

7.

Individuals or groups responsible for design veri 5 cation are other than the original designer l . and the dQpc.'s immediate supervisor. ~ ~ 8. Design and speciGcation changes are subject to design controls and approvals applicable to the - origina1 design. - 9. - Design documents and revisions thereto are distributed.to responsible individuals and '. ~ controlled to prevent inadvertent use of superseded material.. 10. Design errors and deSciencies that adversely affect SR structures, systems, and components. 1 are documented, and appropriate corrective action is taken. t i 11. Design documents and reviews, records, and changes thereto are collected, stored, maintained, and controlled systematically. 12. Standard olf-the-shelf commercial or previously approved materials, parts, and equipment essential to the SR functions of structures, systems, and components. are.rc6..cd for suitability of application before they are had i -i 13. De persons or groups responsible for design reviews and other design veri 6 cation activities ' j i and their authority and responsibilities are identified. 14.' Design changes to NSR items initiated and approved at the plant are' controlled to ensure : compliance with 10 CPR 50.59. 15. Processes used to select suitable materials, parts, equipment, and proce==en for SR structures, - systems, anl components includes. the application of %. cst industry stanlards -and - speci5 cations, material and prototype hardware testing programs, and design reviews. 16.- Computer programs used in design are subject to design controls and progr& verification.- o . IB.4 PROCUREMENTDOCUMENT CON'mOL(5) ' i 5 Controls have been establashed to specify the requirements and sequence of actions for: requesting - l items or services; review of the requested item or service to establish the necessary.techmcal and

i quality requirements; preparation, review and control of procurement documents; evaluation and j

selection of vendors and; control of deviations from the procurement document requirements. The degree to which these controis are imposed on the purchase of items and services by BGAE for - CCNPP depends on-1. De functional (safety) classification of each item or service'as SR or NSR according to - a controls established by the RDO and i 2. He Procurement Category of the item within it's-functional classi6 cation as a basic component, commercial grade item, designated non-safety related item (DNSR) or NSR item: J i 5 Commercial Grade - An item satisfying all three of the following criteriai a. 4 1. Not subject to design or specification requirements that are unique to nuclear facilities; and 2. Used in applications other than nuclear facilities; and j -I L i ii I Page 21 of 59

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QUALITY ASSURANCE POLICY Revision 40 3. Is to be ordered from the manufacturer / vendor on the basis of specifications set forth in the vendor's published product description (for example, a catalog).- J b. Basic Component - An item 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". Designated Non-Safety Related - A NSR item which BG&E has made a regulatory or I c. design basis commitment; or, for plant availability reasons, BG&E has implemented special controls to assure reliability. These NSR items are included within the quality assurance process. d. Non-Safety Related - An item that does not perform a safety related function. 3. The procurement method to be used for the item or service: Purchase Orders placed by BG&E personnel for items or services intended for safety related applications and DNSR items and services fall into two categories, Nuclear Grade Method procurement and Commercial Grade Method procurement. Nuclear Grade - Purchases that are designated to be placed with vendors that maintain a. a 10CFR50 Appendix B quality program and supply items that meet the definition of Basic Component. The requirements of 10CFR21 will be invoked on the vendor under this method. I b. Commercial Grade - Purchases that are designated to be placed with commercial grade j vendors that supply items or services that meet the definition of Commercial Grade. These items must be dedicated for SR use by BG&E. Items and/or services classified as DNSR will be urchased using the Commercial Grade Method with technical requirements established an RDO. Qualified NSSD/NED personnel trained in quality assurance. program requirements with RDO authority review safety-related and designated non-safety related procurement documents for proper inclusion of technical and quality requirements. Personnel in NSSD/NED review safety-related and designated non-safety related procurement documents to ensure that the requirements stated therein are correct, inspectable, controllabic, contain adequate acceptance and rejection criteria, and comply with the requirements of the procurement program. These reviews and approvals are documented prior to placement of the purchase order. All changes made to procurement documents, including specifications and other technical attachmeras, are subject to the same levels of review, approval and control that were applied in preparing and processing the original documents. Bids submitted to supply safety-related items or services receive the same review and approval cycle as used for safety-related procurement requisitions. Vendor Selection Personnel in NOAD evaluate vendors who provide SR and designated NSR items and services to verify they can provide acceptable items and services. Page 22 of 59

QUALITY ASSURANCE POLICY Revision 40 Controls for Nuclear Grade Purchases Controls have been established to ensure that, before placement of a purchase order under the Nuclear Grade method of purchase, there is evidence of the following: 1. He vendor has been evaluated as stated in Section 1B.7 of this policy and found to have a satisfactory QA program. 2. He 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 services available to generalindustry will be 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 shalh 1. Reference part numbers or descriptions, and additional requirements to casure that items ordered can be identified 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 applicable regulatory requirements, component and material identification, RDO approved drawing and specification, codes, industrial standards, test and inspection requirements, and special process instructions such as welding, heat treating, nondestructive testing, and cleaning.

3... Identify the requirements of 10 CFR 50, Appendis B, which must be complied with and i

described in the vendor's QA program, for Nuclear Grade Purchases. 4. Require that major contractors designated as BG&E agents to purchase SR and designated NSR items or services must have procurement controls to ensure they purchase or acquire these items or services in compliance with the necessary sections of ANSI N45.2.13. 5. Identify required documentation (i.e., drawings, specifications, procedures, inspection and fabrication plans, inspection and test records, personnel and procedure qualifications, and material chemical and physical test results) to be prepared, maintained, and submitted to DG&E or the purchaser for review and approvat 6. Identify records which must be retained, controlled, maintained, er delivered to BG&E or the I purchaser before use or installation of hardware. I i 7. Specify BG&E or its agent's right of access to vendor facilities and records for source inspection, surveillance, verification and audits. 8. Identify requirements of the vendor's quality control process which must be implemented when providing a commercial grade item. j i Reference or specify the critical characteristics that a commercial grade item must possess to 9. ensure that the item received is the item specified. I l Page 23 of 59 i i

-i i I r# 1TY ASSURANCE POLICY ~ O Revision 40

i

10. ' incorporate the requirements of 10 CFR 21 for Nuclear Grade procurements.

1 11.' 1 ~ Include requirements for QA program elements to be passed on to sub-vendon. .j M 1B.5.. INSTRUCTIONS.PROFFDURES AND DRAWINGS Controls delineate the yac-of actions to be performed in the preparation, review, approval, and - { control of instructions, procedures, and drawings. Controls require that: 1. Methods for complying with each of the apph' cable criteria of 10 CPR 50, Appendix B, must be : I specified in instructions, procedures, and drawings.~ j q 2. Instructions, procedures, and drawings must specify the (such as worbn appropriate quantitative (such as - dunensions, tolerances, and operating limits) and quahta y acceptance criteria for verifying that important activities have been satisfactorily accomplished.

i

.p Controls ensure that: 1. 'Ihe QA Policy is approved by the Vice President-Nuclear Energy Division. (I) - 1 2. QAPs are dcabrM by Departments responsible for conducting particular activities, reviewed j by the managers of the responsible d*uartment(s) for that particular activity, and appsoved by theVicePresident-NuclearEnergyDivu,b:- (t) l 3. Nuclear Program Directives are prepared under the direction'of the Department Manager assigned as the Program S xmsor. Affected Department Managers review directives and their j revisions. 'Ibe Manager-90AD ensuses directives are..~.d by the Quality Assurance c i organiration and approval recommended to the Program Sponsor. 'Ihe responsible Program Sponsor approves directives and their revisions. Directives are prepared,.. ~.J, approved, j and periodically reviewed according to an app ~ Jim to' the Nuclear Program Directives j! Manual. 4. Procedures are prepared, approved, and controlled according to the Control Procedures. ) Control Procedures establish. review, approval, revision, change, and ~ periodic review 1 requirements for applicable procedures. If format' and content requirements are not contained in Control Procedures, they shall specify the document to be used to' determine j format and content requirements. Control Procedures are reviewed by the Quality Assurance j Organization. Other procedures are reviewed by Quality Assurance on a requested basis. ] a 5. Basis items added during procedure revisions or changes will be recorded.' (1) i 1 IB.6 DOCUMENTCONTROL 3! .. Requirements have been established to control the documentation of activities controlled by the QA - l; . Program. QA Program controlled documents include the UPSAR; Operating L% including the Technical Speci6 cations: Emergency Response Plan; Security Plan; QA Policy; the ISFSI updated specifications;and draw (ings. Safety Analysis Report SAR) and Materials Licen i Revisions to the QA Policy are controlled by QA Program documents which are written to ensure j compliance with 10 CFR 50.54(a)(3). i i t i Page 24 of 59 a,.

~ ~ q .,.g b t a QUAllTY ASSURANCE POIJCY L i Revision 40 -i - Alterations to the UFSAR are controlled by QA Program d- =mnts which are written to ensure compliance with 10 CFR 50.71. Aherations to the ISFSI updated SAR are controlled by QA Program documents which are written g to ensure compliance with 10 CFR 72.70. =;

• P Alterations to the Operating license, including the Technical SM-tions are controlled by QA l

Program documents which are written to ensum compliance with 10 CPR 50.59(c),10.CPR 50.90 - and 10 CPR 50.92. - Alterations to the ISPSI Materials r k-me including the na4=W specifications, are controlled by a OA Program documents which are written to ensure compliance with 10 CPR 72.48(c),'10 CFR 72.56, and 10 CFR 72.58. - V h Alterations to the Emergency Response Plan are controlled by QA Program documents which are i written to ensure compliance with 10 CFR 50.54(q), and with 10 CFR 72.44(f) for the ISFSI. I i Akerations to the Security Plan are controlled by QA Program documents which are written.to - j ensure comphance with 10 CFR 50.54 (p), and with 10 CFR 72.44(e) for the ISFSI. j l.. QAPs are required to: j i-j I 1. Establish controls to ensure that regulatory requirements and BG&E commitments will be ' implemented. y 2. Describe interdepartmental interfaces and establish controls for interdepartmental activities.- ] i 3. Specify how important activities, such as plant maintenance or in. service inspection, are to be '{ performed, and give sufficient detail to control the performance of the activity or to ensure l that requirements for lower-level procedures are clearly specified. 1 4. Be prepared and controlled in accordance with QA Program documents that describe the : format, sequence of topics, contents, review and approval, issue. and distribution, and i requirements for revision and record retention. 1 During the review of each QAP, compliance with applicable criteria speciSed in 10 CFR 50, 1 Appendix B, is verified and documented. The Manager-NSSD, is responsible for issuing, revising, and controlling QAPs. l f QAPs are developed by one of the departments responsible for the subject activities. Each procedure is given a compliance review by a member of the Quality Assurance Organization, and - l technical review by a member of one of the responsible departments. Each QAP is reviewed by'

i department manager (s) who have responsibilities for activities governed by that.QAP, and the j

Managers of the Nuclear Energy Division. (1) Each QAP is approved by the Vice President-Nuclear Energy Division and issued by the Manager-NSSD. (1) Directives are required to: 1 1. Establish controls to ensure that regulatory requirements and BG&E commitments will be implemented. 2. Establish controls to ensure that management requirements will be implemented. Page 25 of 59 j 4

4 OUALITY ASSURANCE POLICYT l Revision 40 ~ ^ P P 3. Assign responsibilities 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-l review requirements. l Nuclear Program Directsves are prepared and technically reviewed under the direction of the Department Manager assigned as the Program Sponsor.. Each directive is r vimd by atrected Department Managers. Each directive is given a compliance review by a member of the Quality Assurance organization. Nuclear Program Directives are approved by the sponsoring Manager after j ensuring resolution and incorporation of QA compliance rewew comments. (9).'Ihe Manager-3 NSSD ensures issuance of each directive. .i i Administrative and Technical Procedures are prepared when needed to implement QA Program document requirements according to a Control Procedure. Individual organi=tions are responsible for preparing, revising, issuing, and_ controlling procedures. Each procedure is given a technical review under the direction of the sponsonng organization. The Quality Assurance organization performs. compliance reviews on Control Procedures. Other procedures are reviewed by Ouality Assurance on a requested basis. j i Organizations that issue instructions, procedures, specifications, or drawings are required to establish controls that ensure the following: 1. Changes to a document are reviewed and approved by the organintion that performed the original review and approval unless the control procedure designates another qualified responsibic organization. i 2. Approved changes are promptly incorporated into instructions, procedures, drawings, and j other documents associated with the change. r 3. Obsolete or superseded documents are controlled to reduce the possibility of inadw rtets use. l Superseded documents retained for reference are marked and stored in separate fik.S. Other .j 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. i 1B.7 CONTROL OF PURCHASED MATERIAL EOUIPMENT. AND SERVICES (5) NOAD, NSSD, NED, and PMMD personnel are responsible for the control of purchased items and I services for SR and designated NTR applications at CCNPP. The controlsinclude: t Accepting items or services only from vendors who have been evaluated and selecteel in accordance with this policy. i Procurement documents for spare or replacement parts of structurcs, systems, and components as designated under the OA Program subject to controls at least equivalent to i those applied to the original equipment, or an evaluation / justification shall be documented when less stringent controls are involved. l I Page 26 of 59 1

QUALITY ASSURANCE POLICY Revision 40 Vendor surveillance, verification and audit activities, and receipt verification are conducted 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 requirements. Vendor Evaluation %e 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 CCNPP and assessing the need to impose source surveillances and/or verifications during the manufacture of items or performance of services for BG&E. Vendor evaluations depend on the procurement classification of the item (s) being supplied. He National Institute of Standards and Technology (NIST), by virtue of its being the nationally recognized standard, is an acceptable provider of calibration masters, standards or services. Utilities holding an NRC Construction Permit or Operating License are acceptab!c suppliers of all items except for those items to be used in an ASME Boiler and Pressure Vessel Code Section III apphcation. Neither of the above are required to be listed on the Approved Vendors List (AVL). ) Nuclear Grade NQAD performs evaluations and audits to verify that the vendor has developed and implemented an acceptable quality assurance program that complies with the requirements specified in the procurement specification or proposed procurement specification. These evaluations and audits are conducted and documented using written procedures or checklists that identify the OA requirements applicable to the items supplied. Comanercial Grade Since BG&E accepts the responsibility of verifying the conformance of commercial grade items and/or service, they may be procured from vendors with no formal quality assurance program. In this instance, BO&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 controls are implemented in the manufacture of items or performance of services for BG&E. Vendor controls evaluated to be satisfactory may be invoked as requirements within the purchase order and may be used as part of the basis for acceptance of the item. The depth of vendor evaluation varies according to the complexity and function of the item involved and to the role of the vendor in acceptance of the item. Vendor Approval Upon completion of the evaluation, satisfactory vendon 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 with BG&E's requirements. An auditing organization such as NUPIC, another utility, a contractor to BG&E, etc., may be used to verify that the vendor has developed and implemented a QA program that complies with 10 CFR 50, Appendix B or a commercial grade program that complies with the requirements of BG&E's procurement requirements or similar requirements. Page 27 of 59

s-F i QUALITY ASSURANCE POLICY 1,. Revision 40 l ^ .When required by operational considerations, an order'may be placed with a vendor prior:to ' completion of the evaluation and approval process only after obemining the Manager-NSSD's - approval. BO&E's acceptance of basic component items or services provided by an unapproved vendor is contingent on the subsequent NQAD evaluation and approval of the vendor as stated above. Verification of Vendor Actmties [ Vendor surveillance, and source verification activities are conducted by qualified NOAD ~ personnel ' l - in accordance with written procedures or checklists. These procedures or checklists, along with the procurement documents, specify the characteristics or processes to be witnessed, inspected or. i verified. Personnel performing these activities are qualified to catablish whether or not a vendor is - capable of providing products of acceptable quality. Ihc depth and frequency of vendor surveillances, verifications and audits is commensurate with the l complexity and function of the item or service and the ability of the vendor to provide the necessary assurance of acceptability. When a vendor's certificates of conformance 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 processes. Recciot NSSD is responsible for receiving and storing materials, parts, and components. Additionally, NSSD is responsible for performing standard and special receipt inspections and coordinating testing necessary to accept SR items, designated NSR items and commercial grade items j for SR use. Standard receiving inspection ofitems is performed to assure the following:. \\ 1. The item is properly identified and that this identification corresponds with the documentation received. L 2. Stated packaging, shipping and handling requirements have been maintained. 3. Items have not been damaged, workmanship is of adequr.te quality, and the items are adequately clean in accordance with procurement document requirements. 4. Documentation required by the Purchase Order has been received and is reviewed to assure that the item conforms to the purchase order requirements. j ~ Special receiving ins - n may be required if the item was not inspected at the source; when j t requested by the R or; as part of the acceptance basis for commercial grade items. f 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 i their acceptability. If traceability is lost or the documentation review is unsatisfactory, an item { becomes subject to the controls established for non-conforming items. i Page 28 of 59

>{ ~ n, = QUAUTY ASSURANCEPOLICY Revision 40 l ^ r Non. conforming items are identiGed and handled in accordance with Section 1B.15 of this policy? 9- . and, when practicable, are placed in a segregated area to prevent ined-At installation or use until ' proper dispositionis made, a Documentation 'i ~ BG&E procurement dm====ts require vendors to provide documentation identifying the purchased. j . item and the specific procurement requirements that are met by the item. si a -c< Vendor inspection records or certiGcates of conformance attesting to acceptance must be in the j r-n ' + of BGAE before the item may be released for installation or use. However, an L! unacceptable item may be given a " Conditional Release" if there is reasonable assurance that it can;

j be made acceptable after installation but before the system that contabs it is considered operational q

Itemr, released under " Conditional Release" must be controlled under the Non Confonnance Report -i (NCR) system. Vendor requested deviations from procurement document requirements, including l nonconformances dispositioned "use-as-is" or " repair" must be submitted to BGAE for evaluation tl and approval of the deviation or a recommended disposition prior to shipment. j 1B.8 IDENTIFICA*110N AND CONTROL OF MATERIATR PARTS! AND COMPONENTS (5). 'I NSSD/NED personnel ensure that procurement documents uire that SR and designated NSR-items, including partially fabricated sub-assemblies, are ident' and controlled to prevent the'use -

l ofincorrect or defective material.

i t Requirements for identi6 cation by use of heat number, part number, or serial number, or by other means, are referenced or stated in procurement documents. These documents. require the identiGcation to be placed on the item or in records traceable to the item so that the function and quality of the item are not affected. ' Ibis identification is required to be maintained throughout fabrication, storage, erection, installation, and use. NSSD personnel ensure traceability information is correctly transferred to subdivided materials stored in the Warehouse. User organirations ensure - i traceability information is correctly transferred to subdivided materials after issuance from the Warehouse. NOAD is responsible for performing periodic inspections or surveillances to verify 1 program adherence. i Assigned NSSD personnel purchase identify, store, and issue items as sp-#ieA by procurement controls and provide for maintaining the integrity of items and their traceability to associated documents during storage andissue. l BO&E contractors and their sub-contractors (who are approved to work on-site under their own QA program) are responsible for establishing and implementing programs in accordance with specified reqdrements for identifying and controlling materials, parts, and components under their junsdiction. Identification of items important to the function of SR and designated NSR structures, systems, and t i components can be traced to appropriate documentation such as drawings, spifications, purchase orders, manufacturing and inspectaon documents, deviation reports, and physx:al and chemical mill-test repotts. i I I l c l q Page 29 of 59 i i

] m, + c g . QUALITY ASSURANCE POLICY T < Revision 40. 1 I 1 ~ d .l i , SR and, designated NSR ite=ns received at CCNPP are receipt inspected to verify ~ that all - V requirements of the procurement documents have been met.- If a discrepancy is observed, such as j - damage or docanentation, information to the effect is recorded on the' receiving inspection report, and the t item is identified as such and placed in a separate " hold" area when t practicable. _If the item is A it is identified to indicate acceptance and that it is approved for '. 4 . storage or installation and use. When groups of items in storage are subdsvided, each subgroup is separatelyidentified. ~

p if an item is found to be or is made discrepant during processing,' it is identified as such and placed in

a separate areawhen practicable.

1 e 1 Acceptance documentation is required to be traceable to a purchase order, drawing, sp~ineation, 1 requisition number, or assembly. As individual items are assembled, instaBed, and lamW, their 1 acceptance-tag numbers are recorded in plant maintenance or operation records. ~ j After completion of tests and inspections, records that document test results and traceability are kept j as part of the plant records. 1 T 1B.9 CONTROL OFSPECIALPROrmpR L l-Controls Controls have been established for writing, qualifying, approving, and issuing ures to control; l such special processes as welding, heat treating, and nondestructive testing during the operation

j of CCNPP. Special Process Procedures

1 1. Are prepared in accordance with applicable codes, standards, specifications, criteria, and other - ] special requirements. i 1 . 2. Ensure that special processes are performed by qualined personnel according to. qualified 1 procedures that comply with applicable regulatory requirements.- 1 3. Specify requiremcats for control, parameters to be consideacd, acceptable methods' of j documentation, and the codes, standards, specifications, or criteria which govern the qualification. j s 4. Define the necessary qualification of personnel, procedures, or equipreent when special processes are not covered by existing codes or standards or when quality requirements for an j item exceed the requhements of established codes or standards. BGAE contractors and their sub-contractors are responsible forcontrol ' special & used by-them and for maintaining records to verify that special prr-mem are ormed in accordance with? j requirements established by the portions of their QA programs that apply to special pro==*= .j Quahfication of Methods i i Procedures, equipment, and personnel connected with special processes are qualified in accordance - with applicable codes, standards, speedications, or supplementary requirements as follows: j i 1. Welding activities conducted by BO&E are performed according to welding procedure specdications quahfied in accordance with applicable welding requirements of the ASME l Code. Each welding procedure specification is written, qualified, and approved in accordance Page 30 of 59 i -J

7 g- ~y ,n , -~ jt )-j =. g i Revision 40 ~ j 2 QUAUTY ASSURANCE POUCY a O with a controlling dacu=eated pwwd-Copies of welding prneadure specifications are. I made avadable to welders and, when required, to Authorized Inspe=J Before contracting .j for wekhng, the Pd dp.a Metallurgist reviews and approves non-BG&E welding procedure - specdications and procedure quahfication records in accordance with a written procedure. 2.L Heat-treating requirements included in welding procedure specifications are establahed ini 1 conformance with heat-treatag requirements of the applicable ASME Code. o N 3. . Nondestructive Framinatinnt are performed : to written procedures; proved by actual demonstration, when prae *ic-M, to the ! satisfaction of, the Pre, cipal Engineer v Nondestructive Pamminarion - Nuclear and, when required, the Authorised Is-r dor. y s a ^ These procedures are p according to appropriate sections of the ASME Code for particular ij examination methods. ,. personnel qualincations, and: thet records: that : venfy the 41 Performance of Nondestructive Fmannnatinns are kept as nuclear plant records.. Nondestructive Framination Procedures describing methods not described in the ASME Code and/or SNT-TC.1A ' i and its Sup dements.are at least e9uivalent to those recognized by the Amnie=a Society of Mechanical Engineers and the Amencan Society for Nonalestructive Testing...*naining programs. d - acceptable to the Principal Engineer - Nor.dcm.ictive Fzamination - Nuclear are developed to l co-yl.,s.cet these alternative methods and to establish the capability of personnel to perform the-J uired examination according to BG&E procedures and to the level of performance to which the -;j in

• dual will be certified.

l Methods of Nondestructive Framinatinn include, but are not restricted to, radiographic, j

uhrasonic, liquid-penetrant, magnetic-particle, eddy-current, ! visual, and leak-testing examinations. Procedures are prepared to cover these naminations in accordance with a QA y Program document that details the specific ex==iantion, requirements for a content of the procedure, such as certification level, accept / reject criteria,pprovaj examination t coverage and sequence, surface preparation, test equipment, records required, permissible : marking, cleanup requirements, and reference to applicable sections of the ASME Code. On-Me=*ina of Personaal I Special processes are pcifeia.cd by certified personriel using _ written process sheets, shop P procedures, checidists, and travelers (or equivalent), with recorded evidenz of venfication as. follows: 1. BO&E welders, and welders under contract-to BG&E, are qualined and certified in ~ accordance with the applicable requirements of the ASME Code. %e Principal Metallurgist l ~ maintains records of the welding procedure specifications, including essential variables under which the welders 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 emnergency, verbal clearance from the Principal Metallurgist, is on file at CCNPP. Eadi welder is required to be requahfied as specified in the applicable code. 2. Non-BO&E welders are not permitted to weld SR and designated NSR items until they'are - qualified and certified in accordance with the applicable requirements of the ASME Code. l-i l l Page 31 of 59 1

y, y 'p'

j

. QUAIIIY ASSURANCE POLICY - l Revision 40 l 4 .i 3 3. Noodestructive Examination personnel employed by or responsible to BGAE are certi5ed l according to applicable sections of the ASME Code and/or SNT-TC-1A and its Supplements. l BG&E employees are trained and certi5ed in eccmh with a written procedure. Non-t BGAE personnel are qualified to procedures approved by BGAE, and their quali5 cations and. t certifications of personnel are veri 6c.1 according to written procedures. r . Qualification records of procedures, equipment, and ~s.c, el associated with special processes j i conducted by BGAE are Sled and kept current by the Principal Metallurgist or Principal Engineer - Nondestructive Examination - Nuclear. j ' 'Ibe Manager-NOAD provides independent verification that special processes are performed by ~ l qualified personnel.- i 1B.10 INSPECTION = Activities that affect the quality of SR and designated NSR items are inspected as specified in : approved instructions, procedures, and plans which set forth requirementa and aacptance criteria to ensure that work is done in conformance with particular requirements. i Controls A.e4 during inspections ensure that: i 1. Pctsonnel who perform quality veri 5 cation inspections are independent of the personnel.who i puiura.cd the activity bemg inspected. 2. Inspection procedures or instructions, with necessar'y drawings and specifications for use, are available before inspection operations are performed ~ i 3. In the case of special processes, inspectors are quali5ed, and their quali5 cations comply with applicable codes and standards. 4. Test and measuring equipment is calibrated within required limits. 5. Inspection procedures, as appbcable,.:pecify objective acceptance criteria, prerequisites for performing mspections, limitmg conditions, requirements for'special equipment and Quality.. r . Veri 5 cation (QV) hold-points at which inspections are to be witnessed. 6. Appropriate inspection requirements are established for modification,. repair, - and j replacement. 7. Personnel who perform quality verification inspections are quahfied in accordance with appropriate codes, standards, and Company training programs, and their qualifications and

i certifications are kept current.

l 8. Procedures for maintenance and modification are reviewed by QV per.csg.c! to determine the { need for independent ins tion and the degree and method if such an inspection is required, l and to ensure the iden ' tion of inspection personnel and the documentation of inspection i results. i f i 1 Page 32 of 59 ) f . ~

QUALITY ASSURANCE POLICY Revision 40 l 9. Procedures for Nondestructive Examination, excluding visual examination procedures performed on nuclear fuel, are reviewed by qualified personnel in FED. Procedures for nuclear fuel inspection and visual examination on nuclear fuel are reviewed by qualified personnel in NED. Review is to determine the adequacy of procedural controls and of - inspection criteria, the need for independent inspection, and the degree and method, if such inspection is reguired; and to ensure the identification of qualified inspection personnel and the documentation ofinspection results. 10. Inspection results are recorded, evaluated, and retained. Inspection procedures, instructions, and checklists used by QV personnel provide the following: 1. Identification of characteristics to be inspected. 2. Identification ofindividuals or groups responsible for performing the inspection. 3. Acceptance and rejection criteria. P 4. Description of the method ofinspection. S. Identification (including revision number) of required procedures, drawings and specifications. 6. Identification ofinspector or data recorder. 7. Verification of completion and certification of inspection. 8. Record of results ofinspection. 9. Provision for identifying mandatory inspection hold-points for witness for an authorized inspector or BG&E inspection personnel. 10. Provision for indirect control by monitoring processing methods, equipment, and personnel if direct inspection is not possible. 11. Specification of necessary measuring and test equipment including requirements for accuracy. The General Supervisor-Quality VeriGcation (GS-QV) is responsible for the preparation and implementation of procedures for activities conducted by Quality Verification personnel. (11) 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 documented; that equipment is returned to operating status after test, modification, or repair; that instruments are properly-calibrated; and that personnel who perform tests are properly trained 4ad qualified. In-service inspections are performed on pressure-containing components within the reactor coolant system boundary according to requirements of the 'ISs. In-service inspections and examinations on components designated Class I or Class II by the ASME Code are witnessed or otherwise veri 5ed by an authorized Code Inspector who is responsible for ensuring that the work is performed by qualified personnel according to written qualified procedures. Records ofin-service inspections, results, corrective action required and taken, mspection standards required for repair, and results of inspection of repairs are maintained and compared with the results of subsequent examination. Page 33 of 59

'k QUALITY ASSURANCE POIJCY Revision 40 i 1B.11 'IEST CONTROL To demonstrate the ability of SR'and haiy=H NSR structures, systems, and components to. l function as des' , they are subjected to a program of surveillance and operational testing.. Procedures s ~ the systematic development, review, approval, and conduct of tests and review of test resulta.. Conditions such. as failures, malfunctions,' deficiencies, deviations, and non-a conformances discovered during testing are dac~nted and evaluated. j Whenever testing is required to demonstrate that SR and designed NSR material, parts, components, or systems will perform satisfactorily in service, a test program is established and procedures are used i that have been written and appmved 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 perforinance are identified and controlled, and i demonstrate satisfactory performance after plant modification and maintenance activities. written test procedures are developed, reviewed, and appmved 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. 3. 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. i 7. Methods of documenting or recording test data and results. 8. Provision for ensuring that test prerequisites have been met. Test results are documented and evaluated; they are accepted or rejected by a qualified, responsible - individual 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 & =anstrate 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 j qualified NSSD personnel,(5) 1 Page34 of 59

3 QUALITY ASSURANCE POLICY Revision 40 ? .1B.12 CONTROL OF MEASURING AND TEST EOUIPMENT i Calibration controls have been established to prescribe the technique and frequency of calibration,' maintenance, and control of aseasuring and test instruments, tools, gauges, fixtures, reference and transfer standards and nondestructive test equipment used in measuring,insp*We and monitoring - SR and designated NSR components, systems, and structures during the operations phase of j L CCNPP. 1 Personnc! of the following functional organizations control, calibrate, and adjust measuring and test - equipment: Electric System Operation and Maintenance Department ' Calvert Cliffs Nuclear Power Radiation Safety Plant Department . Performance Engineering Unit - -- MechanicalMaintenance Electrical and Contzois l Nuclear Operations i -. Chenustry - i . Calibration controls require each group to identify measuring and test equipment and calibration test ' data related to it. Written procedures are prepared and implemented to ensure that tools, gauges, instruments, and

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

Manufacturer's Procedures are used for calibration or a procedure is prepared for each category of measuring and test equipment as necessary. 'Ibese Calibration Procedures contain the following< information: + 1. Identification of the item to be calibrated and its period of calibration. 2. Standards to be used, specific test-points, and checks, tests, and measurements to be made. ' 3. Acceptance criteria to be used and special precautions to be taken when naremry. Measuring and test equipment that require calibration are assigned an identifying serial number.- Instruments are calibrated at speedied intervals according to the required accuracy, purpose, degree of usa 2e, stability characteristics, and other conditions that affect the measurement. - b 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 usmg .m. that equipment. 1 Test and measuring equipment that cannot be adjusted to required tolerances during calibration is identified and placed in a designated segregated arca; if the equipment can be used in limited applications, the limitations are identified. 'Ihe 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 status. An i interval of calibration is established for each item of measuring and test equipment and recorded on a . master record of calibrations prepared as a calibration schedule. 1 l Page35 of 59

.;~ 1 i QUALITY ASSURANCE POLICY. Revision 40 1 i Measuring land test eq ipment'is controlled to prevent the use of uncalibrated or defective equipment, the spread o radioactive contamination, the introduction of impurities into high-purity systems, and damage to or loss of equipment. Identification tap are placed on measuring and test j equipment to indicate such special conditions as radioactive cleanliness, special limitations, or failure ' to meet established calibration requirements. r Measuring and test equipment is calibrated and adjusted'at specified intervals, or before use, against - l certified -standards.. Reference and transfer standards are traceable to nationally recognized t standards; or, where national standards do not exist, provisions are established to document the basis' for calibration. i .I 1B.13 HANDLING. STORAGE. AND SHIPPING d - Appropriate and special requirements for handling, preservation, storage, cleaning, packaging, and? shipping of SR and designated NSR items are specified in procurement documents. 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. Special handling, preservation, storage, cleaning, packaging,-and shipping activities associated with . SR and designated NSR items are performed by suitably trained personnel in.accordance with1 specificwritten procedures. Controls have been established for the safe storage of hazardous materials. -Items with a limited' shelf life are controlled to ensure that they will not be used in SR and designated NSR applications after expiration of designated shelf-life periods. 1B.14 INSPECTION. TEST AND OPERATING STATUS ~! 1 Controls have been established for the application and removal of status indicators such as tags, l markings, labels, and stamps to ensure that the inspection, test, and operding status of SR and .) designated NSR structures, systems, and components is clearly indicated at all times. Procedures / instructions are prepaird to identify and control inspection,' testing, and operating status ~ 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 in:iicators, including the euthority for their application and removal; control bypassing operations, such as jumping or temporary removal of electrical leads; and identify non-conforming, inoperative, or malfunctioning structures, systems, or components. Senior shift personnel are responsible for.abgeng, isolating, and appropriately tagging installed equipment and systems so that activities affecting quality can be performed. ' a ne Manager-NOAD is responsible for the performance of surveillances to verify that the inspection, testing, and operating status of structures, systems, and components are properly. identified and controlled during operation, maintenance, and testing of the plant. He bypassing of required inspections, tests, and other critical operations is controlled to ensure that bypassed inspections or tests are properly documented and that the effect of bypassing 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 SR and designated NSR structures, systems, or components is identified to prevent inadvertent use. 1 Page 36 of 59

- QUALITY ASSURANCE POLICY Revision 40 .~ 1B.15 NONCONFORMING MATERIAT R PAR'IE. OR COMPONENTS (6). Controis have been established for identifying, documenting, segregating, reviewing, dispositioning, and notifying affected organizations of Issues affecting materials, parts, or components (i.e., items). i Issues affecting nuclear plant items are referred to as nonconformances. Nonconformances are 1 hardware deficiencies which render the quality of an item 2nacceptable or indeterminate.- i i 'Any individual identifying an actual or suspected nonconforming item is responsible for documenting - i and reporting such nonconforming item promptly to supervisory or Nuclear Quality Assurance Department personnel. Nonconforming items are controlled by documentation, marking, logging, tagging, or physical -l segregation to prevent inadvertent installation or use. Nonconformance control documents are submitted to responsible departments for resolution. Designated personnel have the r2sponsibility and authority for approving the resolution of . nonconformances. Nonconformance control documents are not closed until cormctive actions have been completed. l Nonconforming items are dispositioned as rework, repair, reject, or accept-as-is. The disposition of a 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 l original inspection and/or test requirements or acceptable alternatives to ensure that critical characteristics possibly affected by the nonconformance remain acceptable. 1, Nonconforming items may be conditionally released for installation, test, 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 Speedication operabilitq may be relmased for use following verification that the noncofforcing(itee meets-all - operability requirements specific to its functiof and is approved for use by authorized Operations I persofnel& Cgnditionally released items will be resolved in accordance with this Section. Conditional release evaluations are documented, reviewed, and approved prior to implementation. 1B.16 CGRREKTIVM ACQON (6) j Controls have been established to ensure t'at Issues are identified, documented, reviewed, and I corrected. 'Ihese controls are applied to deficiencies associated with the programmatic content, process, and. implementation of the Quality Assurance Program as well as nonconformances (ref Section 1B.15). Corrective actions are implemented by responsible personnel and may include immediate actions,' 5 remedial actions and/or actions to prevent recurrence, based on the significance and extent of the Issue. t Issues identified as potentially impacting the safe production of nuclear power are evaluated for Technical Specificatsoo Operability, NRC Reportability, Nuclear Safety Significance, and if the activity should be stopped. 'Ibe VP-NED, or designated alternate, is informed of Issues which 1 require NRC notification. i Corrective action verification is performed for Significant issues prior to the close-out of the i corrective action document. Verification is performed and documented by individuals not directly 1 Page 37 of 59 i .l

'i a6.- l 4 K QUAIIIY ASSURANCE POLICY Revision 40 ' involved with implementing the corrective action (s). Unacceptable corrective action (s) are reported - to supervisory or management personnel directly responsible for resolving the Issue and to progressively higher levels of management until the Issue is resolved. Significant Issues require a root cause analysis and.the implementation of corrective actions to prevent recurrence and are reported to management for review and assessment. Issues are periodically analyzed for the identification of adverse quality trends. The existence of an - adverse quality trend is resolved in'accordance with this section. A Trend Report is issued to i - management at intervals specified in approved procedures. 1B.17 . OUAIIlY ASSURANCE RECORDS Controls have been established to ensure that quality assurance records are maintained to provide - documentary evidence of the quality of SR and designated NSR items and activities. Applicable design specifications, procurement documents, test procedures, operational procedures, QAPs, Es, and other documents specify records that should be generated, supplied, or maintained by and for BG&E. - Quality assurance records are classified as lifetime or non-permanent. Lifetime records, maintained for particular items for the life of CCNPP,.for particular items have significant value in relation to demonstrating capability for safe o wration; 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-sesvice 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 BG&E's ability to reconstruct significant events and to satisfy applicable regulatory requiremeras. Retention periods are based on requirements specified in QA Program documents. Retention periods shall be documented. Procurement documents specify vendor responsibilities for the generation, retention, and submission to BG&E of quality assurance documentation related to the fabrication, inspection, and test of SR and designated NSR items and services. Inspection and test records contain the following as appropriate: 'I i 1. Description of the type of observation.' 2. Date and results ofinspection or test. 3. Information related to noted discrepancies, including action taken to resolve them. ~ 4. Identification ofinspector or recorder of data. 5. Statement as to acceptability of results. Controls have been provided to ensure that records are protected from possible destruction. Within established time-intervals, completed lifetime records are transnutted to the Records Management Unit for incorporation into the Long Term Records Storage and Retrieval' System. Page38 of 59

m QUALITY ASSURANCE POLICY ' Revision 40 3 .g 1B.18 AUDITS i Internal audits are performed by BG&E's Quality Audits Unit' to casure that activities and i n l' procedures established.to implement the requirements of 10 CFR 50, Appendix B,' comply with. [ BO&E's overall OA Program. 'Ihese audits provide a comprehensive independent verification' and evaluation of quality-related activities and procedures. : Audits ensure the effective and proper j implementation of BG&E's QA Program.' 'Ibey are scheduled on the basis of the importance to safety of activities being performed. i ' Vendor audits are performed to evaluate QA programs, procedures, and activities. : Audits of major + vendors are made early enough to' ensure compliance with 'all. aspects of BO&E's procurement , documents. Additional audits are performed as required to ensure that.all requirements of BG&E's ' QA Program are properly implemented according to procurement documents.: Audits of designated activities ~ as required by the TSs are performed under cognizance of the OSSRC. Audits are performed in accordance with preestablished written procedures or checklists by qualified NOAD personnel who have no direct responsibility for the werk being audited. Technical specialists ' j from other BG&E departments and outside consultants may assist as necessary in performing audits. Audits include objective evaluation of quality-related practices, procedures, instructions, activities, and items, as well as review of documents and records. Reports of audits are analyzed and documented.. Results that indicate the QA Program to-be inadequate, ineffective, or improperly implemented, including the need for re-audit of deficient areas, arc reported to the Manager and Supervisor of the audited actMty. Controls have been~- established for verifying that corrective action is taken promptly to correct noted deficiencies.- ~i To ensure that BG&E's NOAD complies with the requirements of BG&E's OA Program, an independent management audit of NOAD activities is performed annually by.a Joint Utility Management Audit (JUMA) Team. - i . f b r i I r i Page39of 59 [ e,

f QUAllTY ASSURANCE POLICY Revision 40 r I TABLE 18-1 BALTIMORE GAS AND ELECTRIC COMPANPS POSITION ON GUIDANCE CONTAINED IN ANSI STANDARDS l Revision ofIndustry Standards Aonlicable to the Baltimore Gas and Electric Ouality Assurance Program Reauirement Some of the Industry Standards listed in Section 1B.2 identify other Standards that are reguiredcand some Regulatory Guides define the revisions of those Standards that are acceptable to the NRC. Resoonse i 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 + Reauirement Section 5.2.15 requires that plant procedures shall be reviewed by an individual knowledgeable in the ) area affected by the procedure every two yean to determine if changes are necessary or desirable.. f

Response

BG&E ap lies this requirement of a two-year review to all plant procedures except test procedures perform less of'en than every two more than 60 days hefore performance. years or at unspecified frequencies. These are re 3 Reason Engineering Test ProcMures (ETPs) and others like them are written for a one-time-only l 4 performance and kept for eference for future similar tests. -If they are used again, they are reviewed and modified to meet condititas existing at the time of performance. l Some Surveillance Test Procedures (STPs) are performed every three to five years. They too are reviewed before each performance to coture that they are compatible with existing conditions and l responsive to current needs. l Item 2 (10) Reautrement j t Section 5.2.2 rpecifies that temporary procedure changes that clearly do not change the intent of the approved proxdure shall as a minimum be approved by two members of the plant staff 'l Page40 of 59 t

li i ' QUAUTY ASSURANCE POUCY Revision 40' I 9 knowledgeable in the areas affected by the procedure; and' at least one of these individuals shall be : -l the supervisor in charge of the shift and hold a senior operators' license on the unit affected. +

Response

j 7 r BGAE does not require the Shift Supervisor to be the Senior Reactor Operator (SRO) approving temporary changes to' procedures; any active SRO (either on-shift or o.+stati) may provide the SRO ' l approval for procedure changes. iq ~ Reasop l Many proposed temporary procedure changes do not require the Shift Supervisor's immat=* l 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 j is not necessary to ensure plant safety. a Requiring the Shift Supervisor to review all changes is burh.x and contrary to plant safety in . light of the total number of pru.siures that exist and the time the Shift Supervisor must dedicate to j ensuring the plant is safely operated and main'ained. Additionally, our Technical Specification requires this' approval be from someone hoir'ing an SRO license (not cera==ily the Shift Supervisor). l l i ANSI Nig.1 - 3/8/71 l liggj i -1 Requirement l Paragraph 4.2.2 states that at the time of initial cote loading'or appointment to the active position,- the Operations Manager shall hold a Senior Reactor Operator's (SRO) License. q Paragraph 3.2.1 states that positions at the functional level of Manager are those to'which are - assigned broad respcasibilities for direction of major aspects of a nuclear power plant. 'This functional level generally includes the plant manager (plant superintendtat, or other title), his line' assistants, if any, and the principal members of the operating organization reporting directly to the plant manager and having overall responsibility for operation of the plant or for its maintenance or tark=*al service activities.

Response

i 1 Baltimore Gas & Electric has two positions in its organization, Superintendent-Nuclear Operatens and General Supervisor-Nuclear Plant Operations. Neither of these positions needs to Individually meet all of the requirements of both paragraphs 3.2.1 and 4.2.2. The S-NO will satisfy paragraph 3.2.1 and most of 4.2.2 except that he will not maintain an SRO license. Instead, the S-NO will hold or have held an SRO license. The GS-NPO will hold and maintain an SRO license. The OS-NPO y satisfies paragraph 4.2.2, but he does not satisfy 3.2.1 because he does not report directly to the plant manager. k Page41 of 59

rP QUALITY ASSURANCE POIJCY ' Revision 40 i c Reason L 'the S-NO will hold or have held an SRO license, as opposed to having a heense at the time of 1 'a ~ tment to the position. He will have an excellent understanding of plant operations. 'Ihe OS-I will not only hold an SRO license at the. time of appointment to the position, but he will t maintain the license. The OS-NPO directly supervises the operating shift organisation, whereas the - S-NO is also responsible for operations procedure dcsdy,eent, modifications acceptance, and operations /maintenancs 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. t ANSI N45.2.1 - 1973 Requirunent Subsection 3.2 oclines requirements for demineralized water.

Response

BO&E specifications for demineralized water are different than the specifications outlined in the' standard. - Reason j i BG&E specifications for demineralized water are consistent with guidehnes provided by the Nuclear Steam Supply System supplier. BO&E specifications are generally more restrictive than those specified by ANSIN45.2.1. ANSI N4512 - 1972 u-1 i Reauirement Subsection 2.4 could be interpreted to mean that on-site and off-site peur.onnel who perform any inspection, examination, or testing activities related to the packing, shipping, receiving, storage, and handling of items for nuclear power plants shall be qualified in accordancewith ANSI N45.2.6.

Response

f \\ BG&E requires that only persons who are responsible for approving items for acceptance shall be qualified in accordance with Regulatory Guxle 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 Our receipt inspection procedures require persons who approve items for acceptance to be qualified ) in acco: dance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6). QV technicians, inspectors or QA auditors verify that storage areas meet requirements. All other inspection, Page 42 of 59

^ p 5 QUALITY ASSURANCE POLICY Revision 40 j exannination, and testing activities are subject to review by persons quali6ed to Regulatory _ Guide 'i 1.58 (which endones ANSI N45.2.6). Isess 2 Requirement-The second sentence of Subsection 2.4 requires that: Off. site inspection, nummination, or testing shall be audited and monitored by l personnel who are qualified in accordance with ANSI N45.2.6. I a

Response

\\ . BG&E uses personnel qualified in accordance with ANSI N45.2.23 to perform. auditing and monitoring functions. Reason i r 'Ihe quali5 cation requirements for auditos cannot always be met by persons qualified to Regulatory .i Guide 1.58 (which endorses ANSI N45.2.6). -i Requirement ~j t Subsection 2.7 requires that activities covered by the-Standard shall be divided into four levels' j though recognizing that within the scope of each level there may be a range of controls depending on the importance of the item to safety and reliability. Ecssonns 1. Tbc level of protective measures defined by Subsection 2.7 are applied to Basic Component 1 purchases. -l 2. Personnel of BO&E's Nuclear Enginecnng Department (NED) will determine the level of - i protective measures to be applied to Commercial Grade purchases.- i ) i i l 1 1 1 1 Page 43 of 59 )

1 W QUAIIIY ASSURANCE POLICY - 1 D Reason L{ i BG&E's position is as follows: 1. For Commercial Grade items, it is not always possible to assign a level of d=dication 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 M vendors is adequate. 6 Itsas 4 L Requirement (, Subsection 3.0 specifies detailed requirements for packing items for each level de6ned in Subsection -l ll 2.7.

Response

BO&E has replaced Section 3.0 with the following: 1. Packaging forShipment to BO&E Personnel of BG&lfs NED or NSSD shall ensure that procurement documents for. Basic y Component and Ca.mnercial Grade item purchases either indicate that the normal methods of j packaging and ab',pment used by industry in general are acceptable for the items being 7 l procured or sprufy the level of protection assigned to the item and the requirement that the vendor conform to applicable requirements for items in that classification deGned in Regulatory Guide 1.38, Rev. 2 - March 1977. 2. 'Ihe 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 BG&E, provided that the item is stored in an area 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 shall identify if any of the reqmrements of Section 6.4.2 of ANSI N45.2.2 1972 apply. Reason 1. 'Ihis substitution will ensure that the item will receive adequate protection during shipment - and storage, thus eliminating 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. Page 44 of 59

~ p. b QUAIII'Y ASSURANCE POLICY. Revision 40 ' l 1.r lism 5 i Requirement . Section 4.0 defines shipping requirements related to the protection levels assigned to items.

Response

e BG&E has replaced Section 4.0with the following: l 1. Shipping to Baltimore Gas and Electric i BGAE wi!! mvoke the requirements for shipping specified in Section 4.0 of ANSI N45.2.2 - : 1972 on Gasic Component purchases only when NED or PSSD per(onnel have specified in procurement documents that the atem shall be packaged in conformance with ANSI N45.2.2, 4. Section 3.8. BG&E will not invoke the requirements of ANSI N45.2.2 -(1972, Smetion 4.0, on Commercial- .I Grade item purchases. i 2. [hipxing from Baltimore Gas and Electric j ' Items shipped from BO.E need not conform to any of the requirements of ANSI N45.2.2, but. { the orgamzation 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 acceptable,- ti.ey have already determined that the supplier's methods of shipping are adequate. As items are -' i shipped from BG&E only for repair, the detailed requimments specified in Section 4.0 of ANSI N45.2.2 are not necessary, lita.f i Enquirement 3 Subsection 6.4 gives detailed requirements for care of items in storage, according to the protection l levels assigned to theitems. (

Response

BG&E does not require items to be stored in the packing used for shipment if the storage level in 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 personnel during the procurement process. If an item is taken from one storage area to another, however, the pemons who move it are responsible for ensuring, as applicable, that additional packing is supplied to give adequate protection during l transportatKm. i L l J i i i i l i Page 45 of 59 j J l

w QUALIIY ASSURANCE POLICY Revision 40 4 Reason The degree of protection given an item during storage should be tailored to the importance of the a item to, safety and the probability of deterioration durmg storage; to base storage requirements purely on the categories in Subsection 2.7 of ANSI N45.2.2 - N72 is impractical. BG&E requires NED or NSSD pemonnel to specify requirements more closely related to the actual function of items and to storage conditions. Hem 7 Requirement Subsection 7.3.3 requires compliance with a series of ANSI documents.

Response

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 be compatible with documents referred to in these documents. Reason 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 N45.2.3 1973 Item 1 Reauirement Subsection 2.1 outlines housekeeping cleanliness requirements for five designated zones. Resnonse BG&E has established three classes for cleanliness requirements. There is no class equivalent to the ANSI Zone 1. Requirements of ANSI Zones 4 and 5 have been consolidated into BG&E's class 3. Reason 1.. ANSI Zone 1-level of cleanliness applies to new construction activities. - es.s. 2. Where required, smoking rest rictions are posted for BG&E's class 3 areas. Ite m 3 Reunuuent Subsection 2.1 requires for Zones I, II, and III, that a written record of the entry and exit of all personnel and material shall be established and maintained. Page 46of 59 i

q l . QUAIIIY ASSURANCE POLICY Revision 40

Response

l l BG&E has established the following methods for personnel and material accountability: 1. Written accountability.1 2.~ Where possible tethering of tools and materials to permanent plant structures or persons. l [ 3. Post-maintenance closcout inspections. l Reason DGAE's'three metinis of accountability offer the same level of control as that required by the.. standard. .i ANSI N45.2.6 - 1978 i i item ! Reauirement Subsection 1.2 states in part, he requirements of this standard apply to personnel who perform insgrction,

i examination, and tests during fabrication prior to and during receipt ofitems at the y

construction site, during construction, during preoperational and startup testing, and. during operational phases of nuclear power plants.- l Resnonse-A ~ \\ Personnel of BGAE's Quality Assurance organizations within the NOAD who pedorm inspections, examinations, and tests at the plant site during operational phases of the nuclear power plant are. required to be quahfied in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6).- All other BG&E personnel who perform inspection, examination, and testing functions associated with normal operations of the plant are qualified either to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1 - 1971. l Beason-A i i 1. . %c individuals who perform inspection, examination, and testing functions associated with normal operation of the plant, such as maintenance and certain technical reviews, are normally qualified to ANSINIR 1 - 1971. 2. Some testing activities conducted during normal operation of the plant, such as suncillance 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. l 'i Page 47 of 59 i

~ ' 'l i - QUALITY ASSURANCE POLICY Revision 40 -i Respame.B . BG&E does not always require vendor personnel performing inspection or test activities to comply l .with the requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) but evaluates the i need for invoking Regulatory Guide 1.58 (which endorses ANSI N45.2.6) on the vendor during the j review of procurement documents. The requirements are not applied to procurement classified as Commercial Grade. Reason-B BG&E's position is as follows: 1. For replacement items purchased as Commercial Orade Items, the purchaser may not impose nuclest unique requirements on the vendor. Additionally, items may be manufactured before ,l placement of the purchase order and the vendor may not be required.to maintain records of the performance ofinspections or tests. .l 2. For Basic Component Purchases, the qualification requirements for inspection,' examination, j and test personnel are determined by: } a. Item status (new or replacement). b. Complexity and importance ofitem.- Manufacturer's OA program approval level (Appendix B, ANSI N45.2, etc.). c. Rceponse-C l BG&E does not requ:re personnel 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 endorses ANSI N45.2.6). l.i Reason-C inspections, examinations, or tests that are repetitious or oflimited scope need not be performed by i individuals qualified to the requirements of Regulator l provided that they receive instruction in the following: y Guide 1.58 (which endorses A 1. Activities to be verified. 2. Acceptance criteria. 3. Method of documenting results. 4. Method of reporting deficiencies. } j 'Ihe 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. t i l I i Page 48 of 59

- QUALITY ASSURANCE POLICY Revision 40 l Resnonse.D When it is necessary to monitor the activities 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 Oukie 1.58 (which endorses ANSI N45.2.6) and ANSI N45 ? 73 establish training requirements suitable for monitoring vendor activities. ite m 2 Requirement l Table 1 speciGes that level III personnel shall be capable of qualifying Level III personnel.

Response

When there is only one Level III position or when a new level III position is created, BG&E. personnel with the title General Supervisor, or higher, qualify Level III personnel. Reason 1 BG&E prsonnel in these grades are capable of certifying Ixvel III personnel without being trained as I.cve IIIinspectors. NOTE: Regulatory Guide 1.58 (which endorses ANSI N45.2.6-1978) states m 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, II, and III personnel, the candidate should be a high school graduate or have earned 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 personnel 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. Page 49 of 59

e. 1 QUALITY ASSURANCE POIJCY 1 Revision 40 ? i ANSIN4L23-IM6 q s Item 1 'RequirementL [ Section 4.0 titled " Receipt" gives instructions for receipt controls. ' i

Response

k BGAE applies these requirements'only to the receipt of records by the Plant History File. t EGagon 1i Most reconis received by such organi=tions as Receiving Inspection, F=pa--4g, etc., are not i shipped in a manner that makes these requirements applicable. Dese requirements are applicable,; j however, when the records are finally turned over to the Plant History File. t i llantl 4i Bauirement I Subsection 5.6.1 reads as follows, " Design and construction _ of a single recorti storage facility shall ; 'f meet the following criteria:" Items a) and b) of the subsection state that: t "a) Reinforced concrete, concrete block, masonry, or equal construction." i "b). A floor and roof with drainage control. If a floor drain is provided, a check valve (or equal) shallbeincluded." ~ 1 1 Response / Reason l item a - De intent of this requirement is both structural integrity and fire resistance. His vault is entirely enveloped by a structurally sound, fire resistive building. Second, the vault rests on a reinforced slab - on grade and its walls extend fully to the underside of the structural deck. Third, tbc walls of the vau t are constructed of gypsum wallboard on metal studs per Underwriters Laboratory Test Number U412, assuring the equivalent of 2 hour fire resistive construction.-' This is equal construction ~to concrete block in terms of fire protection. The walls carry n equivalent structural integrity to that needed of concrete blockj structural load; hence, they) ' (See footnote following page)."-4 ' Response / Reason S Item b i Again, the vault is con or need for floor drain. pined within an environmentally protected building. As such, it has no roo; (See footnote following page). I i i ) i Page 50 of 59

m QUALITY ASSURANCE POLICY Revision 40 f Item 3 Essuirement Subsection 5.6 allows only the dual facility defined in Subsection 5.6.2 as an alte: native to the single [ facility defined in Subsection 5.6.1.

Response

BG&E allows the following alternative storage requirements for organizations other than the f Records Management Unit: Organizations that originate records and do not transfer them to the Records Management Unit within 30 days 'of completion shall establish one of the following three controls as' i alternatives to the requirements specified for tbc Records Management Unit: 1. Duplicate Storage Either A or B. l A. Within 30 days of completion of a record, a duplicate record file shall be established. This activity shall be controlled by pacedures which provide for the following: 1. Assignment of responsibility for records. 2. Description of storage area. 3. Description of filing system. 4. An index of the filing system. ) 5. Rules governing access to and control of files. 6. M'ethods for maintaining control of and accountability for records removed from the file. 7. Method for filing supplemental information and disposing of superseded or i obsolete records. I 8. Method for preselving records to prevent deterioration. 9. Method for maintaining specially processed records that are sensitive to light, pressure, or temperature. 'Dese responses have been forwarded to the NRC by the BG&E letter dated 02/11/83 from Robert G. Nichols, Sr. Facilities Project Administrator, Real Estate and Office Services Department, to Terry L Harpster, Chief QA Branch, Division of OA, Safeguards and Inspection Programs, IE, USNRC. Dese responses have also been accepted by the NRC in their letter dated 04/22/83 from Walter P. Haass, Deputy Chief, QA Branch, Division of Quality Assurance, Safeguard {, afd Inspections Programs, Office of Inspection and j Enforcement. l Page 51 of 59

v. QUALITY ASSURANCE POLICY Revision 40 i

10. Trafsfer of duplicates to the Records Management Unit within twg yeirs of completion of records.

B. Make arrangements with(at'deast one other department that receives a copy of each 'i docueent to subject this o ther copy to the controls specified abgve. 2. Fire-resistant Building Storage Records shall be stormd if steel cabinets located in a fire-resistant building or a ngn-combustible building with a fire suppression system. The procedural controls defined for duplicate storage shall be applied. I 3. Non-fire-resistant Building Storage Within non-fire-resistant facilities, records shall be stored in UL one-hour-minimum fire-rated storage cabincts and be subject to the procedural controls defined for duplicate storage. BG&E defines a Fire-resistant Building as follows: A facility constructed to resist the initiation or spreading of fire; non-combustible - and/or fire-suppressive materials used; building certified as fire-resistant by the Risk Management Unit of BG&E's Corporate Finance Group. Reason i Although these ahernatives are compatible with standard methods of handling records, they do not i materially decrease the level of protection afforded to the records. ANSI N45.2.23 - 1978 [ l!ER.1 Reauirement l 2.3 Qualification oflead Auditors - tion 2.3.1 requires prospective Lead Auditors to obtain a minimum of ten credits under-the woring system defm' ed in paragraphs 2.3.1.1-2.3.1.4. Resoonse BG&E has revised the scoring system as follows: Education and Experience The prospective Lead Auditor shall have accumulated a minimum of ten credits under the following scoring system: 1.0 Education (4 credits maximum) Page 52 of 59

m 1 if .l !OUALITY ASSURANCE POLICY d Revision 40 - J 1.1-For the Associate degree for an accredited institution, score one credit, if the. ) degree is in engineerug, physical sciences, mat -+ or quality assurance, h score two credits. Or, for the Bachelor de f di i i i . score two credits; if the degree is in==i== gree rom an accre ted nst tut on, ing, physical sciences, matbematics, or quality assurance, score three credits. ~ l j 1.2 - For the Master degree in engineenng, physical sciences, business management, or - quality assurance from an' accredited institution, score one credit. i 1.3. For the successful completion of part of the required curriculum for an Associate,. l Bachelor, or Master degree, score a corresponding percentage of.the. credits .i speci6ed above for the degree.. i 1.4 For the successful completion of Navy Nuclear Training, its equivalent in another i armed service, or the training required for becoming a licensed operator in a commercial nuclear power plant, score two credits. ~ ~ 'l ..2.0 Experience (9 credits maximum) i 2.1 Technical Experience (5 credits maximum) l I For experience in engineering, manufacturing, construction, operation, or i maintenance, score one credit for each full year. l li 2.2 NuclearLe hce i ee If two yean of technical experience have been in the nuclear Geld, score one additional credit. i ' 2.3 Quality Assurance Experience 't If two or more yean of the technical experience have been in quality assurance or quality control, score two additional credits. Persons whose work activities are 1 controlled by the OA Program but who are not full-time members of the OA 4 organization may be awarded half the credits that would be given to a person with l specific quality assurance experience. 2.4 Audit Expenence 1 J If two or more years of the technical experience have been in auditing, score one additionalcredit. y 2.5 Supplemental Experience 1 Persons who have a proportion of the experience specified in 2.1-2.4 may be 1 awarded a corresponding percentage of the credits specified.' l s 2.6 Time exclusively spent in training does not apply as credit toward experience 'l requirements forlead auditors. 1 3.0 Training (2 credits maximum) i 1 Persons who have successfully completed the training requirements of ANSI N45.2.23 may be given two credits. j V' i Page 53 of 59 .i l

n p y 1 ^ h .QUAUTY ASSURANCE POUCY. Revision 40 : y ~ 4.0. ~ Rights of Management (2 credits maximum) ' UL The Manager-NOAD,1 may grant ' additional credits for other~ performance facton i ? . applicabic to auditing as follows: ~ j f 4.1 ; For certi6 cation of competence in engineering or science related to nuclear ~ power plants, or in quality assurance specialties, issued and approved by a State'. ' Agency or National Professional or Technical Society, score two credits. ] i 4.2 For nuclear experience in excess of 2 yean, score one credit for 'ench two years - ll experience. 1 4.3 For practical experience that can be related to power plants, in excess of 5 years, score one credit for each two yean of experience.' j Esanon A BG&E is in agreement with the basic purpose of ANSI N45.2.23-that is, to establish minimum 3 educational or emperience requirements for Lead Auditors. We think, however, that the system of l 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 capabilities of persons selected. We calculated-the credit score of 11 of our present lead Auditors at the time they were appointed ' { Lead Auditors. Six had completed Navy Nuclear Training and spent several years in the Navy

l Nuclear Program. Four of these scored only 8 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. t i One of our auditors, with neither nuclear nor power plant experience, had a credit score of 12-l because he hekt a Bachelor's degree in engineering and was a professional engineer with over 5 years - design experience, i i 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 ' j experience of prospective Lead Auditor candidates. t We consider the flaw in the current system to be the emphasis on educational requirements' that will .[ allow a person with a Master's degree and no nuclear or power plant experience to become a Lead -l Auditor, but will exclude a person who has no degree, even though he may have 20 years' experience i in operating or maintaining nuclear or power plant systems. 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 unsuitable candidates to meet the qualification requirements while excluding some acceptable candidates. -l -i For these reasons, we think that the supervision of prospective Audit Team T caders should be given i more flexibility in determining whether, for a particular individual,' educational or professional' qualifications are more significant and valuable than past experience. lj i -i I.; c !'l Page 54 of 59 j

g, 4 QUAIJTY ASSURANCE POllCY ~ Revision 40 r 6 ne present credit system, while recognizing the Associate degree, gives no credit for completion of L s 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 credit as a pemon who has an Associate degree Guin an accredited institution in engineering,-physical sciences, mathematics, or quality assuran,e.. ~ ~' e . The points now awarded for education are related to the efect 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 degree. Penons who have completed part of a degree course should receive a percentage of the credits allowed for that course.

He requirements for training pf=I in ANSI N45.2.23, paragraph 23.2,'would seem to ensure. ~ that prospective lead Auditors will meet the requirements of paragraph 23.1.4 dealing with the ' rights of management. We think, therefore, that all prospective Lead Auditors should qualify for these two credits. Similarly, the present system recogniacs the efect that working in a QA Program will have on the ability of a person to comprehend regulations and technical requirements. Persons who are not assigned u full-time members of the QA Organization, however, receive similar exposure if they perform activities controlled by a QA Program. We therefore allow such persons half the credits. specified for quality assurance experience. IREnl Requirement 33. Requalification Lead Auditors who fail to maintain their proGeiency for a period of two years or more shall be required to requalify. Requalification shall include retraining in accordance with the' requirements of paragraph 233, reexamination in accordance.with paragraph 23.5, and participation as an Auditor in at least one nuclear quality assurance audit. Renamese BG&E requalifies Lead Auditors on the basis of the satisfactory performance of one audit, as observed by a qualified lead Auditor. Ball &QA De purpose of the training specified in paragraph 233 of the Standard is to ensure that candidates understand the fundamentals of auditing and the requirements for activities to be audited. He 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 QA Programs and program auditing. BO&E considers that the satisfactory performance of an audit under the observation and guidance of a qualified 1. cad Auditor should ensure that persons with lapsed certification will review and understand the pertinent documents. 1 i Page55 of 59 }

c~ QUALITY ASSURANCE POLICY ~ Revision 40 ? ANSI N101.4-1972 Receiressent Section 1.2 specifies applicability requirements for the Standani. Respons._e BO&E requires that only activities performed inside containment structures and related to protective l coatings applied to ferritic steels, aluminum, stainicss steel, zinc-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 containment 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 services.

Response

BO&E has two approaches for safety-related and designated non safety related procurement as described in Sections, IB.4 and 1B.7. Controls established for Basic Component Purchases correspond to the requirements 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. - 4 t Page 56 of 59

~ }i, .t. f F ( q$' 37g;n, ,m l V y ' OUAUTY ASSURANCEPOUCY-3 Revision 49 40 ATTACHMENTA-1 l 1 BASES FOR QA POIJCYREVISIONS (1) l E Entry PRF-Q i A No.: Bases for Revision (s) ~ 1. 771 Procedure Upgrade Action Plan (PUAP). mar L. B. D - H 1med.,120-89.' - 2.. 783-10 CPR Part 21 reauir===a=*= ~ d 1 ii! 3. 797' NRC famaaenian '#89-1&B9-17 (i m*aar from R. E. naa*aa to R. P. Haihal~ dated July 13.1989.1 I I m a 1. 824 NRC netter from M. W.14ad= to G. C. Creel d=*-A March 13.1990. This j j lattar maaroved a one *i=== a-anaian to the neriadie inview raa== Ira-ate for j u orne=d== es achad ihd to be uneradad by the Pracad i es Unerade Praiaet - .? l 's M..__."* m ggg dianantimanad and g_ _ _-J by PRF4 954r d r 5. 844 Pra-==t Pronram Praiart unarada Perfor== ace i=- re. cc==r Plan - l (PIP) A-*ian Plan #5.3.1 and OAU Ai di* Piadia 87-13-01 j f 6. 844 1B.15 and 1B.16 revised to cleariv a=*W: ' nronram maali.=t-:!;v

==d. l ~ q controls. ca-ia-at terminalonv. cig r =ta- ' responsibilitics and_foramed anorn=ch towards develoni-- mad I----l-= +- an iana-ratad ~ u===-nt Svstem. I 7. 891 PIP Action Plan 5.3.1 Follow-On Activitv. i will nermit ' 8. 894 IB.15 and 1B.16 revised - to clarifv - reauir- =

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which L .I imnkmentatinn of the baar Mannaamant Su=ta= - PIP ita= 4.10.0. I 9. 854/907 G. C. Cree? letter to the NRC d=*ad 7/2&91 which di=c -M madifie=* ions to. - l .t and acceotance of. chane to the OA Policy involvine OA' comrliance l t i reviews of OAPs and Directives. 10. 83,5_ G. C. Creel lattar to the NRC d=*ad 10/U90 diac- :aa ta=norary cha=== not. affectine " Approved Procedure Infaat" and the relieving of the -t Admini=*rativ 'Nrden on Shift Supervisors Page57 of 59 l i 2 -A

i; .QUALTTY ASSURANCE POUCY

r-Revision 4040 1

l ATTACHMENTA-3 BASES FOR QA POIJCY REVISIONS (1). c. Entry PRF-Q i No,. . No. h -- for Reviaiants) - 11. 887 Audit Findian No 9026-01 (Imala-a*=*3aa of Surv :11-- Requirements). I 12. 954 G. C. Creel la**ar to the NRC dated 7/3/91 di=caaiia aine the one *i==a i

• -aarary chanae to the neriadic ratw interval assieved in Basis (4) above.

-l 13. 957 PIP Action Plan follow-on activity (5.3.11. 14. 953 PIP Action Plan 4.1 and NUREG-0737 (TMI Actinn Plan Rem.h-r-ts) Item I.C.5. " Procedure for Faadb=ek of Oper=*ine T--- ~= v to Pl==* Staff" i 15. 990 OAU Survei11=aca 5-92-28 "Interf=ce Between Forni,, u....em,og Denartmant and Ni_i_ cia =r Fnarev Division on Pic k?L; at C:. ert Oin

• N Rece-aad=*ian 4.2.

-l QA And3* P=---- -h ion 92-04-R03 (ISFSI naaratin=at ah-1 l 16. 998 t L -i i F i i l i l i -) Page 58 of 59 I 'I

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