ML20108E030

Revised QA Policy for Calvert Cliffs Nuclear Power Plant (App 1B of Calvert Cliffs Ufsar)

ML20108E030
Person / Time
Site:	Calvert Cliffs
Issue date:	05/01/1996
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20108E023	List: ML20108E017 ML20108E030
References
NUDOCS 9605090198
Download: ML20108E030 (72)

Text

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QUALITY ASSURANCE POLICY l

BALTIMORE GAS AND ELECTRIC COMPANY i

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Quality Assurance Policy for the )

l Calvert Cliffs Nuclear Power Plant (Appendix IB of the Calvert Cliffs Updated Final Safety Analysis Report)

Approved Date (I)

C. H. Cruse Vice President Nuclear Energy Division i

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! 9605090198 960501 l PDR ADOCK 05000317 P PDR l Page 1of72 1

QUALITY ASSURANCE POLICY

_ Revision 424_3 TABLE OF CONTENTS APPENDIX IB OUALITY ASSURANCE PROGRAM FOR THE OPERATIONS PHASE Section Page IB.1 ORGANIZATION AND RESPONSIBILITIES . .. .. . . . . . . . . . . . . . . . . ... . . . 15 l 1B.2 QUALITY ASSURANCE PROGRAM .. . . .. . . . . . ... . . . . . . . . . . . . . . . . . . . . . .H13 1B.3 D ESIGN CONTROL , .. .. . .. . . . . . . ... . . .. . . . . . . .. .. . . .. . . . . . . . . . . . . . . . . ..H19 1B.4 PROCUREMENT DOCUMENT CONTROL (5).... . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . .HM IB.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS . . . .. .. . .. . . . ..2_424 IB.6 DOCUMENT CONTROL.. . . . . . . . . . . . . . . . . . . . . .. .. . . . . .2124 .

IB.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (5) . . .. 2HN IB.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS (5). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . .H30 IB.9 CONTROL OF SPECIAL PROCESSES... . . . .... . . . . . . . . . . .. . ....H34 18.10 INSPECTION.. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . , , ..Hn l 18.11 TEST CONTROL.. . .... . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...MM IB.12 CONTROL OF MEASURING AND TEST EQUIPMENT... ... . . . . . . . . . . . . . . . . . . . .HM IB.13 HANDLING, STORAGE, AND SHIPPING .. . ..... . . . . . . . . . . . . . . . . . . . . . . .. . . . .. .HM 1B.I4 INSPECTION, TEST, AND OPERATING STATUS . . . . . . . . . . . . . . . . . . . . . . . . . . .HM IB.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS (6). . . . . .. ..H38 iB.16 CORRECTIVE ACTION (6).. .. . . ... ... . . . . .

. . . . . . . . .HM 1B.17 QUALITY ASSURANCE RECORDS . . . ....... . . . . . . . . . . . . .._4_039 1B.18 AUDITS... . ... . . . . . . . . . .. . . . . . . . . . . . . . .4240 Page 2 of 72 l

QUALITY ASSURANCE POLICY

\ Revision 4241 LIST OF TABLES Table No. Eage 1B-1 BALTIMORE GAS AND ELECTRIC COMPANY'S POSITION ON GUIDANCE CONTAINED IN ANGE-INDUSTRY STANDARDS AND REGULATORY GUJDES . 4141 .

A A ES Attachment Letter A BASES FOR QA POLICY REVISIONS (1)..... .... .. . . . . . . . . . . . . . . . ..gso l

ES Figure No.

IB-1 BALTIMORE GAS AND ELECTRIC COMPANY )

CORPORATE ORGANIZATION.......... . ........ . . ... . . . . . . ... ........6162

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Addendum No.

IB-1 REVIEW FUNCTIONS OF THE POSR

C. PROCEDURE

REVIEW COMMITTEE.

OUALIFIED REVIEWERS. AND OSSRC. .6663 Eane 3 of 72

QUALITY ASSURANCE POLICY Revision 4243 l LIST OF EFFECTIVE PAGES Latest revision number is listed for pages revised aAer revision 38.

Page Last Revision Page Iin Revision Page I 24 Revision 1 24 9 47 41 2 25 444J 48 41 3 g 26 444J 49 41 4 4243 27 41 50 41 5 28 41 51 41 6 42 9 29 41 52 41 7 42 30 41 53 41 8 42 31 41 54 41 9 42 32 41 55 41 l

10 42 33 41 56 41 11 42 34 41 57 12 42 35 41 58 13 41 36 59 42 14 41 37 41 60 42 15 4443 38 41 51 43 16 414J 39 41 62 M 17 40 444J 414J 61 M 18 41 444J 64 H 19 444] 42 4243 65 g 20 444J 43 4443 66 J 4

21 41 44 41 67 43 22 41 45 41 68 43 23 41 46 41 69 43 l'

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QUALITY ASSURANCE POLICY I l Revision 424_1 IB.! ORGANIZATION AND RESPONSIBILITIES -

I All levels of organization have defmite and unique responsibilities in assuring safe, economical, and reliable operation of Calvert Cliffs Nuclear Power Plant (CCNPP). Top level management is responsible for ensuring that policies are established, resources are authorized, management philosophy and commitments are communicated to lower levels of the organization, independent verification of management controls are ,

performed, results are reviewed, and appropriate actions taken when necessary. l 1

Middle level management is responsible for translating management policies, philosophy, commitments, and goals;. applicable federal, state, and local rules and regulations; Operating Licenses, Technical Specifications (TS), and the Updated Final Safety Analysis Report (UFSAR) into control programs for ,

activities such as design, procurement, construction, testing, operation, refueling, maintenance, repair, )

modification, training, plant security, fire protection, records, inder-leat verification, and corrective action Middle level management is also responsible for defining, measuring, and modifying the overall effectiveness of control programs; taking appropriate action on the results; and keeping top management informed of the status, adequacy, and effectiveness of control programs, and matters which could have an impact on nuclear safety.

First line craft and non-craft supervisors are individually responsible for ensuring that appropriate procedures are understood and used to implement each activity described in the control programs; identifying problems, seeking solutions, verifying implementation of solutions; investigating root causes of problems and taking preventive actions; ensuring that conditions adverse to plant and personnel safety are promptly identified, reported, and corrected; detecting trends which may not be apparent to a day-to-day observer, recommending generic solutions for adverse trends to management, and taking appropriate actions, to achieve desired results; ensuring that employees assigned to do a job are properly qualified through appropriate training and experience; have properly qualified procedures, tools, equipment, and parts to do the job, and, ensuring that indep= lent 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 supervisors 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 the job.

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

Procedures may be deviated from during emergencies to prevent or minimize injury to personnel or damage to plant equipment. Any such deviations should be thoroughly documented. (1) l Pane 5 of 72

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I QUALITY ASSURANCE POLICY Revision 420 l l

Corporate Ornanization and Soccific Responsibilities  !

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) l Chairman of the Board President and Chief Operating Officer Senior Vice President-Generation Vice President-Nuclear Energy Division (NED)

Plant General Manager-Calvert Cliffs Nuclear Power Plant Department (CCNPPD) l Manager-Nuclear Engineering Department (NED)

Manager-Nuclear Quality Assurance Department (NQAD) i Manager-Nuclear Support Services Department (NSSD)

Manager-Nuclear Outage & Project Management Department (NOPMD)

In addition to these individuals, the Vice Presidents of Corporate Affairs (CA), Fossil Energy Division (FED), Electric Interconnection and Transmission Division (EITD), General Services Division (GSD), and the Management Services Division (MSD), as well as the Managers of the System Operation and Maintenance Department (SOMD), Purchasing & Materials Management Department (PMMD),

Information Systems Department (ISD), Facilitics and Fleet Services Department (FFSD), Fossil Engineering & Maintenance Department (FEMD), Fossil Support Services Department (FSSD), and the Safety and Medical Services Department (SMSD) are assigned support responsibilities. (1) The above )

Managers constitute the Nuclear Program Managers who are assigned responsibilities within the QA 4 Program. Other departments performing any maintenance / modification activities at CCNPP are responsible for performing these activities in accordance with applicable QA Program requirernents. This can be accomplished by either developing their own QA Program procedures or by working to the QA Program through appropriate Nuclear Energy Division personnel using CCNPP procedures. (15)

Also, two advisory groups perform quality-related functions for plant operations, nese are the Plant Operations and Safety Review Committee (POSRC) and the Off-Site Safety Review Committee (OSSRC)

,'whose makeup and responsibilities are described in S TS: for CCNPP in Addendum 1B-l. 09)

Chairman of the Board. President and Chief Operatina 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 for establishing the overall QA Policy. They assign project responsibilities to the organizations shown in heavy-lined boxes in Figure 1B-1. (1)

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\ Revision 4243 l

De 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, !wg.ementing, and maintaimng the QA Program are assigned to Department Managers by the Vice President-Nuclear Energy Division. Managers delegate their authority as required to implement their i

responsibilities. (1)

Quality assurance matters that cannot be resolved by the Managers or Vice Presider.4s aic brought to the attention of the Senior Vice President Generation, President and Chief Operating Officer, or the Chairman of the Board for resolution.

Vice President-Nuclear hav Divisian

%e Vice President-Nuclear Energy Division, is responsible to the Senior Vice President-Generation for l ensuring that the QA Program is developed and implemented. He authority to develop QA Program  !

Documents is assigned to da=ignated Nuclear Program Managers. De Vice President-Nuclear Energy I Division, is also responsible for ensuring that the requirements of the QA Program that relate to the design, operation, and maintenance of the plant are implemented. His responsibility is carried out through Nuclear Program Managers.

Mananer-Nuclear Ouality Assuranca Deoartment Ac Manager-NQAD, is responsible for assuring an appropriate QA Program is established and effectively executed for CCNPP. He is responsible for auditing, quality verification, vendor evaluation, and independent safety evaluation functions for CCNPP. These responsibilities include:

1. Developing, and revising the QA Policy.

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

3. Taking necessary corrective action, which can include the stoppage of work when manufacturing, 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 operating, 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 independent of departments, sections, and employees responsible for performing specific activities, and have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions through designated channels; and to verify implementation of solutions. Non-NQAD personnel xho are authorized to perform activities under NQAD programs are matrixed to NQAD for the performance of such activities, and possess similar organizational freedom and independence from the activities.

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.

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QUALITY ASSURANCE POLICY Revision 424J l The organization of NQAD is shown in Chapter 12 of the UFSAR. The Manager-NQAD, delegates the followmg responsibilities for accomplishing the followmg activities:

Planning and scheduling evaluations of vendor quality assurance programs. i Reviewing proposed changes to QA Program documents for compliance with regulations and licensing documents.

Planning, scheduling, and performu3g internal audits /surveillances and evaluations of on-site and off-site functions performed under the nuclear QA Program.

Supporting maintenance and operations activities by performing inspections and l surveillances, or by providing oversight of other department personnel as they perform inspections and surveillances. (11)

Directing investigations of significant events to determme root cause, rammmending corrective action, and generating appropriate reports to document the investigation results; directing a program for identifying trends within the corrective action systems.

Directing reviews of the operating experience of other plants of similar design to determme the applicability of significant events with respect to CCNPP. (14) l 1

Plant General Man =er-Calvert Cliffs Nuclear Power Plant Department The Plant General Manager is responsible for operations, chemistry, radiation safety, maintenance, industrial safety and fire protection, and systems and performance engineering activities at CCNPP He must ensure that these activities are conducted in accordance with the plant operating license and TSs, the UFSAR, the QA Program, and procedures. The Plant General Manager fulfills the position and requirements of the Plant Manager, as defined in ANSI N18.1 (1971). He, or one of his designated principal alternates, shall have acquired the experience and training normally required for examination for a senior reactor operator's license The organization of CCNPPD is shown in Chapter 12 of the UFSAR. The Plant General Manager, delegates responsibilities for accomplishing required activities as follows:

1. The Superintendent-Nuclear Operations (S-NO) is responsible to the Plant Genern! Manager, for the operation of the plant, including the general supervision of all shift operating personnel and prioritization of maintenance activities to support operations. This responsibility covers the safety of plant personnel and equipment, all fuel-handling and refueling activities, and adherence to applicab!c license and regulatory requirements. The Superintendent-Nuclear Operations fulfills the position and requirements of the Operations Manager as dermed in ANSI N18.1 (1971) with the exception taken in Table 1B.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 command authority of his position to take whatever steps he deems necessary during emergency situations to place and maintain in a safe configuration any unit that may be affected.

2. The Superintendent-Nuclear Maintenance (S-NM) is responsible to the Plant General Manager for managing and directing activities of the Nuclear Maintenance Section to provide high quality maintenance programs, plans and schedules, and qualified personnel to perform Page 8 of 72 l

QUALITY ASSURANCE POLICY l Revision 424J l

maintenance functions necessary to assure the safe, reliable, and economic operation of the l plant to generate power within applicable laws, standards, codes, and regulatory ,

requirements. l

a. The General Supervisor-Electrical and Controls (GS-E&C), is responsible to the  !

Superintendent-Nuclear Maintenance, for the conduct of electrical and instrument l 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 l planning 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.

b. The General Supervisor-Mechanical Maintenance (GS-MM), is responsible to the Superintendent-Nuclear Maintenance, for the conduct of mechanical maintenance, repair, and modifications needed to keep the plant and its facilities, systems, and equipment in safe arxl efficient working condition. He is responsible for planning and supervising or controlling the mechanical 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 mechanical maintenance, repair, and modifications activities.

3. The Superintendent-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 engineering, surveillance testing administration, chemistry and radiation safety support, inservice inspection, and industrial safety and fire protection support to assure the safe, reliable, economic operation of CCNPP. The S-TS is also responsible for overall direction and coordination of activities to ensure compliance with the Radiological Effluent Technical Specifications. This responsibility is carried out through the General Supenisor-Chemistry with support from the Director-Environmental Programs and the Manager-FSSD.

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

=~~wbry systems and for maintaining radioactive effluents within specified limits.

Additionally, the GS-C provides program management oversight of the Radiological Environmental Monitoring Program to ensure compliance with the Radiological EfYluent Technical Specifications.

b. The General Supenisor-Radiation Safety (GS-RS) under the nuclear QA Program, is responsible to the Superintendent-Technical Support for:

Ensuring the radiation protection of personnel at CCNPP.

• Complying with radioactive material transport regulations.

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

T%! Support for development, implementation and coordmation of the industrial safety program; i.r.plcmcr. ting the fire prevention and fire fighting programs for the CCNPP; and planning, scheduling and monitoring activities directly related to safety, fire pre 6a, and prevention.

d. The General Supervisor-Plant Engineering (GS-PE), is responsible to the Superintendent - Techmcal Support for providing field engineering and technical evaluation of plant systems and to evaluate and coordmate resolution of system and component problems with operations, maintenance, and engmeering perse. .cl 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

e. The Principal Engineer-Nuclear Inspection Services is responsible to the Superinter. dent - Technical Support for providing inservice inspection services for the Calvert Cliffs Nuclear Power Plant. .

l Mananer-Nuclear Enaineerina Department I l

h Manager-NED, is responsible for directing the efforts of personnel and proyuhng resources '

necessary to support des:ign, modification and engineering activities covered by the QA Program l for CCNPP. These activities include nuclear, mechanical, civil, reliability, instrument and controls, and electrical engineering; nuclear fuel management; configuration management; life cycle management; plant design support; fire protection program development; engineering planning; licensing, and design and drawing.

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

Providing conceptual and detailed engineering, design and drawing, fire protection program development, data base configuration control, and documentation and maintenance of plant design bases for the power and control systems for the Calvert Cliffs Nuclear Power Plant.

Directing and performing safety evaluations, preparation and resiew of nuclear safety accident and transient analysis, fuel management, nuclear engineering related to core physics, reactor engineering, external fuel cycle management, reliability engineering and development and integration of programs necessary to operate up to arxl beyond the current licensed lifetime for the Calvert Cliffs Nuclear Power Plant.

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

Providing licensing services; coordination and operation of various industry information exchange systems; evaluation of plant events and conditions adverse to quality for reportability to the NRC and other agencies, assisting in the investigation and evaluation of events, and preparation of the reports; coordination of 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 compliance-related communications with external agencies including assistance in ensuring their consistency with existing licensing basis conunitments; and coordination of regulatory inspections and visits and company presentations to the NRC.

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\ Revision 4241 Manager-Nuclear Out- and Proiect Man-ment Denartment The Manager-NOPMD is responsible for directing the efforts of personnel and providmg 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. 'Ihe Manager-NOPMD delegates responsibilities for accomplishing the following activities:

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

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

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

Manaaer-Nuclear Suonort Services Deoartment The Manager-NSSD is responsible for emergency planning, training, nuclear security, onsite procurement coordination, procurement engineering, receipt inspection and storage / issue ofitems, procedures upgrade, state regulatory matters, strategic planning, and staff senices functions for CCNPP.

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

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

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

equipment, materials, and services for nuclear power plants; coordinating investigations cancerning state regulatory matters; coordinating the efforts of Nuclear Energy Division i 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 procurement documents identify technical and quality requirements; procurement (SR and DNSR) documents receive independent review and approval for the proper inclusion of technical and quality requirements; ensuring spare and replacement parts are suitable for their intended application (s); specification of critical characteristics and acceptance criteria for dedication of commercial grade items; specification of special storage requirements for age sensitive items.

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QUALITY ASSURANCE POLICY Revision 4241 l l

• Performing receipt inspection functions including special receipt inspectons and coordmatmg l testing performed to accept commercial grade items, designated NSR items or upgrade NSR  ;

items for use in SR applications (5) l

• Ensuring that the operational, mainnnance, licensing, and traimng activities 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 annual Strategic plan for the Nuclear Energy Division including the Nuclear Program Plan.

Directmg the efforts of BGE personnel involved in emergency planmng activities.

Individuals supporting the CCNPP QA Program are designated as follows:

Vice President-Fossil Enerav Diyision j The Vice President-FED, is responsible to the Senior Vice President-Generation for ensuring that the activities of FED personnel involved in CCNPP maintenance and modifications; Materials Engineering and Analysis; and radiological environmental monitoring, meet the requirements of the QA Program. His responsibility is carried out through the Manager-FEMD, and the Manager-FSSD.

Mananer-Fossil Enaineerina & Maintenance Department j

( The Manager-FEMD, is responsible for directing the efforts of FEMD personnel involved in maintenance and nodification activities at CCNPP.

Mananer-Fossil Support Services Deoartment The Manager-FSSD, is responsible for directing the efforts of FSSD personnel involved in: (1) ,

i maintaining and operating Radiological Environmental Monitoring equipment and performing l l sample collection and analysis, (2) ensuring materials engineering and analysis relating to SR structures, systems, and components are completed in accordance with Company and regulatory requirements.

I Vice President-Electric Interconnection and Transmission Division l

De Vice President-EITD, is responsible for ensuring that the requirements of the QA Program that relate to the calibration of test equipment and the testing of protective relaying, and metering controls for SR electrical power equipment are implementcd. This responsibility is carried out through the Manager-SOMD.

Mananer-System Oocration and Maintenance Deoartment The Manager-SOMD, is responsible for directing the efforts of personnel involved in the testing of electrical power equipment, the calibration of test equipment and the testing of protective relaying and metering controls for the electrical power equipment of CCNPP.

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QUALITY ASSURANCE POLICY \

\ Revision 4243 yice President General Services Diviaina i

ne Vice President 4SD 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 construction, maintenance, and operation of facilities; and support services for computer software and hardware.

%ese responsibilities are carried out through the Manager-PMMD, Manager-ISD, and Manager-FFSD.

Manneer-Purch==ia- and Materials Manneement Deoartment The Manager-PMMD, is responsible for directmg the efforts of personnel involved in the purchasing ofitems and services for CCNPP and for the issuance of Contracts for Fitness for Duty Activities.

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

Mananer-Facilities and Fleet Services Denartment l De Manager-FFSD, is responsible for directing the efforts of FFSD personnel involved in the planmng, design, construction, maintenance, and operation of facilities and related systems directly l supporting or impacting power plant operations.

Vice President-Manaoement Senices Division The Vice President-MSD, is responsible for ensuring that the activities of MSD personnel involved with I medical examinations for CCNPP operators, Nuclear Security Officers, and respirator users, meet the requirements of the regulations. The responsibility is carried out through the Manager-SMSD.

Manager-Safety and Medical Senices Deoartment The Manager-SMSD, is responsible for directing the efforts of SMSD personnel involved with medical examinations for CCNPP operators (10CFR55), Nuclear Security Officers (10CFR73),

respirator users (10CFR20), and with the Fitness for Duty rule (10CFR26).

Vice President-Coroorate Affairs ne Vice President-CA is responsible for ensuring that QA Program requirements related to the Radiological Effluent Technical Specifications are implemented. This responsibility is carried out through the Director - Environmental Programs.

IB.2 QUALITY ASSURANCE PROGRAM General Controls The QA Program consists of the Updated Final Safety Analysis Report (UFSAR) Appendix IB, QA Policy, Quality Assurance Procedures, certain Nuclear Program Directives and their implementing procedures. The UFSAR Appendix IB and QA Policy are the same document except for the way changes are incorporated. The QA Policy is updated when each change is approved. Revisions to the QA Policy are controlled by QA Program documents which are written to ensure compliance with 10 CFR l Pace 13 of 72

I QUALITY ASSURANCE POLICY Revision 43_43 l 50.54(a)(3). De UFSAR Appendix IB is updated annually. All QA Policy changes approved during the previous year are incorporated during that update.

He QA Policy identifies NRC regulatory requirements, industry standards, and specific codes applicable to the eighteen criteria cha~4 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.

Quality Assurance Procedures (QAPs) describe controls for the actions identified in the QA Policy QAPs cover major activities related to operatmg a nuclear power plant, such as plant operation, plant maintenance, trammg, purchase ofitems and services, calibrations, etc. '

Nuclear Program Directives address actions identified in UFSAR Appendix IB. Directives identify regulatory commitments, management requirements, and assign responsibilities for business activities (i.e.,

^

design, maintenance, operations, etc.) within the BGE Nuclear Program. As directives are written and implemented, they will systematically replace QAPs.

BGE's QA Program for CCNPP is applied to structures, systems, components, and activities that have been designated SR because they prevent accidents or mitigate the consequences of postulated accidents that could cause undue risk to the health or safety of the public. He QA Program is also applicable to designated NSR structures, systems, components, activities, and services as required by in regulations.

Designated NSR program requirements are based on a graded approach to Quality Assurance required to meet applicable regulatory designated requirements and guidance. He level of QA Program controls placed on designated NSR items are defined in QA Program documents and/or implementing procedures. .

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

Controls have been established for specifying on a Quality List (Q-List) all SR structures, systems, components, and activities that are subject to the requirements of the QA Program.

De Statement of Authority, in the Quality Assurance Manual for Nuclear Power Plants, signed by the Chairman of the Board, establishes the overall QA Policy of BGE. His 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 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 prosisions of the Program.

De Policy is approved by the Vice President-NED and implemented by Nuclear Program Managers. (1)

The QA Program has established controls for BGE and its contractors as required to ensure that the criteria of 10 CFR 50, Appendix B, will be met throughout the operations phase of the plant; i.e., during actisities of testing, operation, maintenance, repair, modification, and refueling.

The QA Program has also established controls to ensure that the construction, operational, and l decommissioning phases for the Independent Spent Fuel Storage Installation (ISFSI) are conducted in compliance with 10 CFR 72. Activities associated with the operational and decommissioning phase shall be controlled under the CCNPP 10 CFR 50 Appendix B QA Program; existing policies, programs, i

directives, and procedures stated as applicable for CCNPP are also applicable for the ISFSt. (16)

Changes to the QA Program documents are issued with a transmittal notice, which is completed by the recipient and returned to indicate that the documents listed on the transmittal have been received and incorporated into the recipient's Manual. Nuclear Program Managers ensure QA Program documents are revised as regulations, standards, results, or experience dictate. (1) He Manager-NQAD evaluates the degree of compliance with the requirements of QA Program documents and procedures. Audits are Page 14 of 72 l

QUALITY ASSURANCE POLICY c LW regularly to ensure compliance with established requirements, and the results of these audits are reported to responsible management personnel.

& Vice President-NED, ensures that activities of the NQAD are audited regularly by personnel  ;

Pt of the Department %ese auditors assess the effectiveness of the Department's implementation 1 of appropriate portions of BGE's QA Program He Vice President-Nuclear Energy Division, evaluates the '

report of the independent audit to determme if changes are required to the QA Program. He is responsible for negotiating such changes with the appropriate level of management and for sending to the Chairman of i the Board a copy of the audit report and an account of the corrective action taken.

l If a difference of opinion arises between NQAD personnel and those of other Sections or Departments, the dispute is resalved as follows: The Supervisor / General Supervisoi 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 obtained, the matter is referred up through the following management personnel until it is resolved:(3)

1. The Manager-NQAD, and the Manager responsible for performing the activity.

NOTE:

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

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

3. The Senior Vice President-Generation, President and Chief Operating Officer, or the Chairman of the Board.

l To ensure that important activities are performed correctly, BGE conducts formal training programs for I Company personnel with significant responsibilities. These programs include both initial and continuing l training and are conducted in accordance with written procedures or instructions. Department Managers I are responsible for ensuring that the training needs of personnel in their Departments are identified, formal i training programs to satisfy those needs are developed, and the training programs are implemented in i accordance with the requirements of the QA Program documents.

The QA Program was developed to meet the requirements of the Regulations;_and Regulatory Guides.gf_the Nuclear Renulatory Commission 04RCL and Industry Standards ofi: N:d= 'b;;;ht: j Co.. ..bd :

(NRG)-listed below. Exceptions taken to guidance contained in these documents and equivalent BGE alternatives are stated in Table IB-1.

REGULATIONS 10 CFR 50.55a - Codes and Standards.

10 CFR 50.59 - Changes, Tests, and Experiments.

10 CFR 55 - Operators' Licenses.

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

10 CFR 72, Subpart G - Quality Assurance (ISFSI) l Pace 15 of 72

QUALITY ASSURANCE POLICY Revisicn424J l REGULATORY GUIDES 1.8 - Personnel Selection and Training (September 1975)". His endorses ANSI N18.1 (03/08/71)"*.

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

1.30 - QA Requirements for Installation, Inspection, and Testing of Instrumentation and Electric Equipment (08/lIn2)*. His endorses ANSI N45.2.4 (03/Oln2). I 1.33 - QA Program Requirements (Operation, Rev. 2,02n8)"!. This endorses ANSI N18.7-1976/ANS l 3.2 (02/19n6)*".

1.37 - QA Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (03/16n3)". His endorses ANSI N45.2.1 (02/26n3)*".

1.38 - QA Requirements for Packaging, Shipping, Receiving, Storage, and Handling ofItems for Water-Cooled Nuclear Power Plants (Rev. 2,05/77)". His endorses ANSI N45.2.2 (12/20n2)"*.

1.39 - Housekeeping Requirements for Water-Cooled Nuclear Power Plants (03/16/73)*. His endorses ANSI N45.2.3 (03/15/73)"*.

1.54 - QA Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants (06n3)". This endorses ANSI N101.4 (11/28/72)"*.

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

His endorses ANSI N45.2.6 (1978)"*

1.64 - QA Requirements for the Design of Nuclear Power Plants (10n3)* This endorses ANSI N45.2.11, Draft 3, Rev.1 (07/73).

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 ANSI N45.2.12 (1977).

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

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

INDUSTRY STANDARDS ANSI N45.2.5 - Supplementary QA Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants; Draft 3, Rev.1 (1In3).

ANSI N45.2.8 - Supplementary QA Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants; Draft 3, Rev. 2 (09/73).

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QUALITY ASSURANCE POLICY

\ Revision 4243 ANSI N45.2.9 - Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants; DraR (10n6)*".

ANSI N45.2.13 - QA Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants; 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 in Industry Standard and states alternatives.

1. BGE takes exception to auidance offered in Regulatory Guide and states alternatives.

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QUALITY ASSURANCE POLICY Revision 424J l Procedural Controls The QA Policy and revisions thereto are reviewed by Nuclear Program Managers. QA Policy revisions are reviewed by NQAD personnel to determine if they constitute a reduction in commitments previously made to the NRC. If so, the revisions are sent to NRC for approval prior to implementation. 'Ihe Manager-NQAD reviews revisions to the QA Policy and recommends approval to the Vice President-Nuclear Energy Division. The Vice President-NED approves the QA Policy and revisions thereto.

Each Quality Assurance Procedure (QAP) is prepared by one or more of the Departments responsible for conducting the activity. The QAP and revisions thereto are reviewed by NED Managers and affected l

l Department Managers. The Manager-NQAD ensures QAP revisions are reviewed by the Quality Assurance organization and rew.i i.cr.ds approval to the Vice President-NED. The Vice President-NED approves all QAPs and revisions thereto. 'Ihe Manager-NSSD ensures issuance of all QAPs and revisions thereto. (1) QA Program documents control the distribution and revision of the QA Policy and other QAPs.

Nuclear Program Directives are prepared under the direction of the Department Manager assigned by the Vice President-NED as the Program Sponsor. Each directive and revisions thereto are reviewed by affected Department Managers. The Manager-NQAD ensures directive revisions are reviewed by the Quality Assurance organi=tian and approval recommended to the Program Sponsor. The Program Sponsor approves the directive and revisions thereto. The Manager-NSSD ensures issuance of all directives and revisions thereto.

QA Program documents ensure that: I

1. The need for special controls, processes, test equipment, tools, and skills is specified when necessary l to ensure that required quality is attained in performance of the activity.

2. Quality is verified by inspections and tests.

3. Personnel who perform activities affecting quality achieve and maintain suitable proficiency through appropriate training and experience.

Administrative or Technical Procedures are prepared as needed 'Ihey establish the processes used to implement directive or QAP requirements. He controls for review and issue of procedures are discussed in ,

Sections IB.5 and 18.6.

Review of Ooerations l Procedures require that CCNPP shall be operated and maintained in accordance with the plant TSs and operating license. He following organizations review plant operations to ensure that these procedures are followcxt:

1. The Manager-NQAD provides independent verification that the requirements contained in the Plant's j operating license, UFSAR, TSs, and plant procedures are met. This is accomplished through l quality assurance audits.

2. The OSSRC provides independent verification by review that CCNPP is operated in accordance 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, metallurgy, radiological safety, instrumentation and control systems, mechanical and electrical systems, quality assurance, and emironmental factors. Be Pane 18 of 72 l 1

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QUALITY ASSURANCE POLICY prae-Aing of all =~*iar are documented and sent to the Vice President-Nuclear Energy Division,  !

Committee members, and others designated by the Committee Chairman.

3. He on-site POSRC reviews matters pertaining to nuclear plant safety. This Committee screens i subjects of potential concern to the OSSRC and performs preliminary investigations under the I direction of the Plant General Manager. POSRC membership and functions are governed by l Ti!r! SM--t Addaadam IB-1 and written procedures. {))L%c results of all meetings are docunnented and sent to the members of the OSSRC, and others designated by the Committee l Chairman.

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he maintenance and repair of systems, structures, and components subject to the QA Program are performed by personnel under the direction of the General Supervisors of Electrical and Controls, Radiation Safety, and Mechanical Maintenance, according to written procedures and instructions as prepared by the maintenance force and approved as stated in QA Program documents. These Procedures:

1. Ensure that quality-related activities, such as inspections and tests, are performed with appropriate equipment and under suitable environmental conditions.  ;

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

3. Show where independent verifications of inspections or checks should be performed by specified personnel other than those performing the work.

When necessary, non-plant Company personnel or outside contractors are brought in to supplement the plant work force. In such instances, the approval of work procedures and the tagging of equipment are coordinated by a member of the BGE organization responsible for the performance of the work.

Controls are established in QA Program documents to ensure that materials and parts used in the repair, maintenance, and modification of SR and designated NSR portions of the plant are appropriate for the service intended Written procedures are prepared for the storage and identification of materials and parts to ensure that they do not deteriorate in storage and can be correctly identified before installation or use.

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

designated NSR structures, systems, and components are required to have quality assurance programs I consistent with the importance of the end-product to safety.  !

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

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

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

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

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QUALITY ASSURANCE POLICY Revision 4243 l

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 experunents has been divided into classifications. Procedures required by QA Program documents describe arxl control the method for determining the approoriate process classification. 'Ihe process classifications control the preparation and reporting of safety evaluations. Three methods of treatment are allow 3ble:

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.

2. Implementing the change, test, or experiment in accordance with Procedures rrquired by QA Program documents but controlling the change, test, or experiment with a process classification.

3. Controlling the change, test, or experiment with a process classification and not allowing the implementing activity to begin until the review requirements of 10 CFR 50.59 and 10 CFR 50, Appendix B, have been met.

Changes, tests, or experiments which require approval by the NRC are : ppm;d reviewed by the POSRC l and by the OSSRC.

Controls have been established to ensure that design changes to SR structures, systems, and components are reviewed either by the organization that made the original design or by a Responsible Design Organization (RDO) that meets requirements specified in ANSI N45.2.11, Section 8.0.

Responsible Desian Ornanizations 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 documents, and deviations and changes from such standards are controlled.

3. Suitable design controls are used in applying principles of reactor physics; makmg seismic, stress, thermal, hydraulic, radiation, and accident analyses; ensuring compatibility of materials; and providing accessibility for in-service inspection.

4. Designs are reviewed to ensure that design characteristics can be 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, attemative calculations, and qualification testing are properly chosen and followed; the most adverse design conditions are specified for test  ;

programs used to verify the adequacy of designs. i l

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

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

original design.

9. Design documents and revisions thereto are distributed to responsible individuals and controlled to prevent inadvertent use of superseded material.

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

I1. Design documents and reviews, records, and changes thereto are collected, stored, maintained, and  !

controlled systematically.

l l 12. Standard off-the-shelf commercial or previously approved materials, parts, and equipment essential  !

l to the SR functions of structures, systems, and components are reviewed for suitability of i l application before they are selected.

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

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14. Design changes to NSR items initiated and approved at the plant are controlled to ensure compliance with 10 CFR 50.59.

l l 15. Processes used to select suitable materials, parts, equipment, and processes for SR structures, j systems, and components includes the application of pertinent industry standards and specifications, material and prototype hardware testing programs, and design reviews.

16. Computer programs used in design are subject to design controls and program verification.

l 1B.4 PROCUREMENT DOCUMENT CONTROL (5)

Controls have been established to specify the requirements and sequence of actions for: requesting items or services; review of the requested item or service to establish the necessary technical and quality requirements; preparation, review and control of procurement documents; evaluation and selection of l vendors and; control of deviations from the procurement document requirements.

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

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1. The functional (safety) classification of each item or service as SR or NSR according to controls established by the RDO and

2. The Procurement Category of the item within it's functional classification as a basic component, commercial grade item, designated non-safety related item (DNSR) or NSR item:

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

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1. Not subject to design or specification requirements that are unique to nuclear facilities; and i

2. Used in applications other than nuclear facilities; and i

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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 i

basis commitment; or, for plant availability reasons, BGE has implemented special controls to assure reliability. 'Ihese 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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3. 'Ihe procurement method to be used for the item or service:

Purchase Orders placed by BGE personnel for items or sersices intended for safety related i

! applications and DNSR items and services fall into two categories, Nuclear Grade Method procurement and Commercial Grade Method procurement. l 4

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! a. Nuclear Grade - Purchases that are designated to be placed with vendors that maintain a

, 10CFR50 Appendix B quality program and supply items that meet the defmition of Basic

! Component. 'Ihe requirements of 10CFR21 will be invoked on the vendor under this method i

l b. Commercial Grade - Purchases that are designated to be placed with commercial grade vendors that supply items or services that meet the defmition of Commercial Grade. These items must be dedicated for SR use by BGE.

Items and/or services classified as DNSR will be purchased using the Commercial Grade l Method with technical 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 related 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. These reviews and approvals are documented prior to placement of the purchase order.

All changes made to procurement documents, including specifications and other technical attachments, are

! subject to the same levels of review, approval and control that were applied in preparing and processing the original documents.

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

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

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l Revision 424J Controls for Nuclear Grade Purchases Controls have been established to ensure that, before placement of a purchase order under the Nuclear Grade method of purchase, there is evidence of the following:

I

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

2. He item to be purchased is manufactured under the requirements of the evaluated and approved Program.

l Controls for Commercial Grade Purchases I l l 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 wh~I= to be used to verify the critical characteristics identified in the procurement I document (s). l Procurement Document Reauirements Procedures require that procurement documents shall:

1. Reference part numbers or descriptions, and additional requirements to ensure that items ordered can be identified and verification can be made that each item received is the item ordered.

2. Contain/ reference technical requirements for the basis of design, by inchiding the applicable regulatory requirements, component and material identification, RDO approved drawing and specification, codes, industrial standards, test and inspection requirements, and special process instructions such as welding, heat treating, nondestructive testing, and cleaning.

3. Identify the requirements of 10 CFR 50, Appendix 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 l' services in compliance with the necessary sections of ANSI N45.2.13.

5. Identify required documentation (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 retained, controlled, maintained, or delivered to BGE or the purchaser before use or installation of hardware.

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

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

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

that the item received is the item specified.

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

I1. Include requirements for QA program elements to be passed on to sub-vendors.

IB.5 INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS Controls delineate 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 dimensions, tolerances, and operating limits) and qualitative (such as workmanship samples) acceptance criteria for verifying that important activities have been satisfactorily accomplished.

Controls ensure that:

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

}

2. QAPs are developed by Departments responsible for conducting particular activities, reviewed by  !

the managers of the responsible department (s) for that particular activity, and approved by the Vice President-Nuclear Energy Division. (1)

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

as the Program Sponsor. Affected Department Managers review directives and their revisions. The 1 Manager-NQAD ensurcs directives are reviewed by the Quality Assurance organization and l approval recommer,ded to the Program Sponsor. The responsible Program Sponsor approves directives and their revisions. Directives are prepared, reviewed, amlapproved, " pc fr!!y reviewed according to an appendix to the Nuclear Program Directives Manual. {J13)

4. Procedures are prepared, approved, and controlled according to the Control Procedures. Control Procedures establish review, apprcval, revision, change, and periodic review requirements for applicable procedures. If format and content requirements are not contained in Control Procedures, they shall specify the document to be used to determine format and content requirements. Control Procedures are reviewed by the Quality Assurance Organization. Other procedures are reviewed by I Quality Assurance on a requested basis.

5. Basis items added during procedure revisions or changes will be recorded. (1) I he Plant General Mananer may designate soecific orocedures or clase= of crocedures in writing to be reviewed by the Procedure Review Committee or by Oualified Reviewers in lieu of review by the POSRC. l Review by the Procedure Review Committee and by Oualified Reviewers shall be in amordance with l Addendum IB-l. (19) )

Procedures listed in Technical Specification 6.4 shall be aooroved by the Plant General Manager or by connizant Mananers. Suoerintendents. or General Suoervisors (or Directors) that reoort directly to a  !

Mananer orior to implementation as soecified by administrative reauirements. The aooroval authority for l specific orocedures or classes of crocedures shall be designated in writing by the Plant General Manaaer l and shall be a different individual from the Oualified Reviewer. (19)

Temoorary channes to procedures of Technical Specification 6.4 may be made orosided: I 1

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a. The intent of the oriainal oreMure is not altered.

b. The channe is aooroved by two members of the olant mananement staff knowledaemble in the areas l affected by the orocedures. at la==* one of whom holds a Senior Paartor Operator's Licanse on the unit affected.

e. The channe is daenmented reviewed by the POSRC. the Preadere Review Committaa or by a Oualified Reviewer and aooroved by the da=ionatad anoroval authority within 14 days of imolementation. (19) '

IB.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 License, including the 1 Technical Specifications; Emergency Response Plan; Security Plan; QA Policy; the ISFSI updated Safety Analysis Report (SAR) and Materials License, including Technical Specifications; procedures;  ;

specifications; and drawings.

Revisions to the QA Policy are controlled by QA Program docunwnts which are written to ensure l

compliance with 10 CFR 50.54(a)(3). l Alterations to the UFSAR are controlled by QA Program documents which are written to ensure l compliance with 10 CFR 50.71.

Alterations to the ISFSI updated SAR are controlled by QA Program documents which are written to ensure compliance with 10 CFR 72.70.

4 Alterations to the Operating License, including the Technical Specifications, are controlled by QA Program !

documents which are written to ensure compliance with 10 CFR 50.59(c),10 CFR 50.90 and 10 CFR 50.92.

Alterations to the ISFSI Materials License, including the technical specifications, are controlled by QA 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. l l

1 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.

QAPs are required to:

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

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

3. Specify how important activities, such as plant maintenance or in-service inspection, are to be performed, and give sufficient detail to control the performance of the activity or to ensure that l requirements for lower-level procedures are clearly specified, i l Pane 25 of 72

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

During the review of each QAP, compliance with applicable criteria specified in 10 CFR 50, Appendix B, is verified and documented.

He Manager-NSSD, is responsible for issuing, revising, and controlling QAPs.

QAPs are developed by one of the departments responsible for the subject activities. Each procedure is given a compliance review by a member of the Quality Assurance Organization, and technical review by a member of one of the responsible departments. Each QAP is reviewed by depastment manager (s) who have responsibilities for activities governed by that QAP, and the Managers of the Nuclear Energy Division. (1)

Each QAP is approved by the Vice President-Nuclear Energy Division and issued by the Manager-NSSD.

(1)

Directives are required to:

1. Establish controls to ensure that regulatory requirements and BGE commitments will 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 Manual that describes the format, contents, review and approval, adrevision;, =d p.id =d=

requirements._f.19)

Nuclear Program Directives are prepared and technically reviewed under the direction of the Department Manager assigned as the Program Sponsor. Each directive is resiewed by affected Department Managers.

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

Admmistrative and Technical Procedures are prepared when needed to implement QA Program document requirements according to a Control Procedure. Individual organizations are responsible for preparing, revising, issuing, and controlling procedures. Each procedure is given a technical review under the l direction of the sponsoring organization. The Quality Assurance organization performs compliance reviews on Control Procedures. Other procedures are reviewed by Quality Assurance on a requested basis.

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

1. Changes to a document are reviewed and approved by the organization 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, drawings, and other documents associated with the change.

3. Obsolete or superseded documents are controlled to reduce the possibility of inadvertent use.

Superseded documents retained for reference are marked and stored in separate files. Other superseded documents are removed from the files.

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\ Revision 4241 When changes to drawings or specifications are required, change requests are prepared by the organization that desires the change. Requests are review 1x1 and approved by BGE RDOs.

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QUALITY ASSURANCE POLICY Revision 4241 l IB.7 CONTROL OF PURCHASED MATERIAL EOUIPMENT. AND SERVICES (5)

NQAD, NSSD, NED, and PMMD personnel are responsible for the control of purchased items and services for SR and designated NSR applications at CCNPP.

He controls include:

Accepting items or services only from vendors who have been evaluated and selected in accordance with this policy.

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

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

Vendor Evaluatis ne vendor evaluation is conducted to determine acceptability of a vendor to provide the requested item or service, to determine what vendor programs, procedures and documents need to be invoked by the procurement document, determining the vendor's performance history for supplying items to CCNPP and 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 item (s) being supplied.

He National Institute of Standards and Technology (NIST), by virtue ofits being the nationally recognized standard, is an acce .W; providef of calibration masters, standards or services. Utilities holding an NRC Construction PermrW Operatin s License are acceptable suppliers of all items except for those items to be used in an ASME Boiler and Pressure Vessel Code Section 111 application. Neither of the above are required to be listed on the Approved Vendors List (AVL).

Nuclear Grade NQAD performs evaluations and audits to verify that the vendor has developed and implemented an acceptable quality assurance program that complies with the requirenwnts specified in the procurement specification or proposed procurement specification. Dese evaluations and audits are conducted and documented using written procedures or checklists that identify the QA requirements applicable to the items supplied.

Commercial Grade Since BGE accepts the responsibility of verifying the conformance of commercial grade items and/or service, they may be procured from vendors with no formal quality assurance program. In this instance, BGE dedicates the commercial grade item and/or service for SR use.

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

Vendor controls evaluated to be satisfactory may be invoked as requirements within the purchase order and may be used as part of the basis for acceptance of the item.

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i QUALITY ASSURANCE POLICY 1he depth of vendor evaluation varies according to the complexity and function of the item involved and to the role of the vendor in acceptance of the item.

Vendor Approval Upon completion of the evaluation, satisfactory vendors are added to BGE's AVL. The vendors on this list 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.

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QUALITY ASSURANCE POLICY Revision 424J \

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'c 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. )

l 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 documents, specify the characteristics or processes to be witnessed, inspected or verified.

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

The depth and frequency of vendor surveillances, verifications and audits is commemurate with the complexity and function of the item or service and the ability of the vendor to provide the necessary assurance of acceptability.

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 procesu t.

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

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

Standard receiving inspection ofitems is performed to assure the following:

1. The item is properly identified and that this identification corresponds with the documentation received.

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

3. Items have not been damaged, workmanship is of adequate quality, and the items are adequately clean in accordance with procurement document requirements.

4. Documentation required by the Purchase Order has been received and is reviewed to assure that the item 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 acceptance basis for commercial grade items.

A written record of the results of the NSSD receipt inspection and the disposition of received items is maintamed as part of permanent plant records.

All SR and designated NSR items accepted and released for issue to a controlled storage area or released for installation or further work bear an acceptance tag and have documentation to support their acceptability. If traceability is lost or the documentation review is unsatisfactory, an item becomes subject to the controls established for non-conforming items.

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QUALITY ASSURANCE POLICY Non-conforming items are identified 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 attesting to acceptance must be in the possession of BGE before the item may be released for installation or use. However, an unacceptable item may be given a " Conditional Release" if there is reasonable assurance that it can be made acceptable after installation but before the system that contains it is considered operational. Items released under

" Conditional Release" must be controlled under the Non Conformance Report (NCR) system.

Vendor requested deviations from procurement document requirements, including nonconformances dispositioned "use-as-is" or " repair" must be submitted to BGE for evaluation and approval of the desiation 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. These documents require the identification to be placed on the item or in records traceable to the item so that the function and quality of the item are not affected.

This identification is required to be maintained throughout fabrication, storage, erection, installation, and use. NSSD personnel ensure traceability information is correctly transferred to subdisided materials stored in the Warehouse. User organizations ensure traceability information is correctly transferred to subdisided 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 maintaining the integrity of items and their traceability to associated documents during storage and issue.

BGE contractors and their sub-contractors (who are approved to work on-site under their own QA program) are responsible for establishing and implementing programs in accordance with specified requirements for identifying and controlling materials, parts, and components under their jurisdiction.

Identification of items important to the function of SR and designated NSR structures, systems, and components can be traced to appropriate documentation such as drawings, specifications, purchase orders, manufacturing and inspection documents, desiation reports, and physical and chemical mill-test reports.

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QUALITY ASSURANCE POLICY Revision 424_3 l Receipt i

SR and designated NSR items received at CCNPP are receipt inspected to verify that all requirements of i

the procurement documents have been met. If a discrepancy is observed, such as damage or missing

documentation, information to the effect is recorded on the receiving inspection report, and the discrepant

] item is identified as such and placed in a separate " hold" area when practicable, if the item is acceptable, it j is identified to indicate acceptance and that it is approved for storage or installation and use. When groups ofitems in storage are subdivided, each subgroup is separately identified.

, If an item is found to be or is made discrepant during processing, it is identified as such and placed in a separate area when practicable.

^

Acceptance documentation is required to be traceable to a purchase order, drawing, specification, requisition number, or assembly. As individual items are assembled, installed, and inspected, their acceptance-tag numbers are recorded in plant maintenance or operation records.

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

i IB.9 CONTROL OF SPECIAL PROCESSES 1

Controls e

i Controls have been established for writing, qualifying, approving, and issuing procedures to control such

! special processes as welding, heat treating, and nondestructive testing used during the operation of CCNPP.

Special Process Procedures:

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

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

. 3. Specify requirements for control, parameters to be considered, acceptable methods of 2

documentation, and the codes, standards, specifications, or criteria which govern the qualification.

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4. Define the necessary qualification of personnel, procedures, or equipment when special processes i

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

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

] and for maintaining records to verify that special processes are performed in accordance with requirements i established by the portions of their QA programs that apply to special processes.

i' Oualification of Methods Procedures, equipment, and personnel connected with special processes are qualified in accordance with applicable codes, standards, specifications, or supplementary requirements as follows:

4

- 1. Welding activities conducted by BGE are performed according to welding procedure specifications qualified in accordance with applicable welding requirements of the ASME Code. Each welding procedure specification is written, qualified, and approved in accordance i,

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QUALITY ASSURANCE POLICY with a controlling documented procedure. Copies of welding procedure specifications are made available to welders and, when required, to Authorized Inspectors Before contractmg for welding, the Principal Metallurgist reviews and approves non-BGE welding procedure specifications and procedure qualification records in accordance with a wTitten procedure.

~

2. Heat-treatmg requirements included in welding procedure specifications are established in )

conformance with heat-treating requirements of the applicable ASME Code.  !

3. Nondestructive Examinations are performed to written procedures proved by actual demonstration, when practicable, to the satisfaction of the Principal Engineer - Nondestmetive Examination -

Nuclear and, when required, the Authorized Inspector.

"Ihese procedures are prepared according to appropriate sections of the ASME Code for particular exammation methods Procedures, personnel qualifications, and the records that verify the Performance of Nondestructive Examinations are kept as nuclear plant records. Nondestructive Exammation Procedures describing methods not described in the ASME Code and/or SNT-TC-1 A and its Supplements are at least equivalent to those rengai=I by the American Society of Mechanical Engineers and the American Society for Non-destructive Testing. Training programs acceptable to the Principal Engineer - Nondestructive l Examination - Nuclear are developed to complement these alternative methods and to establish the i capability of personnel to perform the required examination according to BGE procedures arxi to the level of performance to which the individual will be certified.

Methods of Nondestructive Examination include, but are not restricted to, radiographic, ultrasonic, ,

liquid-penetrant, magnetic-particle, eddy-current, visual, and leak-testing examinations. l Procedures are prepared to cover these examinations in accordance with a QA Program document l that details the specific examination, requirements for approval, and content of the procedure, such I

as certification level, accept / reject criteria, examination coverage and sequence, surface l

preparation, test equipment, records required, permissible marking, cleanup requirements, and reference to applicable sections of the ASME Code.

l Oualification of Personnel Special processes are performed by certified personnel using wTitten 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 accordance with the applicable requirements of the ASME Code. The Principal Metallurgist maintains records of the l welding procedure specifications, including essential variables under which the welders are l examined, and the results of the examinations. A welder is not permitted to weld SR and designated l NSR items until an appropriate performance qualification record, a letter of certification, or, in an l emergency, verbal clearance from the Principal Metallurgist, is on file at CCNPP. Each welder is

required to be requalified as specified in the applicable code.

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

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l QUALITY ASSURANCE POLICY Revision 424.] l

3. Nondestructive Examination personnel employed by or responsible to BGE are certified according 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 written procedure. Non-BGE personnel are qualified to procedures approved by BGE, and their qualifications and certifications of personnel are verified I according to writter. procedures.

Qualification records of procedures, equipment, and personnel associated with special processes conducted by BGE are filed and kept current by the Principal Metallurgist or Principal Engineer - Nondestmetive Examination - Nuclear.

'Ihe Manager-NQAD provides independent verification that special processes are performed by qualified personnel.

IB.10 INSPECTION Activities that affect the quality of SR and designated NSR items are inspected as specified in approved

, instructions, procedures, and plans which set forth requirements and acceptance criteria to ensure that work is done in conformance with particular requirements.

Controls exercised during inspections ensure that: j

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

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

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

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

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

6. Appropriate inspection requirements are established for modification, repair, and replacement. l 1

7. Personnel who perform quality verification inspections are qualified in accordance with appropriate i codes, standards, and Company training programs, and their qualifications and ceitifications are  ;

kept current.

1

8. Procedures for maintenance and modification are reviewed by QV personnel, or others authorized by I QV, to determine the need for independent inspection and the degree and method if such an  ;

inspection is required, and to ensure the identification ofinspection personnel and the documentation ofinspection results.

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\ Revision 42_41

9. Procedures for Nondestructive Examination, excluding visual examination procedures performed on nuclear fuel, are reviewed by qualified personnel in FED. Procedures for nuclear fuel inspection and visual examination on nuclear fuel are reviewed by qualified personnel in NED. Resiew is to deternune the *"7 of procedural controls and of inspection criteria, the need for independent inspection, and the degree and method, if such inspection is required; and to ensure the identification of qualified inspection personnel and the documentation ofinspection results.

10. Inspection results are recorded, evaluated, and retained Inspection procedures, instructions, and checklists used by inspection personnel provide the following:

1. Identification of characteristics to be inspected

2. Acceptance and rejection criteria.

3. Description of the method ofinspection.

4. Identification of required procedures, drawings and specifications.

5. Identification ofinspector or data recorder.

6. Verification of completion and certification ofinspection.

7. Record of results ofinspection.

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

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

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

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

Other inspections are conducted randomly to verify that overall plant operations are being conducted according to approved procedures and to ensure that the use of jumpers is properly documented; that equipment is returned to operating status after test, modification, or repair; that instruments are properly calibrated; and that personnel who perform tests are properly trained and qualified.

In-service inspections are performed on pressure-containing components within the reactor coolant system boundary according to requirements of the TSs.

In-senice inspections and examinations on components designated Class I or Class II by the ASME Code i are witnessed or otherwise verified by an authorized Code Inspector who is responsible for ensuring that the work is performed by qualified personnel according to written qualified procedures. Records of in-senice 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 exammation.

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QUALITY ASSURANCE POLICY Revision 4;14_1 l 1B.11 TEST CONTROL To demonstrate 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 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 l documented and evaluated.

Whenever testing is required to demonstrate that SR and designed NSR material, parts, components, or systems will perform satisfactorily in service, a test program is established and procedures are used that have been written and approved in accordance with basic requirements.

Nuclear Engineering Depa:tment, and CCNPPD conduct tests to verify that plant behavior conforms to I design criteria, ensure that failure and substandard performance are identified and controlled, and I demonstrate satisfactory performance after plant modification and maintenance activities.

Written test procedures are developed, reviewed, and approved before testing is performed. They specify instructions for testing, methods of test, test equipment, and instrumentation; and for the following as applicable:

1. Adequate and appropriate equipment.

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

3. Suitable and controlled environmental conditions.

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

5. Provision for data collection and storage.

6. Acceptance and rejection criteria.

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

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

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

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

Results of testing performed as part of receipt inspection are evaluated, accepted and approved by qualified  ;

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QUALITY ASSURANCE POLICY

\ Revision 4243 IB.12 CONTROL OF MEASURING AND TEST EOUlPMENT 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 l standards, and nondestructive test equipment used in measuring, inspecting, 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 Operation and Maintenance Department Calvert Cliffs Nuclear Power -

Radiation Safety Plant Department -

Performance Engineering Unit

- Mechanical Maintenance Electrical and Controls Nuclear Operations Chemistry Calibration controls require each grocp 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. These Calibration Procedures contain the following information:

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

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

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

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

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

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

Test and measuring equipment that cannot be adjusted to required tolerances during calibration is identified and placed in a designated segregated area; if the equipment can be used in limited applications, the limitations are identified.

The status of each item 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 established for each item of measuring and test equipment and recorded on a master record of calibrations prepared as a calibration schedule.

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QUALITY ASSURANCE POI, ICY Revision 424J l Measuring and test equipment is controlled to prevent the use of uncalibrated or defective equipment, the spread of radioactive contammation, the introduction ofimpurities into high-purity systems, and damage to 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 requirements.

Measuring and test equipment is calibrated and adjusted at specified intervals, or before use, against certified standards, Reference and transfer standards are traceable to nationally ramenb~i standards; or, where national standards do not exist, provisions are established to document the basis for calibration.

1B.13 HANDLING. STORAGE. AND SHIPPING Appropriate and special requirements for handling, preservation, storage, cleamng, packaging, and

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

Procedures have been established to ensure that the handling, preservation, storage, cleaning, packaging, and shipping of SR and designated NSR items are performed in accordance with specified requirements to reduce the likelihood of damage, loss, or deterioration by such environmental conditions as temperature or humidity.

Special handling, preservation, storage, cleaning, packaging, and shipping activities associated with SR and designated NSR items are perfonned by suitably trained personnel in acccidance with specific written procedures.

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

IB.14 INSPECTION. TEST. AND OPERATING STATUS I Controls have been established for the application and removal of status indicators such as tags, nurkings, labels, and stamps to ensure that the inspection, test, and operating status of SR and designated NSR structures, systems, and components is clearly indicated at all times.

Procedures / instructions are prepared to identify and control inspection, testing, and operating status by the use oflogs, forms, and tags that identify the inspection, test, and operating status of structures, systems, and components; control the use ofindicators, including the authority for their application and removal; control bypassing operations, such as jumping or temporary removal of electrical leads; and identify non-conforming, inoperative, or malfunctioning structures, systems, or components. l Senior shift personnel are responsible for aligning, isolating, and appropriately tagging installed equipment and systems so that activities affecting quality can be performed.

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

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

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\ Revision 46 IB.15 NONCONFORMINO MATERIALS. PARTS. OR COMPONENTS (6)

Controls have been established for identifying, documenting, segregating, reviewing, dispositioning, and notifying affected organizations ofIssues affecting materials, parts, or components (i.e., items).

Issues affecting nuclear plant items are referred to as nonconformances. Nonconformances are hardware deficiencies which render the quality of an item unacceptable or indeterminate.

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

Nonconforming items are controlled by documentation, marking, logging, tagging, or physical segregation to prevent inadvertent installation or use.

Nonconformance control documents are submitted to responsible departments for resolution. Designated personnel have the responsibility and authority for approsing the resolution of nonconformances.

Nonconformance control documen.s are not closed until corrective actions have been completed.

Nonconforming items are dispositioned as rework, repair, reject, or accept-as-is. He disposition of a repair or accept-as-is nonconformance is treated as a design change and is evaluated and approved or rejected by the RDO.

Reworked, repaired, and replacement items are inspected and/or tested in accordance with the original inspection and/or test requirements or acceptable alternatives to ensure that critical characteristics possibly affected by the nonconformance remain acceptable.

1 Nonconforming items may be conditionally released for installation, test, energization, pressurization, or use if the conditional release will not adversely affect nor preclude identification and correction of the ,

nonconformance. Nonconforming items required for Technical Specification operability may be released  !

for use following verification that the nonconforming item meets all operability requirements specific to its function and is approved for use by authorized Operations personnel. Conditionally released items will be j resolved in accordance with this Section. Conditional release evaluations are documented, reviewed, and approved prior to implementation.

1 IB.16 CORRECTIVE ACTION (6) l Controls have been established to ensure that Issues are identified, documented, reviewed, and corrected.

Rese 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).

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

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

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

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QUALITY ASSURANCE POLICY Revision 4241 \

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

Inues are periodically analyzed for the identification of adverse quality trends 'Ihe existence of an adverse l

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 maintamed to provide docurnentary evidence of the quality of SR and designated NSR items and activities. Applicable design specifications, procurement documents, test procedures, operational procedures, QAPs, TSs, and other h-ts specify worda dr. dould h prated, cupplied, or maintained by and for BGE.

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

Lifetime records, maintained for particular items for the life of CCNPP, for particular items have significant value in relation to demonstrating capability for safe operation; maintammg, reworking, repairing, replacing, or modifying an item; determining the cause of an accident or malfunction of an item; l

and providing required baseline data for in-service inspection.

The following records shall be retained for the duration of the Facility Operatina License:

a. Records and drawina channes reflectina facility desian modifications made to systems and cauioment described in the Final Safety Analysis Report.

b. Records of new and irradiated fuel inventory. fuel transfers and assembly bumun histories.

c. Records of facility radiation and contamination surveys.

d. Records of radiation exoosure for all individuals enterina radiation control areas. 1

e. Records of naseous and liauid radioactive material released to the environs.

f. Records of transient or operational cycles for thore facility components identified in Desian Authority Pronram orocedures.

a. Records of training and aualification for current members of the olant staff.

h. Records ofin-service inspections performed oursuant to the Technical Specifications.

i. Records of Ouality Assurance activities identified in this NRC anoroved OA Policy as lifetime records,

i. Records of reviews performed for channes made to orocedures or couioment or resiews of tests and experiments oursuant to 10 CFR 50.59.

k. Records of meetinas of the POSRC. the Procedure Review Committee. and the OSSRC.

1. Records of the service lives of all safety related snubbers including the date at which t_hq l service life commences and associated installation and maintenance records.

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QUALITY ASSURANCE POLICY Non-permanent records, which show evidence that a SR and designated NSR activity was performed in accordance with applicable requirements, are retained for periods sufficient to ensure BGE's ability to reconstruct significant events and to satisfy applicable regulatory requirements. Retention periods are based on requirements specified in QA Program documents. Retention periods shall be documented.

The following records shall be retained for at least five years:

a. Records and loas of facility operation covering time interval at each oower level

b. Records and loas of orincipal maintenance activities. insoections. repair and replacement of orincipal items of eauioment related to nuclear safety.

c. All Reportable Even_th

d. Records of surveillance activities. insoections and calibrations required by the Technical Specifications.

e. Records of reactor tests and exoeriments.

f. Records of channes made to Ooeratina Procedures.

a. Records of radioactive shipments.

h. Records of sealed source and fission detector leak tests and results.

i. Records of annual ohysical inventory of all scaled source material of record.

Procurement documents specify vendor responsibilities for the generation, retention, and submission to BGE of quality assurance documentation related to the fabrication, inspection, and test of SR and designated NSR items and services.

Inspection and test records contain the following as appropriate:

1. Description of the type of observation.

2. Date and results ofinspection or test.

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

4. Identification ofinspector or recorder of data.

5. Statement as to acceptability of results.

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

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i QUALITY ASSURANCE POLICY Revision 4243 }

IB.18 AUDITS Internal audits are performed by BGE's Quality Audits Unit to ensure that activities and procedures established to implement the requirements of 10 CFR 50, Appendix B, comply with BGE's overall QA Program 'Ihese audits are rmifvi.r.ed under the enani>=nce of the OSSRC and provide a comprehensive l irecperdera verification and evaluation of quality-related activities and procedures. Audits ensure the effective and proper implementation of BGE's QA Program. Audits of selected aspects of operational phase activities are nerformed with a frequency evo., == urate with their strenath of ocrfornunce and safety sinnificance and in such a manner as to assure that an endit of all safetv-rel*A functions is completed within a oeriod of two years. (Audits soccified in reaulations are nerformed at the freauencia noted therein.) In addition to the audit subiects specified in Reaulatory Guide 1.33 Revision 2 and ANSI N18.7-1976/ANS-3.2. audits ocrformed within a ceriod of two years shall also encomnam the Facility Fire Protection Proaram and implementina crocedures; an independent fire orotection and loss orevention oronram insoection and audit utilizina either analified offsite licensee oersonnel or an outside fire orotection firm: the radiolonical enviis r-uial monitorina oroaram and the results thereof: the Offsite Dose Calculation Manual and imolementina orocedures: the Process Control Program and implementina procedures for orocessina and nackaaina of radioactive wastes: the nerformance of activities reouired by the OA Pronram for effluent and environmental monitorina: and the performance of actisities reauired by the OA Pronram to meet the criteria of 10 CFR 50. Anoendix B. Audits shall also encomcass any other area of facility operation considered anorooriate by the OSSRC or the VP-NED. An insnection and audit of the fire orotection and loss orevention orogram shall be performed by a aualified outside fire consultant at least once ner 36 months. (191 '!hy . : ::M!:d : 6 S::: ef S b.;,c"-- : te .:f:'y of::9.itic:

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.

f"'- Of f-^7^^f ^^t;5- . .--^i^Oy i TS- ^c: p;ir.d r.i ^^.; .i== Of S OSS"C. 1 Aud2s are performed in accordance with preestablished written procedures or checklists by qualified NQAD personnel who have no direct responsibility for the work being audited. Technical specialists from other BGE departments and outside consultants may assist as necessary in performing audits. Audits include objective evaluation of quality-related practices, procedures, instructions, activities, and items, as well as review of documents and records.

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Reports' of audits are analyzed and documented. 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 correct noted deficiencies.

To ensure that BGE's NQAD complies with the requirements of BGE's QA Program, an independent management audit of NQAD activities is performed annually by a Joint Utility Management Audit (JUMA)

Team.

I Page 42 of 72 l

QUALITY ASSURANCE POLICY l Revision 4243 TABLE IB-1 BALTIMORE GAS AND ELECTRIC COMPANY'S POSITION ON GUIDANCE CONTAINED IN, ANSI INDUSTRY STANDARDS AND REGULATORY GUIDES Revision ofIndustry Standards Applicable to the Baltimore Gas and Electric Ouality Assurance Program Reauirement Some of the Industry Standards listed in Section 18.2 identify other Standards that are required, and some Regulatory Ouides define the revisions of those Standards that are acceptable to the NRC.

Response

BGE's QA Program was developed to respond to the specific revision of the documents listed in Section  !

IB.2 and is not necessarily responsive to other documents listed in the uterenced Industry Standards.

l ANSI N18.7/ANS 3.2 - 1976 Item 1 (19)

Requirement Section 5.2.15 requires that plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less freauently than every two years to determine if changes are necessary or desirable. A ::vbi= e a crc =&re cc=titu:= = cad =: re.iev (19)

Response

BCE cpp!!= Sb requir=;;; cf a twc y= reviev to all p!=: pree &r= ==pt :=: precedur= pc-formed  ;

= :P.= i= : ::7 twc y=n: = :: :=pecified frequ= ic. H. = =: review;d ac ==: i= 50 dy: I b;f=: p=fc== =.P!=: preced== =: =bj=: c =c====:ic contech A!:h cent:n=!!v i&n:ifv n=id prc=d= :.i:;ic=. (19)

Routine olant procedures do not receive biennial reviews. but are subiect to orogrammatic controls which continually identify needed procedure revisions.

Routine olant orocedures that havgnot been used_for two years are reviewed consistent with ore-evolution briefing recuirements. Additionally. orocedure use and adherence requirements state clear procedure comoliance expectations and the need to stop.the iob if a procedure cannot be performed as written.

Non-routine plant procedures whose usage may be dictated by an event (such as Emergency Operatina Procedures. Abnormal Operating Procedures. and Emergency Response Plan Imolementina Procedures) receive biennial reviews accordina to administrative orocedures.

Applicable olant orocedures are reviewed following an unusual incident and following amy modification to a system.

l Page 43 of 72

l QUALITY ASSURANCE POLICY i Revision 4243 l The biennial audit of the Procedures Program includa= a representative sample of clant proeMures. The audit helps ensure the accentability of the orocedures and verify that the Pracadures Pronram is beiDS Liwk;rcr.ted effectively.

1 Reason

. " -c_-;'-- i.; T= " -:::5 = (E"_:) - '_ c^::; !!k: is; = .d= 6 : x; in ='y p.'cc; ;; n'

g - __ g p. __ g ui .__.

g g _y _; .. _; _;_ : , g = y__.,5_..g _ _ > __ _2:gg i  :- $^'  : r!" ; t 6 i ; ;'p;'a.. -- : I l f r- Scre:!!' - : T=t ";-::: 5 = (S":) = p ' cad :=rj 1:= :: f.= y:=. U.:y ::: = miewed l i:' :. ;-d. p;'e:c..== :: :xx: 1-2 Sy = ec;dhk ;;ii : ": ; -

--- - ' . # x ' = ::

l x.._.: . ::i. I Proarammatic controls meet the intent of the biennial review orocess from both a technical and oractical

='madanint because they constitute dynamic. rather than static, orocadure review met _hada!aav. Thus. the biennial review orocess is raduadant to established programmatic controls and is unnaca===rv.-44M I Item 2 (10)

Reauirement l

l Section 5.2.2 specifies that temporary procedure changes that clearly do not change the intent of the <

approved procedure shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedure; and at least one of these individuals shall be the supervisor in charge of ,

the shift and hold a senior operators' license on the unit affected.

l Response  :

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

Reason 1

Many proposed temporary procedure changes do not require the Shift Supervisor's immediate attention or knowledge of the change since they do not affect plant safety. Other SROs are available and qualified to perform this task since the Shift Supervisor's detailed review of the proposed change is not necessary to ensure plant safety.

Requiring the Shift Supervisor to review all changes is burdensome and contrary to plant safety in light of the total number of procedures that exist and the time the Shift Supervisor 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 necessarily the Shift Supervisor).

REGULATORY GUIDE 1.33-1978 (19) l Reauirement

! Section C.. Regulatory Position. item 4. states:

l Page 44 of 72 l l

QUALITY ASSURANCE POLICY l Revision 4243 Section 41 " Audit Proaram."of ANSI N18.7-1976/ANS 3.2 s*=*~ that audits of =alacted aspects of operational chase activities shall be nerformed with a frequency commensurate with their safety sinnificance and in such a manner as to ensure that an audit of all safetv-related functions is comoteted within a ceriod of 2 years. In amplificatinn of this reauirement. the followma oroaram elements should be audited at the indicated freauencies:

a. He results of actions taken to correct deAgiencies that affs;t nuclear safety and occur in facility cauipment. structures. systems. or j method of ooeration - at least once ner 6 months.

b. %e conformance of facility ooeration to orovisions contained within the technical specifications and anolicable license conditions - at least once ner 12 months.

c. The nerformance. trainina. and aualifications of the facility staff

- at least once oer 12 months.

Response

ne audit freauency for all safety-related functions is at least once every two years (except as otherwise reauired in reaulationst Basel The more freauent audit intervals do not allow BGE management the flexibility to devote auditina resources consistent with the strenath of performance and safety significance of an activity. Experience has shown that some audits are oerformed more freauentiv than deemed aooropriate for the function.

ANSI N18.1 - 3/8/71 Reauirement Paragraph 4.2.2 states that at the time of initial core loading or appointment to the active position, the 1 Operations Manager shall hold a Senior Reactor Operator's (SRO) License. i 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. This functional level I generally includes the plant manager (plant superintendent, or other title), his line assistants, if any, and the principal members of the operating organization reporting directly to the plant manager and hasing overall  ;

responsibility for operation of the plant or for its maintenance or technical service activities.

Response l Baltimore Gas & Electric has two positions in its organization, Superintendent-Nuclear Operations and i General Supervisor-Nuclear Plant Operations. Neither of these positions needs to individually meet all of l

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 Superintendent-Nuclear Operations will hold or have held an SRO license. The GS NPO will hold and I

I l Pane 45 of 72

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l QUALITY ASSURANCE POLICY \

Revision 4243 l mamtam an SRO license. The GS-NPO satisfies paragraph 4.2.2, but he does not satisfy 3.2.1 because he does not repott directly to the plant manager.

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Page 46 of 72 l

QUALITY ASSURANCE POLICY Reason The Superintendent-Nuclear Operations will hold or have held an SRO license, as opposed to having a license at the time of =pps^- = to the position. He will have an excellent unhimudmg of plant operations. The GS-NPO will not only hold an SRO license at the time of appointment to the position, but he will maintain the license. The GS-NPO directly supervises the operatmg shift organization, whereas the Superintendent-Nuclear Operatons is also respcasible for operations procedure development, modifications

=eceptance, and operations / maintenance coordinations. The Superintendent-Nuclear Operation's level of i

supervision does not require current in-depth and plant specific knowledge which results from maintaining an SRO license.

].tggll(17)

Reauirement i

Paragraph 3.2.2 states that supervisors are persons principally responsible for directmg the actions of operators, technicians, or repairmen. Those positions usually designated as intermediate and first line supenisors are included in this category.

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

Re= nance Baltimore Gas and Electric has three supenisory positions in its organization - Supervisors, and in some cases Assistant General Supervisors and General Supervisors - which are organizationally equivalent (when supenising technicians / repairmen) to the positions described in paragraph 3.2.2 of ANSI N18.1-3/8/71. All these individuals need not possess the four years of craft / discipline experience required by paragraph 4.3.2. Instead, at least the first line supenisor shall possess four years experience in the craft / discipline he supervises while other supenisors in the organization may be selected to fill supervisory positions based on possessing a minimum of an Associate's Degree, with four years of related technical experience, and demonstrated supervisory ability. (18) Additionally, all first line and intermediate supervisors shall have at least a high school diploma or equivalent.

Esanon To provide a balanced and broad base of supervisory ability within the site organizations made up of technicians / repairmen, it is desirable to include as supervisors both individuals with extensive craft / discipline experience accrued through field work and indisiduals with related education and experience who have demonstrated the ability to effectively supervise.

ANSI N45.2.1 - 1973 Reauirement

! Subsection 3.2 outlines requirements for demineralized water.

i Response l

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

l Page 47 of 72 l

QUALITY ASSURANCE POLICY Revision 424J l Reason BGE specificatens for demineralized water are consistent with guidelines provided by the Nuclear Steam Supply System supplier. BGE specifications are generally more restrictive than those specified by ANSI N45.2.1.

ANSI N45.2.2 - 1972 litIRl Reauirement Subsection 2.4 could be interpreted to mean that on-site and off-site personnel who perform any inspection, exammation, or testing activities related to the packing, shipping, receiving, storage, and handling ofitems for nuclear power plants shall be qualified in accordance with ANSI N45.2.6.

Rsaanne BGE requires that only persons who are responsible for approving items for acceptance shall be qualified in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6) and that persormel who verify that storage areas meet requirements will be qualified to either Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or ANSI N45.2.23.

Reason Our receipt inspection procedures require persons who approve items for acceptance to be qualified in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6). QV technicians, inspectors or QA auditors verify that storage areas meet requirements. All other inspection, examination, and testing activities are subject to review by persons qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6).

html Reauirement The second sentence of Subsection 2.4 requires that:

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

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

Reason The qualification requirements for auditors cannot always be met by persons qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6).

Pare 48 of 72 l

i I I QUALITY ASSURANCE POLICY him.2 Reauirement Subsection 2.7 requires that activities covered by the Standard shall be divided into four levels, though recognizing that within the scope of each level there may be a range of controls dependmg on the importance of the item to safety and reliability.

Response

1. The level of protective neasures dermed by Subsection 2.7 are applied to Basic Component purchases.

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

1 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.

Item 4 Reauirement Subsection 3.0 specifies detailed requirements for packing items for each level defmed in Subsection 2.7.

Resoonse l

BGE has replaced Section 3.0 with the following:

1. Packaging for Shipment to BGE Personnel of BGE'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 confonn to applicable requirements for items in that classification defined in Regulatory Guide 1.38, Rev. 2 - March 1977.

2. The normal methods of pac ~kaging used by the industry in general are acceptable for items being procured as Commercial Grade.

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QUALITY ASSURANCE POLICY Revision 424J l

3. Packaging for Storage by BGE l

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

1 Reason l 1. This substitution will ensure that the item will receive adequate protection during shipment and storage, thus eliminatmg unnecessary restrictions and enabling BGE to use commercial sources to l the utmost l 2. Experience shows that industrial practices for packaging Commercial Grade items are adequate for most applications.

htm.1 Reauirement Section 4.0 defines shipping requirements related to the protection levels assigned to items.

r

Response

BGE has replaced Section 4.0 with the following:

l 1. Shipping to Baltimore Gas and Electric BGE will invoke the requirements for shipping specified in Section 4.0 of ANSI N45.2.2 - 1972 on Basic Component purchases only when NED or FSSD personnel have specified in procurement documents that the item shall be packaged in conformance with ANSI N45.2.2, Section 3.8.

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

Reason I

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

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% .s a e m-QUALITY ASSURANCE POLICY i l Revision 4243 litBLf ,

Reauireme_nt Subsection 6.4 gives detailed requirements for care ofitems in storage, according to the protection levels 1 assigned to the items. 1

Response

BGE does not require items to be stored in the packing used for shipment if the storage level in the area provides the same protection as the level of packing assigned to the 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.

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 impractical. BGE requires NED or NSSD personnel to specify requirements more closely related to the actual function of items and to storage

)

conditions.

litEL 7.

Reauirement Subsection 7.3.3 requires compliance with a series of ANSI documents.

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 these documents.

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.

l Pane 51 of 72

I QUALITY ASSURANCE POLICY Revision 42]4 l ANSI N45.2.3 - 1973 lital Reauirement 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, smoking restrictions are posted for BGE's class 3 areas.

litEl 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.

Basponse BGE has established the following methods for personnel and material accountability:

1. Written accountability.

2. Where possible tethering of tools and materials to permanent plant structures or persons.

3. Post-maintenance closcout inspections.

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

ANSI N45.2.4 - 1972 Reauirement The last paragraph of Subsection 6.2.1 (Equipment Tests) states:

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

Page 52 of 72 l

QUALITY ASSURANC2 POLICY

! Revision 4243 Response l l

De new calibration program at Calvert Cliffs does not use calibration stickers that contain date of l calibration and identity of person that performed the calibration. The new calibration stickers indicate that  :

the instrument is periodically calibrated according to the calibration program. The sticker, a green "C,"

means the instrument is in the program.

Reason i In the past, the date of calibration noted on the instrument was important because the calibration history of preventive maintenance was not kept on computer. Computer tracking systems and trending 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 recommend

• ions, 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 instruments 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.

ANSI N45.2.6 - 1978 l Item.1 Reauirement Subsection 1.2 states in part, ne requirements of this standard apply to personnel who perform inspection, examination, and tests during fabrication prior to and during receipt of items at tlw construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.

Response-A Personnel of BGE's Quality Assurance organizations who perform independent verification through inspections, examinations, or tests at the plant site during operational phases of the nuclear power plant are required to be qualified in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1,1971. All other BGE personnel who perform inspection, examination, and testing functions associated with normal operations of the plant are qualified either to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1 - 1971.

Reason-A

1. The individuals who perform inspection, exanunation, and testing functions associated with normal operation of the plant, such as maintenance and certain technical resiews, are normally qualified to ANSI N18.1 - 1971.

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QUALITY ASSURANCE POLICY Revision 424. 3 \

2. Some testing activities conducted during normal operation of the plant, such as surveillance testing, do not require that test personnel meet the requirements specified in Paragraph 4.5.2 of ANSI N18.1 for technicians. Personnel qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) are adequately qualified to conduct such testing.

Pananw-B BGE does not always require vendor personnel perfornung inspection or test activities to comply with the requirements of Regulatory Guide 1.58 (which endorses ANSI N45.2.6) but evaluates the need for invoking Regulatory Guide 1.58 (which endorses ANSI N45.2.6) on the vendor during the review of procurement documents. The requirements are not applied to procurement classified as Commercial Grade.

Reason-B BGE's position is as follows:

1. For replacement items purchased as Commercial Grade Items, tim purchaser may not impose nuclear unique requirements on the vendor. Additionally, items may be manufactured before placement of the purchase order and the vendor may not be required to maintain records of the performance ofinspections or tests.

2. For Basic Component Purchases, the qualification requirements for inspection, examination, and test personnel are determmed by;

a. Item status (new or replacement).

b. Complexity and importance ofitem.

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 trained as required by Regulatory Guide 1.58 (which endorses ANSI N45.2.6).

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

1. Activities to be verified.

2. Acceptance criteria.

3. Method of documenting results.

4. Method of reporting deficiencies.

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

Page 54 of 72 l

QUALITY ASSURANCE POLICY Pa=mnen-D l

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

lit!Ill Requiremen_t Table I specifies that Level III personnel shall be capable of qualifying Level III personnel.

Response

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

Reason BGE personnel in these grades are capable of certifying Level III personnel without being trained as Level 111 inspectors.

NOTE:

Regulatory Guide 1.58 (which endorses ANSI N45.2.6-1978) statesin part, under item 6 of Regulatory Position, that.. "In addition to the recc,ninici.dations listed under Section 3.5 (of ANSI N45.2.6-1978) for Level I, II, and III personnel, the candidate should be a high school graduate or have earned the General Education Development equivalent of a high school diploma...." Based on the NRC letter dated January 17, 1985 from Thomas T. Martin to A. E. Lundvall, Jr., the above educational requirements will be implemented for inspection, examination, and testing personnel hired or assigned after 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 lit!!!l Reauirement Section 4.0 titled " Receipt" gives instructions for receipt controls.

Response

DGE applies these requirements only to the receipt of records by the Plant History File. I l Pane 55 of 72 i I

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QUALITY ASSURANCE POLICY Revision 4243 l Banaan Most records received by such organizations as Receiving Inspection, Engineering, etc., are not shipped in .

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

l Item 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 constructicn."

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

Resnonse/P.eason Ite m a The intent of this requirement is both structural integrity and fire resistance. This vault is entirely enveloped by a structurally sound, fire resistive building. Second, the vault rests on a reinforced slab on grade and its walls extend fully to the underside of the structural deck. Third, the walls of the vault are constructed of gypsum wallboard on metal studs per Underwriters Laboratory Test Number U412, assuring the equivalent of 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire resistive construction. This is equal construction to concrete block in terms of fire protection. The walls carry no structural load; hence, they provide equivalent structural integrity to that needed of concrete block.1 (See footnote following page).

l Response / Reason i 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).

htHL2 Reauirement Subsxtion 5.6 allows only the dual facility defined in Subsection 5.6.2 as an alternative to the single facility defined in Subsection 5.6.1.

IThese responses have been forwarded to the NRC by the BGE letter dated 02/11/83 from Robert G. Michols, Sr. Facilitics Project Administrator, Real Estate and Office Services Department, to Tcay L. Harpster, Chief QA Branch, Division of QA, Safeguards and Inspection Programs, IE, USNRC. These responses have also been accepted by the NRC in their letter dated 04/22/83 from Walter P. Haass, Deputy Chief, QA Branch, Division of Quality Assurance, Safeguards, and Inspections Programs, Office ofInspection and Enforcement.

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QUALITY ASSURANCE POLICY 1 Revision 424_3 ne==

BGE allows the following alternative storage requirements for orgamzations 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 alternatives to the requirements specified for the Records Management Unit:

1. Duplicate Storage  !

Either A or B.

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

1. Assignment of responsibility for records.

2. Description of storage area.

3. Description of filing system.

4. An index of the filing system. -

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5. Rules governing access to and control of files. '

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 records.

8. Method for preserving records to prevent deterioration.

9. Method for maintaining specially processed records that are sensitive to light, pressure, or temperature.

10. Transfer of duplicates to the Records Management Unit within two years of completion of records.

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

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

The 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-minimum fire-rated storage cabinets and be subject to the procedural controls defined for duplicate storage.

l Page 57 of 72

l QUALITY ASSURANCE POLICY I Revision 424J l l BGE defines a Fire-resistant Building as follows:

A facility constructed to resist the initiation or spreadmg of fire; non-combustible and/or fire-suppressive materials used; building certified as fire-resistant by the Risk Management Unit of EGE's Corporate Finance Group.

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

ANSI N45.2.23 - 1978 htilLl.

l Reauiremen_t 2.3 Qualification of Lead Auditors Section 2.3.1 requires prospective Lead Auditors to obtain a minimum of ten credits under the scoring system defined in paragraphs 2.3.1.1-2.3.1.4.

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- Resoonse j

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BGE has revised the scoring system as follows:

Education and Experience The prospective Lead Auditor shall have accumulated a minimum of ten credits under the following scoring system:

1.0 Education (4 credits maximum) 1.1 For the Associate degree for an accredited institution, score one credit, if the degree is 1 in engineering, physical sciences, mathematics, or quality assurance, score two credits.

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

1.2 For the Master degree in engineering, physical sciences, business management, or  !

quality assurance from an accredited institution, score one credit. j 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.

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1.4 For the successful completion of Navy Nuclear Training, its equivalent in another  ;

armed service, or the training required for becoming a licensed operator in a commercial nuclear power plant, score two credits.  !

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QUALITY ASSURANCE POLICY 2.0 Experience (9 credits maximum)

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2.1 Technical Experience (5 credits maximum)

For experience in engineering, manufacturing, construction, operation, or maintenance, score one credit for each full year.

l 2.2 Nuclear Experience l

If two years of technical experience have been in the nuclear field, score one additional credit.

l 2.3 Quality Assurance Experience If two or more years of the technical experience have been in quality assurance or

, quality control, score two additional credits. Persons whose work activities are l controlled by the QA Program but who are not full-time members of the QA l organization may be awarded half the credits that would be given to a person with l specific quality assurance experience.

2.4 Audit Experience l If two or more years of the technical experience have been in auditing, score one

! additional credit.

l 2.5 Supplemental Experience Persons who have a proportion of the experience specified in 2.1-2.4 may be awarded a corresponding percentage of the credits specified.

2.6 Time exclusively spent in training does not apply as credit toward experience requirements for lead auditors.

3.0 Training (2 credits maximum)

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

4.0 Rights of Management (2 credits maximum)

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

4.1 For certification of competence in engineering or science related to nuclear power plants, or in quality assurance specialties, issued and approved by a State Agency or l National Professional or Technical Society, score two credits. l 1

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

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 experience.

l l Page 59 of 72

QUALITY ASSURANCE POLICY Revision 424J l Eenson BGE is in agreement with the basic purpose of ANSI N45.2.23-that is, to establish mimmum educational or experience requirements for Lead Auditors. We thmk, however, that the system of credits outlined in ANSI N45.2.23 tends to reduce the size of the pool of potential replacement auditors without making redeeming improvement in the capabilities of persons selected.

1 We calculated the credit score of 11 of our present Lead Auditors at the time they were appointed Lead l Auditors. Six had completed Navy Nuclear Training and spent several years in the Navy Nuclear l

Program. Four of these scored only 8 credits total, including 2 credits allowed by paragraph 2.3.1.4 of  :

ANSI N45.2.23 for rights of management based on their having completed the BGE QA training programs for Lead Auditors.

l One of our auditors, with neither nuclear nor power plant experience, had a credit score of 12 because he i held a Bachelor's degree in engineering and was a professional engineer with over 5 years design l expenence.

1 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 maAates.

l We consider the flaw in the current system to be the emphasis on educational requirements that will allow a person with a Master's degree and no nuclear or power plant experience to become a Lead Auditor, but will I exclude a person who has no degree, even though he may have 20 years' experience in operating or ,

maintaining nuclear or power plant systems. i The practical balance between education and experience will vary with individuals and particular work assigmnents. Any attempt to establish rigid requirements is likely to allow some unsuitable candidates to l meet the qualification requirements while excluding some acceptable candidates. I For these reasons, we think that the supenision of prospective Audit Team Leaders should be given more flexibility in determining whether, for a particular individual, educational or professional qualifications are more significant and valuable than past experience.

The present credit system, while recognizing the Associate degree, gives no credit for completion of the nuclear training programs. We think that someone who has taken Navy Nuclear Training or its equivalent in another armed senice, or someone who has completed the training required to become a licens:xt operator in a commercial nuclear power plant, should receive the same credit as a person who has an Associate degree from an accredited instimtion in engineering, physical sciences, mathematics, or quality assurance.

"Ihe 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.

The requirements for training specified in ANSI N45.2.23, paragraph 2.3.2, would seem to ensure that prospective Lead Auditors will meet the requirements of paragraph 2.3.1.4 dealing with the rights of management. We think, therefore, that all prospective Lead Auditors should qualify for these two credits.

Page 60 of 72 l L _ _ _

I QUALITY ASSURANCE POLICY

\ Revision 4243 Similarly, the present system recognizes the effect that working in a QA Program will have on the ability of a person to comprehend regulatons and technical requirements. Persons who are not assigned as full-time members of the QA Org=i=% 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 experience. I htEll Reauirement i 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 .

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

Response

BGE requalifies Lead Auditors on the basis of the satisfactory performance of one audit, as observed by a qualified Lead Auditor.

Reason The purpose of the training specified in paragraph 2.3.3 of the Standard is to ensure that candidates understand the fundamentals of auditing and the requirements for activities to be audited. The fact that persons have not maintained their proficiency does not mean that they need complete re-training; it means only that they have not been able to review and study the applicable Codes, Standards, Procedures, instructions, and other documents related to QA Programs and program auditing. BGE considers that the satisfactory performance of an audit under the observation and guidance of a qualified Lead Auditor should ensure that persons with lapsed certification will review and understand the pertinent documents.

l i

ANSI N101.4 - 1972 l

Reauirement Section 1.2 specifies applicability requirements for the Standard.

Resoonse BGE requires that only activities performed inside containment structures and related to protective coatings applied to ferritic steels, alundnum, stainless steel, zinc-coated (galvanized) steel, concrete, or masonry

surfaces shall conform to applicable Sections of ANSI N101.4.

Reason Deterioration of protective coatings applied to surfaces outside containment structures would have no

, detrimental effects on the safe operation of the plant.

i t

l l Page 61 of 72

QUALITY ASSURANCE POLICY Revision 424_3 l ANSI N45.2.13 1973 Reauirement 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

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. 'Ihe extent to which the individual requirements of ANSI N45.2.13 are applied to Conunercial 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.

1 i

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l Page 62 of 72 l

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

Entry PRF-Q

__h__. No. Bases for Revision (s)

1. 771 Procedure Unarade Action Plan (PUAP). oer L. B. Russell letter 1-20-89.

2. 783 10 CFR Part 21 reauirements.

3. 797 NRC Inen~ tian #89-16/89-17 (Letter from R. E. Denton to R. P. Heibel dat~3 July 13.1989.)

4. 824 NRC letter from M. W. Hodnes to G. C. Creel dated March 13.1990. This letter ,

i anoroved a one-time exemption to the oeriodic review reauiremente for procedures scheduled to be upgraded by the Procedures Uoarade Proiect. This exemption was discontinued and removed by PRF-O 954.

5. 844 Procurement Program Proiect unarade. Performance Imorovement Plan (PIP)

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

6. 844 IB.15 and IB.16 revised to clearly establish proaram anolicability and controls.

cnnsi= tant terminoloav. organizational responsibilities and focused anornach j towards developina and imolementing an intearated Management System.

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

8. 894 IB.15 and 1B.16 revised to clarify requirements which will ocrmit imolementation of the Issues Mananement System - PIP item 4.10.0.

9. 854/907 G. C. Creel letter to the NRC dated 7/26/91 which discussed modifications to. and acceotance of. channes to the OA Policy involvina OA comoliance reviews of OAPs and Directives.

10. 815 G. C. Creel letter to the NRC dated 10/3/90 discussing temporary channes no.1 affectina "Anoroved Procedure Intent" and the relievina of the Administrative Burden on Shift Suoervisors.

l Page 63 of 72

QUALITY ASSURANCE POLICY Revision 424. 3 l ATTACHMENT A-2 BASES FOR QA POLICY REVISIONS (1)

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

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

12, 954 G. C. Creel letter to the NRC dated 7/3/91 discontinuina the one-time t

I temoorary channe to the oeriodic review interval anoroved in Basis (4) above.

4 i

13, )

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

14, 953 PIP Action Plan 4.1 and NUREG-0737 (TMI Action Plan Reauiremante) l Item I.C.5. " Procedure for Feedback of Oocratina Experience to Plant Staff."

l 15, 990 OAU Surveillance 5-92-28 " Interface Between Facilities Management Deoartment and Nuclear Enerav Division on Proiects at Calvert Cliffs." RecommenAation 4.2.

16. 998 OA Audit Recommendation 92-04-R03 (!SFSI ooerational chase).

j 17. 93-06 NOAD Audit Findina 92-10-01. Facility StaffTrainina.

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

19. 95-02 License Amendment Reauest dated March 15.1995 (Admin Controls Section 6.0 i l

Uoarade and OA Policy Channe) NRC 91075 D:::d F;b 95 'D-dd l

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QUALITY ASSURANCE POLICY l Revision 424]

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i l Page 65 of 72

QUALITY ASSURANCE POLICY Revision 424_3 l ADDENDUM 1B-1 (19)

REVIEW FUNCTIONS OF THE POSR

C. PROCEDURE

REVIEW COMMITTEE. OUALIFIED REVIEWERS. AND OSSRC 1.0 PLANT OPERATIONS AND SAFETY REVIEW COMMITTEE (POSRC) 1.1 FUNCTION The POSRC shall function to advise the Plant General Manager on all matters related to nuclear safety.

1.2 COMPOSITION The POSRC shall be composed of at least seven. but no more than ten. members. including the Chairman. Members shall collectivelv have experience in the followina areas:

&c_1.sgr Operations Electrical and Controls Maintenance Chemistry Mechanical Maintenance Nuclear Engineerina Radiation Safety Plant Engineerina Desian Engineering I

Members shall be anoointed in writina by the Plant General Manager. Members shall have a I minimum of eight years oower olant exocrience of which a minimum of three years shall be nuclear 1 oower experience. At least one member shall have an SRO license on Calvert Cliffs Units 1 and 2.

l 1.3 CHAIRMAN l The Chairman and alternate Chairmen of the POSRC shall be annointed in writina by the Plant General Manager. Chairmen shall have a minimum of 10 year _toower olant ex_gerience of which a minimum of three years shall be nuclear oower exocrience.

1.4 ALTERNATES All attemate members shall be appointed in writing by the Plant General Manager. Alternate members shall have a minimum of eight years oower olant experience of which a minimum of three years shall be nuclear oower exoerience. l l 1.5 MEETING FREOUENCY

! The POSRC shall meet at least once per calendar month and as convened by the POSRC Chairman or one of the designated attemates.

1.6 OUORUM A auorum of the POSRC shall include the Chairman or one of the desianated alternate chairmen and shall consist of a maiority of the members. includina alternates. No more than half of the auorum shall be alternates. includina an alternate chairman.

I

! Pane 66 of 72 l

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I QUALITY ASSURANCE POLICY l l Revision 424J 1.7 RESPONSIBILITIES The POSRC shall be responsible for the followinn except for thma items desionatM for review by the Procedure Review Committee or Oualified Reviewer in accordance with Addaad"m sections 2 l and 3. resocctivelv: I

a. Review of 1) all orocedures reauired by Technical Specification 6.4 and channes thereto.

and 2) any other orooosed orocedures or channes thereto as determined by the Plant '

General Manaaer to affect nuclear safety.

Cross-disciolinary reviews of these oracedures are conducted in accordan.sg with administrative orocedures in addition to the reviews conducted by POSRC. the ProcMure Review Committee. or Oualified Reviewer. i

b. Review of all oroposed tests and exoeriments that affect nuclear safety.

c. Review of all orooosed changes to Aooendix A Technical Soecifications.

d. Review of all orooosed channes or modifications to olant systems or eauioment that affect i nuclear safety.

l

e. Review of the Plant Security Plan and imolementina crocedures and shall submit  !

recommended channes to the Off-Site Safety Review Committee.

I

f. Review of the Emergency Plan and imolementina orocedures and shall submit recommended channes to the Off-Site Safety Review Committee. 1

e. Review of channes to the Process Control Program and the Offsite Dose Calculation Manual.

h. Review of all 10 CFR 50.59 Safety Evaluations that supoort orocMures in 1.7.a and channes or modifications in 1.7.d above.

i. Investi2ation of all violations of the Technical Soccifications includina the orecaration and fgwardinn of reoorts coverina evaluation and recommendations to orevent recurrence to the Plant General Manager. the Vice President - Nuclear Energy and to tle Chairman of I the Off-Site Safety Review Committee. l

i. Review of all Reoortable Events. The results of this review shall be submitted to the OSSRC and the Vice President - Nuclear Enerav.

k. Review of facility operations to detect notential safety hazards.

1. Review of any accidental. unolanned or uncontrolled radioactive release that exceeds 25%

of the limits of Technical Soccification 3.11.1.2. 3.11.2.2 or 3.11.2.3. includina the orecaration of reports coverina evaluation. recommendations and disposition of the corrective action to o_ revent recurrence and for forwarding of these reports to the Plant General Manager and the Off-Site Safety Review Committee.

• POSRC is only reauired to review Fire Protection procedures and channes thereto which afTect nuclear safety.

l l Page 67 of 72

k &-Ma.J<$,- -g + -J' ta- A 6," i L,, - a s a. a-.: a L a. s a

-, 4- w QUALITY ASSURANCE POLICY Revision 424.3 l

m. Performance of special reviews. investiention: or analyses and renorts thereon as raneaetad by the Chairman of the Off-Site Safety Review Committee.

n. Review of Safety Limit Violation Reoorts.

1.8 AUTHORITY The Plant Operations and Safety Review Committee shall:

t l

a. Recommend to the anoroval authority anoroval or disanoroval of oreaderes considered under 1.7.a above.

b. Recciiiiieiwi to the Plant General Mananer aooroval or di=anoroval of items considered under 1.7.b throuah h above.

c. Render determinations in w(an with renard to whether or not each item considered under 1.7.a throuah h above constitutes an unreviewed safety auestion. l J

d. Evaluate root causes and recommended actions to orevent recurrence for items considered l under 1.7.i throuah I above.

l l e. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President - Nuclear Enerav and the Chairman of the Off-Site Safety Review Committee of dienareement between the POSRC l and the resoonsible anoroval authority in the case of item 1.7.a above or between the POSRC and the Plant General Manager: however. the Plant General Manaoar shall have resoonsibility for resolution of such disaareements oursuant to Technical Soccification 6.1.1.

l.9 RECORDS The POSRC shall maintain written minutes of each meetina and cooies shall be orovided to the Vice President - Nuclear Enerav. Chairman of the Off-Site Safety Review Committee. and the Plant General Mananer.

l 2.0 PROCEDURE REVIEW COMMITTEE l

2.1 FUNCTION The Procedure Review Committee may function to review items listed in 1.7.a above in lieu of l review by POSRC or Oualified Reviewer as directed by the Plant General Mananer.

2.2 COMPOSITION The Procedure Review Committee shall be compond of a Chairman and einht individuals who t hall collectively have exocrtise in the areas contained in 1.2 above.

Members shall be anoointed in writina by the Plant General Mananer. Members shall have a minimum of eight years oower plant exoerience of which a minimum of three years shall be nuclear power exoerience. At least one member shall be a POSRC member or alternate. The charter for

, the Procedure Review Committee shall include a descriotion of membership. aualifications.

functions. and reoorts and shall be described in olant administrative orocedures. The Procedure Review Committee may be dissolved at the discretion of the Plant General Mananer.

Page 68 of 72 l l

QUALITY ASSURANCE POLICY 2.3 CHAIRMAN The Chairman and alternate Chairmen of the Procedure Review Committaa = hall be anoointed in writina by the Plant General Manmoer. Chairmen shall have a minimum of einht years nower olant exoerience of which a muumum of three years shall be nuclear oower exoerience.

2.4 ALTERNATES All alternate members shall be anoointed in writina by the Plant General Manager. Alternate members shall have a minimum of eight years power plant exoerience of which a minimum of three years shall be nuclear nower experience.

2.5 MEETING FREOUENCY ne Procedure Review Committeefhall meet at least once oer calendar month and as convened by the Chairman or his desiana_ted alternates.

2.6 OUORUM A auorum for the Procedure Review Committee shall consist of the Chairman or one of the designated alternate Chairmen and three orimarv or alternate members orovided at least four disciolines are reoresented.

17 AUTHORITY The Procedere Review Committee shall:

a. Recommend to the Anoroval Authority aoproval or disanoroval of orocedures considered under 1.7.a above.

b. Render determinations in writing with regard to whether or not each orocedure under 1.7.a above constitutes an unreviewed safety auestion.

c. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President - Nuclear Enerav and the Chairman of the Off-Site Safety Review Committee of disaareements between the Procedure Review Conunittee and the responsible aoproval authority. He Plant General Mananer shall have responsibility for resolution of such disagreements oursuant to Technical Soecification 6.1.1.

2.8 RECORDS The Procedure Review Committee shall maintain written minutes of each meetina and cooies shall be orovided to the Plant General Manager.

3.0 OUALIFIED REVIEWERS 3.1 FUNCTION He Plant General Manaaer may designate soccific orocedures or classes of crocedures described in 1.7 a above to be reviewed by Oualified Reviewers in lieu of review by POSRC or the Procedure Review Committee.

l Eage 69 of 72

QUALITY ASSURANCE POLICY Revision 424_3 \

{

3.2 AUTHORITY l

Oualified Reviewers shall:

a. Recc.iinicad to the aooroval authority approval or di=anoroval of desianatad oracMures and channes considered under 1.7.a above and

b. Render deternunation in writina with renard to whether or not a=ch oracMure under 1.7.a above constitutes an unreviewed safety auestion.

c. Provide written antificatinn within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice Presidant - Nuclaar Enerav and the Chairman of the Off-Site Safety Review Committee of disaisces. cats between the Oualified Reviewer and the anoroval authnrity. The Plant General Mannaar shall have .

responsibility for resolution of'such disaircenicats ouran=at to Techniemi Soccificatian )

6.1.1.

3.3 CERTIFICATION Oualified Reviewers shall be nominated. trained. and certified in accordance with administrative orocedures. Cenification shall be by a deoartment mananer.

3.4 CERTIFICATION REOUIREMENTS Certification reauirements of personnel designated as Oualified Reviewers shall be in accordance with administrative crocedures.

Oualified Reviewers shall have:

a. A Bachelor's dearee in enaineerina. related science. or technical discipline. and two vears of nuclear oower olant exnerience:

M

b. Six years nuclear oower olant experience M

c. Eauivalent combination of education and experience as aooroved by a Deoartment Mananer.

3.5 RECORDS Review of crocedures by Oualified Reviewers shall be documented in accordance with administrative orocedures.

4.0 OFF-SITE SAFETY REVIEW COMMITTEE (OSSRC) 4.1 FUNCTION The Off-Site Safety Review Committee shall function to orovide indcoendent review and audit of designated activities in the areas of:

a. nuclear Dower olant operations Page 70 of 72 l

1 QUALITY ASSURANCE POLICY l Revision @

b. nuclear enameerina

c. chemistry and radiochemistry

d. metallurav and non-destructive examinatina

e. instrun=*=tian and control

f. radiolonical safety

a. mechanical and electrical ennineerina

h. auality assurance oractices i

4.2 COMPOSITION )

The Off-Site Safety Review Committee shall be composed of at least seven members. inclu m ne the Chairman. Members of the Off-Site Safety Review Committee may be from the Nuclear Enerav Division or other BGE oraanization or from organizations external to BGE and shall collectively have expertise in all of the areas of 4.1 above.

4.3 OUALIFICATIONS

%e Chainnan. members and alternate members of the Off-Site Safety Review Committee shall be I anoointed in writina by the Vice President - Nuclear Enerav and shall have an =We denree in enaineerina or a ohysical science. or the couivalent. and in addition shall have a minimum of five years technical experience in one or more areas n_iven in 4.1 above. No more than two alternata shall oarticioate as votina members in Off-Site Safety Review Committee activities at any one li!!E 4.4 CONSULTANTS Consultants shall be utilized as determined by the Off-Site Safety Review Committee Chairman to provide expert advice to the Off-Site Safety Review Conunittee.

4.5 MEETING FREOUENCY The Off-Site Safety Review Committee shall meet at least once per six months.

4.6 OUORUM The auomm of the Off-Site Safety Review Committee necessary for the oerformance of the Off-Site Safety Review Committee review and audit functions shall consist of'more than half the Of_f-Site Safety Review Committee membershio or at least four members. whichever is areater. This i auorum shall include the Chairman or his annointed alternate and the Off-Site Safety Review Committee members. includinn anoointed alternates. meeting the reauirements of 4.3 above. No more than a minority of the auomm shall have line responsibility for operation of the olant.

4.7 SUBCOMMITTEES The Chairman may establish subcommittees to perform reviews of selected items enumerated in 4.8 below. Each subcommittee shall be chartered in writina. have at least three members / alternates. and orovide reports to the full committee on the results ofits reviews with any anorooriate reconw.endations.

l Pane 71 of 72

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i QUALITY ASSURANCE POLICY Revision 424J l 4.8 REVIEW He Off-Site Safety Review Committee shall review:

a. He safety evaluatians for 1) channes to orncMures. ~iniament or svetamm and 2) tats or em-inw.nts completed under the provisinne of 10 CFR 50.59. to verify that such actions did not ena_=_tituta an unreviewed safety au~ tion.

b. Proposed chanaan to orocedures. eauipment or systems which involve an unreviewed safety cua tian as defined in 10 CFR 50.59.

c. Prooosed tests or experiments which involve an unreviewed safety au~ tion as defined in 10 CFR 50.59.

d. Proposed channes in Technical Soecificatians or the Operatina License.

e.' Violation of codes. renulations. orders. Technical Soecifications. licen_ma reauirements. or ofinternal procedures or instructions havina nuclear safety significance.

f. Sinnificant operatina abnormalities or deviations from normal and exaaet~_I oerformanca ofplant eauioment that affect nuclear safety.

n. All Reportable Events.

h. All reconnized indications of an unanticioated deficiency in some asnact of A~ ion or operation of safety related stmetures. systems. or comoonen(L

i. Reoorts and meetinas minutes of the POSRC.

4.9 AUDITS l Audits of facility activities shall be performed under the connizance of the Off-Site Safety Review Committee. These internal audits are discussed in Section fB.18 of the OA Pohev.  :

l 4.10 AUTHORITY l l

l The Off-Site Safety Review Committeg shall report to and advise the Vice President - Nuclear Encrav on those areas of resoonsibility specified in 4.8 and 4.9 above.

4.11 RECORDS l Records of Off-Site Safety Review Committee activities shall be orecared. anoroved and distributed as indicated below:

a. Minutes of each Off Site Safety Review Committee meeting shall be orepared. apatgvgd i

and forwarded to the Vice President - Nuclear Enerav within 14 days followinn each meeting

b. Reports of revie_w; encomoassed by 4.8 above. shall be orecared. aooroved and forwarded to the Vice President - Nuclear Enerav within 14 days followinn completion of the review.

Audit reoorts unwmuassed by 4.9 above. shall be forwarded to the Vice President -

~

c.

Nuclear Enerav and to the management oositions responsible for the areas audited within 30 days after completion of the audit.

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