ML20096H068

Rev 29 to Amend 5 to Updated Topical Rept VEP-1-5A, Operational QA Program

ML20096H068
Person / Time
Site:	North Anna
Issue date:	01/17/1996
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20096H040	List: ML20096H037 ML20096H068
References
VEP-1-5A-A05, VEP-1-5A-A5, NUDOCS 9601260250
Download: ML20096H068 (92)

Text

{{#Wiki_filter:.___ _____ __-______- _ - _ - - _ REVISION 29 1/96 NAPS UFSAR VIRGINIA ELECTRIC AND POWER COMPANY OPERATIONAL QUALITY ASSURANCE PROGRAM TOPICAL REPORT VE P-1 -5 A (UPDATED) Amendment Five June,1986 (Updated 1/96) l 17.2 OhOb338 ADO K PDR

REVISION 29 1/96 NAPS UFSAR I TABLE OF CONTENTS Section No. Iille Page Table of Contents 17.2-i List of Figures 17-2-iii List of Tables 17.2-iii t List of Amendments 17.2-iv Abstract 17.2-v 17.2 Quality Assurance During the Operations Phase 17.2-1 ~ 17.2.0 General 17.2-1 .1 Topical Report 17.2-1 .2 Quality Assurance Standards and Guides 17.2-1 17.2.1 Organization 17.2-3 1 17.2.1.1 General Description 17.2-3 l j .2 Nuclear Management 17.2-4 .3 Organization 17.2-11 l 4 17.2.2 Quality Assurance Program 17.2-12 l f 17.2.2.1 General Description 17.2-12 l .2 Quality Assurance Program 17.2-13 l 4 .3 Identification of Structures, Systems, and Components 17.2-14 l .4 ' Periodic Review of the Operational Quality Assurance 17.2-14 l Program .5 Qualification of Nuclear Oversight Personnel 17.2-14 l .6 Qualification of Other Support Personnel 17.2-15 l .7 Certification of Quality Assurance Department 17.2-15 l Personnel .8 Certification of Other Support Personnel 17.2-15 l 17.2-1 June,1986

REvaSION 29 1/96 NAPS UFSAR Section No. Iit[g Page 17.2.3 Design Control 17.2-16 l 17.2.4 Procurement Document Control 17.2-18 l 17.2.5 Instructions, Procedures, and Drawings 17.2-19 l 17.2.6 Docun ent Control 17.2-20 l 17.2.7 Control of Purchased Material, Equipment, and 17.2-21 ' l Services 4 l 17.2.8 Identification and Control of Materials, Parts, and 17.2-23 l Components 17.2.9 Control of Special Process 17.2-24 l 17.2.10 Inspection 17.2-25 l l 1 17.2.11 Test Control 17.2-27 l 1 17.2.12 Control of Measuring and Test Equipment 17.2-28 l 17.2.13 Handling, Storage, and Shipping 17.2-29 l 17.2.14 Inspection, Test, and Operating Status 17.2-30 l ) 17.2.15 Nonconforming Materials, Parts, and Components 17.2-31 l 17.2.16 Corrective Action 17.2-33 l j .1 Authority to Stop Work 17.2-34 l .2 Imposition of "Stop Work" 17.2-34 l 17.2.17 Quality Assurance Records 17.2-36 l 17.2.18 Audits 17.2-37 l 4 1 7. 2 -11 June,1986 i

REVISION 29 1/96 NAPS UFSAR LIST OF FIGURES (APPENDIX A) Fiaure No, Iille Page i 17.2.1-1 Nuclear Organization 17.2-40 l l 17.2.1-2 Nuclear Station Organization 17.2-41 l 1 4 LIST OF TABLES (APPENDIX B) Table No. Iilla Page 17.2.0 Conformance of the Company's Operational 17.2-42 l Quality Assurance Program to NRC Regulatory Guides and ANSI Standards 17.2.1 Relationship of the Company's Operational 17.2-92 l Ouality Assurance Program to Appendix B, 10 CFR 50 l 1 b 17.2-iii June,1986

REVISION 29 1/96 NAPS UFSAR . LIST OF AMENDMENTS l . Amendment No. Amendment Date Original 07-01-75 One 12-30-75 i i 4 Two 09-27-76 Three 03-01-77 4. a Four 10-01-82 Four (Updated) 08-30-85 i Five 06-30-86 l Five (Updated) 03-23-87 I Five (Updated) 06-21-88 Five (Updated) 06-21-89 i Five (Updated) 06-21-90 i Five (Updated) 05-28-91 Five (Updated) 06/16/92 Five (Updated) 02-28-94 l 1 i l i 17.2-iv June,1986 1 1 a

REVISION 29 1/96 NAPS UFSAR ) ABSTRACT This topical report describes Virginia Electric and Power Company's, hereafter referred to as the Company, quality assurance program for the operational phase of its nuclear power stations. The report is organized as, distributed, and used for Chapter 17, part 2 - Quality Assurance (Operations) - of the Company's Updated Final Safety Analysis Reports. The Company quality assurance program conforms to applicable regulatory requirements such as 10 CFR 50, Appendix B and to approved industry standards endorsed therein as clarified within this topical report. Included is a point-by-point comparison of the program with the 18 criteria of 10 CFR 50, Appendix B. This topical report is intended to be a comprehensive up-to-date description of the Company's Operational Quality Assurance Program for nuclear power generating stations. The Operational Quality Assurance Program is defined as those managerial and administrative policies and controls used to assure the safe and reliable operation of the nuclear facilities. These include all those planned and systematic actions necessary to provide adequate confidence to management and regulatory agencies that structures, systems, and components will perform satisfactorily in service. The Operational Quality Assurance Program encompasses policies, directives, instructions, training, and procedures which ensure compliance with reguations, Codes, standards, licenses, and other Company commitments. As such, this topical report, in conjunction with the applicable operating license, provides the foundation for operating the nuclear facilities in a manner which ensures the safety of the public, employees, and plant equipment. The policies are further defined through the Nuclear Operating Department Standards (NODS), the applicable Safety Analysis Report (SAR), Nuclear Design Control Manual (NDCM), and each facility's emergency plan, physical security plan, radiological protection plan, and fire protection plan. Administrative and implementing procedures govem the various aspects of day-to-day operation of the nuclear facilities. The Company's Operational Quality Assurance Program Topical Report is referred to by several generic titles both within this document and within other administrative controls for each nuclear facility. These include Chapter 17.2 of the UFSAR, the [ Company's] quality assurance program, the Operational Quality Assurance Program (upper and lower cased letters), the OA Topical Report, VEP 1-5A, Quality Assurance Program - Operational Phase, etc. These are used interchangeably to refer to this document which represents Management's philosophy and methodologies for complying with the 18 criteria of 10 CFR 50, Appendix B. 17.2-v June,1986

.= REVISION 29 1/96 NA@S UCSAR 1 \\ 4 17.2-QUALITY ASSURANCE DURING THE OPERATIONS PHASE j 1 i 17.2.0 General It is the policy of the Company to establish and maintain a formal quality 3 assurance program for the operational phase of nuclear power generating stations. This program is described by written policies, standards, and procedures. The J application of this program accomplishes two impodant objectives: (1) to provide d orderly, uniform administrative and managerial procedures to assure safe, reliable, j and economic operation of nuclear power stations and (2) to assure compliance with j regulations promulgated by the US. Nuclear Regulatory Commission. l j 17.2.0.1 Topical Report i i This topical report is written in the format of a Safety Analysis Report (SAR) Chapter 17, part 2, " Quality Assurance During the Operations Phase", in accordance with the NRC's " Standard Format and Content of Safety Analysis Reports for Nuclear i Power Plants" (Nov.1975) and subsequent NRC guidelines. The quality assurance j program described herein is applicable to all Company nuclear power stations as i referenced by Chapter 17 of the stations' UFSARs. Subsequent changes to the Company's Operational Quality Assurance i Program will be incorporated as applicable in this topical report. The topical report is { intended to be a comprehensive description of the Company's Operational Quality ' Assurance Program for nuclear power stations. 17.2.0.2 Ouality Assurance Standards and Guides The Company Operational Quality Assurance Program conforms to Appendix B of 10 CFR 50 as amended and complies with the regulatory positions of the Regulatory Guides indicated in table 17.2.0, as modified or clarified in that table. l i j i [ 17.2-1 June,1986

REVISION 29. 1/96 NAPS OFSAR i i TABLE 17.2.0 i Conformance of the Comoanv's Ooerational Quality Assurance Proaram i To NRC Reaulatorv Guides and ANSI Standards t l The ANSI standards, and other documents (i.e., other standards, codes, regulations, or appendices) that are required to be included as a part of this quality-assurance program are either identified in Table'17.2.0 or they are described her.ein. l Although this table includes references to ANSI Standards and Regulatory Guides that-are required to be a part of this quality assurance program, the table is not intended to l be a complete list of all NRC Regulatory Guides (etc.) to which the Company is committed. The specific applicability or acceptabi!ity of these listed standards, codes, l regulations, or appendices is either covered in this program or such documents are not considered as quality assurance program requirements; although they may be a used as guidance. When sections of ANSI Standards and other documents are 4 - referenced within this program, it is understood that the Company will comply with the referenced sections as clarified in Table 17.2.0. e 1 GENERIC STATEMENTS WITH REGARDS TO TABLE 17.2.0 AND THE OPERATIONAL QUALITY ASSURANCE PROGBAM i 4 For operations phase mainten6nce and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, the Company shall control these activities under this Operational Quality i Assurance Program. Designated modifications may be controlled under a contractor's j Quality Assurance Program which has been approved by the Company's Quality Assurance Program. When this Operational Quality Assurance Program or an approved contractor's Quality Assurance Program is used, the Company shall comply with the Reaulatorv Position established in the guides listed herein in that quality a assurance programmatic / administrative requirements included therein (subject to the clarification in this table) shall apply to these maintenance and modification activities even though such requirements may not have been'in effect originally. Maintenance or modifications which may affect the function of safety related structures, systems, or i components shall be performed in a manner at least equivalent to that specified in i original des'ign bases and requirements, materials specifications, and inspection requirements. A suitable level of confidence in structures, systems, or components on i - which maintenance or modifications have been performed shall be attained by appropriate inspection and performance testing. i DefinitlQng in the referenced standards in this table which are not included in ANSI N45.2.10 will be used as clarified in the Company's commitment to Regulatory Guide 1.74, 1 4 4 17.2-2 June,1986

~. - - - ] REVISIOR 29 : ' 1/96 NAPS UFSAR i 17.2.1 ORGANIZATION + 4 6 1 17.2.1.1 General Description i A. Nuclear Oraanization j Nuclear is divided into four distinct groups; Nuclear Operations, Nuclear j Engineering and Services, Nuclear Security and Administrative Services, and Nuclear Oversight. Nuclear Operations, Nuclear Engineering and Services, and Nuclear Security and Administrative Services are responsible for licensing, operation, and support of the i nuclear power stations. Nuclear Oversight has the responsibility to assure compliance with the Operational Quality Assurance Program. 8. Nuclear Ooerations i Nuclear Operations is a line organization responsible for operation and i j maintenance of the Surry and North Anna Nuclear Power Stations. This i organization is comprised of various departments, including Operations, Mr.intenance, Outage & Planning, Nuclear Licensing and Operations i l Support, Station Nuclear Safety. Station Emergency Planning, Station Licensing, Station Procedures, Radiological Protection, Chemistry, Safety i & Loss Prevention, Station Records Management, and Nuclear Site i Services (maintenance support, modifications, and plant improvement i' projects). i l C. Nuclear Enaineerina and Services Nuclear Engineering and Services is responsible for support of the nuclear i: organization through providing engineering services, financial and business services, personnel training, and emergency planning. The engineering departments are the design authorities for the Nuclear Organization and provide design and operational engineering support to the n uclear stations. The Financial and Business Services Department provides support through procurement, materials management, document control, and records management activities. The Nuclear Training i Department develops and administers training to Nuclear Operations, j Nuclear Engineering and Services, Nuclear Security and Adminfstrative i Services, and Nuclear Oversight personnel. Nucle ~ r Emergency Planning a i schedules and coordinates emergency training exercises with federal, i state, and local agencies and works with intemal groups to ensure that [ emergency plans meet regulatory requirements and commitments, j D. Nuclear Securitv and Administrative Services j The Nuclear Security and Administrative Services / -up is responsible for support functions associated with Nuclear Piar. curity, Personnel i Administration, Fitness For Duty, and Nuclear Projo l 1 17.2-3 f ..-..-,-,.nn ~

REVISION 29 1/96 NAPS UFSAR E. Nuclear Oversight Nuclear Oversight is responsible for independently planning and performing activities to verify the development and effective implementation of nuclear management's quality assurance programs for engineering, procurement, construction, modification, maintenance, and operation activities associated with the Nuclear Stations. 17.2.1.2 Nuclear Management A. Senior Vice President - Nuclear The Senior Vice President - Nuclear has corporate responsibility for and directs the planning and development of the Nuclear Ornanization staff, organization resources, and nuclear power generation.

1. Management Safety Review Committee NOi10) i The MSRC is the body which performs the offsite safety review function. It reports to the Senior Vice President - Nuclear and provides an independent review in the areas of station operations, maintenance, reactivity management, engineering, chemistry & radiochemistry, radiological safety, quality assurance practices, and emergency preparedness. The Technical Specifications of each station further define the function, composition, alternates, consultants, meeting frequency, quorum, reviews, audits, authority and records of this committee.

One of the functions of the MSRC is to oversee the Safety Evaluation Program to ensure that it is effective in identifying unreviewed safety questions. The MSRC accomplishes this function by reviewing a sample of approved safety evaluations to ensure that unreviewed safety questio.ns are being properly identified and by concucting periodic assessrpents of the Safety Evaluation Program. The review of a sample of safety evaluations uses a graded and safety significant approach to select safety evaluations for review. All safety evaluations are screened upon receipt, and the fcllowing criteria are used to select a sample for MSRC review: Safety evaluations for certain types of activities will receive a 100% review by the MSRC. These include, for example, safety evaluations for Technical Specification changes, justifications for continued operation and special tests. i All safety evaluations for changes that have a high potential for impacting nuclear safety or regulatory requirements will be reviewed by the MSRC. I 17.2 4

. ~..-,_ -_-- l REVISION 29 1/96 NAPS UFSAR l l l A representative sample of safety evaluations will be reviewed from the remaining safety evaluations prepared. These safety evaluatiores will be selected to ensure a representative sample of i safety evaluations of each type of activity has been reviewed in an amount consistent with program objectives. Provisions are also in place to adjust the sample sizes of the safety evaluations based on MSRC and assessment findings. f

2. Nuclear Oversicht Board (NOB)

The NOB functions to provide independent review and oversight of } nuclear activities at the senior management level and in an advisory capacity to the Senior Vice President - Nuclear. The NOB reviews nuclear management practices, policy issues, regulatoy and performance trends and organizational factors relating to nuclear activities, and provides program oversight through management reports, document reviews, group discussions, and individual experience. Membership consists of senior nuclear utility executives and other members appointed on the basis of industry knowledge and/or expertise. j B. Vice President-Nuclear Ooerations The Vice President - Nuclear Operations is the Corporate individual l responsible to the Senior Vice President - Nuclear for the operation of the i nuclear power stations. He has overall responsibility for implementing the quality assurance program for the operational phase of the nuclear power i stations. J

1. Station Manaaer Responsible to the Vice President - Nuclear Operations for the overall j

safe and efficient operation of the station, and for the implementation j of quality assurance requirements in the areas specified by the i operational quality assurance program. The Station Manager has i supervisory control over all Virginia Electric and Power Company ? personnel within the station organization and administrative control over all other Company and non-Company individuals within the nuclear site's boundary. The Station Manager is the local representative of Company management and is empowered to implement all Company policy with regard to operations of the facility, support of Company public relations policy, and employee relations policies. The Station Manager is also responsible for coordinating station functions with offsite (Company and non-Company) agencies and services. In the absence of the Station Manager, these duties will be assumed by the Assistant Station Manager (Operations & Maintenance) unless otherwise designated in writing. 17.2-5

REVISION 29 1/96 MPS UFSAR I p i l

a. Station Nuclear Safety and Ooeratina Committee l

{ Serves in an advisory capacity to the Station Manager. The- + technical specifications of each station define the responsibilities of l this committee. The Station Nuclear Safety and Operating Committee is separate from operational quality assurance activities in that its authority and responsibilities are not established by the t Operational Quality Assurance Program. However, since the prime responsibility of this committee is to provide a continuing review of the operational and safety aspects of the station, it does perform a l quality assurance function. i e

b. Assistant Station Mananar (Ooerations and Maintenance) l Responsible to the Station Manager for directing and coordinating all aspects of dej-to-day station operations and maintenance. The Assistant Station Manager Operations and Maintenance (O&M) is j

the Vice Chairman of the Station Nuclear Safety and Operating i Committee (SNSOC) and is responsible for planning and coordination of unit outages. In the absence of the Assistant i Station Manager (O&M), the Station Manager assumes the duties of the Assistant Station Manager (O&M). In the absence of both the Station Manager and the Assistant Station Manager (O&M), these duties will be assumed by the Superintendent - Operations unless otherwise designated in writing. b.1 Suoerintendent-Operations l The Superintendent - Operations reports directly to the Assistant Station Manager (O&M) and is responsible for directing and coordinating station oparations and fuel handling activities in accordance with approved plans, programs, licenses, Technical Specifications, and good operating practices. He is responsible for identifying deviations from the Technical Specifications and Facility Operating License (FOL) and for reporting any unusual occurrences in connection with station operations to the Assistant Station Manager (O&M or NS&L). The Superiritendent - Operations is also responsible for: 1) development and implementation of uniform operating policies and procedures,2) implementation of on the-job training for Operations personnel,3) ensuring that each shift is adequately staffed and sufficient back-up personnel are available, 4) ensuring that all required operating data is properly recorded and retained as appropriate, and'5) being a participating member of the SNSOC. 17.2-6 e m -Tf+ ery+ -= s.m,mwr r -+-r w -w-- -u

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a b.1.1 Suoervisor Shift Ooerations l l The Supervisor Shift Operations reports to the Superintendent - Operations and provides direct supervision to the Shift Supervisors, operational input to the SNSOC, and identifies any deviations from the j Technical Specifications or any unusual events. The Supervisor Shift Operations must possess a valid Senior Reactor Operator (SRO) license, and may only be relieved by an individual who possesses a valid SRO license. This position fulfills the function-of the " operations manager" as described in ANS 3.1 (12/79 1 Draft). I b.2 Suoerintendent Maintenance l l The Superintendent Maintenance reports directly to the Assistant Station Manager (O&M) and is responsible for I directing and coordinating the maintenance activities at the station. He is responsible for: 1) ensuring that station facilities and equipment are maintained in accordance with regulatory requirements and station procedures,2) the development and 5 implementation of uniform policies and procedures for i i installation, maintenance, and repair of station equipment and { systems, 3) ensuring maintenance tasks will be performed in a timely and efficient manner, and 4) participating as a member of l the SNSOC. t b.3 Suoerintendent Outaae & Plannina The Superintendent Outage & Planning reports directly to the Assistant Station Manager (O&M). He is responsible for the overall planning and scheduling of maintenance and maintenance-related work activities such that safe and reliable plant operation is optimized. The Superintendent Outa0e & Planning is responsible for detailed maintenance planning to support scheduled outages being completed as needed. He is also responsible for the execution of outages, maintenance of t plant equipment history, and monitoring of station performance. I 17.2-7 4 t .,,c., -. y -m .c

REVISION 29 1/96 NAPS UFSAR 4 j

c. Assistant Station Manaaer (Nuclear Safety and Licensina) 4 Responsible to the Station Manager for directing and coordinating nuclear safety issues at the station. The Assistant Station Manager j

(NS&L) is the Chairman of the Station Nuclear Safety and Operating Committee (SNSOC) and conducts periodic meetings to ensure compliance with station technical specifications, manage l l licensing activities within the station, interface with Corporate j 1 management on operating experience and licensing issues, manage station procedures, administer the station environmental compliance program, and manage station emergency plan activities. The Assistant Station' Manager NS&L)is independent of cost and scheduling concerns assoc (iated with operations, 3 maintenance, and modification activities. He is is responsible for maintaining information on industry operating experience, being i cognizant of licensing and regulatory issues, administering the Commitment Tracking System (CTS), administering the nuclear safety assessment and Shift Technical Advisor (STA) programs, administering the Station Emergency Plan, ensuring adequate training for station employees regarding emergency preparedness, i and coordinates the station quality inspection program.

d. Suoerintendent Site Services Responsible to the Station Manager for directing all aspects of assigned projects including coordination of activities with station management, engineering, and construction. Support activities such as accounting, procurement planning, scheduling and cost control are also included in these responsibilities.

i

e. Suoerintendent Radiolooical Protection Responsible to the Station. Manager for administering the Radiological Protection Program at the station. Responsibilities include:

1) monitor the radiological effluent programs and i

personnel radiation protection programs,2) maintain records of j radiological exposures for all persons working or visiting within the ) station's restricted area,3) ensure regular surveys of the station,4) maintain records of background radiation levels, and 5) check all radioactive material releases and shipments from station and maintain appropriate records. The Radiological Protection group is responsible for determining the radiation levels of all work areas, and posting, as needed, areas where sources of radiation exist. Additionally, the Superintendent Radiological Protection is also responsible for managing the primary and secondary plant j chemistry programs and for coordinating activities related to non-radiological environmental protection. i i 17.2-8 I t-v y m

REVISION 29 1/96 NAPS UFSAR i 4 The Superintendent Radiological Protection directs the activities of his group to minimize the exposure of station personnel to excessive doses of radiation and to prevent the spread of i radioactive contamination. All activities in these areas are l coordinated with other station groupe to ensure full awareness of l problems through implementation of the station ALARA program. I The Superintendent Radiological Protection also participates #as a i member of the SNSOC. f. Suoervisor Administrative Services The Supenfisor Administrative Services reports to the Gration + Manager and is responsible for managing the activities related to administrative tasks for smooth station operation. These tasks 1 include: planning and budget, station records management, station safety and loss prevention, fire protection, and medical assistance.

g. Station Suoervisorv Personnel l

Responsible directly to the Station Manager through their respective superintendents, for implementing the operational quality j assurance program requirements applicable to their specific areas j of responsibility.

h. Station Staff It is the responsibility of each member of the station staff to adhere j

to the provisions contained in the operational quality assurance program when performing their work tasks to acsure quality workmanship. Personnel with unescorted access status shall receive training (Nuclear Employee Training) in the use of and i adherence to the operational quality assurance program. f C. Vice President - Nuclear Enoineerina and Services l Responsible to the Senior Vice President - Nuclear and has corporate responsibility for long-term nuclear operations support activities related to engineering, finance and business, personnel training, and emergency i planning. As such, he has responsibility for the system level implementation of the requirements established by the Operational j Quality Assurance Program for the nuclear power stations. l i l 17.2-9 i-i i

REVISION 29 1/96 NAPS UNSAR D. Manaaer - Nuclear Security and Administrative Services The Manager - Nuclear Security and Administrative Services is responsible to the Senior Vice President - Nuclear for Nuclear Plant Security, Personnel / Human Resources, Nuclear Plant Access Programs, l and Fitness for Duty. Other responsibilities include: providing staff support to the Senior Vice President - Nuclear and coordinating intemational information exchange activities. i i E. Manaaer-Nuclear Oversiaht The Manager-Nudlear Oversight is responsible to the Senior Vice President - Nuclear for assuring compliance with the Operational Quality Assurance Program for nuclear operations and associated support activities. The Manager - Nuclear Oversight may make recommendations to the Nuclear Organization's management. If he disagrees with any action taken by the Nuclear Organization and is unable to obtain j resolution, the Manager - Nuclear Oversight shall bring the matter to the 4 attention of the Senior Vice President - Nuclear who will determine the 3 final disposition. l

1. Director - Nuclear Oversiaht (one at each site) l The Director - Nuclear Oversight is responsible to the Manager -

Nuclear Oversight for assuring compliance with the operational quality assurance program for the nuclear power stations through internal audits. The Director - Nuclear Oversight may make recommendations to the station management. If he disagrees with any actions taken by the station management and is unable to obtain resolution, the Director - Nuclear Oversight shall notify the Manager - Nuclear Oversight and the Vice President - Nuclear Operations.

2. Suoervisor - Quality (Vendor Programs)

The Supervisor - Quality (Vendor Programs) is responsible to the Manager - Nuclear Oversight for assuring compliance with established vendor Quality Assurance Programs. This is accomplished through scheduling and conducting triennial extemal audits, annual vendor Quality Assurance Program evaluations, reviewing audits conducted by extemal organizations (e.g., other utilities and NUPIC), and maintenance of the Safety - Related Vendors List and the Commercial Grade Vendors List. 17.2-10

ncVidlVN 23 1/Wo NAPS UFSAR l

3. Staff Quality Specialist (Audit Coordinator)

The Staff Quality Specialist (Audit Coordinator) is responsible to the Manager - Nuclear Oversight for assuring compliance with the Operational Quality Assurance Program, administration of the intemal audit program, and interfacing with station Nuclear Oversight personnel. 17.2.1.3 Organization Each nuclear power station's Technical Specifications contain the company's organizational requirements for facility operation and corporate management. Additionally, duties and responsibilities of key positions within the nuclear organization are further defined in the appropriate administrative controls. t i e i i 17.2-11

REVISIOle 29 1/96 NAPS UFSAR i-17.2.2 OUALITY ASSURANCE PROGRAM 17.2.2.1 General Description The objective of the Company Quality Assurance Program for operating nuclear power j stations is to comply with the criteria as expressed in 10 CFR 50, Appendix B, as amended, and with the quality assurance program requirements for nuclear power plants as referenced in the Regulatory Guides and ANSI Standards as listed in tsble 17.2.0. This program, its policies and procedures are described herein: the Topical Report (VEP-1-5A) (entitled Operational Quality Assurance Program); the Nuclear l l } Operations Department Standards (NODS); and the corporate and station procedures. j This program applies to those quality-related activities that involve the functions of ~ safety related structures, systems, and components associated with the operation, j maintenance and modification of nuclear power stations and those non safety-related components described in the UFSAR. Designated modifications may be performed l under a contractor's Quality Assurance Program approved by the Company's Quality Assurance Program. The contractor's Quality Assurance Program when used for modifications will comply with the criteria expressed in 10 CFR 50, Appendix B, as i amended, and with the Regulatory Guides and ANSI Standards as listed in Table J 17.2.0. i The goal of this program is to assure the safe, reliable and efficient operation of the i nuclear power station in accordance with sound engineering principles. i i The program provides written policies, standards, procedures, and instructions 4 covering engineering, design, procurement, modifications, periodic surveillance, t testing, and maintenance after the systems have been installed, checked and turned over to the Company for operation. Nuclear Operations Department (NOD) policies i i and standards establish commitments to the Operational Quality Assurance Program. l Detailed procedures and instructions are issued by the station in accordance with and to meet the requirements of their Technical Specifications for administrative, normal L operation, periodic testing, abnormal and emergency conditions. Audit and inspection programs have been implemented to assure that these procedures are j being correctly applied. T Nuclear Oversight personnel, both station and corporate, report through a line of l 1 3 management completely separate from operational and production management and i influences, and fulfill the following three-part role: i

1. Audit to ensure that the overall operation of the nuclear power station is l

carried out in accordance with Technical Specifications, applicable codes i and standards, NRC guides and regulations, company policies and j commitments. j

2. Serve as a management tool for station and system. management personnel,

{ illuminating problem

areas, detecting trends, and providing recommendations regarding solution of problem areas when applicable.

] I 17.2-12 E_______-________---_.__-,--

REVISION 29 1/96 NAPS UFSAR

3. Provide alllevels of management with an independent source of information regarding the quality aspect of station operations, maintenance and modification activities, Differences of opinion between Nuclear Oversight personnel and other departments are resolved by the cognizant Manager and the Director - Nuclear Oversight or are forwarded through normal administrative chains of both individuals for resolution at the executive level.

Final decision-making authority rests with the Senior' Vice President-Nuclear. Nuclear Oversight conducts audits in accordarice with the Operational Quality Assurance Program and performs other duties as directed by the Manager - Nuclear i Oversight. Nuclear Oversight representatives have access to all areas of the station at any time deemed necessary for audits and activities related to quality. They have access to station records required for in-depth auditing of station operations, including confidential personnel records (but only to the extent necessary to verify personnel qualifications or other information related to quality). Station personnel assigned to conduct assessments and inspections in accordance with the Operational Quality Assurance Program have access to all areas of the station necessary to accomplish those activities. j 17.2.2.2 Quality Assurance Program The Company Operational Quality Assurance Program is displayed in a point-by point I comparison to Appendix B,10 CFR 50 in Table 17.2.1, which follows. l r 17.2-13

HEVISION 29 1/95 NAPS UFSAR 17.2.2.3 Identification of Structures, Systems, and Components Safety related structures, systems, and components are identified in the UFSAR. The portions of these structures, systems, and components that are within the scope of the Operational Quality Assurance Program are further identified in the respective O-List for North Anna and Surry Power Station. 17.2.2.4 Periodic Review of the Operational Quality Assurance Program Audits of activities required by the Operational Quality Assurance Program will be conducted at least once per 24 months. These. audits are performed under the cognizance of the Management Safety Review Committee. 17.2.2.5 Qualification of Nuclear Oversight Personnel The Manager - Nuclear Oversight shall have a four-year accredited engineering or science degree or equivalent with a minimum of ten years experience related to electric power generating facilities. At least five years of overall experience shall have been in a supervisory capacity, two years of which should have involved quality assurance related matters. The Director - Nuclear Oversight shall have a four-year accredited l engineering or science degree or equivalent with a minimum of eight years experience related to electric power generation facilities, two years of which involve experience in nuclear power stations. At least four years of overall experience shall have been in a supervisory capacity, two years of which should have involved quality assurance related matters. 4 The Supervisor-Quality (Vendor Programs) shall have a four-year accredited engineering or science degree, or equivalent with a minimum of two years overall experience or equivalent training in power plant operations is a prerequisite with at least one year of this experience involved in nuclear power station quality assurance program implementation. The Staff Quality Specialist (Audit Coordinator) shall have a four - year ~ accredited engineering or science degree, or equivalent with a minimum of two years overall experience or equivalent training in power plant operations is a prerequisite with at least one year of this experience involved in nuclear power station quality assurance program implementation. Replacement personnel in the key positions listed will meet or exceed the applicable requirements of ANSI /ANS 3.1 (Draft 12/79) as clarified in Table 17.2.0. l 17.2-14

REVISION 29 1/96 NAPS UFSAR i 4 i c [ 17.2.2.6 Qualification of Other Support Personnel y The Quality inspection Coordinator shall have a four-year accredited engineering or science degree, or equivalent with a minimum of two years overall experience or equivalent training in power plant operations. At least one year of this i .l experience shall be involved in nuclear power station quality assurance progr.am t implementation. ~ l The Nuclear Training representative responsible for certifying maintenance and 3 modification inspection personnel shall have a four-year accredited engineering or j q science degree, or equivalent with a minimum of'two years overall experience or l equivalent training in power plant operations. At least one year of this experience shall be involved in nuclear power station quality assurance program implementation. ? The Supervisor - Quality (Vendor Surveillance) shall-have a four-year accredited engineering or science degree, or equivalent with a minimum of two years overall experience or equivalent training in power plant operations. At least one year of this experience shall be involved in nuclear power station quality assurance program implementation, j Replacement personnel in the key positions listed will meet or exceed the i 4 i applicable requirements of ANSI /ANS 3.1 (Draft 12/79) as clarified in Table 17.2.0. 17.2.2.7 Certification of Nuclear Oversight Personnel l The certification of Nuclear Oversight personnel is accomplished in accordance with the Quality Assurance Certification Program. This program provides for the certification and recertification of auditors and lead auditors. 1 I The program outlines the qualification and certification requirements for personnel and requires the individual to be certified prior to performing specified audit functions. Nuclear Oversight management has the responsibility to certify audit personnel. 4 17.2.2.8 Certification of Other Support Personnel i The certification of maintenance and modification inspection personnel [i.e., Quality Maintenance Team (OMT) and station Quality Control inspectors)], Material Verification personnel, Vendor Surveillance personnel, Fuel Accountability and i inspection personnel, and Inservice Testing [ Visual Test (VT)] personnel is accomplished in accordance with the approved certification programs. l These programs outline the qualification and certification requirements of personnel and require the individual to be certified prior.to performing specified 4 i functions. Nuclear Training has the responsibility to train, qualify, and certify maintenance and modification inspection personnel. 17.2-15

f- _ REvlSIO'N 29 1/96 NAPS UFSAR 17.2.3 ~ DESIGN CONTROL 1 Nuclear Standards describe the design control program. Measures are established to assure that applicable regulatory requirements and the nuclear power station design bases are correctly translated into the Company specifications, drawings, procedures, and instructions applicable to design changes and/or 1 l modifications for the operating nuclear power station. 4 All design changes and/or modifications to safety-related structures, equipment, i systems and components described in the UFSAR are reviewed, approved, and acted upon by the Station Nuclear Safety and Operating Committee in accordance with their j responsibilities and functions as referenced in the Technical Specifications. The Management Safety Review Committee is responsible for ensuring that independent 3 reviews are performed for safety evaluations associated with design changes approved by the Station Nuclear Safety and Operating Committee. The responsibility i for the development, identification of requirements, monitoring, and implementation of i an effective design control program is delegated to the Vice President - Nuclear Engineering and Services with input as appropriate from the Station Manager and operations personnel. The Nuclear Design Control Program (NDCP), delineates procedures that assure design changes, including field changes, are subject to design control measures commensurate with those applied to the original design and the applicable specified design requirements. These procedures assure that design basis, regulatory requirements, codes and standards are correctly translated into specifications, drawings, procedures, or instructions for those structures, systems and components classified as safety-related in the UFSAR and O-List. The NDCP provides for verifying i or checking the adequacy of design, such as by the performance of design reviews, by l the use of attemate or simplified calculational methods, or by the performance of a l - suitable testing program. When a testing program is solely used to test the adequacy i of a design, the test will be conducted under adwse design conditions. The i i provisions of this section assure that the verifying or checking process is performed by i individuals other than those who performed the original design. These individuals are identified and their authority and responsibility is described. The NDCP also identifies the design documents that are required to be reviewed and the personnel responsible l j for their review and revisions, to assure that design characteristics can be controlled, t inspected and tested, and that inspection and test criteria are identified. Design change documents and revisions thereto are distributed to responsible supervisors to } determine whether revisions to controlled design and operating documents are necessary. Design documents and reviews, records and changes thereto are collected, stored and maintained in a systematic and controlled manner. The NDCP establishes measures for the selection and review for suitability of application of materials, parts, equipment and processes that are essential to the i safety-related functions of the systems, structures and components. These measures i include the use of valid and applicable industry standards and specifications, materials and prototype hardware testing programs, and design reviews. In the event-of a design modification to a system which is safety related, engineering studies i i 4 i i i 17.2-16

HEvlSION 29 1/96 NAPS UFSAR 4 are initiated to evaluate parts, equipment, processes, and material suitability for repair of such equipment or components; previously approved items are used without further review. Previously approved materials, parts or components used for a different application are reviewed for suitability prior to approval for their new application. Quality measures are assured through all levels of the design control program by the design control organization, station and Corporate support organizations, hnd the Station Nuclear Safety and Operating Committee. Any errors or deficiencies noted in the design process are documented on the design change forms and subsequently l corrected. Procedures for design controls, analysis, and reviews have as their basis the applicable portions of documents referenced in the Nuclear Design Control Manual, and include ANSI N45.2.11 - 1974 as modified in Table 17.2.0. The Nuclear Design Control Program Instruction Manual for Architect / Engineers establishes procedures to describe the design interface between the Company and contractors for the review, approval, release, distribution, and revision of documents 4. involving design interfaces. Suitable design controls are applied to such disciplines as reactor physics; seismic stress, thermal, hydraulic, radiation and accident analysis, compatibility of materials; and accessibility for inservice inspection, maintenance and repair. Designs are reviewed to assure that (1) design characteristics can be controlled, inspected, and tested, and (2) inspection and test criteria are identified. } Changes to non safety-related structures, systems, and components will be controlled in accordance with applicable procedures and to meet the requirements, where applicable, of 10 CFR 50.59. I f b i I t d 17.2-17 4

REVISION 29 1/96 NAPS UFSAR 17.2.4 PROCUREMENT DOCUMENT CONTROL i Nuclear Operations Department Standards and their supporting procedures describe the program for completing procurement documents including review, j approval, document control, and change control. In addition, references to procedures that govem the actions of Nuclear Oversight and Vendor Surveillance are made which include provisions for access to the suppliers' facilities and records, for source inspection or audit, and qualification of vendors prior to the initiation of quality related actions when the need for such inspection and/or audit has been determined. This program also provides for records to be prepared, maintained, made available for review, or delivered to the Company prior to use or installation of the hardware, such as drawings, specifications, procedures, procurement documents, inspection and test records, personnel and procedure qualifications, material, chemical and physical tests results, an the identification of quality assurance requirements applicable to the items or services purchased, including sub-tier procurement requirements when required. Policies and standards are established in the Nuciear Department Standards Manual to ensure that procurement documents reference all actions required by a supplier in accordance with the applicable codes, specifications, and drawings. Procurement documents incorporate the design basis technical and quality requirements including the applicable regulatory requirements, component and material identification requirements, drawings, specifications, codes and industrial standards, test and inspection requirements, and special instructions for special procedures such as welding, heating treating, nondestructive testing and cleaning as applicable. Procurement documents for spare or replacement parts of safety-related structures, systems and components are subject to technical and quality controls at 7 least equivalent to those used on the original equipment. Procurement documents are prepared, reviewed, and approved as delineated in administrative controls. Copies of procurement documents, or equivalent documents such as Receiving Reports or Requisitioner's Purchase Orders, are retained and are available for review. j l l i t I i l 17.2-18 ~.. s..-. .-a s-

REVISION 29 1/96 NAPS UFSAR ) i 17.2.5 INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS As required by the individual unit's Technical Specifications, detailed written j procedures are established, approved, implemented, and maintained. Other activities affecting quality of structures, systems, and components within the scope of 10 CFR 50 Appendix B are prescribed by documented instructio.ns, i procedures, or drawings of a type appropriate to the circumstances. These activities are accomplished in accordance with these instructions, procedures, or drawings. . Applicable instructions, procedures, or drawings include for reference appropriate qualitative and/or quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Administrative procedures describe the requirements for developing, reviewing, approving, and controlling procedures used for testing as well as corrective maintenance, operating, design change implementation, administrative, and other r activities performed at the power station. These requirements include references, f prerequisites, precautions, limitations, manufacturer's specifications, check-off lists, i and acceptance criteria (as appropriate). When applicable the acceptance limits and requirements contained in the design and procurement documents constitute a portion of the acceptance criteria referenced and contained in written testing procedures. Changes to procedures require an Activity Screening to be performed before a j change can be implemented. The Activity Screening includes criteria the preparer j must consider to determine if a safety evaluation is required for a proposed change. Procedure changes that require a safety evaluation are reviewed by the Station Nuclear Safety and Operating Committee (SNSOC) which serves as the onsite review l group. Procedure changes that do not require a safety evaluation as determined by l the Activity Screening are not required to be reviewed by SNSOC, but still require independent review and approval by a Senior Reactor Operator and cognizant management prior to implementation. The above requirements are applicable to both intent and non-intent procedure changes. At its discretion, SNSOC may review procedure changes that do not require a safety evaluation in lieu of a Senior Reactor Operator. New procedures and procedure revisions are also reviewed using an Activity Screening to determine if a safety evaluation is required. If the procedure is new or if a revision requires a safety evaluation, the procedure is reviewed by SNSOC. Revisions that do not require a safety evaluation are reviewed by cognizant management prior to implementation. Due to the numerous programmatic reviews that are entailed in the preparation of new and revised procedures changes, a Senior Reactor Operator review is not mandatory. At its discretion, SNSOC may review procedure revisions that do not require a safety evaluation. l 17.2-19 d .. i...-.+ v -v r --- + -

REVISION 29 1/96 NAPS UFSAR 4 1 I 17.2.6 DOCUMENT CONTROL Measures are established and documented within the operating nuclear power f stations and at Innsbrook Technical Center describing the control of documents, such as procedures, instructions, and drawings, to provide for their review, approval, and issue, and changes thereto, prior to release and to assure they are adequate and the quality requirements are stated. Provisions call for, among other things, (1) the revi.ew j and approval of all new station procedures and design changes prior to release,~the review and approval of all changes / revisions to stattpn procedures and all proposed changes or modifications to plant systems or equipment that affect nuclear safety by i the Station Nuclear Safety and Operating Committee, (2) policy and procedures for i l issuance of and changes to station drawings and approval of changes, and (3) the maintenance and distribution of these procedures. Normally changes to documents are reviewed and approved by the same organizations that performed the original review and approval; however, this responsibility may be delegated to other qualified responsible organizations._ Approved changes are incorporated into procedures and l drawings and other appropriate documents associated with the change. Procedures and drawings and changes thereto are processed, distributed and controlled. The station maintains a record of all holders of procedures and drawings and an index of all procedures and drawings, listing the current revision date. Instructions require that a copy of the appropriate procedure be available at the activity location prior to the commencement of that activity. These measures are addressed in the Technical l Specifications and Administrative Procedures for each station. i Administrative procedures list certain documents that require strict administrative control for distribution, revision, and routing. These documents are categorized as " Controlled Documents." Examples of controlled documents are: Station Procedures, Station Drawings, and the Precautions, Limitations, and Setpoint t Document. Also set forth are the distribution and controlling procedures for design 4 l and procurement documents. Maintenance and modification inspection activities l ensure that current procedures are used to accomplish work. t 1 1 i i i i 1 17.2-20 4 i b 4 w

+44da---+d_"--* Wand *4i,4 M 45 w Di a O A-4Ma.a.s.__pi-mA_ REVISION 29 1/96 NAPS UFSAR l i 17.2.7 CONTROL OF PURCHASED MATERIAL. EQUIPMENT. AND SERVICES An evaluation of suppliers is performed prior to contract award, except in emergency situations where an item or service is needed to preclude development or deterioration of an unsafe condition at the plant, by one or more of the following: (1)A review of the supplier's capability to comply with the elements of 10 CFR 50, Appendix B that are applicable to the type of material, equipment, or service being procured,,(2) A review or previous records and performances of suppliers who have provi~ ed i d similar articles of the type being procured, (3) A survey of the supplier's facilities and quality assurance program to determine his capability to supply a product or service which meets the design, manufacturing, and quality requirements, or (4) A review of qualification information supplied by another utility or outside organization. Surveillance of suppliers during fabrication, inspection, testing, and shipment of materials, equipment, and components is planned and performed in accordance with written procedures to assure conformance to the purchase order requirements as R applicable. These procedures provide for:

a. Instructions that specify the characteristics or processes to be witnessed, inspected or verified, and accepted; the method of surveillance and the extent of documentation required; and those responsible for implementing these instructions. Surveillance shall be performed on those items where verification of procurement requirements cannot be determined on receipt.

b. Audits and/or inspections which assure that the supplier complies with all quality requirements.

I Administrative procedures describe the requirements for controlling purchased material, equipment, and services including commercial grade items for use on safety-related structures, systems, equipment, and components. The requirements applied to spare and replacement parts are at least equivalent to those applied to the original parts. Inspections and surveillance of suppliers of nuclear safety - related items is performed under the direction of the Vice President - Nuclear Engineering and Services. The results of these actions are documented and filed. The periodic inspections assure that applicable material and equipment received at the station meet the requirements of the specifications, purchase orders, code, drawings, or other purchasing documents. This assurance includes the review of documentation i received, physical inspection, cleanliness, packaging, marking or functional testing, as i required. Purchased items are normally under the control of the on-site" organization. This organization is authorized to contact system organizations and NSSS, A/E contractors and subcontractors through the auspices of system representatives for assistance as required. Verification of these activities is accomplished under the j direction of the Manager - Nuclear Oversight. Periodic evaluations of procurement history of the suppliers are performed by 4 Nuclear Oversight to verify continued supplier capability. l 17.2-21 m-m m-r-++r -w i--

REVISION 29 1/96 NAPS UFSAR i ? Documentation conceming the quality of material, components, and equipment received is reviewed by the Nuclear Engineering and Services representative for l conformance with the Purchase Requisition and Purchase Order. The procurement of nuclear fuel is controlled in accordance with procedures that have been developed by the Nuclear Engineering and Services Organization to address the requisite quality attributes of this function. Verification of this activify is performed under the supervision of the Director - Nuclear Oversight. 4 A f 1 a a a 17.2-22

REVISION 29 1/96 NAPS UFSAR l 17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS. PARTS. AND COMPONENTS Installed components at the nuclear power station are adequately identified and substantiated with documented records by the Architect - Engineer and the NSSS Vendor during the construction phase of the station. These identifications and records are maintained in the station files. Replacement materials, parts, and components including partially fabricated ' subassemblies are adequately and properly identified to allow control and traceability to pertinent quality assurance records such as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and chemical mill test reports. The identification system is consistent, as practical, with that used during the construction of the station, with similar identification used during design change activities. The location and method of identification do not affect the function or quality of the item being identified. Verification of correct identification of safety-related materials, parts, and components is required and documented prior to the release for fabrication, assembling, shipping, or installation. Maintenance and modification inspection activities ensure, on a random basis, that materials, parts, and components utilized at the nuclear station are appropriately identified and controlled. 4 1 J 4 17.2-23

REVlSION 29 1/96 NAPS UFSAR 17.2.9 CONTROL OF SPECIAL PROCESSES The control of special processes is maintained and implemented through the use of procedures, technique sheets, travelers and inspection verification reports, and personnel qualified in accordance with the applicable codes, specifications, and standards for the specific work. In instances where the Company assigns such work to contractors, the contractor must submit their procedures and personnel qualifications to the Company for approval prior to the start of work. Special processes include, for example, those involving welding, heat treating, nondestructive testing, cadwelding, removal of undesirable substances during shop and site cleaning, degreasing and flushing, and verification of wall thickness of valves and other cast components important to nuclear safety. The Company conducts inspections of work involving special processes to assure that procedures and personnel are properly qualified and their workmanship is in compliance with applicable specifications, codes, and standards. Records of procedures, equipment, and personnel qualification are maintained and kept current in accordance with the provisions of Section 17.2.17 herein. l 17.2-24

REVISION 29 1/96 NAPS UFSAR i l 4 i 2 17.2.10 INSPECTION l Inspection procedures for those activities affecting quality have been established. These procedures govem the inspection and documentation of activities i relating to repairs, modifications, and changes made to safety related systems, { structures, and components. Written maintenance procedures are provided which c include inspection hold points. Examinations, measurements, or tests of materials or components associated with safety related equipment and systems are performed for each work operation, l where necessary, to assure quality. If inspection is impossible or inappropriate, l j indirect control by monitoring methods, equipment, and personnel is provided. Both j l methods are provided when control is inadequate without both. i The station maintenance procedures are reviewed under the cognizance of the Assistant Station Manager (Nuclear Safety and Licensing) or designee to determine l the need for an independent inspection and the degree and method if such an inspection is required. Modification procedures are reviewed by the design authority i to determine the need for an independent inspection consistent with administrative ) procedures and engineering specification requirements. Examinations, j measurements, or tests that require witnessing are identified as " inspection hold" 4 points in procedures. The inspection performed at a hold point is specific in nature; i quality characteristics and acceptance / rejection criteria are included or qualitative i criteria such as operability checks, compliance with procedural steps, or cleanliness i instructions are specified. The inspection is documented by signature or initials on the written procedure form. Maintenance and modification inspection personnel perform physical l inspections at random intervals to ensure quality requirements are met. These checks are performed as the conditions of the maintenance warrant. These personnel and i other inspectors are qualified in accordance with codes and standards as applicable to the function they are performing. The inspection program requires that inspectors be assigned as appropriate for the activity being inspected. An inspector may be a member of the organization performing the activity. However, they must be qualified and shall not be the person i performing the activity or the supervisor directly responsible for the activity. Maintenance and modification inspection personnel are under the administrative direction of the Quality inspection Coordinator when performing Quality Control inspections. Personnel so assigned shall become familiar with the procedure being used and other pertinent documents such as technical manuals and drawings prior to performing the inspection. l i i 4 17.2-25 r-+ ..~c

] REVISION 29 1/96 NAPS UFSAR [ 1 i Personnel responsible solely for the conduct of nondestructive examination are qualified to SNT-TC-1 A as referenced by Table IWA-1600-1 of the applicable Code. In l addition, personnel who conduct inservice or preservice examinations meet the l additional and/or altemative qualification requirements specified by IWA-2300 for the applicable examination method and qualification level. Maintenance and modification j inspection personnel, Material Verification personnel, Fuel Accountability and j inspection personnel, and Vendor Surveillance personnel meet the qualification requirements of ANSI N45.2.6-1978, as clarified in Table 17.2.0 under NRC I Regulatory Guide 1.58. The inspectors' qualifications are periodically reviewed for recertification. Generally, all physical inspections are under the control of the on-site organization,' However, the Station Manager is authorized to request assistance as required from Corporate support organizations. l l 1 The inspection of nuclear fuel and related items is controlled in accordance with procedures that have been developed by Nuclear Engineering and Services to i address the requisite quality attributes of this function. j Additionally, inspection activities pertaining to Design Control (Section 17.2.3); 4 Procurement Document Control (Section 17.2.4); Test Control (Section 17.2.11); l Nonconforming Materials, Parts, or Components (Section 17.2.15); and Corrective Action (Section 17.2.16) shall be controlled in accordance with provisions established j for this function in the referenced sections contained herein. f j. i a i i i i J e 17.2-26

j REVISION 29 1/96 NAPS UFSAR l I l 17.2.11 TEST CONTROL I i The test program described in the Technical Specifications assures that safety-related structures, systems, and components will perform satisfactorily when required. Written " Periodic Test" procedures for this program are reviewed and approved as specified in the individual unit's Technical Specifications. These test procedures ( include or reference: l l 1 (1) The requirements and acceptance limits contained in applicable design j and procurement documents. j (2) Test prerequisites such as the availability of adequate and appropriate equipment and calibrated instrumentation; trained, qualified, and licensed } or certified personnel; the completeness of the item to be tested; suitable and controlled environmental conditions; provisions for data collection and storage. l l (3) Instructions for performing the test. (4) Inspection points as appropriate. I i f (5) Acceptance and rejection criteria. { l (6) Methods of documenting or recording test data and results. l a The Periodic Test Program provides for testing of instrumentation and electrical l equipment in the categories of (1) instruments installed as listed in the Technical Specifications, (2) installed instrumentation used to verify Technical Specification parameters, and (3) installed safety-related instruments and electrical equipment that j 1 provide an active function during operation, shutdown, or abnormal conditions (i.e., j vice being designated safety-related solely because the instrument is an integral part of a pressure retaining boundary). This instrumentation shall be in a calibration j program. This program provides, by the use of equipment history data, status, records, and performance schedules, for the date that calibration is due and indicates the status of calibration. The identity of person (s) performing calibration is provided on the l calibration documents. Testing of modifications is done in accordance with procedures developed [ within the Design Change Program described in Section 17.2.3 of this report. l 2 Testing upon. completion of maintenance is done in accordance with Maintenance Procedures developed as described in Section 17.2.5 of this report. l-t. l 2 e 17.2-27 I i l

j ' REvislON 29 1/96 NAPS UFSAR l i k I 17.2.12 RONTROL OF MEASURING AND TEST EQUIPMENT i i A program has been established and documented in administrative procedures that describes the calibration technique and frequency, maintenance, and control of all " Measuring and. Test Equipment" (portable instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive test equipment) which are used in the measurement, inspection, maintenance, and monitoring of safety-rela.ted l components, systems, and structures. Measuring and test equipment does'not include: measuring equipment used for preliminary checks or utility troubleshooting l l where accuracy is not required. There is also no intention to imply a need for special calibration and control measures of rulers, tape measures, levels, and other basic j tools if normal commercial practices provide adequate accuracy. Controls for i measuring and test equipment include the transportation, storage, and protection of j i the equipment; the handling of associated documents giving the status of all items { under the calibration system such as maintenance history, calibration test data, and l individual log sheets assigned to each device; and the permanent marking of each device by a unique number. i The maintenance, calibration technique,- and frequency of calibration of measuring and test equipment utilized in activities affecting quality at the power station are normally performed as specified in the manufacturer's instruction manual or in ,~ approved written procedures. In some cases the calibration interval may be assigned or changed based on accumulated experience by trained technicians. The recall system may include provisions for the temporary extension of the calibration due date under certain conditions specified in approved procedures. If standards are not i available or there is some special reason that procedures cannot be followed, the modified procedures and/or interval are documented, including justification. In other i cases, rather than require calibration at specified intervals, procedures may specify the i. device be calibrated prior to use, as in the case of torque wrenches or micrometers. Where permitted by commercially available state of the art equipment, reference j standards are no more than 1/4 the error allowed in the measuring and test equipment i calibrated by that standard. Measuring and test equipment used on safety-related l systems or equipment are calibrated utilizing reference standards whose calibration j has a known valid relationship to nationally recognized standards, such as the National Institute of Standards and Technology (NIST), or accepted values of natural j physical constants. If no national standard exists, the basis for calibration is documented. Whether the device is calibrated at the power station or at an NIST i traceable outside laboratory, one or more stickers are affixed on a conspicuous surface identifying, but not limited to, date of calibration and next calibration due date. j When measuring and test equipment utilized in activities affecting quality are found to be out of calibration an evaluation will be performed and documented i concerning the validity of previous tests and the acceptability of devices previously tested. All previous tests and measurements performed during the current or proceeding calibration cycle shall be redone if the evaluation so indicates. i implementation of the measuring and test equipment programs is assured j through Nuclear Oversight audits and through inspections by the appropriate line 1 organizations during performance of work. 4 17.2-28

REVISION 29 1/96 NAPS UFSAR ) i l 1 17.2.13 HANDLING. STORAGE. AND SHIPPING j Measures have been established in administrative procedures to provide adequate methods by qualified personnel for the classification, packaging, cleaning, preservation, shipping, storage, and handling of material and equipment received at the station. These measures, prepared in accordance with design and specification requirements, define responsibility, levels of essentiality, degree of receipt inspection, tagging, categories of inspection and their definition, and storage levels for categorized items. The procedures also control cleaning, handling, storage, J packaging, shipping, and preservation of materials, components, and systems to preclude damage, loss, or deterioration by environmental conditions such as l temperature or humidity. Implementation of these measures is verified through inspections by Materials Verification and Vendor Surveillance inspectors. t i ll 't [ f l i I 4 f 17.2-29

REVISION 29 1/96-NNPS UFSAR 17.2.14 INSPECTION. TEST. AND OPERATING STATUS Measures for the identification and documentation of the inspection and test status for items to prevent inadvertent bypassing of specified inspections and tests are established in administrative procedures and in station operating procedures. These measures define the three general categories of inspection and test status for items: Accept, Reject, or Hold. They provide for status identification through the use. of stickers, tags, record cards, test records, check-off lists, or logs. The operating statu's of items and/or equipment is identified through records, checklists, or operational tagging systerns that are maintained to indicate the status and authority to operate the item and/or equipment. Operating status is additionally controlled through the normal station operating procedures. The application and removal of the various status tags, stickers, and other indicators is controlled by Station Procedures. l I i 17.2-30 ,.n .e n -n -_..,-. _.-._,_ __ _ ~ _

REVISION 29 1/96 NAPS UFSAR 1 4 4 17.2.15 NONCONFORMING MATERIALS. PARTS. AND COMPONENTS A documented system for controlling nonconformances observed during receipt inspection, storage, fabrication and erection, installation, initial and/or acceptance testing, or initial operation is established and provides for the preparation, issuing, and distribution of Station Deviation Reports and Discrepant Shipment Reports in 2 accordance with prescribed procedures. These procedures apply to new or reworked materials, parts, or components which possess manufacturer / supplier cauted nonconformances. l The identification, documentation, segre.gation, review, disposition, and notification to affected organizations of nonconforming material, parts, or components are described or referenced in station Technical Specifications, Administrative i procedures, and/or station operating procedures. Nonconformance of purchased services are controlled under Section 17.2.7 Control of Purchased Material, l Equipment, and Services; Section 17.2.10 inspection; and administrative procedures. Specifically, instructions require that the. individual discovering a nonconformance identifies, describes, and documents the nonconformance on a i Station Deviation Report or a Discrepant Shipment Report in accordance with administrative procedures. When a nonconforming item is identified, it is placed in the hold area 1 established in the storeroom or other segregated location, if practical, and identified I with a hold tag to prevent its inadvertent use, if material is dispositioned as ' reject' the hold tag shall remain attached to the material / component until loaded for departure from site and shall only be removed in accordance with approved procedures by j authorized personnel at that time. Hold items may be released on a risk basis following the documented approval of such risk release by the Station Manager on a Release on a Risk Basis Form. Each i risk release is handled on a case basis and depends on the nature of the hold status. The basis and ~ conditions of the release are described on the form, including the criteria for clearing the original hold status. Rejected material is not risk released. A Station Deviation Report or a Discrepant Shipment Report for a j nonconforming material, part, or component dispositioned " accept as is" requires an engineering analysis and approval. The results of this review and approval are 4 documented and become a part of station records. Should the disposition of a nonconformance require the rework or repair of i materials, parts, components, systems, or structures, such rework or repair is reinspected or retested by a method which is at least equal to the original inspection or test method. The inspection requirements and the inspection, rework, or repair procedures are documented and become a part of station records. 1 17.2-31

REVISION 29 1/96 NAPS UFSAR The disposition and approval of nonconformances are the responsibility of the on-site organization. However, the Station Manager has the authority to request assistance as appropriate from Corporate support organizations or from Nuclear Oversight. The Station Deviation Reports trends are periodically reviewed for conditions adverse to quality by station management. in service failures of materials, parts, and components are dispositioned by the use of Deviation Reports and/or Work Orders as described in Section 17.2.16 of this report. Implementation and verification of the procedures for the control of nonconformances are assured through audits and inspections. l The nonconformances observed during the inspection of nuclear fuel and related items and the disposition of those nonconformances is controlled in accordance with procedures that have been developed by Nuclear Engineering and Services to address the requisite quality attributes of this function. 1 t 4 4 17.2-32 r

HEV1 MON 29 1/90 NAPS UFSAR [ f l i L l 17.2.16' CORRECTIVE ACTION i Corrective action measures are established as an integral part of the j processing and resolving of nonconformances and failures in service. Through these i measures, assurance is confirmed that significant adverse quality conditions are i identified, documented, their cause determined, and the corrective actions have been } taken that preclude repetition of the adverse quality conditions. Verification of Jhe j proper implementation of corrective action measures and close-out of corrective action i documentation is assured through the monitoring effort of the station staff and the j audits conducted by Nuclear Oversight. Adverse conditions significant to quality, the cause of the conditions, and the initiation of corrective action are reported to appropriate levels of both offsite and onsite management by use of Deviation Reports and audit findings. If further corrective action is required the appropriate management j program for performing, tracking and closing the issue will be used. Nuclear Engineering and Services maintains a program to evaluate complex l l design concems that may lead to adverse quality conditions at the nuclear stations. The Potential Problem Reporting (PPR) system allows for detailed, multidiscipline ) reviews of complex design concems that may yield station deviation reports. Many ( design concems cannot be determined to be adverse to quality until a detailed design review is performed. The PPR process controls this activity as part of the Nuclear Design Control Program. The procedures for processing a Deviation Report require that each adverse condition significant to quality be categorized as either requiring a Licensee Event Report, Special Report or NRC Notification or as a nonreportable deviation. Nonreportable deviation refers to deviations not reportable to the Nuclear Regulatory l Commission. The reporting requirements differ for each of the categories of deviation but require the appropriate levels of management be notified in each case. l Procedures require that corrective maintenance of nuclear safety related material, parts, or components be documented on a Work Order. Maintenance and modification inspection personnel are notified prior to the commencement of safety related maintenance. Maintenance and modification inspection personnel may then initiate a surveillance program as necessary. Examples of areas subject to surveillance are (1) the use of approved maintenance procedures, (2) the existence of Radiation Work Permits and proper tagout, if applicable, (3) the existence of required plant conditions, and (4) documentation of Technical Specification requirements. If the maintenance and modification inspection personnel elect to inspect the work, the surveillance does not have to be performed prior to commencement of work. Also, Nuclear Oversight audits completed Work Orders to assure maintenance performed was properly documented, maintenance procedures were properly signed off and check lists were completed if applicable, Technical Specification limits were met if applicable, materials used were documented, and Work Orders were being adequately reviewed by appropriate supervisory personnel. 17.2-33

REVISIOR 29 1/96 NAPS UFSAR Station Technical Specifications require that rework or repair of nuclear safety-related materials, parts, components, systems, and structures be accomplished in accordance with approved written procedures. The procedures for rework or repair of safety-related equipment are approved by the Station Nuclear Safety and Operating Committee to ensure provisions for an adequate inspection of the completed rework or repair. The cognizant supervisor reviews the completed procedures to insure the l t acceptance criteria have been satisfied and for the completeness of the po'st-maintenance check-out. l !l The Quality inspection Coordinator determines the scope of the required inspection effort on the basis of the exte.nt of modifications or repair to safety-related i equipment, systems, or components. For some repairs and modification activities, pre-Job briefings held by station personnel in accordance with applicable administrative i . procedures may be attended by maintenance and modification inspection personnel at the discretion of the Quality inspection Coordinator. For maior evolutions. such as j refueling, steam generator modifications, etc., inspection activities will be planned and coordinated as directed by the Quality inspection Coordinator. 17.2.16.1 Authority to Stop Work Nuclear Oversight and the Quality inspection Coordinator have the authority, and the l responsibility, to stop work in progress which is not being done in accordance with approved procedures or where safety or equipment integrity may be jeopardized. This extends to off-site work performed by vendors fumishing safety-related materials and services to the Company. 17.2.16.2 Imposition of "Stop Work" A. Nuclear Oversloht and the Quality Insoection Coordinator - The Nuclear Oversight representative or maintenance or modification inspector advises the cognizant supervisor or.=upervisory personnel to stop work in progress whenever he determines that it is not being conducted in accordance with applicable procedures, instructions, guides, or standards or may jeopardize the safe operation of the station. Nuclear Oversight representatives inform the Director - Nuclear Oversight of the stop work order. The maintenance or j modification inspector informs the Quality inspection Coordinator and the Director - Nuclear Oversight of the decision to stop work. The Director - Nuclear Oversight or the Quality inspection Coordinator then notifies the Station Manager of the decision to stop work because of adverse quality conditions. He shall also notify' the Manager - Nuclear Oversight. I [ 1 17.2-34 l .. - - ~ .~.

. =. - - -.. REVISIOR 29 1/96 NAPS UFSAR I B. Station Manager - The Station Manager evaluates the determination to stop work. l f

1. If he concurs with the decision to stop work, he initiates the necessary i

corrective action. Only after the discrepancy has been corrected and the corrective action approved by the initiating organization does work resume.

2. In the event the Station Manager does not concur with the decision to stop work, he may order work to resume by notifying the Director -

Nuclear Oversight (who shall notify the Manager - Nuclear Oversight) and the appropriate station supervisory personnel in his organization of his decision. He shall also refer the issue to the Vice President - Nuclear Operations for review and approval. C. Vice President - Nuclear Ooerations - The Vice President-Nuclear Operations is responsible for approving or disapproving the Station Manager's decision in those cases where the Station Manager does not concur with the stop work and orders work to resume. l D. Manager - Nuclear Oversiaht - The Manager - Nuclear Oversight may refer any concerns he may have concerning the-handling of "stop work" to the Vice l President-Nuclear Operations. He may direct imposition of "stop work" whenever he deems such action to be appropriate. '1 E. . Imposition of offsite "stop work" performed by vendors shall be controlled by appropriate administrative procedures. i 4 l i i i i 4 4 i i 3 17.2-35

4e. e REVISION 29 1/96 NAPS UFSAR 17.2.17 OUALITY ASSURANCE RECORDS The requirements and responsibilities for quality assurance records transmittal, retention, and maintenance subsequent to completion of work at the power station have been established and are documented in administrative procedures. Quality Assurance records relating to the operating status of the station and documentary evidence of the quality of items and activities affecting quality 'are maintain 6d in accordance with the Technical Specifications and administrative procedures. These records include plant history; operating logs; principal maintenance and modification activities; Licensee Event Reports; results of reviews, inspections, tests, audits, and material analysis; rnonitoring of work performance, qualification of personnel, procedurcs, and equipment; and other documentation such as drawings, specifications, procurement documents, calibration procedures and reports, deviation reports, and corrective action requests. Identification and retrievability of these records is facilitated through proper indices and an established basic filing system. Record storage facilities are constructed, located, and secured to prevent the destruction of records by fire, flooding, theft, and deterioration through environmental conditions such as temperature and humidity. 1 i 17.2-36 {

MtbiblOlt 29 1/96 NAPS UFSAR 17.2.18 AUDITS The system of audits devised to verify compliance with quality related aspects of the power station is described in the station Technical Specifications. Intemal audits l of selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner which assures that biennial (2 years) audits of safety related activities are completed. The audits are regularly scheduled on a formal preplanned audit schedule. The audit system is reviewed periodically and revised as necessary to assure coverage commensurate with current and planned activities. Additional audits may be performed as deemed necessary by management. The scope of the audit is determined by the quality status and safety importance of the activities being performed. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with preplanned and approved audit plans or checklists. 1 Nuclear Oversight is delegated the responsibility for conducting periodic internal and extemal audits. Intemal audits are conducted to determine the adequacy of the station's programs and procedures, that they are meaningful, and comply with the overall Quality Assurance Program. Extemal audits determine the adequacy of vendor and contractor 10 CFR 50, Appendix B QA Programs. An audit includes an objective evaluation of quality related practices, procedures, and instructions; the effectiveness of implementation; and the conformance with policy and directives. An audit also includes the evaluation of work area, activities, processes, and items and the review of documents and records. Provisions are established requiring that audits be performed in those areas where the requirements of Appendix B to 10 CFR 50 are being implemented. These areas include as a minimum, but are not limited to, those activities associated with operation, maintenance, modification, and repair controls; the preparation, review, approval, and control of design changes, procurement documents, instructions, procedures, and drawings; receiving and plant inspections; indoctrination and training programs; the implementation of the operating and test 4 procedures; and the remaining criteria in Appendix B to 10 CFR 50. The results of each audit are reported in writing to the distribution delineated in accordance with station Technical Specifications. Additional internal distribution is made to other concerned management levels in accordance with approved procedures. Management responds to all audits and initiates corrective action where indicated. Where corrective action measures are indicated, documented follow-up of applicable areas through inspections, review, re-audits, or other appropriate means is conducted to verify implementation of assigned corrective action. 17.2-37

RiiViblON 29 1/96 NhPS UFSAR If the Manager - Nuclear Oversight determines the response to an intemal audit finding is unacceptable or if a finding response is not received in the time allotted or if corrective action for a finding is not accomplished as indicated on the response, the matter is brought to the attention of the Station Manager or appropriate Corporate Manager for resolution if the Manager - Nuclear Oversight does not agree with the resolution proposed, he notifies appropriate levels of management in accordance with established escalation procedures. The escalation of extemal audit issues identified by Nuclear Oversight is controlled by administrative procedures. The responsibility for analyzing audit reports for trends and effectiveness lies with the Manager - Nuclear Oversight. As trends are discovered or if the effectiveness of the program is in question, the analysis of the Manager - Nuclear Oversight is forwarded to the management level consisten! with the seriousness of the problem. f A i a 17.2-38

hi-ViblON 29 1/96 NAPb UFSAR APPENDIX A FIGURES NUCLEAR ORGANIZATION 17.2-39

. _. _. _.. = APPENDIX A NUCLEAR ORGANIZATION FIGURE 17.2.1-1 'I Ti 5 E 9 E 5 Seneor Vice President 2 MSRC Nuclear NOB 3'- 0 V: 17.2.12.A.1 17.2.12.A 17.2.12. A2 Secretary to Senior Regulatory Affairs Executive Advisor g i I I I Vice President Manager Nuclear Security Manager Nuclear N at np ng A 8 N ar s t and Services Services 17.2.12.B 17.2.12.C 172.1.2.D 172.1.2.E l-17.2-40

APPENDIX A NUCLEAR STATION ORGANIZATION FIGURE 17.2.1-2 $s Eoz to w SNSOC adon Managa Director E' Nuclear Oversight 17.2.1.2.B.1.a 17.2.1.2.B.1 17.2.1.2.E.1 Secretary Z> ~ I I l l 0* C Assistant Station Assistant Station Superintendent Site Superintendent Supervisor ] Manager (O&M) Manager (NS&L) Services Radiological Administrative y Protection Services 'D 17.2.1.2.B.1.b 17.2.1.2.B.1.c 17.2.1.2.B.1.d 17.2.1.2.B.1.e 17.2.1.2.B.1.f Superintendent Operations L SupervisorShift 17.2.1.2.B.1.b.1 Operations 17.2.1.2.B. I.b.1.1 Supeteniendent Maintenance 17.2.1.2.B.1.b.2 Superintendent Outage & Pfanning i 17.2.1.2.B.1.b.3 17.2-41

_-. =. - TABLE 17.2.0 Standard, Requirement or Guide i l Reaulatory Guide 1.8 "Personne; Oualificahon and Training" (Second Proposed Revision 2,9/80) Endorses ANSI /ANS-3.1 (Draft 12/79) h' l The applicability of this guide / standard to other personnelin the Company organization is addressed in other sections of the UFSAR and the h l Technical Specifications of the individual nuclear facility. O The Company's Position Conformance Status Justification [, i The Operational Quality Assurance Program complies with Clarification and Attemative meet or exceed For Exception: NRC License Amendment this guide and standard, with one (1) exception, one (1) applicable guides and standards. Nos.142 and 125 dated December 4,1990 clarification and three (3) attematives. They are: for North Anna and NRC License o' Amendment Nos.151 and 148 dated (1) Exception: With regard to Section 4.2.2 of ANS 3.1 (Draft 12/79) titled Operations Manaaer. Paraaraoh C. December 31,1990 for Surry approved revisions to the Technical Specifications i Trainino: The Operations Manager will have or have held a granting relief from Section 4.2.2 of ANS 3.1 senior operator license. (Draft 12/79). The exception allows the 1 Superintendent - Operatione to hold or have 2 i (2) Clarification: With regard to the term " Bachelor's previously held a Senior Reactor Operator Degree" as used in the draft the following qualifications may License for the facility or a similar designed j ! be considered equivalent to a Bachelor's Degree: Pressun, zed Water Reactor plant. The g Supervisor Shift Operations will fulfill the n A. 6 years of applied engineering experience at a nuclear Operations Manager requirements of ANS y facility in the area for which qualification is sought, 3.1 (Draft 12/79). This change allows the x Supenntendent Operations to perform B. 6 years of operational or technical experience / training management functions and examine training related to engineering in nuclear power, and programs. C. In addition, experience and training requirements For Clarification: ANSI /ANS - 3.1 (Draft shallbe met as delineated. 12/79) does not provide a clear attemative to formal educational requirements, but does r provide guidance. This guidance was utilized to develop clarification to qualify non-degree holding personnel. i r 17.2-42 June,1986 ~.

TABLE 17.2.0 Standard, Requir: ment or Guide The Company's Position Conformance Status Justification hs (3) Allemative: With regard to Section 4.4.5 of ANS 3.1 For Altemative: ANSI /ANS 3.1 1978. E' (Draft 12/79) titled Quality Assurance. Paragraph 4.4.5 is considered to be h consistent with the Company experience m The Company's Nuclear Oversight organization Wi!I comply requirements which are delineated in other T with Paragraph 4.4.5 as originally stated in ANSI /ANS 3.1 - areas of this report. Further, the 1978 1978. requirement is considered more conservative than the Draft 12/79 ANS c: Requirement. (4) Altemative: With regard to Section 4.3.2, Suoervisors For attemative: ANSI Section 4.3.2; Not Reauirina NRC License. Paragraph b; Experience: At Individuals having the specified attemate the time of appointment to the position; the supervisor shall experience possess a working knowledge of h5ve 4 years experience in the craft or discipline he plant activities (e.g., operations, supervises or an equivalent number of years nuclear plant maintenance, I & C, health physics, etc.) 3,2 experience in a supervisory position with a Senior Reactor sufficient to perform a broad range of T Operator's License. supervisory functions. The individual's day-to-day interaction with the various plant 5 (5) Alternative: With regard to Section 5.3.3 of ANSI /ANS activities has provided him with an (n 3.1 (Draft 12/79) titled Trainino for Shift Technical Advisor understanding of how each activity is y with Bachelor Dearee without an NRC Senior Operator integrated into safe and effective plant License, Section 3). The Shift Technical Advisors will operations. His combination of SRO training observe control manipulations on the simulator as and plant experience is adequate to assure appropriate. that actions performed by individuals under his supervision are both technically correct and consistent with approved programs and procedures. For alterrantive: ANSI section 4.3.2 (Draft 12/79): The performing of control manipulations is not considered a Shift Technical Advisor task. The primary objective of Shift Technical Advisor simulator instruction is to demonstrate plant and cperator response to given cono~itions or events, not to develop expertise in control manipulations. r. 17.2-43 June,1986

TABLE 17.2.0 Standard, Requirement or Guide t j X i rn Reendatory Guide 1.26 -Quality Group Classifcation and Standards for Water, Steam, and Radioactrve Waste Containing Components of Nuclear Power 5 l Plants.* (Rev. 3,2/76). } The Company's Position Conformance Status Justification 2 l m The Operational Quality Assurance Program complies with Clarification meets or exceeds applicable The Nuclear Design Control Program w this guide with the following clarification: guides and standards. standards provides the methodology and m The Company does not use the specific A, B, C, and D level procedures for determining the quality O' classification system set forth in this guide. However, the classification of components. A specific Company followed the requirements of this guide in listing of these components is maintained in a document called the O-List. developing the list of structures, systems, and components for which the program is applicable. The specific listing of items to which the Operational Quality Assurance Program applies is described in detail in the O-List for Surry and North Zg. Anna Power Stations. to The Company also followed the requirements of this guide in C developing the ASME Section XI Class 1, 2 and 3 n, boundaries for the inservice inspection and testing program. These classes and boundaries are updated for each 10 year I inspection interval. 17.2-44 June,1986

_.__m TABLE 17.2.0 Standard, Requirement or Guide x Begulatory Guide 1.29

• Seismic Design Classification" (Rev. 3,9/78)

$e C The Company's Position Conformance Status Justification Z m-w The Operatior al Quality Assurance Program complies with Clarification meets or exceeds applicable Regulatory Guide 1.29 is primarily this guide with the following clarification: guides and standards. concemed with the design and construction G a phase of nuclear power plants. The O' See Generic Statement which prefaces this table with regard Company's clarification has been formulated to construction related guides, standards and instructions. to provide a means of translating design and construction criteria into guidance applicable to operating nuclear power facilities. 2 'D (l' Cn (D> T t t i 1 17.2-45 June,1986 l

l l l TABLE 17.2.0 Standard, Requirement or Guide Im Heaulatory Guide 1.30 "Ouality Assurance Requirements for the Installation, inspection, and Testing of instrumentation and Electric Equipment' 5 (8/72). Endorsec ANSI N45.2.4 - 1972. E O The Company's Position Conformance Status Justification 2. m er The Operational Quality Assurance Program complies with Clarifications and attematives meet or These clarifications to ANSI N45.2.4 - 1972 this guide with the following clarifications and attematives: exceed applicable guides and standards. are required to ensure that GA program B continuity is maintained. In actuality these (1) See Generic Statement which prefaces this table with clarifications have been extracted trom other r: gard to construction related guides, standards, and instructions. standards and guides and are considered more conservative. These clarifications also insure that only one standard or guide is (2) Section 2.1 - Plannina requirements, as determined by committed to for its applicable circumstance. st; tion management, will be incorporated into maintenance cnd modification procedures. 2 (~ (3) Section 3 - Eteconstruction Verification: (a) verification Cr is required only for the modification (s) (b) will be implemented C with the clarification that " approved instruction manuals" shall y' be interpreted to mean the manuals provided by the supplier y, T Es required by the procurement order. These manuals will not be reviewed and approved, per se, by the Company; (c) no special checks will be made by the person withdrawing a replacement part from the warehouse-equivalent controls are assured by compliance with ANSI N45.2.2 as set forth in this table; and (d) will be complied with, as determined by station management as part of the maintenance / modification program. 17.2-46 June,1986

TABLE 17.2.0 Standard, flequirement or Guide y. rr. The Company's Position Conformance Status Justification 5i Ul Secten 4 - InstaRahon instructons will be implemented h by inclusion, as determmed by station management, in the appropriate memtenance or modifcation procedure for safety - rv*' related items. Standard Company maintenance practices require that care be exercised in the six areas listed whether aj a procedure is reqcired or not. E! Secten 5.1 - Inspections: including subsections . 5.1.1, 5.1.2, and the first sentence n 5.1.3, will be implemented as set forth in Section 17.2.10 of the Operational QA Program. The inspection program will f incorpc ste, as determined by station management, those 2:; items listed in these subsections The remaining sentence 4 in 513 is covered in equi alent d t il in the Company's v ea commitmerW to ANSI N18.7, secton 5.2.6; the requirements cr - cs set forth in that commitment will be implemented in c- - ' m addihon to the requirements stated here. E> Section 5.2 - Tests including subsections 5.2.1 I [ through 5.2.3, will be implemented as set forth in Sectens 17.2.3 and.11 of the Operational QA Program. The test program will consider the elements outlined in this Section, cs determined by station management, when developing t.%, t requirements for inclusion in maintenance and modification procedures, in some cases, testing requirements may be met by post-installation surveillance testing in lieu of a special post-installation test. Where elements of Section 5.2 are not being met they shall be i documented and justified. r i i 17.2-47 June,1986 ,-----e-. e ..,..-.*w----..,-.-*.~+--_-_~._-.._.....,-+...-..m-e.: ~ m-.-m me....r...+~m..c.w4,i-..%. w.we, .4.,--...-#- i.wr%.w m..vw ww ,--.-.---,w +.--.-.c. c.,n-,+.....e

TABLE 17.2.0 Standard, Requirrement or Guide - .xm. - The Company's Position Conformance Status ~ Justification -i-E Secten 6 - Post Construction Verificationi is not - generally considered applicable at operating facilities because of the scope of work and the relatively short interval 'w between installation and operation. Where considered necessary by station management, the elements described -t .In this section will be used in the development and r implementation of inspection and testing programs as descreed in Sections 17.2.3,.10, and.11 of the Operational OA Program. l Sechon 6.2.1 -- Eauipment Tests

• The last paragraph of this section deals with taggmg and labeling. The Company will comply with an alternate last paragraph which reads:

2>' ?Each safety-related item of process instrumentation is identified with a ur'ique number. This number is utilized in [, instrument maintenance records so that current calibration c status, includog data such as the date of the calibration and n identity of the person that performed the calibration, can be .y ; readily determined Such information may also be contained x on tags or labels which may be attached to installed instrumentation *. Section 7 - Data Analvsis and EvaluatiDB: will be implemented as stated herein after adding the clarifying phrase "when determined by station management" at the beginnmg of that paragraph. l. L i i i I i 17.2-48 June,1986 . - - - - -.. - - ~.. -

TABLE 17.2.0 Standard, Requirement or Guide R-y"=*w h 1.33 " Quality Assurance Requirements (Operation)" (Rev. 2,2/78)- Endorses ANSI N18.7-1976. k 1 The Company's Position Conformance Status Justification E O The Operational Quality Assurance Program complies with Clarifications and attematives meet or. These clarifications are required to ensure ' z. this guide with the following clarifications arvi attematives: - exceed apphcable guides and standards. that QA program continuity is maintained. S to

1) Paragraph C.3 (" Subjects Requiring independent ~

i.e., that only one standard or guide is ' Review') of Regulatory Guide 1.33 (and Section committed to for a particular topic. b'. 4.3.4 of ANSI N18.7 - 1976 which it references) will be implemented as required by the apphcable nuclear facility Technical Specifications, Emergency Plan, Security Plan, and Fitness for Duty Program which i _ designate the areas sub ect to independent reviews. t

2) Paragraph C.4 (" Audit Program") of Regulatory Guide 2>

1.33 (and Section 4.5 of ANSI N18.7 - 1976 which it references) will be implemented as required by the j i applicable nuclear facility Technical Specifications, c Emergency Plan, Security Plan, Fitness for Duty n Program, and administrative controls which designate y the minimum areas to be audited The audit program is n further defined and will be implemented as required by the commitment to ANSI N45.2.12 as stated in Table 17.2.0 of the Operational Quality Assurance Program. Paragraph C.4.c of Regulatory Guide 1.33 (and ANSI N18.7 to which it references) will be implemented as clarified in Section 17.2.18 of the Operational Quality Assurance Program Topical Report. Specifically, the frequency for conducting audits of the performance, training, and qualifications of the facility staff may vary based on performance and the safety significance of the audited activity but will not be less frequent than biennial - (2 years).

3) Paragraph C.5a of Regulatory Guide 1.33 (and Section 4.4 of ANSI N18.7 which it references) will be implemented with the clarification that the Station Nuclear Safety and Operating Committee may perform this activity.

17.2-49 June,1986

TABLE 17.2.0 Standard, Requirement or Guide T In The Company's Position Conformance Status Justification 5 $G

4) Paragraph C.S.d of Regulatory Guide 1.33 (and Section 5.?.7.1 of ANSI N18.7 which it references) will be m

implemented by adding the clarifying phrase *When T determined by station management in front of the fourth sentence of the fifth paragraph. For modifications where these requirements are not considered practicable, a o-review in accordance with the provisions of 10CFR50.59 shall be conducted and documented.

5) Paragraph C.5.e of Regulatory Guide 1.33 (and Section 5.2.13.4 of ANSI N18.7 which it references) will be implemented subject to the same clarifications made for ANSI N45.2.2 elsewhere in Table 17.2.0 of the 2y-Operational OA Program.

y

6) Paragraph C.S.f of Regulatory Guide 1.33 (and Section k'

5.2.19.(2) of ANSI N18.7 which it references) will be m emplemented when detenmned by station management.

7) Paragraph C.S.g of Regulatory Guide 1.33 (and Section 5.2.19.1 of ANSI N18.7 which it references) will be implemented with the addition of the modifier "normally" after each of the verbs (should) which the Regulatory Guide converts to "shall." It is the Company's intent to fully comply with the requirements of this paragraph, and any conditions which do not fully comply will be documented and approved by station management personnel. In these areas, the reason for the exception shall also be documented. The documentation shall be retained for the same period of time as the affected preoperational test.

17.2-50 June,1986

TABLE 17.2.0 Strndard, Requiremert or Guide Trn The Company's Position Cordormance Status Justification S* ??-

8) Wdh regard to Section 4.2 of ANSI N18.7 - 1976 titled

'[t Program Da,maiori. Two aspects are addressed in this pe Section: audits and independent revievirs. The independent review program is implemented as required by the Tochtwcal Specifications of the individual nuclear facility. The Company audit program will be described in b' s ~ rm.wido se with and to meet the requirements of ANSI l. N45.2.12 as endorsed in Table 17.2.0 of the Operational l OA Program, the requirements of the individual nuclear i facility Technical Specifications, and Sections 17.2.16 i and 17.2.18 of the Operational QA Program. Z>

9). W!th regard to Section 4.3 of ANSI N18.7 - 1976 titled T

~ independent Review Process: The requirements of this (n Sechon, including all of its subparts, shall be met by c, n ! compliance with the Technical Specification requirements of the individual nuclear facility I +

10) With regard to Section 5.2.2 of ANSI 18.7 - 1976 titled Procedure Adherence. The third and fourth sentences

{ of the first paragraph of the Section address approval requirements -for temporary changes to procedures which do not change the intent of the approved l l procedure Adequate reviews will be provided by two members of the plant supervisory staff knowledgeable in the areas affected, one of which will hold a senior reactor operator license on the unit affected. Adequate reviews will be performed in accordance with Section 17.2.5 above and the Technical Specifications. .[ [ 5 17.2-51 June,1986-

L l~ (' TABLE 17.2.0 Standard, liequirement or Guide 'D : The Company's Position Conformance Status AMO.- -M -mJ 50 +

11) With regard to Section 5.2.7 of ANSI N18.7-1976 titled Maintenance and Modifir= Hon: Since some emergency h.

situations could arise which might preclude preplannmg to ! of aN actmhes, the Company will comply with an attemate

• [

to_ the first sentence in the second paragraph which _f :' reads: "Except in emergency or abnormal operating

b' conditions where immediate actions are required to protect the health and safety of the public, to protect equipment or personnel or to prevent the deterioration i

of plant conditions to a possibly unsafe or unstable level, maintenance or modification of equipment shall be y preplanned and performed in accordance with written. procedures. Where written procedures would be z! required and are not used, the activities that were = E-iC d shall be documented after-the-fact and '$'i receive the same degree of review as if they had been c1 proplanned." ni M

12) With regard to Section 5.2.7.1 of ANSI N18.7 - 1976 titled Maintenance Programs The Company win comply with the requirements of the first sentence of the fifth

.[ paragraph, when determined by station management. This clarification is needed since it is not always possible t to promptly determine the cause of the malfunction. In all l 4 cases, the Company will initiate proceedings to .i determine the cause, and will make such determmations promptly, when detemuned by station management.

13) With regard to Section 5.2.8 of ANSI N18.7 - 1976 titled i

Surveillance Testina and k=aar*vi Sche <W in lieu of -l a " master surveillance schedule," the following i requirement shall be complied with: "A surveillance ) testing schedule (s) shall be established reflecting the status of aN in-plant surveillance tests and inspections.'

14) With regard to Section 5.2.13.1 of ANSI N18.7 - 1976 I

titled Procurement Document Control: The words "the same degree of control" in the last sentence are replaced with *Engmeering remew." 17.2-52 June,1986 .i u..... _ __ _ __. _._ ;..

. _ _.. _ _.. - - = _.. _..... _ _ _ _.. _ _ _.. _. TABLE 17.2.9 Standard, Requirement or Guide I' m The Company's Position Conformance Status Justehcation 5 V_

15) With regard to Section 5.2.15 of ANSI Nt8.7 - 1976 titled The' biennial review requirement is deleted.

h Review Anoroval and Control of Procedures: The third The procedures upgrade program provides - re, sentence in paragraph three is interpreted'io mean: a rya ,_^.L and enecteve process for Applicable procedures, as determined by Station developing and revising procedures which Manage,M, shall be reviewed following an accidmd, an a encompasses the intent of the biennial g unexpectea transient, significant operator error or review. equipment malfunction. i The first sentence of the fourth paragraph is considered to be met via procedure reviews as described by i administrative procedures. Additional procedure review, cpproval, and control 2>- requirements / exceptions are discussed in Section 17.2.5 above. C 6

16) With regard to Section 5.2.17 of ANSI N18.7 - 1976 titled n-inspections Not all inspections will require generation of y

o a separate inspection report. Inspection requirements may be integrated into appropriate procedures or other documents with the procedure or document serving as the record. However, records of inspections will be identifiable and retrievable.

17) Wdh regard to Section 5.3.9 of ANSI N18.7 - 1976 titled Emergency Procedure As directed by the NRC, the Company follows a format for emergency procedures which is " symptom" based as opposed to " event" based as stipulated in Section 5.3.9.1. Since the Company has these " symptom" based procedures; " event" based procedures are not normally provided.

r -17.2-53 June,1986 l i ~ - - ~ ~ ' ~ - ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

TABLE 17.2.0 1 f Standard, Requwement or Guide T, nn > ~ The Company's Position Conformance Status Justification 5i

18) With regard to Section 5.3.9.2 of ANSI N18.7 - 1976

. 50. titled Events of Potenhal Emeroencv The Company will h$ interpret ilem (11) to mean the natural occurrences whch . oc - have been evaluated in the UFSAR for the individual - - 5e nuclear facility. 5..i 8'

19) With regard to Section 5.3.9.3 of ANSI N18.7 - 1976 titled Procedures for implementina Emeroency Plan:

The Company's NRC accepted Emergency Plan for each nuclear facility will be implemented in lieu of the r requerements in this Section. E .. 2 u-(DC I n: D l .l t I l 7 l i I I l l l [ i -17.2-54 June,1986 - I 1 -e-,, 2-m. ..m.. ...-ve.- ..~,..--..w<-.~.~.-----.--e..-,-- --.v-.--we, vw.---...- -r.=.s..-.,--w.--w.e,..wn,-mie4, .----,.cmw ...-e+

.i TABLE 17.2.0 Standard, Requwement or Guide - NRC P,asulatory GL@ 1.37 'Ouality Assurance Requirements for C1..in,y of Fluid Sy.i and Associated Components of Water-Cooled 'D Nuclear Power Plants"(3/73)- Endorses ANSI N45.2.1 - 1973. m' The Corppany's Position Conformance Status Jushhcation [, The Operational Quality Assurance Program coinplies with Clarifications meet or exceed applicable The four clarifications listed were generated re* this guide witn the following clarifications: guides and standards. to translate general guidance into exact _, i

1) The guide and standard are applicable to those areas of commstments, and to provide altemate gl}

means to pedorm routme tasks. the Quality Assurance Program addressing on-site cleaning of materials and components, cleanness 5 control, and preoperation cleaning and layup of fluid systems. i

2) With regard to Paragraph C.3 of Regulatory Guide 1.37:

4 The water quality for final flushing of fluid systems and 2 { associated components shall be at least equivalent to the quality of the operatmg system water except for the d oxygen and nitrogen content; but this does not infer that e chromates or other additives, normally in the system n water, will be added to the flush water. _y; T :

3) With regard to Paragraph C.4 of Regulatory Guide 1.37:

Expendable materials such as inks and related products, temperature indicating stick, tapes, gummed labels, wrapping materials (other than polyethylene), water soluble dam materials, lubricants, NDE penetrant materials and couplants, desiccants, and like materials which contact stainless steel or nickel alloy surfaces; shall not contain lead, zinc, copper, mercury, cadmium and other low melting point metals, their alloys or compounds as basic and essential c6i ; cal constituents. No more than 0.1 percent (1,000 ppm) halogens will be allowed where such elements are peachable or where they could be released by breakdown of the compounds under expected environmental conditions. i 17.2-55. June.1986 i .,.______ _. - - -. _ - -.. _ _ _. _ _ _ -. _ _ _.. _ _ _ _ _.. _ -... ~.. _ ~ -.. _ _.. .- m m.m.. m. ,m,___,......._a-,,.--..,,..,.-x._m .~.~ ..~.-.... m.-

TABLE 17.2.0 Standard, Requirement or Guide NRC.".egd:c-y Guide 1_37 " Quality Assurance Requirements for Cleaning of Fluid Sysimn. and Associated C0inpc6m46 of Water-Cooled -h Nuclear Power Plants * (3/73) - Endorses ANSI N45.2.1 - 1973. 5 E The Company's Position ' Conformance Status Justificatinn -{

4) With regard to Section 5 of ANSI N45.2.1 '1973 titled rc E

Installation Cleanino: The recommendation that local rusting on corrosion resistant alloys be removed by mechanical methods is interpreted to mean that local g o rusting may be removed mechanically, but the use of other removal means is not precluded as determined by Engineering. 2 e >T U' Cn T r 17.2-56 June,1986

TABLE 172.0 Standard, Requirement or Guide LJRC Regulatory Guide 1.38 " Quality Assurance Requirements for Packaging Shipping, Receiving, Storage, and Handling of items for Water-Cooled Im Nuclear Power Plants" (Rev. 2,5/77) - Endorses ANSI N45.2.2 - 1972. 5W The Company's Position Conformance Status Justification h to The Operational Quality Assurance Program complies with Clarifications and altematives meet or The clarifications in this section are C this guide with the following clarifications and attematives: exceed applicable guidos and standards. proposed only to translate general guidance a

1) With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled into specific requirements.

E O' Plannina: (First sentence.) The specific items to be The proposed attematives are provided to governed by the Standard shall be identified in reflect current Company practices which are Administrative Procedures. distilled from over ten years of experience gained at operational nuclear facilities.

2) With regard to Section 2.3 of ANSI N45.2.2 - 1972 titled Results: The specific methods for performing and z.

documenting tests and inspections are given in Sections 17.2.10 and 17.2.11 of the Operational OA Program. The requirements in these Sections will be implemented m in lieu of the general requirements here. c. m g

3) With regard to Section 2.7 of ANSI N45.2.2 - 1972 titled I

Clarification of items: The Company may choose not to explicitly use the four level classification system. However, the specific requirements of the Standard that are appropriate to each class are applied to the items suggested in each classification and to similar items as determined by station management. 4) With regard to Section 3.2.1 of ANSI N45.2.2 - 1976 titled Level A Items: As an attemate to the requirements for packaging and containerizing items in storage to control contaminants (items (4) and (5)), the Company may choose 17.2-57 June,1986

m.. - _.. - t l TABLE 17.2.0 Standard, Requirement or Guide i r; - The Company's Position Conformance Status Justhh m_ a storage atmosphere which is free of harmful h; contaminants in concentrations that could produce damage to stored items as determined by station te C management. Similarly (for !!em (7)) the Company may obviate the need for caps and plugs, as determined by station management, with an appropriate storage . 'b ' atmosphere, and may choose to protect weld-end preparations and threads by controlling the manner in which the items are stored. These clarifications apply whenever items ' (4), (5) or (7) are subsequently referenced and to Section 3.5.1 titled Caos and Pluas and Section 3.4 titled MelhoduTrastryat!nn z-S. With regard to Section 3.2.3 of ANSI N45.2.21972 titled Level C ltems: (Subpart 2) states *ltems shall be t - ! packaged with a waterproof enclosure...,* as an c altemative, the company may choose appropriate - y. packagmg when the storage environment prevents y i harmful contaminants in concentrations that could I produce damage to stored items as determined by Station management. 6) With regard to Section 3.3 of ANSI N45.2.2 - 1972 titled Cleaning: (Third sentence) the Company interprets

• documented cleaning methods" to allow generic cleaning procedures to be written which are implemented, as hecessary, by trained personnel. Each particular cleaning operation shall have an individual cleaning procedure or reference a generic procedure.

The generic procedures will specify methods of cleaning or which type (s) of solvent may be used in a particular apphcation. 17.2-58 June,1986 ,.-.a 4--%..,~.-,,,...-m, -m--.s .,.,,,.,.,.,,,3.em.e,,.,.w.m_, .. w....e ,#c.,m,,,.,.,. ._,-,_-.#.m.. ec.,.4..e..., ,.e.

m t TABLE 17.2.0 t Standard, Requirement or Guede r. rr : The Company's Position Conformance Status Justification 5-5G

7) With regard to Section 3.4 of ANSI N45.2.2 - 1972 titled Methods of Preservation: (First sentence) the Company k

- will comply with these requirements subject to the m. C clarifications of Section 3.2.1, (4) and (5) above, and the defimhon of the phrase " deleterious corrosion" to mean that corrosion which cannot be subsequently removed b. and which adversely affects form, fit or function.

8) With regard to Section 3.6 of ANSI N45.2.2 - 1972 titled Barrier and Wran Material and Da==v ants: This section requeres the use of nonhalogenated materials in contact with austenitic stainless steel. Refer to Regulatory Guide 1.37 above for the Company position.

2g;

9) With regard to Section 3.7.1 of ANSI N45.2.2 - 1972 titled e

Containers: Cleated, sheathed boxes may be used up c, to 1,000 lbs. rather than 500 lbs. as specified in 3.7.1(1). n This type of box is safe for, and has been tested for, loads up to 1,000 lbs. Other national standards allow this I' (see Federal Specification PPP-B-601). Special qualifications testing shall be required for loads above 1,000 lbs. i

10) With regard to Section 3.7.2 of ANSI N45.2.2 - 1972 titled Crates and Skids Skids or runners will normally be used on containers with a gross weight of 100 lbs. or more. Skids or runner will normally be fabricated from 4 x 4 inch nominal lumber size, minimum, and laid flat except where this is iiispien,E si because of the small dimensions of the container. If forklift handling is required, minimum floor clearance for forklift tines will be provided i

r r 17.2-59 June,1986 .~..

TABLE 17.2.0 Standard, Requirement or Guide I The Company's Position Conformance Status Justification 5' rn $E'

11) With regard to Sections 4.3,4.4 and 4.5 of ANSI N45.2.2

- 1972 titled, respectively, Precautions Durina Loadina h. and Transit. IdentificMian and Markina. and'Shioment ' to* from Countries ' Outside the United States: The Company will comply with the requirements of these Sections subject to the clarifications taken to other

g S6ctions which are referenced herein.

12) With regard to Section 5.2.1 of ANSI N45.2.2 - 1972 titled Shinoina Damaae inspection: Warehouse personnel will norrrally visually scrutinize incoming shipments for damap9 of the types listed in this Section; 2

this activity is not necessarily performed prior to unloading. Since all required items receive the item inspection of Section 5.2.2, separate documentation of (n the Shipping Damage inspection is not necessary. c. Release of the transport agent after unloading and y signing for receipt of the shipment may be all of the y-I- action taken to document completion of the Shipping Damage Inspection. Any rivin uriformance noted will be documented and dispositioned as required by Section 17.2.15 of the Operational OA Program. The person performing the visual scrutiny during unloading is not considered to be performing an inspection function as defined under Regulatory Guide 1.74; therefore, while he will be trained to perform this functon he may not necessarily be certified (N45.2.6) as an Inspector. 17.2-60 June,1986

TABLE 17.2.0 Standard, Requirement or Guide m rti The Company's Posit;on Conformance Status Justification 5 10

13) With regard to Section 5.2.2 of ANSI N45.2 2 - 1972 h

titled Item Insoection: The second division of this to subsection requires six additional inspection' activities if an item was not inspected or examined at the source. Procurement Engineering shall determine and document the extent of receipt inspection based on E' consideration of Paragraph 5.2.2.

14) With regard to Section 5.4 of ANSI N45.2.2 - 1972 titled Status lrA21;. a System: The Section states in part

" Tags shall be securely affixed to the items and displayed in an area that is readely accessible." As an attemative. the company may choose to use Labels or Tags to 2> identify stems. 3, Tu)

15) With regard to Section 6.1.2 of ANSI N45.2.2 - 1972 k

titled Levels of Storage: Subpart (2) is replaced with the fciiv.;. g: y 2 (2) Level B items shall be stored within a fire resistant, weather-tight, and well ventilated building or equivalent enclosure in which measures have been takers against vandalism. This building shall be situated and constructed so that it will not normally be subject to flooding; the floor shall be paved or equal, and well drained. If any outside waters should come in contact with stored equipment, such equipment will be labeled or taggec nonconforming, and then the nonconformance document will be processed and evaluated in accordance with Section 17.2.15. Items shall be placed on pallets, shoring or shelves to permit air circulation. The building shall be provided with uniform heating and temperature control or its equivalent to prevent condensation and corrosion. Minimum temperature shall be 40*F and maximum temperature shall be 140 F or less if so stipulated by a manufacturer. 17.2-61 June,1986

TABLE 17.2.0 Standard, Requirement or Guide 27 The Compan1(s Position Conformance Status Justification - . 5-rn W

16) With regard to Section 6.2.1 of ANSI N45.2.2 - 1972 titled Access to Storage Areas-llems which fan withen the level D classification of the standard will be stored in an te e-area which may be posted to limit access, but other positive controls such as fencing or guards will not normally be provided.

E'

17) With regard to Section 6.2.4 of ANSI N45.2.2 - 1972 titled Storace of Food and Ancae: "d items: The sentence is replaced with the following "The use or storage of food, and dnnks in any storage area shall be controlled and shall be limMed to designated areas where such use or storage is not deletenous to stored items 2 ;-

> t where station management deems appropnete j'l

18) With regard to Sechon 6.2.5 of ANSI N45.2.2 - 1972 ki titled "-- was to Pr_.

.; E.a. ci, of A..;.T =:=* The sentonce is replaced with the following *Extemunators $'f in i or other appropnete measures shall be used to control animals to minimize possible contamination and mechamcel damage to stored malenal." } f ^ I L L l ? -i 17.2-62 June,1986- { t w w.e.. .<-%.,w+m.-v.--., _-w-w---~~.-,__. w=..s m. ~ _ +, - =.. m m -..-mw.m-----#...+- ,. ~. -.-.-v -r.---.. .-...-.-.~,.__-..---o---i ...m.u-.-m---

TABLE 17.2.0 StIndard, Requwement or Guide 37 The Company's Position Conformance Status - 'Justificah Ui

19) With regard to Section 6.3.4 of ANSI N45.2.2 - titled

' h. Identification: The section states "All items and their contamers shall be plainly marked so that they are easily - to - e -identified without excessive handling or unnecessary opening of crates and boxes." The company shall t substitute "All items (or, if in containers, their containers) shall be plainly marked so that they are easily identified without excessive handing or unnecessary opening of ' crates and boxes." - 20) With regard to Section 6.4.2 of ANSI N45.2.2 - 1972 titled Care of items: The following altematives are provided for the indicated subpart: h ,~ t) (5) " Space heaters in electrical equipment shall be ^ energized unless a documented engineering 5-evaluation determmes that such space heaters are m not required." >x (6)

• Large (greater than or equal to 50HP) rotating electrica! equipment shall be given insulation resistance tests on a scheduled basis unless a documented engineering evaluation determines that such tests are not required."

t (7) "Withm thirty days of having been placed in storage, rotating equipment weighing over approximately 50 pounds shall be evaluated by engineering personnel to determine if shaft rotation in storage is required: The results of the evaluation shall be documented. If rotation is required, it shall be [ i performed at specific intervals, be documented, and be conducted so that parts receive a coating of lubrication where applicable and so that the l shaft does not come to rest in the same position l occupiad prior to rotation. For long shafts or heavy + equipment subject to undesirable bowing, shaft l orientation after rotation shall be specified and j obtained. b 17.2-63 June,1986 _e,,w g 9 7,3_,,ry,,me,.,.m., ,_,y.., w. m_., -.,m-- ,,,m.,_ m_,.., ...m.,, ,_,.,,m, yy..,,.._,,.py,, - ,,.m, ,,m,.,,w,,_.,,,,,g.,,

= _. TABLE 17.2.0 Standard, Requirement or Guide 3 The Company's Position Conformance Status Justification ~E-U

21) With regard to Section 6.5 of ANSI N45.2.2 - 1972 titled

( Removal of items from Storaoe: The Company does not consider the last sentence of this Section to be {e applicable to the operations phase due to the relatively short period of time between installation and use. The first sentence of the Section is replaced with: "the Company will develop,- issue, and implement a procedure (s) which cover (s) the removal of items from storage. The procedure (s) will assure that the inspection status of all material issued is known, controlled and appropriately dispositioned."

22) With regard to Section 6.6 of ANSI N45.2.2 - 1972 titled Storaos Records: The Company will comply with the h--

T requirements of this Section with the clarification that, for record purposes, only the access of personnel not specihcally authorized such by station management into S-U indoor storage areas shall be recorded. Unloading or pick-up of material shall not be considered " access. *nor y shall inspection by maintenance and modification inspection personnel or audit by Nuclear Oversight personnel, authorized contractors, NRC or other regulatory agents, nor shall tours by non-employees. 4 17.2-64 June,1986

m TABLE 17.2.0 St ndard, Requiremerd or Guide 1 1rr + The Company's Position Conformance Status Justification 5 V;

23) With regard to Section 7.3 of ANSI N45.2.2 - 1972 titled h

Ho sting Eauement Rerating of hoisting equipment will y. be considered only when absolutely necessary. Prior to -- performmg any lift above the load rating, the equipment manufacturer must be contacted for his approval and direction. The manufacturer must be requested to E', supply a document granting approval for a limited [ number of lifts at the new rating and any restrictions involved, such as modifications to be made to the i equipment, the number lifts to be made at the new rating, and the test lift load. At all times, the codes goveming rerating of hoisting equipment must be observed. 2 i t T i If rerating hoisting equipment is necessary and the Company cannot or does not contact the equipment 5 manufacturer as described above, the test weight used VJ in temporarily rerating hoisting equipment for special lifts i will be at least equal to 110% of the lift weight. A dynamic i load test over the full range of the lift using a weight at least equal to the lift weight shall be performed I i

24) With regard to Section A3.9 of ANSI N45.2.2 - 1972 titled Marking: As an attemative to the requirements in Subpart 4, the Company may choose to mark containers i

with waterproof ink or paint with legible characters. . Additionally, the requirements of Subpart 6 shall only apply to shipment of items. Items in storage shall be affixed with labels or tags with sufficient information to preserve the item's identity. { f I 1 ~ 17.2-65 I June,1986 i

. _n h TABLE 17.2.0 Standard, Requirement or Guide NBC Regulatgry Guide _,139 " Housekeeping Requirements for Water-Cooled Power Plants * (Rev. 2. 9/77) - Endorses ANSI N45.2.3 - 1973. xm5 The CompanVs Position Conformance Status Justification The Operational Quality Assurance program complies with Clarifications meet or exceed applicable These clarifications are proposed to perform y 2 this guido with the following clarifications: guides and standards. a twofold function. See Generic Statemant which prefaces this table. A) To translate construction criteria to B

1) Additional clarifications for ANSI N45.2.3 - 1973 are operating plant oriented O'

Indicated below for specific Sections. requirements. B) To reflect experience gained at Section 2.1 Plannino: The Company may choose i operational nuclear facilities. not to utilize the five-level zone designation system, but will utilize standard janitorial and work practices to maintain a level of cleanliness as delineated in the it should be noted that where the Company 2 Company's Accident Prevention Manual which is does not specifically implement equivalent to the requirements contained in the requirements as delineated herein, the referenced section. proposed altematives are reflected in written C procedures and policy and contain all n Cleanliness will be maintained, consistent with the necessary elements to assure quality is y; maintained. work being performed, so as to prevent the entry of I foreign materialinto safety-related systems. This will include, as a minimum, documented cleanliness inspections which will be performed prior to system closure. As determined by station management, (e.g., the size of the opening would permit entry of the tools being used) control of personnel, tools, equipment, and supplies will be established when the reactor system is opened for inspection, maintenance or repair. Additional housekeeping requirements will be implemented as required for control of radioactive contamination. 17.2 66 June,1986

... - ~. _ _ TABLE 17.2.0 St:ndard, Requirement or Guide ' Il m The Company's Position Conformance Status - Justification 5 m h Section 2.2 - Procedures and instructions: Appropriate procedures will be written and implemented. to, Sechon 3.2 - Control of Facihbes The Company may choose not to utilize the five-level zone designation system, but will utilize the Company's Nuclear Operations Industrial Safety & Health Accident Prevention Manual to maintain a level of cleanliness commensurate with the requirements of this section. Cleanliness will be maintained, consistent with the work bemg performed, so as to prevent the entry of 2 I foreign materialinto safety-related systems. This will . include, as a minimum, documented cleanliness 3 inspections wtuch will be performed prior to system c_ n closure. As necessary, (e.g., the size of the opening would permit entry of the tools being used) control of y personnel, tools, equipment, and supplies will be n established when major portions of the reactor system are opened for inspection, maintenance or repair. Additional housekeeping requirements will be implemented as required for control of radioactive 7 contamination. Section 3.3 - M :;-leis and Eautoment: See Generic Statement which prefaces this table. Section 3.4 - Construction Tools. Suoolies and Equipment See Generic Statement which prefaces this table. t Section 3.5 - Surveillance. Inspections and Examination: Subparagraph (1) See Generic Statement which prefaces this table. 17.2-67 June,1986

~ TABLE 17.2.0 St ndard, Requirement or Guide 'W NRC ResiAsiciv Guide 1.58 - Qualification of Nuclear Power Plant inspection, Examination and Testing Personnel" (Rev.1,9/80) - m Endorses ANSI N45.2.6 - 1978. I $G. oZ The Company's Position Conformance Status Justification toe The Operational OA Program complies with this guide with Clarifications meet or exceed apphcable The proposed clarifications reflect Company e the following clarifications: guides and standards. piacikms and are provided here to assure g that OA program continuity with other

1) With regard to Section 1.2 of ANSI N45.2.6 - 1978 titled delineated standards and guides is Anolicability: The third paragraph requires that the maintained.

Standard be used in conjunction with ANSI N45.2; the l Company no longer specifically commits to ANSI N45.2 in the Operational OA Program. The fourth paragraph requires that the Standard be imposed on personnel Z other than Company eiripic,;;;;; the applicability of the Standard to suppliers will be documented and applied, (n as appropnate, in the procurement documents for such C suppliers. m en

2) With regard to Section 1.4 of ANSI N45.2.6 - 1978 titled T

Defmitions Definitions in this Reg. Guide 1.58 which are i not included in ANSI N45.2.10 will be used: all definitions which are included in ANSI N45.2.10 will be l used as clarified in the Company's commitment to Regulatory Guido 1.74.

3) With regard to Section 2.5 of ANSI N45.2.6 - 1978 titled Physical The Company willimplement the requirements i

of this Section with the stipulation that, where no special j physical characteristics are required, none will be specified. The converse is also true: If no special physical requirements are stipulated by the Cumpany, none are considered necessary.

4) With regard to Section 3.1 of ANSI N45.2.6 - 1978 titled General The Company willimplement the requirements of this Section with the stipulation that Level 111 inspectors are not a specific requirement of the Company's inspection program.

17.2-68 l June,1986 i ~

TABLE 17.2.0 Simdard, Requirement or Guide NRC Reculatory Guide 1.64 "Quakty Assurance Requirements for the Design of Nuclear Power Plants" (Rev. 2,6/76)- Im Endorses ANSI N45.2.11 - 1974. h1 O The Company's Position Conformance Status Justification Z m u> The Operational Quality Assurance Program complies with Clarification meets or exceeds apphcable Clarification is considered an acceptable this guide with the following clarification: guides and standards. attemative to that proposed in the g See Generic Statement which prefaces this table. referenced standard in that all quality elements have been maintained. 1) With regard to Paragraph C.2(1) of Regulatory Guide 1.64: ll in an exceptional circumstance the designers immediate Supervisor is the only technically qualified individual available, this review may be conducted by the Z Supervisor, providing that: (a) the other provisions of the Regulatory Guide are satisfied, and (b) the (_ justification is individually documented and approved in en advance by the Supervisors management, and (c) c Nuclear Oversight audits cover frequemy and y. effectiveness of use of Supervisors as design verifiers to y I guard against abuse. ~ 17.2-69 June,1986

.u TABLE 17.2.0 Simdard, Requirement or Guide NRC F= "^ w G@ta 1.74 " Quality Assurance Terms and Definitions" (2/74)- Endorses ANSI N45.2.10 - 1973. x! In, 5 The Company's Position Conformance Status Justification {' 2 The Operational Quality Assurance Program complies with Clarification meets or exceeds applicable The clarifications illummate actual Company te ; this guide with the following clarification: guides and standards. - QA program practices and are considered to enhance the Company's cuirivii;^.. wiit to

1) The Company reserves the right to define additional quality practices gf words or phrases which are not included in this Standard.

Such additional definitions will be documented in f appropriate procedures and/orin attachments / appendeces to Nuclear Oversight procedures or in ? sections of the Operational QA Program. l'

2) The Company intends for inspections and tests to be performed in accordance with the Operational QA Z

Program by personnel certified as required by that [* . program and for activities defined by

• Inspection
• and

' " Testing" in ANSI N45.2.10. Appropriate references to cj n i the organization which will perform the activity or quality procedures to be used for performmg the activity will be 7! I-made. If such references are not made, inspections or x, tests are to be considered under the followmg definition: i " Inspection" (when used to refer to activities that are not l performed by certified personnel) - Examining, viewing closely, scrutinizing, looking over or otherwise checking activities. Personnel performmg these functions are not necessarily certefied to ANSI N45.2.6. However, station management through prior procedure review shall determme the appropriate personnel qualifications and '7 reportmg relationships. " Testing" (when used to refer to activities that are not performed by certified personnel) - completion of T predetermined procedure steps which determine or verify the capability of an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions. Personnel performing these steps may D91 necessarily be certified to ANSI N45.2.6. If the completion of the 17.2-70 l June,1986 -. _. _. _..... _ _ _. _ _ ~ _. _. _.,,. - - -. ~. -.. -... _... _. _ _ _ _.. _... _.. _ _ _ _.. - -. _.. _.. _. _ - -.. _.., _ -... _... _ _ _. _ _ _. ~. _ _..

T TABLE 17.2.0 Standard, Requirement or Guide 'D The Company's Position Conformance Status Justification 5 m 50 procedural steps utilizes skills and knowledge which they have already obtained from applicable training and h experience based programs or formal education g, to programs. Station management through prior procedure review shall determine the appropriate personnel qualifications and reporting relationships. y m

3) The definition of " procurement documents" will be that This revised definition of " Procurement provided in ANSI N45.2.13, as augmented by Regulatory Guide 1.74 and the definition provided in 10 Documents" acknowledges the definition CFR 21.3(k). Specifically, the Company will utilize the provided in 10 CFR 21.3(k). Additionally, the term " contractually binding" is removed to following compound definition: " Documents that identify and define the requirements which facilities or basic reflec' that procurement records retained in 2

components must meet in order to be considered accordance with the Company's commitment y acceptable by the purchaser. Procurement documents to ANSI N45.2.9 may not necessarily be the T* may include purchase requisitions, purchase orders (i.e., original or a copy of the contractually binding Receiving Reports), drawings, contracts, letters of intent, document if the pertinent information is 5 work orders, proposals and their acceptances, electronic available threagh one or more of the (n documents ;isted in the revised definition, y procurement system documents, and specifications or instructions which are used to define requirements for purchase. Supplier-generated documents and records which were required to be submitted to the Company or to be retained by the supplier are also examples of procurement documents."

4) " Program Deficiencies" (Not defined in ANS! N45.2.10, but used and defined differently in ANSI N45.2.12) -

Failure to develop, document or implement effectively any applicable element of the Operational QA Program.

5) " Quality Assurance Program Requirements"(Not defined in ANSI N45.2.10 but used and defined differently in ANSI N45.2.13) - Those individual requirements of the Operational OA Program which, when invoked in total or in part, establish the requirements ci the quality assurance program for the activity being controlled.

Although not specially used in the Operational OA Program, ANSI N45.2 may be imposed upon the Company's suppliers. 17.2-71 June,1986

l, TABLE 17.2.0 St ndard, Requirement or Guide 3' ' The Company's Position Conformance Status Justification S ;' tv E

6) With the exception of the' time intervals defined by the station Technical Specifications, the following definitions

.h, shall be applied when defining time intervals for other

g; activities-e!

t'! Weekk atleast once per 7 days 1 Monthly at least once per 31 days t Guartarty or every 3 months at least once per 92 days Samianr==mv or =rs 6..s.;;. at least once per 184 z.! days >^ m-; Every 9 months: at least once per 276 days Cn Yearly or annually at least once per 366 days 11 Ehennial(2 years): at least once per 732 days { Tnennial(3 years) at least once per 1098 days The above time hiervals may be extended by up to 25%. 4 1 I I ~ a 17.2-72 ' June,1986

i TABLE 17.2.0 Standard, Requirement or Guide NRC Reoulatory Guide 1.88 " Collection, Storage and Maintenance of Ncclear Power Plant Quahty Assurance Records" (Rev. 2,10/76 - [ Endorses ANSI N45.2.9 - 1974). $G The Company's Position Conformance Status Justification O The Operational Quality Assurance Program complies with Clarifications and attematives meet or These proposals are the results of Tre this guide with the following clarifications and alternatives: exceed applicable guides and standards, experience gained at operating nuclear

1) With regard to Section 3.2.2 of ANSI N45.2.9 - 1974 titled facilities for over a decade. As with all guides g

index The phrase "an index" is clarified to mean a and standards, additional clarity is sometimes os co!!ection of documents or indices which, when taken required. Further the attemative (6) presented herein reflects the "as-built" together, supply the information attnbuted to "an index" in the standard. condition of the Company's records storage facilities. These facilities were constructed The specific location of a record "within a storage area" prior to any regulatory position being may not be delineated (e.g., The specific location within delined, and, at the time of construction, 7 a computer record file may not be constant. Further, the were considered more than adequate to Company may utilize a computer assisted random access assure permanent records retention. The y filing system where such location could not be readily discrepancies which might exist between " documented", nor would such a location be " relevant"). current guides and standards and "as-built" k The storage location will be delineated, but where file conditions are more than compensated for in locations change within time, the cpecific location of a by other more stringent measures such as, y record within that file may not always be documented. a) constant surveillance of the facility both

2) With regard to Section 4.2 of ANSI N45.2.9 - 1974 titled by monitoring devices, security patrols, and fire inspections, and Timeliness: The Company's contractual agreement with its contractors and suppliers will constitute fulfillment of the requirements of this Section.

b) Permanentlyinstalled dedicatad fire suppression apparatus.

3) With regard to Section 5.4 of ANSI N45.2.9 - 1974 titled Preservation: The following clarification is substituted for the current subsection 5.4.2: " Records shall be stored in enclosed containers, cabinets or other comparable document storage hardware."

17.2<73 Juno,1986

TABLE 17.2.0 - Standard, Requirement or Guide "D m-The Company's Position Conformance Status Justification { The following clarification is substituted for the current 6 subsection 5.4.3 " Provisions shall be made for special z to processed records (such as radiographs, photographs, negatives, microfilm and magnetic media) to prevent damage as appropriate to the record type and will a address the manufacturer's recommendations." b'

4) With regard to Section 5.5 of ANSI N45.2.9 - 1974 titled Safekeepina: Routine general office and nuclear site security systems and access controls are provided.

5) With regard to Section 5.6 of ANSI N45.2.9 - 1974 titled Facility. Records shall be forwarded to the appropriate z

records storage facility promptly after comp'etion when g required processing and reviews have been completed. m cn Paragraph 4, subsection 3 is clarified to require a two-hour minimum fire rating to be consistent with the 1979 I version of the Standard and NRC Criteria for Record Storaos Facilities (Guidance - ANSI N45.2.9, Section 5.6) issued 7/15/79. Paragraph 4, subsection 9 is clarified to read: "No pipes or penetrations except those providing fire protection,

lighting, temperature / humidity

control, or communications are to be located within the facility and they shall comply with a minimum two-hour fire protection rating.

1 17.2-74 June,1986

_.m. m 1 TABLE 17.2.0 Standard, Requirement or Guide D-The Company's Position Conformance Status Justification . m: 5 m._.

6) The Surry Power Station facility conforms to ANSI N45.2.9 h,

a 1974 as clarified in this Table except that it is rated at- ~ approximately 2 hours; doors, frames, and hardware are y - e three-hour rated. This facility is considered to meet the ' intent ~ of ANSI N45.2.9 and provides adequate protection for records. E~" The North Anna Power Station Records Vault meets the intent of Chapter 3 of NFPA No. 232-1975, subpct to . the followmg provisions: r a) The file room is constructed with a merumum fire rating - 7i of two (2) hours t D b) Heating, cooling and ventilation for the file room is by means of a forced air system, with all fans, filters, and heating and cooling elements located in an n' M' equipment room which is extemal to the file room. Ducts for this system are located on the ceiling of the file room and are provided with the standard door dampers with a minimum rating of two (2) hours where they penetrate the file room barrier to other areas of the building. c) The file room is provided with an early warning fire l detection system and automatic fire suppression l system. A protective signaling system is provided, with a remote alarm located at a constantly attended station. l d) Ti/srs service is provided to the file room, with the wire penetration constructed and sealed in i accordance with NFPA No. 232-1975. l i l-l- 17.2-75 June,1986 x m -.-...m ,m ,,..-.,m,. s,,,,,,mO,,.., i m. .,,,.m, x.,

TABLE 17.2.0 St ndard, Requirement or Guide x. m The Company's Position Conformance Status Justification 5 E e) All records stored in the file room are stored in metal h cabinets or rolling file shelves, which are arranged to provide adequate access and aisleways. ' Work not m S directly related to the storage, retrieval or auditing of records is not allowed in the file room. Smoking, eating, and drinking is prohibited in the file room. g c) f) A wall divides the file room into two sections, with one section used as a file room and the other section used for microfilming of records and/or supply storage. The dividmg wall has a rnerumum fire rating of two (2) hours, including the fire door dampers in the duct penetrating the wall. 2>- T The North Anna Power Station Training Center Vault meets the intent of Chapter 3 of NFPA No. 232-1975, subject to the following provisions: k. g a) The file room is constructed with a minimum fire rating of two (2) hours. b) Heating, cooling and ventilation for the file room is by means of a forced air system, with all fans, filters, and heating and cooling elements located in an equipment room which is extemal to the file room. Ducts for this system are located above the ceiling of the file room and are provided with accordion dampers with a minimum rating of two (2) hours where they penetrate the file room barrier to other areas of the building. c) The file room is provided with an early warning fire detection system and automatic fire suppression system. A protective signaling system is provided, with a remote alarm located at a constantly attended station. 17.2-76 June,1986

TABLE 17.2.0 Standard, Requirement or Guide Il The Company's Position Conformance Status Justification 5 m 9 d) Telephone service is provided to the fi!e room, with the wire penetration constructed and sealed in h-accordance with NFPA No. 232-1975. ge e) All records stored in the file room are stored in metal I' cabinets, which are arranged to provide adequate 8 access and aisleways. Work not directly related to the storage, retrieval or auditing of records is not allowed in the file room. Smoking, eating, and drinking is prohibited in the file room. The Innsbrook Technical Center's Vital Records Vault for nuclear records conforms to the requirements of Section 5.6 2 of ANSI N45.2.9 - 1974 without exceptions, >g The Surry Training Center training records vault (Main Building) conforms to the requirements of section 5.6 ANSI S N45.2.9 - 1974 without exceptions. u>y The Surry Training Center training records vault (Simulator Building) conforms to the requirements of section 5.6 ANSI N45.2.9 - 1974 with the following exceptions: a) The door is a UL-rated three-hour fire door. b) The records storage vault is constructed with a minimum fire rating of two (2) hours. 17.2-77 June,1986

TABLE 17.2.0 Stendcrd, Requirement or Guide - NRC.~e E-v Gt=rta 1.94 " Quality Assurance Requirements for Installation, iiwi,~un, and Testing of Structural Concrete and Structural Steet k Dunng the Construction Phase of Nuclear Power Plants * (Rev 1,4/76) - Endorses ANSI N45.2.5 - 1974. 5 $9 .O The Company's Position Conformance Status Justification 2 m to The Operationai Quality Assurance Program complies with Clarification meets or exceeds applicable The proposed clarification is used to this guide with the following clarification-guides and standards. translate construction oriented documents g See Genenc Statement which prefaces this table. to operational regulations.

1) With regard to Section 2.5.1 of ANSI N45.2.5 - 1974 titled Selection: The Company complies with the requirement set forth in the first paragraph of this Section for selection of measuring and test equipment on the basis of sufficient accuracy to determine conformance to the 2>

standard's requirements: This is accunviished without the use of calibrated balances or volumetric buckets. C h> 31 17.2-78 June,1986- ,. ~. -. _ -. _ _. _.. _ _..., _.. _... - _

l TABLE 17.2.0 Standard, Requirement or Guide NRC Reaulatorv Guide 1.116 "Quahty Assurance Requirements for Installation, inspectivii and Testing of Mechanical Equipment and Systems" (Rev. O-R,6/76) - Endorses ANSI N45.2.8 - 1975. 5 Lao The Company's Position Conformance Status Justification 2 g. The Operational Quality Assurance Program complies with Clarification meets or exceeds apphcable This clarification is proposed as a this guide with the following clarification: g'Jdes and standards. constructen to operations device. ,g' See Generic Statement which prefaces this table. 2> l Tfn Cn (n. 3 I 17.2-79 June,1986

E TABLE 17.2.0 Standard, Requirement or Guide NRQ I.e ' ^ -v Guide 1.123 " Quality Assurance Requirements for Control of Procurement of items and Sennces for Nuclear Power Plants" h* (Rev.1,7/77) - Endorses ANSI N 45.2.13 - 1976. $s The Company's Position Conformance Status Justification The Operational Quality Assurance Program complies with Clarifications meet or exceed apphcable Clarifications contained herem reflect actual m this guide with the following clarifications: guides and standards. Company OA Program piin,t;cm. Further, E'

1) With regard to Section 1.3 of ANSI N45.2.13 - 1976 titled these proposals assure continuity with the QA Program and other regulations or Definitions:

With two exceptions (Procurement guxles, and are considered to enhance the Document and Quality Assurance Program aforementioned program. i i. Requirements) defirwhons in this Standard which are not included in ANSI N45.2.10 will be used; all definitions which are included in ANSI N45.2.10 will be used as clarified in the Company's commstment to Regulatory Guide 1.74. The two exceptions are defined in Table zl 17.2.0 under Regulatory Guide 1.74. T - in i t

2) With regard to Section 1.2.2 of ANSI N45.2.13 - 1976 Cm titled Purchasers Responsduhhes: Item c is modified as follows: " Evaluation of the suppliefs OA program shall I

be conducted as determmed by Nuclear Oversight based l on the complexity and use of the procurement."

3) With regard to Section 3.1 of ANSI N45.2.13 - 1976 titled Procurement Document Preparation. Review and Chance Control: The phrase "the same degree of control" is stipulated to mean " equivalent level of review and approval." The chsnged document may not always be rereviewed by the originator; however, at least an i

equevalent level supervisor shall review and approve any changes.

4) With regard to Section 3.4 of ANSI N45.2.13 - 1976 titled Procurement Document Control: The Company will meet the requirements of Sections 17.2.4 and 17.2.7 of the Operational OA Program in lieu of the requirements I

specified in this Section. 17.2-80 June,1986

._m m_ TABLE 17.2.0 f St ndard, Requirement or Guide 3 2) The Company's Position Conformance Status Justification $g.

5) With regard to Section 5.3 of ANSI N45.2.13 - 1976 titled Preaward Evaluation: The Company will comply with an attemate paragraph which reads: "Except in unusual ye circumstances as determined and documented by station management (e.g., replacement parts are

8.

needed to preclude the development of some unsafe or undesirable cond6 hon at a nuclear facility), and except in those cases where dedication techniques that do not rely on the supplier's OA program are necessary (e.g. the sole use of special tests and inspections to verify the quality of certain commercial grade items where the i supplier has no formal QA program), a preaward evaluation of the Supplier shall be performed as required 7y by the Operational OA Program." V+ (n

6) With regard to Section 6.4 of ANSI N45.2.13 - 1976 titled Control of Chanoes in items of Service The phrase "the k

in ~ Operational QA Program" will be inserted in lieu of " ANSI N45.2, Section 7."

7) With regard to Section 8.2 of ANSI N45.2.13 - 1976, titled Desposition. The third sentence of item b is revised to read:

Nonconformances to the contractual procurement requirements or Purchaser approved documents and which consist of one or more of the following shall be submitted to the Purchaser for approval of the r recommended disposition prior to shipment when the nonconformance could adversely affect the end use of a module or shippable component relative to safety, interchangeability, operability, reliability, integrity, or maintainability:

1) Technical or material requirement is violated; I

P 17.2-81 June,1986

k TABL5 17.2.0 St ndard, Requirement or Guide D m The Company's Position Conformance Status Justification 5 SE

2) Requirement in Supplier documents, which have been approved by the Purchaser, is violated:

"[ m to

3) Nonconformance cannot be corrected by continuation of the original manufacturing process or by rework; and/or y

o>

4) The item does not conform to the original requirement even though the item can be restored to a condition such that the capability of the item to function is unirnpaired.

• A module is an assembled device, instrument, or piece of h

equipment identified by serial number or other ^ V identification code, having been evaluated by inspection and/or test for conformance to procurement requirements regarding end use. A shwable component is a part of a tn - tubassembly of a device, instrument, or a piece of equipment which is shipped as an individual item and y which has been evaluated by inspection and/or test for conformance to procurement requirements regarding end use. 17.2-82 June,1986

TABLE 17.2.0 Standard, Requirement or Guide 3m NRC Reaviatory Guide __L144 " Auditing of Quality Assurance Programs for Nuclear Power Plants" (Rev.1. 9/80)- Endorses ANSI N45.2.12 - 1977. ha The Company's Position Conformance Status Justification Z The Operational Quality Assurance Program com. plies with Clarifications meet or exceed applicable These clarifications have been proposed to this guide with the following clarifications: guides and standards. maintain program continuity with other e

1) With regard to Section 1.4 of ANSI N45.2.12 - 1977 titled referenced standards and guides committed to in Table 17.2.0.

Definitions: With one exception (Program Deficiencies) the definitions in this Standard which are not included in Further, where attematives have been ANSI N45.2.10 will be used as clarified in the Company's proposed they reflect Company OA Program commitment to Regulatory Guide 1.74. The one practices and are considered to enhance the excepted definition and clarified definition relevant to this standard are defined in Table 17.2.0 under referenced program. Z Regulatory Guide 1.74. Not all standards, guides and regulations can k

2) With regard to Section 2.2 of ANSI N45.2.12 - 1977 titled be considered programmatically error-free, M

therefore, operational experience utilizing C Personnel Qualifications: The qualification of Company these documents and the proposed audit personnel will be accomplished as described to attematives must be taken into meet the requiremeG3 of ANSI N45.2.23 - 1978 as consideration. 2 endorsed in Table 17.2.0 and Sections 17.2.2 and 17.2.18 of the Operational OA Program.

3) With regard to Section 2.3 (and subsections 2.3.1 through 2.3.3) of ANSI N45.2.12 - 1977 titled Trainino:

The training of Company audit personnel will be accomplished as described to meet the requirements of ANSI N45.2.23 - 1978 as endorsed in Table 17.2.0 and Sections 17.2.2 and 17.2.18 of the Operational OA Program. 17.2-83 June,1986

TABLE 17.2.0 St!.ndard, Requirement or Guide 32 mS The Company's Position Conformance Status Justification E O

4) With regard to Section 2.4 of ANSI N45.2.12 - 1977 titled z

Maintenance of Proficiencv: The maintenance of to proficiency of the Company audit personnel will be accomplished as described to meet the requirement of a ANSI N45.2.23 - 1978 as endorsed in Table 17.2.0 and B C5 Sections 17.2.2 and 17.2.18 of the Operational OA Program.

5) With regard to Section 3.3 of ANSI N45.2.12 - 1977 titled Essential Elements of the Audit System: The Company will comply with subsection 3.6.5 as it was originally written (subsection 3.2.5) in ANSI N45.2.12, Draft 3 Z.

Revision 4: " Provisions for reporting on the effectiveness of the Quality Assurance Program to the gj responsible management." For the auditing organization c (The Company), effectiveness is reported as required by ] the individual nuclear facility Technical Specifications. y Other than audit reports, the Company may not directly 'D report on the effectiveness of the quality assurance programs to the audited organization when such organizations are outside of the Company. Subsection 3.3.6 requirements are considered to be fulfilled by compliance with the organization and reporting measures outlined in the Operational QA Program and the Technical Specifications of the individual nuclear facility. Subsection 3.3.7 requires verification of effective corrective action on a *tirnely basis., 17.2-84 June,1986 -. -. ~.

TABLE 17.2.0 I Stindard, Requirement or Guide TroS The Company's Position Conformance Status Justification U_ ' C Timely basis is interpreted to mean within the framework 2 or period of time for completion of corrective action that is g, C accepted by Nuclear Oversight. Each finding requires a response and a corrective action completion date; these dates are subject to revision (with the approval of Nuclear $o' Oversight) and must be escalated to higher authority when there is disagreement between the audited and the auditing organization on what constitutes ' timely corrective action." '

6) With regard to Section 3.5 of ANSI N45.2.12 - 1977 titled Schedulina: Subsection 3.5.3.1 is interpreted to mean 2

3. that the Company may procedurally review qualification of a contractor's or supplier's quality assurance program y prior to awarding a contract or purchase order by means C other than audit. n. g'

7) With regard to Section 4.3.1 of ANSI N45.2.12 - 1977 titled Pre-Audit Conference: The Company will comply with requirements of this Section by inserting the word

• Normally" at the beginning of the first sentence. This clarification is required because in the case of certain unannounced audits or audits of a particular operation or work activity, a pre-audit conference might interfere with the spontaneity of the operation or activity being audited. In other cases, persons who should be present at a pre-audit conference may not always be available.

Such lack of availability should not be an impediment to beginning an audit. Even in the above examples, which are not intended to be all inclusive, the material set forth in Section 4.3.1 will normally be covered during the course of the audit. 17.2-85 June,1986

TABLE 17.2.0 Standard, Requirement or Guide 5 - I' rv 5 The CompanVs Position Conformance Status Justification F' O

8) With regard to Section 4.3.2 of ANSI N45.2.12 - 1977 t

titled Audit Process-p : C i a) Subsection 4.3.2.2 could be interpreted 10 limit I auditors to the review of only objective evidence; b! sometimes and for some program elements, no objective evidence may be available or subjective evidence may be more appropnate. The Company i will comply with an allemate sentence which reads:

• When available, objective evidence shall be examined for compliance with Quality Assurance Program requerements. When subjective evidence 2 -][

is used (e.g., personnel interviews, direct observations by the auditor), then the audit report must indicate how the evidence was obtained." C n e M b) Submi;vn 4.3.2.4 is modified as follows to take into i account the fact that some nonconformances are y virtually " obvious

• with respect to the needed corrective action:

i ?

• When a nonconformance or quality assurance program deficiency is identified as a result of an

,6 audit, unless the apparent cause, extent and corrective action are readily evident, further investigation'shall be conducted by the audited l organization in an effort to identify the cause and l effect and to determene the extent of the corrective i action required." i l i s 17.2-86 June,1986 .- n ~_ - _. - - - - - -. -,.. -, ~ - - - ..e-- - - - -. * - -w <m- +-m m--.-- ,-erem,,-,,- ew,,- ~.e.

_.m TABLE 17.2.0 Standard, Requirement or Guide 3 i . fr. The Company's Position Conformance Status .Jushfication 5' 9l c) Subsection 4.3.2.5 contains a recommendation which is clarified with the definition of " acknowledged by a [l E-member of the audited organization" to mean that a " member of the audited organization has been T informed of the findings." Agreement or I disagreement with a finding may be expressed in the t response from the audited organization.

9) With regard to Section 4.3.3 of ANSI 45.2.12 - 1977 titled Post-Audit Conference: The Company will substitute and comply with the followmg paiagiaph. "For all extemal audits, a post-audit conference shall be held with 7 l 6

y management of the audited organization to present audit findings and clarify. misunderstandings; where no T> U adverse findogs exist, this conference may be waived by 5< management of the audited organization: such waiver y: shall be documented in the audit report y Unless unusual operating or maintenar.ce conditions i preclude attendance by appropriate managers / supervisors, a post-audit conference shall be held with managers / supervisors for all intemal audits for the same reasons as above. Again, if there are no adverse findings, management of the intemal audited organization may waive the post-audit conference: such waiver shall be documented in the audit report

• 5 17.2-87 June,1986 r

m TABLE 17.2.0 Standard, Requirement or Guide ' i -y rv -1 The Cumpany's Position Conformance Status Ju.is.'ication -Ei C+

10) Wsth regard to Section 4.4 of ANSI N45.2.12 - 1977 titled 2,

Reporting-te.1

• i a) This Section requires that the audit report shall be signed by the audit team leader; this is not always the

~(., c' ! - most expeditious route to take to assure that the audit report is issued as soon as piscisusi. i ^ 1 The Company will comply with Section 4.4 as clarified i in the following opening statement: "An audit report, -} which shall be sogned by the audit team leader, the Staff Quality Specialist (AuditCoordinator) or his 2 supervisor in his absence, shall provide": In cases where the audit report is not signed by the Audit [ Team Leader due to his absence, one record copy c' of the report must be signed by the Audit Team n-, Leader upon his retum. The report shall not require. yi the Audit Team Leader's review, concurrence, or p ; signature if the Audit Team Leader is no longer t employed by the auditing organization at the time i the audit report is issued. b) The Company will comply with subsection 4.4.3 cfarified to read: " Supervisory level personnel with l whom significant discussions were held during the course of pre-audit (where conducted), audit, and post-audit (where conducted) activities, i c) Subsection 4.4.6 requires audit reports to irclude recommendations for corrective actions; the Company may choose not to comply with this [ I requirement. Instead, Audit Team Leaders are l-required to document a!I adverse findings on audit finding forms. l l Y 17.2-88 L June,1986 's

TADLE 17.2.0 St:ndard, Requirement or Guide - I! m5 The Company's Position Conformance Status Justification 500 The procedure for processing audit findings allows z the Audit Team Leader to document actions which w to are considered necessary to correct the finding; the Audit Team Leader may also document actions t which are considered unacceptable for correcting E the finding: the audit finding with these " Recommendations" is then transmitted to the audited organization. In addition, the Audit Team Leader is required to review the response to the audit fmdmg and determine if it is acceptable. Any disagreements must be escalated to higher tr.anagement for resolution. 2> T

11) With regard to Section 4.5.1 of ANSI N45.2.12 - 1977 titled By Audlied Orgamzation The Company will comply 5

wiih the following clarification of this Section: m-

• Management of the audited organization or activity shall review and investigate all adverse fmdmgs, as necessary, (e.g., where the cause is not already known, another organization has not already investigated and found the cause, etc.) to determine and schedule appropriate corrective action includmg action to prevent recurrence.

They shall respond, in writing, within thirty days after the date of issuance of the audit report. The response shall clearly state the corrective action taken or planned to prevent recurrence and the results of the investigation if conducted. In the event that corrective action is not completed by the time the response is submitted, the audited organization's response shall include a scheduled date for completion of planned corrective action. The audited organization shall take the appropriate action to assure that corrective action is scwir ished as v scheduled. 17.2-89 June,1986

TABLE 17.2.0 St ndan". Requirement or Guide NBC Reculatorv Guide 1.146 " Qualification of Quakty Assurance Program Audit Personnel for Nuclear Power Plants"(Rev. O,8/80)- h Endorses ANSI N45.2.23 - 1978. 5 $G The Company's Position Conformance Status Justification { The Operational Quality Assurance Program comr%s with Clarifications and attematives meet or The clarifications and attematives reflect T to this guide with the following clarifications and atteman. exceed applicable guides and standards. experience gained at operational nuclear facilities and are intended to enhance and ii3

1) With respect to Section 1.4 of ANSI N45.2.23 - 1978 titled provide additional guidance in the areas ot O'

Definitions: Definitions in this Standard which are not auditing as delineated herein, included in ANSI N45.2.1 T will be used; " AUDIT

• which is included in ANSI N45.2.10 will be used as addressed in the Company's commitment to Regulatory Guide 1.74.

2) With respect to Section 2.2 of ANSI N45.2.23 - 1978 titled Qualification of Auditors: Subsection 2.2.1 2

references ANSI N45.2 therefore, the Company will comply with an a!!emate subsection 2.2.1 which reads: Cn* Orientation to provide a working knowledge and understanding of the Operational OA Program, D including the ANSI standards and Regulatory Guides included in Table 17.2.0 of the Program, and the Company's procedures for implementing audits and reporting results.

3) With respect to Section 2.3 of ANSI N45.2.23-1978 titled Qualification of Lead Auuitors: Subsection 2.3.3.1 references ANSI N45.2; therefore, the Company will comply with an attemate subsection 2.3.3.1 that reads:

Knowledge and understanding of the Operational QA Program, including the ANSI Standards and Regulatory Guides included in Table 17.2.0 of the Program, particularly ANSI N45.2.12 and other nuclear-related codes and regulations, as applicable.

4) With respect to Section 3.2 of ANSI N45.2.23 - 1978 titled Maintenance of Proficiency: The Company will comply with the requirements of this Section by defining

• annual assessment" as one which takes place every 12 months or less and which uses the initial date of 17.2-90 June,1986

TABLE 17.2.0 Standard, Requirement or Guide I tv i The Company's Position Conformance Status Justification 5 E certification (not the calendar year) as the starting date for h determmmg when such annual assessment is due. m, te

5) With respect to Section 4.1 of ANSI N45.2.23 - 1978 titled Ornaruzational Resoonsibility-The Company will comply

~< with this Section with the substitution of the following E sentence in place of the last sentence in the Section. s The Manager - Nuclear Oversight, Director - Nuclear Oversight, Supervisor-Quality (Vendor Programs), Staff Quality Specialist (Audit Coordinator), or Audit Team Leader shall, prior to commencing the audit. assign personnel who collectively have experience 2.' y or training commensurate with the scope, ,~ complexity, or special nature of activities to be ], audited. c, n (W

6) With respect to Section 5.3 of ANSI N45.2.23 - 1978 titled Undahno of Lead Aanr's Records: The Company will substitute the following sentence for this Section:

Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Section 3.2 (as clarified). 17.2-91 June,1986 ~.

REVISION 29 V96 NAPS UFSAR TABLE 17.2.1 Appendix B Topical 10 CFR 50 Report Criterion Section Iltle Abstract i 17.2.1 Organization Defines the relationship of, departments to the quality assurance effort associated with the operation of the nuclear power station. Il 17.2.2 Quality Assurance Defines the Operational Program Quality Assurance Program, its overall responsibility and provisions. lil 17.2.3 Design Control Defines the policy, responsi-i bility and procedures for l exercising design control. IV 17.2.4 Procurement Establishes policy applic-Document Control able to plant operation and maintenance. i V 17.2.5 Instructions, Establishes guidelines for Procedures and preparing instructions, Drawings procedures and drawings. VI 17.2.6 Document Control Establishes policy for the control of procedures and instructions. Vil 17.2.7 Control of Purchased Establishes methods for Material, Equipment assuring that purchased and Services items conform to the speci-fied quality requirements. Vill 17.2.8 Identification and Establishes procedures for Control of Material, the identification and Parts and Components control of material, parts and components. IX 17.2.9 Control of Special Establishes procedures Processes which assure that special processes are controlled and accomplished by qualified personnel. 17.2-92

REVISION 29 1/90 NAPS UFSAR l l i 1 Appendix B Topical 10 CFR 50 Report l Criterion Section - Titig Abstract X 17.2.10 Inspection Establishes a program for inspection of activities affecting quality. XI 17.2.11 Test Control Establishes policy for power i stations test programs. j 4 i Xil 17.2.12 Control of Measuring Establishes policy for con-f and Test Equipment trol and calibration of test and measuring equipment. i 4 XIll 17.2.13 Handling, Storage Establishes policy for this and Shipping function as related to material and equipment. 1 i XIV 17.2.14 Inspection, Test, Makes reference to appro-j and Operating Status priate administrative t 3 procedures which govem I this function, i XV 17.2.15 Non-Conforming Establishes policy for i Material, Parts, or reporting and controlling 1 l Components non-conforming materials, parts, or components. i XVI 17.2.16 Corrective Action Establishes policy for t identifying, documenting, notifying, determining causes 3 and preventing defects from recurring. ) i l XVil 17.2.17 Quality Assurance Assures maintenance, identi-Records fication and retrievability of records. ) XVill 17.2.18 Audits Defines policy and procedures for audit programs. n l 17.2-93 m .}}