ML20096E510

Resubmitted Rev 13 to QA Program

ML20096E510
Person / Time
Site:	Indian Point
Issue date:	12/31/1995
From:	CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:
Shared Package
ML100430644	List: ML20096E510
References
NUDOCS 9601220212
Download: ML20096E510 (93)

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Revision 13, December,1995 QUAUTY ASSURANCE PROGw l

9601220212 960108 ^

PDR ADOCK 05000247 PDR P

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t TABLE OF CONTENTS +

SECTION. PAGE NO.

Foreword............................................................................................... i  :

3.0 OWNER ORGANIZATION . ... . . . .. . . . . . .. . . . . . . . . . . .. . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . .. . . .. 1 l 3.1 General........................................................................................ 2'  !

3.2 - Assignment of Authority and Responsibility............................. 2 l 3.3 Indoctrination and Training ...................................................... 5 l

3.4 Onsite Operating Organization ................................................ 6 4.0 REVIEWS AND A UDITS .. . . . . . . . . . . . . . . .. ... .. . . . . . . ...... . . ... . . .. . . ..... . . . . . . . .. . . ..... . .. . . . . 8 l 4.1 Audit Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 5.0 PROGRAM, POUCIES AND PROCEDURES ........................................ 11 5.1 Program Description .. . ... . . . . .. . .. .... . . . . . . .. . . . . . . . .. . ... . . .. .. .. . . . . . .. . . . . . .. . .. . I1  !

5.2 R ules of Practic e . . . . . . ... . . .. . . . . . . . .. . . . . . . . . . . .. . . ... . . . . . . . . . . . . . . .. . . . . . . . . . . .. . . . . 12 ,

5.2.1 Responsibilities and Authorities of Operating Per sonnel . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 . .. . .

5.2.2 Procedure Adherenc e................. ............ .. .... ...... .. . . . ....... 12 ,

5.2. 3 Operating Orders. . . . . . . . . .. . . . .. . ... . . . . . . . . .. . . .. . . . .. . ... . . . . . . . ... . .. . . 13 ,

5.2.4 Special Orders. . .. . .. . .. . .. . . .. . .. . . . . . . . . . . . . . .. . . . .. .. . . . . . . . . . . . . . . . . . . .. . . . 14  ;

5.2.5 Temporary Proc edures . . .. . . . . . . . . . . . ... . . . . . . . . .. . ... . . . ... . . . . . . . . . . . . . 14 l 5.2.6 Equipment Control. .. ... . . .. . . . .... ... ..... ..... ...... ... . . ... .. .... .. ... . .. 15 i 5.2.7 Maintenance and Modification.. .... ....... ........ ... ......... 16  !

5.2. 7.1 Maintenance.. . . .. . . . . . . . . . . .. . . . . . . .. .. . . . . .. . . . . . . . . . . . . . . . . . . . . 16 5.2.7.2 Modification s.. ... .. ...... .... ... ....... .......... .... ... . . . ... ... . 19 5.2.8 Surveillance Testing and Inspection Schedule........... 23 5.2.9 Plant Security and Visitor Control.................................. 24 5.2.10 Housekeeping and Cleanliness Control....................... 25 5.2.1 1 Corrective Actions............ . . ... ..... .. .... .. ........... ...... ........ .... 26 5.2.12 Plant Records Management.......................................... 27 5.2.13 Procurement and Materials Control.............................. .27 5.2.13.1 Procurement Document Control..................... 28 5.2.13.2 Control of Purchased Material, Equipment and Services . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . .. . 30 5.2.13.3 Identification and Controlif Materials. Parts an d Components. . . . . . . . . . .. . .. .. ... .. . . . . . . . . . . .. . . . . . . . . . . . 31 5.2.13.4 Handling Storage and Shipping.................... 33 5.2.14 Nonconforrning items.. ... . . . . . . . . . . . . . . . . . . . . . . ... .. . . . . . . . . . . . ... . . . . . . 35 5.2.15 Review, Approval, and Control of Procedures......... .... 36 5.2.16 Control of Measuring and Test Equipment................... 37

5. 2.17 Inspec tions . . . . ... . . . .. .. . . . .. . . .. . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . 38 ,

5.2.18 Control of Special Processes.... .... ....... .... .................. 39 5.2.19 Test Control . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . ... . . . . . . . . .. . . . . . . . .. . .. . . . . . . . . 41 . . . . . . ..

5.3 Preparation of Instructions and Procedures............................ 42 i

APPENDIXA Class 'N Items CHARTA Corporate Organization CHART B. Nuclear Power Organization TABLEA Interpretations / Alternates / Exceptions TABLE B Interpretations / Alternates

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FOREWORD The following quality assurance program conforms to the requirements of 10CFR50, Appendix B. Additionally, Con Edison commits to having a Quality Assurance Program complying with the Regulatory Position in the following Regulatory Guides as modified by Table A and Table B.

NRC Reaulatorv Guides 1.8 ' Personnel Selection and Training,' Revision 1, 1 September,1975 i 1.29 " Seismic Design Classifications," Revision 3, l September,1978 j l

1.30 " Quality Assurance Requirements for the Installation. Inspection and Testing of Instrumentation and Electrical Equipment,'

August 11,1972 1.33 Quality Assurance Program Requirements (Operation)," Revision 2, February,1978 1.37 " Quality Assurance Requirements for Cleanmg ,

of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants", March  ;

1,1973 l

1.38 " Quality Assurance Regt2rements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants," Revision 2, May,1977 1.39 " Housekeeping Requirements for Water-Cooled Nuclear Power Plants," Revision 2, September, 1977 1.54 " Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants,' June,1973 1.58 " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel,' Revision 1, September,1980  :

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. I 1.64 ' Quality Assurance Requirements for the Design of Nuclear Power Plants," Revision 2, June,1976 1.74 " Quality Assurance Terms and Definitions,"

Februmy,1974 l

1.88 ' Collection, Storage and Maintenance of i Nuclear Power Plant Quality Assurance Records,' Revision 2, October,1976 ,

1.94 " Quality Assurance Requirements for  !

Installation, Inspection, and Testing of Stmetural Concrete and Structural Steel during the Construction -Phase of Nuclear Power  :

Plants,' Revision 1, April,1976 1.116 " Quality Assurance Requirements for  !

Installation, Inspection, and Testing of Mechanical Equipment and Systems,' Revision '

O-R, June,1976 '

l.123 " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear i Power Plants,' Revision 1, July,1977 1.144 ' Auditing of Quality Assurance Programs for  ;

Nuclear Power Plants,' January,1979 1.146 ' Qualification of Quality Assurance Program  !

Audit Personnel for Nuclear Power Plants,' i August,1980 l Many ANSI standards endorsed by these Regulatory Guides give quality assurance programmatic control for the design and/or construction phases of nuclear power plants. Accordingly, Con Edison has, where practicable, adopted these standards' .

requirements and guidelines to the operations phase of its nuclear power plants and has developed provisions for certain operations phase conditions not addressed in these standards.

Where any discrepancies exist between this program description and the requirements and guidelines of the above Regulatory Guides, the requirements and guidelines of the ANSI Standards and associated Regulatory Guides shall prevail as modiued by Table A and Table B.

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. 1 OUALITY ASSURANCE PROGRAM 3A

. Owner Oraanization 3_d General Con Edison owns nuclear units Indian Point No. I and No. 2. Unit No. 2 is in operation.

This program of administrative controls and quality assurance applies to the operation of Indian Point Unit No. 2, including those activities conducted on the Unit No. I site that are necessary to support Unit No. 2 operation. This program is in effect at all times to assure that operational phase activities are carried out without undue risk to the health and safety of the public.

This program is documented through corporate instructions and administrative procedures developed by participating organizations and provides control of activities affecting the quality of structures, systems, and components of the nuclear plants and their operation consistent with their importance to safety.

The determination of which systems, structures and components affect safety is in accordance with 10 CFR 50 Appendix B and includes those o which comprise or are necessary to ensure the integrity of the reactor coolant pressure boundary o which ensure the capability to shutdown the reactor and maintain it in a safe shutdown condition o whose failure could result in conservatively calculated offsite doses that exceed 0.5 Rem to the whole body or its equivalent to any part of the body; and o structures whose failure could reduce the functioning of plmit features within the above categories to an unacceptable safety level.

Those structures, systems, and components are those that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public and are designated as Con Edison Class "A". Activities affecting quality are documented within a document control system which assures that instructions, procedures and drawings are reviewed and approved for release by authorized individuals.

" Class A" items include environmentally qualified (EO) equipment which are those items l

located in a harsh environment and which are in compliance with 10 CFR 50.49, the DOR Guidelines, and/or NUREG-0580.

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2-I The EQ equipment is identified on an electronic data base which is updated by an EQ ,

System Engineer. The electronic data base is accessible by organizations such as  !

Nuclear Power, Nuclear Power Engineering and Nuclear Quality Assurance. I 2

12 Assianment of Authority & Responsibility The Chairman and Chief Executive Officer of Con Edison has directed that all personnel involved in activities associated with the safety of the nuclear power plants participate in the quality assurance program.

Lines of authority, responsibility, and communication among the organizations participating in this program are shown in Charts A mid B. Chmt A depicts the corporate organization and Chart B the on-site organization. These relationships, departmental responsibilities and key personnel job cescriptions are documented and updated as appropriate.

The major organizations or groups participating in this program are Nuclear Power (including Nuclear Quality Assurance), Nuclear Power Engineering, Maintenance and Construction (Nuclear Projects), Purchasing, Central Stores and the Nuclear Facilities Safety Committee. Changes to the quality assurance program, which is described herein, may be initiated by any of these organizations. Nuclear Quality Assurance coordinates overall development of this Quality Assurance Program Description and obtains concurrences of the organization (s) affected by the changes. The approval of at least the Vice President Nuclear Power is required for changes to this Quality Assurance Program Description for submittal to the Nuclear Regulatorf Commission.

Procedural controls provide for ' waiving' of tests, inspections and operations previously specified by Nuclear Power Engineering, Nuclear Quality Assurance or Nuclear Power.

These procedural controls provide authority to personnel or organizations that originally E specified the test, inspection or operation to reevaluate their necessity and, where appropriate, to authorize a waiver.

In case of an emergency or a similar situation, procedural controls provide for possible waivers to inspections, tests or operational requirements. These conditions and controls, discussed further in item 3 of Table A, require documented authorization by the Vice President, Nuclear Power or his designated alternate.

Provisions in the quality assurance program also provide for development of procedures for unique situations which differ from specified programmatic controls with the approval of the Senior Vice President, Central Operations. l 5

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Disputes involving quality arising from a difference of opinion between Nuclear Quality  ;

Assurance personnel and other departments' personnel are resolved by the direct  :

management of the personnel involved or, where necessary, by a higher level of  !

management. Nuclear Quality Assurance, by virtue of its independence within the corporate structure, can assure that significant quality disputes receive appropriate '

resolution satisfactory to Nuclear Quality Assurance. l l

The duties and responsibilities of the participants are described in Position Guides, procedures or manuals. These duties and responsibilities are designed to assure that the attainment of program objectives is verified by qualified personnel who do not perform or directly supervise the work.

The Vice President, Nuclear Power and, reporting to him, the Plant Manager Nuclear Power Generation and the Department Manager Site Services are responsible for the i day-to-day operation, safety, security and maintenance at the plant. 6 7

1 The Department Manager, Nuclear Quality Assurance oversees the quality assurance l )

activities at Indian Point and Nuclear Quality Assurance procurement and audit 8 ,

activities. He has three managers reporting to him: Manager, Quality Audits and l Surveillances; Manager, Procurement QA and Quality Control; and Manager, QA 9 Programs. The Department Manager, Nuclear Quality Assurance reports directly to the l Vice President, Nuclear Power. The Department Manager, Nuclear Quality Assurance 8 l

is responsible for the indoctrination and training of personnel reporting to him.  !

l The Nuclear Facilities Safety Committee (NFSC) is composed of Company employees the majority of which are independent of the Nuclear Power organization. The NFSC is responsible for advising the Senior Vice President, Central Operations regarding plant l safety. The organization and duties of this Committee are described in a charter and in 5 the Plant Technical Specifications and approved by the Executive Vice President, Central Operations. ,

l The NFSC is kept fully informed by Nuclear Power management personnel of matters  !

related to nuclear safety. This information is documented and reviewed by the NFSC. I The NFSC meets at least quarterly to review items related to safety and semiannually to I review and evaluate the results of periodic audits performed by Nuclear Quality Assurance to further assure safe operation and the adequacy of the audit program. l An on-site group known as the Station Nuclear Safety Committee (SNSC) functions within the on-site organization and advises the Vice President, Nuclear Power on all matters related to nuclear safety. The organization and duties of the SNSC are described in a charter forming part of plant Technical Specifications. This committee meets at least once per calendar month and is comprised of key station personnel.

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Nuclear Power Engineering is primarily responsible for the design activities included in system and component modification. To exercise this responsibility, Nuclear Power Engineering prepares, issues, revises, and controls design documents including 2 specifications, drawings, and modification procedures.

Held Engineering provides direct engineering support to the plant. 'lhis group is located at the plant site and reports to Nuclear Power Engineering. l 2

System Engineering and Analysis provides day to day technical advice to the plant. This group is also located at the plant site but reports to Nuclear Power. System Engineering and Analysis also prepares and issues documents associated with minor modifications. 1 Nuclear Power Material Procurement is responsible for preparing, issuing and ,

controlling purchase orders which are initiated by the plant, for reviewing purchase J orders issued by Nuclear Projects via Purchasing, for receipt inspection of incoming Class "A" Items purchased by Nuclear Power and for the inventory control of Class "A" i stock items. l Maintenance and Construction via its on site organization, Nuclear Projects, is l responsible for plant modifications, utilizing either company forces or outside contractor 3 labor, and may also be given responsibility for selected repairs. Work is accomplished j under the direction of designated Nuclear Projects, Project Superintendents in '

accordance with Nuclear Projects administrative directives. Nuclear Projects is i responsible for initiating, reviewing and preparing purchase documents for material for l plant modifications. Nuclear Projects may issue purchase documentation via l Purchasing, Nuclear Power Material Procurement or directly to vendors. Nuclear Projects is also responsible for receiving, inspection and storage of Class "A" items procured by Nuclear Projects. Alternatively, Nuclear Projects may utilize the receiving inspection and storage services of Nuclear Power Material Procurement and the Central Stores Cortlandt Warehouse.

I Purchasing is responsible for issuing and controlling purchase orders which are initiated by Nuclear Power Engineering and those initiated by Nuclear Projects which are l 4 processed via Purchasing. Purchasing also maintains an approved vendors list. 2 Central Stores (Cortlandt Warehouse) provides storage facility for materials and supplies for Indian Point Station and fills orders for supplies from users and other storerooms.

Nuclear Power is responsible for procurement and timely delivery of nuclear fuel to Indian Point 2 consistent with assuring reliable supply. Nuclear Power responsibilities include planning and providing for all nuclear fuel requirements, determining the required quantities of uranium, UF6 conversion senrices, enrichment, fabrication,

4 l shipping, storage and other nuclear fuel services, preparation of uranium specifications, arranging and controlling all traffic of nuclear fuel and by-products prior to fabrication and in transfer to and from the nuclear plant.

Nuclear Quality Assurance is responsible for assuring that quality assurance programs are established consistent with this program and company policy and, assures that these programs are properly implemented. Nuclear Quality Assurance carries out these responsibilities primarily through program development, site swveillance and first-line inspection and by auditing those activities which affect plant safety. Nuclear Quality Assurance develops audit plans and schedules, and administers other activities associated with auditing. The Department Manager, Nuclear Quality Assurance reports to the Vice President, Nuclear Power, who reports directly to the Senior Vice President, Central Operations. This provides Nuclear Quality Assurance with the authority and 8 5

organizational freedom to identify quality problems; to initiate, recommend or provide solutions through designated channels; and to verify implementation of solutions.

Nuclear Quality Assurance is responsible for indoctrination and training of Nuclear Quality Assurance personnel and for reviewing proposed changes to this program.

Nuclear Quality Assurance reviews documents which implement this program to assure that each includes adequate quality assurance principles.

Each organization participating in this program is responsible for providing indoctrination and training of its personnel performing activities affecting quality and safety to ensure that suitable proficiency is achieved and maintained. Nuclear Quality Assurance or Nuclear Power Test and Performance, as applicable, certifies Con Edison non-destructive examination personnel. Nuclear Quality Assurance personnel are trained to have and maintain proficiency in skills related to their specific assignments and in their knowledge of this program. Nuclear Quality Assurance personnel are provided indoctrination and training in the areas of quality assurance management and quality assurance practices, procedures, and requirements, including applicable regulatory and code requirements. Nuclear Quality Assurance provides indoctrination and training concerning the requirements of this quality assurance program to Nuclear Quality Assurance personnel, and appropriate personnel in other organizations.

M Indoctrination and Trainina Indoctrination and training in the administrative controls and quality assurance program is conducted for Nuclear Power Engineering, Purchasing, Nuclear Projects, Operations, l Maintenance and Nuclear Quality Assurance personnel who perform activities which 2 affect quality. This training includes:

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.(1) company policies, procedures and instructions which establish the program, (2) procedures or instructions which implement the program.

Personnel participating in the quality assurance program are conversant with the requirements of Appendix B to 10 CFR 50 and the liegulatory Guides, as appropriate, listed in the Foreword. To further their understanding of this document, such personnel participate in industry-technical society discussion groups and maintain contact with

. latest industryliterature.

Training of Nuclear Quality Assurance personnel is based on the individual needs to improve or develop new skills in performing their jobs. Accordingly, selected courses are attended by Nuclear Quality Assurance Engineers, Nuclear Quality Assurance Examiners and Consultants. These courses are in the areas of quality assurance management, quality assurance requirements for the nuclear industry, engineering auditing, reliability, non-destructive examination techniques, and welding technology. When required by Code, detailed and specific training is given to examiners in non-destructive examination in accordance with SNT specifications.

A record of training sessions, including a list of those attending and a description of the material discussed, is maintained.

For operations training, station staff retraining and replacement training, a program is maintained under the direction of a Department Manager, Nuclear Training. l 12 14 On-site Ooeroting Organization The on-site operating organization includes one or more individuals knowledgeable in the following fields: nuclear power plant operation, nuclear power plant mechanical, electrical and electronic systems; nuclear engineering; chemistry and radiochemistry and radiation protection. Members of the facility staff have appropriate experience, training and retraining to assure that necessary competence is maintained in accordance with the provisions of the plant Technical Specifications. The training and retraining programs are documented and approved by the Departrnent Manager, Nuclear Training.

13 Qualification and training in welding is in accordance with the requirements of ASME Section IX or other applicable codes.

Positions requiring personnel to have a current NRC reactor operator license are delineated in the Plant Technical Specifications.

The bases for the qualification of personnel who perform quality assurance inspections, examinations and tests are the following:

a) Education: minimum required - high school graduate or, alternatively, suitable job experience in the particular area.

b) Training: minimum required - evidence of specialized training sufficient to perform a particular job, e.g., welding inspection or, alternatively, demonstrated capability via job experience.

c) Evaluation: personnel are evaluated annually to determine their capability to perform their job function. Each evaluation is documented and included in the individual's personnel folder.

d) Specific Capabilities:

1. Physical: minimum required - physically capable of performing the job function including adequate vision and other physical characteristics, if necessary for the job.

2. Technical: minimum required - familiarity with tools and equipment to be used on the job and proficiency in their use including, as necessary, measuring and test equipment calibration and control methods.

The above qualification bases apply to Nuclear Quality Assurance, Nuclear Projects and Material Procurement inspection personnel who perform site inspections of maintenance and modification activities and receiving inspections.

For particular projects Nuclear Quality Assurance, Nuclear Projects or Material Procurement personnel may be supplemented by other Company organizations or by outside forces. In these situations, Nuclear Quality Assurance, Nuclear Projects and Material Procurement retain the responsibility for using appropriately qualified personnel.

If the performance of an individual has not met the requirements specified for the particular job, supervision has recourse to provide additional training, additional supervi-sion or to remove the individual from the job assignment. Position Guides, procedures and manuals identify major responsibilities of particular positions. On-the-job supervi-sion and formal yearly reviews assure the necessary continued proficiency of any particular individual. Prior to the assignment of personnel to a job function, the qualifications of the personnel are evaluated by supervision. This evaluation considers previous education, training, results of past supervisory reviews and on-the-job experience and perfonnance to assure the initial proficiency of the individual. On-the-job performance after assignment to particular job functions is monitored by supervising personnel. The qualifications of Nuclear Quality Assurance, Material Procurement and Nuclear Projects inspection personnel, including their education, experience and training, are documented. Personnel involved in particular NDE activities, including the 1

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l performance evaluation and supervision in nondestructive examinations are appropriately qualified in accordance with the requirements specified in SNT-TC-1A. '

Personnel on-the-job performance is reviewed annually, and the results are documented and retained in personnel folders.

The facility management and technical support organizations are defined in the plant Technical Specifications. At least one licensed Operator is in the control room when fuel is in the reactor. At least two licensed Operators are present in the control room daring reactor start-up, scheduled reactor shutdown and during recovery from reactor trips. An individual qualified in radiation protection procedures is on site when fuel is in the reactor. Core alterations after initial fuelloading are directly supervised by a licensed Senior Reactor Operator.

The Plant Manager, Nuclear Power has overall responsibility for facility operation. l 6

The Department Manager, Nuclear Quality Assurance is responsible for overall Nuclear l Quality Assurance activities. Nuclear Quality Assurance reviews and audits the quality 14 assurance program. Additionally, audit activities are periodically reviewed by the Nuclear Facilities Safety Committee.

LQ Reviews and Audits Programs for reviews and for audits of activities affecting plant safety during the operational phase have been established. These programs assure that these activities are carried out in accordance with regulatory requirements, approved procedures and instructions, and license provisions. They provide for the following:  !

o review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety i I

o review of tests, procedures and experiments that affect nuclear safety o review of proposed changes to the plant Technical Specifications o investigation of all violations of the plant Technical Specifications o review of facility operations to detect potential nuclear safety hazards o review of the Plant Security Plan and implementing procedures o review of the Emergency Plan and implementing procedures o verification that reportable events which require reporting to the NRC within twenty-four hours, are promptly investigated and corrected o review of changes to the Process Control Program and the offsite Dose Calculation Manual These programs are carried out by the Station Nuclear Safety Committee (SNSC) and Nuclear Quality Assurance. The independent review program, administered by the

V Nuclear Facilities Safety Committee L 'SC), identifies those personnel performing reviews; standing committees functioning as independent review bodies; and the composition, meeting frequency, quorum definition of such committees; the kinds of records maintained by such committees and the documentation of reviews as provided for in the plant Technical Specifications. These programs are, thernselves, reviewed for effectiveness by management.

The NFSC charter identifies the areas to be audited by Nuclear Quality Assurance; the responsibilities and authorities of involved personnel; provisions for the use of specialists (consultants) or sub-groups; authorization to perform audits; distribution of reports; lines of reporting and authority; timeliness of information dissemination; requirements for follow-up and re-audit and other provisions required for effectiveness reviews and audits.

11 Audit Proaram The audit program conducted by Nuclear Quality Assurance provides for a i comprehensive system of planned and periodic audits to verify that operating nuclear facilities are operated, administered, and managed in accordance with applicable requirements and to assess quality program effectiveness.

Nuclear Quality Assurance documents audit plans and establishes a schedule of periodic audits. These audits are designed to verify compliance with all aspects of the quality assurance program and are conducted at least once every two years or more frequently commensurate with their safety significance. These audits include the following:

o The conformance of facility operation to all provisions contained within the plant Technical Specifications and applicable license conditions at least once per 12 months.

o The conformance of all provisions contained within the Environmental Technical Specifications (Appendix B) pertaining to radiological matters and applicable license conditions at least once per 12 months.

o The performance, training and qualifications of the entire station staff at least once per 12 months.

o. The results of all actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety at least once per 6 months.

o The Facility Fire Protection Program and its implementing procedures at least once per 24 months.

o The Facility Emergency Plan and implementing procedures at least once per 12 months.

o The Facility Security Plan and its implementing procedures at least once per 12 months.

l o A fire protection and loss prevention inspection and audit performed utilizing either qualified offsite licensee personnel or an outside fire protection firm at least  !

once per 12 months. I o The radiological environmental monitoring program and the results thereof at least once per 12 months.

o The Offsite Dose Calculations Manual and implementing procedures at least once per 24 months.

o- The Process Control Program and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.

o The performance of activities required by the quality assurance program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory  ;

Guide 4.1, Revision 1, April 1975 at least once per 12 months.

o The Fitness for Duty Program nominally every 12 months.

o The procedure review and revision program that evaluates the need for revising l procedures at least every 2 years. 1 o Any other area of facility operation considered appropriate by the NFSC, or the Senior Vice President of Central Operations. l l 5

The only exception to the two year (or more often) frequency is an inspection and audit of the fire protection and loss prevention program performed by an outside Qualified fire consultant which is conducted at least once per 36 months.

The audits are conducted by Nuclear Quality Assurance who may utilize other Consolidated Edison employees (except those having direct responsibility in the area being audited) and/or consultants or specialists from outside the Company. The results of each audit are reviewed by the auditors with the management of the activity audited at the conclusion of the audit. A written report containing the audit findings and

< recommendations is issued by Nuclear Quality Assurance within thirty days of the completion of the audit process. The audit report is issued to the management of the audited group (s) for reply to the audit results. It is distributed to the Secretary, Nuclear Facilities Safety Committee; the Senior Vice President, Central Operations; the Vice President, Nuclear Power; the General Auditor; the Senior. Officers of the activities audited; the Manager, Regulatory Affairs, the appropriate General Manager; the 5 Department Manager, Nuclear Quality Assurance and, when it involves ASME,Section III Code Requirements, to the Authorized Inspector. It is the responsibility of the activity 3 audited to review the report and reply, in writing, within thirty days to Nuclear Quality Assurance concerning the actions to be taken to resolve each finding. Nuclear Quality Assurance is responsible for verifying the effectiveness of these actions, including reaudit when necessary. The Nuclear Facilities Safety Committee reviews the adequacy of the audit program at least semiannually.

LQ Proaram, Policies and Procedures El Procram Description Administrative controls and quality assurance requirements are described in documents such as corporate instructions, station administrative orders and station procedures. A summary document which identifies these administrative and quality assurance procedures has been compiled and is maintained current. This document is suitably indexed to identify relationships of the contents to the pertinent criteria of 10 CFR 50, Appendix B and applicable Regulatory Guides.

Nuclear power plant structures, systems, components and consum ebles covered by this program are identified as " Class A' Items and are thou that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. A list of " Class A" structures, systems, components and consumables appears in Appendix A. Identification of Class A components within systems are made and documented on a case-by-case basis, as required, via established procedures. This may include declassification. In addition, the Vice President Nuclear Power has an option to utilize the above program for specific non-safety related modifications. The major organizations and their responsibilities are identified and delineated in paragraph 3.2 of 'his document.

This program provides control of activities affecting the quality of Class A items to an extent consistent with their importance to safety. In the case of consumables, adequate quality is assured by activities such as testing on arrival, review of manufacturer's certification, or vendor evaluation. Additional controls such as vendor surveillance and receipt inspection are not necessarily performed. These controls are described in the various documents identified in the summary document.

This program takes into account the need for special controls, processes, tests, equipment, tools and skills to attain the required quality and the need for verification of quality by inspection, evaluation or test. These needs are accommodated through the issuance of and compliance with procedures, such as:

a. Non-Destructive Examination Procedures

b. Welding Procedures

c. Operating Procedures

d. Start-up Testing Procedures

e. Calibration of Measuring and Test Equipment

f. Receiving Inspection Procedures

g. Vendor Evaluation Procedures

h. Maintenance and Modification Procedures

12 Rules of Practice Rules and instructions pertaining to personnel conduct and control are contained in various procedures and operating orders issued by the on-site organization. These ,

include special instructions and authority for normal procedural actions, emergency actions, responsibilities of key personnel, watch schedules, availability and duties of key personnel at all times, preparation of procedures and documenting and retention i requirements.

Ell Besconsibilities and Aufhorities of Ooeroting Personn_e_1 Responsibilities and authorities of the plant operating personnel are delineated in i operating and administrative procedures prepared and approved by appropriate on-site '

management as required by the sections of the plant Technical Specifications entitled l

' Administrative Controls'. These include.  ;

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a. The reactor operator's authority and responsibility for reactor shutdown under l various conditions. I

b. The responsibility to determine safe operating procedures for reactor return to power after a trip or an unscheduled or unexplained power reduction.

c. The responsibility for a Senior Reactor Operator to be present at the plant and the authority to provide direction for returning the reactor to power following a trip or unexplained power reduction.

d. The responsibility to believe and respond conservatively to instrument indications unless they are proved to be incorrect.

e. The responsibility to adhere to the plant Technical Specifications.

f. The responsibility to review routine operating data to assure safe operation.

5.2.2 Procedure Adherence l

The requirement that procedures be adhered to is both a plant administrative requirement and a plant Technical Specification requirement. Safety-related i procedures and procedure changes are reviewed by the Station Nuclear Safety Committee. In the event of an emergency not covered by an approved procedure, operations personnel take appropriate action to protect the health and safety of the public and to minimize personnelinjury and damage to the facility. Written directives identify the manner in which procedures are to be implemented.

Procedural actions which must be committed to memory are those defined as 'Immediate Operator Actions" in the Emergency Operating Procedures.

.- l Documentation of procedure use is required when specifically called for by the procedure in question. For example, a startup " Procedure Check-Off" is completed during plant warm-ups and power ascensions from shutdown conditions; a shutdown

' Procedure Check-Off"is completed during planned plant shutdowns and cooldowns. j Following a unit trip or shutdown, a precriticality " Procedure Check-Off" is completed prior to initiating control rod withdrawal for the purpose of achieving criticality if more  !

than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have elapsed since completing the %st precritical check-off procedure.

After comple' tion, all check-off procedures are s,gned by the Operations Watch l Supervisor. Copies of all procedures are available to appropriate members of the plant  !

staff. I I

5.2.3 Operating Orders i Dissemination to the plant staff of instructions of general and continuing applicability to l the conduct of business is provided through the issuance of appropriate administrative i directives and operating procedures to the affected personnel. Station administrative orders identify responsibilities and are binding upon all members of the Nuclear Power and Maintenance and Construction Departments as appropriate to the subject matter l contained therein. Procedures for activities at the nuclear facility by groups other than 3 Nuclear Power and Maintenance and Construction are to be consistent with the l 1

requirements of Station Administrative Orders. Additional guidance, if necessary, is 3 j issued within individual subsections or staff groups to provide for delineation of detail not covered in Station Administrative Orders. Such additional guidance is in the form of administrative directives and/or procedures and may deal with shift changes, control room restrictions, operator duties and requirements, maintenance instructions, I document control and other such matters applicable to the needs for operating a safe l nuclear plant. l Routine plant procedures used more than every two years are reviewed and updated via various self-assessment processes which include consideration of the need for follow-up action (example: proceduralrevisions).

The self-assessment processes include:

o plant modifications.

o nonconformance resolutions.

o plant event and significant occurrence analyses.

o operator feedback, including operator training.

o maintenance work package reviews.

o temporary procedure changes.

- 14 -

o surveillance tests.

o operating experience reviews.

o mtdits and surveillances.

o responses to NRC correspondence.

Routine plant procedures that have not been used for two years shall be reviewed before use to determine if changes are necessary or desirable.

Non-routine procedures (e.g., emergency operating, off normal, emergency plan implementation and other procedures which are event-initiated) shall be reviewed every two years.

Provisions are made for periodic review and updating of the above instructions. Station 2.3 Administrative Orders are reviewed biennially. The Department Managers in Nuclear Power ensure that these reviews are accomplished. Section Managers assure that administrative directives of their respective sections are reviewed biennually.

15 5.2.4 Special Orders 16 24 25 A mechanism exists for the issuance of management instructions which have short-term applicability and which require dissemination. The plant Technical Specifications direct that these orders, among others, be established, reviewed, implemented and maintained. These instructions are written to provide direction for non-recurring events, special situations or other categories of a similar nature.

These are prepared at the appropriate management level and distributed to the affected organizations and personnel. Because of the unique nature of the contents of these instructions, they are automatically canceled, once implemented.

5.2.5 Temocrary Procedures Temporary Operating Instructions are issued, when required, as temporary procedures and are related to the performance of special tests or operations that are applicable for a short period of time. Procedures are issued for guidance during off-normal conditions and during special circumstances, as required.

The review and approval mechanisms for these temporary procedures or changes thereto are the same as those for normal operating procedures as described in paragraphs 5.2.2 and 5.2.15 which include the assignment of approval authority to management.

5.2.6 Eauloment Control Prior approval by Operations personnelis required for the release of equipment or systems for maintenance or repair. Normally, for interfacing station activities, Maintenance Supervisors, Instrument and Control Supervision, and Operations Watch Supervisors meet beforehand to plan the work. They verify that equipment or systems can be released and determine the time required to do the job, and safety considerations to personnel and the public. Essential elements of these details are documented in work permits.

When permission is granted to remove equipment from service, the equipment is rendered inoperative and protected for work. Operations Watch Supervisors verify that the work is completed prior to readying the equipment or system for return to service.

Shutdown and subsequent start-up procedures guide the preparation of equipment or systems for maintenance. They include cognizance of such parameters as monitoring and control of reactivity, load reduction and cooldown rates, sequencing in activating or deactivating, provisions for decay heat removal and emergency operating situations.

Specific check-lists provide the assurance that pertinent factors are considered. Entries

into closed systems or vessels are controlled. This extends to accountability for items taken in and out by maintenance personnel.

Temporary alterations which include such items as bypass devices, lifted electrical contacts, vmying of setpoint limits, jumping, and opening of trip links require prior approval frem, and are controlled by, Operations Watch Supervisors acting in accordance with approved directions. Entries are documented in log books.

Status of inspections in association with work on equipment or systems is controlled through utilization of procedures, travelers, work step lists, check lists, tags and labeling.

Nonconformances associated with maintenance are documented on inspection reports.

Acceptance of a disposition of nonconformances by Nuclear Quality Assurance is required prior to release of an item for service. Usually, tests are conducted upon completion of work as a preoperational activity. Test requirements are determined by Test and Performance. Completion of tests are certified by Operations Watch Supervisors.

Upon completion of servicing work, operations personnel are responsible for verifying that the work is complete and that operating items are restored to prerequisite positions in accordance with applicable procedures.

i, 5.2,7 Maintenance and Modification Maintenance / modification of safety-related structures, systems, and components including the installation, inspection and testing of instrumentotion, electrical equipment and structural concrete, structural steel, mechanical equipment and piping and the application of protective coatings, are controlled by Nuclear Power or Nuclear Projects procedures, as applicable, and are performed in a manner that assures a level of quality consistent with precedents set by the Architect Engineer and NSSS Supplier or appropriately reviewed alternates to those precedents.

Pre-operational performance testing provides an added measure of confidence that systems and components will continue to perform their intended functions after maintenance or modification.

These activities are performed in accordance with applicable procedures, manuals, instructions, drawings, specifications and other documents that take into account, as appropriate, planning requirements, codes and standards, the levels of skills required to do the work, and the assurance that properly identified acceptable material is used.

Preparation involves consideration of such factors as assigning responsibilities, identification of written instructions and scheduling and interfacing with other applicable operations activities. Included in the instructions are precautions to be observed, installation instructions, identification of equipment, procedures, travelers, step lists, check lists, inspection points, and cleaning, handling and housekeeping requirements, as applicable. Particular attention is paid to prerequisites such as assignment of personnel, assurance that proper documentation and materials are available, need for i, manufacturer's manuals and preparation for documenting results. Pre-installation activities extend to assuring that only properly accepted material is used, written instructions are available and work permissions have been granted.

5.2.7.1 Maintenance A maintenance program to maintain structures, systems, and components at a quality level necessary for them to perform their intended function is in effect. Maintenance activities are planned, scheduled and accomplished in a manner consistent with safety considerations mid plant Technical Specification requirements. In preparation for maintenance activities, such details as the use of approved material, need 'for special tools or equipment, safety precautions and detailed work instructions are considered.

. Procedures involving maintenance of a recurring nature are contained in a maintenance procedure manual. These procedures may be revised as experience is gained.

. i

' j i

l Preventive maintenance procedures contain maintenance frequency requirements for  ;

safety-related systems components.

Inspections and smveillances during maintenance, and repair work verify continued functional capability of equipment on the EQ data base. When these inspections and surveillances show that the equipment does not meet established acceptance criteria the inspection results are reviewed by Nuclear Power Engineering and quantitatively l evaluated to determine that age-related degradation has not compromised the ability of 2 the equipment or system to perform its specified functions. Results of inspections and surveillances are also factored into future inspection intervals in order to change the frequency at which these inspections are conducted, thereby aiding in determining the  ;

qualified life of the equipment and its maintenance interval.

Plant maintenance activities are carried out in the following manner: )

1 The work order is the mechanism by which station personnel can identify and document l conditions in the field which require corrective work. The initiator of the work order is responsible for the correctness of the information which he identifies, e.g., the nature of 4 the condition which requires corrective work. Operations reviews all work orders to determine their validity and to approve their implementation. '

Any employee of Con Edison discovering a deficiency on plant components initiates a work order to correct the deficiency or reports it to his supervisor. When an employee reports a deficiency to his supervisor, the responsibilities of the supervisor include j facilitating processing of the deficiency via the plant computerized work order l management system.  !

The following may authorize work orders:

i o Vice President, Nuclear Power o Plant Manager o Department Manager Operations o Department Manager Maintenance o Section Manager Instrumentation and Control o Senior Watch Supervisor (in an emergency may authorize for operations 6 manager).

]

Test and Performance reviews all work orders to determine testing requirements, including acceptance criteria, ensures that the test criteria address the actual work that was accomplished and assures that the component will be tested under conditions that simulate or actually meet normal operating conditions for that component.

Test and Performance is a group consisting of a manager, test engineers and a test supervisor (s) who define post-maintenance test requirements and supervise equipment testing. The review of work orders by Test and Performance constitutes an independent review in that Test and Performance reports to the Department Manager, System Engineering and Analysis who is independent of the Plant Manager who is responsible for plant operation. 6 17 The review of work orders by Test and Performance normally occurs prior to the start of work, however, if after the swt of work, the work scope changes (e.g., to suit field conditions), Test and Performtry e reviews the revised scope to determine any revised testing requirements.

Test and Performance identifies Post-Maintenance Testing (PMT) requirements on the work order. T::is is accomplished by entering them in the computerized work order management system. The manager of Test and Performance is responsible for supervising Test and Performance personnel to assum that the PMT requirements are accurately and completely entered in the system. Test and Performance also prepares and issues PMT procedures. Additionally, PMTs are reviewed by Operations Watch Engineers to assure that they are appropriate.  ;

The Operations Department Manager, or his designee, specifies on each work order whether Maintenance or Instrumentation and Control is responsible for the work.

Questions involving the assignment of these tcsponsibilities are resolved by managers 26 of the respective groups, or their designees. 18 For work managed by Nuclear Power, Maintenance or Instrumentation and Control, as l applicable, is responsible for the correctness of the work order and implementing 18 documents and o designates the work group, o updates work orders with any changes or additional information as required, o prepares schedules in conjunction with operations and applicable work groups, o prepares implementing documents for the work order as required, and enters this information on the work order. The work implementing documents consist of the work order and one or more of the following depending on job complexity: check lists, step lists, procedures, sketches, drawings, etc.

The work implementing documents, developed by Maintenance or Instrumentation and l Control are reviewed for adequacy and correctness by a qualified person other than the 18 preparer. This latter review constitutes an independent review.

. 1 l

l l

l 1

In the case of other projects (ex. major capital projects) managed by Nuclear Projects, )

work verification packages are assembled by Nuclear Projects QC Coordinators / I Planners. The work verification packages are also reviewed for adequacy and correctness by a qualified person other than the preparer.

Test and Performance reviews the results of Post Maintenance Testing to verify that acceptance criteria has been satisfied and indicates this on the work order. l 5.2.7.2 Modifications When the work constitutes a modification to the plant, modification documentation is prepared by either Nuclear Power Engineering or System Engineering and Analysis as ,

determined by the Department Manager, System Engineering and Analysis in l consultation with Nuclear Power Engineering, as necessay. This determination is based  ;

primarily on job complexity (e.g., scope and design impact) with the more complex jobs i generally assigned to Nuclear Power Engineering.

11 Procedures are in effect for the control and implementation of these design activities.

Examples of the subjects covered in the procedures are:

1. Responsibilities within the engineering organizational unit and its various disciplines,

2. Managing the flow of technicalinformation among internal supporting disciplines such as Civil, Electrical and Mechanical Engineering and Design Engineering (externally supported design activities are controlled through procurement of ,

subcontracted services as the need arises), 1

3. Rules for developing and reviewing concept and scope documents and preliminary design documents with appropriate Station and installer organiza-tions,

4. Control of the preparation, review, approval, release, and distribution of documents and their changes,  ;

5. Rules concerning retention of design documents, l

6. Design verification, l

7. Rules for development of design criteria, design concepts, detailed designs, integration of Field Engineering forces, and review by affected Nuclear Power Engineering disciplines as applicable to the scope of the particular modification.

A Discipline Engineer within the designcrted organization is assigned responsibility to prepare the modification documentation. The Discipline Engineer determines how the modification documentation should be developed and processed as one of the following:

o Modification (major) - a plant change that modifies plant design.

t o Minor modification - a plant change where the replacement component results in limited installation impact (e.g., no adverse seismic affect) and does not alter the system process or function.

o Determination Of Equivalency (DOE)- an evaluation to determine that a replacement component is an equivalent replacement and is suitable for instal-lation.

Documentation developed for major modification includes, as applicable, the following:

o Design criteria.

o Concept and scope.

o Supporting calculations, o Specifications, drawings.

o Prerequisites and corequisites.

o Special test requirements, acceptance criteria.

o Flushing / cleaning requirements.

o Welding requirements.

o Special precautions.

Minor modification documentation includes the above, as applicable, except that new design criteria are not established.

DOE documentation provides justification for a determination of equivalency.

Dements of the design process including design verification are identified in procedures.

Some of the matters considered are:

1. Suitability of parts, equipment or processes for the application.

2. Compatibility of materials with each other and with the design environment.

3. Radiological controls.

4. Provisions for handling, storage, cleaning and shipping, as applicable.

5. Computations and calculations:

a) Numerical accuracy, b) Consistency of results between altemate and original methods, c) Identification of design assumptions.

6. Analytic methods.

7. Fire protection.

8. Determining the reasonableness of results in comparison to design bases. '

9. Permissibility of qualification testing alternatives as a verification technique.

10. Reasonableness of outputs when compared to inputs.

I1. Approval of vendor submittals.

12. Prerequisites.

13. Requirements for welding.

14. Evaluating safety significance to assure compliance with regulatory requirements.

15. Verification that pertinent quality provisions have been incorporated.

16. Rules for utilizing original Architect-Engineer and NSSS design details in plant replacement items, additions or modifications.

17. Rules for distribution of design details to other affected interfacing organizational units, which include Nuclear Power for comment or information.

18. Inservice Inspection and Testing requirements.

19. Environmental Qualification of electrical equipment important to safety in accordance with the requirements of 10 CFR 50.49.

Inherent in these procedures are provisions for the control of documents and their changes. The modification documents carry revision level designations to assure that correct revision levels will be used in the work. For addition of new, complex systems, specification and drawing lists are prepared, issued and used. Procedures provide details for the maintenance, retention and storage of these design documents.

Some representative considerations accounted for in the formulation of modification procedures are:

1. Requirements of codes, standards, and regulatory documents.

2. Conditions affecting design such as pressure temperature, voltage, stress and seismic loads. '

3. Functional and physical interfaces between systems.

4. Operating, maintenance, testing and inspection requirements, as applicable.

5. Process flow, equipment descriptions, material requirements and their compatibility. l

6. Safety requirements.

7. Environmental, cleanliness and quality assurance requirements.

8. Performance characteristics.

9. Electricallayouts, cable and conduit schedules.

10. Specialinstallation requirements for environmentally qualified equipment. These may be contained on the Design Modification Drawings, Vendors' drawings, or in specialinstructions.

The modification documentation is prepared and signed by the Discipline Engineer.

Additionally, the modification documentation is reviewed and approved by a qualified Engineer other than the preparer. This additional review is to assure that the modification documentation is technically correct and that appropriate quality provisions '

(e.g., non-destructive examinations) are specified.

s Affected plant functions perform critical reviews of the modification documentation.

These include System Engineering and Analysis, Operations, Training, Test and l Performance, Computer Applications, and Environmental Qualification. Generally, these 11 reviews verify that modification documentation includes adequate technical guidance and criteria, evaluate the impact of the modification in their respective areas of responsibility, support determination of post-modification testing requirements, assure consistency with the Plant Technical Specifications, assure that applicable safety '

evaluation requirements have been satisfied and provide for radiological control requirements.

After the modification documentation is issued for implementation, supplemental work verification packages (WVPs) are assembled by Nuclear Projects QC Coordina-tors / Planners. These WVPs consist of forms, checklists, etc. and information which, when compiled and completed will provide objective evidence of the proper completion of the work. The WVPs contain, as applicable, the following types of records and information:

1. Summary of scope of work as identified in the Engineering modification package.

2. An index of records included in the WVP.

3. Weld information forms.

4. Dectrical disconnect and reconnect forms.

5. Cable pull slips.

6. Cable tray inspection checklists.

7. Conduit installation records.

8. Test data records.

9. Torquing records.

10. Grouting checklists.

I 1. Material used forms.

12. Cleanliness records. l

13. Work completion walkdown records.  ;

14. WVP content checklist. '

The QC Coordinators / Planners specify those work steps to be verified and signed off by Field Supervisors and those independent hold points or inspection points that will be performed by QC Coordinators / Planners. The WVPs are reviewed and approved by the i responsible Project Superintendent to assure the WVP is consistent with the scope of the modification. Nuclear Projects QC Coordinators / Planners report to Nuclear Projects Project Superintendents. The QC Coordinators / Planners are independent of the Field Supervisors who are directly responsible for the work.

In addition to the QC functions performed by the Nuclear Projects OC Coordinators / Planners, Nuclear Quality Assurance (an organization independent of Nuclear Projects), will conduct overview inspections, surveillances and/or audits of

\

selected activities of Nuclear Projects. The overview inspections, surveillances or audits will be conducted when plant modifications are being implemented on a nominal quarterly basis or more frequently. Additionally, where special qualifications are required to perform examinations (e.g., non-destructive examinations) Nuclear Quality Assurance inspection personnel may supplement the activities of Nuclear Projects QC Coordinators / Planners.

Nuclear Power Instrumentation and Controls prepares work procedures, as necessary, to implement modifications to installed instrumentation.

The work documentation is reviewed by personnel other than the documentation preparer to assure that it is complete and correct.

Verification of work during and after installation includes performance of inspections, tests, when applicable, non-destructive examination, recording as-constructed information, status indication, pressure testing, when applicable, and by other appropriate means.

Test and Performance is responsible for preparing post-modification test procedures, .

evaluating test results, and informing Operations personnel of acceptability of the test I results.

Records of the completed work package are filed. Examples of the types of records are the job folder, results of inspections or tests, modification documents, maintenance work  ;

order, reference to other documents and close-out documentation. Similar controls '

apply to preventive, routine and corrective maintenance, as appropriate.

5.2.8 Surveillance Testing and Inspection Schedules Surveillance testing and inspections, including in-service testing of pumps and valves, are the responsibility of Nuclear Power and are accomplished in accordance with the surveillance requirements in the plant Technical Specifications and Inservice Inspection  ;

and Testing Program. Included in these activities are: reactor coolant system surveillance, reactor coolant system integrity testing, containment tests, engineered safety features, emergency power system periodic tests, main steam stop valves, auxiliary feedwater system, reactivity anomalies, environmental monitoring surveys, and radioactive materials. Upon completion of testing, surveillance test results and inservice test sesults are reviewed by Test and Performance. This review consists of:

1. Verifying that the operability and overall acceptance criteria were satisfied.

2. Ascertaining that data were entered as required.

3. Verifying the test was done on schedule.

e

4. Trend analysis, as appropriate.

5. Evaluating condition (s) adverse to quality.

6. Evaluating data for compliance with Plant Technical Specification requirements.

The NDE portion of the Inservice Inspection program is the responsibility of Nuclear Quality Assurance and is based on ASME Code Section XI. NDE personnel will be q=lifiM to SNT 'IC-1A 1975 as per our commitment to RG 1.58, Rev.1, September 1980. 19 However, NDE poisonnel who specifically perform ASME XI inservice examinations shall be qualif n in accordance with the applicable edition of ASME XI as determined by Code of Federal Regulations 10CFR50.55a(g). As required, baseline data are gathered to permit a comparison of any changes occurring as a result of plant operations. The areas requiring inspections and the overall schedule are consistent with the requirements of the plant Technical Specifications. Test and Performance maintains inservice testing records and Nuclear Quality Assurance maintains NDE inservice l inspection records. 19 519 Plant Security and Visitor Control A comprehensive security and visitor control program has been established, including measures to thwart attempted sabotage. Procedures have been developed by Nuclear Power which supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.

Measures have been established by the Departmant Manager Site Protection, to deter l or discourage penetration by unauthorized persons, to detect such penetrations should 26 they occur, to apprehend in a timely manner either unauthorized persons or authorized persons acting in a manner constituting a threat of sabotage, and to provide for oppupiate authorities to take custody of violators. The means by which plant security and visitor control are enforced by both security and operating personnel include measures for physical and administrative control of access to the plant site or portions thereof, selecting and retaining reliable personnel and detecting aberrant behavior, monitoring the status of vital equipment and facilities, augmenting security in the event of actual or potential threats to plant security and designing features of the plant specifically for security purposes or features which, by their nature, reduce the vulnera-bility of the plant to sabotage attacks.

The security program provides for the identification of the following three security areas:

1. Con Edison-owned property under the administrative and procedural control of the Department Manager Site Protection and suitably marked by signs and other l 26

I means which provide reasonable assurance that persons entering the area are aware they are on Con Edison property

2. A crotected area administratively and procedurally under the control of the Department Manager Site Protection affording clear fields of view on its perimeter l and: 26

3. Vital areas isolated from non-vital equipment and facilities to the maximum extent practicable to limit access to a minimum number of authorized persons. As part of the security program, a list of these vital areas is maintained. Vital areas are protected against intrusion by unauthorized personnel. These areas are adm!nistratively and procedurally under control of the Department Manager Site Protection, in conjunction with the Plant Manager, and the Department Manager Operations.

The Department Manager Site Protection has developed a Security Force Manual, approved by the Station Nuclear Safety Committee and is responsible for its 6 26 maintenance, up dating, and distribution to authorized individuals and organizations.

Operations personnel form a part of the security force. Accordingly, the Operations Watch Supervisor, the Support Facilities Supervisor, Reactor Operators, Nuclear Plant Operators and other operating personnel are assigned various authorities and responsibilities forming a part of the security program.

The Department Manager, Site Protection is responsible for developing and properly l locating signs and notices relating to security for training and drills and for submitting 26 reports relating to security to the Department Manager, Site Services. l 7

The Vice President, Nuclear Power has overall responsibility for the security program and its state of readiness.

5.210 liousekeeping and Cleanliness Control Control procedures for housekeeping are prepared by Nuclear Power. These )

procedures encompass activities related to the control of cleanliness of facilities, i materials and equipment; fire prevention and protection, including disposal of I combustible material, radioactive contamination control; storage of solid radioactive l waste, etc.

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Procedures are prepared for and particular attention is given to work and storage areas where important items are handled and stored to preclude damage or contamination.

. The Plant Manager provides for separate controlled storage areas, and issue, use and l retum of excess Class A materials. Procedures prepared by Nuclear Quality Assurance 6 are used to verify control of the cleanliness of open primary systems. The Vice President,

Nuclear Power establishes policy regarding work permits and provisions for the radiological as well as conventional health and safety of all employees. The Plant l Manager establishes policy for removal of equipment and material from the controlled 6 area and its shipment, and the method of handling solid radioactive waste material for its removal from the controlled area at Indian Point Station.

Fire protection and prevention procedures are prepared and implemented by responsible Nuclear Power Personnel. These procedures include provisions for fire fighting and fire watches dunng and immediately following welding, enforcement of good housekeeping practices, building and maintenance care and outdoor housekeeping.

Periodic inspections and surveillances are performed by Nuclear Quality Assurance personnel. Reports of results are issued to higher management.

5.211 Corrective Actions Measures have been established which ensure that conditions adverse to quality which may occur during work, e.g., maintenance, are promptly identified in nonconformance reports or significant nonconformance reports and corrected. In the case of significant conditions adverse to quality, the cause of the condition is determined and corrective action taken and appropriately documented and reported.

The action addressee on nonconformance reports is responsible for either correcting the nonconformance or designating the organization responsible for completing the necessary corrective actions. The managements of these designated organizations are responsible for taking the necessa17 corrective actions.

Nuclear Quality Assurance, is responsible, via audits, for verifying that corrective actions resulting from non-conformance reports are implemented at the site.

When significant nonconformance reports are issued, Nuclear Quality Assurance prepares and distributes a quarterly report indicating the status of all unresolved significant nonconformance reports. This report is routed to appropriate management concerned with correcting the deficiency. The distribution of the quarterly status report of unresolved non conformance reports assures that the identification of significant conditions adverse to quality and corrective actions initiated are documented and reported to appropriate levels of management.

The action addressee on significant nonconformance reports is responsible for either correcting the deficiencies or designating the organization responsible for completing the necessary corrective actions. The managements of these designated organizations are responsible for taking the appropriate corrective actions. When corrective action has been completed, this will be identified on the report and forwarded to Nuclear

Quality Assurance, by the action addressee. Corrective action shall include determination of the cause of the nonconformance and the measures necessary to preclude repetition.

Nuclear Quality Assurance reviews the action taken and takes the initiative to resolve disputes and disagreements, if any. After cgreement has been achieved, Nuclear Quality Assurance completes the report by noting concurrence. Copies of completed reports are then routed to the action addressee and other appropriate Con Edison organizations.

Conditions adverse to safety found during operations are reported as required by the l plant Technical Specification. This report includes a description of the condition, its cause and corrective action taken or recommended. The distribution of this report includes the Nuclear Facilities Safety Committee.

5.2,12 Plant Records Manacement Con Edison's policy is to maintain documentary evidence of the quality of items and activities affecting plant safety. Consequently, a system for records preparation and ,

retention, as necessary, has been established.

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Quality assurance records located in the Nuclear Records Management Center, together with other files of other Con Edison organizations and at contracted storage facilities are retained for periods specified in the Indian Point Records Type List.

Nuclear Quality Assurance maintains records which include certain personnel qualification records, and nonconformance reports. Operating logs are maintained by Operations. Test procedures and results are maintained by Test and Performance.

Material Procurement maintains records of receipt inspections results and backup data.

Inspection reports include the signature of the inspector, the type of observation, the results, the acceptability, and the actiott taken in connection with any deficiencies noted. ;

Documented procedures establish the requirements and responsibilities for record maintenance and retention subsequent to completion of work. The records are filed and maintained to minimize deterioration, damage and to prevent loss.

5.2.13 Procurement and Materials Control Measures have been established for procurement documentation and control of matedals and components which affect plant safety, including spare and replacement parts. Procedures and appropriate instructions assure that purchased materials and components associated with safety-related structures or systems are purchased to

appropriate specifications and codes; produced or fabricated to proper requirements; packaged and transported in a manner that will maintain their quality; properly documented, completed, identified and stored; and correctly controlled to assure the identification, segregation, and disposition of nonconforming material. These procedures, as appropriate, provide for procurement document preparation, review and change control; selection of procurement sources; bid evaluation and award; control of suppliefs performance, verification of material quality, control of nonconforming items, acceptance of items and services, maintenance of quality assurance records; evaluation of the procurement process and corrective action.

Procurement documents include, as appropriate, provisions for the scope of work to be accomplished; technical requirements; quality assurance program requirements; a statement of right of access to a supplier's plant, facility and records; special quality assurance requirements; documentation and, as applicable, provisions for processing nonconformances.

5.2.13.1 Procurement Document Control Measures are provided for a procurement document control system which assures that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the purchase orders for material, equipment and services, whether purchased by Con Edison or by vendors or sub-vendors. Nuclear Quality Assurance identifies quality assurance program requirements to be included or referenced in requests for quotations  ;

and purchase orders. These quality assurance program requirements are imposed on  !

a vendor by means such as specifying applicable provisions of Con Edison's quality  :

assurance specifications, the approved vendors quality assurance manuals, pertinent Code quality assurance requirements, such as, ASME Section III, ANSI N45.2 or unique requirements for the specific purchase order. -

For procurement of iterns associated with plant modifications, Nuclear Power Engineering, Nuclear Power or Nuclear Projects as applicable, identify technical and regulatory requirements to be included or referenced in procurement documents. 2 When Nuclear Projects manages a project (ex. major capital projects), Nuclear Projects QC Coordinators / Planners prepare procurement documentation incorporating commercial requirements and the specified technical and regulatory requirements. j Procurement documents processed via Purchasing are reviewed by Nuclear Power i Engineering to assure they are technically correct, and reviewed by Material Procurement to assure that they identify proper supplementary quality requirements. 2 This procurement process is generally used for material which is specified in Nuclear l Power Engineering electrical and mechanical material lists.

2

Nuclear Projects purchase documentation that is processed directly to vendors or via Material Procurement is prepared by Nuclear Projects QC Coordinators / Planners and reviewed by Nuclear Projects engineering personnel to assure inclusion of appropriate QA and technical provisions. This procurement process is generally used for material not specified in Nuclear Power Engineering electrical and mechanical material lists.

Where Nuclear Power manages the project, Nuclear Power prepares the procurement -

documentation incorporating technical, regulatory and quality requirements. In these cases the documentation is reviewed by Material Procurement to assure that they are complete and adequate.

As a minimum the review of procurement documents is accomplished by personnel other I than the preparer. '

Quality assurance requirements are imposed on contractors by specifying applicable Code quality assurance provisions such as ASME Section III, ANSI N45.2 or unique quality requirements for the specific requisition.

Purchasing, Matenal Procurement or Nuclear Projects, as applicable, evaluates Bids and Proposals for commercial content. Vendor exceptions to technical requirements are evaluated by Nuclear Power Engineering or System Engineering and Analysis as l l applicable. Vendor exceptions to quality assurance program provisions which have 2 j been stipulated by Nuclear Quality Assurance as a result of source evaluation activities 11 shall be evaluated by Nuclear Quality Assurance. If the bidder or proposer takes no exceptions to the specifications and requirements, the buyer may secure purchase authorization.

Vendors me evaluated and approved prior to issuance of a purchase order to provide assurance that the vendor is capable of manufacturing and delivering a product i conforming to the requirements of applicable purchase specifications. Vendor approval documentation is maintained and updated, and purchase orders sent only to the approved vendors. In cases, however, where commercial grade items or services cre procured and Consolidated Edison assumes singular responsibility for verifying the acceptability of the item or service for use, the items or services may be procured from vendors who have not been evaluated or approved. After a purchase order is issued, the vendor may be reviewed on a surveillance basis during the manufacturing stage to assure conformance to specification requirements.

Upon receipt of purchase authorization, the cognizant buyer releases the requisition along with other appropriate documents e.g. Standard Terms and Conditions, for preparation of the purchase order. Copies of the purchase order are made available to Nuclear Quality Assurance and the requisitioning activity.

i If an outstanding purchase order must be modified, a properly authorized modification to the Purchase Requisition must be prepared and reviewed. Copies of modified purchase orders are distributed to those who received copies of the original purchase order.

5.2.13.2 Control of Purchased Material. Eauipment and Services Measures have been established which assure that purchased items and services,  ;

whether purchased directly or through contractors, conform to procurement documents.

These measures include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor, inspection and audit at the ,

source and exarnination of items upon delivery. )

l Purchasing (or Material Procurement), Nuclear Power Engineering, and Nuclear Quality Assurance evaluate the capabilities of approved vendors. Nuclear Power Engineering evaluates the overall manufacturing capability of the vendor, including his particular 2 technical ability to produce the item or component delineated in the specification.

Purchasing or Material Procurement evaluates the vendor's financial and administrative capabilities. Nuclear Quality Assurance evaluates the vendor's quality assurance program. The Nuclear Quality Assurance review includes consideration of the following:

l

1. Quality assurance personnel qualifications,

2. Review and control of design documents,

3. Documented manufacturing procedures,

4. Quality assurance procedures, acceptance criteria and calibration practices,

5. Quality assurance records and their retention,

6. Vendor receipt inspection and,

7. Quality assurance requirements imposed by the vendor on his subcontractors.

For a vendor to be maintained as an approved vendor, an evaluation of that vendor is made at least once every five years. Additional reviews of a vendor's facilities or his pedormance may be conducted by Nuclear Quality Assurance on a more frequent basis. l During the course of production, manufacturing or service activities, surveillance of the  !

vendor's performance may be conducted.

Vendor surveillance plans are prepared for complex equipment. The surveillance plans identify the areas such as, tests and records to be reviewed. The applicable purchase order, including the specifications and drawings, forms the basis for determining the areas for review.

i i

i Material procured by Nuclear Power is received at the Indian Point offsite Cortlandt Warehouse receiving and storage facility where it is inspected by Material Procurement inspectors in accordance with Material Procurement written ins'tructions.

Material procured by Nuclear Projects is received at on site receiving and storage facilities where it is inspected by QC Coordinators / Planners in accordance with written instructions developed and approved by Nuclear Projects QC Coordinators / Planners.

Alternatively, materials procured by Nuclear Projects may be received and inspected by Material Procurement inspectors and stored in the Cortlandt Warehouse. l Documentary evidence that material and equipment conform to the procurement  ;

requirements is available at the plant site prior to use of such material and equipment. '

Receiving inspection written instructions require, as appropriate, checking that objective evidence of quality required from the vendor has been received. Results of receiving inspections are documented on a checklist.

This documentation includes, as a minimum, the identity of the inspector, the type and results of inspection, the acceptability, and the action taken in connection with any deficiencies noted.

The status of accepted materialis identified by tags, stickers or other approved methods which provide suitable traceability. Nonconforming material is tagged until the nonconformance is dispositioned. If the disposition is to reject the material, the tag is maintained on the material until the rejected material is returned to the supplier or scrapped. Nonconformance and corrective actions are controlled in accordance with 5.2.14.

Accepted components or materials retain their status identification until they have been satisfactorily installed and the installation check has been completed or until it is necessary to remove the status identifier for installation purposes. Records of control of purchased material, equipment and services are maintained in accordance with 5.2.12.  ;

5.2.13.3 Identification and Control of Materials. Parts and Components l l

Measures have been established for the identification and control of material, parts and i components. Procedures are provided by Nuclear Power, Nuclear Power Engineering, l l Material Procurement and, as appropriate, other involved organizations which insure 2 that only accepted items are used and installed and which, where applicable, relate an item to an applicable drawing, specification or other pertinent technical document.

Identification marking is applied by suppliers and/or Con Edison organizations in a clear,

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unambiguous manner which does not adversely affect the function of the item. When groups of items are sub-divided, identification marking is appropriately transferred to smaller groups or individual items by Central Stores storeroom personnel, Nuclear Power or Nuclear Projects personnel except for indication of inspection status identification (" accept" tags, etc.) which is transferred by Material Procurement, Nuclear Quality Assurance personnel, Nuclear Projects QC Coordinators / Planners, or Project Support personnel.

E0 Where required for receipt identification and traceability purposes, materials and shipping containers bear specific marking prior to use at Indian Point.

Where such identification by the vendor is deemed necessarf, the vendor is instructed by the Purchase Order documents concerning the identification required. In cases where identification is to be done by personnel at Indian Point, written instructions are issued to accomplish the identification.

Shipping containers are identified and marked by the vendor in accordance with instructions included in the purchase order document in order to permit positive identification. Component or materialidentification numbers may also be required for traceability and these requirements are also specified by the Purchase Order. Where it becomes necessarf ot provide identification of material or components, detailed marking procedures are established. These procedures, if applicable, are prepared by Nuclear Power Engineering, Nuclear Power, or Nuclear Projects and reviewed by a l qualified individual other than the preparer. Care is taken to assure that marking 2 methods will not adversely affect the material or design characteristics. For example, marking materials containing sulfur and low melting point elements, such as, lead mid mercury are not used for identifying nickel alloys and stainless steel.

Care is also taken to apply the markings prior to modification or cutting operations to assure that traceability is not destroyed or lost. Nuclear Quality Assurance is responsible for verifying that marking performed at Indian Point is accomplished in accordance with approved procedures.

During the course of maintenance, repair, or modification work, it will be necessary for traceability purposes to identify new or repaired weld joints. This identification is accomplished in accordance with procedures approved by Nuclear Power Engineering. l 2 i Nuclear Power Engineering provides unique weld joint numbers for all welds shown on l l single line diagrams which carry piece numbers traceable to bills of material and weld 2 l joint numbers for piping fabrication and installation at Indian Point.

Nuclear Power or Nuclear Projects, as applicable, is responsible for assuring that unique weld joint identification numbers are provided in accordance with Nuclear Power Engineering's numbering system or Contractor's equivalent. Nuclear Power or Nuclear Projects, as applicable, is responsible for assigning unique weld joint numbers for other 2 welds required during installation and site fabrication including field run piping work and shall also be responsible for permanent weld identification.

Nuclear Power or Nuclear Projects, as applicable, shall assure that weld joint l identification is accomplished by identifying the welds on piping sketches or drawings l prepared by Nuclear Power Engineering, Nuclear Power, Nuclear Projects, or Contractors, as applicable, or where precise traceability cannot be assured by these methods, by permanently marking the weld at or near the weld joint. Where pipe size, accessibility or other limitations make physical marking impractical, metal tags shall be secured at or near the weld joint. The tags shall be permanently marked with weld identification information including directional information if tags are offset from the weld. Nuclear Power or Nuclear Projects, as applicable, shall provide "as constructed" i information to Nuclear Power Engineering in writing for updating engineering drawings. l 2

Adequate records of identification and control are retained for periods in accordance with 5.2.12 above.

5.2.13.4 Handlina, Storage and Shinoing Measures have been established which provide control of handling, storage and shipping. These measures include, where applicable, provisions for cleaning, packaging and preservation of material and equipment in accordance with appropriate instructions, procedures, drawings or other documents to prevent damage, deterioration and loss. Included are measures for very expensive, critical, sensitive and perishable items. Nuclear Power Engineering and other organizations, such as Nuclear Power or Nuclear Projects, establish or reference requirements for handling, storage and shipping. {

These requirements are identified in applicable requisitioning / procurement documents.

Items are packaged in a manner adequate to protect them against corrosion, contamination, physical damage or any effect which would lower their quality or cause the item to deteriorate during shipping, handling and storage. The specific requirements for packaging, etc., are determined by the procurement document review system and the requirements identified or referenced in the procurement document by Nuclear Power, Nuclear Projects and Nuclear Power Engineering. l 2

The degree of protection varies according to storage condition and duration, shipping environment and handling conditions. Items are protected against damage during loading, shipping, and handling by the supplier, shipper, and appropriate Con Edison

organization. Modes of transportation are consistent with the degree of protection required and with the packaging methods employed.

Items procured by Nuclear Power are received at the Indian Point offsite Cortlandt Warehouse receiving and storage facility. Central Stores personnel at the Cortlandt Warehouse receive and store items for use at the site. Items procured by Nuclear Projects may be received and stored at on site facilities or the Cortlandt Warehouse.

Upon their arrival, items are checked by Material Procurement or Nuclear Projects QC personnel for damage and for general compliance with purchase order requirements or internal documents where items are manufactured by Con Edison. Results of inspection are documented in a receipt inspection checklist by the receiving inspector.

Required marking is verified to provide positive identification during receiving, storage and installation.

Appropriate records relating to packaging, shipping, receiving, storage and handling are maintained by Nuclear Power in accordance with 5.2.12.

Storage is accomplished in a manner sufficient to minimize the possibility of damage or lowering quality due to corrosion, contamination, deterioration or physical damage from the time an item is stored until the time the item is removed from storage and installed at its final location. Storage requirements are based on supplier recommendations, Nuclear Power requirements and/or instructions supplemented, as appropriate, by Nuclear Power Engineering recommendations. l 2

Results of storage examination and inspections are documented and deficiencies corrected in accordance with established Nuclear Power or Nuclear Projects procedures.

During storage, appropriate care is exercised by personnel to maintain item integrity.

Central Stores or Nuclear Projects, as applicable, is responsible for handling items.

Maintenance and Construction, Nuclear Power, Nuclear Projects and Central Stores l maintain handling equipment in accordance with appropriate procedures, methods and 3 instructions.

As appropriate, handling instmetions and procedures have been established by Nuclear Power, Nuclear Projects and Nuclear Power Engineering for items requiring special l handling. As appropriate, hoisting equipment used for handling is initially certified by 2 the manufacturer. Except for test purposes, hoisting equipment is not loaded beyond rated load as certified by the manufacturer.

Safety requirements for material hoists are adhered to by Nuclear Power, Nuclear j Projects, Maintenance and Construction and Central Stores. Re-rated equipment is j given a dynamic load test over the full range of the lift. Normally, the test weight used in 3

4 temporarily re-rating hoisting equipment for speciallifts is at least equal to 110% of the I lift weight.

Records pertaining to packing, shipping, receiving, storage and handling, including 1 procedures, reports, personnel qualification, test equipment calibration,  !

nonconformances and inspection and examination are prepared and maintained by l Nuclear Power, Nuclear Projects, Central Stores etc., in accordance with the provisions of 5.2.12 and applicable guides and regulatory requirements. j 1

5.2.14 Nonconforming Items .

A system, including appropriate instructions, has been established for identifying, l documenting, segregating and dispositioning nonconformances. This system provides i for notification of affected organizations, for review and acceptance, rejection, repair or l re-work of nonconforming items and establishes the responsibilities for the disposition  !

of nonconforming items. This system also provides for identifying an item as nonconforming and controlled, as accepted "as is", as scrap or as held for further disposition. This system provides for documenting the acceptability of nonconforming items which bave been repaired, reworked or used "as is".

Incoming items are tagged as received. The items are receipt-inspected in accordance with documented instructions by inspectors in Material Procurement. Items which are acceptable are given an " accept" tag, sticker, etc. and put in separate locked storage.

Items which cannot be accepted are " hold" tagged and stored in segregated locked storage to await disposition. Items " hold" tagged but too large for segregated, locked storage or indoor storage are suitably identified to prevent their use. Items which are to be scrapped are also " hold" tagged and kept in separate locked storage imtil disposed of. Only items which have been properly receipt inspected and accepted can be used.

Items which do not meet acceptance criteria are evaluated for disposition. Material Pro-curement or Nuclear Projects, as appropriate, prepares a nonconformance report. The report identifies the nonconformance and recommends corrective action to the organization (action addressee) responsible to initiate action or resolve the nonconformance. Copies are forwarded or made available to affected organizations, such as Nuclear Power, Nuclear Quality Assurance, Nuclear Power Engineering and l Purchasing. Nonconforming items are accepted, rejected, repaired or reworked in 2 accordance with documented procedures specified by the organizations involved in resolving the deficiencies identified.

When significant nonconformances are identified, Nuclear Quality Assurance personnel, or other personnel performing quality assurance functions (ex. Test and Performance NDE personnel), as applicable, investigate and initiate a significant nonconformance report. This report is used to document significant nonconformances with specified

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quality requirements when found during plant testing, or plant modification, maintenance  ;

and repair activities.

)

The significant nonconformance report identifies the deficiency and recommends corrective action to the organization (action addressee) responsible to initiate action or resolve the deficiency. Copies are forwarded to other affected organizations such as l Nuclear Power, Nuclear Quality Assurance, Nuclear Power Engineering, Purchasing or l l contractors. Non-conforming items are accepted, rejected, repaired or reworked in 2 l accordance with documented procedures specified by the organizations involved in  !

I resolving the deficiencies identified. Items which have been reworked or repaired are

! reinspected and/or retested in a manner identical to the original inspection and/or test or in an alternate manner approved by Nuclear Power, Nuclear Projects, Nuclear Quality ,

Assurance or Nuclear Power Engineering, as applicable. Significant plant events, including equipment malfunctions, are reviewed by SNSC. Additionally, systematic analyses of equipment malfunctions are accomplished by System Engineering and Analysis. Results of the analyses including any recommended actions are documented and submitted, as a minimum, to the manager of the affected organization. The results of the analyses are also reviewed quarterly by a committee of Senior Management including the Vice President, Nuclear Power Department Manager, System Engineering and Analysis: Plant Manager and Department Manager, Nuclear Quality Assurance.

Analysis of trends may also be initiated independently by Nuclear Quality Assurance as part of its audit review program.

2 5,2,15 Review. Acoroval and Control of Procedures 21 The administrative controls and quality assurance program provide measures which control and coordinate the approval and issuance of documents, including changes there to, which prescribe activities affecting quality. These documents include those which describe organizational interfaces or which prescribe activities affecting safety-related structure systems or components. These documents also include operating and special orders, operating procedures, test procedures, equipment control l

procedures, fire protection procedures, emergency procedures, maintenance or modification procedures, refueling and material control procedures. These are in the form of documents such as station administrative orders, administrative directives, Nuclear Quality Assurance operating procedures, Purchasing, Nuclear Power Engineering and Maintenance and Construction procedures and corporate instructions.

2 The administrative controls and quality assurance program requires that activities 3 affecting quality be prescribed by documented instructions or procedures of a type appropriate to the circumstances, and accomplished in accordance with these l instructions or procedures.

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The total program definition is reviewed by Nuclear Quality Assurance at least every two years to assure continued program adequacy.

Procedures or instructions are reviewed by other than the originating individual. ,

Included in the review organizations are Nuclear Power, Nuclear Power Engineering, l Nuclear Projects, Purchasing, Nuclear Quality Assuranca, the Station Nuclear Safety 2 Committee and the Nuclear Facilities Safety Committee. The Station Nuclear Safety Committee reviews changes to procedures or instructions to verify that such changes do not constitute an unreviewed safety question as defined in Section,10CFR50.59.

Following an unusualincident during operations, testing, etc., an unexpected transient, significant operator's error or equipment malfunction or modification of a system,  !

applicable procedures or instructions are reviewed by appropriate individuals or  !

organizations. Changes to procedures or instructions are reviewed and approved by the appropriate organization. The system for review, approval and control of instructions or procedures provides for the identification of individuals and organizations involved, identification, as appropriate, of documents to be used in performing the activity, coordination and control of interface documents and the maintenance and updating of distribution lists.

These instructions or procedures include, as appropriate, quantitative or qualitative acceptance criteria for determining that certain activities have been satisfactorily accomplished. This administrative controls and quality assurance program establishes measures for controlling the issuance of documents such as procedures or instructions, including changes thereto, which prescribe activities affecting quality. These measures assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where  !

the prescribed activity is performed.

Each organization participating in this administrative controls and quality assurance program identifies to Nuclear Quality Assurance administrative documents judged ,

necessary to implement the administrative controls and quality assurance program. The organizations responsible for these documents include Nuclear Quality Assurance on distribution as each is issued or changed. Nuclear Quality Assurance in a timely manner, reviews these documents for adequacy. In addition, Nuclear Quality Assurance maintains an index of documents that define the basic structure of the administrative controls and quality assurance program.

5116 Control of Measurina and Test Eauioment Measuring tools, gages and test equipment used at the site on items which affect plant safety are controlled and recalled for calibration at prescribed intervals.

)

Nuclear Power, Nuclear Projects and Nuclear Quality Assurance, as appropriate, )

maintain required standards, conduct calibrations, adjustments, and approves calibra- l tion procedures. I Nuclear Quality Assurance, Nuclear Projects and Nuclear Power maintcin records of )

measuring and test equipment under their control. These records include: 1

1. Identification number  !

2. Description of theitem I

3. Manu'acturer's name and model number j

4. Calibration frequency l S. Reference to method or procedure 1 Only after items are listed on the measuring and testing list can they be used on Class A systems. Each measuring tool, gauge, and test equipment bears a tag or a sticker which indicates the next calibration due date.

Calibration requirements are based on the type of equipment, usage, and any other j conditions affecting accuracy control requirements.  !

I 1

Calibrations are made against certified measurement standards which have a known l relationship to national standards where such standards exist. Where no such standards j exist, the basis for calibration is documented. The accuracy of each calibrating standard j is at least equal to the accuracy requirement for the equipment being calibrated. If cdlled for by engineering specification or drawing or other written instruction, calibrating standards of a specified greater accuracy will be used.

Discrepancies discovered in examination or test equipment are reported in accordance with procedures for reporting nonconformances and corrective actions. A documented review is initiated of all work accomplished with the equipment since the previous calibration. To determine if applicable requirements have been satisfied, a review is conducted of all material, components and equipment checked with discrepant examination or test equipment since its last acceptable calibration or periodic check.

Nuclear Quality Assurance or Nuclear Projects QC Coordinators / Planners, as applicable, issues a nonconformance report if required.

5.2,17 Inspections Programs for inspection of items and activities affecting safety have been established and are implemented by personnel reporting to Material Procurement, Test and Performance, Maintenance, Instrument and Control, Nuclear Quality Assurance, Nuclear

Projects and contractors working under their direction, or by other properly authorized personnel.

For plant maintenance and modification, examination, checks and inspections are normally accomplished by supervisors responsible for the work. When independent 4 examinations are deemed necessary the examinations are accomplished by personnel who did not perform the work and who did not directly supervise the work.

Quality requirements, including inspection requirements, are established either by Nuclear Power Engineenng during development of modification documents, or Nuclear Projects or Maintenance during development of work instructions. Nuclear Quality Assurance and other organizations (ex. Test and Performance) conduct independent 2 inspections to verify compliance as specified in work instructions. 18 Work inspection instructions identify the inspections, hold points and documentation <

required for a job. For large and complex work, travelers or other documentation, e.g.

modification implementing procedures, are issued by the Nuclear Projects or Nuclear Power. The documentation identifies the operations to be performed on an item after  :

it is drawn from storage. Mandatory independent inspection hold points are also 1

' identified on the documentation, as applicable.

The Department Manager, Nuclear Quality Assurance has the authority to order l cessation of work where continuation of work would lead to unacceptable conditions. 8 Work may be resumed if approved by the Plant Manager; or management levels above the General Manager. l 6

The inspecting organizations maintain records of required independent inspection activities.

5.2.18 Control of Soecial Processes Measures have been established and documented which assure that special processes are accomplished under controlled conditions employing appropriately qualified personnel and procedures.

Nuclear Power Engineering prepares in-house welding procedures and acceptance criteria. Maintenance and Construction qualifies welding procedures and personnel to applicable ASME Codes and maintains appropriate records in accordance with ASME 2 Code Section IX. 3

9 Welding materials are specified, purchased, receipt inspected, stored, identified, and issued in accordance with written procedures. Nuclear Power Engineering provides l weld joint identification and authorizes weld modifications or repair. 2 For welds accomplished by Company forces at Indian Point or at Van Nest shops, the proper completion of weld inspection forms, weld inspection and acceptance, and permanent recording of weld acceptance, is the responsibility of the Nuclear Quality Assurance inspector or Maintenance and Construction Quality Control inspector l respectively. 3 For welds accomplished by contractor personnel, the contractor weld process control i form for welds shall require the approval of contractor quality assurance personnel. In cases where the welding contractor does not provide NDE services, as the welding proceeds the appropriate section of weld inspection form shall be completed by the l Nuclear Quality Assurance inspector or Maintenance and Construction Technical l l Engineer Inspection and Quality Control, as appropriate, to indicate that inspection 3 l requirements have been satisfied and to provide permanent record of traceability of  !

material and inspection information, as required.

Nuclear Power, Maintenance and Construction, or Nuclear Projects, as appropriate, l prepare "as-constructed"information (marked-up drawings) showing weld locations and 3 respective weld identification numbers. The "as constructed" information for modifications is forwarded to Nuclear Records Management Center which verifies that these drawings conform to the latest modification package drawing list and then forwards them to Nuclear Power Engineering. Nuclear Power Engineering revises the l  ;

affected original drawings, and distributes copies to the Nuclear Records Management 2 l Center. Nuclear Power forwards "as constructed" information for repairs to Field 1 Engineering for reporting to Nuclear Power Engineering as necessary. Nuclear Quality l Assurance or Nuclear Projects monitors welding activities to assure compliance with 2 l approved procedures. Welding codes or requirements for work performed by contractors requires prior Engineering approval. Heat treatment is conducted in accordance with approved procedures.

The Department Manager, Nuclear Quality Assurance or the Manager, Nuclear Power l Test and Performance or their designees certify level III Non-Destructive Examiners. 8 Level 111 examiners are responsible for examinations of Iovel I and lovel Il personnel.

All NDE personnel must meet the required physical fitness criteria, pass a written examination, satisfactorily operate test equipment and interpret or analyze collected indications. Nuclear Power Engineering identifies the type of NDE to be performed.

4

l Nuclear Quality Assurance or Test and Performance, as applicable, monitor NDE ,

services to assure compliance with requirements and maintains appropriate records of  !

work performed.

Chemical cleaning may be required during certain maintenance or modification work.

The maintenance procedure identifies the approved process to be followed as well as any inspections and other controls required.

5,2,19 Test Control Nuclear Power provides, and maintains control over operating procedures and test procedures to assure that they are appropriately prepared, authorized, implemented, documented and evaluated. '

The plant Technical Specifications incorporate various engineering requirements and parameterlimits that are appli,:able during operation of the plant. Procedures include measures to report conditions adverse to quality and to assure adequate corrective action. The NFSC reviews proposed changes to procedures which involve an unreviewed safety question as defined in Section .10CFR50.59. Nuclear Power i establishes procedures for indicating the status of inoperable equipment; for example, j tagging valves and switches to prevent inadvertent operation. '

A series of periodic tests have been prepared to satisfy the requirements of the plant l Technical Specifications.

Test procedures contain:

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(1) The test objective l (2) The acceptance or operability criteria to be used in evaluating test results (3) Pertinent references, as appropriate (4) Precautions i

(5) Limitations  !

(6) Check-off sheets, as appropriate (7) Technical specifications, as required (8) Special equipment, as required (9) Step-by-step instructions Each test procedure is approved by Test and Performance.

Test and Performance sends a copy of the test procedure to the chairman of the Station Nuclear Safety Committee who arranges a SNSC review.

- 42 -

Once approved by the Station Nuclear Safety Committee, these test procedures are maintained in a central file and updated, as required, for possible future use.

Maintenance and preoperational test control consists of the following:

(1) Each Work Order issued for Class A items is evaluated for retest requirements by Test and Performance which provides such requirements as necessary.

(2) Prior to the test, Operations insures that all Work Orders to which the test applies have been signed off for work completion. Operations also assures that there are no unresolved conditions adverse to Quality for any item within the bounday of the test.

(3) For refueling or other major shutdowns, a total test program is developed including an overall schedule for tests to be performed. The program is based on a review of all Work Orders and associated test requirements by the appropriate organizational units.

(4) Test procedure results are submitted to Test and Performance for review. Test and Performance monitors test results to assure that data meet acceptance requirements.

Test and Performance monitors the performance of test procedures, as necessay, to assure that the tests are performed in accordance with written procedures.

Post-maintenance test results are evaluated by station personnel. When test results are deemed satisfactory, the Operations Watch Supervisor certifies the test results by signing and dating the appropriate sections of the approval sheet. The record copy of the test results and the applicable Work Order covered by that test are filed in the central record file. Test results are reported to Test and Performance for evaluation.

Nuclear Power prepares and controls operating records in accordance with  ;

requirements of the plant Technical Specifications. These records provide I documentation for all operations, tests, inspections, shutdowns, changes and other pertinent activities associated with daily operations listed in the plant Technical Specifications. These records are maintained at the site in a manner convenient for review and are retained for five years or longer, as required by applicable codes or regulations.

5.3 Preoaration of Instructions and Prccedures l

The administrative controls and quality assurmace program is carried out in accordance l with written instructions and procedures. These instructions and procedures are prepared by organizations participating in the program, e.g., Nuclear Power, Nuclear l 2 l 1

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_ _ - . _ _ _ _ _ _ _ _ _ . . . _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ m 4

e' Power Engineering,' Nuclear Projects, Purchasing, Nuclear Fuel Supply and Nuclear l Quality Assurance and are reviewed, approved and controlled in accordance with 5.2.15.

2 These instructions and procedures describe activities affecting safety at the plant and I provide an approved, preplanned method of conducting operations. Procedures are in I documents such as general administrative directives, station administrative orders, l

administrative directives, plant technical procedures, Nuclear Quality Assurance procedures, Nuclear Power Engineering and Purchasing operating procedures, Nuclear l Projects field directives'and corporate instructions. Each instruction and procedure is 2 l

of a detail uppropriate to the circumstance and permits the user to perform the required activity without direct supervision; is appropriately titled, dated, and approved; contains a clear, concise statement of purpose; and, as appropriate, contains in its body the titles and identifying numbers of applicable reference documents; and identifies prerequisite  :

activities, precautions to be taken, limitations to be applied, corrective action to be ,

implemented, step-bystep instructions, acceptance criteria and check-off lists. .

. Procedures fall into the following general categories:

1. System procedures describing operation related to the safety of the plant. . I

2. General plant procedures providing instructions for the integrated operation of the  !

plant.

3. Startup procedures which provide for starting the reactor from hot or cold i condition and recovery from reactor trips.

4. l:

Shutdown procedures which provide for controlled reactor shutdown or shutdown following reactor trips.

5. Power operation and load changing procedures which provide for steady-state  ;

power operation and load changing, including response to unanticipated load changes. l

6.  !

Process monitoring procedures which provide for monitoring plant system '

performance and which, as appropriate, identify limits for significant process '

parameters. .

7. Fuel-handling procedures which provide for such activities as core alterations, i refueling, fuel accountability, receipt and shipment of fuel and safety measures. i

8. Maintenance procedures which provide for preparation for maintenance, 3 performance of maintenance, post-maintenance checks and return to service, and maintenance records.

9. Radiation control procedures which provide for implementation of the radiation control program including the acquisition of radiation data, and which identify equipment for perfonning radiation surveys and for measurement, evaluation and assessment of radiation hazards.  ;

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10. Calibration and test procedures which provide for penodic calibration and testing  :

of safety-related instrumentation and control systems and of measuring and test equiprnent used in activities affecting safety.

Chemical-radiochemical control procedures which provide for activities such as 11.

sampling and analyses, coolant quality maintenance, control of deleterious agents and for the control, treatment and management of radioactive wastes and

, the control of radioactive calibration sources.

12. Emergency procedures which provide guidance for operations during potential emergencies in a manner that will allow a trained operator to identify in advance the course of events signaling an emergency as well as describing the action he should take; and for distinguishing, at least initially, between abnc mal and emergency conditions; for identifying symptoms of a particular kind of emergency condition; for automatic action; for immediate operator action; for subsequent operator action; and for categories of events of particular kinds of emergencies,

such as loss of coolant.

13. Procedures for implementing the emergency plan which provide for assignment of authorities and responsibilities; protective measures; specific action; medical treatment; equipment requirements; identification of emergency communications network; description of alarm signals, restoration of the plant to normal 4

conditions; and for testing of procedures, communications network and alarm system.

14. Test and inspection procedures which provide a description of objectives, j i acceptmice criteria; prerequisite and special conditions, limiting conditions, the j test or inspection procedure; specify any special equipment or calibration required; and which, as appropriate, identify hold points.

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5

.i APPENDIX A -;

Class A Items

l. Core and Reactor Internals. [

2. Control Rods and Control Rod Drives and Drive Housings. [

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3. Primary Coolant System.

. . Pressurizer System. _-.

• Primary Relief System.

. Reactor Coolant Pump Shaft. l

. Reactor Coolant Pump Flywheel. l

. Reactor Coolant Pump Seals.

. All pressure boundaries (vessels, pumps, piping and valves) through the  ;

second pressure boundary isolation device.  !

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4. Secondary Coolant System. l

• Main Steam Unes up to and including the Second Main Steam Isolation . j Valves (MS-2). '

• Main Feedwater System to the Steam Generator downstream of and including the system's second Isolation Valve.  ;

• Boiler Blowdown from the Steam Generators up to and' including the j system's isolation valves.  ;

e The Main Steam Line to the Auxiliary Feedwater Turbine Drive.  ;

• Turbine Stop and Control Valves.  :

. First Stage Turbine Pressure Transmitters. .

. Independent Electrical Overspeed Protection System. l

. Feedwater Regulator Valves (Main and low Flow Bypass), t

. Main Boiler Feedwater Pump Motor Operated Discharge Valves (BFD 21

& BFD 2-22).

. Main Steam Traps and Atmospheric Dump Drains and Silencer Drains.

Feedwater I.eading Edge Flowmeters and Associated Pressure Transmitters (PT-3101 through 3104).

5. Auxiliary Boiler Feedwater System.

Includes:

. Condensate Storage Tank, supply piping and valves to the Auxiliary Feedwater Pumps.

. City water to Auxiliary Feedwater pump up to and including valve CT-49.

Page 2 of 6

6. Chemical and Volume Control System.

7. Containment Building.

Includes:

.- Access air locks.

. All piping and electrical penetrations.  :

. Internal floors, walls and structural steel.

8. Containment Isolation System.

9. Containment Spray System.

10. Containment Air RecirculationCooling and Filtration System.

I 1. Gaseous Waste Processing System.

12. Liquid Waste Processing System.

13. Nuclear Service Water System. ,

. All cooling paths to and from nuclear safety related equipment.

14. Instrument Air System.

. Compressor and associated equipment and essential air header to nuclear instruments, control and valves.

. Closed Cooling Water System.

15. Fuel Handling System.

16. Reactor Control and Instrumentation System.

17. Reactor Protection / Trip System.

18. Sampling System.

.- Including only pressurized lines up to the second Containment Isolation Valve.

19. On-site Emergency A.C. Power System.

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Page 3 of 6 Includes: l 1

. Bectrical components and circuitry up to and including isolation devices for non-emergency loads.

. Emergency Diesel Generators and Diesel Generator Auxiliary Systems, i.e.,

fuel oil, Cooling Water and Startup Air Systems.

(6.9 Kv Buses and Lighting Systems are both Non-Class A.)

20. On-site D.C. Power Systems.

Includes:

. Bectrical components and circuitry up to and including isolation devices for non-emergency loads.

. Batteries, battery chargers, D.C. power panels, D.C. distribution panels and associated cabling, i

21. Process and Area Radiation Monitoring Systems.

22. Containment Penetration and Weld Channel Pressurization System.

23. Hot Penetration Cooling System.

24. Isolation Valve Seal Water System.

25. Post Accident Containment Hydrogen Control System.  !

Includes:

• Hydrogen Recombiner System.

• Post Accident Containment Vent System.

. Containment Building Post Accident Air Sampling System (H2-02 Analyzers).

26. Safety Injection System.

• High Head Injection for ECCS. l

. Iow Head Injection for ECCS.

-. Recirculation and Containment Sumps.

. Accumulators.

• External and Internal ECCS Recirculation Systems.

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l Page 4 of 6

27. Residual Heat Removal System.

Includes:

. Iow Head Injection for ECCS.

. External and Internal Recirculation Systems.  :

. Recirculation and Containment Sumps.  !

28. Component Cooling System.

Includes: '

. Auxiliary Component Cooling Pumps and Piping.

29. Refueling Water Storage Tank.

30. Spent Fuel Pool Cooling and Make-up System.

31., Ventilation / Filtration System for Areas containing Safety Related Systems and Systems containing Radioactivity.  ;

32. Reactor Vessel Service and Inspection Equipment.

Includes:

Polar Crane.

Equipment that is used over the core and that could cause damage to the nuclear fuel assemblies during the time the reactor head is removed.

. Reactor Vessel and head inspection tools.

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33. Containment Sump System. <

includes:

. Sump Pump.  !

. Piping, flow and levelInstruments. l

. Level Instrumentation in the Reactor Cavity Sump.

34. Primary Coolant Imk Detection System.

35. Nitrogen Supply to Nuclear Equipment.  ;

l l

36. Hydrogen Supply to Nuclear Equipment.

i Page 5 of 6

) 37. Primay Water Make-up System. l

38. Supports required for all the above listed items.

Includes:

i

. Structures and Seismic Restraining Devices.

39. All Regulating Systems, Controlling Systems and instrumentation used with the above listed items.

Includes:

. Indications used to determine operator action before (normal operation),

during and following a postulated accident.

40. Allitems designed in Design Specification as per ASME Section III, Classes 1, 2, and 3, MC and CS.

41, All equipment performing Category 1 or 2 functions per Regulatory Guide 1.97.

42. Any fuses and circuit breakers which provide protection (limit electrical fault currents) for containment electrical penetrations. ,

43. ATWS* Mitigation System Actuation Circuitry (AMSAC)

• ATWS - Anticipated Transient without Scram.

c

• Note:

In order to preclude the need to develop an AMSAC specific QA program, AMSAC equipment will be treated as " Class A", which for quality assurance purposes will invoke Con Edison's 10CFR50, Appendix B program. Should any aspect of our 10CFR50, Appendix B, QA program, prove overly restrictive or otherwise unnecessary, provision will be made to waive that aspect, provided that the quality assurance guidance contained in Generic 1.atter 85-06 is observed. Procedures which may waive provisions of 10CFR50, Appendix B, shall be developed for these unique situations and approved by the Senior Vice President, Central Operations per section 3.2 of this Quality Assurance Program. {

The following consumables are used in conjunction with the items listed above:

44. Diesel Generator Fuel Oil.

C

' 9 Page 6 of 6

45. Boric Acid.

46. Lubricating Fluids whose loss could degrade critical components.

47. Demineralizer Resin.

Includes:

• Resins used in the Chemical and Volume Control Systems.

48. Sodium Hydroxide for use in the Containment Spray System.

49. Weld Rod and Weld Filler Material.

50. Hydraulic Snubber Fluids and Seals.

6

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TABLE A Regulatory Guide / ANSI Intesvretatim/AltemateException item No, Std. Reference Reautrement

1. General Certain Regulatory Guides in- The Cm Edison commitment refers to the voke orimply Regulatory Regulatory guides (and the ANSI Standards Guides and standardsin addi- they endorse) specifically identified in the ,

tion to the standard each pri- '

" Foreword *. Additional Reguistory Guides, marily endorses. other guides and similar documents implied or referenced in those specifically identified in the " Foreword

• are not part of this commit-ment.

2. General Certain ANSI Standards extend Our commitment to these standards applies the scope of applicability to in- mly to those systems, structures, and compo-clude systems, structures, and nents whose satisfactory performance is re-components whose satisfactory quired to prevent postulated accidents that performance is required for a could cause undue risk to the health and safety plant to operate reliably. of the public; or to mitigate the consequences of such accidents. Reliable operation of the plant may depend upon other systems struc-tures and components which are not covered by this commitment.

I A-1

• i

. ~

b TABLE A

}lenulatory Guide / ANSI Interpretation /AltemateException +

Item No. Std. Reference Reauirement

3. General NRC Regulatory Guides, and The majority of ANSI Standards endorsed by ANSI Standards do not provide the Regulatory Guides to which Con Edison for deviation from any require- has committed are concemed with the design ment (s)when emergency or and/or construction phases of nuclear power other urgent conditions make plants. Consequently, Con Edison has such deviation necessary adaptal these standards to its operations phase, where practicable, and has developed provisions for certain conditions not ad- l dressed in the standards.

r In the event of an emergency condition which, if not promptly corrected could likely affect the health and safety of the public, the Vice President, Nuclear Power or his designated altemate(s) may authorize emergency repairs and deviations from written procedures. The natuse of the emergency, its cause and the corrective action taken are documented. ,

Waivers to specific procedures may be autho- l rized by the Vice President, Nuclear Power or his designated attemate if necessary to avoid significant loss of unit capacity with due con-sideration for public health and safety. Such waivers, including the need therefore, are documented.

i The above provisions assure procedural con- I trol for by-passing critical inspections, tests, and operations. i a

A-2 .

~ . , _.

. P J

TABLE A Renulatory Guide / ANSI Interpretaten/ Alternate /Excepuan item No, Std. Reference Reuoum,a,t-  !

4. General Certain ANSI Standards contain lhe majority of ANSI Standards endorsed by ,

requirements which, under cer- the Regulatory Guides to which Con Edison i tain conditions, may conflict has committed are concerned with the design with limiting personnel radia- and/or construction phases of nuclear power ,

tion exposure. plants. Consequently, Con Edison has . i adapted these standards to its operations .;

phase, where practicable, and has developed  !

provisions for certain conditions not ad- 1 dressed in the standards When conformance with particular standards  !

requirements; e.g., cleaning of fluid systems, housekeeping, would conflict with limiting personnel radiation exposure, the degree of conformance to the standards is determmed by appropriate levels ofmanagement.

i'

5. General Various standards require in- Except in ANSI N45.2.5, the frequencies of spections, examinations and required inspections, examinations and tests tests, but do not specify the fre- are not specified in the standards. Accord-quencies of these activities. ingly, the fmuency ofinspections, examina- f tions and tests required by the standards - e other than ANSI N45.2.5 -is identified on a i

, job by job basis The amount ofinspections examinations and tests identified is based upon the safety sigruficance of the item in- f volved.

I l

A-3 ,

. _ - . . _ _ . _ _ _ . _ _ _ _ _ _ _ .-u__m -.____- _ . _ _ _ _ _ _ _ _ . -_ _:-m m._a-_ uo -__ m u 7 M m r n -- mw y

TABE A Regulatory Guide / ANSI Inkrpnsahnn/Aleenseehn9hnn  !

Item No Std. Reference Requennent ,

6. ANSI N18.7

• Temporary changes winch Temporary changes will be maharized per the Sechon 5.2.2 clearlydo not change theintent pauvimons of the Ahnuneative Controls of the approved pmcedure shall, Section of the plant Technical Speedicabons.

as a mmunum,be approved by

- two..~..: s of the plant staff knowledgeable in the areas af-fected by the pi. J. m*

7. ANSI N18.7 (a)

• Maintenance or Modifica- R+- a (a),(b) and (c), as a whole, First Sentence of tion shallbeperformedina require a degree of quahty for replacement 5.2.7 manner to ensure quality atleast items consistent with their funcuon. Our pro-equivalent to that specified in gram allows this degree of quahty to be more ,

osiginal-design bases and re- or less strmgent than the ongmal, provided quuements, materials speedica- the specified quality iq-.mme are re-  !

tions, and inspection require- viewed and approved by Nuclear Power En- l ments. . gmeenng prior to use.

L First Sentence of (b)"A mamtenance program 5.2.7.1 shall be developed to mamtam safety related 4.M-ss, sys-tems and +~,ts at the  ;

quality requiredfor them to per- '

form theirintended funchons." .

ANSI NIB.7 Para (1) (c)"P=M to specificebens of5.2.13 and codes equivalent to those specified for the original equip-ment,or those specified by a Properly reviewed and approved .

revision.  ;

A-4 i

(

- _ _ - - _. . - - - - -- -~

TABLE A Fe=da*=v Guide / ANSI Interoretatam/AhernateExceptam item No, Std. Reference Reuuomi.cra

8. ANSI N18.7 General requirements for non- Paragraph 5.2.14 applies to programmatic as Section 5.2.14 conforming items .well as to specific provisions of ANSI N18.7 and its associated references. Consistent with paragraph 5.2.14, our quality assurance pro-gram will contain provisions for controlled, documented waivers to its requirements.

9. ANSI NI8.7 Requires certain provisions in Per 5.2.13 procurement document contents Section 5.2.13.1 procurement documents. for replacement items will be based pnmarily on original procurement document contents.

The provisions of 5.2.13.1 will be included if required by original procurement document or warranted by performance of the item. Pro-curement document content for new items will meet the requirements of 5.2.13.1. When re-quirements of ANSI standards are included in procurement documents, the requuements may not be identified as excerpts from ANSI ,

standards Pis--.. cat documents are devel-oped and reviewed in accordance with para- l graph 5.2.13 of the Quality Assurance Pro-grsm description.

f i

i t

A-5 ,

. , , . ~ _ <. . ..- _.. .- - ~ . . . . . - _ _ _ _ . _ _ _ _ . _ _ _ . _ _ _______________.m__ _ _ . _ . _ _ _ _ .. . _ _ _ _ _ . . .

. ,,_m.._

b I.e TABLE A .

Regulatory Gade/ ANSI Interpretaben/Ahernate/Excephon item No. Std. Reference Reamrement

10. ANSI N18.7 Section " drawmgs,Nahiand Drawmgs are idenhfied by drawmg number, 5.2.13.1, (2) - ndM codes and standards. revision number, and title. - -

, shall be idenhfied by titles and deses ofissue_.".

I 1. ANSI N18.7 Secton Where changes are made to pro- Conastent with the re. ofANSI 5.2.13.1 curement documents,they shall N45.2.11, paragraph 7.2, minor chances to ist Para. be subject to the same degree of (prm,-aa) documents, such as, inconse-control as was usedin the prep- quential editorial m.4is, or changes to aration of the original docu- commercial terms and conditions may not  ;

ments. regare that the revised (pru -aa) docu-ment receive the same review and approval as ,

theongmald- A  :

11.1 ANSI N18.7 Section "The frequency of =_sh==W As an ahanate to a penodic review, proce-5.2.15 [ procedure] reviews shall be dures arein .J as described in Sechon specified. " 5.2.3.

t

" Plant procedures shall be re-viewed by an individual knowl-  ;

edgeable in the area affected by i the praceane no less frequently  ;

than every two years. ".

12. ANSI N18.7 Section " Inspection shall be performed Exammahons, checks, and inspections of ,

5.2.17 by qualified individuals other work at Indian Point Station are nonnally ac- l than those who performed or comphshed and documented by Supervisors duectly supervised the activity responsible for the work. Where mdependent being %d" --ninath=. checks, and inspechons are  ;

determined appropriate, pm.d who do not perform work and do not directly supervise the work are unhzed. Dese i%t ex-annnshons, checks, and inspechons are com- ,

parable in extent to ma@-Jug constnic-tion phase activities. i i

[

i i

A-6 ,

TABLE A ,

Regulatory Guide / ANSI Internretation/AlternateExmotion Item No, Std. Reference Rouuu mat i3. ANSI N18.7 Sectim 5.2.17 Deviatims, their cause, and any Casistent with the h- *ian require-last paragraph,next to corrective action completed or ments of Criterim XVI. Appendix *B" to 10 last sentence planned shall be documented. CFR 50, for corrective action, signdicant de-viations, their cause and any corrective action completed or planned are Aa-4 Re-suits ofinspections used to accept or reject items shall be dos =m.o;cd in all cases.

14. ANSI N18.7 Section 6 *When the precedmg American Our commitment to ANSI standards does not References National Standards referred to extend beyond the standards (date, revision, in this document are superseded etc.) identified in that commitment.

by a revision approved by the American National Standards Institute,Inc., the rnision shall apply."

15. ANSI N18.7 General and specific procure- Alternate methods to those specified in these ANSI N45.2 ment requirements. standards may be used in special cases to sup-ANSI N45.2.2 port pix met ofitems; e.g., those items ANSI N45.2.13 urgently needed, items where commercial quality is sufficient or sole source items. In these cases, prior to prAurement, exceptions to the standard requurments will be docu-mented and concurred in by Nuclear Power l

Fr.gimuig Nuclear Power and Nuclear 2 Quality Assurance.

r A-7

l .

TABLE A Renulatory Guide / ANSI Interoretation/AlternateException ,

item No. Std. Reference Requirement t

16. ANSI N45.2.2 "The specific items to be gov- Items governed by this standard or portions Section 2.1 erned by this standard shall be thereof are identified on a case-by-case basis identified." during the design document and procurement document development processes.

17. ANSI N45.2.2 Each of the specific items gov- All safety-related items are protected to an Section 2.7 erned by this standard shall be extent commensurate with their sensitivity and classified into one of four levels. importance to safety, but are not specifically classified in various levels per the guidance of ,

paragraph 2.7. Therefore, satisfaction of re-quirements for packaging, shipping, receiv-ing, storage and handling for particular items could be different than those suggested.

I 8. ANSI N45.2.2 General marking requirements. Some items are of a size, shape or consistency Subsection 3.9 which preclude markmg. Marking in such cases is applied to box or other enclosure.

Tagging is employed, where necessary

19. ANSI N45.2.2 " Preliminary visualinspection Inspection after unloading is sufficient to de-Subsection 5.2.1 or examination shall be per- termine the condition ofmany items. In spe-formed prior to unloading..." cial instances, preunloading examination is performed, I

i A-8

._________ _ _2_-_-_ .___u _ _ _____ v m _ - - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ . _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . . . .

TABLE A Regulatory Guide / ANSI Intemretation/AltemateExcepton Item No, Std. Reference Requirement

20. ANSI N45.2.2 h (receiving)inspectims Receiving inspectim is performed in a man-Section 5.2.2 shall be performed in an area ner and in an environment wluch do not en-equivalent to thelevel ofstorage danger the requisite quality of an item; how-requirements for the item. ever, receiving inspection area environmental-controls may be less stringent than storage environmental requirements for that item.

21. ANSI N.45.2.2 ."The'Special Inspection

• pro- h "Special Inspection" procedure shall be Paragraph 5.2.3 cedure, complete with docu- readily available to inspection personnel and mentation instructions shall be may be attached to the item or container.

attached to the item or con-tainer...".

22. ANSI N45.2.2 "A statement documenting the A statement documenting the authority and Paragraph 5.3.3 authority and technicaljustifica- justification for the conditional release is pre-tion for the conditional re- pared. Justification may not always be of a lease. shall be prepared. ". technical nature.

23. ANSI N45.2.2 The use or storage of food, People working in storage areas have a right Subsection 6.2.4 drinks and salt tablet dispensers of access to water dispensers per OSILA re-in any storage area is prohib- quirements. Additionally, due to location and ited. layout of the building, personnel temporarily store lunches in the workplace. This area is regularly policed for sanitation.

l l

l l A-9 l

l b___________________________ _ _ _ _ _ _

=.

TABLE A

• Renulatorv Guxle/ ANSI Internretation/Altemate/Exceocon Item No. Std. Reference Reu== w t

24. ANSI N45.2.2 *Catamer marbngs shall ap- Contamers are adequately marked for storage, Appendix (A-3) pearon a rmmminn of two sides ximtificahon and retneval. Muluple marbng A.3.9 (1) of the container,preferablyon i%m.- are imposed,where necessary Second Group one side and one end."

25. ANSI N45.2.2 " Container marbngs shall be... O=*=iner markmgs are of a size which per-Appendix (A-3) no less than 3/4" high container mits easy recognition.

A.3.9 (4) permitting."

Second Group

26. ANSI N45.2.2 " Container marbags shallin- The information required in container mark-Appendix (A-3) clude the following informa- ing is evaluated on a cas:-by-case basis.

A.3.9 (6) tion " Markmg is adequate in each case.

27. ANSI N45.2.2 "Non-nmalhc plugs and caps Non-metal plugs and caps are of a suitably Appendix (A-3) shati be brightly colored." visible color.

Section A 3.5.1 (1)

28. ANSI N45.2.2 Plugs orcaps shall be secured In cases where plugs or caps do not snugly fit, Appendix (A-3) with tape or other means as nec- additional secunng desices or iram will Section A 3.5.1 (5) essary to prevent accidental re- be used.

moval.

29. ANSI N45.2.3 Identifies various housekeeping When this standard is applied, its requue-requirements, including cleanli- ments we implemented in those areas affected ness, fire prevention and fire by work activities associated with modifica- ,

, protection which must be ac- tions or maintenanw as determmed twj l complished during the progress by Nelear Power Engmeenng or Nuclear ofconstmetion.

l Quality Assurance. Remaining prosisions of para. 5.2.10 of I8.7 will be adhered to. 2 A-10

TABLE A

• Regulatory Guide / ANSI Interwetahon/Ah-dwe=*aa item No. Std. Refenace R- w.t

30. ANSI N45.2.4 l'im.s:iuction wnficaban. This secnon requires ven6cahon that items Secnon 3.0 are in satisfactory condition for installation and have not suffered since initial reccept in-spechon. Documentabonofthatvenficahon in addition to the hw:stion of the initial receipt mspecuanis not regared.

31. ANSI N45.2.4 Identifies various tests to be O=deent with sechon 5.2 ofIEEE 336, Secum 5.2 performed. Draft 1, Resisim 2,1976, these tests will be performed "as appropriate" as dcL J by Nuclear Power Engmeenng or Nuclear Power.

l 2

32. ANSI N45.2.4

• Mechanical tests shall be per- For the plant operational phase

• system pres-Subsecuan 5.2.2 formed to ascertam that...com- sure raungs" is interpreted to mean system Mechamcal Tests ponents or systems can with- operating pressure. For the Reactor Coolant stand system pressuir ratings." Sym Facility Techmcal Specinc=* inns identifytestmgsqu m.ats.

33. ANSI N45.2.4 " Items requinng cahbratim items reqmnng calibratim are tagged indicat- ,

Subsection 6.2.1 shall be tagged... indicating date ing date ofcalibration. Identity of person that I ofcalibration and identity of perfonned the calibration shall be indicated peram..." m tag or traceable through records-

34. ANSI N45.2.5 Requires periodic calibration of 1he initial accuracy ofliquid-in-glass ther-Sectim 2.5 thirassters. mometers is established and, because of their mherent stability, they need not be " adjusted or calibrated at prescribed intervals *.

A-1 I

- - - _ _ _ _ _ _ _ . - _ . _ ~ . . .

TABLE A

• Renulatory Guide / ANSI Intemretation/AlternateExcepten item No. Std. Reference Reauirement

35. ANSI N45.2.5

• when discrepancies._ are

. Consistent with ANSI N18.7,5.2.16 what Secten 2.5.2 found allitems inspected shall desices are found to be out of calibration, an Second paragraph be considered unacceptable." evaluatim shall be made and documented

corm -.g the validity of previous tests. -

36. ANSI N45.2.4 'These tests shall be made to For the plant operatim phase, this require-Subsection 6.2.2 verify that all parts of a system ment is interpreted as not requinng that an Systems Tests properly coordinate with each entire system be re-tested after completim of other." modificatie of only a porton of that syssem. I The testing requirements of the plant Teclei-cal Specifications are for inoperable eqmp-ment.

37. ANSI N45.2.5 " Inspections shall be performed Design controls verify qualifications of pro- ,

, Section 3.3.4 to... verify that the process is cesses and suitability for particular applica-suitable for the particular appli- tions. Verification of availability ofman- ,

cation. Verify that manpower, power equipment, etc. is pufuind by project equipment and materials are management rather than inspectim personnel.

available.. " i

38. ANSI N45.2.5 This section specifies inspec- Quality of materials is verified prior to Section 4.2 tions ofstorage, handling facili- batching in lieu of these. inspections.

ties, stock piles, water, etc.

39. ANSI N45.2.5 Various wrenches require cali- This requirement will be conformed with in  !

Section 5.4 bration twice daily or weekly. the case ofcontinued use. For intermittent use

, calibration frequency is I,ased upon usage and calibration intervals may be greater than days or weeks.

i A-12 ,

TABLE A -

Rendatory Guide / ANSI Interpretation /AlternateExceouen Item No. Std. Reference Reauirement

! 40. Regulatory Guide 1.58 General requirements for in- NDE p-..d meet the requirements of ANSI N45.2.6 spection, examination and test- ASNT-TC-1 A. Other personnel are qualified ing personnel. as discussed in Sections 3.3 and 3.4 of the Program Descriptiert

41. ANSI N45.2.8 Ifchecks disclose apparent loss We will check LL=** tion of an item prior Section 3.2 ofidentification, affirm identifi- to release for installation; however, option is cation prior to release for instal- maintained to knowledgeably install equip-lation. ment lacking full identification providing defi-ciencies are resolved prior to its use; i.e., op-eratiert Such action is recorded in quality contml documents.

42. ANSI N45.2.9 This standard provides general The requirements of this standard will be ap-

, Section 1.1 requirements... ofnuclear power plied to records generated after this standard plants. is implemented. ,

43. ANSI N45.2.9 Definition of Quality Assurance This definition results in unreasonable re-Section 1.4 Records. quirements regarding time of application of the record system. Con Edison willintroduce records into the system as soon as practical after completion of the document.

44. ANSI N45.2.9 he quality assurance records ne types of quality assurance records shall Section 3.2.2 shall be listed in an index. be listed in an index.

He index shallindicate, as a In a d-s with ANSI N45.2.9. peragraph minimum, record retention 3.2.2, the index will indicate the location of times, where the records ere to the records within the record system.

be stored and the location of the records within the storage area. j A-13

. - - , . _ - . . _ - . . .. .-- . . _ . . - . . . - . - - . = - . . - - . ~ . . - . . .- . - - . - . _ - - - . . . - -

TABW A ,

P-1*=v Gade/ ANSI Interpretation /Ahernatefxceptice ,

item No. Std. Reference Rcquirement >

45. ANSI N45.2.9 A specific subnuttalplan shall Purchase orders wirmhfy any particular record Section 4.2 be estabhshed for quality assur- subnnttalim-A as apphcable. Ac- '

ance records by - - 1 = - ceptance of the purchase order by the agpher between the y h and sup- constitutes agreement with the purchaser.

Plier.  ;

46. ANSI N45.2.9 a receipt control system shall We will provide these adnunistrative controls Sections 43,4.4 include: forourNuclear Power Eiw-g, Nuclear l and 53 Power and Nuclear Quality Assurance record storage ares (s) but, where only a snall num-2

1. A records checklist...

2. A record of . records ber of non-permanent records are controlled i I

received. by indivulual orgamzation(s), these auxiliary

' 3. Proceduresforreceiptand adnumstrative controls are unnecessary i inspection of... records.

system shallpermit  ;

assessment _ status....of rec rds. [

.. a method for verifying that records received are in agreement . and are in good condition.

a method ofverifymg I that the records agree with ,

pre-established records checklist."

t l

1 A-14 .

i

TABLE A "

. Renulatory Gu&lANSI Interpretatmn/ Alternate /Exceptmn Item No. Sad. Reference Reautrement

47. ANSI N45.2.9 *Special processed records shall In det s.a .g storage r%.~a., we will 4

Secten 5.4 be storal. as r====aadai by take into account recommendatens of the the manufacturer of these mate- manufacturerif availabic. Normally,these rials." rh. . .J tions willbe followed;however, a blanket commitment is ;.i.y. sci.ble as we must retain the flexibility for final determina-tion ofstorage needs.

i 48 ANSI N45.2.9 "For storage of film. cont:ols See above.

Section 5.6 shall be provided as recom-mended by the manufacturer *

49. ANSI N45.2.9 A full time security system shall For the purpose of this commitment " storage Section 5.5 be established to preclude the area" is interpreted to mean a Con Edison entry ofunauthorized personnel facility which contains records; e.g., the In-into the storage area. This sys- dian Point site,4 Irving Place, etc., and "secu-tem shall guard against larceny rity system" is interpreted to mean security and vandalism. ir.cr.s.- es.

50. ANSI N45.2.9 Requires a " Facility" or dupli- Non-permanent records need not be dupli-Section 5.6 cate records. cated or stored in a

• Facility" but are required to be stored per NFPA Class I record provi-sions.

51. ANSI N45.2.9 " Storage system shall provide In accordance with ANSI N45.2.9, paragraph Section 6.2 for the accurate retrieval ofin- 6.2, the storage system shall provide for the formation without undue delay." accurate retrieval ofinformation.

l t

1 A-15

TABLE A

• Reedannry Gmde/ ANSI Interpretation /AlternateEucptxe

Item Na SM. Reference Reuuum.cr.

.

t

52. Regulatory Guide 1.88 *When NFPA 232-1975 is When a single record storage facility is main-used, Quality Assurance Re . tamed, permanent (lifetime) records will be

cords should be classified as afforded fire protection in accordance with NFPA Class I Records

• NFPA Class I record provisions.

Fire protection in accordance with NFPA i Class 2 provisions shall be prosided for re-cords hgnatai as non-permanent 1

53. ANSI N45.2.9 "An attematiw to. a record Our duplicate records may be stored in sepa-Section 5.6 storage facility... is. duplicate rate rooms distant from one another but within records stored in a separate re- the same building providing their simulta-mote location? neous exposure to hazards is unlikely. - ,

if records are stored in the same building, protection will be provided to assure that si- ,

multaneous exposure to hazards is unlikely.

i

! 54. ANSI N45.2.9 A list shall be generated desig- lock and key controls, duplication of records '

Section 6.2 nating those personnel who in separate locations and other securigt mea-shall have access to the files. sures could obviate the need for access lists.  :

In cases where access lists are utilized, they are not required in all cases to identify spe-cific individuals. - l t

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TABLE A Reaulatory Guxle/ ANSI ~ Interpretahon/ Alternate /Excepison Item No. Std. Reference Reautrement

55. ANSI N45.2.9 "Upon final transfer the owner Except for special cases as agreed to by Con ,

Section 7.2 shall. acknowledge receipt .". Edison and the vendor, acknowledgement or receipt of vendor quality assurance reconis is u - - y.

i' 56. ANSI N45.2.9 Applicable Codes and Stan- Codes and standards used in design are not Appendix A dards used in Design. considered records to be stored and controlled [

per the requirements of N45.2.9. ney will

! be stored and controlled in accordance with

! nonnellibrary practices.

i

57. ANSI N45.2.10 " Quality Assurance Terms and Where terms defmed in ANSI N45.2.10 are f Definitions." also defined in other standards to which Con Edison has referred via commitments to Reg- ,

ulatory Guides in the " Foreword" of the pm-gram description, the definitions in those i other standants shall apply. l

58. ANSI N45.2.10 Definitions of" Certificate of Based upon the guulance of ANSI N45.2.13, Conformance" and " Certificate 10.2, the dermitions of these two terms may i ofCompliance". be usedinterchangeably.

59. Deleted QAPD Rev.13 l [

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A-17 i l

TABLE A -

Regulatory Guide / ANSI Intemretation/Altemate/ Exception Item No. Std. Reference Reauirement

60. ANSI N45.2.11 Program procedures shall cover A variety of experience reports from a number Section 2.2 making experience reports of sources are made available to design per-evailable to cogmzant design sonnel without benefit of written procedures.

personnel.

61. ANSI N45.2.1I " Program procedures shall Procedures describing technical training are Section 2.2 cover necessary training ofper- unnecessary llowever,ourprogramincludes sonnel performing activities procedures for programmatic training of Engi-covered by this standard." neers.

62. ANSI N45.2.11 "The results of the review shall Con Edison documents completion of the de-Section 6.3 be documented .. a number of sign verification activity, but does not neces-basic questions that shall be sarily document that each of the questions addressed .." listed has been considered ia the verification ,

process. The subjects required to be consid- l ered during design review are identified in l procedures.

63. ANSI N45.2.13 Specifies subjects to be evalu- Except in special cases items d_, e., and f. may Section 5.2 ated during bid evaluation. be evaluated prior to submittal to bids.

64. ANSI N45.2.11 " Changes from specified design Changes from specified design inputs and Section 3.1 inputs inchuling the reason for quality standards are identified, approved, the changes shall be identified, documented and controlled. The reasons for approved, documented and con- the changes need not be documented.

trolled."

Section 4.2 " Changes from specified quality standards including reasons for the changes shall be identified, approved, documented and con-trolled."

A-18

TABLE A

• i Renulatory Guide / ANSI Internretation/AlternateFw-an_ina item No. Std. Reference Requirement 1

65. ANSI N101.4 Identifies numerous detailed, When N101.4 is applied, new quality require-specific requirements that must ments will be developed based on its provi-be accomplished in the course sions, but specific r% u-.a4 such as doc-of procurmg, applying and in- umented site wian field demonstrations, spectmg protective coatings. substrate pnmmg, applicator reporting, in-spection reportmg and report forms will bc l considered on ajob-by-job basis. J

66. Regulatory Guide 1.37 Prohibits chemical compounds Use ofcleaning agents contairdng only trace Section C.4 that contain chlorides, fluorides, amounts of these compounds is acceptable.

lead, zinc, copper, sulphur or mentury.

67. Regulatory Guide 1.64 Restriction on design verifica- Considering the various duties of a supersi-Section C.2 tion. sor, both admmistrative and tecluncal, univer-sal prohibition of design verification by the originator's supervisor is inappropriate. De-sign verification is performed by an individ-ual(s) other than the originator if that indisid-ual(s) did not specify a singular design ap-proacti, rule out certain design considerations or establish the design inputs for the particular design aspect being verified.

A-19

!. IABLE A i

Reedatary Ginde/ ANSI Interpretaten/ Alternate /Excepten i Item No, Std. Reference Reauirement t "

j. 68. ANSI N45.2.12 Requirements for Auditing of Thiswandard is pnmanly applicable to audits Quality Assurance Prey _. for conducted of utilities' quality assurance pro-Nuclear Power Plants. grams byinternal auditing u.. -=ei==

Some ofits provisions are ;...y. ia.1 and uns=-y to apply when wh.g vendor  ;

surveillance and vendor evaluatens and in these cases all of the provisions of this stan-dard will not apply.

69. ANSI N45.2.13 "Informatim whidi shall be "Expenence of users" is interpreted to mean [

Section 4.2a evaluated shallinclude 1) Expe. Con Edison or other utility expenence at con- t rience ofusers ofidentical or ventional plants and nuclear plants.  ;

similar products of the prospec- i tive supplier *

70. ANSI N45.2.13 General requirements for Certif- Vendor certifications that do not necessarily  !

Sectim 10.2 icate of Conformance. contain all of the requirements of section 10.2 -

may also be used as a basis for receiving in-spection. t

71. ANSI N45.2.13 "The certificate shall be attested Certificates may be signed at times by com- i

! Section 10.2d to by a person who is responsi- pany president, staff personnel, or Engineer- ,

l ble for this quality assurance ing and not necessarily persons directly re-function and whose function and sponsible for the quality assurance function as l

position are described in the described in the supplier's quality assurance  ;

Purchaser's or Supplier's quality progrant assurance program.*

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TABI.E A -

Regulatory Guide / ANSI Lnterpretation/Altemate/ Exception Item No, Std. Reference Reauirement

72. ANSI N45.2.13 "The certification system,in- The vendors overall quality essurance pro-Section 10.2e ciuding the procedures to be gram is reviewed dtuing the vendor evalua-followed in filling out a certifi- tion activity. Specific procedures arlated to cate and the administrative pro- the details of the certification system, if appli-cedures for review and approval cable, may not necessarily be resiewed.

of the certificates shall be de-scribed in Purchaser's or sup-plier's quality assurance pro-gram."

73. ANSI N45.2.12 "Means shall be provided to Verification of validity of suppliers certifi-Section 10.2f verify the validity ofsuppliers cates is conducted if past quality perfonnance certificates." indicates the need for such verification.

74. ANSI N45.2.23 An audit is a documented activ- The requirements of ANSI N45.2.23 apply to 1.4.3 ity performed in accordance personnel who perfonn audits involving qual-with written procedures or ity assurance elements. They do not apply to checklists to venify, by examina- personnel who perform audits involving com-tion, that applicable elements of pliance with Technical Specifications in areas the quality assurance program such as Auxiliary Electrical Systems, Steam have ben developed, docu- & Power Conversion and Containment Inte-mented, and effectively imple- grated leak Testing etc., nor to personnel who mented in accordance with perform vendor evaluations or surveillance.

specified requirements. An au-dit should not be confused with surveillance orinspection for the sole purpose of process con-trol or product acceptance.

A-21

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TABLE A Regulatory Gade/ ANSI Interpretsuon/ Alternate /Exceptan item No. Std. Reference Reqmrement

75. ANSI N45.2.23 " in addition score one(1)

Also score one (1) credit for a Massers De-2.3.1.1 credit for a masters degreein- gree in m ' =ew =.  ;

engmeermg, physmal sciences,  ;

busmess management, or qual-ity assurance from an accredited institution."

76. ANSI N45.2.23 " .if two (2) or more years of Also score two (2) additional credits for two 2.3.1.2 this evenence have been in (2) or more years reliability expenence. .

quality assurance, score two(2) additionalcredits,or ".

" If two(2)or more years of Also score three (3) additional cmlits for two this experience have beenin (2) or more years nuclear reliability experi-nuclear quality assurance, score ence.

three (3) additional credits, or... "

77. ANSI N45.2.23 " .. Certification ofcompetency Also score two (2) credits for ASQ certifica-2.3.1.3 in engmeermg, science, or qual- tion as a Reliability Engmeer ity assurance specialties issued and approved by a State Agency,or National Profes-sional or Technical Society, score (2) credits."

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• i TABLE A - l Renulatory Gmde/ ANSI JalgtprgyaltonMhstnels@sagt19n Item No. Std Reference Requirement i

7g. ANSI N45.2.23

• Theprospectivelead Audi-

. Separate attestment regardmg ownmumca- ['

2.3.2 tors shall have the capability to tions skill shall not be made. Designation as comrmancate effectively both Lead Auditor shall constitute indication of written and oral. These skills adequate commumcation skill. ,

shall be attested to in writing by the lead Auditor's employer."

79. ANSI N45.2.23

• Prospective Lead Auditors

. Previous on-the-job trammg at prior compa-2.3.3 shall have training to the extent nies, organizations or Con Edison shall an-necessary to assure their compe- stitute credit towards Lead Auditor designa-tence in auditing skills? tion. Contractor personnel used as lead Au- l di: ors shall be certified by their employers whose training piogram shall have been re-viewed and found satisfactory by Con Edison.

4

80. ANSI N45.2.23 "The prospective Lead Auditor Participation in vendor quality assurance pro-2.3.4 shall have participated in a min- gram evaluations, vendor surveillance, site imum offive (5) quality assur- Nuclear Quality Assurance surveillance or ance audits within a penod of ASME *N" stamp nuclear surveys, shall con-time not to exceed three(3) stitute credit towards meeting this require- -

years prior to the dateofqualifi-_ ment.

cation, one audit ofwhich shall be a nuclear quality assurance audit within the year prior to his 3

qualification.

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• e TABLE A -

i-  !

Remilatory Guale/ ANSI Interpretation /AlternateExceptxui l Item No, Std. Reference Requirement '

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81. ANSI N45.2.23

• Theprospectivelead Audi-Audit = n --:-rmay waive the requue-2.3.5 tor shall pass an examination ments of ANSI N45.2.23, paragraph 2.3.4  ;

which shall ev:aluate his com- and 2.3.5 requiring pasticipation in audits and i prehension of and ability to ap- exanunation, when the individual has demon-ply the body ofknowledge iden- strated, by past experience and/or knowledge, r tified in paragraph 2.3.3.* an obvious capability to conduct modits. .

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82. ANSI N45.2.23

• lead Auditors shall maintain Participation in mxior quality assurance pro-3.2 their proficiency through one or gram evaluations, vendor surveillance, site more of the following: regular Nuclear Quali*y Assurance surveillances, or and active participation in the ASME *N" stamp nuclear marveys, shall con- i audit process; review and study stitute credit towards maintenance of profi-  !

, ofcodes, standards, procedures, ciency. Documented annual assessment of instructions, and other docu- auditors is not required for personnel whose i i

ments related to quality assur- ongoing responsibilities include auditing, ven-  !'

ance programs and program dor evaluation, vendor surveillance, or site auditing; participation in train- Nuclear Quality Assurance surveillances.

ing programs. Based on man- ,

agement annual assessment, i I

management may extend the .

qualification, required training, or require requalification. s i These evaluations shall be doc-  !

umented.' '

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___ _ _ _ _ _______z_ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ __. . . . . _ _ . . . . _ - . . - - _ _

TABLE A

• Renulatory Guide / ANSI Interpretation /AlternateExecotson  ;

Item No. Std. Reference Reauirement

83. ANSI N45.2.23 " lead Auditors who fail to Management shall deterrmce the basis for 33 maintain their proficiency for a r==likation on a case-by-case basis, and penod of two years or more may elect to waive retrauung, reexanunation ,

shall require requalification. and audit participation based upon a review of Requalification shallinclude the individual's knowledge and capability, retrainingin accordance with prior performance and recent experience the requirements ofparagraph .

2.33, reexamination accordance with paragraph 23.5, and par-  ;

ticipation as an Auditorin at least one nuclear quality a sur-ance audit."

L 1

A-25

3 TABLEB REGUIATORY i

GUIDE /

ITEM ANSI STD.

NQ, REERENCE GU:DEUNC Ikruusu.iATION / ALTERNATE i

ANSIN45.2.1.1973

Cleaning of MukiSystems "

" This "should" is beyond the scope of this standard as indicated .

1. "Such items should receive their required level of 3.'I by the last sentence on the page.

cleanliness...". l

2. Under " NOTE", " localized rusting...should be Inboratory types tests on localized rusting will be conducted 3~"2- when the need for such tests is determined by Nuclear Power evaluated metallurgically." ,

Engineering or Nuclear Quality Assurance. 2 Section The special fabrication and inspection requirements will be

3. The forth "should" requires fabrication of a 5

complete unit where inspection can be blocked.

The fifth "should" requires inspection of the complied with as required by Nuclear Power Engineering or Nuclear Quality Assurance.

l[

2!

completed unit immediately prior to closing  ;

access points. i Section The sixth "should" requires cleaning of surfaces The degree of surface cleanliness and the frequency of cleaning 4.

before proceeding to the next installation or will be as' determined by Nuclear Power Engineering or Nuclear

~

l, ,

construction step. Quality Assurance. 2l Section Organic acids will be used only as permitted by Nuclear Power

5. The seventh "should" prohibits the use of mineral l 5

or organic acids on stainless steel Engineering. After their use, however, all residual traces of the 2' acid will be removed.

B-1

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TABLEB REIGUIATORY -l GUIDE /

h ANSI Sm.

M REn:RENCE GUIDEUNE INTERPRETATION / ALTERNATE ANSI N45.2.1,1973 [

" Cleaning of nuid Systems - i Section When the need for removal of rust is deternuned, it shall be

6. eighth "should" requires removal of local 5

rusting from corrosion resistant alloys by removed by mechanical means. l mechanical means.

Section We interpret system to mean the primary coolant system.

7. se nd "should" requires personnel entering 6

the system to wear clean outer clothing and shoe Covers.

""I " loose tools will be controlled as specified by procedure or by

. h first "should" requires attachment of loose .

tools "to either the workman or the exterior of the Nuclear Quality Assurance. Precautionary measures such as i system with a lanyard." barriers between work areas, and tool check-in and check-out controls may obviate the need for attachment Sub When alkaline cleaning is performed, it will be accomplished in

9. first "should" specifies a method for

~2~2 determining the effectiveness of alkaline cleaning. accordance with the requirements of Nuclear Pbwer Engineering. l3 2!

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1

TABLEB REGULA10RY GUIDE /

IIEM ANSI STD.

Na REFERENCE GUIDELINE Ikn.rwrufATION / ALTERNATE ANSIN452 l.1973

" Cleaning of ,

FlukiSystems "

Su

10. The second "should" requires flushing of pockets 2

and dead legs.

The third "should" requires that attention be When alkaline cleaning is performed, it will be accomplished in given to removal of solution. accordance with the requirements of Nuclear Pbwer Engineering. l The forth "should" requires system to be sealed. 2

11. The first "should" requires flushing to remove 3

chelating agents.

The second "should" requires flushing of pockets When chelate cleaning is performed, it will be accomplished in and deadlegs. acconiance with the requirements of NuclearIbwer Engineering. l The third "should" requires that attention be given 2' to removalof solution.

The forth "should" requires system to be sealed.

l ANSI N45.2.2.

[ " Packaging, Shipping.

j Receiving. i Storage, and H<matirvy - ~.

l

12. Subsection Requires location and stacking limits to be Consistent with the provisions of ANSI N45.2.2,1972 Appendir "A",

4.3.6 specified on crates and boxes. A.3.9.6 (e), such requirements will be specified, "as appropriate".

B-3 ,

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TABLE B REGULATORY GUIDE /

h ANSI STD.

NQ, REstENCE GUIDEUNE IkruuttETA110N / ALTERNATE ANSI N452.2

" Pockaging. Shipping. '

Receiving. Storage. and

" i Hwnm- .

Appendix A, A.3.5.2.

13. (1),(a) Limits halogen and sulphur content of tape. Nuclear Power Engineering may allow the use of tapes containing l i greater amounts of halogen after appropriate evaluation. -2 i

ANSI N45.2.9.1974

" Becords "

14. Subsection The second "should" requires compatibility Special compatibility requirements of organization's records inder 3.2.2 between the organization's system and the system will be identified, where necessary, in procurement owner's system. documents.

15. Subsection The first "should" requires that records shall be See Table A Page A-16, #52.

5.6 protected by NFPA Class A four hour minimum rated facility.

16. Subsection Requires that non-permanent records be retained Procedures will identify retention times of non-permanent records.

7.3 as specified in Appendix A.

17. Regulatory Guide Endorses the recommendations and requirements See Table A Page A-13, #40.

1.58. Revision 1, of ANSI N45.2.6,1978.

9.80 Nminationand Testing Personnel" B-4 t

4 TABLEB REGUWORY GUIDE /

ITEM ANSI STD.

No. BEEIRENCE GUIDEI.INE INTuustE FATION / ALTERNATE ,

t

18. ANSI N45.2.5,1974 The requalification procedure for cadweld splices

" . Concrete... should be identical to the original qualification The contentEngineering.

NuclearPower of the requalification procedure shall be

, Structural procedure. 2; Steek."  ;

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( ATI'ACHMENTII Summary of Changes to QAPD Pages The QAPD pages that were changed are indicated by change bars in the right margin on the revised pages. Underneath each change bar is a number. The number is a reference to the explanation for each page change as provided below.

CHANGE NUMBER EXPLANATION 1 The paragraphs have been revised editorially for clarity. In addition, they have been revised to indicate that environmentally qualified equipment is now maintained in an electronic data base.

2 The functions of Central Engineering with regard to providing engineering support for Indian Point 2 have been combined into one centralized group called Nuclear Power Engineering.

3 Power Generation Maintenance and Construction have been combined into one organization called Maintenance and Construction.

4 Reference to a corporate instruction which describes the Quality Assurance Program has been deleted. The Corporate Instruction contained informa-tion and requirements similar to this Quality Assurance Program Descrip-tion (QAPD). This OAPD will serve in lieu of the current Corporate Instruction as the prime document describing the QA Program. Implement-ing procedures will also describe elements of the QA Program. This l change is being made so as avoid inefficiencies and costs associated with l

control and distribution of two separate documents which contain similar I and duplicative information.

5 The position of the Executive Vice President, Central Operations has been ,

changed to Senior Vice President, without change in function. l 6 The title of General Manager, Nuclear Power Generation has been changed to Plant Manager, without change in function.

7 The function of Security has been transferred from the previous position of General Manager, Technical Services to a Department Manager, Site Services.

1

8 The title of Director Nuclear Quality. Assurance has been changed to Department Manager, without change in function.

9 The audit function of the NQA Manager of Audits and Programs has been transferred and combined with the function of NQA Manager of Surveillences.

10 The functions of the NQA Manager, Procurement QA and Manager NQC have been combined into one group under the NQA Manager Procurement QA/QC, 11 The title of Plant Engineer has been changed to Department Manager, System Engineering and Analysis, without change in function.

12 The functions of both Operations training and Staff training have been combined under a Department Manager, Nuclear Training.

13 The title of the Nuclear Training Manager, Nuclear Power has been changed to Department Manager, Nuclear Training, with no change in functions.

14 Sentence has been revised to clarify that the Department Manager NQA .

has responsibility for overall QA activities and is not limited to Site Activities only.

15 Deleted title of Director NQA. This editorial change results from changes of titles within Nuclear Power. All key top level personnel are " Managers".

16 (Not used) 17 The functions of Test and Performance have been transferred from Technical Services to System Engineering and Analysis.

18 The Projects and Planning group has been decentralized. Its functions and personnel have been absorbed within its parent organization: Mainte-nonce. l 19 The overall responsibility for the inservice inspection program, including records, has been transferred to NQA. Test and Performance continues to retain IST responsibilities.

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i 20 Nuclear Projects - Project Support personnel have been granted authoriza-tion to transfer inspection status indicators in addition to material procurement, NQA, and Nuclear Projects QC Coordinators / Planners.

21 'Ihe responsibility for review of equipment malfunctions have been clarified to reflect that:

I a.) Significant plant events are reviewed by SNSC; b.) Systematic analysis of equipment malfunctions are accom-plished by personnelin System Engineering and Analysis; c.) The results of these analyses are reviewed by a high level committee, which includes Vice President, Nuclear Power and Department Manager, Nuclear Quality Assurance; 22 Item 59 in Table A of Interpretations / Alternate / Exception was deleted. It -

was determined that the definition of the term " modification" in ANSI N45.2.10 is acceptable and therefore an alternate term as previously indicated in item 59 is unnecessary.

23 The sentence which stated that SAO's and AD's shall be reviewed biennially was deleted since it duplicated information in the succeeding paragraph.

24 The need for Department Managers and section Managers to specifically report on the results of the reviews of Station Administrative Orders and Administrative Directives to their respective management has been deleted. Audits / surveillances of the review of SAO's and AD's will evaluate the review process.

25 The need to assure that Administrative Directives have been biennially reviewed has been assigned to the more appropriate management level of Section Managers in lieu of Department Managers as AD's typically are applicable to sections.

26 Various Manager titles have been changed to Department Manager or -

Section Manager without change in function.

GW/see 3

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A'ITACHMENTIII  !

Summary of Changes to Organization Charts A and B )

Charts A and B have been revised to indicate the latest organizational structure.

Changes in these charts are of two types: )

i

1. Those that relate to quality assurance / quality control activities described in the Quality Assurance Program Description (QAPD).

i

2. Those that do not relate to quality assurance / quality control activities described in the QAPD.

The changes that relate to qa / qc activities described in the QAPD are explained in detail. The changes that do not relate to qa / qc activities will be generally described. l The following changes which relate to qa / qc activities have been made to Chart A:

1. The organizational structure of Nuclear Power Engineering has been substituted for the previous organizational structure of Central Engineering. Nuclear Power Engineedng centralizes all of the engineering support for Indian Point 2 which was previously provided by separate groups within Central Engineering.

2.

Power Generation Maintenance has been combined with Construction into one organization called Maintenance and Construction.

3. The functions of the Executive Vice President, Central Operations have been assigned to a Senior Vice President, Central Operations.

4. The details of the Nuclear Power organization have been deleted from Chart A and a reference to Chart B for those details has been added.

l

5. The inspection and quality control function within the Shop Operations group of Maintenance and Construction now reports to the Maintenance Engineering group in lieu of the Maintenance Planning Manager.

6. The functions of Vice President, Purchasing and Vice President, Transportation and Stores were combined.

1

The following changes to Chart A do not relate to qa / qc activities described in the QAPD:

1. The functions of the Controller and the Safety and Training Manager in Power Generation Maintenance have been deleted as extraneous information.

2. The title of the Mechanical Repair Shop Manager in Shop Operations of 3

Maintenance and Construction has been deleted. Functions have been distributed to the Machine Shop and Motor and Pump Shop groups.

3. The function of General Manager, Electrical Transmission Maintenance and Construction which previously was depicted in the Construction Department has i

been deleted as extraneous information.

< 4. The titles of Superintendent, Cortlandt Warehouse and the General Operating Supervisor, Astoria Warehouse have been revised to Operating Supervisor and Manager respectively. In addition, their reporting chain to the Executive Vice President, Central Senrices has been revised.

5. The dotted lines which depicted the locations of organizations at Indian Point and 1

Van Nest have been deleted as extraneous information.

The following changes which do relate to ga / qc activities have been made to Chart B:

1. The title of Manager, Administrative Senrices was revised to Department Manager, Site Services and the functions of Site Protection, Configuration Management and Computer Applications have been assigned to the Manager, Site Services.

2. The Department Manager, Nuclear Training now reports to the Vice President, Nuclear Power.

3. The title of Manager, Nuclear Safety and Licensing was changed to Department Manager, without change in function.

~

4. The QA Audit function has been combined with the QA Surveillance function under a Section Manager.

5. The function of Quality Control and Procurement QA have been combined under a Section Manager.

6. The title of Director, Nuclear Quality Assurance has been changed to Department Manager, without change in function.

2 1

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7. The title of General Manager, Technical Services has been changed to Depart-ment Manager, System Engineering and Analysis.

1

8. Various other Manager titles have been changed to Department Manager or

, Section Head, without change in function.

9. The title of General Manager, Nuclear Power Generation has been changed to Plant Manager, without change in function.

- 10. The dotted lines which depicted the location of two NOA Sections at Corporate Headquarters have been deleted as extraneous information.

11. The title of " Design Basis Project Manager" has been deleted. The design basis l

~

functions have been transferred to the System Engineering and Analysis 1 Department.

12. System Engineering and Engineering Analysis Section Managers have been added to the System Engineering and Analysis Department.

13. The functions of the Technical Consultant and Radiation Assessor are now shown as reporting to the VP Nuclear Power via dotted lines in lieu of solid to indicate that they are responsible for their technical activities to the VP Nuclear Power, however, they may report to other managers for administrative purposes.

GW/see 3