ML20100F960

Rev 45 to Bg&E QA Policy for Ccnpp

ML20100F960
Person / Time
Site:	Calvert Cliffs
Issue date:	01/16/1996
From:	Denton R BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20100F954	List: ML20100F952 ML20100F960
References
NUDOCS 9602220262
Download: ML20100F960 (57)

Text

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o- , ', m QUALITY ASSURANCE POLICY Revision 45 BALTIMORE GAS AND ELECTRIC COMPANY Quality Assurance Policy forthe Calvert Cliffs Nuclear Power Plant 4

Approved Date I I b!7b(1)

R. E. Denton

\ Vice President .

I Nuclear Energy Division 9602220262 960216 PDR ADOCK 05000317 P PDR Page 1of57

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QUALITY ASSURANCE POLICY Revision 45 TABLE OF CONTENTS  :

Section Page iB.I ORGANIZATION AND RESPONSIBILITIES . ..... ................................................... ...... 5 iB.2 QUALITY AS SURANCE PROGRAM ..... .. . .................................. ..................... . ..... 13 1B.3 D ES IG N CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . I 1B.4 PROCUREMENT DOCUMENT CONTROL (5)....................... .................. ....... .. . . .. 20 1B.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS ..................... ... ......................... 22 1B.6 DOCUM ENT CONTROL..... .. . . . .... . ...... . ...... ..... . .. . .... . . ........ . . . . ....... .. ... . .... . . . . ... ... .. . . 23 IB.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (5) . .. 25 l IB.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COM PONENTS (5) .. . .. . . .. . .. . .. . .. ... . . . . . . . . . ... .... . . . . . .. .. . . . . . .. .. . . ... ... . ... .. . . . . . . . . . . . . 2 7 1B.9 CONTROL OF SPEC 1AL PROCESSES.... .. .. . . . .........................28 1B.10 INS PECTI ON . .. . . . .. . .. . . . . . . ..... . . . ... . . . .. . . . . .. . . . . . . ..........................................30 1B.11 TES T C O NTR O L . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31 1B.12 CONTROL OF MEASURING AND TEST EQUIPMENT. ... .. .... ..... . .... . . . ... .. 32 iB.13 HANDLING, STORAGE, AND SHIPPING .. .. ... .. . . . . . . . . . . . . . . . .. . .. . ... 33 1B.14 INSPECTION, TEST, AND OPERATING STATUS ..... .. . . ..... . . ............. . 34 1B.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS (6)... .. .. ... ..... .. . 34 1B.16 CO RRECTIVE ACTION (6) . . .... . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . .. . . . . ... . . . . 3 5 l

1B.17 QUALITY AS SURANCE RECORDS ....... .... . ............. .. .. ............ .... . . . ...... . . ... 35 1B.18 AUDITS........................................................................................36 l

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QUALITY ASSURANCE POLICY Revision 45 LIST OF TABLES Table No. Page 1B-1 BALTIMORE GAS AND ELECTRIC COMPANY'S POSITION ON........................... . 38 GUIDANCE CONTAINED IN ANSI STANDARDS LIST OF ATTACHMENTS Attachment Letter A BASES FOR QA POLICY REVISIONS (1)... . .. .. ....... . . ... .... ....... .......... ..... .. . .. . 55 LIST OF FIOURES Figure No.

IB-1 BALTIMORE GAS AND ELECTRIC COMPANY CORPORATE ORGANIZATION .. . .... ......... .... ......... ... ..... . .... . .... ....... ... ..... 5 8 l

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QUALITY ASSURANCE POLICY Revision 45 MRT OF EFFECTIVE PAGES  !

l Latest revision number is listed for pages revised after revision 38.

Page Last Revision Page Last Revision Page last Revision 1 24 44 47 41 2 25 44 48 41 3 26 44 49 41 4 44 27 45 50 41 5 28 41 51 41 6 45 29 41 52 41 )

7 44 30 41 53 41 l

8 42 31 43 54 41 9 45 32 43 55 41 10 43 33 43 56 41 11 42 34 41 57 12 45 35 41 58 13 45 36 59 42 14 44 37 41 60 42 15 - 41 38 44 16 41 39 41 17 41 40 41 )

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20 41 43 41 21 41 44 41 22 41 45 41 1 23 41 46 41 I E

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• i QUALITY ASSURANCE POLICY Revision 45

.. j IB.1 ORGANIZATION AND RESPONSIBILITIES l All levels of organization have definite and unique responsibilities in assuring safe, economical, and reliable operaten of Calvert Cliffs Nuclear Power Plant (CCNPP). Top level management is responsible for ensurung that policies are established, resources are authorized, management philosophy and comnutments are communicated to lower levels of the orgaai=% iadaaaadaat verificaten ofir r.r a..aa controls are periv....c4, results are reviewed, and appropriate actions taken when necessary, Mxidle level management is responsible for translating management policies, philosophy, comnutments,  ;

and goals; applicable federal, state, and local rules and regulations; Operating Licenses, Technical  ;

Sa~inacions (TS), and the Updated Final Safety Analysis Report (UFSAR) into control programs for  ;

activities such as design, procurement, construction, testing, operation, refueling, ma atenaner, repair,  !

modification, training, plant security, fire protection, records, independant verification, and corrective '

acten Middle level management is also responsible for danaiag. measuring, and modifying the overall effectiveness of control programs; taking appropriate action on the results; and keeping top management I informed of the status, adequacy, and effectiveness of control programs, and matters which could have an i impact on nuclear safety.  !

First line craA and non craft supervisors are individually responsible for ensuring that appropriate procedures are understood and used to implement each activity described in the control programs; identifying problems, seeking solutions, verifying implementation of solutions; investigating root causes of problems and takmg preventive actions; ensuring that conditions adverse to plant and personnel safety are promptly identified, reported, and corrected, detecting trends which may not be apparent to a day-to<iay observer, recc.rs.cr. ding generic solutions for adverse trends to management, and t.skmg appropriate actions, to achieve desired results; ensuring that employees assigned to do a job are properly qualified through appropriate traimng and experience; have properly qualified procedures, tools, equipment, and parts to do the job, and, ensuring that ind= adant inspections of work are conducted in accordance with preestablished requirements. First line non craft supervisors are responsible to ensure that procedures are written, reviewed, and approved; first line craft supervisor:: may not have this responsibility. Non-

supervisory personnel acting as job directors are responsible for ensuring that properly qualified procedures are understood and used; and ensuring that tools, equipment, and parts are on hand to do thejob.

4 Adherence to procedures is vital to the safe and reliable operation of the Calvert Cliffs Nuclear Power Plant. Personnel are responsible for adhering to established procedures, interpreting them conservatively in j case of doubt, and recommending changes when necessary. Procedures with the potential to affect nuclear l or personnel safety shall be strictly adhered to. When an activity controlled by such procedures cannot be 1 accomplished as described or accomplishment of such activity would result in an undesirable situation, the work shall be stopped and the plant placed in a safe condition. Work shall not resume until the procedure

} is changed to reflect correct work practices. (1) f Procedures may be deviated from during emergencies to prevent or minimize injury to personnel or damage to plant equipment. Any such deviations should b thoroughly documented. (1) i

! Cornorate Organintian and Sne-ific Reenansioihties The Corporate Organization Chart of the Baltimore Gas and Electric Company (BGE) is shown in Figure IB-1. Persons responsible for the principal elements of the Company's Quality Assurance (QA) Program -

are as follows:(1)

Chairman of the Board I

President and Chief Operating Officer i j Senior Vice President-Generation 1 Page 5 of 57 i

I QUALflY ASSURANCE POLICY Revision 45 Vice President-Nuclear Energy Division (NED)

Plant General Manager Calvert Cliffs Nuclear Power Plant Department (CCNPPD)

Manager-Nuclear Erf. Mig Department (NED)

Manager-Nuclear Quality Assurance Department (NQAD)

Manager-Nuclear Support Semces Department (NSSD)

Manager-Nuclear Outage & Project Managemet Department (NOPMD)

In addition to ti,ese individuals, the Vice Presidents of Fossil Energy Division (FED), Electric Interconnection and Transmission Division (EITD), General Semces Division (GSD), and the Management Services Division (MSD), as well as the Managers of the System Operation and Maintenance Department (SOMD), Purchasing & Materials Mar.r.gc.w.: Department (PMMD), Informaten Systems ,

Department (ISD), Facilities and Fleet Services Depanment (FFSD), Fossil hMing & Maintenance Department (FEMD), and the Safety and Medical Services Department (SMSD) are assigned support ,

responsibilities. (1) The above Managers constitute the Nuclear Program Managers who are assigned i responsibilities within the QA Program Other departments performmg any maintenance / modification ,

activities at CCNPP are responsible for performing these activities in accordance with applicable QA Program requirements. 'Ihis can be accomplished by either developing their own QA Program procedures or by working to the QA Program through appropriate Nuclear Energy Division perior.r.cl using CCNPP procedures. (15)

Also, two advisory groups perform quality-related functions for plant operations. These are the Plant i Oprations and Safety Review Committee (POSRC) and the Off-Site Safety Review Committee (OSSRC) I wiose makeup and responsibilities are described in the TSs for CCNPP.

f Chairman of the Board. President and Chief Operatinn Officer. and Senior Vice President Generation BGE's QA Program for nuclear power plants is established under the authority of the Chairman of the Board, President and Chief Operating Officer, and Senior Vice President Generation, who are responsible i for establishing the overall QA Policy. They assign project responsibilities to the organizations shown in

! heavy-lined boxes in Figure 1B 1. (1)

'Ihe Chairman of the Board assigns authority through the President and Chief Operating Officer and Senior Vice President Generation to the Vice President-Nuclear Energy Division. Primary responsibilities for developing, implementing, and maintammg the QA Program are assigned to Department Managers by the Vice President-Nuclear Energy Division. Managers delegate their authority as required to implement their j responsibilities. (1)

I Quality assurance matters that cannot be resolved by the Managers or Vice Presidents are brought to the

, attention of the Senior Vice President Generation, President r.nd Chief Operstmg Officer, or the Chairman of the Board for resolution.

Vjce President-Nuclear Energy Division .

The Vice President-Nuclear Energy Division, is responsible to the Senior Vice President-Generation for .

j casuring that the QA Program is developed and implemented. 'Ihe authority to develop QA Program D~~=ts is assigned to designated Nuclear Program Managers. The Vice President-Nuclear Energy Division, is also responsible for ensuring that the requirements of the QA Program that relate to the design, operation, and mamtenance of the plant are implemented. 'Ihis responsibility is carried out through Nuclear Program Managers.

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.i QUALflY ASSURANCE POLICY f

Revision 45 j Mme-- -Naalaar Oa=li+v A*-=@=== ^

3 The Manager-NQAD, is responsible for assuring an appropriate QA Program is established and 1 effectively executed for CCNPP. He is responsible for auditing, quahty verina=*6, vendor -

j ev=!a=*6. and iP safety evaluation functens for CCNPP. These responsibilities

include

) 1. i Developing, and revising the QA Pol'cy.

2. Ensuring that QA Compliance reviews are completed for program acceptability of Directives I and their revisions before they are approved. (9) i

, 3. Taking necessary corrective action, which can include the stoppage of work when i

manufactunng, maintenance, or modification activities fail to comply with approved specifications, plans, or procedures. Such corrective action is arranged through appropriate

channels and is delegated when necessary. When a unit is operstmg, the Manager-NQAD, may recommend to the Plant General Manager that the plant be shut down. The Plant General Manager has the final responsibility for the overall evaluation of all aspects and implications of shutting down an operating unit.

! NQAD personnel who report to the Manager-NQAD, are iPt of departments, sections, j and employees responsible for performing specific activities, and have sufficient authority and 1

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organizational freedom to identify quality problems; to initiate, reco.. .wd, or provide solutions ,

through designated channels; and to verify implementation of solutions. Non-NQAD personnel who are authorized to perform activities under NQAD programs are matrixed to NQAD for the

, performance of such activities, and possess similar organizational freedom and iantapaariaaca from l the activities, i BGE has established that the Manager-NQAD, should have at least six years of responsible

experience in engineering, design, manufacturing, construction, quality assurance, or power plant operation, as well as a knowledge of regulations and standards related to nuclear power plants.

3 l The organization of NQAD is shown in Chapter 12 of the UFSAR. 'Ihe Manager-NQAD, l delegates the following responsibilities for accomplishing the following activities:

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• Planning and scheduling evaluations of vendor quality assurance programs.

l Reviewing proposed changes to QA Program documents for compliance with regulations and

, licensing documents.

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• Planning, scheduling, aad performmg internal audits /surveillances and evaluations of on-site

{ and off-site functions performed under the nuclear QA Program.

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• Supporting maintenance and operations activities by perfornung inspections and surveillances, or by providing oversight of other department persc.w.cl as they perform

. inspections and surveillances. (11)

Directing investigations of significant events to determme root cause, im+m=4ag corrective action, and generating appropriate reports to riaan na=+ the investigation results; -

directing a program for identifying trends within the corrective action systems I

• Directmg reviews of the operating experience of other plants of similar design to deternune the applicability of significant events with respect to CCNPP. (14)

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l QUALITY ASSURANCE POLICY Revision 45 PL.: c_ __al M--- .Calvert Cliffs N==' = Pcwcr Plant Dr=^

- 'Ihe Plant General Manager is responsible for operations, chemistry, radiation safety, maintenance, industrial safety and fire pre. and systans and performance ensmeerms activities at CCNPP. He must ensure that these activities are conducted in accordance with the plant operating hcense and TS , the UFSAR, the QA Program, and procedures. The Plant General Manager fulfills the position and requiranents of the Plant Manager, as dannad in ANSI N18.1 (1971). He, or one of his designated principal alternates, shall have acquired the sperierge and training normally required for exammation for a senior reactor operator's license.

1he organizatica of CCNPPD is shown in Chapter 12 of the UFSAR. "Ihe Plant General Manager, M-?== responsibilities for accomplishmg required activities as follows:

1. The Superintandaar-Nuclear Operations (S-NO) is responsible to the Plant General Manager, for the operation of the plant, including the general supervision of all shift operatmg personnel and priontization of maintenance activities to support operations. 'Ihis responsibility covers the safety of plant personnel and equipment, all fuel-handling and refueling activities, and adherence to applicable license and regulatory requirements. The Superintendent-Nuclear Operations fulfills the position and requirements of the Operations Manager as defined in ANSI N18.1 (1971) with the exception taken in Table IB.I.

The Superintendent-Nuclear Operations delegates primary management responsibility to the Shift Supervisor on duty, via the General Supervisor-Nuclear Plant Operations (GS-NPO) to ensure the safe operation of the plant under all conditions. The Shift Supervisor maintains the broadest possible perspective on operational conditions that affect the safety of the plant.

As the senior member of plant management on each shift, he exercises the cc.. .er,d authority of his position to take whatever steps he deems necessary during emergency situations to place and maintain in a safe configuration any unit that may be affected.

2. 'Ihe Superintendent-Nuclear Maintenance (S-NM) is responsible to the Plant General Manager for managing and directing activities of the Nuclear Maintenance Section to provide high quality maintenance programs, plans and schedules, and qualified personnel to perform ,

maintenance functions necessary to assure the safe, reliable, and economic operation of the '

plant to generate power within applicable laws, standards, codes, and regulatory l requirements.

a. The General Supervisor-Electrical and Controls (GS E&C), is responsible to the Superintendent-Nuclear Maintenance, for the conduct of electrical and instrument maintenance, repair, and modifications needed to keep the plant and its facilities, systems, and equipment in safe and efficient working condition. He is responsible for planmng and supervising or controlling the electrical and instrument maintenance activities conducted by plant maintenance personnel, and for ensuring that work is performed in accordance with applicable Codes and Standards and that required maintenance records are developed and kept. He is responsible for controlling tools and equipment used for electrical and instrument maintenance, repair and modifications activities.

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QUALITY ASSURANCE POLICY Revision 45

b. 'Ihe General Supervisor-Mechanical Maintenance (GS-MM), is responsible to the Supenntendent-Nuclear Maintenance, for the conduct of =~har421 maintenance, J repair, and modifications needed to keep the plant and its facilities, systems, and -

equipment in safe and efficient working condition. He is responsible for planning and supervising or controlling the mechanical maintenance activities conducted by plant  !

maintenance pesad, and for ensuring that work is performed in accordance with  !

applicable Codes and Standards and that required maintenance records are daiped 1 and kept. He is responsible for controlling tools and equipment used for mach =neal maintenance, repair, and moddicatiana activities.

3. The Superintendant-Technical Support (S-TS) is responsible to the Plant General Manager for managing and directing the activities of the Technical Support Section to provide systems

and performance origineerung, surveillance testmg administration, chamai=*ry and radiataan j safety support, inservice inspection, naadastructive a==3==+iaa, materials testing and evaluation, and industrial safety and fire protection support to assure the safe, reliable,

. economic operation of CCNPP. The S-TS is also responsible for overall direction and I comdhetion of activities to ensure compliance with the Radiological Effluent Technical

Specifications. This responsibility is carned out through the General Supervisor cha,niary 1 with support from the Manager-FEMD.

4

a. The General Supervisor-Chemistry (GS-C) is responsible to the Superintendent-Technical Support for the chemistry and radiochemistry of the primary and -aadary l

j systems and for maintaining radioactive effluents within specified limits. Additionally, i the GS-C provides program management of the Radiological Environmental ,

- Monitoring Program to ensure compliance with the Radiological Effluent Technical j

Specifications.

b. The General Supervisor-Radiation Safety (GS-RS) under the nuclear QA Program, is responsible to the Superiataadaat-Tecimical Support for:

• Ensuring the radiation protection of personnel at CCNPP.

• Complying with radioactive material transport regulations.

c. The Supervisor-Safety and Fire Protection is responsible to the Superintendent-

Technical Support for development, implementation and coordination of the industrial

safety program; implementing the fire prevention and fire fighting programs for the i CCNPP; and planning, scheduling and monitoring activities directly related to safety, fire protection, and prevention.

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d. The General Supervisor-Plant Engmeering (GS-PE), is responsible to the i Superiataadant Technical Support for providing field engineering and technical  !

i evaluation of plant systems and to evaluate and coordmate resolution of system and l i

, component problems with operations, maintenance, and engineering personnel for the Calvert Cliffs Nuclear Power Plant. Additionally, the GS-PE is responsible to the S-TS for providing plant reliability / availability testing and evaluation, plant performance improvement, and administration of the Surveillance Test Program. j i  !

e. The Principal Engineer-Materials hgiaaaring and Inspection is responsible to the

Superintendent-Technical Support for providing inservice inspection, =aadaaructive examination, and materials testing and evaluation services for the Calvert Cliffs Nuclear Power Plant.

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QUALITY ASSURANCE POLICY Revision 45 i Manager-Nuclear Engineering Department l The Manager-NED, as respons ble for &recting the efforts of personnel and provi&ng resources i j necessary to support design, modi 6 cation and engineering activities covered by the QA Program for CCNPP. These activities include nuclear, mechamcal, civil, reliability, instrument and

controls, and electrical engmeering; nuclear fuel management, configuration management; life j cycle management; plant design support; fire protectaan program development; engineermg

plannirig; hecesing, and design and drawing.

1

} The organization of NED is shown in Chapter 12 of the UFSAR. The Manager-NED delegates responsibilities for accomplishing the following activities:

Providmg na-*M and dotaded engineermg, design and drawing, fire protection program dcA =t, data base configuration control, and documstion and maintenance of plant design bases for the power and control systems for the Calvert Cliffs Nuclear Power Plant.

• Directing and perfomung safety evaluations, preparation and review of nuclear safety accident and transient analysis, fuel management, nuclear engineering related to core physics, l reactor engineering, external fuel cycle management, reliability engineering and development

+

and integration of programs necessary to operate up to and beyond the current licensed lifetime for the Calvert Cliffs Nuclear Power Plant.

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• Providing plant design support, and engineering planning and scheduling for the power and i control systems for the Calvert Cliffs Nuclear Power Plant.

Providing licensing services; coordmation and operation of varmus industry information 4

cxchange systems; evaluation of plant events and conditions adverse to quality for

, reportability to the NRC and other agencies, assisting in the investigation and evaluatio:: of i events, and preparation of the reports; coordination of tracking and resolution of company commitments to the NRC; research and preparation of responses to NRC letters, bulletins,

, circulars and information notices; UFSAR research and revision control; maintenance and revision of the current licensing basis for nuclear power plants; coordination of all j compliance-related communications with external agencies including assistance in ensuring l their consistency with existing licensing basis commitments; and coordination of regulatory j inspections and visits and company presentations to the NRC.

Mananer-Nuclear Outane and Proiect Marmeement Department

{

1he Manager-NOPMD is responsible for directmg the efforts of personnel and provxhng resources

necessary to support site integrated scheduling, outage management and project management for assigned projects. The organization of NOPMD is shown in Chapter 12 of the UFSAR. The Manager-NOPMD delegates responsibilitics for accomplishing the following activities

I Developing, implementing and maintaining a site integrated schedule which schedules all significant plant related activities at CCNPP.

Managing the planning, scheduling and performing of all outages at CCNPP.

Providing overall project management for engineering, procurement, construction and testing of nuclear power plant modification for CCNPP.

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QUALITY ASSURANCE POLICY Revision 45 1

4 Mpysner-Nuclear Support Services Department 1he Manager-NSSD is responsible for emergen:y planrung, training, nuclear security, onsite procurement coordmation, procurement engmeering, receipt inspection and storage / issue of items, procedures upgrade, state regulatory matters, strategic planning, and staff services functions for CCNPP.

The orgamzation of NSSD is shown in Chapter 12 of the UFSAR. The Manager-NSSD delegates responsibilities for accomplishing the following actisities:

Providing support to Managers in the Nuclear Energy Division to ensure their personnel are properly trained and quali6ed to perform their assigned duties, including those duties which implement the nuclear QA Program. Traimng required by special work forces and contractors would be performed by the appropriate BGE Department, and/or Host Company (vendor).

Distributing, and coordina'ing the preparation of revisions to the QA Program documents; collecting, storing, maintaining, and retrieving QA records for nuclear power plants; maintaining, controlling, and distributing drawings and technical manuals related to

, equipment, materials, and services for nuclear power plants; coordinating investigations r

ccacerning state regulatory matters; coordinating the efforts of Nuclear Energy Division personnel involved in the procurement of structures, systems, components, parts, and services related to the design, construction, fueling, maintenance, and modifications of CCNPP.

Establishing procedures to assure that SR and DNSR pocurement documents identify technical end quality requirements; procurement (SR and DN3R) documents receive independent review and approval for the proper inclusion of technical and quality requirements; ensuring spare and replacement parts are suitable for their intended application (s); specification of critical characteristics and acceptance criteria for dedication of commercial grade items; specification of special storage requirements for age sensitive items.

Performing receipt inspection functions including special receipt inspections and coordinating testing performed to accept commercial grade items, designated NSR items or upgrade NSR items for use in SR applications. (5)

Ensuring that the operational, maintenance, licensing, and trauung actisities associated with plant security are effectively implemented, and that nuclear security provisions provide protection for personnel, equipment, and facilities at CCNPP against potential security threats.

Directing the efforts of personnel responsible for the storage and issuance of items for CCNPP.

Development of the annud Strategic plan for the Nuclear Energy Disision including :he Nuclear Program Plan, Directing the efforts of BGE personnel involved in emergency plannmg activities.

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QUALITY ASSURANCE POLICY Revision 45 Indivuluals supportirig the CCNPP QA Program are designated as follows:

Vice Praidaat-F==il Faarav Divi =iaa ne Vice President-FED, is responsible to the Senior Vice President Gmeration for ensuring that the activities of FED perd involved in CCNPP maintenance and modifications, and radiological envira==~*=1 monitoring, meet the requirements of the QA Program his responsibility is carried out through the Manager FEMD.

Man.=ar-Fa==il Fn != don & Maintan= ara Denartment he Manager-FEMD, is responsible for directing the efforts of FEMD personnel involved in 9

maintenance and modification activities at CCNPP and maintaining and operatmg Radiological Environmental Monitonng Program equipment and performing sample collection and analysis.

Vice President-Electric Inter ::onnection and Trunamineina Division i

The Vice President-EITD,is responsible for ensuring that the requirements of the QA Program that relate

! to the calibration of test equipment and the testing of protective rela 3i ng, and metering controls for SR 2

electrical power equipment are implemented. His responsibility is carried out through the Manager.

SOMD.

Mananer-System Operation and Maintenance Deoartment i ne Manager-SOMD, is responsible for directing the efforts of personnel involved in the testing of

electrical power equipment, the calibration of test equipment and the testing of protective relaying 1 and metering controls for the electrical power equipment of CCNPP.

Vice President General Services Division 1

ne Vice President GSD is responsible for ensuring implementation of the QA Program requirements that relateto: the procurement of SR or designated NSR structures, systems, components, and senices; the i construction, maintenance, and operation of facilities; and support services for computer softare and hardware.

l Dese responsibilities are carried out through the Manager-PMMD, Manager-ISD, and Manager-FFSD.

. Mananer-Purchasinn and Materials Mananement Deoartment

The Manager-PMMD, is responsible for directmg the efforts of personnel involved in the purchasing ofitems and senices for CCNPP and for the issuance of Contracts for Fitness for Duty i Activities.

4 Mananer-Information Systems Department ne Manager ISD, is responsible for directing the efforts of ISD personnel involved in acquiring and supporting computer software and hardware. -

Maan=ar-Facilities and Fleet Services Denartment 4

De Manager-FFSD, is responsible for directing the efforts of FFSD personnel involved in the t

planning, design, construction, maintenance, and operation of facilities and related systems directly supporting or impactmg power plant operations.

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! QUALITY ASSURANCE POLICY  !

Revision 45 .

Vice PraiAa=*-M--- = ant Services Divisia=

The Vice President-MSD, is responsible for ensuring that the activities of MSD gid involved with:

. medical examinations for CCNPP operators, Nuclear Security Officers, and respirator users; psychological assessments supporting the Access Authorization rule; and the Fitness for Duty rule meet the requirements  ;

of the regulations. The responsibility is carried out through the Manager-SMSD. '

Manager-Safety and Madieal Services Denart>= ant

The Manager-SMSD, is responsible for directing the efforts of SMSD personnel involved with l medical exanunations for CCNPP operators (10CFR55), Nuclear Security Officeru (10CFR73),

j respirator users (10CFR20); psychological assessments supporting the Access Authorization rule

(10CFR73); and with the Fitness for Duty rule (10CFR26).

j 1B.2 OUALITY ASSURANCE PROGRAM 1 General Controls k

The QA Program consists of the QA Policy, certain Nuclear Program Directives and their admmistrative procedures. Revisions to the QA Policy are controlled by QA Program documents which are written to

)

ensure compliance with 10 CFR 50.54(a)(3). QA Policy changes are submitted according to 10 CFR 1

50.71.

)

i The QA Policy identifies NRC regulatory requirements, industry standards, and specific codes applicable 4

to the eighteen criteria contained in 10 CFR 50, Appendix B. The QA Policy also indicates action that will be taken by BGE in response to these documents and to commitments made in the UFSAR and TSs for

CCNPP.

Nuclear Program Directives address actions identified in the QA Policy. Directives identify regulatory

, commitments, management requirements, and assign responsibilities for business activities (i.e., design, j maintenance, operations, etc.) within the BGE Nuclear Program.

l BGE's QA Program for CCNPP is applied to structures, systems, components, and activities that have

been designated SR because they prevent accidents or mitigate the consequences of postulated accidents l i that could cause undue risk to the health or safety of the public. The QA Program is also applicable to i

! designated NSR structures, systems, components, activities, and services as required by regulations.

Designated NSR program requirements are based on a graded approach to Quality Assurance acquired to

meet applicable regulatory designated requirements and guidance. The level of QA Program controls placed on designated NSR items are defined in QA Program docu.,ets and/or implementing procedures.

' 1he controls from other sections of this QA Policy are selected as necessary to meet the particular regulations being implemented.

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! Controls have been established for specifying on a Quality List (Q-List) all SR structures, systems, I components, aM Erivities that are subject to the requirements of the QA Program 1

l 1he Statement of Authority, in the Nuclear Program Policies Manual, signed by the Chairman of the

~

Board, establishes the overall QA Policy of BGE. This Statement sets the goal of safe and reliable operation of CCNPP; commits the Company to a QA Program designed to ensure the plant's compliance i with regulatory requirements, BGE commitments, and established practices for reliable plant operation; and requires every person involved in QA Program activities to comply with the provisions of the Program.

1he QA Policy is approved by the Vice President-NED and implemented by Nuclear Program Managers.

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QUALITY ASSURANCE POLICY Revision 45 ne QA Program has established controls for BGE and its contractors as required to ensure that the critena of 10 CFR 50, AWN B, will be met throughout the operations phase of the plant; i.e., during activities of testing, operation, maintmance, repair, modification, and refuelmg l

i ne QA Program has also established controls to ensure that the construction, operatenal, and d=-:= +issiomng phases for the IP Spent Fuel Storage Installation (ISFSI) are conducted in compliance with 10 CFR 72. Activities menaciated with the operational and deco.. ..;;sioning phase shall be controlled under the CCNPP 10 CFR 50 AWw B QA Program; existmg policies, programs, directives, and procedures stated as applicable for CCNPP are also applicable for the ISFSI. (16) j Nuclear Program Managers ensure QA Program documents are revised as regulations, standards, results, j or experience dictate. (1) De Manager-NQAD evaluates the degree of compliance with the requirements

of QA Program documents and procedures. Audits are conducted regularly to ensure compliance with '

established requirements, and the results of these audits are reported to responsible management personnel.

l

]

De Vice President-NED, ensures that activities of the NQAD are audited regularly by personnel independent of the Department. Dese auditors assess the effectiveness of the Department's implementation of appropriate portions of BGE's QA Program ne Vice President-Nuclear Energy Division, evaluates the

. report of the i%t audit to deternune if changes are required to the QA Program He is responsible i for negotiating such changes with the appropriate level of management and for sendmg to the Chairman of

] the Board a copy of the audit report and an account of the corrective action taken.

)4 If a difference of opinion arises between NQAD personnel and those of other Sections or Departments, the j dispute is resolved as follows: ne Supervisor / General Supervisor of the QA Unit /Section involved first

tries to resolve the matter with the organization responsible for conducting the activity. If a resolution cannot be obtamed, the matter is referred up through the following management personnel until it is

resolved:(3) i

l. He Manager-NQAD, and the Manager responsibic for performing the activity.

I NOTE:

l If the dispute is with another Unit /Section in NQAD, the issue will be settled by the Vice President-Nuclear Energy Disision. (3) i

2. The Vice President-Nuclear Energy Division. (1)

3. He Senior Vice President Generation, President and Chief Operating Officer, or the Chairman of

, the Board, a

To ensure that important activities are performed correctly, BGE conducts formal traming programs for Company personnel with significant responsibilities. Dese programs include both initial and continuing training and are conducted in accordance with written procedures or instructions. Department Managers are responsible for ensuring that the training needs of personrel in their Departments are identified, formal

, training programs to satisfy those needs are developed, and the training programs are implemented in accordance with the requirements of the QA Program documents.

The QA Program was developed to meet the requirements of the Regulations, Regulatory Guides, and Industry Standards of the Nuclear Regulatory Commission (NRC) listed below. Exceptions taken to -

g;uidance enataia~l in these documents and equivalent BGE alternatives are stated in Table IB 1.

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i QUALITY ASSURANCE POLICY Revision 45 REGULA110NS 10 CFR 50.55a - Codes and Standards 10 CFR 50.59 - Changes, Tests, and Experiments.

10 CFR 55 - Operators'I_h - .

10 CFR 50, Appendix B - Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

10 CFR 72, Subpart G - Quality Assurance (ISFSI)

REGULATORY GUIDES l 1.8 - Personnel Selection and Training (September 1975)". This endorses ANSI N18.1 (03/08/71)*".

1.16 - Reporting of Operating Information (as specified in Calvert Cliffs Technical Specifications).

1.30 - QA Requirements for Installation, inspection, and Testing of Instrumentation and Electric Equipment (08/l1/72)*. This endorses ANSI N45.2.4 (03/Oln2).

1.33 - QA Program Requirements (Operation, Rev. 2, 02n8)". This endorses ANSI N18.7-1976/ANS 3.2 (02/19n6)"*.

1.37 - QA Requirements for Cleaning of Fluid Systems and Associated Co.i.yr.ccits of Water-Cooled

Nuclear Power Plants (03/16n3)". This endorses ANSI N45.2.1 (02/26n3)"*.

l 1.3P - QA Requirements for Packaging, Shipping, Receiving, Storage, and Handling ofItems for Water-l Cooled Nuclear Power Plants (Rev. 2,05n7)". This endo.ses ANSI N45.2.2 (12/20n2)"*.

m

! 1.39 - Housekeeping Requirements for Water-Cooled Nuclear Power Plants (03/16n3)*. This endorses ANSI N45.2.3 (03/15n3)"*.

3 1.54 - QA Requirements for Protective Coatmgs Applied to Water Cooled Nuclear Power Plants (0603)". This endorses ANSIN101.4 (11/28n2)*".

1.58 - Qualification of Nuclear Power Plant Inspection, Examination, and Testmg Personnel (09/80)".

This endorses ANSI N45.2.6 (1978)"*.

1.64 - QA Requirements for the Design of Nuclear Power Plants (10n3)*. This endorses ANSI N45.2.11, DraA 3, Rev.1 (0703).

, 1.68 - Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors (lln3)".

1.144 - Auditing of Quality Assurance Programs for Nuclear Power Plants, Rev.1 (09/80)". This endorses ANSIN45.2.12 (1977).

1 1.146 - Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Aug.

, 1980).*. This endorses ANSI N45.2.23 (1978)"*.

Page 15 of 57

QUALflY ASSURANCE POLICY Revision 45 INDUSTRY STANDARDS ANSI N45.2.5 - Supplementary QA Requimnents for Installation, Inspecth and Testag of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants; DraA 3, Rev.1 (lin3). .'

ANSI N45.2.8 - Supplcunentary QA Requiranents for lastallation, '-y% and Testing of Mechanical Equipment and Systems for the Construction Phase ofNuclear Power Plants; DraA 3, Rev. 2 (09n3).  ;

ANSI N45.2.9 - Requirements for Collection, Storage, and Maintenance of Quahty Assurance Records for Nuclear Power Plants; Dran (10n6)*.

ANSI N45.2.13 - QA Requirements for Control of Procuranent of Equipment, Materials, and Services for Nuclear Power Plants; DraR 2, Rev. 2, (10n3)***.

NOTATIONS FOR REGULATORY GUIDES AND INDUSTRY STANDARDS NRC endorses an Industry Standard or draR without reservation.

NRC takes exception to or provides additional guidance in a regulatory position statement.

• BGE takes exception to guidance offered and states alternatives.

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

QUALITY ASSURANCE POLICY

, Revision 45

Procedural Controls

The QA Policy and revisions thereto are reviewed by Nuclear Program Managers. QA Policy revisions are l reviewed by NQAD personnel to deermine if they constitute a reduction in commitments prenously made to the NRC. If so, the revisions are sent to NRC for approval prior to implana*h The Manager-i NQAD renews revisions to the QA Policy and recommends approval to the Vice President-Nuclear Energy

)

Division.1hc Vice President-NF.D approves the QA Policy and revisions thereto QA Program &->- =ts I j control the distribution and revidte of the QA Policy.

Nuclear Program Directives are prepared under the direction of the Department Manager assigned by the

! Vice President-NED as the Program Sponsor. Each directive and revisions thereto are reviewed by

{ affected Department Managers The Manager-NQAD casures directive revisions are reviewed by the

Quality Assurance organization and approval recommended to the Program Sponsor. The Program i Sponsor appreves the directive and revisions thereto lhe Manager-NSSD ensures issuance of all i directives and revisions thereto.

j QA Program documents ensure that:

l. The need for special controls, processes, test equipment, tools, and skills is specified when necessary ,

to ensure that required quality is attained in performance of the activity.

2. Quality is verified by inspections and tests. ,

j 3. Personnel who perform activities affecting quality achieve and maintain suitable proficiency through

! appropriate training and experience.

Review of Operations i

Procedures require that CCNPP shall be operated and maintamed in accordance with the plant TSs and 1

operatmg license. The following organizations review plant operations to ensure that these procedures are followed:

1. The Manager-NQAD provides independent verification that the requirements contained in the Plant's

, operating license, UFSAR, TSs, and plant procedures are met. This is accomplished through quality assurance audits.

{

. 2. The OSSRC provides inepa*nt verification by review that CCNPP is operated in accordance l with established requirements. The OSSRC, which functions under a written Charter approved by

the Vice President-Nuclear Energy Division, is composed of on-site and off-site personnel knowledgeable of in-plant operations, nuclear engineering, chemistry and radiochemistry, 1

metallurgy, radiological safety, instmmentation and control systems, mechanical and electrical

. systems, quality assurance, and environmental factors. The prMags of all meetings are

' MnadM and sent to the Vice President-Nuclear Energy Division, Committee members, and others designated by the Committee Chairman.

I 3. The on-site POSRC reviews matters puaining to nuclear plant safety. This Committee screens subjects of potential concem to the OSSRC and performs preliminary investigations under the .

direction of the Plant General Manager. POSRC membership and functions are governed by Technical Specifications and written procedures. The results of all meetmgs are documented and .

sent to the members of the OSSRC, and others designated by the Committee Chairman.

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QUALITY ASSURANCE POLICY Revision 45 i The maintenance and repair of systems, structures, and components subject to the QA Program are i performed by iw.c. .c: under the direction of the General Supervisors of Electrical and Controls,

Ramatu Safety, and Mechanical Maintenance, acceig to wntten procedures and mstructions as j prepared by the maintenance force and approved as stated in QA Program t-

-2=ets. These Procedures:

1. Ensure that quality-related activities, such as inspections and tests, are pdor.r.cd with appropriate equipment and under suitable envi,o e.;.1 conditions.

2. Indicate inspections and checks that must be made and records and data that must be kept.

3. Show where i% verific=*6e of inspections or checks should be performed by specified personnel other than those performing the work.

]

When - y, non plant Company perso .cl or outside contractors are brought in to supplanent the

plant work force. In such instances, the approval of work procedures and the taggmg of equipment are

. coordmated by a member of the BGE organization responsible for the performance of the work.

Controls are establirhed in QA Program documents to ensure that materials and parts used in the repair,

mairvenance, and modification of SR and designated NSR portions of the plant are appropriate for the servict intended Written procedures are prepared for the storage and identification of materials and parts i

to etm re that they do not deteriorate in storage and can be correctly identified before installation or use.

, Equipment manufacturers and contractors used for the repair, maintenance, and modification of SR and J

designated NSR structures, systems, and components are required to have quality assurance programs

consistent with the importance of the end-product to safety.

IB.3 DESIGN CONTROL Control Plant changes which affect the design, function, or method of performing the function of a structure, system, or component described in the UFSAR and are controlled by QA Program documents which are j written to ensure compliance with Regulatory Guide 1.64 and 10 CFR 50.59.

i Controls for changes, tests, and experiments conducted at CCNPP vary according to the following:

! 1. As the item or activity affected is or is not described in the UFSAR.

l

) 2. As the item or activity affected has been classified SR or NSR.

3. As the item or activity affects or does not affect nuclear safety.

4. As the proposed change, test, or experiment does or does not constitute an Unreviewed Safety

Question or require a change to the TSs.

To ensure compliance with 10 CFR 50.59, the process for controlling changes, tests, or experiments has been divided into classifications. Procedures required by QA Program documents describe and control the method for determmmg the appropriate process classification. The process classifications control the preparation and reportmg of safety evaluations. Three methods of treatment are allowable: .

1. Implementing the change, test, or experiment in accordance with Company practice for operating

power plants, or in accordance with Procedures required by QA Program documents.

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o QUALITY ASSURANCE POLICY

, Revision 45

2. Implementing the change, test, or +s.wa in acco-d.c.cc with Procedures required by QA Program hW= but controlling the change, test, or +s.v with a process classification.

3. s Controlling the change, test, or v .c.t with a process classification and not allowing the impk.eaing activity to begin until the review requirements of 10 CFR 50.59 and 10 CFR 50, Appendix B, have been met.

tM-=, tests, or experiments which require approval by the NRC are approved by the POSRC and by the i OSSRC.

Controls have been established to ensure that design changes to SR structures, systems, and m ,-----ts are reviewed either by the organization that made the original design or by a Responsible Design Organization (RDO) th'at meets requirements specified in ANSI N45.2.ll, Section 8.0. .

Responsible Design Organizations RDOs, either on contract or within BGE, ensure that:

1. Applicable regulatory requirements and design bases requirements are correctly translated into

. specifications, drawings, written procedures, and instructions.

2. Appropriate standards for quality are specified in design docun.cets, and deviations and changes from such standards are controlled.

l 3. Suitable design controls are used in applying principles of reactor physics; making seismic, stress, thermal, hydraulic, radiation, and accident analyses; ensuring compatibility of materials; and 4

providing accessibility for in-service inspection.

i

. 4. Designs are reviewed to ensure that design characteristics can be controlled, inspected, and tested, and that inspection and test criteria are identified.

5. Interfaces, both external and internal, are controlled for the activities of all participating organizations.  ;

6. Methods for verifying or checking, such as design reviews, alternative calculations, and qualification testmg are properly chosen and followed; the most adverse design conditions are specified for test 4

programs used to verify the adequacy of designs.

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7. Individuals or groups responsible for design verification are other than the original designer and the designer's immediate supervisor.

)

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8. Design and specification changes are subject to design controls and approvals applicable to the original design.

9. Design documents and revisions thereto are distributed to responsible individuals and controlled to

prevent inadvertent use of superseded material.

4 .

10. Design errors and deficiencies that adversely affect SR structures, systems, and components are documented, and appropriate corrective action is taken. -

11. Design documents and reviews, records, and changes thereto are collected, stored, maintained, and controlled systematically.

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[' QUALilY ASSURANCE POLICY Revision 45 i

12. Standard off-the-shelf commercial or previously approved materials, parts, and equipment essential to the SR functions of structures, systems, and components are reviewed for suitability of i application before they are selected.

13. He persons or groups responsible for design reviews and other design verification activities and their authority and responsibilities are identified.

14. Design changes to NSR items intiated and approved at the plant are controlled to misure compliance

. with 10 CFR 50.59.

15. Processes used to select suitable materials, parts, equipment, and processes for SR structures, 4

systems, and components includes the application of pertinent industry stand =ds and specifications, material and prototype hardware test.ng programs, and design reviews.

4

16. Computer programs used in design are subject to design controls and progmm veri 6 cation.

IB.4 PROCUREMENT DOCUMENT CONTROL (5)

Controls have been established to specify the requirements and sequence of actions for: requesting items or services; review of the requested item or service to establish the necessary technical and quality requirements; preparation, review and control of procurement h==ts; evaluation and selection of

! vendors and; control of deviations from the procurement document requirements.

l De degree to which these controls are imposed on the purchase ofitems and services by BGE for CCNPP i depends on:

1

. 1. He functional (safety) classification of each item or service as SR or NSR according to controls

! established by the RDO and

! 2. De Procurement Category of the item within it's fune*iaad classification as a basic component, l commercial grade item, designated non-safety related item (DNSR) or NSR item:

e j a. Commercial Grade - An item satisfying all three of the following criteria:

+

1. Not subject to design or speci6 cation requirements that are unique to nuclear facilities;

and

2. Used in applications other than nuclear facilities; and

3. Is to be ordered from the manufacturer / vendor on the basis of specifications set forth

in the vendor's published product description (for example, a catalog).

b. Basic Component - An item either procured as a safety related item or as a commercial grade item which has been accepted and dedicated for safety related application. This term is synonymous with " Safety-Related Component".

. c. Designated Non-Safety Related - A NSR item which BGE has made a regulatory or design .

basis commitment; or, for plant availability reasons, BGE has implemented special controls to assure reliability. Dese NSR items are included within the quality assurance process. .

. d. Non-Safety Related - An item that does not perform a safety related function.

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QUALITY ASSURANCE POLICY Revision 45

3. The procurement method to be used for the item or service:

Purchase Orders placed by BGE ph for items or services intended for safety related.  ;

applicatens and DNSR items and services fall into two categories, Nuclear Grade Method procurement and Commercial Grade Method procurunent.

a. Nuclear Grade - Purchname that are designated to be placed with vendors that maintain a 10CFR50 Appendix B quahty program and supply items that meet the definition of Basic C = ,aaaaat The requirements of 10CFR21 will be invoked on the vendor under this method

b. Commercial Grade - Pun:hases that are designated to be placed with commercial grade vendors that supply items or services that meet the definition of Commercial Grade 'Ibese items must be dedicated for SR use by BGE.

Itans and/or services classified as DNSR will be purchased using the Commercial Grade Method with *~ hale =1 requirements established by an RDO.

Qualified NSSD/NED personnel trained in quality assurance program requirements with RDO authority review safety-related and designated non-safety related procurement documents for proper inclusion of technical and quality requirements. Personnel in NSSD/NED review safety-related and designated non-safety sclated procurement documents to ensure that the requirements stated therein are correct,

+

inspectable, controllable, contain adequate acceptance and rejection criteria, and comply with the requirements of the procurement program. 'Ihese reviews and approvals are dacamaa*M prior to placement of the purchase order.

All changes made to procurement documents, including speci0 cations and other technical =t*=rhments, are subject to the same levels of review, approval and control that were applied in preparing and processing the original documents.

l Bids submitted to supply safety-related items or services receive the same review and approval cycle as used for safety-related procurement requisitions.

Vendor Selection Personnel in NQAD evaluate vendors who provide SR and designated NSR items and services to verify they can provide acceptable items and services. '

l Controls for Nuclear Grade Purchases J Controls have been established to ensure that, before placement of a purchase order under the Nuclear l Grade method of purchase, there is evidence of the following: j

1. 'Ihe vendor has been evaluated as stated in Section IB.7 of this policy and found to have a 1 satisfactory QA program.

2. "Ihe item to be purchased is manufactured under the requirements of the evaluated and approved program. -

Controls for Commercial Grade Purek=- .

Controls have been established to ensure that items or services available to general industry will be sufficiently controlled to perform their SR and designated NSR function. NSSD/NED personnel will specify the acceptance methods to be used to verify the critical characteristics identified in the procurement h=aat(s).

Page 21 of 57

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QUALITY ASSURANCE POLICY Revision 45 pv.:w...=.: D:- = -= pwa._--=,

Procedures require that procurement he shall:

1. Reference part numbers or descriptions, and additional requirements to ensure that items ordered can be ident:6ed and ven6 cation can be made that each item received is the item ordered.

2. Contain/ reference technical requirements for the basis of design, by includmg the applicable regulatory requirements, component and material identification, RDO approved drawing and specirwatina, codes, industrial standards, test and inspecten requirements, and special process instructmas such as weldme, heat treating, nondestructive testing, and cleaning

3. Identify the requirements of 10 CFR 50, A#N B, which must be complied with and described in the vendor's QA program, for Nuclear Grade Purchases

4. Require that major contractors designated as BGE agents to purchase SR and designated NSR items or services must have procurement controls to ensure they purchase or acquire these items or services in compliance with the necessary sections of ANSI N45.2.13.

5. Identify required himantation (i.e., drawings, specifications, procedures, inspection and fabrication plans, inspection and test records, personnel and procedure qualifications, and material chemical and physical test results) to be prepared, maintained, and submitted to BGE or the purchaser for review and approval.

6. Identify records which must be retamed, controlled, maintained, or delivered to BGE or the purchaser before use or installation of hardware.

i

7. Specify BGE or its agent's right of access to vendor facilities and records for source inspection, surveillance, verification and audits.

i 8. Identify requirements of the vendor's quality control process which must be implemented when providing a commercial grade item. i

9. Reference or specify the critical characteristics that a commercial grade item must possess to ensure that the item received is the item specified.

I 10. Incorporate the requirements of 10 CFR 21 for Nuclear Grade procurements.

11. Include requirements for QA program elements to be passed on to sub-vendors.

IB.5 INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS l

j Controls delincate the sequence of actions to be performed in the preparation, review, approval, and control ofinstructions, procedures, and drawmgs Controls require that:

1. Methods for complying with each of the applicable criteria of 10 CFR 50, Appendix B, must be specified in instructions, procedures, and drawings -

2. Instructions, procedures, and drawings must specify appropriate quantitative (such as dunensions, tolerances, and operatmg limits) and qualitative (such as workmanship samples) acceptance criteria for verifying that important activities have been satisfactorily accomplished.

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QUALITY ASSURANCE POLICY

Revision 45 l Controls ensure that

1 j 1. The QA Policy is approved by the Vice President-Nuclear Energy Division. (1)

2. Nuclear Program Directives are prepared under the direction of the Department Manager assigned

as the Program Sponsor. Affected Department Managers review ducctives and their revisions. 'Ibe Manager-NQAD ensures directives are reviewed by the Quahty Assurance vi =W and

,i approval ra.. .sdc4 to the Program Sponsor. 'Ihe respocsible Program Sponsor approves directives and their revisions. Directives are prepared, reviewed, approved, and periodically reviewed according to an =pp=A to the Nuclear Program Directives Manual.

3. Procedures are prepared, approved, and controlled accordmg to the Control Procedures. Control Procedures establish review, approval, revision, change, and periodic review i%.u..sts for j applicable procedures. If format and contet requirements are not enntainari in Control Procedures,

they shall specify the d~-

• to be used to d.A...dr,s format and content requiranents. Control Procedures are reviewed by the Quality Assurance Oganiratian to ensure compliance with j regulatory requirements and industry standards. Other procedures are reviewed by Quality l Assurance on a requested basis.

4. Basis items added during procedure revisions or changes wit! be recorded. (1) 2 1B.6 DOCUMENT CONTROL

' Requirements have been established to control the documentation of activities controlled by the QA Program QA Program controlled documents include the UFSAR; Operating Licesise, including the Technical Specifications; Emergency Res ponse Plan; Security Plan; QA Policy; the ISFSI updated Safety Analysis Report (SAR) and Materias License, including Technical Specifications; procedures; specifications; and drawings.

l Revisions to the QA Policy are controlled by QA Program documents which are written to ensure compliance with 10 CFR 50.54(a)(3).

! Alterations to the UFSAR are controlled by QA Program documents which are written to ensure j compliance with 10 CFR 50.71.

l l Alterations to the ISFSI updated SAR are controlled by QA Program documents which are written to ensure compliance with 10 CFR 72.70, b Alterations to the Operating License, including the Technical Specifications, are controlled by QA Program documents which are written to ensure compliance with 10 CFR 50.59(c),10 CFR 50.90 and 10 CFR

] 50.92.

! Alterations to the ISFSI Matenals License, including the technical specifications, are controlled by QA Program documents which are written to ensure compliance with 10 CFR 72.48(c),10 CFR 72.56, and 10

CFR 72.58.

Alterations to the Emergency Response Plan are controlled by QA Program documents which are written to -

ensure compliance with 10 CFR 50.54(q), and with 10 CFR 72.44(f) for the ISFSI.

Alterations to the Security Plan are controlled by QA Program documents which are written to ensure  ;

compliance with 10 CFR 50.54 (p), and with 10 CFR 72.44(e) for the ISFSI. 1 l

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--____ ________ _ .____ _ ___ _ - _ _ _ --____-_ _ J

QUALITY ASSURANCE POLICY Revision 45 Directives are required to:

1. Establish controis to ensure that regulatory requirements and BGE commitments will be implemented

2. Establish controls to ensure that management requirements will be implemented

3. Assign responsibilities and interfaces within the program

4. Be prepared and controlled in accordance with an appendix to the Nuclear Program Directives i Manual that describes the format, contents, review and approval, revisions, and periodic review requirements.

I Nuclear Program Directives are prepared and technically reviewed under the direction of the Department Manager assigned as the Program Sponsor. Each directive is reviewed by affe' cted Department Managers.

Each directive is given a compliance review by a member of the Quality Assurance organization Nuclear Program Directives are approved by the sponsoring Manager after ensuring resolution and incorporation of QA compliance review comments. (9) The Manager-NSSD ensures issuance ofeach directive.

Administrative and Technical Procedures are prepared when needed to implement QA Program document

, requirements according to a Control Procedure. Individual organizations are responsible for preparmg, revising, issuing, and controlling procedures. Each procedure is given a technical review under the i

direction of the sponsoring organization. The Quality Assurance organization performs compliance reviews on Control Procedures. Other procedures are reviewed by Quality Assurance on a requested basis.

Administrative procedures are required to:

1. Describe interdepartmental interfaces and establish controls for interdepartmental activities.

2. Specify how important activities, such as plant maintenance or in-service inspection, are to be performed, and give sufficient detail to control the performance of the activity or to ensure that requirements for lower-level procedures are clearly specified.

i 3. Be prepared and controlled in accordance with QA Program documents that describe the format, 3 sequence of topics, contents, review and approval, issue and distribution, and requirements for l revision and record retention.

During the review of each administrative procedure, compliance with applicable regulatory requirements 3

and industry standards is verified and documented.

Organizations that issue instructions, procedures, specifications, or drawings are required to establish controls that ensure the following:

1. Changes to a document are reviewed and approved by the orgamzation that performed the original review and approval unless the control procedure designates another qualified responsible organization.

2. Approved changes are promptly incorporated into instructions, procedures, drawmas, and other documents associated with the change. .

i 1

3. Obsolete or superseded documents are controlled to reduce the possibility of inadvertent use, Superseded documents retained for reference are marked and stored in separate files. Other superseded documents are removed from the files.

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QUALITY ASSURANCE POLICY Revision 45 i

When changes to drawing) v ei,i4LZees are required, change requests are prepared by the organization that desires the change. Requests are reviewed and approved by BGE RDOs.

IB.7 CONTROL OF PURCHASED MATERIAL. EOUIPMENT. AND SERVICES (5) i NQAD, NSSD, NED, and PMMD personne: are responsible for the control of purchased items and services for SR and designated NSR applications at CCNPP.

'Ibe controls include:

i A l*% items or services only fiom ven6rs who have been evaluated and selected in accordance j with this policy.

Procuremem documents for spare or replacement parts of structures, systems, and cc...pc.s.ts as designated under the QA Program subject to controls at least equivalent to those applied to the original equipment, or an evaluation / justification shall be documented when less stringent controls are involved.

i i Vendor surveillance, verification and audit activities, and receipt verification are conducted to ensure the vendors comply with specified technical and quality requirements, and ensure items are identified, stored, handled and shipped in accordance with procurement daw requirements.

Vendor Evaluation

1

The vendor evaluation is conducted to de:ernune acceptability of a vendor to provide the requested item or

' j service, to determine what vendor programs, procedures and documents need to be invoked by the 1 i procurement d=iment, determining the vendor's performance history for supplying items to CCNPP and i' assessing the need to impose source surveillances and/or verifications during the manufacture ofitems or performance of services for BGE. Vendor evaluations depend on the procurement classification of the j item (s) being supplied. ,

The National Institute of Standards and Technology (NIST), by virtue ofits being the nationally rm=ai=1

, standard, is an acceptable provider of calibration masters, standards or services. Utilities holding an NRC

, Construction Permit or Operating License are acceptable suppliers of all items except for those items to be  :

4 used in an ASME Boiler and Pressure Vessel Code Section III application. Neither of the above are .

required to be listed on the Approved Vendors List (AVL). l 1

) Nuclear Grade 4

NQAD performs evaluations and audits to verify that the vendor has developed and implemented an acceptable quality assurance program that complies with the requirements specified in the procurement specification or proposed procurement specification. These evaluations and audits 4

are conducted _ and documented using written procedures or checklists that identify the QA requirements applicable to the items supplied.

Commercial Grade )

j Since BGE accepts the responsibility of verifying the conformance of commercial grade items 4

and/or service, they may be procured from vendors with no formal quality assurance program. In -

this iew BGE dedicates the commercial grade item and/or service for SR use.

A survey may be iwifvii.v4 of commercial vendors to assess what, if any documented controls are implemented in the manufacture at items or performance of services for BGE.

Page 25 of 57

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-QUALITY ASSURANCE POLICY l Revision 45 Vendor controls evaluated to be satisfactory may be invoked as requirements within the purchase order and may be used as part of the basis for =+/=c of the item.

The depth of vendor evaluation varies according to the complexity and function of the item involved and to the role of the vendor in acceptance of the item.

Vendor Apprpval Upon completion of the evaluation, satisfactory vendors are added to BGE's AVL. The vendors on this list are evaluated on an annual basis and subject to re-audit or commercial grade survey on a triennial basis to verify continued compliance with BGE's requirements.

An auditing organization such as NUPIC, another utility, a contractor to BGE, etc., may be used to verify that the vendor has developed and implemented a QA program that complies with 10 CFR 50, Appendix B or a commercial grade program that complies with the requirements of BGE's procurement requirements or similar requirements.

When required by operational considerations, an order may be placed with a vendor prior to completion of the evaluation and approval process only after obtaining the Manager-NSSD's approval. BGE's acceptance of basic component items or services provided by an unapproved vendor is contingent on the subsequent NQAD evaluation and approval of the vendor as stated above.

Verification of Vendor Activities Vendor surveillance, and source verification activities are conducted by qualified NQAD personnel in accordance with written procedures or checklists. These procedures or checklists, along with the procurement hments, specify the characteristics or processes to be witnessed, inspected or verified.

Personnel performing these activities are qualified to establish whether or not a vendor is capable of providing products of acceptable quality.

The depth and frequency of vendor surveillances, verifications and audits is commensurate with the complexity and function of the item or senice and the ability of the vendor to provide the necessary

assurance of acceptability.

i

^

When a vendor's certificates of conformance are used as part of the acceptance of an item or service, the validity of these documents is periodically evaluated and documented by the above mentioned processes.

Receipt 4

NSSD is responsible for receiving and storing materials, parts, and components.

Additionally, NSSD is responsible for performing standard and special receipt inspections and coordinating testmg necessary to accept SR items, designated NSR items and commercial grade items for SR use.

Standard receiving inspection ofitems is performed to assure the following:

I. The item is properly identified and that this identification corresponds with the documentation -

received.

1 .

2. Stated packaging, shipping and handling requirements have been maintained.

3. Items have not been damaged, workmanship is of adequate quality, and the items are adequately

clean in accordance with procurement Mment requirements.

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4 QUALITY ASSURANCE POLICY Revision 45

4. L%==tation required by the Purchase Order has been received and is reviewed to assure that the item conforms to the purchase order requirements.

Special receiving inspection may be required if the item was not inspected at the source; when requested by the RDO or; as part of the =W== basis for commercial grade items.

A written record of the results of the NSSD receipt inspection and the disposition of received items is maintained as part ofi m....r =^ plant records. l All SR and designated NSR items accepted and released for issue to a controlled storage area or released for installation or funher work bear an acceptance tag and have t-:-: ==tation to support their acceptaoility. If traceability is lost or the h==*=*6 review is unsatisfactory, an item twas subject to the controls established for non-conforming items.

Non conforming items are identi6ed and handled in accordance with Section 1B.15 of this policy and, when practicable, are placed in a segregated area to prevent inadvertent installation or use until proper disposition is made.

Documentation BGE procurement documents require vendors to provide documentation identifying the purchased item and the specific procurement requirements that are met by the item.

Vendor inspection records or certificates of conformance attestmg to acceptance must be. in the possession of BGE before the item may be released for installation or use. However, an unacceptable item may be  !

given a " Conditional Release" if there is reasonable assurance that it can be made acceptable after )

installation but before the system that contains it is considered operational. Items released under

" Conditional Release" must be controlled under a non conformance report system.

Vendor requested deviations from procurement document requirements, including nonconformances dispositioned "use-as-is" or " repair" must be submitted to BGE for evaluation and approval of the deviation or a recommended disposition prior to shipment.

IB.8 IDENTIFICATION AND CONTROL OF MATERIALS. PARTS. AND COMPONENTS (5)

NSSD/NED personnel ensure that procurement documents require that SR and designated NSR items, including partially fabricated sub-assemblies, are identified and controlled to prevent the use ofincorrect or defective material.

Requirements for identification by use of heat number, part number, or serial number, or by other means, are referenced or stated in procurement documents. 'Ihese documents require the identification to be placed on the item or in records traceable to the item so that the function and quality of the item are not affected.

'Ihis identification is required to be maintamed throughout fabrication, storage, erection, installation, and use. NSSD personnel ensure traceability information is correctly transferred to subdivided materials stored in the Warehouse. User organizations ensure traceability information is correctly transferred to subdivided materials after issuance from the Warehouse. NQAD is responsible for performing periodic inspections or surveillances to verify program adherence. -

Assigned NSSD personnel purchase identify, store, and issue items as specified by procurement controls -

and provide for ruintammg the integrity of items and their traceability to associated dw.w,sts during storage and issue. 1 Page 27 of 57

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QUALfIY ASSURANCE POLICY i- Revision 45

BGE contractors and their subcontractors (who are approved to work on-site under their own QA i program) are responsible for establishing and implanenting programs in as d-we with specified requirements for identifying and controlling materials, parts, and s .g,;_..;. under theirjurisdiction.

, Identi6 cation of items important to the function of SR and designated NSR structures, systems, and i w ..rczze:s can be traced to appropriate documentation such as drawmgs, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and chemical mill-test reports.

Receipt l

, SR and designated NSR items received at CCNPP are receipt inspected to verify that all requirements of the procurement han~* have been met. If a discrepancy is observed, such as damage or missing haantation, information to the effect is recorded on the receiving inspection report, and the discrepant item is identified as such and placed in a separate " hold" area when practicable. If the item is -*ymble, it is identified to indicate ry - and that it is approved for storage or installation and use. When groups j ofitems in storage are subdivided, each subgroup is separately identified. 1 1

j If an item is found to be or is made discrepant during processing, it is identified as such and placed in a

separate area when practicable.

Acq~e documentation is required to be traceable to a purchase order, drawing, specification, j

requisition number,'or assembly. As individual items are assembled, installed, and inspected, their l 1

l acceptance-tag numbers are recorded in plant maintenance or operation records.

4 After completion of tests and inspections, records that hmant test results and traceability are kept as part of the plant records.

i IB.9 CONTROL OF SPECIAL PROCESSES Controls Controls have been established for writing, qualifying, approving, and issuing procedures to control such special processes as welding, heat treating, and W'uctive testing used during the operation of CCNPP.

Special Process Procedures:

1. Are prepared in accordance with applicable codes, standards, specifications, criteria, and other

special requirements.

j 2. Ensure that special processes are performed by qualified personnel according to qualified procedures i that comply with applicable regulatory requirements.

5

3. Specify requirements for control, parameters to be considered, acceptable methods of documentation, and the codes, standards, specifications, or criteria which govem the qualification.

1

4. Define the r-ary qualification of persciggl, procedures, or equipment when special processes

, are not covered by existing codes or standards or when quality requirements for an item exceed the requirements of established codes or standards -

BGE contractors and their sub contractors are responsible for controlling special processes used by them .

and for maintaimns records to verify that special processes are performed in accordance with requirements j established by the portions of their QA programs that apply to special processes, f

4 2

i i Page 28 of 57

QUALITY ASSURANCE POLICY i

Revision 45 Ouahfication ofMethods Pmoedures, equipment, and personnel connected with special processes are q:alified in acco.-d.sce with

applicable codes, standards, sp+"- =

ans, or supplementary requirements as follows.

i

1. Welding activities conducted by BGE are p.foi...e4 acco.d4 to weldmg procedure specifications 1

=1ihd in accord.i.cc with applicable welding requirements of the ASME Code. Each welding procedure specification is written, ;=13hd and approved in accordance with a controlling documented procedure. Copies of weldmg procedure speci6 cations are made avadable to welders and, when required, to Authorized Inspectors. Before contracting for weldmg, the General j

Supervisor-Mechanical Maintenance reviews and approves non-BGE weldmg procedure

speci6catens and procedure ;=1*=*iaa records in accordance with a wntten procedure.

2. Heat treating requirements included in weldmg procedure =-i&=' ions are established in

conformance with heat-treatmg requirements of the applicable ASME Code.

t

3. Nondestructive Examinations are performed to written procedures proved by actual dcisces.Gon, when practicable, to the satisfaction of the Principal Engineer-Materials hgin-ing and Inspection and, when required, the Authonzed Inspector.

'Ihese procedures are prepared acco,dQ to appropriate sections of the ASME Code for particular j examination methods. Procedures, personnel qualifications, and the records that verify the Performance of Nondestructive Examinations are kept as nuclear plant records. Nondestructive Fv=mia=* ion Procedures describing methods not described in the ASME Code and/or SNT-TC-1A and its Supplements are at least 4

equivalent to those rmmi-I by the American Society of Mechanical Engineers and the Amencan Society for Non-destructive Testing. Training programs acceptable to the Principal Engineer-Materials Engineering and Inspection are developed to complement these alternative methods and to establish the l

capability of personnel to perform the required examination according to BGE procedures and to the level

of performance to which the individual will be certified.

Methods of Nondestructive Examination include, but are not restricted to, radiographic, ultrasonic, i liquid-penetrant, magnetic-particle, eddy-current, visual, and leak-testing examinations.

4 Procedures are prepared to cover these examinations in accordance with a QA Program document '

! that details the specific examination, requirements for approval, and content of the procedure, such as certification level, accept / reject criteria, examination coverage and sequence, surface preparation, test equipment, records required, permissible marking, cleanup requirements, and reference to applicable sections of the ASME Code.

1

{ . Qualification of Personnel l

,' Special processes are performed by certified personnel using written process sheets, shop procedures, checklists, and travelers (or equivalent), with recorded evidence of verification as follows:

1. BGE welders, and welders under contract to BGE, are qualified and certified in accvid.sce with the applicable requirements of the ASME Code. The General Supervisor-Mechanical Maintenance maintains records of the welding procedure specifications, including essential variables under which the welders are examined, and the results of the examinations A welder is not permitted to weld SR -

and designated NSR items until an appropriate performance qualification record, a letter of certification, or, in an emergency, verbal clearance from the General Supervisor-Mechanical -

Maintenance, is on file at CCNPP. Each welder is required to be requalified as specified in the applicable code.

2. Non-BGE welders are not permitted to weld SR and designated NSR items until they are qualified i and certified in accordance with the applicable requirements of the ASME Code.

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4 QUALITY ASSURANCE POLICY Revision 45

3. Nondestructive Examination personnel anployed by or responsible to BGE are certified mixei4 to applicable sections of the ASME Code and/or SNT-TC-1A and its Supplements. BGE employees are trained and certified in accordance with a wntten procedure. Non-BGE grecs.41 are qualified to procedures approved by BGE, and their Mine=*iaas and certifications of personnel are verified accordmg to written procedures.

Quahfication records of procedures, equipment, and personnel associated with special processes conducted by BGE are filed and kept current by the General Supervisor-Machanical Mam eanance or Principal Fa.iaa. . Materials FT=- e; and 1==aar*iew The Manager-NQAD provides 3% verification that special processes are gifes.../. by qualified personnel.

1B.10 INSPECTION Activities that affect the quality of SR and designated NSR items are la=aac*ad as specified in approved instructions, procedures, and plans which set forth requirements and acceptance criteria to ensure diat work is done in conformance with particular requirements.

Controls exercised during inspections ensure that:

1. Personnel who perform quality verification inspections are independent of the personnel who performed the activity being inspected

2. Inspection procedures or instructions, with rwa ==ary drawings and specifications for use, are available before inspection operations are performed.

3. In the case of special processes, inspectors are qualified, and their qualifications comply with applicabic codes and standards.

4. Test and measuring equipment is calibrated within required limits.

5. Inspection procedures, as applicable, specify objective acceptance criteria, prerequisites for j performing inspections, limiting conditions, requirements for special equipment and . Quality l Verification (QV) hold-points at which inspections are to be witnessed.

6. Appropriate inspection requirements are established for modification, repair, and replacement.

i 7. Personnel who perform quality verification inspections are qualified in accordance with appropriate

' codes, standards, and Company training programs, and their qualifications and certifications are kept current.

l 8. Procedures for maintenance and modification are reviewed by QV personnel, or others authorized by

i. QV, to determine the need for independent inspection e.nd the degree and methoi if such an inspection is required, and to ensure the identification ofinspection prso. wl and the documentation 4

of tapection results.

i

9. Procedures for Nondestructive E==ia=* ion, including procedures for nuclear fuel inspection and visual examinatier. on nuclear fuel,' are reviewed by qualified personnel in NED. Review is to .

determine the adequacy of procedural controls and of inspection criteria, the need for i%t inspection, and the degree and method, if such inspection is required; and to ensure the identification i of qualified inspection personnel and the t-:-:s-station ofinspection results.

10. Inspection results are recorded, evaluated, and retamed Page 30 of 57

J ,

QUALITY ASSURANCE POLICY Revision 45 Inspectson procedures, instructions, and thrilints used by inspection personnel provide the followmg-

1. Identification of characteristics to be i=~*d

2. Acy== and rejection enteria.

3. Description of the method ofinspection.

4. Identification of required procedures, drawings and speci6 cations

5. Identification ofinspector or data ris,isi.

6. Verification of completion and certification ofinspectmn

7. Record of results ofinspection.

8. Provision for identifying mandatory inspection hold-points for witness for an authorized inspector or BGE inspection personnel.

9. Provision for indirect control by monitoring processing methods, equipment, and personnel if direct inspection is not possible.

10. Specification of necessary measuring and test equipment including requirements for accuracy.

The General Supervisor-Quality Verification (GS-QV) is responsible for the preparation and implementation of procedures for inspection and surveillance activities performed by or for QV. (11)

Other inspections are conducted randomly to verify that overall plant operations are being conducted according to approved procedures and to ensure that the use of jumpers is properly hmented; that equipment is returned to operating status after test, modification, or repair; that instruments are properly ,

calibrated; and that personnel who perform tests are properly trained and qualified. I l

In-service inspections are perform-d on pressure-contauung components within the reactor coolant system I boundary according to requirements of the TSs. l b In-service inspections and exammations on components designated Class I or Class Il by the ASME Code l are witnessed or otherwise verified by an avthorized Code Inspector who is responsible for ensuring that i the work is performed by qualified personnel according to written qualified procedures. Records of in-service inspections, results, corrective action required and taken, inspection standards required for repair,  !

[ and results of inspection of repairs are maintained and compared with the results of subsequent '

l examination.

! i l

1B.11 TEST CONTROL l

To 1.r.crohne the ability of SR and designated NSR structures, systems, and components to function as

designed, they are subjected to a program of surveillance and operational testing. Procedures specify the l systematic development, review, approval, and conduct of tests and review of test results. Conditions such .

! as failures, malfunctions, deficiencies, deviations, and non-conformances discovered during testing are i d~ ===*d and evaluated.

I Whenever testing is required to demonstrate that SR and designed NSR material, parts, components, or

, systems will perform satisfactorily in service, a test program is established and procedures are used that

, have been written and approved in accordance with basic requirements.

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P QUALITY ASSURANCE POLICY Revision 45 Nuclear hia mg Department, and CCNPPD conduct tests to verify that plant behavior conforms to

design criteria, ensure that failure and substandard performance are identified and controlled, and

t s..sessie satisfactory performance aRer plant modification and maintenance activities.

i Written test procedures are devcleid, reviewed, and approved before testing is gifvi...cd. 'Ibey specify instructions for testing, nwthods of test, test equipment, and instrumentation; and for the following as applicable:

4

1. Adequate and appropriate equipment.

) 2. , Preparation, condition, and completeness ofitem to be tested

3. Suitable and controlled environmental conditions.

4. Mandatory inspection hold-points for witness by BGE inspection or authorized inspector personnel.

5. Provision for data collection and storage.

6. Acceptance and rejection criteria.

7. Methods of documenting or recording test data and results.

8. Provision for ensuring that test prerequisites have been met.

Test results are documented and evaluated; they are accepted or rejected by a qualified, responsible

individual or group.

Results of completed tests on SR and designated NSR structures, systems and components (per Q-List) that identify a malfunction or were out of specification are reviewed and evaluated by the POSRC and accepted and approved by the Plant General Manager. Test records are kept in sufficient detail to make i possible an evaluation of test results and to show how individual tests demonstrate that SR and designated  ;

] NSR structures, systems, and components and the plant as a unit can operate safely and as designed. SR

and designated NSR test records are retained as plant history records.

! Results of testing perfonned as part of receipt inspection are evaluated, accepted and approved by qualified NSSD personnel. (5) j IB.12 CONTROL OF MEASURING AND TEST EOUIPMENT 1

Calibration controls have been established to prescribe the technique and frequency of calibration, maintenance, and control of measuring and test instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive test equipment used in measuring, inspectmg, and monitoring SR and designated NSR components, systems, and structures during the operations phase of CCNPP.

Personnel of the following functional organizations control, calibrate, and adjust measuring and test equipment:

System Opemtion and Maintenance Department Calvert Cliffs Nuclear Power -

Radiation Safety .

Plant Department -

Performance Engineering Unit Mechanical Maintenance Electrical and Controls Nuclear Operations l Chemistry l

Page 32 of 57

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' QUALITY ASSURANCE POLICY Revision 45 Calibration controls require each group to identify measuring and test equipment and calibration test data related to it.

Written procedures are prepared and implemented to ensure that tools, gauges, instruments, and related test

and measuring devices are of proper accuracy to verify conformance to established requirements.

[ Manufacturer's Procedures are used for calibration or a procedure is prepared for each category of measuring and test equipment as necessary. 'Ihese Calibration Procedures contain the following i mformation i

1. Identification of the item to be calibrated and its period of calibration.

2. Standards to be used, speciSc test-points, and checks, tests, and measurements to be made.

i

3. Ac m criteria to be used and special precautions to be taken when necessary.

, Measuring and test equipment that require calibration are assigned an identifying serial number.

l- Instruments are calibrated at specified intervals according to the required accuracy, purpose, degree of usage, stability characteristics, and other conditions that affect the measurement.

! When equipment is found out of calibration, an evaluation is made by the supervisor responsible for that l equipment to determine any adverse effect on items previously accepted on the basis of using that equipnent.

! Test and measuring equipment that cannot be adjusted to required tolerances during calibration is identified

?

and placed in a designated segregated area; if the equiprnent can be used in limited applications, the l limitations are identified.

i 'the status of each item controlled under the calibration system is recorded and maintained. Equipment is

marked or records of calibrations are maintained to indicate calibration status. An interval of calibration is 4

established for each item of measuring and test equipment and recorded on a master record of calibrations

. prepared as a calibration schedule.

Measuring and test equipment is controlled to prevent the use of uncalibrated or defective equipment, the spread of radioactive contamination, the introduction ofimpurities into high-purity systems, and damage to 1

) or loss of equipment. Identification tags are placed on measuring and test equipment to indicate such  ;

special conditions as radioactive cleanliness, special limitations, or failure to meet established calibration j

requirements. l Measuring and test equipment is calibrated and adjusted at specified intervals, or before use, against  !

, certified standards. Reference and transfer standards are traceable to nationally recognized standards; or, where national standards do not exist, provisions are established to document the basis for calibration.

3

i. IB.13 HANDLING. STORAGE. AND SHIPPING r

Appropriate and special requirements for handling, preservation, storage, cleamng, packaging, and  !

shipping of SR and designated NSR items are specified in procurement documents.

I Procedures have been established to ensure that the handling, preservation, storage, cleaning, packaging, .

and shipping of SR and designated NSR items are performed in accordance with specified requirements to reduce the likelihood of damage, loss, or deterioration by such environmental conditions as temperature or  :

, humidity.  !

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Page 33 of 57

QUALITY ASSURANCE POLICY Revision 45 Special w%. preservation, storage, F =M. packaging, and shipping activities ===~i=W with SR and l designated NSR items are perfonned by suitably tramed personnel in accorder.cc with spect6c wntten l procedures.

1 Controls have been established for the safe storage of hazardous matenals. Items with a imuted shelf-life are controlled to ensure that they will not be used in SR and designated NSR applications after expiration ofdesignated shelf-life periods.

IB.14 INSPECTION. TEST. AND OPERATING STATUS Controls have been established for the application and removal of status indicators such as tags, markings, labels, and stamps to ensure that the inspection, test, and operating status of SR and desp=H NSR structures, systems, and w-vca ;. is clearly indicated at all times.

l 1 Procedures / instructions are prepared to identify and control inspection, testing, and operating status by the

! use of logs, forms, and tags that identify the inspection, test, and operating status of structures, systems, and components; control the use ofindicators, including the authority for their application and removal; control bypassing operations, such as jumping or temporary removal of electrical leads; and identify non-i conforming, inoperative, or malfunctioning structures, systems, or components Senior shift personnel are responsible for aligning, isolating, and appropriately tagging installed equipment and systems so that activities affectmg quality can be perfomuxi.

The Manager-NQAD is responsible for the performance of surveillances to verify that the inspection, testing, and operating status of structures, systems, and components are properly identified and controlled during operation, maintenance, and testing of the plant.

'Ihe bypassing of required inspections, tests, and other critical operations is controlled to ensure that bypassed inspections or tests are properly <tenmented and that the effect of bypassing the inspection or test is evaluated by the organization responsible for specifying the inspection or test. Controls have been established to ensure that the status of non-conforming, inoperative, or malfunctioning SR and designated NSR structures, systems, or components is identified to prevent inadvertent use.

IB.15 NONCONFORMING MATERIALS. PARTS. OR COMPONENTS (6)

Controls have been established for identifying, documenting, segregating, reviewing, dispositioning, and I

notifying affected orgaruzations ofissues affecting materials, parts, or components (i.e., items).

l Issues affectmg nuclear plant items are referred to as nonconformances Nonconformances are hardware  !

deficiencies which render the quality of an item unacceptable or indetermmate.

Any individual identifying an actual or suspected nonconforming item is responsible for documenting and reportmg such nonconforming item promptly to supervisory or Nuclear Quality Assurance Department personnel.

Nonconforming items are controlled by docurrentation, markmg, logging, taggmg, or physical segregation to prevent inadvertent installation or use.

Nonconformance control documents are submitted to responsible departments for resolution. Designated .

personnel have the responsibility and authority for approving the resolution of nonconformances Nonconformance control documents are not closed until corrective actions have been completed.

Page 34 of 57

1 .

l QUALITY ASSURANCE POLICY l

l Revision 45 Nonconforming items are dispositioned as rework, repair, reject, or accept-as-is. 'the disposition of a repair or accept-as-is inciisformance is treated as a de6ign change and is evaluated and approved or rejected by the RDO.

Reworked, repaired, and reph aa* items are i-a~*~8 and/or tested in accordance with the original inspection and/or test requirements or ==ptakle alternatives to ensure that critical characteristics possibly affected by the nonconformance remain acceptable.

Nanconformmg items may be conditionally released for installation, test, eneroiwiaa. pressurization, or use if the conditional release will not adversely affect nor preclude identification and correction of the nonconformance. Nonconforming items required for Technical Speci6 cation operability may be released for use following verification that the nonconforming item meets all operability requirements specific to its function and is approved for use by authorized Operations personnel. Conditionally released items will be resolved in accuid.iice with this Section Conditional release evaluations are h==*~i reviewed, and approved prior to implementation.

1B.16 CORRECTIVE ACTION (6)

Controls have been established to ensure that Issues are identified, documented, reviewed, and corrected These controls are applied to deficiencies associated with the programmatic content, process, and implementation of the Quality Assurance Program as well as nonconformances (ref Section IB.15).

l Corrective actions are implemented by responsible personnel and may include immediate actions, remedial actions and/or actions to prevent recurrence, based on the significance and extent of the Issue.

Issues identified as potentially impacting the safe production of nuclear power are evaluated for Technical Specification Operability, NRC Repostability, Nuclear Safety Significance, and if the activity should be stopped. 'Ihe VP-NED, or designated alternate, is informed ofIssues which require NRC notification.

Corrective action verification is performed for Significant Issues prior to the close-out of the corrective action document. Verification is performed and documented by individuals not directly involved with 1 implementing the corrective action (s). Unacceptable corrective action (s) are reported to supervisory or j management personnel directly responsible for resolving the Issue and to progressively higher levels of management until the Issue is resolved.

Significant Issues require a root cause analysis and the implementation of corrective actions to prevent recurrence and are reported to management for review and assessment.

Issues are periodically analyzed for the identification of sdverse quality trends The existence of an adverse quality trend is resolved in accordance with this section. A Trend Report is issued to management at intervals specified in approved procedures.

IB.17 OUALITY ASSURANCE RECORDS Controls have been established to ensure that quality assurance records are rnaintained to provide

' documentary evidence of the quality of SR and designated NSR items and activities. Applicable design specifications, procurement documents, test procedures, operational procedures, TSs, and other documents specify records that should be generated, supplied, or maintained by and for BGE.

Quality assurance records are classified as lifetime or non-permanent.

Page 35 of 57 1

\

QUALITY ASSURANCE POLICY Revision 45 Lifetime records, numtmind for particular items for the life of CCNPP, for pasticular items have significant value in relation to t- ..ai-bating capability for safe operation; maintaining, reworking, mpairing, replacmg, or ivisst,-4 an item; des.J 4 the cause of an accident or malfunctaan of an itan; and providing required haneline data for ingervice i=5=+1aa Non-i....er.ir.t records, which show evidence that a SR and designated NSR activity was i fvi...sd in accordance with applicable requirements, are retained for periods suf5cient to ensure BGE's ability to reconstruct significant events and to satisfy applicable regulatory requirements Retention periods are based on requirements specified in QA Program documents Retention periods shall be docun=dM. 4 I

Procurement h=aats specify vendor responsibilities for the generation, retention, and submission to BGE of quality assurance documentation related to the fabrication, inspection, and test of SR and designated NSRitems and services.

Inspection and test records contain the followmg as appropriate:

~

1. Description of the type of observation.

2. Date and results ofinspection or test.

3. Information related to noted discrepancies, including action taken to resolve them.

i

4. Identification ofinspector or recorder of data.

{

l

5. Statement as to acceptability of results. l

Controls have been provided to ensure that records are protected from possible destruction. Within I l established time-intervals, completed lifetime records are transmitted to the Records Management l Unit for incorporation into the Long Term Records Storage and Retrieval System.

IB.18 AUDITS '

l Internal audits are performed by BGE's Quality Audits Unit to ensure that activities and procedures l

established to implement the requirements of 10 CFR 50, Appendix B, comply with BGE's overall QA Program 'Ihese audits provide a comprehensive independent verification and evaluation of quality-related activities and procedures. Audits ensure the effective and proper implementation of BGE's QA Program.

'Ihey are scheduled on the basis of the importance to safety of actisities being performed.

Vendor audits are performed to evaluate QA programs, procedures, and activities. Audits of major vendors are made early enough to ensure compliance with all aspects of BGE's procurement documents. Additional audits are performed as required to ensure that all requirements of BGE's QA Program are properly implemented according to procurement documents.

Audits of designated activities as required by the TSs are performed under cognizance of the OSS'AC.

Audits are performed in accordance with preestablished wTitten procedures or checklists by qualified NQAD personnel who have no direct responsibility for the work being audited. Technical specialists from -

other BGE departments and outside consultants may assist as necessary in performmg audits. Audits include objective evaluation of quality-related practices, procedures, instructions, activities, and items, as -

well as review of documents and records I

i

)

Page 36 of 57

l. .

l s i QUALITY ASSURANCE POLICY Revision 45 Reports of audits are analyzed and 6'-*~I Results that indicate the QA Program to be inadequate, ineffective, or improperly implemented, including the need for re-audit of deficient areas, are reported to the Manager and Supervisor of the audited activity. Controls have been established for verifying that corrective action is taken promptly to concet noted deficiencies.

To ensure that BGE's NQAD complies with the requirements of BGE's QA Program, an i%t -

management audit of NQAD activities is gifviw.cd annually by a Joint Utility Management Audit (JUMA)

Team.

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I Page 37 of 57

4 .

QUALITY ASSURANCE POLICY Revision 45

. TABLE IB-1 BALTIMORE GAS AND ELECTRIC COMPANY'S POSITION ON GUIDANCE CONTAINED IN ANSI STANDARDS Revision ofIndustry Standards Applicable to the Bmitimore Gas and Fim_ric Oumli+v Anurance Proaram Requirement Some of the Industry Standards listed in Section IB.2 identify other Standards that are required, and some Regulatory Guides define the revisions of those Standards that are acceptable to the NRC.

Response

BGE's QA Program was developed to respond to the specific revision of the h= ate listed in Section IB.2 and is not necessarily responsive to other documents listed in the referenced Industry Standards.

ANS 3.2 - 1976 l

Reouirement I Section 5.2.15 requires that plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure every two years to determme if changes are necessary or desirable.

Response

l BGE applies this requirement of a two-year review to all plant procedures except test procedures performed less often than every two years or at unspecified frequencies. 'Ihese are reviewed no more than 60 days before performance.

Reason l

Engineering Test Procedures (ETPs) and others like them are written for a one-time-only performance and kept for reference for future similar tests. If they are used again, they are reviewed and modified to meet conditions existing at the time of performance Some Surveillance Test Procedures (STPs) are performed every three to five years. 'Ihey too are reviewed before cach performance to ensure that they are compatible with existing conditions and responsive to current needs.

Item 2 (10)

Requirement Section 5.2.2 specifies that temporary procedure changes that clearly do not cht.nge the intent of the approved procedure shall as a mmimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedure; and at least one of these individuals shall be the supervisor in charge of the shift and hold a senior operators' license on the unit affected, i

Page 38 of 57

• 4 QUALITY ASSURANCE POLICY Revision 45

Response

BGE does not require the ShiA Supervisor to be the Senior Reactor Operator (SRO) approving temporary changes to procedures; any active SRO (cather on-shift or on-staff) may provide the SRO approval for procedure changes.

Raason Many proposed L.. gary procedure changes do not require the Shift Supervisor's immediate attention or knowledge of the change rince they do not affect plant safety. Other SROs are available and quahfied to perform this task sirre the Shift Superviso/s detailed review of the proposed change is not necessary to ensure plant safety.

Requiring the Shift Supervisor to review all changes is burh- and contrary to plant safay un light of the total number of procedures that exist and the time the Shift Supernsor must dedicate to ensuring the plant is safely operated and maintained Additionally, our Technical Specification requires this approval be from someone holding an SRO license (not recessarily the Shift Supervisor).

ANSI N18.1 - 3/8/71 119m.1 Requirement Paragraph 4.2.2 states that at the time ofinitial core loadmg or appointment to the active position, the Operations Manager shall hold a Senior Reactor Operator's (SRO) License.

Paragraph 3.2.1 states that positions at the functional level of Manager are those to which are assigned broad responsibilities for direction of major aspects of a nuclear power plant. 'Ihis fi=wtiaa=1 level generally includes the plari manager (plant superintendent, or other title), his line assistants, if any, and the principal members of the operating orgamzation arposting directly to the plant manager and having overall responsibility for operation of the plant or fm Ps maintenance or technical service activities.

Response

Baltimore Gas & Electric has two positions in its organization, Superintendent-Nuclear Operations and General Supervisor-Nucl:ar Plant Operations. Neither of these positions needs to indisidually meet all cf the requirements of both paragraphs 3.2.1 and 4.2.2. The Superintendent-Nuclear Operations will satisfy paragraph 3.2.1 and most of 4.2.2 except that he will not maintain an SRO license. Instead, the Superin*=L at-Nuclear Operations will hold or have held an SRO license. "Ihe GS-NPO will hold and 3 maintain an SRO license. 'Ihe GS-NPO satisfies paragraph 4.2.2, but he does not satisfy 3.2.1 because he

does not report directly to the plant manager.

i

! Esatan l 'Ihu Superintendent-Nuclear Operations will hold or have held an SRO license u opposed to having a licerma c the time of appe=&.c4 to the position. He will have an excellent understandmg of plant operations. 'Ihe GS-NPO will not only hold an SRO license at tlw time of appointment to the position, but ,

j he will maintain the hcense 'Ibe GS-NPO directly supervises the operating shift organization, whereas the j Sup ^ =6+ Nuclear Operations is also responsible for operations procedure development, modifications

' ==W =+, and operations / maintenance couid; nations. 'Ihe Superintendent-Nuclear Operation's level of supervision does not require current in depth and plant specific knowledge which results from maintaming an SRO hoense i

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QUALITY ASSURANCE POLICY Revision 45

. &R1(17)

Requirement Paragraph 3.2.2 states that supervisors are persons principally responsible for directing the actions of operators, technicians, or repairmen %ose positions usually designated as intermediate and first line -

supervisors are included in this category.

Paragraph 4.3.2 states that supervisors not requiring Atomic Energy Commission (AEC) heenses shall have a high school diploma or equivalent and a minimum of foor years of experience in the craft or discipline he supervises.

Response

Baltunore Gas and Electric has three supervisory positions in its nor erMon - Supervisors, and in some cases Assistant General Supervisors and General Supervisors - which are organizationally equivalent (when supervising technicians /repaumen) to the positions described in paragraph 3.2.2 of ANSI N18.1-3/8/71. All these individuals need not possess the four years of craft / discipline experience required by paragraph 4.3.2. Instead, at least the first line supervisor shall possess four years experience in the craft / discipline he supervises while other supervisors in the organization may be selected to fill supervisory positions based on possessing a muumum of an A tiate's Degree, with four years of related technical experience, and demonstrated supervisory ability. (18) Additionally, all first line and intermediate ,

supervisors shall have at least a high school diploma or equivalent.

Reason To provide a balanced and broad base of supervisory ability within the site organizations made up of l

technicians / repairmen, it is desirable to include as supervisors both individuals with extensive craft / discipline experience accrued through field work and individuals with related education and experience who have demonstrated the ability to effectively supenise.

1 ANSI N45.2.1 - 1973 e

Reauirement j Subsection 3.2 outlines requirements for demineralized water.

ne- ,

i I

BGE specifications for demmeralized water are different than the specifications outlined in the standard.

Reason

BGE specifications for denuneralized water are consistent with guidelines provided by the Nuclear Steam l Supply System supplier. BGE specifications are generally more restrictive than those specified by ANSI ~

, N45.2.1.

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I QUALITY ASSURANCE POLICY -  !

Revision 45 i ANSI N45.2.2 - 1972 1k5.1 Requirement Subsection 2.4 could be interpreted to mean that on-site and off-site persormel who perform any 1

9% exaseiaa, or testing activities related to the Mias shipping, receiving, storage, and handling ofitems for nuclear power plants shall be qualified in accordance with ANSI N45.2.6.

Response

BGE requires that only persons who are responsible for approving items for ==+/ == shall be qualified in acceid-r.cc with Regulatory Guide 1.58 (which endorses ANSI N45.2.6) and that personnel who verify that storage areas meet requirements will be quali6ed to either Red =*ary Guide 1.58 (which endorses  :

ANSI N45.2.6) or ANSI N45.2.23.

Esanon Our receipt inspection procedures require persons who approve items for acceptance to be qualified ir.

accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6). QV technicians, inspectors or QA auditors verify that storage areas meet requirements. All other inspection, examinatioi, and testing activities are subject to review by persons qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6).

html Reauirement  :

'Ihe second sentence of Subsection 2.4 requires that:

Off-site inspection, exanunation, or testing shall be audited and monitored by personnel who are qualified in accordance with ANSI N45.2.6.

Response

BGE uses personnel qualified in accordance with ANSI N45.2.23 to perform auditing and monitoring functions.

Reason i

l The qualification requirements for auditors cannot always be met by persons qualified to Regulatory Guide 1.58 (which endorses ANSIN45.2.6).

html Requirement -

Subsection 2.7 requires that activities covered by the Standard shall be divided into four levels, though -

recognizing that within the scope of each level there may be a range of controls depending on the importance of the item to safety and reliability.

l Page 41 of 57

QUALITY ASSURANCE POLICY Revision 45

Response

1. The level of protective measures defined by Subsection 2.7 are applied to Basic Component purchases. ,

2. Personnel of BGE's Nuclear Fnp=mng Department (NED) will determine the level of protective measures to be applied to Commercial Grade purchases.

Reason BGE's position is as follows:

1. For Commercial Grade items, it is not always possible to assign a level of classification in accordance with ANSI N45.2.2, as many items are purchased after they have been packaged by the manufacturer and shipped to his local agent, the wholesaler.

2. Experience has shown that the level of protection assigned to Commercial Grade items by vendors is adequate.

II.GLI Reauirement Subsection 3.0 specifies detailed requirements for packing items for each level defined in Subsection 2.7.

Response

1 BGE has replaced Section 3.0 with the following:

1. Packaging for Shipment to BGE Personnel of BGC's NED or NSSD shall ensure that procurement documents for Basic Component and Commercial Grade item purchases either indicate that the normal methods of packaging and shipment used by industry in general are acceptable for the items being procured or specify the level of protection assigned to the item and the requirement that the vendor conform to applicable requirements for items in that classification defined in Regulatory Guide 1.38, Rev. 2 - March 1977.

2. He normal methods of packaging used by the industry in general are acceptable for items being procured as Commercial Grade.

3. Packaging for Storage by BGE in general the packaging used by the ver> dor to ship items for all types of purchases to BGE need not be retained after the item is received by BGE, provided that the item is stored in an area that meets the requirements for a storage area for the level of protection assigned to tie item. Special or unique items, however, may require special protective measures. For such unusual items, the Department that initiated the purchase, together with NED, or NSSD shall identify if any of the requirements of Section 6.4.2 of ANSI N45.2.2 - 1972 apply.

Reason l.

This substitution will ensure that the item will receive adequate protection during shipment and storage, thus climmatmg unnecessary restrictions and enabling BGE to use commercial sources to the utmost Page 42 of 57

QUALITY ASSURANCE POLICY Revision 45

2. Experience shows that industrial practaces for packaging Cw. .w.o;el Grade items are adequate for most applications.

lism.1 Requirement Section 4.0 defmes shipping requirements related to the protection levels assigned to items.

Response

BGE has replaced Section 4.0 with the following-

1. Shipping to Baltimore Gas and Electric l l

BGE will invoke the requirements for shipping specified in Section 4.0 of ANSI N45.2.2 - 1972 on Basic Component purchases only when NED or FSSD persc.w.cl have specified in procurement h==ts that the item shall be packaged in conformance with ANSI N45.2.2, Section 3.8.

BGE will not invoke the requirements of ANSI N45.2.2 -(1972, Section 4.0, on Commercial Grade item purchases

2. Shipping from Baltimore Gas and Electric Items shipped from BGE need not conform to any of the requirements of ANSI N45.2.2, but the organization that packs and handles the item shall provide roughly the same level of protection that the item was given during shipment to BGE.

BsT490 If engineering personnel have determmed that the vendor's methods of packaging are acceptable, they have already determined that the supplier's MMe of shipping are adequate. As items are shipped from BGE only for repair, the detailed requirements specified in Section 4.0 of ANSI N45.2.2 are not necessary.

1110!.1 Reauirement Subsection 6.4 gives detailed requirements for care ofitems in storage, according to the protection levels  !

assigned to the items.

) Response .

l BGE does not require items to be stored in the packmg used for shipment if the storage level in the area i

provides the same protection as the level of packmg assigned to the items. Caps, covers, etc., will be

required only if specified by NED or NSSD personnel during the procurement process. If an item is taken from one storage area to another, however, the persons who move it are responsible for ensuring, as applicable, that additional packing is supplied to give adequate protection during transportation.

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QUALITY ASSURANCE POLICY Revision 45 Reason

'Ihe degree of protection given an item during storage should be tailored to the importance of the item to safety and the probability of deterioration during storage; to base storage requirements purely on the categories in Subsection 2.7 of ANSI N45.2.2 - 1972 is ingractical. BGE requires NED or NSSD personnel to specify requirements more closely related to the actual function of items and to storage conditions.

IkEL2 Requirement Subsection 7.3.3 requires compliance with a series of ANSI h-ts.

Response

BGE controls for the use of hoisting equipment are compatible with the Standards listed in Subsection 7.3.3 of ANSI N45.2.2, although at the discretion of the Plant General Manager, they need not be compatible with documents referred to in ther,e documents. i Reason Lower-level documents referred to in the documents listed in Subparagraph 7.3.3 will not necessarily affect the ability of BGE personnel to properly handle SR items and could lead to confusion.

. ANSI N45.2.3 - 1973 lhEL,].

Egguirement l Subsection 2.1 outlines housekeeping cleanliness requirements for five designated zones.

Response BGE has established three classes for cleanliness requirements. There is no class equivalent to the ANSI Zone 1. Requirements of ANSI Zones 4 and 5 have been consolidated into BGE's class 3.

Reason

1. ANSI Zone I level of cleanliness applies to new construction activities.

2. Where required, smokmg restrictions are posted for BGE's class 3 areas.

ikel Reauirement

, Subsection 2.1 requires for Zones I, II, and III, that a written record of the entry and exit of all personnel .

and material shall be established and maintained i

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QUALITY ASSURANCE POLICY '

Revision 45 Responn BGE has established the following methods for personnel and material accountability:

1. Written accountability.

2. Where possible tethering of tools and matenals to p....er.cr.t plant structures or persons

3. Post-maintenance closcout inspections.

Reason j BGE's three methods of accountability offer the same level of control as that required by the standard l

ANSI N45.2.4 - 1972 i Kequirement 1

The last paragraph of Subsection 6.2.1 (Equipment Tests) states:

Items requiring calibration shall be tagged or labeled on completion indicating date of calibration and identity of person that performed the calibration.

Response

i The new cal:bration program at Calvert Cliffs does not use calibration stickers that contain date of calibration aM identity of person that performed the calibration. The new calibration stickers indicate that the instrument is periodically calibrated according to the calibration program 'Ihe sticker, a green "C,"

means the instrument is in the program.

In the past, the date of calibration noted on the instrument was important because the calibration history of preventive maintenance was not kept on computer. Computer tracking systems and trendmg programs did ,

not exist. In the new system, the date of calibration being on the sticker is not necessary because the date {

of calibration and the identity of the person that performed the calibration is retrievable in the PM history in Nucleis according to equipment ID Calibrations ofinstruments are scheduled and tracked by computer.

We are going into a real predictive and preventive maintenance calibration program. Calibration frequencies will be shifted based on calibration history, PRAs, vendor's reco.m..cr.dations, and instrument use.

A database exists which controls what instruments are added to or deleted from the program By maintaining the database, we ensure that no instruments are identified as calibrated that are not. In the new program mstruments identified as calibrated are kept up to date and specific information is kept on computer with no need for that information to be on the sticker.

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,  : QUALITY ASSURANCE POLICY  !

Revision 45 l

ANSI N45.24 - 1978 l i hagi

, Requirement >

Subsection 1.2 ststes in part, i ,

l The requirements of this standard apply to personnel who perform ia a~+ia= examination, -

, Nul tests during fabrication prior to and during receipt ofitems at the construction site  !

during eersuoction, during pi+.Gosal and startup testing, and during operational phases ofnuclear power plants.

! Response-A V

i ' Personnel of BGE's Quality Assurance organizations who perform iP verification through

• l . inspections, examinations, or tests at the plant site during operational phases of the nuclear power plant are ,

l required to be qualified in accord. scc with Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to

ANSI N18.1,1971. All other BGE personnel who perform inspection, examination, and testmg functons 1 associated with normal cperations of the plant are qualified either to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1 - 1971.

l

! Reason-A 1

. 1. The individuals who perform inspection, ==3==+iaa, and testing functions associated with normal  :

operation of the plant, such as maintenance and certain technical reviews, are norrnally qualified to t

, ANSI N18.1 - 1971.

4: 2. Some testing activities conducted during normal operation of the plant, such as surveillance testing, i

4 do not require that test personnel meet the requirements spccified in Paragraph 4.5.2 of ANSI N18.1 l for technicians. Personnel qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) are '

adequately qualified to conduct such testing. )

j Response-B  !

i BGE does not always require vendor personnel perfonning inspection or test activities to comply with the f requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) but evaluates the need for involang l Regulatory Guide 1.58 (which endorses ANSI N45.2.6) on the vendor during the review of procurement  !

t-:e -ats. 'Ihe requirements are not applied to procurement classified as Commercial Grade. '

Reason-B BGE's position is as follows:

1. - For replacement items purchased as Ces r.id Grade items, the purchaser may not impose nuclear unique requirements on the vendor. Additionally, items may be manufactured before ,

pt of the purchase order and the vendor may not be required to maintain records of the performance ofinspections or tests.

Page 46 of 57

QUALITY ASSURANCE POLICY Revision 45 j 1

2. For Basic Co.h.gss,t Purchases, the qualification requirements for inspection, exanunation, and test i personnel are determined by:

a. Item status (new or replacement).

1

b. Complexity and L.#1ance ofitem. I

c. Manufacturer's QA program approval level (Appendix B, ANSI N45.2, etc.).

Response-C 1

BGE does not require personnel who perform specific limited and repetitious inspection functions, such as inspection for removal or replacement of snubbers, to be tramed as required by Regulatory Guide 1.58 (which endorses ANSI N45.2.6).

Reason-C Inspections, examinations, or tests that are repetitious or of limited scope need not be performed by individuals qualified to the requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) provided that they receive instruction in the following:

1. Activities to be verified.

I

2. Acceptance criteria.

3. Method of documenting results.

l 4. Method of reporting deficiencies.

The person responsible for the inspection activity ensures that such instruction is given to inspectors before l they perform specific inspection functions, and that both this training and the acceptability of the results of the inspection are dociunented.

I Response-D When it is necessary to monitor the activities of a vendor, BGE uses personnel qualified as auditors in accordance with ANSI N45.2.23 or inspectors in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6).

, Reason-D Both Regulatory Guide 1.58 (which endorses ANSI N45.2.6) and ANSI N45.2.23 establish trammg requirements suitable for monitoring vendor activities.

lital Reauirement Table I specifies that Level III personnel shall be capable c f qualifying Level III personnel.

Response

When there is only one I.evel III position or when a new I.evel III position is created, BGE personnel with the title General Supervisor, or higher, qualify Level III personnel.

Page 47 of 57 l

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QUALITY ASSURANCE POLICY Revision 45 Raason BGE personnel in these grades are capable of certifying Imel III personnel without being trained as Level IIIinspectors.

NOTE:

Regulatory Guide 1.58 (which endorses ANSI N45.2.6-1978) states in pait, under item 6 of Regulatory l'osition, that..."In addition to the i=-=== '=6= listed under Secten 3.5 (of ANSI N45 2.6-1978) for level I, II, and III personnel, the ~W* should be a high school graduate or have carned the General Education Development equivalent of a high school diploma...." Based on the NRC letter dated January 17, 1985 from nomas T. Martm to A. E. Lundvall, Jr., the above educational requirements will be implemented for inspection, examination, and testing personnel hired or assigned aAer November 27,1984, in addition to the present commitment to ANSI N45.2.6-1978 for the qualification of such personnel.

ANSI N45.2.9 - 1976 htEL1 Requirement l

Section 4.0 titled " Receipt" gives instructions for receipt controls.

Response

BGE applies these requirements only to the receipt of records by the Plant History File.

E&a80 Most records received by such organizations as Receiving Inspection, Engineering, etc., are not shipped in '

, a manner that makes these requirements applicable. These requirements are applicable, however, when the l records are finally tumed over to the Plant History File.

! htD1.2 Reauirement Subsection 5.6.1 reads as follows, " Design and construction of a single record storage facility shall meet the following criteria:" Items a) and b) of the subsection state that:

"a) Reinforced concrete, concrete block, masonry, or equal construction."

"b) A floor and roof with dramage control. If a floor drain is provided, a check valve (or i equal) shall be included." -

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Page 48 of 57

QUALITY ASSURANCE POLICY Revision 45 E se/ Reason Item a Be intent of this requirement is both structural integrity and fire resistance 'Ihis vault is entirely enveloped by a structurally sound, fire resistive building. Second, the vault rests on a is.fwM slab on grade and its walls extend fully to the underside of the structural deck. Hird, the walls of the vault are constructed of gypsum wallboard on metal studs per Underwnters Laboratory Test Number U412, assuring the equivalent of 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire resistive construction This is equal construction to concrete block in terms of fire protection. De walls no structural load; hence, they provide equivalent structural integrity to that needed ofconcrete block. (See footnote following page).

Response / Reason Item b Again, the vault is contained within an environmentally protected building. As such, it has no roof, or need for floor drain.1 (See footnote).

111 51 2 Esguirement Subsection 5.6 allows only the dual facility defined in Subsection 5.6.2 as an alternative to the single facility defined in Subsection 5.6.1.

Inese responses have been forwarded to the NRC by the BGE letter dated 02/11/83 from Robert G. Nichols, Sr. Facilities Project Administrator, Real Estate and Office Services Department, to

Terry L. Harpster, Chief QA Branch, Division of QA,- Safeguards and Inspection Programs, IE, l USNRC. Dese responses have also been accepted by the NRC in their letter dated 04/22/83 from Walter P. Haass, Deputy Chief, QA Branch, Division of Quality Assurance, Safeguards, and Inspections Programs, Office ofInspection and Enforcement.

Response

l l BGE allows the following alternative storage requirements for organizations other than the Records Management Unit:

Organizations that originate records and do not transfer them to the Records Management Unit

within 30 days of completion shall establish one of the following three controls as alterwives to the requirements specified for the Records Management Unit

i l 1. Duplicate Storage

Either A or B.

i A. Within 30 days of completion of a record, a duplicate record file shall be established. This activity shall be controlled by procedures which provide for the following: ,

l 1. Assignment of responsibility for records.

2. Description of storage area.

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QUALITY ASSURANCE POLICY Revision 45

3. Description offiling system

4. An index ofthe filing system

5. Rules govermng access to and control of files.

1

6. Methods for maintaining control of and accountability for records removed from the file.

. 7. Method for filing supplemental information and disposing of superseded or obsolete 5

records.

i 8. Method for preservmg records to prevent deterioration.

9. Method for maintaining specially processed records that are sensitive to light, 3

pressure, or ts.w4=re.

10. Transfer of duplicates to the Records Management Unit within two years :)f i completion of records.

B. Make arrangements with at least one other department that receives a copy of each document l to subject this other copy to the controls specified above.

2. Fire-resistant Building Storage Records shall be stored in steel cabinets located in a fire-resistant building or a non-

combustible buiEng with a fire suppression system.

'Ihc procedural controls defined for duplicate storage shall be applied.

3. Non-fire-resistant Building Storage

Within non-fire-resistant facilities, records shall be stored in UL one-hour-mmunum fire-rated j storage cabinets and be subject to the procedural controls defined for duplicate storage.

l BGE defines a Fire-resistant BuilCag as follows:

i A facility constructed to resist the initiation or spreading of fire; non-combustible and/or fire-suppressive materials used; building certified as fire-resistant by the Risk

Management Unit of BGE's Corporate Finance Group.

Reason

, Although these alternatives are compatible with standard methods of handling records, they do not materially decrease the level of protection afforded to the records.

3

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t QUALITY ASSURANCE POLICY l Revision 45 ANSI N45.2.23 - 1978 18AR1 Raquirmnent 2.3 Q"-h% ofImad Auditors Section 2.3.1 requires prospective lead Auditors to obtain a minunum of ten credits unkt the scoring system defined in paragraphs 2.3.1.1-2.3.1.4.

Response

BOE has revised the scormg system as follows:

Education and Experience The prospective-lead Auditor shall have accumulated a nummum of ten credits under the following scoring system-1.0 Education (4 credits maximum) 1.1 For the Associate degree for an accredited institution, score one credit, if the degree is in engmeering, physical sciences, mathematics, or quality assurance, score two credits.

Or, for the Bachelor degree from an accredited institution, score two credits; if the 1 degree is in engineermg, physical sciences, mathematics, or quality assurance, score l three credits. '

1.2 For the Master degree in engineenng, physical sciences, business management, or quality assurance from an accredited institution, score one credit.

1.3 For the successful completion of part of the required curriculum for an Associate, ,

' Bachelor, or Master degree, score a corresponding percentage of the credits specified above for the degree. l I'

l.4 For the successful completion of Navy Nuclear Traming, its equivalent in another

, armed service, or the training required for becommg a licensed operator in a

( commercial nuclear power plant, score two credits.

,- 2.0 Experience (9 credits maximum) 2.1 Technical Experience (5 credits maximum) i For experience in engineering, manufacturing, constmetion, operation, or maintenance, score one credit for each full year.

4 i

2.2 Nuclear Experience If two years of technical evder.cc have been in the nuclear field, score one additional credit.

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QUALITY ASSURANCE POLICY

i. Revision 45 2.3 Quahty Assurance Experience

). j j If two or more years of the teknimi expenence have been in quahty assurance or

quJity control, score two additional credits. Persons whose work activities are  ;

) controlled by the QA Program but who are not full-time rc.c r.:ws of the QA l l organizaten may be awarded half the credits that would be given to a person with l i specific quality assurance experience.

l 2.4 Audit Experks.cc If two or more years of the technical experience have been in auditmg, score one

~

j i additional credit.

j 2.5 SupplementalExperience

Persons who have a proportion of the experience specified in 2.1-2.4 may be awarded a correspondmg percentage of the credits specified.

i 2.6 Time exclusively spent in traming does not apply as credit toward experience requirements forlead auditors.

3.0 Traming (2 credits maximum)

Persons who have successfully completed the training requirements of ANSI N45.2.23 may j be given two credits.

4.0 Rights of Management (2 credits naximum)

The Manager-NQAD, may grant additional credits for other performance factors applicable to auditing as follows:

4.1 For certification of competence in engineering or science related to nuclear power plants, or in qu .lity assurance specialties, issued and approved by a State Agency or  ;

National Professional or Technical Society, score two credits. l l

4.2 For nuclear experience in excess of 2 years, score one credit for each two years '

expenence.

4.3 For practical experience that can be related to power plants, in excess of 5 years, score one credit for each two years of expenence.

Reason BGE is in agreement with the basic purpose of ANSI N45.2.23--that is, to establish minimum educational or experience requirements for Imd Auditors. We think, however, that the system of credits outlined in  ;

ANSI N45.2.23 tends to reduce the size of the pool of potential replacement auditors without makmg '

rd - % improvement in the capabilities ofpersons selected .

We calculated the credit score of 11 of our present Imd Auditors at the time they were appointed Imd .

Auditors. Six had completed Navy Nuclear Traming and spent several years in the Navy Nuclear  !

Program. Four of these scored only 8 credits total, includmg 2 credits allowed by paragraph 2.3.1.4 of l ANSI N45.2.23 for rights of management based on their having completed the BGE QA training programs forLand Auditors Page 52 of 57

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o QUALITY ASSURANCE POLICY

. Revision 45 One of our auditors, with neither nuclear nor power plant experience, had a credit score of 12 because he )

held a Bachelor's degree in engmeenng and was a professional agineer with over 5 years design exPenence ,

Because all of these individuals have acted as lead Auditors satisfactorily for several years, it appears that  :

the credit system should be revised slightly to allow for the differences in education and experience of prospective lead Auditor candAta We consider the flaw in the current system to be the emphasis on educational requirements that will allow a person with a Master's dogme and no nuclear or power plant experience to become a Imad Auditor, but will exclude a person who has no degree, even though he may have 20 years' experience in operating or maintaining nuclear or power plant systems.

The practical balance between education and expenence will vary with individuals and particular work assignments. Any attempt to establish rigid requirements is likely to allow some unsuitable candidates to meet the qualification requirements while excluding some %ble candata.

For these reasons, we think that the supervision of prospective Audit Team leaders should be S iven more flexibility in determimng whether, for a particular individual, educational or professional qualifications are more significant and valuable than past experience.

The present credit system, while r-miring the Associate degree, gives no credit for completion of the nuclear trainmg programs. We think that someone who has taken Navy Nuclear Trammg or its equivalent in another armed service, or someone who has completed the training required to become a licensed operator in a commercial nuclear power plant, should receive the same credit as a person who has an .

Associate degree from an accredited institution in engineering, physical sciences, mathematics, or quality assurance.

The points now awarded for education are related to the effect that formal courses might have on the ability ofindividuals to comprehend the regulations or the technical aspects of activities being audited. The point system makes no allowance for the fact that such knowledge comes gradually and not upon receipt of a degree. Persons who have completed part of a degree course should receive a percentage of the credits allowed for that course.

1he requirements for trammg specified in ANSI N45.2.23, paragraph 2.3.2, would seem to ensure that

! pmspective Lead Auditors will meet the requirements of paragraph 2.3.1.4 dealing with the rights of

! management. We think, therefore, that all prospective lead Auditors should qualify for these two credits. ,

i Similarly, the present system recognizes the effect that working in a QA Program will have on the ability of a person to comprehend regulations and technical requirements. Persons who are not assigned as full-time l members of the QA Organization, however, receive similar exposure if they perform activities controlled by a QA Program

We therefore allow such persons half the credits specified for quality assurance  !

expenence.

i l html i

Reauirement .  !

l l

l 3.3 Requalification .

Lead Auditors who fail to maintain their proficiency for a period of two years or more shall be

required to requalify. Requalification shall include retraining in accordance with the requirements t

of paragraph 2.3.3, reexamination in accordance with paragraph 2.3.5, and participation as an Auditor in at least one nuclear quality assurance audit.  :

i Page 53 of 57

QUALITY ASSURANCE POLICY Revision 45 Resnonse BGE requalifies lead Auditors on the basis of the satisfactory performance of one audit, as observed by a qualified lead Auditor. ,

Reason

'Ihe purpose of the training specified in paragraph 2.3.3 of the Standard is to ensure that candidates understand the hd=mentals of auditing and the requirements for activities to be audited. The fact that persons have not ==WaH their proficiency does not mean that they need complete re-training; it means only that they have not been able to review and study the applicable Codes, Standards, Procedures, instructions, and other documents related to QA Programs and program auditing. BGE considers that the satisfactory performance of an audit under the observation and guidance of a qualified lead Auditor should ensure that persons with lapsed certification will review and understand the iwiisit documents ANSI N101.4 - 1972 Reauirement Section 1.2 specifies applicability requirements for the Standard.

Response

BGE requires that only activities performed inside containment structures and related to protective coatings applied to ferritic steels, aluminum, stainless steel, zinc coated (galvanized) steel, concrete, or masonry surfaces shall conform to applicable Sections of ANSI N101.4.

l Reason Deterioration of protective coatings applied to surfaces outside containment structures would have no I detrimental effects on the safe operation of the plant. l 4

ANSI N45.2.13 - 1973 l

Reauirement l ANSI N45.2.13 could be interpreted to mean that all requirements of this standard are applicable to all  !

safety-related items or services.

Response

i BGE has two approaches for safety-related and designated non-safety related procurement as described in Sections, IB,4 and IB.7. Controls established for Basic Component Purchases correspond to the requirements of ANSI N45.2.13. The extent to which the individual requirements of ANSI N45.2.13 are

' applied to Commercial Grade Purchases depends on the nature and scope of the work to be performed and the importance to nuclear safety and the items or services purchased This approach is consistent with the introductory discussion in Section 1.3 of ANSI N45.2.13 - 1973. '

i i ,

Page 54 of 57

e

-3..

QUALITY ASSURANCE POLICY Revision 45 ATTACHMENT A-1 BASES FOR QA POLICY REVISIONS (1)

Entry PRF-Q No. No. Bases for Revision (s)

1. 771 Procedure Unerade Action Plan (PUAP). ner L. B. RuneaH War 1-20-89.

2. 783 10 CFR Part 21 iwnh-. r-

3. 797 NRC Ta*a~+ina #89-16/89-17 (Imar from R. E. Da=*aa to R. P. Haihal datad July 13.1989.)

4. 824 NRC ! attar from M. W. Hadone to G. C. Creel d='ad March 13.1990. This letter anoroved a one-time exemotion to the ceriodic review r~niiremenu for nracadures scheduled to be unaraded by the Procedures Unarade Proiect. This exemotion was discontinued and removed by PRF-O 954.

5. 844 Procurement Pronrarn Proiect unarade. Perfomunce Imorovement Plan (PIP)

Action Plan #5.3.1 and OAU Audit Findino 87-13-01

6. 844 IB.15 and IB.16 revised to clearly establish nronram annlicability and controls.

e consistent terminolony. ornanizational resoonsibilities and facu=ad aooroach i

towards develooine and imolementina an integrated Marmeement Sys*cm. __

l

7. 891 PIP Action Plan 5.3.1 Follow-On Actisity.

8. 894 IB.15 and IB.16 revised to clarify reauirements which will nermit imolementation e of the issues Mananement System - PIP item 4.10.0.

l 9. 854/907 G. C. Creel letter to the NRC dated 7/26/91 which discu==ad modifications to. and l acwds.cc of. channes to the OA Poliev involvinn OA comoliance reviews of OAPs and Directives.

10. 815 G. C. Creel letter to the NRC datad 10/3/90 diecu==ine temnorary channes not

~

affectma "Anoroved Procedure Intent" and the relievina of the Administrative Burden on Shift Sunervisors.

4 l' Page 55 of 57

QUALITY ASSURANCE POLICY Revision 45 ATTACHMENT A-2 BASES FOR QA POLICY REVISIONS (1) l l

1 l

Entry PRF-Q l

No. No. Bases for Revision (s)

11. 887 Audit Findma No. 9026-01 (Imolementation of Surveillance Reauirements).  ;

. 12. 954 G. C. Creel letter to the NRC dated 7/3/91 disemtinuina the one-time temporary channe to the oeriodic review interval anoroved in Basis (4) above.

l

13. 957 PIP Action Plan follow-on activity (5.3.1). '

T

14. 953 PIP Action Plan 4.1 and NUREG-0737 (TMI Action Plan Reauirements)

Item I.C.5. " Procedure for feedback of Operatine Experience to Plant Staff."

}I a 15. 990 OAU Surveillance 5-92-28 " Interface Between Facilities Mananement Deoartment t and Nuclear Energy Division on Projects at Calvert Cliffs." Recommendation 4.2.

16. 998 OA Audit Reco.. ..cedation 92-04-R03 (ISFSI operational chase).

17. 93-06 NOAD Audit Findina 92-10-01. Facility Staff Trainine.

l

18. 93-06 Letter from M. C. Modes of the NRC to R. E. Denton dated June 21.1994.

1 Page 56 of 57

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