ML20081A738
| ML20081A738 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/31/1994 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20081A726 | List: |
| References | |
| NUDOCS 9503150269 | |
| Download: ML20081A738 (59) | |
Text
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. QUAlflY ASSURANCE POLICY Revision 42 -
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i RALTIMORE GAS AND ELECTRIC COMPANY 1
Quality Assurance Policy
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for the Calvert Cliffs Nuc1 car Power Plant (Appendix IB of the Calvert Cliffs i
Updated Final Safety Analysis Report)
Date /O!J/ N (1)
Approved
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R. E. Denton Vice President Nuclear Energy Division s
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1 9503150269 950309 Page1of60 PDR ADOCK 05000317 PDR P
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QUALITY ASSURANCE POLICY l
Revision 42, l
TABLE OF CONTENTS i
APPENDIX 1B OUALITY ASSURANCE PROGRAM FOR THE OPERATIONS PHASE Section Page i
IB.1 ORGANIZATION AND RESPONSIBILITIES.........................
.5 1
IB.2 QUALITY ASSURANCE PROGRAM.........
............ 13 IB.3 DESIGN CONTROL.
19 18,4 PROCUREMENT DOCUMENT CONTkOL (5)....
........ 21 l
18.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS....
................. 24 i
iB.6 DOCUMENT CONTROL..
. 24 I
IB.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (5)...
26 1B.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS (5).
.29 18.9
. CONTROL OF SPECIAL PROCESSES..
... 30 iB.10 INSPECTION........
... 32 1B.1I TEST CONTROL...
... 34 1B.12 CONTROL OF MEASURING AND TEST EQUIPMENT....
....................35 4
IB.13 HANDLING, STORAGE, AND SHIPPING............
.36 18.14 INSPECTION, TEST, AND OPERATING STATUS.
. 36 iB. I 5 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS (6)..
........... 37 1B.16 CORRECTIVE ACTION (6)..
.37 iB.17 QUALITY ASSURANCE RECORDS..
.3R 1B.18 AUDITS...
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.kN3 QUALITY ASSURANCE POLICY Revision 42 LIST OF TABLES Table No.
page 1 B-1 BALTIMORE GAS AND ELECTRIC COMPANY'S POSITION ON.
.40 GUIDANCE CONTAINED IN ANSI STANDARDS LIST OF ATTACHMENTS Attachment Letter A
BASES FOR QA POLICY REVISIONS (1).-
. 58 LIST OF FIGURES 1B.1 BALTIMORE GAS AND ELECTRIC COMPANY CORPORATE ORGANIZATION.....
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I QUALITY ASSURANCEFOLICY
-c Revision 42
. LIST OF EFFECTIVE PAGES Latest revision number is listed for pages revised after revision 38.
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- QUALITY ASSURANCE POLICY -
Revision 42 i l
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ORGANIZATION' AND RESPONSIBILITIES
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j All levels of organization have definite and unique responsibilities in assuring safe, economical, and reliable F
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 communk=*~1 to lower levels of the oramahaua mdopendent verification of management controls are performed, results are reviewed, and appropriare actions taken when necessary; Middle level management is responsible for translating management policies, philosophy, commitments, l
'and goals; applicable. federal, state, and local rules and regulations; Operating Licenses, Technical l
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. Specifications (TS), and the Updated Final Safety Analysis Repod (UFSAR) into control programs for aivities such as design, procurement, construction, testing, operation, refueling, maintenance, repair, j
m modification, training,' plant security, fire protection, records, inhpa= lent verification, and corrective i
action. Middle level mant.g.,, wit is also responsible for defining, measuring, and modifying the overall.
effectiveness of control programs; taking appropriate action on the results; and keeping top managenwnt
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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 i
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
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1 problems and takmg preventive actions; ensuring that conditions adverse to plant and personnel safety are promptly identified, reported, and corrected; detecting trends which may not be apparent to a day-to-day i
observer, rcw,veisidnig generic solutions for adverse trends to====3=at, and taking appropriate.
actions, to achieve desired results; ensuring that employees assigned to do a job are properly gaa8M 5
through appropriate training' and experience; have properly qualified procedures, tools, equipment, and parts to do the job, and, ensuring that iaA unt inspections of work are conducted in accordance with p
preestablished requirements. First line non-craft supervisors are responsible to ensure that procedures are j
written, reviewed, and approved; first line craft supervisors may not have this responsibility.
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Non-supervisory personnel acting as job directors are responsible for ensuring that properly qualified procedures 3
3 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 recowww. ding changes when necessary. Procedures with the potential to affect nuclear or personnel safety shall be strictly adhered to. When an activity controlled by such procedures cannot be accomplished as described or accomplishment of such activity would result in an undesirable situation,' the work shall be stopped 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 nummize injury to personnel or damage to plant equipment. Any such deviations should be thoroughly documented. (I) l l
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L QUALITY ASSURANCE POLICY
. Revision 42 Cornorate Ora==batiaa mad Sa-Tic P==-wibilities -
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- 'Ihe Corporate Organization Chart of the Baltimore Gas and Electric Cmay (BGE) is shown in Figure IB-1. Persons responsible for the principal elements of the Company's Quality Assurance (QA) Program are as follows:(1)
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. Chairman of the Board
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President and Chief Operating Officer i
' Senior Vice President Generation n
1 Vice President-Nuclear Energy Division (NED)
Plant General Manager-Calvert Cliffs Nuclear Power Plant Department (CCNPPD)
Manager-Nuclear Fa-i=~ ring Department (NED) 5 l
. Manager-Nuclear Quality Assurance Department (NQAD)
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1 r-Manager-Nuclear Support Services Department (NSSD) o l
i Manager-Nuclear Outage & Project Management Department (NOPMD) l i
1 in addition to these individuals, the Vice Presidents of Corporate AfBurs (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
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Maintenance Department (SOMD), Purchasing & Materials Ma"*Eament Department-(PMMD),
Information Systems Department (ISD), Facilities and Fleet Services Dws.cr (FFSD), Fossil Engineering & Maintenance Department (FEMD), Fossil Support Services Department (FSSD), and the'-
.j 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 maminiance/ modification activities at CCNPP are
- j responsible for performmg these activities in acco.-/.cc with applicable QA Program requirements.' This i
can be accomplished by either developing their own QA Program procedures or by working to the QA
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Program through appropriate Nuclear Energy Division personnel using CCNPP procedures. (15)'
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Also, two advisory groups perform quality-related functions for plant operations These are the Plant
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Operations and Safbty Review Comnuttee (POSRC) and the Off-Site Safety Review Committee (OSSRC) whose makeup and responsibilities are described in the TSs for CCNPP.
Chair=== of the Boant PraciAa* and Chief Oner=*ia Ohr. and Senior Vice President 4ene'(
BGE's QA Program for nuclear power plants is established under the authorrty of the Chainnan of the Board, President and Chief Operating Officer, and Senior Vice President 4cneration, who are responsibl for establishing the overall QA Policy. They assign project responsibilities to the organizations shown m j
heavy-lined boxes in Figure 1B-1. (1) i
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QUALflY ASSURANCE POLICY
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Revision 42 Re Chainnan of the Board assigns authority through the President and Chief Operating Of5cer and Senior Vice PresidentGeneration to the Vice President-Nuclear Energy Division. Primary responsibilities for developing, implementing, and rnmintaining the QA Program are assigned to Department Managers by the I
Vice President-Nuclear Energy Division. Managers delegate their authority as required to implement their I
responsibilities. (1)
,i Quality assurance matters that cannot be resolved by the Managers or Vice Presidents are brought to the i
attention of the Senior Vice President-Generation, President and Chief Operating OfEcer, or the Chairman of the Board for resolution.
I Vice President-Nuclear Energy Division The Vice President-Nuclear Energy Division, is responsible to the Senior Vice President-Generation for i
ensuring that the QA Prcgram is developed and implemented The authority to develop QA Program Documents is assigned to designated Nuclear Program Managers. De Vice President-Nuclear Energy Division, is also responsible for onsuring that the requirements of the QA Program that relate to the design, operation, and maintenance of the plant are implemented. This responsibility is carried out through Nuc1 car Program Managers.
M_a.rggtr-Nuclear Ouality Assurance Denartment i
The Manager-NQAD, is responsible for assuring an appropriate QA Program is established and effectively executed for CCNPP. He is responsible for auditing, quahty verification, vendor
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evaluation, and independent safety evaluation functions for CCNPP. Rese responsibilities include:
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Developing, and revising the QA Policy.
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Ensuring that QA Compliance reviews are completed for program acceptability of Control i
Programs (QAPs and Directives) and their revisions before they are approved. (9) i 3.
Taking necessary corrective action, which can include the stoppage of work when j
manufacturing, maintenance, or modification activities fail to comply with approved
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specifications, plans, or procedures. Such corrective action is arranged through appropriate l
channels and is delegated w:en necessary. When a unit is operating, the Manager-NQAD, may recommend to the Plant Gereral Manager that the plant be shut down. The Plant i
General Manager has the final responsibility for the overall evaluation of all aspects and i
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 j
organizational freedom to identify quality problems; to initiate, recommend, or provide solutions j
through designated channels; and to verify implementation of solutions. Non-NQAD persormel i
who are authorized to perform activities under NOAD programs are matrixed to NQAD for the l
perfonnance of such activities, and possess similar organizational freedom and independence from the activities.
DGE has established that the Manager-NQAD, should have at least six years of responsible l
experience in engineering, design, manufacturing, construction, quality assurance, or power plant operation, as well as a knowledge of regulations and standards related to nuclear power plants.
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QUALITY ASSURANCE POLICY Revision 42 The orgaruzation of NQAD is shown in Chapter 12 of the UFSAR. The Manager-NQAD, delegates the following responsibilities for accomplishing the following activities:
Planning and scheduling evaluations of vendor quality assurance programs.
Reviewing proposed changes to QA Program documents for compliance with regu!ations and licensing documents.
Planning, scheduling, and performing internal audits /surveillances and evaluations of on-site l and off-site functions performed under the nuclear QA Program.
Supporting maintenance and opcmtions activities by performing inspections and surveillances, or by providing oversight of other department personnel as they perform inspections and surveillances. (II)
Directing investigations of significant eventa to determine root cause, mcommending l
corrective action, and generating appropriate reports to document the investigation results; directing a program for identifying trends within the corrective action systems l
Directing reviews of the operating experience of other plants of similar design to determine I
l the applicability ofsignificant events with respect to CCNPP. (14)
Plant General Mamer-Calve:1 Cliffs Nuclear Power Plant Departmen_t The Plant General Manager is responsible for operations, chemistry, radiation safety, maintenance, industrial safety and fire protection, and systems and performance engineering activities at l l
CCNPP. He must ensure that these activities are conducted in accordance with the plant operating license and TSs, the UFSAR, the QA Program, and procedures. The Plant General Manager fulfills the position and mquirements of the Plant Manager, as defined in ANSI NI R.1 (1971). He, or one of his designated principal alternates, shall have acquired the experience and training normally required for examination for a senior reactor operator's license.
The organization of CCNPPD is shown in Chapter 12 of the UFSAR. 'Ihe Plant General
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Manager, delegates responsibilities for accomplishing required activities as follows:
'Ihe Superintendent-Nuclear Operations (S-NO) is responsible to the Plant General Manager, 1.
for the operation of the plant, including the general supervision of all shift operating personnel and prioritization of maintenance activities to support operations.
"Ihis responsibility covers the safety of plant personnel and equipment, all fuel-handling and i
L refueling activities, and adherence to applicable license and regulatory requirements.
The l
Superintendent-Nuclear Operations fulfills the position and requirements of the Operations Manager as defined in ANSI N18.1 (197#) with the exception taken hi Table iB.1,
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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 j
the broadest possible perspective on operational conditions that affect the safety af the plant.
l As the senior member of plant management on cach 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.
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The Superintendent-Nuclear Maintenance (S-NM) is responsibic to the Plant Ocneral f
Manager for managing and directing activities of the Nuclear Maintenance Section to provide high quality maintenance programs, plans and schedules, and qualified personnel to perform Page 8 of 60 f
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7 QUALITY ASSURANCE POLICY.'
- I Revision 42 mamtenance functions aarenary to assure the safe, reliable, 'and '
c operation of thej plant - to generate power within applicable laws, standards, codes, L and. re ulatory requirements
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The General Supemsor-Electncal and Controls-(GS-EAC); is responsible to the a.
Superintendent-Nuclear Mainte= ace,. for the Mer of electrical and astrument maintenance, repair, and modificatens acertari to. keep the plant and its facilities, _
systems, and equipment in safe and efficient working condition. - He is responsible for '
plannmg and supemsing or controlling the electrical and astrument maintenance a
activities mm8W by plant maintenance personnel, and for ensuring that work is performed in'accordance with applicable' Codes ~ and Standards and that required.
- l maintenance records are dcwJepsi and kept. He is responsible for controlling tools -
j and equipment used for electrical. and'. instmment m==renance, repair and!
modifications activitiesc t
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The General Supervisor-Mechanical Maintenance (OS-MM), is responsible to the '
Sup..andent-Nuclear Maintenance, for the conduct of mechanical maintenance,;
repair, and modiScations needed to keep the' plant and.its facilities, systems, and equipmen in safe and efficient working condition. He is responsible for planning and '
l supervising or controlling the mechanical maintenance activities conducted by plant; mainte.tumce personnel, and for ensuring that work is perfonned in accordance with applicable Codes and Standards and that required maintenance mcords are developed and kept. He is responsible for controlling tools and equipment used for mechanical maintenance, repair, and moda6 cations activities.
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The Superintendent-Technical Support (S-TS) is responsible to the Plant General Manageri for managing and directing the activities of the Technical Support Section to provide systems and performance engineering, surveillance testmg administration, chemistry and radiation.
safety support, inservice inspection,~and industrial safety and fire protection support to assure -
the safe, reliable, economic operation of CCNPP. The S-TS is also responsible for overall direction and coordination of activitics 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 Programs and the Manager-FSSD.'
I The General Supervisor-Chemistry (GS-C). is responsible to the Superintendent-a.
Technical Support for the. chemistry.and radio-chemistry of the primary.and :
secondary systems and for maintaming radioactive effluents within specified limits.
Additionally, the GS-C provides program management oversight of the Radiological Environmental Monitoring Program to ensure compliance with the Radiological -
Effluent Techmcal Specifications.
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The General Supervisor-Radiation Safety (GS-RS) under the nuclear QA Program, is responsible to the Supermtendent-Technical Support for:
1 Ensuring the radiation protection of personnel at CCNPP.
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Complying with radioactive material transport regulations.
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QUALfiY ASSURANCE POLICY 3
Revision 42
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He Supervisor - Safety and Fire Protection is responsible to the Superintendent -
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Technical Support for development, implementation and coordination of the industrial
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safety progmm; implementing the fire prevention and fire fighting programs for the CCNPP; and planning, scheduling and monitoring activities directly related to safety, fire protection, and prevention.
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The General Supervisor-Plant Engineering (GS-PE), is responsible to. the Superintendent - Technical Support for providing field engmcering and technical evaluation of plant systems and to evaluate and coordinate resolution of system and component problems with operations, maintenance, and engineering personnel for the Calvert Cliffs Nuclear Power Plant. Additionally, the GS-PE is responsible to the S.
TS for providing plant reliability / availability testing and evaluation, plant performance improvement, and administration of the Surveillance Test Program.
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The Principal Engineer-Nuclear Inspection Services is responsible to the l Superintendent - Technical Support for providing inservice inspection services for the Calvert Cliffs Nuclear Power Plant.
Mananer-Nucha _rfnnineerine Denartment ne ManaBer-NED, is responsible for directing the efforts of personnel and providing resources necessary to support design, modification and engineering actisities covered by the QA Program for CCNPP. Rese activities include nuclear, mechanical, civil, reliability, instrument and controls, and electrical engineering; nuclear fuel management; configurt ion management; life cycle management; plant design support; fire protection program development; engineering planning; licensing, and design and drawing.
The organization of NED is shown in Chapter 12 of the UFSAR. The Manager-NED delegates responsibilitics for accomplishing the fo!!owing activities:
Providing conceptual and detailed engineering, design and drawing, fire protection program development, data base configuration control, and documentation and maintenance of plant design bases for the power and control systems for the Calvert Cliffs Nuclear Power Plant.
i Directing and performing safety evaluations, preparation and review of nuclear safety accident and transient analysis, fuel management, nuclear engineering related to core physics, reactor engineering, external fuel cycle management, reliability engineering and development and integration of programs necessary to operate up to and beyond the current licensed lifetime for the Calvert Cliffs Nuclear Power Plant.
Providing plant design support, and engineering planning and scheduling for the power and control systems for the Calvert Cliffs Nuclear Power Plant.
1 Prsidmg licensing services; coordination and operation of various industry information exchange systems; evaluation of plant events and conditions adverse to quality for reportability to the NRC and other agencies, assisting in the investigation and evaluation of events, and preparation of the reports; coordination of trackmg and resolution of company r
commitments to the NRC; research and preparation of responses to NRC letters, bulletins, circulars and information notices; UFSAR research and revision control; maintenance and revision of the current licensing basis for nuclear power plants; coordination of all compliance-related communications with external agencies including assistance in ensuring their consistency with existing licensing basis commitments; and coordination of regulatory inspections and visits and company presentations to the NRC.
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QUALITY ASSUPANCE POLICY Revision 42.
M;marer-Nuclear Outane and Project Mananement Denartment The Manager-NOPMD is responsible for directing the efforts of personnel and providing resources necessary to support site integrated scheduling, outage management and project management for assigned projects. The organization of NOPMD is shown in Clmpter 12 of the UFSAR. The Manager-NOPMD delegates responsibilities for accomplishing the following activities:
Developing, implementing and maintaining a site integrated schedule which schedules all significant plant related activities at CCNPP.
Managing the planning, scheduling and performing of all outages at CCNPP.
Providing overall project management for engineering, procurement, construction and testing of nuclear power plant modification for CCNPP.
Manager-Nuclear Suonort Services Department The Manager-NSSD is responsible for emergency planning, training, nuclear security, onsite procurement coordination, prt,curement engineering, receipt inspection and storage / issue ofitems, procedures upgrade, state regulatory matters, strategic planning, and staff services functions for CCNPP.
i The organization of NSSD is shown in Chapter 12 of the UFSAR. The Manager-NSSD delegates -
respontibilities for accomplishing the following activities:
Providing support to Managers in the Nuclear Energy Division to ensure their personnel are properly trained and qualified to perform their assigned duties, including those duties which implement the nuclear QA Program. Training required by special work forces and contractors would be performed by the appropriate BGE Department, and/or Host Company (vendor).
Distributing, and coordinating the preparation of revisions to the QA Program documents; collecting, storing, maintaining, and retrieving QA records for nuclear power plants; maintaining, controlling, and distributing drawings and technical manuals related to equipment, materials, and services for nuclear power plants; coordinating investigations concerning state regulatory matters; coordinating the efforts of Nuclear Energy Disision personnel involved in the procurement of structures, systems, components, parts, and services related to the design, construction, fueling, maintenance, and moditications of CCNPP.
i Establishing procedures to assure that SR and DNSR procurement documents identify technical and quality requirements; procurement (SR and DNSR) documents receive independent review and approval for the proper inclusion of technical and quality requirements; ensuring spare and replacement parts are suitable for -their intended application (s); specification of critical characteristics and acceptance criteria for dedication of commercial grade items; specification of special storage requirements for age sensitive items.
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QUALITY ASSURANCE POLICY Revision 42 Performing receipt inspection functions including special receipt inspections and coordmatmg
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testing performed to accept commercial grade items. designated NSR items or upgrade NSR -
items for usein SR applications. (5)
Enturing that the operational, maintenance, licensing, and training activities associated with :
plant security are effectively implemented, and that nuclear security provisions provide protection for personnel, equipment, and facilities et CCNPP against potential security threats.
Directing the efforts of personnel responsible for the storage and issuance of items for CCNPP.
Development of the annual Strategic plan for the Nuclear Energy Division including the Nuclear Program Plan.
Directing the efTorts of BGE personnel involved in emergency planniuS activities.
Individuals supporting the CCNPP QA Program are designated as follows:
Vice President-Fossil Enerev Division The Vice President-FED, is responsible to the Senior Vice President-Generation for ensuring that the t
activities of FED personnel involved in CCNPP maintenance and modifications; Materials Engineering and-i Analysis; and radiological environmental monitoring, meet the requirements of the QA Program. ' Dais responsibiliry is carried out through the Manager-FEMD, and the Manager-FSSD.
Manager-Fossil Enninsrina & Maintenance Depanment The Manager-FEMD, is responsible for directmg the efforts of FEMD penonnel involved in maintenance and modification activities at CCNPP.
Manager-Fossilluoport Services Denartmen_t The Manager-FSSD, is responsible for directing the efforts of FSSD personnel involved in: (1) maintaining and operating Radiological Environmental Monitoring equipment and performing sample collection and analysis, (2) ensuring materials engineering and analysis relating to SR structures, systems, and components are completed in accordance with Company and regulatory requirements.
Vice President-Electric Interconnection and Transmission Divisign The Vice President-EITD, is responsibic 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.
MAnacer-System Operation and Maintenance Department The Manager-SOMD, is responsible for directing the efforts of personnel involved in the testing of electrical power equipment, the calibration of test equipment and the testing of protective relaying and metering controls for the electrical power equipment of CCNPP.
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Revision 42 Vice President-General Services Division The Vice President-GSD is responsible for ensuring implementation of the QA Program requirements that relateto: the pmeurement of SR or designated NSR structw exems, components, and services; the construction, mamtenance, and operation of facilities; and supr 1 services for computer software and hardware.
These responsibilities are carried out through the Manager-PMMD, Manager-ISD, and Manager.-FFSD..
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a Manacer-Purchasine and Materials Management Department The Manager-PMMD, is responsible for directing the efforts of personnel involved in the pumhasing ofitems and services for CCNPP and for the issuance of Contracts for Fitness for Duty Activities.
Mananer-Information Systems Departmen_t ne Manager-ISD, is responsible for directing the efforts of ISD personnel involved in acquiring and supporting computer software and hardware.
Man;ign-Facihties and Fleet Senices Decartment He Manager-FFSD, is responsible for directing the efforts of FFSD personnel involved in the planning, design, construction, maintenance, and operation of facilities and related systems directly supporting or impacting power plant operations.
Vice President-Management Senices Division The Vice President MSD, is responsible for ensuring that the activities of MSD personnel involved with medical examinations for CCNPP operators, Nuclear Security Officers, and respirator users, meet the requirements of the regulations. The responsibility is carried out through the Manager-SMSD.
Manager-Safety and Medic.;tt Services Deoartment The Manager-SMSD, is responsible for directing the efforts of SMSD personnel involved with medical examinations for CCNPP operators (10CFR55), Nuclear Security Officers (10CFR73),
respirator users (10CFR20), and with the Fitness for Duty rule (10CFR26).
Vice President-Comorate Affairs h
The Vice President-CA is responsible for ensuring that QA Program requirements related to the Radiological EfIluent Technical Specifications are implemented. This responsibility is carried out through the Director - Environmental Programs.
ID.2 QUALI1Y ASSURANCE PROGRAM f
L GeneraLControls ne QA Program consists of the Updated Final Safety Analysis Report (UFSAR) Appendix IB, QA Policy, Quality Assurance Procedures, certain Nuclear Program Directives and their implementing procedures. He UFSAR Apper. dix IB and QA Policy are the same document except for the way changes are incorporated. The QA Policy is updated when each change is approved. Revisions to the QA Policy are comrolled by QA Program documents which are written to ensure compliance with 10 CFR 4
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QUALITY ASSURANCE POLICY Revision 42 50.54(a)(3). The UFSAR Appendix IB is updated annually. All QA Policy changes approved during the l
previous year are incorporated during that update.
i Re QA Policy identifies NRC regulatory requirements, industry standards, and specific codes applicable to the eighteen criteria contained in 10 CFR 50. Appendix B. The QA Policy also indicates action that will
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be taken by BGE in response to these documents and to commitments made in the UFSAR and TSs for j
Quality Assurance Procedures (QAPs) describe controls for the actions identified in the QA Policy. QAPs cover major activities related to operating a nuclear power plant, such as plant operation, plant maintenance, training, purchase ofitems and services, calibrations, etc.
Nuclear Program Directives address actions identified in UFSAR Appendix IB. Directives identify
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regulatory commitments, management requirements, and assign responsibilities for business activities (i.e.,
design, maintenance, operations, etc.) within the BGE NucIcar Program. As directives are written and implemented, they will systematically replace QAPs.
BGE's QA Program for CCNPP is applied to structures, systems, components, and activities that have been designated SR because they prevent accidents or mitigate the consequences of postulated accidents that could cause undue risk to the health or safety of the public. The QA Program is also applicable to 1
designated NSR structures, systems, components, activities, and services as required by in regulations.
Designated NSR program requirements are based on a graded approach to Quality Assurance required to meet applicable regulatory designated requirements and guidance. The level of QA Program controls i
placed on designated NSR items are defined in QA Program documents and/or implementing procedures.
I Re controls from other sections of this QA Policy are selected as necessary to meet the particular regulations being implemented.
i Controls have been established for specifying on a Quality List (Q-List) all SR stmetures, 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 j
Chairman of the Board, establishes the overall QA Policy of BGE. This Statement sets the goal of safe and I
reliable operation of CCNPP; commits the Company to a QA Program designed to ensure the plant's compliance with regulatery requirements, BGE commitments, and established practices for reliable plant operation; and requires every person involved in QA Program activities to comply with the pmvisions of the Program.
The Policy is approved by the Vice President-NED and implemented by Nuclear Program Managers. (1)
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The QA Program has established controls for BGE and its contractors as required to ensum that the entena i
of 10 CFR 50, Appendix B, will be met throughout the operations phase of the plant; i.e., during activities j
of testing, operation, maintenance, repair, modification, and refueling.
j He QA Program has also established controls to ensure that the construction, opemtional, and 1
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 j
i 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) j Changes to the QA Program documents are issued with a transmittal notice, which is completed by the
(
recipient and retumed to indicate that the documents listed on the transmittal have been received and I
incorporated into the recipicnfs Manual. Nuclear Program Managers ensure QA Program documents are revised as agulations, standards, results, or experience dictate. (1) The Manager-NQAD evaluates the degree of compliance with the requirements of QA Program documents and procedures. Audits are Page 14 of 60 j
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QUALITY ASSURANCE POLICY '
Revision 42 conducted regularly to ensure compliance with' established requirements, and the results of these audits are.
. reported to responsible management personnel.
- De Vice President-NED, ensures that activities of the NQAD are audited regularly by. personnel
.I mdependent of the Department. These auditors assess the e&ctiveness of the Department's implementation i
of appropriate portions of BGE's QA Program. The Vice President-Nuclear Energy Division, evaluates the
.j repost of the independent audit to determine if changes are required to the QA Program He is responsible for negotiating such changes with the appropriate level of management and forcsendmg to the Chairman of j
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 or Departments, the dispute is resolved as follows: The Supervisor / General Supervisor of the QA Unit /Secoon involwd first 1
tries to resolve the matter with the organization responsible for MW the activity. If a resolution cannot be obtained, the matter is referred up through the following management personnel until it is 1
resolved; (3) i 1.
The Manager-NQAD, and the Manager responsible for performing the activity.
NOTE:
If the dispute is with another Unit /Section in NQAD, the issue will be settled by the Vice President-Nuclear Energy Division. (3) 2.
The Vice President-Nuclear Energy Division. (1) 3.
The Senior Vice President-Generation, President and Chief Operating OfEcer, or the Chairman of l
the Board.
i To ensure that important activities are performed correctly, BGE conducts formal training programs for Company personnel with significant responsiinhties. These programs include both initial and continuing trainiug and are conducted in accordance with written procedures or instructions. - Department Managers -
1 are responsible for ensuring that the training needs of personnel in their Departments are identified, formal training programs to satisfy those needs are developed, and the training programs are implemented in accordance with the requirements of the QA Program documents.
The QA Program was developed to meet the requirements of the Regulations,- Regulatory Guides, and
'l Industry Standards of the Nuclear Regulatory Commission (NRC) listed below. - Exceptions taken to i
guidance contained in these documents and equivalent BGE alternatives are stated in Table 1B-1.
j REGULATIONS 10 CFR 50.55a - Codes and Standards.
10 CFR 50.59 - Changes, Tests, and Experiments.
10 CFR 55 - Operators' Licenses.
10 CFR 50, Appendix B - Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
10 CFR 72. Subpart G - Quality Assurance (ISFSI) 1 Page 15 of 60
.f QUALITY ASSURANCE POLICY -
d Revision 42 l
REGULATORY GUIDES
'I i
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1.8 - Personnel Selection and Training'(September 1975)". His endorses ANSI N18.1 (03/08/71)"*.
1.16 - Reportmg of Operating Information (as specified in Calvert Cliffs Technical Specifications).
al.30 -.QA Requirements for Installaton, inspection, and Testmg of. Instrumentation and Electric Equipment (08/lIn2)*. His endorses ANSIN45.2.4 (03/01n2).
'1 1.33 - QA Program Requirements (Operation. Rev. 2, 02n8)". This adorses ANSI N18.7-1976/ANS l
- 3.2 (02/19n6)*"..
1.37 - QA Requirements for Cleanmg of Fluid Systems and Associated Co.% wits of Water-Cooled Nuclear Power Plants (03/16n3)**. This endorses ANSI N45.2.1 (02/26n3)*".
1.38 - QA Requirements for Packaging, Shipping, Receiving, Storage, and Iirs.diirs ofItems for Water-Cooled Nuclear Power Plants (Rev. 2,05n7)". This endorses ANSI N45.2.2 (12/20n2)*".
1.39 - Housekeeping Requirements for Water-Cooled Nuclear Power Plants (03/16/73)*. This endorses t
ANSI N45.2.3 (03/15n3)***.
- l i
1.54 - QA Requirements for Protective Coatmgs Applied to Water-Cooled ' Nuclear Power ' Plants.
'5 (06D3)". His endorses ANSI N101.4 (11/28n2)"*.
1.58 - Qualification of Nuclear Power Plant inspection, Exa.nination, and Testing Personnel (09/80)"
This endorses ANSI N45.2.6 (1978)"*.
6 1.64 - QA Requirements for the Design ofNuclear Power Plants (10n3)*. His endorses ANSI N45.2.11, Draft 3, Rev.1 (07n3).
'i 1.68 - Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors (1103)".
1.144 - Auditing of Quality Assurance Programs for Nuclear Power Plants, Rev.1 (09/80)". His
{
endorses ANSI N45.2.12 (1977).
i 1.146 - Qualification of Quality Assurance Program Audit Personnel for Nuc! car Power Plants (Aug.
'{
1980).*. His endorses ANSI N45.2.23 (1978)"*.
1 I
INDUSTRY STANDARDS 7
ANSI N45.2.5 - Supplementary QA Requirements for Installation, Irspection, and Testing of Structural j
Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants; Draft 3. Rev.1 (11n3).
ANSI N45.2.8 - Supplcmentary QA Requirements for Installation, Inspection, and Testing of Mechanical
. Equipment and Systems for the Construction Phase of Nuclear Power Plants: Draft 3, Rev. 2 (09/73).
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QUALITY ASSURANCE POLICY Revision 42
- ANSI N45.2.9 - Requirements for Collection, St.orage, and Maintenance of Quality Assurance Records for
~ Nuclear Power Plants; DraR (10n6)*",
ANSI N45.2.13 - QA Requirements for Control of Procurement of Equipment, Materials, and Services for.
Nuclear Power Plants: Draft 2. Rev. 2, (10n3)*".
NOTATIONS FOR REGULATORY GUIDES AND INDUSTRY STANDARDS -
t
. NRC endorses an Industry Standard or draft without reservation.
NRC takes exception to or provides additional guidance in a regulatory position statement.
f BGE takes exception to guidance offered and states alternatives.
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4 Page 17 of 60
. QUALITY ASSURANCE POLICY Revision 42
. Procedural Controls.
! he QA Policy and revisions thereto are reviewed by Nuclear Program Managers. QA Policy revisions are 4
reviewed by NQAD personnel to determme if they constitute a reduction in commitments previously madef j
-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.
j Division.~ The Vice President-NED approves the QA Policy and revisions thento.
- i 1
Each Quality Assurance Procedure (QAP) is prepared by one or more of the Departments responsible for j
conducting the activity. The QAP and revisions thereto are reviewed by NED. Managers and affected a
Department. Managers. The Manager-NQAD ensures QAP revisions:are revzwed by the Quality.
-l Assurance org=e=% and MC=4= approval to the Vice President-NED.. The 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 ~
i QAPs.
. Nuclear Program Directives are prepared under the direction of the Department Manager assigned by the 1
Vice President-NED as the Program Sponsor.. : Each directive and revisions thereto are reviewed by.
]
a%cted Department Managers. The Manager-NQAD ensures directive revisions are reviewed by the Quality Assurance organization and approval recommended to the Program Sponsor,: The Program j
Sponsor approves the directive and revisions thereto. h Manager-NSSD ensures issuance of all l
directives and revisions thereto i
QA Program documents ensure that:
~
1.
The need for special controls, processes, test equipment, tools, and skills is specified when necessary l
to casure that required quality is attained in performance of the activity.
- l 1
2.
Quality is verified by inspections and tests.
3.
Personnel who perform activities a&cting quality achieve and maintain suitable proficiency through '-
l appropriate training and experience.
I
' Administrative or Technical Procedures are prepared as needed 'They establish the processes used to l
implement directive or QAP requirements. The controls for review and issue ofprocedures are discussed in Sections IB.5 and IB.6.
/
i Review of Operations l
~ Procedures require that CCNPP shall be operated and maintaind in accc dance with the plant TSs and operating license. The following organizations review plant operadmir '.o ensure that these procedures' are -
followed:
1.
The Manager-NQAD provides independent verification that the requirements c=*-M in the Plant's
{
operating license, UFSAR, TSs, and plant procedures are met. This is accomplished through
~
quality assurance audits.
i l
2.
The OSSRC provides independent verification by review that CCNPP is operated in accordance j
with established requirements. The OSSRC, which functens under a written Charter approved by the Vice President-Nuclear Energy Division, is composed of on-site and off-site personnel j
knowledgeable of in-plant operations, nuclear engineering, demistry and radiochesnistry, metallurgy, radiological safety, instrumentation and cor, trol systems, mechanical and electrical
- systems, quality assurance, and environmental factors.
The i
Page 18 of 60
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- QUALITY ASSURANCE POLICY Revision 42 - -
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.proceedmss of all' meetings are documented and sent to the Vice President-Nuclear Energy Division,.
Comnuttee members.' and others designated by the Committee Chainnan.
a 3.
- The on site POSRC reviews matters pertaining to nuclear plant safety. This Committee screens
~
subjects of potential concern to the OSSRC and performs preliminary. investigations under the
- direction of the Plant General Manager. POSRC membership and A=% are governed by-Technical Specifications and written procedures.: The results of all meetings are & =-
11and
~
sent to the m.!ss of the OSSRC, and others designated by the Committee Chairman.
l a
The maintenance and repair of systems, structures, and components subject'to the;QA Program are
- performed by personnet under the direction of the. General. Supervisors of Electrical and Controls; a
. Radiation Safbty, and Mechanical Maintenance,- accordmg to.wntten procedures and' instructions as.
e z
prepared by the maintenance force and approved as stated in QA Program documents. These Procedures:,
1.
, Ensure that quality-related activities, such as inspections and tests, ' re performed with appropriate j
a 1
- equipment and under suitable environmental conditions.
k 2.
Indicate inspections and checks that must be made and records and data that must be kept.
l
- 3.
Show where independent veri 6 cations ofinspections or checks should be performed by specified personnel other than those performing the work.
1 When necessary, non-plant Company personnel or outside contractors are brought in to supplement the -
l plant work force. In such instances, the approval of work procedures and the tagging of equipment'are coordinated by a ' member of the BGE organization responsible for the ped.. 2 of the work.,'
}
Controls are established in QA Program documents to ensure that matenals and parts used in the repair, i
maintenance, and modi 6 cation of SR and designated NSR portaans of the plant are appropriate for the j
service intended Written procedums are prepared for the storage and identificatson of materials and parts to ensure that they do not deteriorate in storage and can be correctly identified befbre installation or use.
l Equipment manufacturers and contractors used for the repair, n Wm and modification of SR and
' f designated NSR stmetures, systems, and components am required to have quality assurance programs consistent with the importance of the end-product to safety.
18.3 DESTON CONTRO_L Control 1
Plant changes which affect the design, function, or method of perfornung the function of a structure, j
system, or component described in the UFSAR and are controlled by QA Program documents which are written to ensure compliance with Regulatory Guide 1.64 and 10 CFR 50.59.
Controls for changes, tests, and experiments conducted at CCNPP vary according to the following:.
1 1.
' As the item or activity affected is or is not described in the UFSAR.
2.
As the item or activity aficcted has been classified SR or NSR.
' )
3 Page 19 of 60
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QUALITY ASSURANCE POLICY Revision 42 3.
LAs the item or activity affects or does not affect nuclear safety.
l l
.4c As the proposed change, test, or experiment does or does not constitute an Unreviewed Safety.
?
- Question or require a change to the TSs.-
To ensure compliance with 10 CFR 50.59, the process for controlling changes, tests, or experiments has' j
been divided into classifications Procedures required by QA Program hmts describe and control the
'i method for detennining the appropriate process classification. Jihe. process classifications control the-preparation and reporting of safety evaluations.1Three methods of treatment are allowable:
- l a
1.
-Implementing the change, test, or experiment in accord.-cc with Company practice for operating.
power plants, or in accordance with Pmeedures required by QA Program h== a-2.
. Implementing the change, test,.or experiment in accordance with Procedures required by.QA;
)
~
Program documents but controlling the change, test, or experiment with a process classification.
-l 3.
Controlling the change, test, or experiment with a process classification and not allowing the, j
unples aing activity to begin until the review requirements of 10 CFR 50.59 and 10 CFR 50, 1
Appendix B, ha/c been met.
Changes, tests, or experbnents which require approval by the NRC att approved by the POSRC and by the -
l OSSRC.
'.j Controls have been established to ensure that design changes to SR structures, systems, and components
{
are reviewed either by the organization that made the original design or by a Responsible Design.
l}
Organization (RDO) that meets requirements specified in ANSI N45.2.ll, Section 8.0.
Responsible Dai== Oraninti9.01 L
RDOs, cither ou contract or within BGE, ensure that:
1.
Applicable regulatory requirements and design bases requirements are correctly translated into -
specifications, drawings, written procedures, and instructions. -
2.
Appropriate standards for quality are specified in design documents, and deviations and dianges '
from such standards are controlled.
/
.q 3.
Suitable design controls are used in applying principles of reactor physics; makmg seismic, stress, i
thermal, hydraulic, radiation, and accident analyses; ensuring compatibility of materials; and providing accessibility for in-service mspection.
-l 4
Designs are reviewed to ensure that design characteristics can be controlled, inspected, and tested,.
i and that inspection and test criteria air identified.
j 5.
Interfaces, both external and internal, are controlled - for the activities of all participating organizations.
6.
Methods for verifying or checking, such as design reviews, alternative calculations, and qualification.
testing are properly chosen and followed; the most adverse design conditions are specified for test.
programs used to verify the adequacy of designs.
I Page 20 of 60 i
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QUALrrY ASSURANCE POLICY
. Revision 42 -
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. N.
- 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._
l A
' 9
' Design documents and revisions thereto are distributed to responsible individuals and controlled to.
N prevent inadvertent use of superseded material.
- l
-10. - Design errors and deficiencies that adversely affect SR structuits, systems, and components are '
I documented, and appropriate corrective action is taken.
I 1.
Design de-r A and reviews, records, and changes thereto are mHu+ul, stored, maintamed, and '
controlled systematically.
~ '
,7 j
- 12.
Standard off-the-shelf commercial or previously approved materials, parts, and equipment -anal
'l to the SR functions of structures, systems, and components are reviewed for suitabilityJof I
application before they are selected.
i 13.
The persons or groups responsible for design reviews and other design verification activities and i
slu:ir authority and responsibilitics are identified.
{
- 14. ' Design changes to NSR items initiated and approved at the plant are controlled to ensure compliance l
with 10 CFR 50.59.
15.
Processes used to select suitable materials, parts, equipment,'and processes for SR structures,-
systems, and components includes the application of pertinent industry standards and specifications, material and prototype hardware testing programs, and design reviews.
j 16.
Computer programs used in design are subject to design controls and program veri 6 cation.
]
i iB.4 PROCUREMENT DOCUMENT CONTROL (5) j q
Cetitrols have been established to specify the requirements and sequence of actions fori requesting items or '
^
services; review of the requested item or. service to establish the necessary technical and quality requirements; preparation, review and 'tantrol of procurement documents; evaluation and selection of -
vendors and; control of deviations from '.ne procurement document requirements.
The degree to which these controls a c imposed on the purchase ofitems and services by BGE for CCNPP -
depends on:
1.
The functional (safety) classi6 cation of each item or service as SR or NSR according to. controls I
established by the RDO r.nd
,I 2.
The Procurement Category of the item within it's functional classification as a basic component,-
commercial grade itera, 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 60 s-
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l QUALITY ASSURANCE POLICY-Revision 42 3.
Is to be ordered from the manufacturerhuutor on the basis of specifications set forth -
in the vendor's published product description (for example, s' catalog)..
b.
Basic Component - An item either procured as a safety related item or as a commercial grade item which has been accepted and dedicated for safety related application. This term is
, synonymous with " Safety-Related Component".-
IWg-*4 Non-Safety Related - A NSR item wiuch BGE has made a regulatory or design -
c.
basis commitment; or, for plant ' availability reasons, BGE has implemented special contmisa
' to assure reliability; 'Ihese NSR items are included within the quality assurance process.
-l 1
d.
! Non-Safety Related - An item that does not perform a safety related function.
-1 3;
The procurement method to be used for the item or service:
.l Purchase Orders placed by BGE~ personnel for items or' services intended for' safety'related applications and DNSR items and services fall into two categories, Nuclear Grade Method.
procurement and Commercial Grade Method procurement.
Nuclear Grade - Purchases that are designated to be placed with vendors that maintain a-a.
10CFR50 Appendix B quality program and supply items that meet the definition of Basic Cn=panent. The requirements of 10CFR21 will be invoked on the vendor under this method
]
a b.
Commercial Grade - Purchases that are designated to be placed with commercial ~ grade -
1 vendors that supply items or services that meet the definition of Commercial Grade. 'Ihese items must be dedicated for SR use by BGE.
Items and/or services classified as DNSR will be puerhased using the Commercial Grade -
- )
Method with techmcal requirements established by an RDO.
4 Qualified NSSD/NED personnel trained in quality assurance program requirements with RDO authority j
review safety-related and designated non-safety related procurement documents for proper inclusion of.
technical and quality requirements. Personnel in NSSD/NED review safety-related and designated non-l safety-related procurement documents to ensure that the requirements stated therein ' are correct.
d inspectable, controllable, contain adequate acceptance and rejection -criteria, and comply with the requirements of the procurement program. These reviews and approvals are' documented prior. to
~
placement of the purchase order.
.l
,j All changes made to procurement documents, includmg specifications anxi br technical attachments, are
-j
' subject to the same levels of review, approval and control that were applied in preparug ud processing the 1
original documents.
' i Bids submitted to supply safety-related items or services receive the same review and approval cycle as used for safety-related procurement requisitions.
Vendor Selection l
Personnel in NQAD evaluate vendors who provido SR and designated NSR items and scivices to verify j
they can provide acceptable items and services.
Page 22 of 60 1
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~' QUALITY ASSURANCE POLICY m
' Revision 42-y
- Caarrots for Nada-Grade Pu1Ghaan l
~
]
Controls have been established to ensure that, before placement of a purchase order under the Nuclear:
Grade method of purchase, there is evidence of the following De vendor has been evaluated as stated in Section;IB.7 of this policy and found to have a n
- 1..
~ satisfactory QA program.
l 2.
De item to be purchased is manufactured under the' requirements of the evaluated and' approved <
j progmm.
1 Controls for Cuo...J l Grade Purchases i
. ~
i Controls have been established to ensure that items'or services available to general industry will be'
'l sufficiently controlled to perform their SR and designated NSR function. NSSD/NED personnel will-specify the==p-w methods to be used to verify the critical characteristics identified in the procurement document (s).
i Procurenent Dama==t F-ir==aate j
Procedures require that procurement documents shall:
1.
Reference part numbers or descriptions, and additional requirements to ensure that items ordered can be identified and verification can be made that each item received is the item ordered.
];
2.
Contain/ reference technical requirements for the basis of. design, by including the applicable--
')
regulatory requirements, component and material. identi6caten, RDO approved drawing and-'
j speMstion, codes, industrial standards, test and inspectaan requirements, and special process
-l instructions such as welding, heat treating, nondestructive testing, and cleanmg 3.
Identify the requirements of 10 CFR 50, Appendix B, which must be complied with and described in -
d the vendor's QA program, for Nuclear Grade Purchases
. 4.
Require that major contractors designated as BGE agents to purchase SR and designated NSR items i
or services must have procurement controls to ensure they purchase or acquire these items or j
services in compliance with the necessary sections of ANSI N45.2.13.
9Property "ANSI code" (as page type) with input value "ANSI N45.2.13.</br></br>9" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 5.
Identify required documentation (i.e., drawings, specifications, procedures,. inspection. and fabrication plans, inspoetion and test records, personnel and procedure qualiGcadons, and material chemical and physical test results) to be prepared, maintained, and submitted to BGE or the j) purchaser for review and approval.
1 6.
Identify records which must be retained, controlled, mamtained, or delivered to BGE or the
.j purchaser before use or installation of haniware.
~
- 7. -
Specify BGE or its agent's right of access to vendor facilities and records for source mspection, -
surveillance, verification and audits.
- j 8.
Identify requirements of the vendor's quality control process which must be implemented when providing a commercial grade item.
9.
Reference or specify the critical characteristics that a commercial grade item must possess to ensure that the item received is the item specified.
Page 23 of 60
.I QUALTTV ASSURANCE POLICY Revision 42 -
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10.
Incorporate the requirements of 10 CFR 21 for Nuclear Grade procurements.
4 I1.
Include requirements for QA program elements to be passed on to sub-vendors.
[
'\\
~
1B.5 -
INSTRUCTION
S. PROCEDURE
S. AND DRAWINGS i
. Controls dehneate the sequence of actions to be performed in the preparation, myiew, approval, and control ofinstructions, procedures, and drawings.
j e
Li Controls require that:
-l 1.
Methods for complying with each of the applicable criteria of 10 CFR 50,? Appendix B. must be l
specified in instructions, procedures, and drawings
.j 2.
Instmetions, procedures, and drawings must specify appropriate quantitative (such as dimensions, ta;erances, and operstmg limits) and qualitative (such as workmanship samples) acceptance criteria j
for verifying that important activities have been satisfactorily accomplished.
Controls ensure that:
i 1.
"The QA Policy is approved by the Vice President-Nuclear Energy Division. (1)'
i 2.
QAPs are developed by Departments responsible for mnMag particular activities, revmwed by l
the managers of the responsible department (s) for that particular activity, and approved by the Vice i
Pmsident-Nuclear Energy Division. (1) 3; Nuclear Program Directives are prepared under the direct on of the Department Manager assigned.
l as the Program Sponsor Affected Department Managers review directives and their revisions. The
- l Manager-NQAD ensures directives are reviewed by the Quality Assurance organization and.
i approval reumm.a.ded to the Program Sponsor. The responsible Program Sponsor approves-directives and their revisions. Directives are prepared, reviewed, approved, and periodically reviewed acconting to an appendix to the Nuclear Program Directives Manual.
5 4.
Procedures are prepared, approved, and controlled according to the Control Procedures. Control
.j Procedures establish review, approval, revision, change, and persodic review requirements for applicable procedures. ' If format and content requirements are not contamed in Control Procedures, they shall specify the document to be used to determme format and contcet requirements. Control Procedures are reviewed by the Quality Assurance Organization. Other procedures are reviewed by i
Quality Assurance on a requested basis.
5.
Basis items added during procedure revisions or changes will be recorded. (1) =
j iB.6 DOCUM.ENT. CONTROL 1
Requirements have been established to control the documentation of ' activities controlled by the QA '
t Program QA Program controlled documents include the UFSAR; Operating License, including the Technical Specifications; Emergency Response Plan; Security Plan; QA Policy; the ISFSI updated Safety Analysis Report (SAR) and Materials License, including Technical Specifications; procedures; specifications; and drawings.
Revisions to the QA Policy are controlled by QA Program documents which are written to ensure compliance with 10 CFR 50.54(a)(3).
Page 24 of 60 4
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QUALITY ASSURANCE POLICY Revision 42
- Alterations to the UFSAR are controlled by QA Program documents which are written to ensure compliance with 10 CFR 50.71.
Alterations to the ISFSI updated SAR are s..mtrolled by QA Program documents which are written to ensure compliance with 10 CFR 72.70.
j Alterations to the Operating License, including the Technical Specifications, are controlled by QA Program i
documents which are written to ensure compliance with 10 CFR 50.59(c),-10 CFR 50.90 and 10 CFR i
50.92.
Alterations to the ISFSI Materials License, including the technical specifications, are controlled by QA.
Program documents which are written to ensure comphance 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 ISFSt.
Alterations to the Security Plan are controlled by QA Program documents which are written to ensure i
compliance with 10 CFR 50.54 (p), and with 10 CFR 72.44(e) for the ISFSI.
QAPs are required to:
1.
Establish controls to ensure that regulatory requirements and BGE commitments will be implemented.
I 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 ive sufficient detail to control the performance of the activity or to ensure that E
requirements for lower-level procedures are clearly specified.
4.
Be prepared and controlled in accordance with QA Program documents that describe the format,
{
sequence of topics, contents, review and approval, issue and distribution, and requirements for revision and record retention.
During the review of each QAP, compliance with applicable criteria specified in 10 CFR 50, Appendix B,.
I is veriSed and documented.
i 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) wino have.
responsibilities for activities govemed 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 conunitments will be implemented.
2.
Establish controls to ensure that management requirements will be implemented.
j Page 25 of 60
QUALITY ASSURANCE POLICY Revision 42 3.
Assign responsibilities and interfaces within the program.
4.
Be prepared and controlled in accordance with an appendix to the Nuclear Program Directives Manual that describes the format, contents, review and approval, revisions, and periodic review requirements.
Nuclear Program Directives are prepared and technically reviewed under the direction of the Department Manager assigned as the Program Sponsor. Each directive is reviewed by affected Department Managers.
Each directive is given a compliance review by a member of the Quality Assurance organization. Nuclear Program Directives are approved by the sponsoring Manager after ensuring resolution and incorporation of QA compliance review comments. (9) The Manager-NSSD ensures issuance of each directive.
Administrative and Technical Procedures are prepared when needed to implement QA Program document requirements according to a Control Procedure. Individual orgamzations are responsible for preparing, revising, issuing, and controlling procedures. Each procedure is given a technical review under the direction of the sponsoring organization. The Quality Assurance organization performs compliance reviews on Control Procedures. Other procedures are reviewed by Quality Assurance on a requested basis.
Organizations that issue instructions, procedures, specifications, or drawings are required to establish controls that ensure the following:
1.
Changes to a document are reviewed and approved by the organization that performed the original review and approval unicss the control procedure designates another qualified responsible organization.
2.
Approved changes are promptly incorporated into instructions, procedures, drawings, and other documents associated with the change.
3.
Obsolete or superseded documents are controlled to reduce the possibility of inadvertent use.
Superseded documents retained for reference are marked and stored in separate files. Other superseded documents are removed from the files.
When changes to drawings or specifications are required, change requests are prepared by the organization that desires the change. Requests are reviewed and approved by BGE RDOs.
1 B.7 CONTROL OF PURCHASED MATERIAL EOUIPMENT. AND SERVICES (5)
NQAD, NSSD, NED, and PMMD personnel are responsible for the control of purchased items and services for SR and designated NSR applications at CCNPP.
The controls include:
Accepting items or services only from vendors who have been evaluated and selected in accordance f
with this policy.
Procurement documents for spare or replacement parts of structures, systems, and components as designated under the QA Program subject to controls at least equivalent to those applied to the original equipment, or an evaluation / justification shall be documented wheu less stringent controls are involved.
t Page 26 of 60
QUALITY ASSURANCE POLICY Revision 42
. Vendor survallance, verification and audit activities, and receipt verification are conducted to -
- j casure the vendors comply with specified tachaie=1 and quality requirements, and ensure items are -
identified, stored, handled and shipped in accordance with procurement document requirements Vendor Evaluation The vendor evaluatson is e=de~l o determine acceptability of a vendor to provide the requested item or t
service, to determine what vendor programs, procedures and documents need to be invoked by the-procurement document, determining the vendor's i=fo.
-e history for supplying items to CCNPP and '
i assessing the need to impose source surveillances and/or verifications during the
-f=c*nre of items or -
1
- performance of services for.BGE. Vendor evaluataons depend on the procurement classification of the item (s) being supplied.
'Ihc Nataonal lastitute of Standards and Technology (NIST), by virtue ofits being the nationally r==i=d '
'i standard, is an acceptable provider of calibration masters, standards or services. Utilities holding an NRC -
'j Construction Permit or Operating License are acceptable suppliers of all items except for those items to he used in an ASME Boiler and Pressure Vessel Code Section III application. Neither of the above'are i
required to be listed on the Approved Vendors List (AVL).
j Ll c'
Nuclear Grade.
i NQAD performs evaluations and audits to verify that the vendor has developed and inip; ited -
i an acceptable quality assurance program that complies with the requirements specified in the -
procurement specification or proposed procurement specification. These evaluations and audits.
are conducted and documented using written procedures or checklists that identify the QA requirements applicable to the items supplied.
Since BOE accepts the responsibility of vesifying the conformance of commercial grade items and/or service, they may be procured fmm vendors with no formal quality assurance program in F
this instance, BGE dedicates the commercial grade item and/or service for SR use.
?
t A survey may be performed of commercial vendors to assess what, if any haeted controls are implemented in the manufacture ofitems or performance of services for BGE.
i
(
Vendor controls evaluated to be satisfactory may be invoked as requirements within the purchase i
order and may be used as part of the basis for acceptance of the item.
j The depth of vendor evaluation varies according to the complexity and function of the item j
involved and to the role of the vendor.in acceptance of the item.
t Vendor Acoroval i
Upon completion of the evaluation, satisfactory vendors are added to BGE's AVL. The vendors on this list i
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.
i An auditing orgaruzation such as NUPIC, anot%r 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 j
or a comrnercial grade program that complies with the requirements of BGE's procurement requirements or similar requirements.
l l
'l Page 27 of 60 1
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QUALTIY ASSURANCE POLICY Revision 42 When required by operational considerations, an order may be placed with a vendor prior to completion of the evaluation and approval process only after obtaining the Manager-NSSD's appmval.
BGE's acceptance of basic component items or services provided by an unapproved vendor is contingent on the subsequent NQAD evaluation and approval of the vends a f. lated above.
Verification of Ventor Activities Vendor surveillance, and source verification activities are conducted by qualified NQAD per:>onnel in accordance with written procedures or checklists. These procedures or checklists, along with the procurement documents, specify the characteristics or processes to be witnessed, inspected or verified.
Personnel performing these activities are qualified to establish whether or not a vendor is capable of providing products of acceptable quality.
The depth and frequency of vendor surveillances, verifications and audits is commensurate with the complexity and function of the item or service and the ability of the vendor to provide the necessary anurance of acceptability.
When a vendor's certificates of conformance are used as part of the acceptance of an item or sewice, the validity of these documents is periodically evaluated and documented by the above mentioned processes.
Receipt NSSD is responsible for receiving and storing materials, parts, and components.
Additionally, NSSD is responsible for performing standard and special receipt inspections and coordinating testing necessary to accept SR items, designated NSR items and commercial grade items for SR use.
Standard receiving inspection ofitems is performed to assure the following:
1.
The item is properly identified and that this identification corresponds with the documentation received.
1 2.
Stated packaging, shipping and handling requirements have been maintained.
3.
Items have not been damaged, workmanship is of adequate quality, and the items are adequately clean in accordance with procurement document requirements.
4.
Documentation required by the Purchase Order has been received and is reviewed to assure that the item confonns to the purchase osder acquirements.
Special rocciving inspection may be required if the item was not inspected at the source; when requested by the RDO or; as part of the acceptance basis for commercial grade items.
A written record of the results of the NSSD receipt inspection and the disposition of received items is I
maintained as part ofpermanent plant records.
i All SR and designated NSR iterns accepted and released for issue to a controlled storage area or released for installation or further work bear an acceptance tag and have documentation to support their acceptability. If traceability is lost or the documentation review is unsatisfactory, an item becomes subject f
to the controls established for non-confonnmg items.
}
Page 28 of 60
r,
~
q QUALITY ASSURANCE POLICY '
Revision 42 '
W
~ Non-cu.Juw..kg items are identified and handled in accordance with Section IB.15 of this policy and, when j
practicable, are placed in a segregated area to prevent inadvertent installation or use until proper',
i disposition is made.
Documentation l
BGE procurement documents requim vendors to provide documentation identifymg the purchased item and lg the specific procurement requirements that are met by the item.
i
.(
Vendor inspecten records or certificates of conformance attesting to acceptance must be in the possession i
of BGE before the item may be released for installation or use. However, an unacceptable item may be :
given a " Conditional Release" if there is reasonable assurance that. it can be made acceptable after -
l installation but before the system that contains it is. considered operational. Items released under
' " Conditional Release" must be controlled under the Non Conformance Report (NCR) system.
Vendor requested deviations from procurement docunn:nt requirements, including nonconformances dispositiocod "use-as-is" or " repair" must be submitted to BGE for evaluation and approval of the deviation j
or a recommended disposition prior to shipment.
l 1B.8 IDENTIFICA*I1ON 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-assemblics, are identified and controlled to prevent the use ofincorrect or defective material.
q 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 clame require the iL2 cation to be placed.
j on the item or in records traceable to the item so that the function and quality of the item are not affected.-
This identificaten is required to be maintained throughout fabrication, storage, erection. installation, and
]'
use. NSSD personnel ensure traceability information is correctly transferred to subdivided materials stored.
in the Warehouse. User orgmabations ensure traceability infonnation is correctly transferred to subdivided j
materials after issuance from the Warehouse. NQAD is responsible for performing periodic inspections or
~
i 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.
i l
BOE contractors and their sub-contractors (who are approved to work on-site under their own QA
~!
program) are responsible for establishing and implementing programs in accordance with specified i
requirements for identifying and controlling materials, parts, and components under theirjurisdiction.
j IdentiGcation 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.
Page 29 of 60 i
I
QUALITY ASSURANCE POLICY Revision 42 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.
If an item is found to be or is made discrepar.t during processing, it is identified as such and placed in a separate area when practicable.
Acceptance documentation is required to be traccable to a purchase order, drawing,' specification, requisition number, or assembly. As individual items am assembled, installed, and inspected, their 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.
ID.9 CONTROL OF SPECIAL PROCESSES fant_rgh Controls have been established for writing, qualifying, approving, and issuing procedures to control such special processes as welding, heat treating, and nondestructive testing used during the operation of CCNpP.
Special Process Procedures:
1.
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.
3.
Specify requirements for control, parameters to be considered, acceptable methods of documentation, and the codes, standards, specifications, or criteria which govern the qualification.
4.
Define the necessary qualification of personnel, procedures, or equipment when special processes are not covered by existing codes or standards or when quality requirements for an item exceed the rrquirements of established codes or standards.
BGE contractors and their sub-contractors are responsible for controlling special processes used by them and for maintaining records to verify that special processes are performed in accordance with requirements:
established by the portions of their QA programs that apply to special processes.
l Oualification of Methods j
Procedures, equipment, and personnel connected with special processes are qualified in accordance with applicab e codes, standards, specifications, or supplementary requirements as follows:
(
l.
Welding activities conducted by BGE are performed according to welding procedure specifications qualified in accordance with applicable welding requirements of the ASME Code. Each welding procedure specification is
- written, qualified, and approved in accordance l
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QUAllW ASSURANCE POLICY Revision 42 with a controlling documented procedure. Copics of welding procedure specifications are made available to welders and, when required, to Authorized Inspectors. Before contracting for welding, the Principal Metallurgist reviews and approves non-BGE welding procedure specifications 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 Examinations are performed to written procedures 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 Codo for particular.
examination methods. Procedurcs, personnel qualifications, and the records that verify the Performance of' Nondestructive Examinations are kept as nuclear plant records. Nondestructive Examination Procedures describing methods not described in the ASME Code and/or SNT-TC-1 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 are developed to complement these alternative methods and to establish the capability of personnel to perform the mquired examination according to BGE procedures and to the level of performance to which the individual will be certified.
Methods of Nondestmetive Exammation include, but are not restricted to, radiographic, ultrasonic, liquid-penetrant, magnetic-particle, eddy-current, visual, and leak-testing examinations.
Procedures are prepared to cover these examinations in accordance with a QA Program document that details the specific exanunation, requirements for appmval, and content of the procedure, such as certification level, accept / reject criteria, examination coverage and sequence, surface preparation, test equipment, records required, permi::sible marking, cleanup requirements, and reference to applicable sections of the ASME Code.
Quahfication of Personnel Special processes are performed by certified personnel using written process sheets, shop procedur s, checklists, and travelers (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 -
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 wsults of the examinations. A welder is not permitted to wcld 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 BGE welders are not permitted to wcld SR and designated NSR items until they are qualified and certified in accordance with the applicable requirements of the ASME Code.
4 Page 3I of 60
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i QUALITY ASSURANCE POLICY Revision 42 3.
Nondestructive Examination 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 employres are trained and certified in accordance with a written procedure. Non-BGE personnel are qualified to procedures approved by BGE, and their qualifications and certifications of personnel are verified according to written procedures.
Qualification records of procedures, equipment, and personnel associated with special processes conducted by BGE are filed and kept current by the Principal Metallurgist or Principal Engi' leer - Nandestructive Exanunation - Nuclear.
t The Manager-NQAD provides independent verification that special processes are performed by qualified personnel.
1B.10 INSPECTION Activities that affect the quality of SR and designated NSR items are inspected as specified in approved instructions, procedures, and plans which set forth requirements and acceptance criteria to ensure that work is done in conformance with particular requirements.
Controls exercised during inspections ensure that:
1.
Personnel who perform quality verification inspections are independent of the personnel who performed the activity being inspected.
2.
Inspection procedures or instructions, with necessary drawings and specifications for use, are available before inspection operations are performed.
3.
In the case of special processes, inspectors are qualified, and their qualifications comply with applicable codes and standards.
4.
Test and measuring equipment is calibrated within required limits.
5.
Inspection procedures, as applicable, specify objective acceptance criteria, prerequisites for performing inspections, limiting conditions, requirements for special equipment and Quality Verification (QV) hold-points at which inspections are to be witnessed.
6.
Appropriate inspection requirements are established for modification, repair, and replacement.
7.
Persounct who perform quality verification inspections are qualified in accordance with appropriate codes, standards, and Company training programs, and their qualifications and certifications are kept current.
8.
Procedures for maintenance and modification are reviewed by QV personnel, or others authorized by..
QV, to determine the need for independent inspection and the degree and method if such an inspection is required, and to ensure the identification ofinspection personnel and the documentation ofinspection results.
t Page 32 of 60 l
QUALITY ASSURANCE POLICY Revision 42 9.
Procedures for Nondestructive Examination, excluding visual examination procedures performed on nuclear fuel, are reviewed by qualified personnel in FED. Procedures for nuclear fuel inspection and visual examination on nuclear fuct 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, and 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.
Verification 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 accuracy.
The General Supervisor-Quality Verification (GS-QV) is responsible for the preparation and implementation of procodures for inspection and surveillance activities performed by or for QV. (11)
Other inspections are conducted randomly to verify that overall plant operations are being conducted according to approved procedures and to ensure that the use of jumpers is properly documented; that equipment is returned to operating status after test, modification, or repair; that instmments 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 boundasy 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 personnc! according to written qualified procedures. Records of in-scryico 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 examination.
Page 33 of 60
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QUALITY ASSURANCE POLICY Revision 42 1B.11 TEST CONTRQL To demonstrate the ability of S1 :: d designated NSR structures, systems, and components to function as designed, they are subjected to e program of su:vei!!ance and operational testing. Procedures specify the systematic development, review, approval, and conduct of tests and review of test results. Conditions such as failures, nudfunctions, deficiencies, deviations, and non-conformances discovered during testing are documented and evaluated.
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 have been written and approved in accordance with basic requirements.
Nuclear Engineering Department, and CCNPPD conduct tests to verify that plant behasior confonns to design criteria, ensure that failure and substandard performance are identified and controlled, and demonstrate satisfactory performance after plant modification and maintenance activities.
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.
3.
Suitable and controlled environmental conditions 4.
Mandatory inspection hold-points for witness by BGE inspection or authorized inspector personnel.
5.
Provision for data collection and storage.
6.
Acceptance and rejection criteria.
7.
Methods of documenting or recording test data and results.
8.
Provision for ensuring that test prerequisites have been met.
Test results are documented and evaluated; they are accepted or rejected by a qualified, responsible individual or group.
Results of completed tests on SR and designated NSR structures, systems and components (per Q-List) that identify a malfunction or were out of specification are reviewed and evaluated by the POSRC and accepted and approved by the Plant General Manager. Test records are kept in sufLeient 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 pc.. % med as part of receipt inspection are evaluated, accepted and approved by qualified NSSD personnel. (5) i i
l 1
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QUALITY ASSURANCE POLICY Revision 42 i
1B.12 CONTROL OF MEASURINAMiD TEST EOUIPMENT I
Calibration controls have been established to prescribe the technique and frequency of calibration, j
maintenance, and control of measuring and test instruments, tools, gauges, fixtures, reference and transfer j
standards, and nondestructive test equipment used in measuring, inspecting, and-monitoring SR and desigrated NSR components, systems, and structures during the operations phase of CCNPP.
l Personnel of the following functional organizations control. cahbrate, and adjust measuring and. test equipment:
System Operation and Maintenance Dwartment Calvert Cliffs Nuclear Power Radiation Safety Plant Department Performance Engineering Unit Mcchnical Maintenance Electrical and Controls
- Nuclear Operations
- Chemistiy 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, ga.iges, instrunsents, and related test and measuring devices are of prore xuracy 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.
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.
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 equipment.
Test and meuuring equipment that cannot he adjusted to required tolerances during calibration is identified and placed in a designated segregated area; if the equipment can be used in limited applications, the limitations are identified.
The status of each item contro!!cd 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.
Page 35 of 60
l QUALITY ASSURANCE POLICY Revision 42 Measuring and test equipment is controlled to prevent the use of uncalibrated or defective equipment, the spread of radioactive contamination, the introduction ofimpurities into high-purity systems, and damage to i
or loss of equipment. Identification tags are placed on measuring and test equipment to indicate such l
special conditions as radioactive cleanliness, special limitations, or failure to meet established calibration requirements.
Measurin3 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, proVsions are established to document the basis for calibration.
l IB.13 HANDilNG. STORAGE. AND SHIPPING j
i Appropriate and special requirements for handling, preservation, stm yn b irm, packaging, and shipping of SR and designated NSF stems are specified in procurement humeau i
Pmecchires have been established to ensure that the handling, preservation,. Stm; %.ng, packaging, and shipping of SR and designated NSR items are performed in accordance v4 spmfN requirements to reduce the likelihood of damage, loss, or deterioration by such environmental coadinct.s is temperature or humidity.
Special handling, preservation, storage, cleaning, packaging, and shipping activitics associated with SR and designated NSR items are perfonned by suitably trained personnel in accordance with specific written procedures.
Controls have been established for the safe storage of hazardous materials. Items with a limited shelf-life are controlled to ensure that they will not be used in SR and designated NSR applications after expiration of designated shelf-life periods.
1B.14 INSPECTION. TEST. AND OPERATING STATUS Controls have been established for the application and removal of status indicators such as tags, markmgs, labels, and starnps to ensure that the inspection,- test, and operating status of SR and designated NSR stmetures, systems, and components is clearly indicated at all times.
1 Procedures / instructions are prepared to identify and control inspection, testing, and operating status by the l
use oflogs, fonns, 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 bypessing 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 activitics affecting quality can be performed.
The Manager NQAD is responsible for the performance of surveillances to verify that the inspection, testing, and operating status of structures, systems, and components are properly identified and controlled during operation, maintenance, and testing of the plant.
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 i
established to ensure that the status of non-conforming, inoperative, or malfunctioning SR and designated NSR structures, systems, or coinponents is identified to prevent inadvertent use.
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QUALITY ASSURANCE POLICY Re ision 42 1B.15 NONCONFORMING MATERIALS. PARTS. OR COMPONENTS (6)
Controls have been established for identifying, documenting, segregating, reviewing, dispositiomng, and q
notifying affected organizations ofIssues affecting materials, parts, or components (i.e., items).
Issues affecting nuclear plant items are referred to as nonconfonnances. Nonconformances are hardware deficiencies which render the quality of an item unacceptable or indetenninate.
Any individual identifying an actual or suspected nonconforming 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 to prevent inadvertent installation or use.
Nonconformance control documents are submitted to responsible departments for resolution-Designated personnel have the responsibility and authority for approving the resolution of nonconformances.
Nonconformance control documents are not closed until corrective actions have been completed.
Nonconforming items are dispositioned as rework, repair, reject, or accept-as-is. He disposition of a repair or accept-as-is nonconfonnance is treated as a design change and is evaluated and approved or rejected by the RDO.
Reworked, repaired, and replacement items are inspected and/or tested in accordance with the original inspection and/or test requirements or acceptable alternatives to ensure that critical characteristics possibly affected by the nonconformance remam acceptahic.
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 t'or 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)
Controls have been established to ensure that Issues are identified, documented, reviewed, and corrected.
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 IB.15).
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.
c Issues identified as potentially impacting the safe production of nuclear power are evaluated for Technical Specification Operability, NRC Reportability, Nuclear Safety Significance, and if the activity should be stopped. The VP-NED, or designated alternate, is informed 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 responsible for resolving the Issue and to progressively higher levels of management until the issue is resolved.
Page 37 of 60
QUALITY ASSURANCE POLICY Revision 42
)
Significant Issues require a root cause analysis and the implementation of corrective actions to prevent recurrence and are reported to management for review and assessment.
1 Issues are periodically analyzed for the identification of adverse quality trends. The existence of an adverse quality trend is resolved in accordance with this section. A Trend Report is issued to management at intervals specified in approved procedures.
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 activities. 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; determining the cause of an accident or malfunction of an item; and providing required baseline data for in-service inspection.
Non-permanent records, which show evidence that a SR and designated NSR activity was performed in accordance with applicable requirements, are retained for periods sufficient to ensure BGE's ability to reconstruct significant events and to satisfy applicable regulatoiy requirements. Retention periods are based on requirements specified in QA Program documents. Retention periods shall be documented.
Procurement documents specify vendor responsibilities for the generation, retention, and submission to BGE of quality assurance documentation related to the fabrication, inspection, and test of SR and designated NSR items and services.
Inspection and test records contain the following as appropriate:
1.
Description of the type of observation.
2.
Date and results ofinspection or test.
3.
Information related to noted discrepancies, including action taken to resolve them.
4.
Identification ofinspector or recorder of data.
5.
Statement as to acceptability of results.
Controls have been provided to ensure that records are protected from possible destruction. Within established time-intervals, completed lifetime records are transmitted to the Records Management Unit for incorporation into the Long Term Records Storage and Retrieval System.
Page 38 of 60
L QUALITY ASSURANCE POLICY
. Revision 42 '
- 1B.18 -
AUDITS 4
~
Internal audits are perfonned by BGE's Quality 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 co...g.d.ensive iad~=adaat veri 6cataan and evaluaten of quality-related.
activities and procedures. Audits ensure the effective and proper implementation of BGE's QA Program.
They are scheduled on the basis of the importance to safety of activities being perfonned Vendor audits are performed to evaluate QA programs, procedures, and activities. Audits of major vendors _'
are made early enough to ensure compliance with all aspects of BGE's procurement documents. Additional audits are performed as required to ensure that all requirements of BGE's QA Program are properly implemented according to procurement documents.
Audits of designated activities as required by the TSs are performed under oogmzance of the OSSRC.-
Audits are performed in accordance with preestablished written procedures or checklists by qualified NQAD personnel who have no direct responsibility for the work being audited. Technical specialists from other BGE departments and outside consultants may assist as necessary in performmg audits. Audits include objective evaluation of quality-related practices, procedures, instructions, activities, and items, as well as review of documents and records.
Reports of audits are analyzed and documented. Results the indicate the QA Program to be inadequate, ineffective, or improperly i...ek.u.ted, including the need for re-audit of deficient areas, are reported to the Manager and Supervisor of the audited activity. Controls have been established for verifying that corrective action is tal.cn promptly to correct noted deficiencies.
To ensure that BGE's NQAD complies with the requirements of BGE's-QA Program, an indapandant management audit of NQAD activities is performed annually by a Joint Utility Management Audit (JUMA)
Team.
Page 39 of 60 i
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QUALITY ASSURANCE POLICY Revision 42.
i TABLE IB-1 j
HALTIMORE GAS AND ELECTRIC COMPANY'S POSITION j
ON GUIDANCE CONTAINED IN ANSI STANDARDS,
Revision ofIndustry Standards Aeolicable to the i
Baltimore Oas a_ndElectric Ouality ssurance Program Reauirement
'{
Some of the Industry Standards listed in Section 1B.2 identify other Standards that are required, and some f
Regulatory Guides define the revisions of those Standards that are acceptable to the NRC.
Resnonse BGE's QA Program was developed to respond to the specific revision of the documents listed in Section
- 1B.2 and is not neceasarily responsive to other documents listed in the referenced ladustry Standards.
ANS 3.2 - 1976 Item 1 Egquirement Section 5.2.15 requires that plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure every two years to detennine if changes are necessary or desirable.
l
Response
f BGE applies this requirement of a two-year review to all plant procedures except test procedures performed less oRen than every two years or at unspecified frequencies. These are reviewed no more than 60 days i
before performance.
Reason Engineering Test Procedures (ETPs) and others like them are written for a one-time-only perfonnance and l
kept for reference for future similar tests. If they are used again, they are reviewed and modified to meet conditions existing at the time of performance.
Some Surveillance Test Procedures (STPs) are performed every three to five years. They too are reviewed before each performance to ensure that they are compatible with existing conditions and responsive to current needs.
- Item 2 (10)
Recuirement 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 shin and hold a senior operators' license on the unit affected.
l Page 40 of 60
- QUALITY ASSURANCE POLICY Revision 42 l
Response
BGE does not require the Shift Supervisor to be the Senio-Reactor Operator (SRO) approving temporary -
l changes to procedures; any active SRO (either on-shift or on-staff) may provide the SRO approval for procedure changes.
Reason j
Many proposed temporary procedure changes do not require the Shift Supenisor's immediate attention or
{
knowledge of the change since they do not affect plant safety. Other SROs are available and qualified to perform this task since the Shift Supenisor's detailed review of the proposed change is not necessary to -
casure plant safety.
i Requiring the Shift Supervisor to review all changes is burdensome and contrary to plant safety in light of i
th: total number of procedures that exist and the time the Shift Supenisor must dedicate to ensuring the i
plant is safely operated and maintained. Additionally, our Technical Specification requires this approval be from someone holding sn SRO license (not necessarily the Shift Supenisor).
ANSI N18.1 - 3/8/71 i
Item I Reauirement 5
i Paragraph 4.2.2 states that at the time of initial com loading or appointment to the active position, the Operations Manager shall hold a Senior Reactor Operator's (SRO) License.
j Paragraph 3.2.1 states that positions at the functional level of Manager are those to widch are assigned broad responsibilitics 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.
l principal members of the operating organization reporting directly to the plant manager and having overall
-i responsibility for operation of the plant or for its maintenance or technical service actisities.
l
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
-I the requirements of both pamgraphs 3.2.1 and 4.2.2. The Superintendent-Nuclear Operations will satisfy paragraph 3.2.1 and most of 4.2.2 cxcept that he will not maintain an SRO license. Instead, the Superintendent-Nuclear Operations will hold or have held an SRO license. De GS-NPO will hold and 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 manages.
t i
Page 41 of 60 i
QUALITY ASSURANCE POLICY Revision 42 Reawn The Supermtendent-Nuclear Operations will hold or have held an SRO license, as opposed to having a license at the time of appointment to the position. He will have an excellent understanding of plant operations. The GS-NPO will not only hold an SRO license at the time of appointment to the position, but he will maintain the license. The GS-NPO directly supervises the operating shift organization, whereas the Superintendent-Nuclear Operations is also responsible for operations procedure development, modifications acceptance, and operations / maintenance coordinations. The Superintendent-Nuclear Operation's level of supenision does not require current in-depth and plant specific knowledge which results from maintaining an SRO license.
Item 2 (17)
Esquirement Paragraph 3.2.2 states that supervisors are persons principally responsible for directing the actions of operators, technicians, or repairmen. Those positions usually designated as intermediate and first line supervisors are included in this category.
Paragraph 4.3.2 states that supervisors not requiring Atomic Energy Commission (AEC) licenses shall have a high school diploma or equivalent and a minimum of four years of experience in the craft or discipline he supervises.
Response
Baltimore Gas and Electric has three supenisory positions in its organization - Supenisors, and in some cases Assistant General Supervisors and General Supervisors - which are organizationally equivalent (when supervising technicians / repairmen) to the positions described in paragraph 3.2.2 of ANSI N18.1-3/8/71. All these individuals need not possess the four years of craft / discipline experience required by paragraph 4.3.2.
Instead, at least the first line supervisor shall possess four years experience in the craft / discipline he supervises while other supenisors in the organization may be selected to fill supervisory positions based on possessing a minimum of an Associate's Degree, with four years of related technical experience, and demonstrated supervisory ability. (18) Additionally, all first line and intermediate supervisors shall have at least a high school diploma or equivalent.
Itcason i
To provide a balanced and broad base of supenisory ability within the site organizations made up of i
technicians / repairmen, it is desirable to include as supervisors both individuals with extensive craft / discipline experience accrued through field work and individuals with related education and experience who have demonstrated the ability to effectively supervise.
Beguirem_gni i
Subsection 3.2 outlines requirements for demineralized water.
BIsponst l
BGE specifications for demineralized water are different than the specifications outlined in the standard.
i l
Page 42 of 60
QUALITY ASSURANCE POLICY Revision 42 Reason i
BGE 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 N45.2.1.
ANSI N45.2.2 - 1972 Item 1 Reauirement Subsection 2.4 could be interpreted to mean that on-site and off-site personnel who perform any inspection, examination, or testing activities related to the packing, shipping, receiving, storage, and handhog ofitems for nuclear power plants shall be qualified in accordance with ANSI N45.2.6.
Ec_soonse BGE requires that only persons who are responsible for approving items for acceptance shall be qualified in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6) and that personnel who verify that storage areas meet requirements will be qualified to either Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or ANSI N45.2.23.
Er4WD Our receipt inspection procedures require persons who approve items for acceptance to be qualificd in accordance with Regulatory Guide 1,58 (which endorses ANSI N45.2.6). QV technicians, inspectors or s
QA auditors verify that storage arcas moet requirements. All rather inspection, examination, and testing activities are subject to review by persons qualified to Rc.gulatory Guide 1.58 (which endorses ANSI l
N45.2.6).
Item 2 Reauirement The second sentence of Subsection 2.4 requires that:
Off-site inspection, examiaation, or testing shall be audited and monitored by personnel who are qualified in accorde.ce with ANSI N45.2.6.
Response
BGE uses personnel qualified in accordance with ANSI N45.2.23 to perform auditing and monitoring functions.
Reason The quahfication requirements for auditors cannot always be met by persons qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6).
Pa.ge 43 of 60
QUALITY ASSURANCE POLICY Revision 42 Item 3 Reouirement 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 comrols depending on the importance of the item to safety and reliability.
Response
1.
The level of protective measures defined by Subsection 2.7 are applied to Basic Component purclases.
- 2.
Personnel of BGE's Nuclear Engineering Depar: ment (NED) will determine the level of protective measures to be applied to Commercial Grade purchases.
Ecason BGE's position is as follows:
1.
For Commercial Grade items, it is not always possible to assign a level of classificetion in accordance with ANSI N45.2.2, as many items are purchased after they have been packaged by the manufacturer and shipped to his local agent, the wholesaler.
2.
Experience has shown that the level of protection assigned to Commercial Grade items by vendors is adequate.
Item 4 Reanirement Subsection 3.0 specifics detailed requirements for packing items for each level defmed in Subsection 2.7.
Response
BGE has replaced Section 3.0 with the following:
1.
Packaging for Shipment to BGE Personnel of BGB's NED or NSSD shall ensure that procurement documents for Basic Component 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 requirements for items in that classification defined in Regulatory Guide 1.38, Rev. 2 - March 1977.
2.
The normal methods of packaging used by the industry in general are acceptable for itents being procured as Commercial Grade.
i t
Page 44 of 60 m
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- QUALITY ASSURANCE POLICY m
~
- Packaging for Storage by BGE.
' 3..
. In general the packagag used by the vendor to ship items for all types of purchases to BGE need not -
' be retamed 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. L Special or umque
' items, howewr, may require special protective measures. For such unusual items, the Department that initiated the purchase, together with NED, or NSSD nhall identify if any of the requirements of ?
t Section 6.4.2 of ANSI N45.2.2 - 1972 apply.
j Reason
-.i..
This substitution will ensure that the item will receive adequate protection during slspment and-1.
storage, thus climinating unnecessary restrictions and enabling BGE to use commercial sources to' i
the utmost.
1 2.
Experience ~shows that industrial practices for packaging Commercial Grade items are adequate for l
~
most applications.
IkaL6
.l Requirement l
Section 4.0 defines shipping requirements related to the protecten levels assigned to items.
]
Resoonse BGE has replaced Section 4.0 with the followmg*
l 1.
Shipping to Baltimore Gas and Electric
'l';
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 perwl have specified in procurement documents that the item shall be packaged in conformance with ANSI N45.2.2, Section 3.8.-
i BGE will not invoke the requirements of ANSI N45.2.2 -(1972, Section 4.0, on Commercial Grade
-l item purchases.
l 2.
Shipping from Baltimore Gas and Electric items shipped from BGE need not conform to any of the requirements of ANSI N45.2.2, but tim -
t orgar.ization that packs and handles the item shall provide roughly the same level of protection that the item was given during shipment to BGE.
l Remon If engineering personnel have determmed 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 :
4 only for repair, the detailod requimments specified in Section 4.0 of ANSI N45.2.2 are'not necessary.
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Page 45 of 60 j
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-- QUALITY ASSURANCE POLICY-3 T
Revision 42
/.
Item 6 RequirsmnIn
'i Subsection 6.4 gives detailed requirements for care ofitems in storage, according to the protection levels
- assigned to the items.
R9:ipsnac
.l BGE does not require items to be stored in the packing used for shipment if the storage level in the area -
provides the same protection as the level of packing assigned to the i+ cms. ' 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 tracaportation, j
'i Reason i
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 requirements purely on the i
categories in Subsection 2.7 of ANSI N45.2.2 - 1972 i mpractical. BGE requires NED or NSSD-l personnel to specify requirements more closely related to be actual function of items and to storage conditions.
j i
htIIL1 l
Reauirement j
Subsection 7.3.3 requires compliance with a series of ANSI documents.
.l Ess e.s t
BGE controls for the use of hoisting equipment are compatible with the Standards listed in Subsection 7.3.3 of ANSI N45.2.2, although at the discretion of the Plant General Manager, they need not.be I
compatible with documents referred to in these documents.
i Reason Lower-level documents referred to in the documents listed in Subparagraph 7.3.3 will not necessarily affect -
j the ability of BGE personnel to properly handle SR items and could lead to confusion.-
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i Page 46 of 60 l
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QUALITY ASSURANCE POLICY
- Revision 42 -
11G111.1 Requirement Subsection 2.1 outlines housekeeping cleanliness mquirements for five designated zones.
Resnonse 1
1
- BGE has established thrco classes for cicanimess requirements. 'Ihere 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 I
. Roanon l
1
~ 1.
ANSI Zone I level of cleanliness applies to new construction activitics.
2.
Where required, smoking restrictions are posted for BGE's class 3 areas.
-l 1
Ite m 2' i
Regmrement I
. Subsection 2.1 requires for Zones I, II, and 111, that a written record of the entry and exit of all personnel ami material shall be establisimd and maintained.
Ecsponse
- l BGE has established the following methods for personnel and material accountability:
l.
Written accountability.
. 2.
Where possible tethering of tools and materials to permanent plant structures or persons.
i 3
Port-maintenance closcout inspections.
.j Reason
- l BGE's three methods of accountability offer the same level of control as that required by the standard.
-l
.l L
la Reauirement The last paragraph of Subsection 6.2.1 (Equipment Tests) states:
l Items requiring calibration shall be tagged or labeled on completion indicating date of calibration and identity of person that performed the calibration.
-i i
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'j a
E Page 47 of 60
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1,
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1
(
QUALITY ASSURANCE POLICY Revision 42 l
Resnonse I
The new calibration program at Calvert Cliffs does not use calibration stickers that contain date of calibration and identity of person that performed the calibration. 'Ihe new calibration stickers indicate that i
the instrument is periodically calibrated according to the calibration program. The sticker, a green "C,"
means the instrument is in the program.
Reama In the p ast, the date of calibration noted on the instrument was important because the calibration history of preventive maintenance was not kept on computer. Computer tracking systems and trending programs did not ex4t. In the new system, the date of calibration being on the sticker 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 maintenance 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 th program. By maintaining the database, we ensure that no instruments are identified as calibrated the are not. In the new program instruments identified as calibrated art kept up to date and specific a1 formation is kept on l
computer with no need for that information to be on the sticker.
Item 1 Reanirement Subsection 1.2 states in part, The requirements of this standard apply to personnel who perform inspection, exammation, and tests during fabrication prior to and during receipt of items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.
Resnonse-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 nuc! car 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 DGE personnel who perfonn inspection, examination, and testing functions associated with nonnal operations of the plant are qualified either to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1 - 1971.
Reason-A
- 1.
The individuals who perform inspection, examination, and testing functions associated with nortnal operation of the plant, such as maintenance and certain technical irviews, are normally qualified to ANSI N18.1 - 1971.
l Page 48 of 60 i
QUALITY ASSURANCE POLICY' Revision 42 2.
Some testing activities conducted during normal operation of the plant, such as surveillance testing, '
do not require that test personnel moet the requirements spectfied in Paragraph 4.5.2 of ANSI N18.I'
'l for tecluncians. Personnel qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) arei j
- dam *1y qualified to conduct such testing.
j f
Response-B
,j BGE does not 'always require vendor personnel perfornung inspection or test' activities to comply with 'the :
l
- requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) but evaluates the need for invoking -
'j
- 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.
- l Reason-B i
i BOE's position is as follows:
.I l
1.
For replacemmt items purchased as Commercial Grade Items, the purchaser may not impose-
)
nuclear uniq se requirements on the vendor. Additionally, items may be manufactured before j
placement of'the purchase order and the vendor may not be required to maintain records of the
.i performance efinspections or tests.
2.
For Basic Componant Purchases, the qualification requirements for inspection, examination, and test personnel are determined by:
3
?
a.'
Item status (new or replacement).
~
- b.
Complexity and importance ofitem.
c.
Manufacturer's QA program approval level (Appendix B, ANSI N45.2, etc.).
I
-l Response <
l BGE does not require personnel who perform specific limited and repetitious inspection functions, such as
)
- inspection for removal or replacement of snubbers, to be trained as required by Regulatory Guide 1.58 -
(which endorses ANSI N45.2.6).
Reason-C Inspections, examinations, or tests that are repetitious or of limited scope need not be performed by -
)
individuals qualified to the requirements:of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) provided that they receive instruction in the following:
i i
1.
Activities to be verified.
-)
i 2.
Acceptance criteria.
j 3.
Method of documenting results.
4 Method of reporting deficiencies.
'Ihe person responsible for the inspection activity ensures that such instruction is given to inspectors before they perform specific inspection functions, and that both this' training and the acceptability of the results of the inspectmn are documented.
4 Page 49 of 60 l
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i Revision 42 -
Response-D
- i When it is' necessary to monitor the activities of a vedor, BGE uses personnel T-"hd as auditors in.-
p -
accordance with ANSI N45.2.23 or inspectors in accordance with Regulatory Guide 1.58 (which endorses -
i
- ANSI N45.2.6).
- i Reason-D.
3 I
Both Regulatory Guide 1.58 (which~ endorses ANSI N45.2.6) and ANSI N45.2.23 establish training r.
requirements suitable for monitoring vendor activities.
i lisal 1
i Reauirement f
Table I specifies that Level III personnel shall be capable of qualifying Ixvel III personnel.
Response
I When there is only one Level III position or when a new Level III position is created, BGE personnel with..
.l the title General Supervisor, or higher, qualify level III personnel l
i Reason
- 1 BGE personnel in these grades are capable of certifying Level III personnel without being tramed as Level III inspectors.
t NOTE:
j i
Regulatory Guide 1.58 (which endorses ANSI N45.2.6-1978) states in part, under item 6 of Regulatory Position, that..."In' addition to the i
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 carned the General Education Development equivalent of -
l 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, l
and testing personnel hired or assigned after November 27, 1984,' in r
addition to the present commitment to ANSI N45.2.6-1978 for the qualification of such personnel.
}
ltem 1
- Reauirenwa Section 4.0 titled " Receipt" gives instructions for receipt controls.
Respousp BGE applies these recrireme.its only to the receipt of records by tie Plant History File.'
Page 50 of 60 m$.ev4
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l QUALITY ASSUR "NCE POLICY Resision 42 Reason i
Most records acceived by such organizations as Receivmg Inspection, Engineering, etc., are not shipped in j
a manner that makes these requirements applicable. These requirements are applicable, however, when the
{
records are fmally turned over to the Plant llistory File.
j LtLn11 Reauirement j
Subsection 5.6.1 reads as follows, " Design and construction of a single record storage facility shall meet the following criteria:" Items a) and b) of the subsection stato 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 included."
Resoonse/ Reason itern a The intent of this requirement is both structural integrity and fire resistance. This vault is entirely enveloped by a structurally sound, fire resistive building. Second, the vault rests on a reinforced slab on grade and its walls extend fully to the underside of the structural deck. Hird, the walls of the vault are -
constructed of gypsum wallboard on metal studs per Underwriters Laboratory Test Number U412, assuring the equivalent of 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire resistive construction. This is equal construction to concrete block in terms of fire protection. ne walls carTy no structural load; hence, they provide equivalent structural integrity to that needed of concrete block. 8 (See footnote following page).
Enstonse/Reasoll item b Again, the vault is contained within an erwironmentally protected building. As such, it has no roof, or need for floor drain.I (Sce footnote).
Item 3 kguirement Subsection 5.6 allows only the dual facility defined in Subsection 5.6.2 as an alternative to the single facility defined in Subsection 5.6.1.
IThese responses have been forwarded to the NRC by the BGE letter dated 02/11/83 from Robert G. Nichols, Sr. Facilities Project Administrator, Real Estate and OfBcc Senices 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. Haass, Deputy Chief, QA Branch, Division of Quality Assurance, Safeguards, and Inspections Programs, Office ofInspection and Enforcement.
Page 51 of 60
QUALITY ASSURANCE POLICY :
~ Revision 42 DGE allows the following alternative storage requirements for organizations other than the Records y===;:-- := Unit:
fOrganizations that originate records and do not ' transfer them to the Records Management Unit-
. within 30 days of completion shall establish one of the followmg three controls as alternatives to the requirements specified for the Records Management Unit:
1.
Duplicate Storage
.y Either A or B.
l A.
Within 30 days of completion of a record, a duplicate accord file shall be established. His activity shall be controlled by procedures which provide for the following:
j 1
1.
Assignment of responsibility for records.
2.
Description of storage area.
{
3.
Description of filing system.
l 4.
An index of the filing system.
t 5.
Rules goveming access to and control of files.
.l 6.
Methods for maintaining control of and accountability for' records removed fmm the-i file.
- i 7.
Method for filing supplemental infonnation and disposing of superseded or obsolete -
i records.
.l 8.
Method for preserving records to prevent deterioration..
l i
9.
Method for maintaming specially processed records that are' sensitive to' light,.
I pressure, or temperature.
-l 10.
Transfer of. duplicates to the Records Management Unit within two years of
]
completion of records.
B.
Make arrangements with at least one other department that receives a copy of each document to subject this other copy to the controls specified above.
~
j l
2.
Fire-resistant Building Storage Records shall.be stored in steel cabinets located is a fire-resistant building or a non-combustible building with a fire suppression system.
He procedural controls defined for duplicate storage sliall be applied.
i 3.
Non-fire-resistant Building Storage
{
Within non-fire-resistant facilities, records shall be stored in UL one-hour-minimum firc-rated i
storage cabinets and be subject to the procedural controls defined for duplicate storage.
]
Page 52 of 60
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f ri QUALITY ASSURANCE POLICY Revision 42 DGE defines a Fire-resistant Building as follows:
A facility constructed to resist the initiation or spreadmg 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.
Reason Although these alternatives are compatible with standard methods of handling records, they do not materially decrease the level of protection afforded to the records.
ANSI N45.2.23 - 1978 Item 1 E.couirement 2.3 Qualification ofIxad Auditors Section 2.3.1 requires prospective Lead Auditors to obtain a minimum 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:
Education and Experience lhe 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 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 quahty assurance, score three credits.
1.2 For the Master degree in engineering, physical sciences, business management, or quality assurance from an accredited institution, score one credit.
1.3 For the successful completion of part of the required curriculum for an Associate, Bachelor, or Master degree, score a corresponding percentage of the credits specified above for the degree.
1.4 For the successful completion of Navy Nuclear Training, its equivalent in another armed service, or the training required for becoming a licensed operator in a commercial nuclear power plant, score two credits.
Page 53 of 60 1
Y L QU/AITY ASSURANCE POLICY 2.0 Experience (9 credits maximum).
2.1 Techmcal Experience (5 credds maximum) i For experience in engineering, manufacturing, construction, operation, or maintenance,--
l score one credit for each full year.
'2.2. - Nuclear Experience.
If two years of technical experience have been in the nuclear field, score one additional credit.-
2.3 ' Quality Assurance Experience If two or more years 'of the technical experience have been in quality assurance or l
quality control, score 'two additional credits Persons whose work ' activities' are controlled by the QA Program but who are not full-time members of the QA l
. 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 l
additional credit.
2.5 Supplemental Experience j
- 1 a corresponding percentage of the credits specified. '
ll Persons who have a proportion of the experience specified in 2.12.4 may be awarded j
2.6 - Time exclusively spent in training does not apply as credit toward experience requirements for lead auditors.
v 3.0 Training (2 credits maximum).
t Persons who ham weessfully' completed the training requirements of ANSI N45.2.23 may'
'.j be given two crao I
4.0 Rights of Management (2 credits maximum)
The Manager-NQAD, may grant additional credits for other performance factors applicable j
to auditing as follows:
1 4.1 For certification of competence in engineering or science related to nuclear power plants, or in quality assurance specialties, issued and approved by a State Agency or National Professional or Technical Society, score two credits.
4.2 For nuclear experience in excess of 2 years, score onc credit for cach two years -
t Cxpericace j
q 4.3 For practical experience that can be related to power plants, in excess of 5 years, score l
one credit for each two years of experience.
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QUALITY ASSURANCE POLICY Revision 42 Reason DGE is in agreement with the basic purpose of ANSI N45.2.23-that is, to establish minimum educational or experience requirements for Lead Auditors. We think, however, that the system of credits outlined in ANSI N45.2.23 tends to reduce the size of the pool of potential replacement auditors without making redeenung improvement in the capabilities of persons selected.
We calculated the credit score of 11 of our present Lead Auditors at the time they were appointed Lead Auditors. Six had completed Navy Nuclear Training and spent several years in the Navy Nuclear Program. Four of these scored only 8 credits total, including 2 credits allowed by paragraph 2.3.1.4 'of ANSI N45.2.23 for rights of management based on their having completed the BGE QA training programs for Lead Auditors.
One of our auditors, with neither nuclear nor power plant experience, had a credit score of 12 because he held a Bachelor's degree in engineering and was a professional engineer with over 5 years design experience.
Because all of these individuals have acted as Lead Auditors satisfactorily for several years, it appears that the credit system should be revised slightly to allow for the differences in education and experience of prospective Lead Auditor candidates.
We consider the flaw in the current system to be the emphasis on educational requirements that will allow a person with a Master's degrec and no nuclear or power plant experience to become a Lead Auditor, but will exclude a person who has no degree, even though he may have 20 years' experience in operating or maintaining nuclear or power plant systems.
The practical balance between education and expenence 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.
For these reasons, we think that the supervision of prospective Audit Team Leaders should be given more flexibility in determining whether, for a particular individual, educational or professional qualifications are more significant 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 Nuclear Training or its equivalent in another armed service, or someone who has completed the training required to become a licensed operator in a commercial nuclear power plant, should receive the same credit as a person who has an Associate degree from an accredited institution in engineering, physical sciences, mathematics, or quality assurance.
The points now awarded for education are related to the effect that formal courses might have on tne ability 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 allowed for that course.
The requirements for training specified in ANSI N45.2.23, paragraph 2.3.2, would seem to ensure tlnt 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.
Page 55 of 60
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QUALITY ASSURANCE POLICY Revision 42 Similarly, the present system recognizes the effect that working in a QA Program will have on the ability of a person to compmhend regulations and technical requirements. Persons who are not assigned as full-time members of the QA Orgaruzation, however, receive similar exposure if they perfonn activities controlled by a QA Program. We therefore allow such persons half the credits specified for quality assurance experience.
Ikm2 Entdrsment 3.3 Requalification Lead Auditors who fail to maintain their proficiency for a period of two years or more shall be required to requalify Requalification shall include retmining 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.
Resoonse BGE requalifies Lead Auditors on the basis of the satisfactory performance of one audit, as observed by a qualified Lead Auditor.
Renwn The purpose of the training specified in paragraph 2.3.3 of the Standard is to ensure that candidates understand the fundamentals of auditing and the requirements for 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 Codes, Standards, Procedures, instructions, and other documents related to QA Programs and program auditing. BGE considers that the satisfactory performance 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.
ANSI N101.4 - 1972 Reauirement Section 1.2 specifies applicability requirements for the Standard.
Response
BGE requires that only activities performed inside containment structures and related to protective enatings applied to ferritic steels, aluminum, stainicss stcci, zinc-coated (galvanized) steel, concrete, or masonry surfaces shall conform to applicable Sections of ANSI N101.4.
Reason Deterioration of protective coatings apphed to surfaces outside containment structures would have no detrimental effects on the safe operation of the plant.
Page 56 of 60
QUALITY ASSURANCE POLICY Revision 42 i
Requiremerrj l
ANSI N45.2.13 could be interpreted to mean that all requirements of this standard are applicable to all safety-related items or services.
Ecsponse i
BGE has two approaches for safety-related and designated non-safety related procurement as described in i
Sections, IB.4 and IB.7.
Controls established for Dasic Component Purchases correspond to the requirements of ANSI N45.2.13 The extent to which the individual requirements of ANSI N45.2.13 are applied to Commercial Grade Purchases depends on the nature and scope of the work to be performed and the irnportance to nuclear safety and the items or services purchased. This approach is consistent with the introductory discussion in Section 1.3 of ANSI N45.2.13 - 1973.
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Page 57 of 60
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QUALITY ASSURANCE POLICY Revision 42 ATTACHMENT A-1 BASES FOR QA POLICY REVISIONS (I)
Entry PRF-Q No.
,_No Bases for Revision (s) m 1.
771 Procedure UpgradeAction Plan (PUAP). per L B. Russell letter 1-20-89.
2.
783 10 CFR Part 21 reattirements.
3.
797 NRC Inmect_ ion #RO-16/R9-17 (Letter from R. E. Denton to R. P.11cibel dated July 13.1989.)
4.
824 NRC letter from M. W. Hodees to G. C. CrenLiiat_ed March 13.1990. This letter aooroved a one-time exemotion to the ocriodic review nxtuirements for orocedures scheduled tg_be uncraded by the Procedures Uncrade Proicct. This exemotion was discontinued and removed by PRF-O 954.
5.
844 Prggprement Procram Pro.yect uocrade. Performance Improvement Plan (PIP)
Action Plan #5.3.1 and OAU Audit Findinz 87-13-01 6.
844 IB.15 and 18.16 revised to clearly establish procram applicability and controls, consistent terntinoloav. e;M6pdonal reroonsibilitigs_and focused aooroacji towards develoning and ing%gf.qag an intecrated Management System.
7.
891 PIP Acti9n Plan 5.3.1 Follow-On Activity.
8.
394 18.15 and 1 B.16Jevised to clarify reauirements which will permit imol mentatiga t
of the issues Manacement System - PIP item 4.10.0.
9, 854/907 fr. C. Creel leticLlo the NRC dated 7/26/91 which discussed modifications to. and acccotance of. (hances to the OA Policy invohine OA compliance reviews of OAPs and Directives 10.
815 G. C. Creel letter to the NRC_ dated 10/3/90 discussing temporaty chances not affcctinc "Anoroved Procedure Intent" and the relieving _ nf the Administrative Burden on Shift Suoervisors Page 58 of 60
w, 7.m QUALITY ASSURANCE POLICY Revision 42
- ATTACHMENT A-2 BASES FOR QA POLICY REVISIONS (1)
Entry PRF-Q No.
No.
Bases for Revision (s) 11.
887 Audit Findina No. 9026-01 (Imolementation pfSprveillance Reauirements).
)
12.
954 G. C. Creel letter to the NRC dated 7/3/91 discontinuing the one-time temporary chege to theyeriodic review interval anoroved in Dasis (4) above.
13, 957 PIP Action Plan follow-on activity (5.3.1).
14.
953 Mctinn Plan 4.1 ind NUREG-0737 (TMI Action Plan Reavirements)
P Item I.C.5. " Procedure for Feedback of Oneratin1 xperience to Plant Staff."
E 15, 990 Q/LQSurveillance 5-92-28 " Interface Between Facilities Management Department Itnd Nuclear Enercy Division on Projects at Calven Cliffs." Recommendation 4.2.
16.
998 OA Audit Recommendation 92-04-R03 GSESI operational chase).
17.
93-06 NOAD Audit Finding 92-10-01. Facility _StaffTrainina.
18.
93-06 I,etter from M. C. Modes of the NRC to R. E. Denton dated June 21.1994.
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Page 59 of 60
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