ML20081A733
| ML20081A733 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/08/1994 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20081A726 | List: |
| References | |
| NUDOCS 9503150267 | |
| Download: ML20081A733 (59) | |
Text
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QUALTIY ASSURANCE POLICY Revision 41 i
BALTIMORE GAS AND ELECTRIC COMPANY i
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Quality Assurance Policy for the Calvert Cliffs Nuclear Power Plant (Appendix ID of tic Calvert Cliffs I
Updated Final Safety Analysis Report) j i
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Date 7/8 99 APPmved A
/u
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(1)
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R. E. Dese6a Vice President Nuclear DerEy Division i
Page 1 of 59 9503150267 950309 PDR ADDCK 05000317 P
QUALITY ASSURANCE POLICY Revision 41 TABLE OF CONTENTS APPENDIX IB OUALITY ASSURANCE PROGRAM FOR THE OPERATIONS PHASE i
1 Section Eage i
1B.1 ORGANIZATION AND RESPONSIBILITIES.
......5 I B.2 QUALITY ASSURANCE PROGRAM...
.14 IB.3 DESIGN CONTROL.
. 19 18.4 PROCUREMENT DOCUMENT CONTROL (5)..
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18.5 TNSTRUCTIONS, PROCEDURES, AND DRAWINGS...................
. 24 iB.6 DOCUMENT CONTROL...,.
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1 B.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (5)..
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IB.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS (5).
.29 1B.9 CONTROL OF SPECIAL PROCESSES..
. 30 1B.10 INSPECTION..
.................32 1B.11 TEST CONTROL...
.34 t
iB.23 CONTROL OF MEASURING AND TEST EQUIPMENT....
.35 1B.13 HANDLING, STORAGE, AND SHIPPING....
...... 36 18.14 INSPECTION, TEST, AND OPERATING STATUS..
.36 IB.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS (6).
.37 i
i 1B.16 CORRECTIVE ACTION (6)..
.37 1B.17 QUALITY ASSURANCE RECORDS.
.38 IB.18 AUDITS...
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i QUALITY ASSURANCE POLICY Revision 41 i
LIST OF TABLFE 1
Table No, Pace iB-1 BALTIMORE OAS AND ELECTRIC COMPANY'S POSITION ON..
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GUIDANCE CONTAINED IN ANSI STANDARDS i
k LIST OF ATTACHMEhrrS Ietter A
BASES FOR QA POLICY REVISIONS (1,
,,, 57 l
Ficitre No.
i 1B 1 BALTIMORE GAS AND ELECTRIC COMPANY CORPORATE ORGANIZATION.......
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QUALITY ASSURANCE POLICY Revision 41 1
LIST OF EFFECTIVE PAGES Latest revision number is listed for pages revised after resision 38.
Page Last Revision Page Last Revision Page Last Revision 1
24 47 41 1
2 25 41 4g 4g 3
26 41 49 41 4
41 27 41 50 41 l
5 28 41 51 41 6
41 29 41 52 41 7
30 41 53 41 8
Il 31 41 54 41 l
9 32 41 55 41 i
10 41 33 41 56 41 3
1I 41 34 41 57 12 41 35 41 58 13 41 36 59 14 41 37 41 15 41 38 41 16 41 39 41 17 41 40 41 18 41 41 19 41 42 41 20 41 43 41 21 41 44 41 22 41 45 41 23 41 46 41 i
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QUALITY ASSURANCE POLICY Revision 41 18.1 ORGANIZATION AND RESPONSIBILITIES All levels of organization have defuute and unique responsibilities in assuring safe, economical, and reliable operation of Calvert Cliffs Nuclear Power Plant (CCNPP). Top level management is responsible for ensuring that policies are established, resources are authorized, management philosophy and commitments are communicated to lower levels of the organization, independent verification of management controls are performed, results are reviewed, and appropriate actions taken when necessary.
Middle level management is responsible for translating management policies, philosophy, commitments, and goals; applicable federal, state, and local rules and regulations, Operating Licenses, Technical Specifications (TS), and the Updated Final Safety Analysis Report (UFS AR) into control programs for activities such as design, procterement, construction, testing, operation, refueling, maintenance, repair, modification, training, plant security, fire protection, records, independent verification, and corrective action. Middle level management is also responsible for defining, measuring, and modifying the overall effectiveness of control programs; takmg appropriate action on the results; and keeping top management informed of the status, adequacy, and effectiveness of control programs, and matters which could have an impact on nuclear safety.
First line craft and non-craft supervisors are individually responsible for ensuring that appropriate procedures are understood and used to implement each activity described in the control programs; identifying problems, seeking solutions, verifying implementation of solutions; investigating root causes of problems and taking preventive actions; ensuring that conditions adverse to plant and personnel safety are promptly. identified, reported, and corrected; detecting trends which may not be apparent to a day-to-dab observer, reconunending generic solutions for adverse trends to management,' and taking appropriat6 8
actions, to achieve desired results; ensuring that employces assigned to do a job are properly qualified through appropriate training and experience; have properly qualified procedures, tools, equipment,'and parts to do the job, and, ensuting that independent inspections of work are conducted in accordance'with -
preestablished requirements. First line non-craft supervisors are responsible to ensure that procedures are 7
written, reviewed, and approved; first line craft supervisors may not have this responsibility. Non-supervisory personnel acting asjob 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 thejob.
Adherence to procedures is vital to the safe and reliable operation of the Calvert Cliffs Nuclear Power' Plant. Personnel are responsible for adhering to established procedures, interpreting them conservatively in case of doubt, and recommending changes when necessary. Procedures with the potential to affect nuclear or personnel safety shall be strictly adherrd 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 doctanented. (1) j l
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QUALITY ASSURANCE POLICY -
Revision 41 Ogrp_onte Ornanization and Soecific Responsibilities
'lho Corporate Organization Chart of the Baltimore Oas and Electric Company (BGE) is shown in Figure l
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IB-1. Persons responsible for the principal elements of the Company's Quality Assurance (QA) Program j
are as follows: (1)
Chairman of the Board President and Chief Operating Officer Senior Vice President-Generation Vice President-Nuclear Energy Division (NED)
Plant General Manager-Calvert Cliffs Nuclear Power Plant Department (CCNPPD)'
Manager-Nuclear Engineering Department (NED)
Manager-Nuclear Quality Assurance Department (NQAD) -
Manager-Nuclear Safety & Planning Depanment (NSPD)
Manager-Nuclear Support Services Department (NSSD)
.s-Manager-Nuclear Outage & Project Management Department (NOPMD)
In addition to these individuals, the Vice Presidents of Corporate Affair's (CA), Fossil Energy Division (FED), Electric Interconnection and Transmission Division (EITD), General Services Division (GSD), and the Management Services Division (MSD), as well as the Managers of the System Operation and Maintenance Departnient - (SOMD), Purchasing & Materials Management Department (PMMD),
Infonnation Systems Department (ISD), Facilities and Flcet Services Department (FSSD), Fossil l Engineering & Maintenance Department (FEMD), Fossil Support Services Department (FSSD),~ and the'
. Safety and Medical Services Department (SMSD) are assigned support responsibilities. (1) The above'-
Managers constitute the Nuclear Program Managers who are assigned responsibilities within the QA Program.
Other departments performing any maintenancc/ modification activities at CCNPP are responsible for performing these activities in accordance with applicable QA Program requirements. This can be accornplished by either developing their own QA Program procedures or by working to the QA Program through appropriate Nuclear Energy Division personnel using CCNPP procedures. (15)
Also, two advisory groups perfonn quality-related functions for plant operations. These are the Plant Operations and Safety Review Committee (POSRC) and the Off-Site Safety Review Committee (OSSRC) whose makeup and responsibilities are described in the TSs for CCNPP.
Chairman of the Board. PresidentatuLChief Oneratina Officer. and Senior Vice President-Generation BGE's QA Program for nuclear power plants is established under the authority of the Chairman of the l Board, President and Chief Operating Officer, and Senior Vice President-Generation, who are responsible for establishing the overall QA Policy. They assign project responsibilities to the organizations shown in heavy-lined boxes in Figure 1B-1. (1)
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QUALTIY ASSURANCE POLICY Revision 41
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& Chairman of the Board assigns authority through the President and Chief Operating Officer and Senior.
Vice PremiAcet Genemtion to the Vice President-Nuclear Energy Division. Primary responsibilities for developing, implementing, and mamtaining the QA Program are assigned to Department Mana8ers by the Vice Presidest-Nuclear Energy Divisum. Managers delegate their authority as required to implement their responsibilities. (1)
Quahty assurance matters that cannot be resolyw by the Managers or Vice Presidents are brought to the attention of the Senior Vice President-Generation, President and Chief Operating Officer, or the Chairman cf the Board for resolution.
yice Praeidant-Nur ta=r Raaenv Division
& Vice President-Nuclear Energy Division, is responsibic to the Senior Vice President-Generation for ensuring that the QA Program is developed and imple== =*ad. 'Ihr authority to develop QA Program Documents is assigned to designated Nuclear Program Managers The Vice President-Nuclear Energy Division, is also responsible for ensuring that the requirements of the QA Program that relate to the design, operation, and maintenance of the plant are implemented. ' Ibis responsibility is carried out through Nuclear Program Managers Marmacr Nuclear Da=13tv ^=="r==<-a Denartment The Manager-NQAD, is msponsible for assuring an repropriate QA Program.is established and effectively executed for CCNPP. He is responsible for auditing, qualitywerificaten,; and the vendor evaluation functions for CCNPP. These responsibilities include:
.j 1.
Developing, and revising the QA Policy.
2.
Ensuring that QA Compliance myiews are completed for program acceptability of Control Programs (QAPs and Directives) and their revisions before they are approved. (9) 3.
T& king necessary corrective action, which can include the stoppage of work when manufacturing, maintenance, or modification activities fail to comply with appthved specifications, plans, or procedures. Such corrective action is arranged through appropriate channels and is delegated when neccesary. When a unit is operating, the Manager-NQAD, may recommand to the Plant General Manager that the plant be shut down. 'Ihe Plant General Manager has the final responsibility for the overall evaluation of all aspects and implications of shutting down an operating unit.
NQAD personnel who report to the Manager-NQAD, are independent of departments, sections, and employees responsible for performing specific activities, and have sufficient authority and orgamzational facekxn to identify quality problems; to " itiate, recommend, or provide solutions m
through designated channels; and to verify implementation of solutions. Non-NQAD personnel who are authorized to perform activities under NQAD programs are matrixed to NQAD for the performance of such activities, and possess similar organizational freedom and indapeadae from the activities.
BGE has established that the Manager-NQAD, should have at least six years of responsible experience in engmeenng, design, manufacturing, construction, quality assurance, or power plant operation, as well as a knowledge of regulations and standards related to nuclear power plants.
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a QUALITY ASSURANCE POLICY He organization of NQAD is shown in' Chapter 12 of the UFSAR. The Manager-NQAD, delegates the following responsibilities for accomplishing required quality assurance activities:
Pinnning and scheduling evaluations of vendor quality assurance programs.
. Reviewing proposed changes to QA Program documents for co' mpliance with regulations and a
licensing documents.
Planning, scheduling, and perfonning internal audits and evaluations of on-site and off-site functions performed under the nuclear QA Program.
Supporting maintenance and operations activitics by performing inspections and surveillances, or by providing oversight of other department' personnel as they perform inspections and surveillances. (11)
Plant GencIa1 Manaer-Calvert Cliffs Npelear Power plant Deoartment ne Plant General Manager is responsible for operations, chemistry, radiation safety, maintenance, and systems and performance engineering activities at CCNPP. He must ensure that these L,
activities are conducted in accordance with the plant operating license and TSs, the UFSAR, the l
QA Program, and procedures. He Plant General Manager fulfdis the position and requirements of the Plant Manager, as dermed in ANSI N18.1 (1971). He, or one of his designated principal alternates, shall have acquired the experience and training normally required for examination forp a
senior reactor operator's license.
The organization of CCNpPD is shown in Chapter 12 of the UFSAR. The Plant General Manager, delegates responsibilities for accomplishing required activities as follows 1.
The Superintendent-Nuclear Operations (S-NO) is responsible to the Plant General renager, for the operation of the plant, including the general supervision of all shift operating personnel and prioritization of maintenance activities to support operations.
This responsibility covers the safety of plant personnel and equipment, all fuel hanEng and refueling activities, and adherence to applicable license and regulatory requirements. The" Superintendent-Nuclear Operations fulfills the position and requirements of the Operations l Manager as dermed in ANSI N18.1 (1971) with the exception :aken in Table IB.I.
The Superintendent-Nuclear Operations delegates primary management responsibility to the Shift Supervisor on duty, via the General Supervisor-Nuclear Plant Operations (GS-NPO) to ensure the safe operation of the plant under all conditions. The Shift Supersisor maintains the broadest possible perspective on operational conditions that affect the safety of the plant.
As the senior member of plant management on each shift, he exercises the command authority of his position to take whatever steps he deems necessary during emergency situations to place and maintain in a safe configuration any unit that may be affected.
2.
The Superintendent-Nuclear Maintenance (S-NM) is responsible to the Plant General Manager for managing and directing activities of the Nuc1 car Maintenance Section to provide high quality maintenance programs, plans and schedules, and qualified personnel to perform maintenance functions necessary to assure the safe, reliable, and economic operation of the plant to generate power within applicable laws, standards, codes, and regulatory requirements.
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I QUALITY ASSURANCE POLICY Revision 41 l-The General Supervisor-Electrical and Controls (GS-E&C), is responsible to the a.
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Superintendent-Nuclear Maintenance, for.the conduct of electrical and instrument
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maintenance, repair, and modi 6 cations needed to keep the plant and its facilities, 3
systems, and equipment in safe and efficient working condition. He is responsible for planning and supervising or controlling the electrical and instrument maintenance activities conducted by plant mamtenance personnel, and for ensuring that work is performed in accordance with :-pplicable Codes and Standards and that required l
maintenance records are developed and kept. He is responsible for controlling tools l
and equipment used for electrical and mstrument maintenance, repair and modifications activities.
b.
.1he General Supervisor-Mcchanical Maintenance (OS-MM), is resporsible to the Superintendent-Nuclear Maintenance, for the conduct of mechanical maintenane repair, and modifications needed to keep the plant and its facilities, systems, and l
l equipment in safe and efficient working condition. He is responsible for planning and supervising or controlling the mechanical maintenance activitics conducted by plant maintenance personnel, and for ensuring that work is performed in accordance with applicable Codes and Standards and that required maintenance records are developed and kept. He is responsible for controlling tools and equipment used for mechanical maintenance, repair, and modifications activities.
3.
The Superintendent-Technical Support (S-TS) is responsible to the Plant General Manager for.mannging and directing the activities of the Technical Support Section to provide systems, and performanca engineering, surveillance testing administration, chemistry and radiation i
safety support necessary to assure the safe, reliable, economic operation of the plant, inservice inspection, and to establish approp:iate standards for the fire protection program.
The S-TS is also responsible.to the Plant General Manager for overall direction and coordination of activities to ensure compliance with the Radiological Effluent Technical Specifications. This responsibility is carried out through the General Supervisor-Chemistry with support from the Director-Environmental Propams and the Manager-FSSD.
The General Supervisor-Chendstry (GS-C) is responsible to the Superintendent -
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Technical Support for the chemistry and radio-chemistry of the primary and secondary systems and for maintainmg radioactive effluents within specified limits.
Additionally, the GS-C provides program management oversight of the Radiolegical Emironmental Monitoring Program to ensure compliance with the Radiological Effluent Technical Specifications.
b.
The General Supervisor-Radiation Safety (GS-RS) under the nuclear QA Program, is responsible to the Superintendent-Technical Support for:
Ensuring the radiation protection of personnel at CCNPP, Complying with radioactive material transport regulations.
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The: General Supcivisor-Plant Engmeering (OS-PE), is responsible. to ' the.
.i Supenaeandans-Technical ' Suppon for-provuhng. field ensmeenne and techmcal
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. evaluation of plant systems and to evaluase and coorthnate resolution of system and
- i component problems with operations, remiadanmaae, and engmeerug personnel for' the j
Calvert Cliffs Nuclear Power Plant.~ AMeiaamily, the OS-PE is responsible to the S-
, TS for providing plant reliabihty/avadability testing and evabiarum, plant performance j
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improvement, and administration of the SunJ" x Test Program.~
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The Principal KaM-Nucicer' inspection ~ Services is ' responsible ?. to the:
Sugh.; Technical Support for providing macrvice inspection services for the 4 Calvert Clifs Nuclear Power Plant.-
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A The Manager-NED, as responsible for directing the efforts of personnel and' providag resources 1
necessary to support design, modification and enginewing metmtics covered by the QA Program
'l for CCNPP. These activities include nuclear, snachanic=I, civil, retsability, mstrument and -
controls, and electrical engmeering; nuclear. fuel management; configuration management; life 1
cycle management, plant design support; fire protectaan program development; and engineering j
planning
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1 lhe orgaruzation of NED as shown in Chapter 12 of the UFSAR. The Manager-NED deiegates
' i responsibilities for accomplishing the following activitics-Providing conceptual and detailed engineenng, design and drawns, fine protection program
t deva - =Odata base configuration control, and documentation and maintenance of plant -
design bases for the power and contml systems for the Calven Cliffs Nuclear Power Plant.
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Directag and performing safety evaluations, preparation and review of anclear safety accident and transiesa analysis, fuel management, nuclear engmeenas related to core physics,- _
reactor engmeenng, external fuel cycle n
=-+=1, reliability cogmocrmg and development.
l and integration.of. programs necessary. to operate up to and beyond the current licensed-l lifetune for the Calvert Cliffs Nuclear Power Plant _
j Providing plant design support, and engineermg planmag and scheduling for the power and L i
control systems for the Calvert Cliffs Nuclear Power Plant.
y.n..ar.Nud-Oi*aac =ad Prht M
-- -- =e Daa====t The Manager-NOPMD is responsible for directing the efforts of wh and provuhng resources :
i i ---- y to support site integrated sdieduling, outage management and project management for :
. assigned projects 'Ihe organir= tion of NOPMD is shown in Chapter 12 of the UFSAR. ~lbe
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Manager-NOPMD delegates responsibilities for accomplishing the following adivities:
y Dmdeis., :.. ar.witing and maintainmg a site integrated schedule wiuch schedules all -
significant plant related acsivities at CCNPP.
4 Managing the pianning, scheduling and performmg of all cutages at CCNPP.
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. QUALITY ASSURANCE POLICY
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' Revision 41 i l
1 Providaag overall project managesnent for engineering, procurement, construction and testmg
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of nuclear pcmer plant modification for CCNPP.
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hannmar.Nael-b% and Plaania-P==n= -
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- The Manager-NSPD is responsible for directing licensing activities, *= ' ; = '- ^ safety crvaluation l
' activities. emergency planning, and industrial safety.
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'the orgamzetion of NSPD is shown 'in Chapter 12 of the UFSAR., The Manager-NSPD delegates fl responsibilities for accomplishing the followmg activities:.
1 Providing licensing ' services; coordination and operation of various industry infonnation exchange. systems; evaluation of. plant events and conditions adverse to quality for s
reportability to the NRC and other agencies, assisting in the investigation and evaluation of q
events, and preparation of the reports; coordination of tracking and resolution of company.
commitments to the NRC; research and preparation of responses to NRC letters, bulletins, circulars and information notices; UFSAR research and revmon control;.maintramare and.
ivvision of the currcsit licensmg basis for nuclear power plants; coe.J.nion of all-compliance-related communications with external ageneses inela% as=*= ace in ensunng their consistency with existing hemsing basis commstments; and coo.G iion of regulatory
' inspections and visits and company presentations to the NRC.
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Directing investagstions of significant events cto determineimot"cause, i--+
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corrective action, and genemtag appropriate reports to documcat the spestigation results0 dimeting a program for identifying trends within the correcteve action syses..
Directing reviews of the operating experience of other plants-of simdar design to detemune
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the applicability of significant events with respect to CCNPP. (14) -
jf Directag the efforts of BOE personnel involved in einergency planning activitics.
' Directing.the efforts of personnel to develop, implement and coordmate the industrial safety program; implement the fire prevention and fire fighting programs for the CCNPP; and to' plan, schedule, and monitor activities duectly related to safety, fire protections and prevention.
Manaaer-Nuetaar Suonort Services Denar= -
'Ihe Manager-NSSD is responsible for training, nuclear security, onsite pa i
procurement engmocring, receipt inspection and storasc.bsue ofitems, procedures upgrade,' state -
regulatory matters, strategic plannmg, and staff services functions for CCNPP.
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- QUALITY ASSURANCE POLICY Revision 41 -
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-The orgarii=*=an ofNSSD is shown in Chapter 12 of the UFSAR. L 'Ihe Manager-NSSD delegates.
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- responsibilities for accomplishing the following activities:
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Providmg suppett to Mr;s
,a in the Nuclear Energy Division to ensure their ' personnel are :
properly tramed and q==he.d o perform their assigned duties, including those duties which:
t implement the nuclear QA Program Training required by special work forces and
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contractors would he performed by the appropriate BOE r+j_-:
- ^ and/or Host Company l (vendor).-
Disenbuting, and coordmatmg the preparation of revisions to the QA Program documentsi
' collectag, stormg, mamtaimng, and retrieving QA records for. nuclear power plants;o
--- :-i+; controlhng, and distnbutang ' drawings and < technical manuals 1related to t equipment, matonals, and services for nuclear power plants; coordinateg.investagstions concesning state regulatory matters; wC ;ing the c5 orts of Nuclear Energy Division'.,
personnel involved in the procurement of senactures, systems, components, parts, and services related to the design, constructirm, fueling
~ - - = and mod 6 cations of CCNPP.-
Establishing procedures.to assure that SR and DNSR procurement documents. identify--
technical and quahtyl requirements; procurement (SR and. DNSR) dac===ne= 1 receive vidapanda=w review and approval for the proper inclusion of. technical 'and quahty requirements; ensuring spare and repluv* weit-parts are suitable for. their: intesided 1) application (s); specification of critical charactenstics and acceptance criteria for deAc=*ian I
of commercial grade itens;.speci6 cation of special stange requirements for age sensitive) items.
s..
Performing receipt inspection functions including special receipt inspections and wJ ung -
testmg gJyra.c,4 to accept commercial grade items, designated NSR items or upgrade NSR j
items for use in SR appisca+3aae. (5) d i
Ensuring that the cperational, maintenance, licensing, and traming activitice associated withi j
plant security are effectively imp'==-41, and that nuclear security provisions providc1
.j protection for pi.um.d, equipment, and huitiae at CCNPP against potenitial security'-
threats.
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'i Directag the c& orts of personnel responsible for the storage and assuance of items for-CCNPP.
Development of the annual Strategic plan for the Nuclear Encrgy Division including'the.
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Nuclear Program Plan.
j' Individuals supporting the CCNPP QA Program are designated as follows:
Vice 6:
=-Fa==il hauv Divisina The Vice Pressdent-FED, is responsible to the Senior Vice President-Generation for ensuring that the activitics of FED personnel involved in CCNPP maintenance and moddicatsons; Materials Ep= ? ug and ;
j Analysis; and radiological environmental monitoring, meet the requirements of the QA Program 'Ihis l
'i responsibility is carried out through the Manager-FEMD, and the Manager-FSSD.
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QUALITY ASSURANCE POLICY Revision 41 l
Mananer-Fossil Encineering & Maintenance Departmen_t ne Manager-FEMD, is responsible for duectag the efforts of FEMD personnel involved in maintenance and modification activities at CCNPP.
Mananer-Fossil Sunoort Services Denartment
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l The Manager-FSSD, is responsible for directing the efforts of FSSD personnel involved in: (1)
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maintaining and operating Radiological Environmental Monitoring equipment and perfonning i
sample collection and analysis, (2) ensuring materials engineering and analysis relating to Sk
'I structures, systems, and components are completed in accordance with Company and regulatory requirements.
y_ ice President-Electric Interconnection and Transmission Division i
The Vice President-EITD, is responsible for ensuring that the requirements of the QA Program that relate to the calibration of test equipment and the testing of protective relaying, and metering controls for SR electrical power equipment are implemented. This responsibility is carried out through the Manager-SOMD.
Manaaer-System Operation and Maintenance Deoartment
'..The Manager-SOMD, is responsible for directing the efforts of personnel involved in the testing ufi
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electrical power equipment, the calibration of test equipment and the testing of protective relaying and metering controls for the electrical power equipment of CCNPP.
Vice President-General Services Division The Vice President-GSD is responsible for ensuring implementation of the QA Program requirements that relate to. the procurunent of SR or designata! NSR structures, systems, components, and services; the construction, maintenance, and operation of facilities; and support services for computer softwam and
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hardware.
l These responsibilities are carried out through the Manager-PMMD, Manager-ISD, and Manager-FFSD.
Manacer-Purchasitut and Materials Mar.arement Deoartment nc Manager-PMMD, is responsible for directing the efforts of personnel involved in the purchasing ofitems and services for CCNPP and for the issuance of Contracts for Fitness for Duty i
Activities.
Manamer-Infomntion Systems Deoartment The Manager ISD, is responsible for directing the efforts of ISD personnel invohed in acquiring and supporting computer software and hardware.
Manneer-Facilities and Fleet Services Denartment I
ne Manager-FFSD, is responsible for directing the efforts of FFSD persormel involved in the planning, design, construction, maintenance, and operation of facilities and related systems directly supporting or impacting power plant operations.
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QUAIJIY ASSURANCE POIJCY Revision 41 U
Vice Presulent-Managunant Samcas Division
- 'Ibe Vias President-MSD, is r==pa==* for casunas that the actmtses of MSD personnel involved with medical h for CCNFP operators, Nuclear Secunty Offloors, and respirasar users, most the requavements of the. ; ' ' = M responsibility is carried out through the Manager-SMSD.
Managar-sammy and Medical services Departenst
' Ins Manager-SMSD is rampa==im for direding the efforts of SMSD personnel involved wish' J
inedical cuaunimadnam for CCNPP operators (10CFR55). Nuclear Secunty Of5cers (10CFR73),
respirator users (10CFR20), and with the Fitness for Duty rule (10CFR26).
Vice Panident{arporaar Aflhirs b Vice President-CA is :==panaihte for casunas that QA Program requiresnents related to the Radiological Effluent Technical Spocafications are implerne= rad This %---- M4y is camed out through
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the Diredor - Enviraamaar=1 Programs.
IB.2 OUAIIIY ASSURANCE PROGRAM I
General Controls l.'
'1he QA Program consists of the Updated Final Safety Analysis Report:(UFSAR) Appendix-1B,:QA Policy, Quahty Assurance Procedures, certain Nuclear Program ' Directives 'and their implementing
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procedures h UFSAR Appendas 1B and QA Policy are the same daemnear except for the way changes are incorporated. "Ihe QA Policy is updated when each change is approved Revisions to the QA Pobey are controlled by QA Program documents which are -written to ensure comphanos with 10. CFR '
50.54(a)(3). 'Ibe UFSAR Appendix IB is updmed manually. All QA Policy changes approved dunng the -
prev.ous year are hevparated during that update.
'Ibe QA Policy identafles NRC regulatory requirements, industry standards, and specific codes appbcable to the eighteen entena contamed in 10 CFR 50, Appendix B. 'Ibe QA Policy also inar=*== action that will be taken by BGE in respcase to these docuanents and to'comniitments made in the UFSAR and TSs for l CCNPP.
Quality E- ---= Procedures (QAPs) describe controls for the actions idrumnad in the QA Policy. QAPs cover major activities related to operating a nuclear power plant, such as plant operation, plant maintenance, traming, purchase ofitems and services, calibrations, etc.
Nuclear Program Directives address actions identified in UFSAR Appendix IB. Directives identify regulatory conur.itments, management requirements, and assign responsibilities for busmess activities (i.e.,
- design,
~
=, operations, etc.) within the BOE Nuclear Program, As directives are written and impismented, abey will 9f
<=*1y replace QAPs.
BGE's QA Program for CCNPP is applied to structures, systems, components, and activities that have l been designated SR because they prevent accidents or mitigate the na==anywmare of postulated machara that could cause undue risk to the health or safety of the public. 'Ihc QA Program is also applicable to designated NSR structures, systems, components, activities, and servions as required by in regulations.
F7 ^ M NSR prograra requirements are based on a graded approach to Quality Assurance required to ineet applicable regulatory designated requirements and guid==aa.
'Ihe level of QA Program controis placed on designated NSR items are defined in QA Program docuenanta and/or implemcating procedures.
N controls froen other sections of this QA Policy are selected as necessary to meet the particular regulatians being implemented Page 14 of 59 l
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- - -.. - - - - - - - - - - - - - - - - - - - - - - - ~
i l
1 QUALITY ASSURANCE POLICY Revision 41 Controls have been established for specifying on a Quality List (Q-List) all SR structures, systems, components, and activities that are subject to the requirements of the QA Program.
The Statement of Authority, in the Quality Assurance Manual for Nuclear Power Plants, signed by the Chairman of the Board, establishes the overall QA Policy of BGE. This Statement sets the goal of safe and l reliable operation of CCNPP; commits the Company to a QA Program designed to ensure the plant's l
compliance with regulatory requirements, BGE conunitments, and established practices for reliable plant l operation; and requires every person involved in QA Program activities to comply with the provisions of the Program.
He Policy is approved by the Vice President-NED and implemented by Nuclear Program Managers. (1)
The QA Program has established controls for BGE and its contractors as required to ensure that the criteria l of 10 CFR 50, Appendix B, will be met throughout the operations phase of the plant; i.e., during activities of testing, operation, maintenance, repair, modification, and refueling.
The QA Program has also established controls to ensure that the construction, operational, and decommissioning phases for the Independent Spent Fuel Storage Installation (ISFSI) are conducted in compliance with 10 CFR 72. Activities associated with the operational and decommissioning phase shall be controlled under the CCNPP 10 CFR 50 Appendix B QA Program; existing policies, programs, directives, and procedures stated as applicable for CCNPP are also applicable for the ISFSt. (16)
Changes to the QA Program documents are issued with a transmittal. notice, which is completed by.the.
E, recipient and retumed to indicate that the documents listed on the transmittal have been received and l
[
. incorporated into the recipient's Manual. Nuclear Program Managers ensure QA Program documents are revised as regulations, standards, results, or experience dictate. (1) The Manager-NQAD evaluates the I
degree of compliance with the requirements of QA Program documents and procedures: Audits are conducted regularly to ensure compliance with established requirements, and the results of these audits are reported to responsible management personnel.
The Vice President-NED, ensures that activities of the NQAD are audited regularly by personnel independent of the Department. These auditors assess the effectiveness of the Department's implementation of appropriate portions of BGE's QA Program. The Vice President-Nuclear Energy Division, evaluates the" l report of the independent audit to determine if changes are required to the QA Program. He is responsible for negotiating such changes with the appmpriate level of management and for sending to the Chairman of the Board a copy of the audit report and an account of the corrective action taken.
If a difference of opinion arises between NQAD personnel and those of other Sections < ' partments, the dispute is resolved as follows: The Supervisor / General Supervisor of the QA Unir i involved first l
trics to resolve the matter with the organization responsible for conducting the h If a resolution carmot be obtained, the matter is referred up through the fo!!owing managemem nel until it is resohrd: (3) 1.
He Manager-NQAD, and the Manager responsible for performing the activity.
Page 15 of 59 I
-. - - - - - - ------. - A
, m m-
' 7.2 a
sy'
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' QUALITY ASSURANCE POLICY <
~
Revisfori 41-n i NOTE: -
e
. If the dispute is with another Unit /Section in'NQAD, the issue will be ~
settled by the Vice President-Nuclear Energy Division; (3) ::
m
'Ihe Vice Presideut-Nuclear Energy Division.' (1) '
2.
. o..
3.
'The Senior Vice President <s'cooration, President and Chief Operating OfBeer, or the' Chamnan ofJ
^
the Board.
y L
'l To ensure that important actmties are pac..d correctly; BGE conducts formal traimag programs for ll Company personnel with saapuficant. responsibilities. "Ihese programs include both initial and contmuing traming and are conducted in accordsam with wr%n peocedures or instructions.' Department Managers
- are responsible for msuiing that the trammg needs of W-M in their Departments am identified, formal-training programs to satisfy those needs are developed, and the traimng programs are implemented in ~
accordance with the requiremmes of the QA Program documents.
~
'Ihe QA Progmm was developed to meet the requirements of the Regulations, Regulatory Guides, and -
Industry Stmadards of the Nuclear Regulatory Commission (NRC). listed below. Exceptions taken to p
- guidance containedin these b = and equivalent BGE alternatives are stated in Table IB-1.-
j L
}
REGULATIONS.
I i
P]! _
10 CFR 50.55a - Codes and Standards 10 CPR 50.59 - Changes, Tests, and Experiments.
a 10 CFR 55 - Operators'Iicenses
- j 10 CFR 50, Appendix B - Quality Assurance Criteria for Nuclear Power Plants and Fuel Rerocessing -
j Plants.
3 10 CFR 72, Subpart G - Quality Assurance (ISFSI)'
REGULATORY GUIDES t
1
- t i
1.8 - Personnel Selection and Traimng (Sw..ber 1975)". 'Ihis endorses ANSI N18.1 (03/08n1)"*.
J P
1.16 - Reporting of Operating Information (as w*d in Calvert Cliffs Technical Specificat==is). '
p l 1.30.- QA Roquirements for Installation, inspection, and Testing of. instrumentation and Electnc Equipment (08/l1/72)*. "Ihis cr.derses ANSI N45.2.4 (03/01/72).
1.33 - QA Program Requirements (Operation, Rev. 2, 02/78)". This endorses ANSI N18.7-1976/ANS -
l
- 3.2 (02/19/76)"*,
a e
I I
!q l
Page 16 of 59
, u a. c. _... _.; _ _.- _ - _. - _.. _ _.~ _ _ _-. _ - __
'l QUALITY ASSURANCE POLICY 1
Revision 41 J
{
-i
..~ 1.37 - QA Requirements for Cleamng of Fluid Systems and' Associated Camp--*- of Water-Cooled '
E Nuclear Power Plants (03/16/73)". This endorses ANSI N45.2.1 (02/26/73)"*.
.l 1.38 - QA Requirements for PWeing. Shipping, Receiving, Storage, and Handling ofItems for Water-
{
Cooled Nuclear Power Plants (Rev. 2. 05/77)**. This endorses ANSI N45.2.2 (12/20/72)"*.
j a,
1.39 -llousekeeping Requirements for Water-Cooled Nucicar Power Plants (03/16/73)*. 'Ihis endorses -
i
. ANSI N45.2.3 (03/15/73)"*.
1.54 - QA Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants (06/73)". This endorses ANSI N101.4 (11/28n2)"*.
l 1.58 - Qualification of Nuclear Power Plant Inspection, Examination, and Testmg Personnel (09/80)".
This endorses ANSI N45.2.6 (1978)***.
s 1
1.64 - QA Requirements for the Design of Nuclear Power Plants (10/73)* This endorses ANSI N45.2.11, DraA 3 Rev.1 (07/73).
j 1.68 - Preoperational and Initial Stanup Test Programs for Water-Cooled Power Reactors (11/73)**.
1.144 - Auditing of Quality Assurance Programs for Nuclear Power Plants, Rev.1 (09/80)"; This
.{
codorses ANSIN45.2.12(1977).
f 1.146...Quahfication.of Quality Assurance Program Audit Persomel for' Nuclear Power Plants (Augi j
8' 1980).*. This endorses ANSI N45.2.23 (1978)"*.
i i
INDUSTRY STANDARD.?
ANSI N45.2.5 - Supplementay QA Requirements for Installation, Inspection, and Testing of Structural I
Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants; Draft 3, Rev.1 l
(1in3).
l ANSI N45.2.8 - Supplementary QA Requirements for Installation, inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nucicar Power Plants; Draft 3, Rev. 2 (09/73).
ANSI N45.2.9 - Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for i
Nuclear Power Plants; Draft (10n6)*".
i S
ANSI N45.2.13 - QA Requirements for Control of Procurement of Equipment, Materials, and Services for I
Nuclear Power Plants; Draft 2, Rev 2, (10/73)"*.
'l 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.
BGE takes exception to guidance offered and states alternatives.
{
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l Page 17 of 59 j
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QUALITY ASSURANCE POLICY RevisiTn 41 Procedural Controls The QA Policy and revisions thereto are reviewed by Nuclear Program Managers. QA Policy revisions are reviewed by NQAD 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. The Manager-
_ NQAD reviews revisions to the QA Policy and recommends approval to the Vice President-Nuclear Energy Division. %e Vice President-NED approves the QA Policy and revisions thereto.
Each Quality Assurance Procedure (QAP) is prepared by one or more of the Departments responsible for conducting the activity. The QAP and revisions thereto are reviewed by NED Managers and affected Department Managers. The Manager-NQAD ensures QAP revisions are reviewed by the Quality Assurance organization and recommends approval to the Vice President-NED. He Vice President-NED approves all QAPs and revisions thereto. The Manager-NSSD ensures issuance of all QAPs and revisions thereto. (1) QA Program documents control the distribution and revision of the QA Policy and other QAPs.
Nuclear Program Directives are prepared under the direction of the Department Manager assigned by the Vice President-NED as the Program Sponsor. Each directive and revisions thereto are reviewed by affected Department Managers. The Manager-NQAD cnsures directivc revisions are reviewed by the Quality Assurance organization and approval recommended to the Program Sponsor. The Program q
Sponsor approves the directive and revisions thereto.- De Manager-NSSD ensures issuance of all directives and revisions thereto.
, QA Program documents ~ ensure that:
1.
He 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.
Personnel who perform activities affecting quality achieve and maintain suitable proficiency through appropriate training and experience.
Administrative or Technical Procedures are prepared as needed They establish the processes used to implement directive or QAP requirements. The controls for review and issue of procedures are discussed in l
Sections IB.5 and IB.6.
i
' Review of Oncrations Procedurcs require that CCNPP shall be operated and maintained in accordance with the plant TSs and operating license. He following organizations review plant operations to ensure that these procedures are l
followed:
I 1.
He Manager-NQAD provides independent verification that the requirements contained in the Plant's operating license, UFSAR, TSs, and plant procedmes are met. This is accomplished through quality assurance audits.
i 2.
He OSSRC provides independent verification by review that CCNPP is operated hi accordance with established requirements. Le OSSRC, which functions under a written Charter approved by the Vice President-Nuclear Energy Division, is composed of on-site and off-site personnel knowledgeable of in-plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, radiological safety, instrumentation and control systems, mechanical and electrical
- systems, quality assurance, and environmental factors.
The Page 18 of 59
- QUALTIY ASSURANCE POLICY Reviai+n 41 -
1
? proceedings of all meetings are d~mw~4 and sent to the Vice President-Nuclear Energy Division -
Committee members, and others designated by the Committee Chauman LI i
~ 3.
The on-site POSRC reviews matters pertauung to nuclear plant safety. 'Ihis Committee screens j
. subjects of potential concern to the OSSRC and performs prelinunary investigatsons under the
)
i-
. direction of the Plant General Manager. POSRC membership and fhactions.are governed by
' Technical Specifications and written procedures. The results of all meetmas are &+
+'eiand) j sent to the members of the OSSRC, and others designated by the Committee Chairman.
- l.
The maintenance and repair of systems, structures, and cow.r~.
- 4. subject to the QA Program are performed by personnel under the direcuon of the General Supervisors of Electrical and Controls, Radiation Safety, and Mechanical Maintenance, according to wntten procedults and instmetsons as prepared by the mantenance force and approved as stated in QA Program documents. 'These Procedures:
.i l.
Ensure that quality-related activities, such as inspections and tests, are performed with appropriate equipment and under suitahic environmental conditions.
l 2.
Indicate inspections and checks that must be made a xl records and data that must be kept.
3.
Show where indenandmt verifications of inspections or checks should be performed by'specified personnel other than those performing the work.
-i I
When necessary, non-plant Company p:rsonnel or outside contractors.arecbrought insto supplentcut the; plant work force., fin such instances,.the approval of work procedures and the tagging of equipment are-j
~
coortimated by a member of the BGE organization responsible for the i.e.f.. a of the work.
l 8
Controls are established in QA Program documcats to ensure that materials and parts used in the repair,.
c maintenance, and m< viia =+ ion of SR and designated NSR portsons of the plant are appropriate for_ the.
service intcaded Written procedures are prepared for the storage and identification of materials and parts-
=
to ensure that they do not deteriorate in storage and can be correctly idenafied before installation or use.
Equipment manufacturers and contractors usM for the repair, maintenance, and modification of SR and
[
~
designated NSR semctures, systems, and components are required to have quality assurance programs.
'=
consistent with the importance of the end-product to safety.
l 1B.3 DESIGN CONTROL L
Opntrol j
h Plant changes which affect the design, function, or method of performing the function of ~a'struc' ture,-
l system, or component described in the UFSAR and are controlled by QA Program de-ts which are -
1 written to ensure compliance with Regulatory Guide 1,64 and 10 CFR 50.59.
Controls for changes, tests, and experiments conducted at CCNPP vary accordmg to the following:
q 1.
As the item or activity affected is or is not described in the UFSAR.'
l
- 2.
As the item or activity a%cted has boon classified SR er NSR.
.p
'h l
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'QUALflY ASSURANCE POLICY Revision 41 l
3.
'As the itan or activity affects or does not ' affect nuclear safety
' 4.
As the proposed change, test,'or experiment does or docs' 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 e.apui--.-.;a has beest divided into classifications. Procedures required by QA Program doewnents describe and control the" d
method for determinmg the appropriate process classification. The process classifications control the preparation and reporting of safety evaluations ' bee methods of treatment are allowable; i
1, I r+L. -.;-g the change, test, or experiment in accordance with Ca=:-ay practice for operating.
power plants, or in accordance with Procedures required by QA Program dc=x..,.ts.
i g
1 2.
Implementing the change, test, or experiment in accordance with Procedures > required by QA -
-i Program documents but controlling the change, test, or experiment with a process classification. '
i 3.
Controlling the change, test, or experiment with a process classification 'and not allowmg the impk.. ;=4 activity to begin until the review requirements of 10 CFR 50.59 and 10 CFR 50, Appendix B, have been met.
{
Changes, tests, or exix.i.ets which require approval by the NRC are approved by the POSRC and by the j
OSSRC.
i
- (
' j :,
Controls have been established to ensure that design changes to SR structures, systems, and componentrU i
are reviewed either by the organization that made the original design or by a Responsible Design
'j
~ ^
Organization (RDO) that meets requimnents specified in ANSI N45.2.11, Section 8.0.
'l i
Resoonsible Desian Oraanizataons RDOs, either on contract or within BGE, ensure that:
l 1.
. Applicable regulatory requirements and dcsign bases requirements are correctly translated into specifications, drawings, written procedures, and instructions.
2.
Appropriate standards for quality are specified in design 4x- - =ts, 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 controllod,- inan~ *~I, and tested, i
and that inspection and test criteria are identified.
5.
Interfaces, both extemal and internal, are controlled for the activities of all participating ~
orgamzations 6.
Methods for verifying or checking, such as design reviews, attemative calculations, and qualification testing are properly chosen and followed; the most adverse design condi* ions are specified for test programs used to verify the adequacy of designs, j
i 1
Page 20 of 59 l
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QUALITY ASSURANCE POLICY RevisiTn 41 7.
Individuals or groups responsible for design verification are other than the original designer and the designer's immediate supervisor, 8.
Design and specification changes are subject to design controls and approvals applicable to the original design.
9.
Design documents and revisions thereto are distributed to responsible individuals and controIIed to j
prevent inadvertent use of superseded material.
I 10.
Design errors and deficiencies that adversely affect SR structures, systems, and components are documented, and appropriate corrective action is taken.
I 1.
Design documents and reviews, records, and changes thereto are collected, stored, maintained, and controlled systematically.
12.
Standard off-the-shelf commercial or previously approved m2terials, parts, and equipment essential to the SR functions of structures, systems, and components are reviewed for suitability of application before they are selected.
13.
The persons or groups responsible for design reviews and other design verification activities and their authority and responsibilities are identified.
4,,
14.
Design changes to NSR items initiated and approved at the plant are controlled to ensure compliance with 10 CFR 50.59.
15.
Processes used to select suitable materials, parts, equipment, and prmses for SR structures, systems, and components includes the application of pertinent industry standards and specifications, material and prototype hardware testing prof,r, rams, and design reviews.
16.
Computer programs used in design are subject to design controls and program ventication.
I B.4 PROCUREMENT DOCUMENT CONTROL (5)
Controls have been established to specify the requirements and sequence of actions for: requesting items or services; review of the requested item or service to establish the necessary technical and quality requirements; preparation, review and control of procurement documents; evaluation and selection of vendors and; control of deviations from the procurement document requirements.
"The degree to which these controls are imposed on the purchase ofitems and services by BGE for CCNPP l depends on:
1.
The functional (safety) classification of each item or service as 3R or NSR according to controls established by the RDO and 2.
The Procurement Category of the item within it's functional classification as a basic component, commercial grade item, designated non-safety related item (DNSR) or NSR item:
Commercial Grade - An item satisfying all three of the following criteria:
a.
1.
Not subject to design or specification requirements that are unique to nuclear facilities; and 2.
Used in applications other than nuclear facilities; and Page 21 of 59
-QUAIIIY ASSURANCE POLICY-
Revisite 41 co; i
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3.
Is to be ordered from the manufacturer / vendor on the basis of specifications set forth
]
in the vendor % published product description (fbr example, a catalog).'
T]
b.
m i
Basic C<--
- it ~- An item either procured as a safety related item or as a commercial grade 1
, item which has been acapted and dedicated for safety related application : This~ term is.
I
~ synonymous with " Safety-Related Component".
v r
Designated Non-Safety Related vA NSR item which BOE has made a regulatory or design y
~
n.
basis comnutmentfor, for plant availability reasonsc BGE has implemented special controls 1
to assure reliability; These NSR items are included withm the quality assurance process.
]
. d.
' Non-Safety RelatM --An item that does not perform a safety related Annction 3;
The procurement method to be used for the item or service:
1 Purchase Orders placed by BGE personnel for items or services intended 'for safets related l i
applications and DNSR items and services fall into' two categories,' Nuclear Grade Method '
procurement and Commercial Grade Method procurement j
Nuclear Grade - Purchases that are designated to be placed with..
vendors that snanntain a-j a.
10CFR50 Appendix B quality program and supply items that meet the definition of Basic j
Component. 'Ibe requirements of 10CFR21 will be invoked on the vendor under this method.
j q
.b.'
Commercial Grade - Purchases that are designated to be ' laced with commercial grade (
'{
p vendors that supply. items or services that-meet the definition of Commercial Grade. These items must be dedicated for SR use by BGE.
j i
' Items and/or services classified as DNSR will be purchased using the' CwMal Grade j
s Method with technical requircanents established by an RDO.
7 a
Qualified NSSD/NED personnel tramed in quality assurance program requirements with RDO authonty.
review safety-related and hign=*ad non-safety related procurement documents for proper inclusion of technscal 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, l
ia=~ *= hic, controllable, contain adequate - acceptance and rejection critena, and comply with the
.}
requirements of the procurement program.' Thes wiews and: approvals : are d-==ted prior.to j
placement of the purchase order.
~
~
t All changes made to procurement documents, including speci6 cations and other technical arrachments, are -
- i subject to the same levels of review, approval and control that were applied in preparing and processing the -
j original documents, j
t Bids submitted to supply safety-related items or services receive the same review and approval cycle as
- f used for safety-related procurement requisitions.
a Vendor SMi=
I Personnel in NQAD evaluate vendors who provide SR and designated NSR items and services'to verify -
l they can provide acceptable items and services.
Ia 1
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li Page 22 of 59 i
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QUALITY ASSURANCE POLICY i
- Revision 41 l
?
p
. Camerols for NJI -r Grade Purekaaa=-
Controls' have been established to ensure that, before placement of a purchase order under the Nuclear Grade method of purchase, there is esidence of the following: '
i 1.
The. vendor has been evaluated as stated in Sectai IB.7 of this' policy'and found to have a.
-l satisfactory QA program, i
7 2.
'Ibe item to be purchased is manufactured under the acquirements of the evaluated and approved Program Caatrols for C =.Q Grade Purch==a=
q Controls have been established to ensure that items or servsces available to gmeral industry will be-l sufficiently controlled to perform their SR and designated NSR 9ac*inaJ. NSSD/NED personnel will specify the acceptance methods to be used to verify the critical characteristics identified in the procurement
{
document (s);
j Procurement Dacummt p~-im-ana I
Proccdures require that procurement documents shall:
i.
8
- 'l 1.
RJum.cc part numbers or descriptions, and additional requiremets to ensure that items ordered can-j 1
be identified and verification can be made that each item receivedis'the itent ordered.'
~
"* 4 en J
2.
Contain/ reference tac %=I requirements for the basis of design, by including the applicabic l
regulatory mquirements, component and material identification, RDO approved 7 drawing and
]
specification, codes, industrial standards, test and mspection requirements, and special process instmetions such as welding, heat treatmg, nondestructive testmg, and cleaning.
l 3.
Identify the requirements of 10 CFR 50, Appendix B, which must be complied with and desenkd in j
the vendor's QA program, for Nuclear Grade Purchases.
i 1
4.
Require that major contractors designated as BGE agents to purchase SR and designated NSR items s l-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.
5Property "ANSI code" (as page type) with input value "ANSI N45.2.13.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Identify required documentation (i.e., drawings, specifications, procedures, -inspection and
' fabrication plans, inspection and test accords, personnel and procedure qualifications, and material chemical and physical test results) to be' prepared, maintamed, and submitted to BGE or the l purchaser for review and approval.
6.
Identify records which must be retained, controlled, maintamed, or delivered to BGE or the l purchaser before use or installation of hardware.
7.
Specify BGE or its agent's right of access to vendor facilities and records for source inspectat, ' l surveillance, verification and audits.
8.
Identify requirements of the vendor's quality control process which must be implemented when providing a commercial gesle item.
9.
Reference or specify the critical characteristics that a commercial grade item must possess to ensure that the item roccived is the item specified.
I Page 23 of 59 i
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e QUALITY ASSURANCE POLICY-j
~ Revisi*n 41 -
~!
I
~ 10.)
Incorporate the requirements of 10 CFR 21 for Nuclear Grade procurements
-j j
1li Include requirements for QA pmgram c'-w - to be passed on to sub-vendors, j
1B.5,
. INSTRUCTION
S. PROCEDURE
S. AND DRAWINGS a
v 1
Controls delineate the sequence 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 apphcable criteria of 10 CFR 50, Appendoc B, must be specified in instructions, procedures, and drawings.
l 2.
Instructions, procedures, and drawings must specify appropriate quantitative (s' ch as dunensions, ll u
tolerances, and opemtmg limits) and qualitative (such as wmb.. ship samples) acceptance criteria ~
-i for verifying that important activitics have been satisfactorily accomplished.
.l Controls ensure that:
+
7 1.
The QA Policy is approved by the Vice President-Nuclear Energy Division. (1)
I,,
' 2.
QAPs are developed by Departments responsible for candadas particular adivstics, reviewed by.
.j
.the managers of the responsible department (s) for that particular activity, and approved by the Vice President-Nuclear Energy Division. (1)
,1 3.
Nuclear Program Directives are prepared under the direction of the Dwuutu.eut Manager assigned
~
as the Program Sponsor, Affected Department Managers review directives and their revisions. The Manager-NQAD ensures directives are reviewed by the Quality Assurance organizatici and i
approval reconunended to the Program Sponsor. 'Ihe responsible Program Sponsor arproves o!
directives and their revisions. Directives are prepared, reviewed, approved, and periodically
-l reviewed according to an appendix to the Nuclear Program Directives Manual, a
4.
Procedures are prepared, approved, and controlled according to the Control Procedures. Control Procedures establish review, approval, revision, change,. and periodic review ' requirements for applicable procedures. If format and content requirements are not contained in Control Procedures,
~
they shall specify the exa-w to be used to determme format and content requirements. Control Procedures are reviewed by the Quality Assurance Organization Other procedures are reviewed by Quality Assurance on a requested basis.
.i 5.
Basis items added during procedure revisions or changes will be recorded. (1) i 1B.6 DOCUMENT CONTROL Requirements have.been established to control the 6mwh of activities controlled by the QA Program. QA Program controlled hmants include the UFSAR; Operatmg License, including the Technical Specifications; Emergency Response Plan; Security Plan; QA Policy; the ISFSI updated Safety 1
Analysis Report (SAR) and Materials Licenso, including Technical' Specifications; procedures;-
i specifications; and drawings Revisions to the QA Policy are controlled by QA Program d~-n=*s which are written to ensurc l
compliance with 10 CFR 50.54(a)(3).
l
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l Page 24 of 59 l
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QUALITY ASSURANCE POLICY Revision 41 Alterations to the UFSAR are controlled by QA Program documents which are written to ensure compliance with 10 CFR 50.71.
i Alterations to the ISFSI updated SAR are controlled by QA Program documents which are written to ensure compliance with 10 CFR 72.70.
Alterations to the Operating License, including the Technical Specifications, are controlled by QA Program documents which are written to ensure compliance with 10 CFR 50.59(c),10 CFR 50.90 and 10 CFR 50.92.
Alterations to the ISFSI Materials License, including the technical specifications, are controlled by QA.
. Pmgram documents which are written to ensure compliance with 10 CFR 72.48(c),10 CFR 72.56, and 10 CFR 72.58.
Alterations to the Emergency Response Plan are controlled by QA Program documents which are written to ensure compliance with 10 CFR 50.54(q), and with 10 CFR 72.44(f) for the ISFSI.
Alterations to the Security Plan ait controlled by QA Program documents which are written to ensure compliance with 10 CFR 50.54 (p), and with 10 CFR 72.44(e) for the ISFSt.
QAPs are required to:
- 1.,
Establish pon.trols to ensure that regulatory requirements and BGE commitments will be/ l implemented.
2.
Describe interdepartmental interfaces and establish controls for interdepartmental activities.
3.
Specify how important activities, such as plant maintenance or in-service inspection, are to be performed, and give sufficient detail to control the perfonnance of the activity or to ensure that requirements for lower-level procedures are clearly specified.
4.
De prepared and controlled in accordance with QA Program documents that describe the format, sequence of topics, contents, review and approval, issue and distribution, and requirements for revision and record retention.
During the review of each QAP, compliance with applicable criteria specified in 10 CFR 50, Appendix B, is verified and documented.
The Manager-NSSD, is responsible for issuing, revising, and controlling QAPs.
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 technical review by a member of one of the responsible departments. Each QAP is reviewed by department manager (s) who have responsibihties for activities governed by that QAP, and the 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.
Establish controls to ensure that regulatory requirements and BGE commitments will bc l implemented.
2.
Establish controls to ens are that management requirements will be implemented.
Page 25 of 59
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~ QUALITY ASSURANCE POLICY; l
x
. Revision 41 4
.4 3?
.i Assign responsibilities and interfaces within the program."
q 4.
Be prepared and controlled in igu,.dS;44 with an appendix.to the Nuclear Program Directives,.
l Manual that describes the format, contents, n: view and approval, revisions, and periodic review
.i
. requirements j
Nuclear Pmgram Directives are' prepared and technically seviewed under the direction of the Department Manager assigned as the Program Sponsor. Each directive is reviewed by affected Department Managers.
Each directive is given a comphance review by a member of the Quality Assurance organization. Nuclear.
Program Directives are approved by the sponsoring Manager after ensuring resolution and incorporatson of d
'.QA compliance review comments. (9) De Manager-NSSD casures issuance of each directive.'
l Administrative and Technical Procedures are prepared.when needed to implement QA Program Av-=t d
O requirements accordmg to a Control Procedure. Individual organizations are responsible for preparms,.
j revising, issuing, and controlling procedures. Each procedure is given, a' technical review under the j
direction of the sponsoring 'organwasion., De Quality Assurance oroanineson performs e--
L; reviews on Control Procedures. Other procedures are reviewed by Quality Assurance on a requested basis.
Organizatsons that issue mstructions, procedures, sy--Z-d=s, or drawings are required to establish g
controls that ensure the following-q 1.
Chastges to a M==* are reviewed and approved by the organi7 atma that performed the ongmal review and approval unless the control procedure designates another 'quahfied responsiblet y
orgamzation.1 2.
Approved changes are promptly incorporated into instructions, procetlures, drawings, and otherI documents associated with the change.
]
3.
Obsolete or superseded documents are controlled to reduce the possibility of inad' ertet use.
'l v
Superseded documents retamed for reference are marked and stored.in separate files. Other i
superseded documents are removed from the files.
When changes to drawings or specifications are required, change requests 'are prepared by the orgam7ation' that desires the change. Requests are reviewed and approved by BGE RDOs.
l 1B.7 CONTROL OF PURCHASED MATERIAL. EOUIPMENT. AND SERVICES _ (5) 1
.NQAD, NSSD, NED, and PMMD personnel are sesponsible for the control of purchased items and services for SR and designated NSR applications at CCNPP.
The controls include:
1 1
Acceptmg items or services only from vendors who have been evaluated and selected in accordance with this policy.
Procurement documents for spare or replacement parts of stmetures, systems, and components as designated under the.QA Program subject to controls at least equivalent to those applied to the origmal equipment, or an evaluation / justification shall be documented when less stringent controls are involved.
e l.
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QUALTIY ASSURANCE POLICY Revi' ion 41 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 hment requirements.
yggdor Evaluation -
De vendor evaluation is conducted to determine acceptability of a vendor to provide the requestod item or service, to determine what vendor programs, pmoedures and documents need to_ be invoked by the procurement document, ii...hing the vendor's performance history for supplying itans to CCNPP and L
assessing the need to impose source surveillances and/or verifications during the manufacture ofitems or performance of services for BGE. Vendor evaluations depend on the procurement classification cf the ~ ]~
item (s) being supplied.
~ The National Institute of Standards and Technology (NIST), by virtue ' fits being the nationally recogmzed o
standard, is an acc@ table provider of calibration masters, standards or services. Utilities holding an NRC Construction Permit or Operating License are acceptable suppliers of a!! items except for those items to be used in an ASME Boiler and Pressure Vessel Code Section III application. Neither of the above are required to be listed on the Approved Vendom 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 the4 requirements specified in.the procurement specification or proposed procurement specification. These'evafuations and' audits +
are conducted and documented using written procedures or checklists that identify the.QA requirements applicable to the items supplied.
e Commercial Grade Since DGE accepts the responsibility of verifying the conformance of commercial grade items l and/or service, they may be procured from vendors with no formal quality assurance program. In this instance, BGE 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 ofitems or performance of services for BGE.
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.
He 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 vendors are added to BGE's AVL. The vendors on this' list l -
are evaluated on an annual basis and subject to re-audit or commercial grade survey on a trienmal basis to verify continued compliance with BGE's requirements.
An auditing organization such as NUPIC, another utility, a contractor to BGE, 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 BGE's procurement requirements or l similar requirements.
Page 27 of 59
' QUALITY ASSURANCE POLICY a
Revisitn 41 n
When required by operational considerations, an order may be placed with a vendor prior to completion of 4
the evaluation and approval process only aAer dedt the Manager-NSSD's approval.-
BGE's j ~
acceptance of basic component items or services provided by an unappmved vendor is contingsat on the subsequent NQAD evaluation and approval of the vendor as stated above.
. VerW-A of V-idActivities 4
L Vendor surveillance,'and source verification activities are conducted by quali6ed NQAD personnel in:
L accordance with written pr* Mares or checklists. These procedures or. checklists, alcag with thei procurement documents,'specify the characteristics or processes to be witnessed, inspected or verifi.d..
Personnel performing these activities are qualified to establish whether, or not m' vendor is capable of:
. providing products of =-:-a- -t-le quality.
The depth and-fi%y of vendor surveillances, verifications and ' audits is commensurate with the; complexity and fundian of the item or service and the ability of the vendor to provide the mury assurance of==p**hility.
When a vendor's certdicates of confura ace are used as part of the me=p-- of an item or service, the validity of these documents is periodically evaluated and & =-- -M by the above mentioned processes.
I Rcccapt 7
NSSD. is responsible for receiving and storing materials, parts, and et V-
. Additionqilly, NSSD is responsible for performmg standard and special receipt aspections and coordinating testieg - y to accept SR items, designated NSR items and commercial grade items for SR use.
Standard receiving inspection ofitems is psfur...d to assure the followmg
,. 17 1.
The item is properly identified and that this identification corresponds with the documentation roccived.
2.
. Stated packaging, shipping and h=Mug requirements have been maintained.
3.
Items have not been damaged, workmanship is of adequate quality, and the items are adequ'ately.
clean in accordance with procuremcat docuanent requirements 4.
Documentation required by the Purchase Order has been received and is reviewed to assure that the -
item conforme to the purchase order requirements.
.t 3-
- Special receiving inspection may be required if the item was not inspected at the source: when requested by.
1~
the RDO or; as past of the==pe= ace basis for commercial grade items.
A written record of the results of the NSSD receipt aspection and the disposition of received items is-maintained as part of permanent plant records.
. All SR and designated NSR items accepted and released for issue to a controlled storage area or released -
for ' installation-or further work bear an acceptance tag and have documentation to support their acceptability. If traceability is lost or the documentation avview is unsatisfactory, an item becomes subject to the controls established for non confornung items.
Page 28 of 59 1
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_ _. ~. _
QUALITY ASSURANCE POLICY Revisitn 41 Non-conforming items are identified and handled in accordance with Section IB.15 of this policy and, when practicable, are placed in a segregated area to prevent inadvertent installation or use until proper disposition is made.
D_ogumentation l
BOE procurement documents require vendors to provide documentation identifying the purchased item and l the specific procurement requirements that are met by the item.
Vendor inspection records or certificates of conformance attesting to acceptance must be in the possession of BGE before the item may be released for installation or use. However, an unacceptable item may be l given a Conditional Release" if there is reasonable assurance that it can be made acceptable after installation but before the system that contains it is considered operational.- Items released under
" Conditional Release" must be controlled under the Non Confonnance Report (NCR) system.
Vendor requested deviations from procurement document requirements, including nonconformances dispositioned "use-as-is" or " repair" must be submitted to BGE for evaluation and approval of the deviation l or a recommended disposition prior to shipment.
IB.8 IDENTIFICATION AND CONTROL OF MATERIALS. PARTS. AND COMPONENTS (5)
NSSD/NED personnel ensure that procurement documents require that SR and designated NSR items, including partially fabricated sub-assemblies, are identified and controlled to ' prevent the use ofincorrectert
' defective material.
Requirements for identification by use of heat number, part number, or serial number, or by other means, are referenced or stated in procurement documents. These documents require the identification 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.
This identification is required to be maintained throughout fabrication, stomge, erection, installation, and use. NSSD personnel ensure traccability information is correctly transferred to subdivided materials stored in the Warehouse User organizations ensure traceability infonnation is conectly transferred to subdivided materials after issuance from the Warehouse. NQAD is responsible for performing periodic inspections or r
surveillances to verify program adherence.
Assigned NSSD personnel purchase identify, store, and issue items as specified by procurement controls and provide for maintaining the integrity ofitems and their traceability to associated documents during storage and issue.
DGE contractors and their sub-contractors (who are approved to work on-site under their own QA l
[
program) are responsible for establishing and implementing programs in accordance with specified requirements for identifying and controlling materials, parts, and components under theirjurisdiction.
Identification of items important to the function of SR and designated NSR structures, systems, and components can be traced to appropriate documentation such as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and chemical mill-test reports.-
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QUALITY ASSURANCE POLICY R vision 41 Receipt SR and designated NSR items received at CCNPP are receipt inspected to verify that all requirements of the procurement documents have been met. If a discrepancy is observed, such as damage or missing documentation, information to the effect is recorded on the receiving inspection report, and the discrepant item is identified as such and placed in a separate " hold" area when practicable. If the item is acceptable, it is identified to indicate acceptance and that it is approved for storage or installation and use. When groups ofitems in storage are subdivided, each subgroup is separately identified.
i If an item is found to be or is made discrepant during processing, it is identified as such and placed in a separate area when practicabic.
Acceptance documentation is required to be traceable to a purchase order, drawing, specification l requisition number, or assembly. As individual items are assembled, installed, and inspected, their 1
acceptance-tag numbers are recorded in plant maintenance or operation records.
After completion of tests and inspections, records that document test results and traceability are kept as
+
part of the plant records.
I B.9 CONTROL OF SPECIAL PROCESSES Controls Controls.have been established for writing, qualifying, approving, and is.euing procedures to control such.
special processes as welding. heat treating, and nondestructive testing used during the operation of CCNPP, Special Process Procedures:
1.
Are prepared in accordance with applicable codes, standards, specifications, criteria, and other special requirements.
2.
Ensure that special processes are performed by qualified personnel according to qualified procedures that comply with applicable regulatory requirements.
1 3.
Specify requirements for control, parameters to be considered, acceptable methods of documentation, and the codes, standards, specifications, or criteria which govern the qualification.
I 4.
Derme the necessary qualification of personnel, procedures, or equipment when special processes I
are not covered by existing codes or standards or when quality requirements for an item exceed the requirements of established codes or standards.
t BGE contractors and their sub-contractors are responsible for controlling special processes used by them l l
7 and for maintaining records to verify that special processes are performed in accordance with requirements j
established by the portions of their QA programs that apply to special processes.
Oualification of Methods Procedures, equipment, and personnel connected with special processes are qualified in accordance with I
applicable codes, standards, specifications, or supplcmontary requirements as follows:
I l
1.
Welding activities conducted by BGE are performed according to welding procedure specifications l
{
qualified in accordance with applicable welding requirements of the ASME Code. Each welding procedure specification '
is
- written, qualified, and approved in accordance Page 30 of 59 1
.)
QUALITY ASSURANCE POLICY i
Revisi n 41
. with a controlling documented procedure. Copics of welding procedure specifications are made available to welders and, when required, to Authorized Inspectors. Before co the Principal Metallurgist reviews and approves non-BGE welding procedure speci5 cations and procedure qualification records in accordance with a written procedure.
2.
Heat-treating requirements included in welding procedure specifications are established -in conformance with heat-treating requirements of the applicable ASME Code.
3.
Nondestructive Exammations are perfonned to written procedurrs proved by actual demonstration, when practicable, to the satisfaction of the Principal Engineer Nondestructive Examination -
Nuclear and, when required, the Authorized inspector.
These procedures are prepared according to appropriate sections of the ASME Code for particular examination methods. Procedures, personnel qualifications, and the records that verify the Performance of Nondestructive Examinations are kept as nuclear plant records. Nondestructive Exanunation Procedures describing methods not described in the ASME Code and/or SNT-TC-I A and its Supplements are at least equivalent to those recognized by the American Society of Mechanical Engineers and the American Society for Non-destructive Testing. Training programs acceptable to the Principal Engineer - Nondestructive Examination - Nuclear kre developed to complement these alternative methods and to establish the capability of personnel to perform the required examination according to BGE procedures and to the level l of performance to which the individual will be certifled.
Methqds of Nondestructive Examination include, but are not restricted to,+ radiographic, ultrasonic,e
, liquid-penetrant, magnetic-particle, cddy-current, visual, and leak-testing exanunationse Procedures are prepared to cover these exammations in accordance with a QA Program document that details the specific examination, requirements for approval, and content of the procedure, such -
as certification level, accept / reject criteria, examination coverage and sequence, surface -
preparution, test equipment, records required, permissible marking, cleanup requirements, and reference to applicable sections of the ASME Code.
Qualification of Personnel Special processes.are performed by certified personnel using written process shects, shop procedures,'
checklists, and traveiers (or equivalent), with recorded evidence of verification as follows:
1.
BGE welders, and welders under contract to BGE, are qualified and certified in accordance with the l applicable requirements of the ASME Code. The Principal Metallurgist maintains records of the welding procedure specifications, including essential variables under which the welders are examined, and the results of the examinations. A wclder is not permitted to weld SR and designated NSR items until an appropriate performance qualification record, a letter of certification, or, in an emergency, verbal clearance from the Principal Metallurgist, is on file at CCNPP. Each welder is required to be requalified as specified in the applicable code.
2.
Non-UGE welders are not permitted to weld SR and designated NSR items until they are qualified ' l and certified in accordance with the applicable requirements of the ASME Code, j
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QUALITY ASSURANCE POLICY Revidon 41-L 3.
. Nondestructive Exanunation personnel employed by or responsible to BGE are certified according to -
applicable sections of the ASME Code and/or SNT-TC-1 A and its Supplements. BGE employees are tramed and certified in accordance with a wntsen procedure.L Non-BGE personnel are qualified
, to procedures approved by BGE, and their qualifications and cettifications of personnel are verified
=--x+'; to written procedures.
I Qualification neords of procedures, equipment, and personnel - -
--I with~ special procceses ea=Aieted -
. by BGE are filed and kept cunent by the Principal Metallurgist or Principal' Engineer'- Nondestructive I.
Examinaraon -Nuclear.
'"Ihe Manager-NQAD provides independent verification that special processes are performed by' qualified
.l
. personnel q
- IB.10
. INSPECTION ly
! Activities that affect the quality of SR and designated NSR items are inspected as specified in approved ~
instructions, procedures, ~and plans which set forth requirements and =
p*==e+ cnteria to ensure that work 1
is done in confonnance with particular requirements.
i Controls exercised during inspections ensure that:
5.
1.
Personnel who perform quality verification mspections are 17-%='-
of the personnel who
' performed theactivity being i===~+-A I
5 2.
Inspectum procedures or instructions, with necessary ' drawings and specifications for' use, are -
available before mspection opemtions are performed.
4 3.
In the case of special processes, inspectors are qualified, and their qualifications comply with d
applicable codes and standards 4.
Test and measuring equipment is calibrated within required limits.'
l
- 5.
. Inspection. procedures, as applicable, specify objedive===*= ace ' criteria,' prerequisites for
]
i performing inspections, limiting conditions,' requirements for special equipment and Quality l-
-l Verification (QV) hold-points at which inspections are to be witnessed.
l l
6.
Appropriate inspection requirements are established for modification, repair, and replacement.
7.
Personnel who perform quality verification inspections are qualified in accordance with appropriate
)
codes, standards, and Company training programs, and their qualifications and certifications.are
'j kept current, j
8.
Procedures for mainten=nm and modification are reviewed by QV personnel, or others authorized by QV, to determine the need for mdependent inspection and the degree and method if such an1 3= =+iaa is required, and to ensure the identification ofinspection i-M and the documentation 1
ofinspection results.
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l Page 32 of 59
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._._.-..-__.;.--.m..
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l QUALITY ASSURANCE POLICY Revision 41 e
J 9.
Procedures for Nondestructive Examination, excluding visual exammation procedures perfurmed on nuclear fuel, are reviewed by quali5ed personnel in FED. Procedures for nuclear fuel inspection and i
visual exanunation 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 required; 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, armi checklists used by inspection personnel provide the following:
1.
Identification of characteristics to be inspected.
2.
Acceptance and rejection criteria.
3.
Description of the method ofinspection.
4.
Identification of required procedures, drawings and specifications.
5.
Identification ofinspector or data recorder.
6.
VeriScation of completion and certification ofinspection.
7.
Record of results ofinspection.
8.
Provision for identifying mandatory inspection hold-points for witness for an authorized inspector or BGE inspection personnel.
9.
Provision for indirect control by monitoring processing methods, equipment, and personnel if direct inspection is not possible.
10.
Specification of necessary measuring and test equipment including requirements for in. aracy.
The Genem! Supervisor. Quality Verification (GS4V) is responsible for the preparation and implementation of procedures for inspection and surveillance activities performed by or for QV. (11) 3 Other inspections are conducted randomly to verify that overall plant operations are being conducted d
according to approved procedures and to ensure that the use of jumpers is properly documented that l
equipment is retumed to operating status after test, modification, or repair; that instruments are properly calibrated; and that personnel who perform tests are properly trained and qualified.
in-service inspections are performed on pressure-containing components within the reactor coolant system
]
boundary according to requirements of the TSs.
In-service inspections and exammations on components designated Class I or Class 11 by the ASME Code are witnessed or otherwise verified by an authorized Code Inspector who is responsible for ensuring that the work is performed by qualified personnel according to written qualified procedures. Records of in-3 service inspections, results, corrective action required and taken, inspection standards required for repair, and results of inspection of repairs are maintained and compared with the results of subsequent ~
j examination.
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QUALITY ASSURANCE POLICY Revisien 41 i
1B.I1 TEST CONTROL To demonstrate the abihty of SR and designated NSR structures, systems, and components to function as designed, they are subjected to a program of surveillance and operational testing. Procedures specify.the systematic development, review, approval, and conduct of tests and review of test results. Conditions such as failures, malfunctions, deficiencie,9, deviations,'and non-conformances' discovered during testing are documented and evaluated.
i 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 that g
have been written and approved in accordance with basic requirements.
3 j.
Nuclear Engineering Department, and CCNPPD conduct tests to verify that' plant behavior conforms to design criteria, ensure that failure and substandard performance are identified and controlled, and demonstrate satisfactory performance after plant modification and maintenance activities.
I Written test procedures are developed, reviewed, and approved before testing is performed. They specify instructions for testing, methods of test, test equipment, and instrumentation; and for the following as applicable:
1.
Adequate and appropriate equipment.
2.
. Preparation, condition, and completeness ofitem to be tested.
"*^b 3.
Suitable and controlled environmental conditions.
4.
Mandatory inspection bold-points for witness by BGE inspection or authorized inspector personnel.
5.
Provision for data collection and storage.
I h
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.
1 Test results are documented and evaluated: they are accepted or rejected by a qualified, responsible I
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 demonstrate that SR and designated NSR structures, systems, and components and the plant as a unit can operate safely and as designed. SR-
-~
and designated NSR test records are retained as plant history records.
Results of testing performed as part of receipt inspection are evaluated,' accepted and approved by qualified NSSD personnel. (5)
Page 34 of 59
QUALITY ASSURANCE POLICY Revision 41 1B.12 CONTROL OF MEASURING AND TEST EOUTPMENT Calibration controls have been established to prescribe the technique and frequency of calibration, i
maintenance, and control of measuring and test instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive test equipment used in measuring, inspecting, and monitoring SR' and i
designated NSR components, systems, and structures during the operations phase of CCNPP.
Personnel of the following functional organizations control, calibrate, and adjust measuring and test equipment:
System Operation and Maintenance Depanment l
Calvert Cliffs Nuclear Power Radiation Safety Plant Department
- Performance Engineering Unit
- - Mcchanical Maintenance
- Electrical and Controls Nuclear Operations Chcmistry 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, instmments,.and'rciated testf
'and measuring devices are of proper r.ccuracy 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. These 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.
g 3.
Acceptance criteria to be used and special precautions to be taken when necessary.
Measuring and test equipment that require calibration are assigned an identifying serial number.
Instruments are calibrated at specified intervals according to the required accuracy, purpose, degree of usage, stability characteristics, and other conditions that affect the measurement.
1 When equipment is found out of calibration, an evaluation is made by the supervisor responsible for that equipment to determine any adverse effect on items previously accepted on the basis of using that I
equipment.
Test and measuring equipment that cannot be ad, lusted 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.
The status of each item contmiled under the calibration system is recorded and maintained. Equipment is marked or records of calibrations are maintained to indicate calibration status. An 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.
7
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l QUALITY ASSURANCE POLICY i
Revision 41 j
l Measuring and test equipment is controlled to prevent the use of uncalibrated or defective equipment, the i
spread of radioactive contamination, the introduction ofimpurities into high-purity systeras, and damage to
- or loss of equipment. Identification tags are placed on measuring and test equipment to indicate such j
special conditions as radioactive cleanliness, special limitations, or failure to meet established calibration requirements.
Measuring and test equipment is calibrated and adjusted at specified intervals, or before use, against certified standards. Reference and transfer standards are traceable to nationally recognized standards; or, where national standards do not exist, provisions are established to document the basis for calibration.
1B.13 IIANDLING. STORAGE. AND SHIPPING Appropriate and special requirements for handling, pres ~ervation, 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 emironmental conditions as temperature or I
humidity.
Special handling, preservation, storage, cleaning, packaging, and shipping activitics associated with SR and designated NSR items are performed by suitably trained personnel in accordance with specific written procedures.
Controls have been established for the cafe 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 ofdesignated shelf-life periods, 1B.14 INSPECTION. TEST. AND OPERATING STATUS C
Controls have been established for the application and r:moval of status indicators such as tags, markings, labels, and stamps to ensure that the inspection, test, and operating status of SR and designated NSR structures, systems, and components is clearly indicated at all times.
Procedures / instructions are prepared to identify and control inspection, testing, and operating status by the use oflogs, forms, and tags that identify the inspection, test, and operating status of structures, systems, and components; control the use of indicators, including the authority for their application and removal; control bypassing operations, such as jumping or temporary removal of electrical leads; and identify non-conforming, inoperative, or malfunctioning structures, systems, or components.
Senior shift personnel are responsible for aligning, isolating, and appropriately tagging installed equipment and systems so that activities affecting quality can b performed.
The Manager-NQAD is responsible for the performance of surveillances to verify that the inspection, testing, ar.d operating status of structures, systems, and components are properly identified and controlled during operation, maintenance, and testing of the plant.
The bypassing of required inspections, tests, and other critical operations is controlled to ensure that 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 prevcat inadvertent use.
Page 36 of 59
r; QUALITY ASSURANCE POLICY Revision 41 18.15 NONCONFORMING MATERIALS. PARTS. OR COMPONENTS (6)
Controls have been established for identifying, documenting, segregating, reviewing, dispositioning, and notifying affected organintions ofIssues affecting materials, parts, or components (i.e., itenu).
Issues,affecting nuclear plant items are referred to as nonconformances.~-Nonconformances are hardware deficiencies which render the quality of an item unacceptable or indeterminate.
Any individual identifying an actual or suspected noncc.nforming item is responsible for documenting 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 segregation i
I to prevent inadvertent installation or use.
Nonconformance control documents are submitted to responsible departments for resolution. Desi nated 6
personnel have the responsibility and authority for approving the resolution of nonconformances.
Nonconformance control documents are not closed until corrective actions have been completed.
Nonconfonning 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 evrduated and approved or rejected by the RDO.
j Reworked, repaired, and replacement items are inspected and/or' tested in accordance with 'the original'
' inspection and/or test requirements or acceptable alternatives to ensure that critical characteristics p..ssibly j
affected by the nonconformance remain acceptable.
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 Specification operability may be released for use following verification that the nonconforming item meets all operability requirements specific to its function and is approved for use by authorized Operations personnel. Conditionally released items will be resolved in accordance with this Section. Conditional release evaluations are documented, reviewed, and approved prior to implementation.
1B.16 CORRECTIVE ACTION (6) l Controls have been established :o ensure that issues are identified, documented, reviewed, and corrected.
g Rese controls are applied to deficiencies associated with the progranunatic content, process, and implementation of the Quality Assurance Program as well as nonconformances (ref Section 1B.15).
I
)
5 Corrective actions are implemented by responsible personnel and may include immediate actions, remedial actions and/or actions to prevent recurrence, based on the significance and extent of the Issue.
Issues identified as potentially impacting the safe production of nuclear power are evaluated for Technical Specification Operability, NRC Reportability, Nuclear Safety Significance, and if the actisity should be stopped. De VP-NED, er designated alternate, is informed ofIssues which require NRC notification.
Corrective action verification is performed for Significant Issues prior to the close-out of the corrective action document. Verification is performed and documented by individuals not directly involved with implementing the corrective action (s). Unacceptable corrective action (s) are reported to supervisory or management personnel directly te' ponsible for resolving the Issue and to progressively higher levels of s
management until the issue is resolved.
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QUALITY ASSURANCE POLICY Revision 41 l
Signi5 cant Issues require a root cause analysis and the implementation of corrective actions to prevent recurrence and are reported to management for resiew and assessment.
lasues are periodically analyzed for the identification of adverse quality trends. The existence of an adverse quality trend is resolved in accordance with this section. A Trend Report is issued to management at intervals specified in approved procedures.
t 1B.17 OUALITY 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 actisities. Applicable design specifications, procurement documents, test procedures, operational procedures,.QAPs, TSs, and other documents specify records that should be generated, supplied, or maintained by and for BGE.
Quality assurance records are classified as lifetime or non-permanent.
Lifetime records, maintained for particular items for the life of CCNpP, for particular items have significant value in relation to demonstrating capability for safe operation; maintaining, reworking, repairing, replacing, or modifying an item; detennining the cause of an accident or malfunction of an item; and providing required baseline data for in-service inspection.
Non-permanent records, which show evidence that a SR and designated NSR activity was performed in accordance with applicable requirements, are retamed for periods sufficient to"casure BOE's ability t63 l reconstruct significant events and'to satisfy applicable regulatory requirements.' Retention periods ard' based o requirements specified in QA Program documents. Retention periods shall be documented.
Procurement documents specify vendor responsibilities for the generation, retention, and submission to BGE of quality assurance documentation related to the fabrication, inspection, and test of SR and l designated NSR items and services.
Inspection and test records contain the following as appropriate:
I 1.
Description of the type of observation.
g t
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 aro transmitted to the Records Management l
Unit for incorporation into the Long Term Records Storage and Retrieval System.
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QUALITY ASSURANCE POLICY Revision 41 IB.18 AUDITS Internal audits are performed by BOE's Quahty Audits Unit to ensure that activities and procedures established to implement the requirements of 10 CFR 50, Appendix B, comply with BGE's overall QA Program. These audits provide a comprehensive independent verification and evaluation of quality-related activities and procedures. Audits ensure the effective and proper implementation of BGE's QA Pmgram. l They are scheduled on the basis of the importance to safety of activities being perfcrmed.
Vendor audits are performed to evaluate QA programs, procedures, and activities. Audits of major vendors y
are made early enough to ensure compliance with all aspects of BGE's procurement doctunents. Additional audits are performed as required to ensure that all requirements of BGE's QA Program are properly implemented according to procurement documents.
Au n:s of designated activities as required by the TSs are performed under cognizance of the OSSRC.
A idits are performed in accordance with preestablished written procedures or checklists by qualified NO AD personnel who have no direct msponsibility for the work being audited. Technical specialists from othu BGE departments and outside consultants may assist as necessary in performing audits. Audits l include objective evaluation of quality-related practices, procedures, instructions, activities, and items, as well as review ofdocuments and records.
Reports of audits are analyzed and documented. Results that indicate the QA Progmun to be inadequate, ineffective, or improperly implemented, including the need for re-audit ~of deficient areas, are1feported to th6)
Manager and Supervisor.of the audited activity. ~ Controls have been established 'for verifying that' corrective action is taken promptly to correct noted deficiencies.
To ensure that BGE's NQAD complies with the requirements of BGE's QA Program, an independent l l
management audit of NQAD activities is performed annually by a Joint Utility Management Audit (JUM M Team.
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i QUALITY ASSURANCE POLICY Revision 41 t
TABLE IB-1 j
t BALTIMORE GAS AND ELECTRIC COMPANY'S POSIT 10N ON GUIDANCE CONTAINED IN ANSI STAND tRDS Revision ofindustry Standards Aoplicable to the Baltimore Oas and Electric Ouality Assurance Program Reavirement Some of the Industry Standards listed in Section iB.2 identify other Standards that are required, and some
?
Regulatory Guides define the revisions of those Standards that are acceptable to the NRC.
Response
BGE's QA Program was developed to respond to the specific revision of the documents listed in Section l iD.2 and is not necessarily responsive to other documents listed in the referenced Industry Standards.
ANS 3.2 - 1976 Itemi Requirement Section 5.2.15 requires that plant procedures shall be reviewed ty an individual knowledgeable in the area affected by the procedure every two years to determine if changes are necessary or desirable.
Response
BGE applies this requirement of a two-year review to all plant procedures except test procedures performed; l less often than every two years or at unspecified frequencies. These are reviewed no more than 60 days before performance.
Beason l
Engineering Test Procedures (ETPs) and others like them are written for a one-time-only performance and kept for reference for future similar tests. If they are used again, they are reviewed and modified to meet conditions existing at the time of perfonnance.
Some Surveillance Test Procedures (STPs) are performed every three to five years. They too are reviewed herom each performance to ensure that they are compatible with existing conditions and responsive to current needs.
Jtem 2 00)
Remlitsment Section 5.2.2 specifies that temporary procedure changes that clearly do not change the intent of the approved procedure shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedure; and at least one of these individuals shall be the supervisor in charge of the shift and hold a senior operators' license on the unit affected.
Page 40 of 59
QUALITY ASSURANCE POLICY Revision 41 I
Besponsq 11GE ducs not require the Shift Supervisor to be the Senior Reactor Operator (SRO) approving temporary l changes to procedures; any active SRO (either on-shift or on-staff) may provide the SRO approval for j
procedure changes.
I i
Many proposed temporary procedure changes do not require the Shift Supervisofs immediate attention or knowledge of the change since they do not affect plant safety. Other SROs are available and qualified to perfomi this task since the Shift Supervisor's detailed review of the proposed change is not necessary to ensure plant safety.
1 Requiring the Shift Supervisor to review all changes is burdensome and contrary to plant safety in light of i
the total number of procedures that exist and the time the Shift Supervisor must dedicate to ensuring the i
plant is safely operated and maintained. Additionally, our Technical Specification mquires this approval bc from someone holding an SRO license (not necessarily the Shift Supervisor).
ANSI N18.1 - 3/8/71 s
item 1 Ecquirem.tr!1 l
Paragraph 4.2.2 states that at the time ofinitial core loading or appointment to the active position, the Operations Manager shall hold a Senior Reactor Operator's (SRO) License.
l Paragraph 3.2.1 states that positions at ti.e functional level of Manager are those to which are assigned broad responsibilities for direction of major aspects of a nuclear power plant. This functional level generally includes the plant manager (plant superintendent, 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 i
msponsibility for operation of the plant or for its maintenance or tecimical scrsice activities.
Response
Baltimore Gas & Electric has two positions in its organization, Superintendent-Nuclear Operations 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 Superintendent-Nuclear Operations will satisfy l paragraph 3.2.1 and most of 4.2.2 except that he will not maintain an SRO license. Instead, the Superintendent-Nuclear Operations will hold or have held an SRO license. The GS-NPO will hold and l maintain an SRO license. The GS-NPO satisfies paragraph 4.2.2, but he does not satisfy 3.2.1 because he does not report directly to the plant menager.
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QUALITY ASSURANCE POLICY Revi~ ion 41 Brasso The Superintendent-Nuclear Operations will hold or have held an SRO license, as opposed to having a l license at the time of appointment to the position. He will have an excellent understanding of plant E
operstions. The GS-NPO will not only hold an SRO license at the time of appointment to the position, but he will maintain the license. The GS-NPO directly supervises the operating shift orgamntion, whereas the l
Superintendent-Nuclear Operations is also responsible for operations procedure development, modifications acceptance, and operations / maintenance coordinations. The Superintendent-Nuclear Operation's level of supervision does not require current in-<lepth and plant specific knowledge which results from maintaining an SRO license.
ANSI N45.2.1 - 1973 Reauirement Subsection 3.2 outlines requirements for demineralized water.
Ecmans BGE specifications for demineralized water are different than the specifications outhnnd in the standard.
Reason DGE specifications for demineralized water are consistent with guidelines provided by the Nuclear Steam Supply System supplier. BGE specifications are generally more restrictive than those specified by ANSI N45.2.. l.
ANSI N45.2.2 - 1972 Item I R auirement Subsection 2.4 could be interpreted to mean that on-site and off-site personnel who perform any inspection, examination, or testing activities n: lated to the packing, shipping, receiving, storage, and handling ofitems for nuclear power plants shall be qualified in accordance with ANSI N45.2.6.
Responig BGE requires that only persons who are responsible for approving items for acceptance shall be qualified l in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6) and that personnel who verify that storage areas meet requirements will be qualified to either Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or ANSI N45.2.23.
Eggagn Our receipt inspection procedures require persons who approve items for acceptance to be qualified in accordance 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
QUALITY ASSURANCE POLICY Revision 41 exarrunation, and testing activities are subject to review by persons qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6).
11ern2 1
f Reauirement The second sentence of Subsection 2.4 requires that:
f l
1 Off-site inspection, examination, or testing shall be audited and monitored by personnel l
who are qualified in accordance with ANSI N45.2.6.
j
Response
BGE uses personnel qualified in accordance with ANSI N45.2.23 to perform auditing and monitoring l functions.
Brason I
The qualification requirements for nuditors cannot always be met by persons qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2 6).
Item 3 Reauirement Subsection 2.7 requires that activities covered by the Standard shall be divided into four levels, though recognizing that within the scope of each level there may be a range of contmls depending on the importance of the item to safety and reliability.
9 E m nss i
1.
The level of protective measures defined by Subsection 2.7 are applied to Basic Component purchases.
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2.
Personnel of BGE's Nuclear Engineering Department (NED) will determine the level of protective l measures to be applied to Ccmmercial Grade purchases.
d.
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QUALITY ASSURANCE POLICY Revision 41 l
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Reas9D 1
l BGE's position is as follows:
1.
For Commercial Grade items, it is not always possible to assi n a level of classification in j
E
. accordance with ANSI N45.2.2, as many items are purchased after they~have been packaged by the i
manufacturer and shipped to his local agent, the wholesaler.
2.
Experience has shown that the level of protection assigned to Commercial Grade items by vendors is adequate.
Item 4 Reauimnet Subsection 3.0 specifies detailed requimments for packing items for each level defined in Subsection 2.7.
Response
BGE has replaced Section 3.0 with the following:
i I.
Packaging for Shipment to BGE Personnel ofBGE's NED or NSSD shall ensure that procurement documents for Basic Coinponent' and Commercial Grade item purchases either indicate that the normal methods of packaging and shipment used by industry in general are acceptable for the items being procured or specify the level of protection assigned to the item and the requirement that the vendor conform to applicable requiiements for items in that classification defined in Regulatory Guide 1.38, Rev. 2 - March 1977.'
t i
2.
The normal methods of packaging used by the industry in general are acceptable for items being procured as Commercial Grade, g
3.
Packaging for Storage by BGE In general the packaging used by the vendor to ship items for all types of purchases to BOE need not be retained after the item is received by BGE, 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 i
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 requirements of Section 6 4.2 of ANSI N45.2.2 - 1972 apply.
Rmon i
1.
This substitution will ensure that the item will receive adequate protection during shipment.and storage, thus eliminating unnecessary restrictions and enabling BGE to use commercial sources to l the utmost.
/
2 Experience shows that industrial practices for packaging Commercial Grade items are adequate for most applications.
Page 44 of 59
QUALITY ASSURANCE POLICY Revision 41 Ilt!!LE l
Esquittulent Section 4.0 defines shipping requirements related to the protection levels assigned to items.
Bnnonse
{
{
BGE has replaced Section 4.0 with the following:
1 1.
Shipping to Baltimore Gas and Electric BGE will invoke the requirements for. shipping specified in Section 4.0 of ANSI N45.2.2 - 1972 on l Basic Component purchases only when NED or FSSD personnel have specified in procurement documents that the item shall be packaged in conformance with ANSI N45.2.2, Section 3.8.
BOE will not mvoke the requirements of ANSI N45.2.2 -(1972, Section 4.0, on Commercial Grade l item purchases.
2.
Shipping from Baltimore Gas and Electric t
Items shipped from BGE need not conform to any of the requirements of ANSI N45.2.2, but the j orgamzation that packs and handles the item shall provide roughly the same ic~ vel of-protection thatv the item was given during shipment to BGE.
Rt.ason if engineering personnel have determined that the vendor's methods of packaging are acceptable, they have already determined that the supplier's methods of shipping are adequate. As items are shipped from BGE l only for repair, the detailed requirements specified in Section 4.0 of ANSI N45.2.2 are not necessary.
Item 6 Reauirement Subsection 6.4 gives detailed requirements for care ofitems in stomge, according to the protection levels assigned to the items.
Response
BGE does not require items to be stored in the packing used for shipment if the storage level in the area l 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 persons who move it are responsible for ensuring, as applicable, that additional packing is supplied to give adequate protection during transportation.
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QUALITY ASSURANCE POLICY.
Revision 41 Reason The degree of protection given an item during storage should be tailored to the importance of the item to safety and the probability of deterioration during storage; to base storage requimments purely on the categories in Subsection 2.7 of ANSI N45.2.2 - 1972 is impractical. BGE requires NED or NSSD l t
personnel to specify requirements more closely related to the actual function of items and to storage conditions.
item 7 r
Reapir. cmc.at Subsection 7.3.3 requires compliance with a series of ANSI documents.
Response
DOE controls for the use of hoistmg equipment are compatible with the Standards listed in Subsection l 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 oflBGE personnel to properly handle SR items and could lead to confusion.
'5 ANSI N45.2.3 - 1973 Item 1 Be@irement e
Subsection 2.1 outlines housekeeping cleanliness requirements for five designated zones.
i Resnonso 1
BGE 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 BGE's class 3.
j Reason 3
.Is ANSI Zone I level of cleanliness applies to new construction activities.
2.
Where required, smoking restrictions are posted for DGE's class 3 areas.
Item 2
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Eeauirement 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 46 of 59
QUALITY ASSURANCE POLICY Respose i
BGE has established the followmg methods for penonnel and matenal accountability:
1.
Written accountability.
2.
Where possible tethering of tools and materials to pennanent plant structures or persons.
3.
Post-maintenance closeout inspections.
Ecanon BGE's three methods of accountability offer the same level of control as that required by the standard ANSI N45.2.4 - 1972 Reauirement The last paragraph of Subsection 6.2.1 (Equipment Tests) states:
Items requiring calibration shall be tagged or labeled on completion mdicating.date of"' T
- calibration and identity of person that perfonned the calibration.
Response
The new calibration' program at Calvert Cliffs does not use calibration stickers that contain date of calibration and idatity of person that performed the calibration. %c new calibration stickers indicate that l
the instrument is periodically calibrated according to the calibrmion program. The sticker, a green "C,"
i means the instrument is in the program j
Reason i
i In the past, the date of calibration noted on the instrument was important because the calibration history of preventive maintenance was not kept on computer. Computer trackmg systems and trendmg programs did -
not exist. In the new system, the date of calibration bemg on the stickur is not necessary because the date of calibration and the identity of the person that performed the calibration is retrievable in the PM history in Nucleis according to equipment ID. Calibrations ofinstruments are scheduled and tracked by computer.
We are going into a real predictive and preventive==inhance calibration program.
Calibration frequencies will be shifted based on calibration history, PRAs, vendor's recommendations, and instrument use.
A database exists which controls what instruments are added to or deleted from the program
.By maintaming the database, we ensure that no instruments are identified as calibrated that are not. In the new program mstruments identified as calibrated are kept up to date and specific information is kept on computer with no need for that information to be on the sticker.
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QUALITY ASSURANCE POLICY Revisi n 41 l
item 1 Reauirement
{
Subsection 1.2 states in pan, The requirements of this standard apply to personnel who perfonn inspection, examination, and tests during fabrication prior to and during receipt of items at the constmetion site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.
Resoonse-A Personnel of BGE's Quality Assurance organizations who perform independent verification through inspections, examinations, or tests at the plant site during operational phases of the nuclear power plant are required to be qualified in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1,1971. All other BGE personnel who perform inspection, exammation, 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.! - 1971.
Reason-A 1,
'Ihc individuals who perform inspection, examination, and testing functions associated with nonnal operation of the plant, such as maintenance and certain technical reviews, are normally qualified to ANSI N18.1 - 1971.
2Property "ANSI code" (as page type) with input value "ANSI N18.1 - 1971.</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Some testing activities conducted during normal operation of the plant, such as surveillance testing, do not require that test personnel meet the requirements specified in Paragraph 4.5.2 of ANSI N18.1 for tecimicians. Personnel qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) are adequately qualified to conduct such testing.
Response-B BGE does not always require vendor personnel performing inspection or test activitics to comply with the l requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) but evaluates the need for invoking Regulatory Guide 1.58 (which endorses ANSI N45.2.6) on the vendor during the review of procurement documents. The requirements are not applied to procurement classified as Commercial Grade.
Rcason-B BGE's position in as follows:
l.
For replacement items purchased as Commercial Grade Items, the purchaser may not impose nnclear unique requirements on the vendor.
Additionally, items may be manufactured before placement of the purchase order and the vendor may not be required to maintain records of the performance ofinspections or tests.
2.
For Basic Component Purchases, the qualification requirements for inspection, examination, and test personnel are determined by:
Item status (new or replacement).
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J
. QUALITY ASSURANCE POLICY Revisi~n 41 b.
Complexity and importance ofitem.
Manufacturer's QA program approval level (Appendix B, ANSI N45.2, etc.).
c.
Response-C BGE does not require personnel who perform specific limited and repetitious inspection functions, such as l inspection for removal or replacement of snubbers, to be trained as required by Regulatory Guide 1.58 (which endorses ANSI N45.2.6).
Reason-C i
inspections, examinations, or tests that are repetitious or of limited scope need not be performed by l
individuals qualified to the requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) provided that they receive instruction in the following:
r 1.
Actsvities to be verified.
2.
Acceptance criteria.
3.
Method of documenting results.
4.
Method of reporting deficiencies.
The person responsible for the inspection activity ensures that such instruction is given to inspectors before they perform specific inspection functions, and that both this training and the acceptability of the results of the inspection are documented.
Resoonse-D When it is necessary to monitor the activitics of a vendor, BGE uses personnel qualified as auditors in l accordance with ANSI N45.2.23 or inspectors in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6).
Reason-D Both Regulatory Guide 1.58 (which endorses ANSI N45.2.6) and ANSI N45.2.23 establish training requirements suitable for monitoring vendor activities.
Item 2 Reauirement Table I specifies that Level 111 personnel shall be capable of qualifying Level 111 personnel.
Respons When there is only one Level 111 position or when a new Level Ill position is created, BGE personnel with l the title Ocneral Supervisor, or higher, qualify Level 111 personnel.
8.saSAr}
BGE personnel in these grades are capable of certifyics Level 111 personnel without being trained as Level l 111 inspectors.
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1 QUALITY ASSURANCE POLICY Revisi n 41 NOTE:
Regulatory Guide 1.58 (which endorses ANSI N45.2.6-1978) statesin
{
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~eamed 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 afict November 27,1984, in addition to the present commitment to ANSI N45.2.6-1978 for the qualification of such personnel.
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ANSI N45.2.9 - 1976 Item 1 Requirement Section 4.0 titled "Roccipt" gives instructions for receipt controls.
Enponse BGE applies these requirements only to the receipt of records by the Plant History File.
Reason Most records received by such organizations as Receiving Inspection, Engineering, etc., are not shipped in a manner that makes these requirements applicable. These requirements are applicable, however, when the records am finally turned over to the Plant History File.
Item 2 i
Reouirrment Subsection 5.6.1 reads as follows, " Design and construction of a single record storage facility shall meet t
the following cntena:" Items a) and b) of the subsection state that:
"a)
Reinforced concrete, concrete block, masonry, or equal construction."
"b)
A floor and roof with drainage control. If a floor drain is provided, a check valve (or equal) shall be it.cluded."
Response / Reason itern.a
'Ihe intent of this requirement is both structum! integrity and fire resistance. This vault is entirely l
enveloped by a stnicturally 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, the walls of the vault are constructed of gypsum wallboard on metal studs p?r Underwriters Laboratory Test Number U412, Page 50 of 59
QUALITY ASSURANCE POLICY Revisisn 41 assuring the equivalent of 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire resistive construction. This is equal construction to concrete block in
. terms of fire protection. The walls carry no structural load; hence, they provide equivalent structural integrity to that needed of concrete block.I (See footnote following page).
7 Response / Reason Item b Again, the vault is contamed within an environmentally protected building. As such, it has no roof, or need for floor drain.1 (See footnote).
Item 3 Ruauirement Subsection 5.6 allows only the dual facility defined in Subsection 5.6.2 as an alternative to the single facihty defined in Subsection 5.6.1.
&csponse BGE allows the following altemative storage requirements for organizations other than the Records l 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 attematives'to-the requirements specified for the Records Management Unit:
1.
Duplicate Storage Either A or B.
A.
Within 30 days of completion of a record, a duplicate record file shall be established. This activity shall be controlled by procedures widch 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 goveming access to and control of files.
6.
Methods for maintaining control of and accountability for records removed from the file.
l'Rese responses have been forwarded to the NRC by the BGE letter dated 02/11/83 from Robert l G. Nichols, Sr. Facilities Project Administrator, Real Estate and Office Services Department, to Terry L Harpster, Chief QA Branch, Division of QA, Safeguards and Inspection Programs, IE, USNRC. These responses have also been accepted by the NRC in their letter dated 04/22/83 from Walter P. liaass, Deputy Chief, QA Branch, Division of Quality Assurance, Safeguards, and Inspections Programs, Office ofInspection and Enforcement.
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n QUALITY ASSURANCE POLICY f/
Revisi"n 41 t
t I
7.
Method for filing supplemental infonnation and disposing of superseded or obsolete records.
l 8.
Method for p.escrying records to prevent deterioration.
j 9.
Method for maintaining specially processed records that are sensitive to light, pressure, or temperature.
10.
Transfer of duplicates to the Records Management Unit within two years of completion of records.
i D.
Make arrangements with at least one other department that mccives a copy of each document to subject this other copy to the controls specified above.
2.
Fire-resistant Building Storage i
Records shall be stored in steel cabinets located in a fim-resistant building or a non-combustible building with a fire suppression system.
The procedural controls defmed for duplicate storage shall be applied.
3.
Non-fire-resistant Building Storage
~
~
Within non-fire-resistant facilities, records shall be stored in UL one-hour-minimum fire-rated -
storage cabinets and be subject to the procedural controls defined for duplicate storage.
BGE 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 BGE's Corporate Finance Group.
Esson Although these alternatives are compatible with standard methods of handling records, they do not materially decrease the level of protection afforded to the records.
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Item I i
Recuirement 2.3 Qualification of Lead Auditors Section 2.3.1 requires prospective Lead Auditors to obtain a rmmmum of ten credits under the scoring system defined in paragraphs 2.3.1.1-2.3.1.4.
Response
BGE has revised the scoring system as follows:
Page 52 of 59
I QUALITY ASSURANCE POLICY Revi-isn 41 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) 1.1 For the Associate degree for an accredited institution, score one credit, if the degree is i
in engineering, physical sciences, mathematics, or quality assurance, score two credits.
Or, for the Bachelor degree from an accredited institution, score two credits; if the degree is in engineering, physical sciences, mathematics, or quality assurance, score three credits.
1.2 For the Master degree in engineering, physical sciences, business management, or quality assurance fmm an accredited institution, score one credit.
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 specified above for the degree.
1.4 For the successful completion of Navy Nuclear Traini9=, its equivalent in another armed service, or the training required for becomin licensed operator in a l
s commercial nuclear power plant, score two credits.
2.0 Experience (9 credits maxunum) 2.1 Techrdcal Experience (5 credits maximum)
For experience in engineering, manufacturing, construction, operation, or maintenance, score one credit for each full year.
2.2 Nuclear Experience 1
If two years of tecludcal experience have been in the nuclear field, score one additional j
credit.
j 2.3 Quality Assurance Experience if two or more years of the technical experience have been in quality assurance or quality control, score two additional credits. Persons whose work activitics are controlled by the QA Program but who are not full-tirne members of the QA organization may be awarded half the credits that would be given to a person.with specific quality assurance experience.
2.4 Audit Experience If two or more years of the technical experience have been in auditing, score one additional credit.
2.5 Supplemental Experience Persons who have a proportion of the experience specified in 2.1-2.4 may be awarded a corresponding percentage of the credits specified.
i Page 53 of 59
QUALITY ASSURANCE POLICY Revision 41 2.6 Time exclusively spent in training does not apply as credit towara expenence l
requirements for lead auditors.
3.0 Training (2 credits maximum) i Persons who have successfully completed the training requirements of ANSI N45.2.23 may l
be given two credits.
4.0 Rights of Management (2 credits maximum)
The Manager-NQAD, may grant additional credits for other performance factors applicable to auditing as follows:
4.1 For certification of competence in engineering or science related to nuclear power i
plants, or in quality assurance specialties, issued and approved by a State Agency or l
National Professional or Technical Society, score two credits.
4.2 For nuclear experience in excess of 2 years, scou, one credit for cach two years experience.
4.3 For practical experience $.: sn be r-lated to power plants, in excess of 5 years, score one credit for each two years of me ience.
cr Reason BGE is in agreement with the basic purpose of ANSI N45.2.23-that is, to establish minimum educational l '
or experience requirements for L, cad Auditors. We thmk, however, that the system of credits outlined in ANSI N45.2.23 tends to reduce the size of the pool of potential replacement auditors without makmg redeeming improvement in the capabilities of persons selected.
We calculated the credit score of 1I 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 Nuclear Program. Four of these scored only 8 credits total, including 2 credits allowcxl by paragraph 2.3.1.4 of ANSI N45.2.23 for rights of management based on their having completed the BGE QA training programs l for Lead Auditors.
One of our auditors, with neither nuclear nor power plant experience, had a credit score of 12 because he held a Bachelor's degree in engineering and was a professional enginees with over 5 years design i
experience.
Because all of these individuals have acted as Lead Auditors satisfactorily for several years, it appears that the credit system should be revised slightly to allow for the differences in education and experience of prospective Lead Auditor candidates.
I 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 Auditor, but will exclude a person who has no degree, even though he may have 20 years' experience 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, Page 54 of 59 4
1 QUALITY ASSURANCE POLICY i
Revision 41 l
i For these reasons, we think that the supervision of prospective Audit Team Leaders should be given more j
flexibility in determining whether, for a particular individual, educational or professional qualifications are more signincant and valuable than past experience.
The present credit system, while recognizing the Associate degree, gives no credit for completion of the nuclear training programs. We think that someone who has taken Navy Nu' clear Training or its equivalent in another armed service, or someone who has completed the training required to become a licensed j
operator in a commercial nuclear power plant, should receive the same credit as a person who has an j
Associate degree fram an accredited institution in enginecring, physical sciences, mathematics, or quality assurance.
The points now awarded for education are related to the effect that formal courses might have on the ability I
ofindividuals 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. Persons who have completed part of a degree course should receive a percentage of the credits a
allowed for that course.
The requirements for training specified in ANSI N45.2.23, paragraph 2.3.2, would seem to ensure that prospective Lead Auditors will meet the requirements of paragraph 2.3.1.4 dealing with the rights of management. We think, therefore, that all prospective Lead Auditors should qualify for these two credits.
f Similarly, the present system recognizes the effect that working in a QA Program will have on the ability of a person to comprehend regulations and technical requirements. Persons who are not assignedias' full-time t
members of the QA Organintion, however, receive similar exposure if they perform activities controlled'tiy*
i a QA Program. We therefore allow such persons half the credits specified for quality assurance expenence.
Item 2 Requirement 3.3 Requalification Lead Auditors who fail to maintain their proficiency for a period of two years or more shall be requised to requalify. Requalification shall include retraining in accordance with the requirements of paragraph 2.3.3, reexamination in accordance with paragraph 2.3.5, and participation as an Auditor in at least one nuclear quality assurance audit.
Response
BGE requalifies Lead Auditors on the basis of the satisfactory perfotmance of one audit, as observed by a l qualified Lead Auditor.
Reamn He purpose of the training specified in paragraph 2.3.3 of the Standard is to ensure that candidates i
understand the fundamentals of auditing and the requirements for activities to be audited. The fact that persons have not maintained their proficiency does not mean that they need complete re-training; it means only that they have not been able to review and study the applicable Co it.structions, and other documents related to QA Programs and program auditing. BGE considers that the satisfactory perfonnance of an audit under the observation and guidance of a qualified Lead Auditor should ensure that persons with lapsed certification will review and understand the pertinent documents.
Page 55 of 59
QUALITY ASSURANCE POLICY Revision 41 i
)
i ANSI N101.4 - 1972 Reauirement Section 1.2 specifies applicability requirements for the Standard.
j f
Resnonse BGE requires that only activities performed inside containment structures and related to protective coatings l applied to ferritic steels, aluminum, stainless stect, zine-coated (galvamzed) steel, concrete, or masonry surfaces shall conform to applicable Sections of ANSI N101.4.
Ecason Deterioration of protective coatings applied to surfaces outside contaimnent structures would have no detrimental effects on the safe operation of the plant.
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, i
t Resnonse BGE has two approaches for safety-related and designated non-safety related procurement as described in l Sections, IB.4 and 18.7.
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 Conuncreial 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.
i Page 56 of 59
QUALITY ASSURANCE POLICY Revisi?n 41 ATTACIIMENT A-1 i
BASES FOR QA POLICY REVISIONS (1)
Entry PRF-Q A
No.
Bases for Revision (s) 1.
771 Procedure Ungrade Action Plan (PUAP). ocr L. B. Russell letter 1-20-89.
2.
783 10 CFR Part 71 requirements.
3.
707 NRC Inspection #89-16/89-17 (Letter from R. E. Denton to R. P. Heibel dated July 13.1989.)
4.
824 NRC letter from M. W. Hodges to G. C. Creel dated March 13.1990. This lettcr I
approved a one-time evmotion to the n riodic review recuirements for orocedur_eg e
scheduled to be uneraded by the Procedures Upgrade Project. This exemption was discontinued and removed by PRF-O 954.
5.
844 _
Procurement Procram Project uncrade. Performance Imorovement Plan (PIP)r Action Plan #5.3.1 and OAU Audit Findinn 87-13-01 6.
844 18.15 and IB.16 revised to clearly establish program _apolicability and controls.
consident terminnloev_ organizational _ responsibilities and focused nonroach towards develonina and implementine an interrated Manancment System.
7.
891 PIP Action Plan 5.3.1 Follow-On Activity.
8.
894
.lIL15 and IB.16 revised to clarify reauirements which will nermit implementation j
of the Issues Manatement System - PIP item 4.10.0.
9.
854/907 O. C. Creel letter to the NRC dated 7/26/91 which discussed modifications to. and acceptance of. changes to the OA Policy involvine OA comoliance resiews of OAPs and_Qinectives.
10, 815 G. C. Creel letter to the NRC dated 10/3/90 discussine temograry chances not affectine "Aonroved Procedure Intent" and the relieving of the Administrative Burden on Shift Suoervisors.
i l
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Page 57 of 59 l
.I i
QUALITY ASSURANCE POLICY Revision 41
(
ATTACIIMENT A-2
[
BASES FOR QA POLICY REVISIONS (1)
Entry PRF-Q D_
D.
Bases for Revision (s) l 11.
887 Audit Findine No 0026-01 (Imolementation of Surveillance Reauirements).
l 12.
954 G. C. Creci letter to the NRC dated 7/3/91 discontinuine the one-time tcrnoorary chance to the periodic review interval anoroved in Basis (4) above.
13.
__ 957 EIP Action Plan follow-on activity (5.3.1).
14.
953 PIP Action Plan 4.1 and NUREG-0737 (TMI Action Plan Reauirerucpts)
I Item I.C.S. Procedure forfeedback of Operatinz Experience to Plant Staff" 15.
990 OAU Surveillance 5-92-28 " Interface Between Facilities Mannoement Denartment l
gnd Nuclear Enercy Division on Projects at Calvert Cliffs." Recommendation 4.2.
16.
998 OA Audit Recommendation 92-04-R03 (ISFSI operational chase).
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Page 58 of 59
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