ML20128M899

Rev 2 to QA Program

ML20128M899
Person / Time
Site:	Fort Calhoun
Issue date:	04/30/1985
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20128M891	List: ML20128M886 ML20128M899
References
NUDOCS 8506030112
Download: ML20128M899 (35)

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APPENDIX A QUALITY ~ ASSURANCE PROGRAM r

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PPENDIX A QUALITY ASSUPAtiCTPROGRAM CONTENTS

-.SECTION i:0.

TITLE-PAGE LA.1

' INTRODUCTION.........................

A-1

'A.2-ORGANIZATION.........................

'A-1

A.2.1 Manager.- Fort Calhoun Station...........

A-2

.A.2.2 Plant Review Committee (PRC)............

A-2 A.2.3' Safety Audit and. Review Conmittee (SARC).....

A-2

'A.2.4

-Manager - Quality Assurance............

A-2 A.2.5-QC' Staff......................

A-4 A.2.6 Division Manager - Material Management.

A-4 A.2.7 Section Manager - Generating Station Engineeri_ng (GSE).................

A-4 nA.2.8 Section Manager - Technical Services........

A-4

.A.3 s

QA PROGRAM..........................

A-4

'A.3.1 Corporate Policy..................

A-4 A.3.P QA!PlaW......................

TA?53 A.3.3

. 0A iProgfaiii Procedures...............

SA-67

~A.3.4 Traiiiing'5nd' Indoctrination............

(A16j-A.4 DESIGN CONTROL.-.....-..................

"A%

.A 5 PROCUREMENT DOCUMENT CONTROL. ;............... If-97) w~

7Alli"wJ A.6, INSTRUCTIONS, PROCEDURES, AND DRAWINGS............

L A. 7.

DOCUMENT CONTROL.......................

PA;12 7 un o

=A.8 CONTROL 0F PURCHASED MATERIAL, EQUIPMENT, AND SERVICES....

eA43 rl -

wm A. 9, IDENTIFICATION.AND CONTROL OF MATERIALS, PARTS AND COMPONENTS. Q143

-A.10 CONTROL.0F SPECIAL PROCESSES.......-..........

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A.11 INSPECTION..........................

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'A.12-TEST CONTROL.........................,

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A.13 CONTROL OF MEASURING AND TEST EQUIPMENT...........

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A.14_

HANDLING, STORAGE, AND SHIPPING,..............

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A.15 INSPECTION, TEST, AND OPERATING STATUS............

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CONTENTS'(Continued)

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TITLE.

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'A.16~

NONCONFORMING MATERIALS, PARTS', OR COMPONENTS......... D5?Q$

A.17 CORRECTIVE ACTION........................

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QUALITY. ASSURANCE. RECORDS....................."n.2,w1m.

NA 24 A.19 AUDITS....-........................ W A224'.)

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A.1 INTRODUCTION This Appendix describes the Omaha Public Power District's (OPPD) Quality Assur-ance Program for the operation of Fort Calhoun Station. The program is based on I

the criteria of Appendix B to 10CFR Part 50, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"; General Design Criterien 3, Appendix A to 10CFR Part 50, " Fire Protection"; Appendix E to 10CFR Part 71,

" Quality Assurance Criteria for Shipping Packages for Radioactive Material;" the l

Tapplicaole guidance provided _in American National Standard,1 ANSI' N18.7+'

'" Administrative Controls,and Quality Assurance for the_0perctions-Phase of 1 Nuclear Power Plantsi and, ANSI N45.2, " Quality Assurance Program Requirements for~Nu61 ear Power Plants,"_and_i.ts. associated daughter standards; and,

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"ResulatoryGuide"-1.120,qReyiston'1," Fire; Protection'G_uidelinesforNuclear, Power: Plants"fandAppendixAtoBranchTechnicaliPosition9.5-l',"Guidelinesfor; mfire Protection for Nuclear Power P,lants." :. Attachment?1 ~ details.the Districts

7spesificicorriitments witti" respect [to the ANSI; N4512 series,'~other' industry QA iistandards,'and~ associated NRC. Regulatory Guides, inclu' ding. clarifications or C alternativesTused;as(a basis for-the_ District's Quality Assurance ~ program and QA _/.

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The program (istapplied to:

Critical Quality Elements (CQE) defined as those i

structures, systems, components, or itens whose satisfactory performance is required to prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public; those fire protection systems and equipment used or installed in areas housing safety-1 related equipment, and other areas where an unsuppressed fire could potentially damage safety-related structures, systems or components, those activities af fecting the components of radioactive material packaging for transport which are significant to safety; Limited Critical Quality Elements (Limited COE) l defined as those structures, systems, components or items whose satisfactory performance is required to prevent or mitigate the failure cf those structures, systems, components or items identified as C0f.

A.2 ORGANIZATION OPPD's organization for carrying out an effective operations phase Ouality Assurance Program is shown in Figure A-1.

The Division Manager - Quality Assurance and Regulatory Affairs is the upper level off-site management position which has direct management responsibility for formulation, implementation, and assessment of the effeCliVeness of the Quality Assurance Program. The Division Manager ; Nuclear' Production is the upper level off-site management position j

which has' direct management responsibility for plant operations and for formu-lation., implementation, and assessment of the effectiveness,of the fire protec-tion p.rogram and the" packaging of radioactive material for transport. The Division Manager - Engineering is the upper level off-site management position which has direct responsibility for designation of those structures, systems, components or itcms classified as CQE-or Limited CQE; and for designation of the tire protection systems, equipment, and zones covered by the fire protection program. The Division Manager - Material Management is the upper level of f-site idanagcment position which has direct management responsibility for formulation and implericntation of District procurement policy.

A-1 "R2 '4/85 l

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A.2.1 Manager - Fort Calhoun Station The Manager - Fort Calhoun StationifiFs} direct responsibility for the safe operation of the nuclear power facility. The Manager - Fort Calhoun Station gre'portOtotheQfilsTon[ Manager {NuyleaRP_roduction.7 A.2.2 Plant Review Committee (PRC)

A committee composed of plant staff members designated as the Plant Review Committee (PRC)[ acts'in an advisory capacity to the Manager - Fort Calhoun Station..The responsibilities and authority of the Plant Review Committee are

' delineated in Section 5.5.1 of Fort Calhoun Station Unit No. 1 Technical Speci-fications,_ Appendix A to Operating 1.icense No. DPR-40.

A.2.3 Safety Audit and Review Committee (SARC)

Another committee composed primarily of off-site, highly qualified and experi-enced District management personnel and consultants, designated as the Safety I

Audit and Review Committee (SARC), {functionf to provide the independent review and audit of activities as designated"in' Sections 5.5.2 and 5.5.3 of Fort Calhoun Station Unit No.1 Technical Specifications, AppendjtA to Operating License No. DPR-40. TheSARCreportstoandadvisestheViceLPresident[on I

reviews and audits of the designated activities.

A.2.4 Manager - Quality Assurance The Manager - Quality Assurance is responsible for the development and imple-

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mentation of the Quality Assurance Program for design,Imodificationi and opera-

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tion. He reports on technical and administrative matters to the Division Manager - Quality Assurance and Regulatory Affairs. This reporting arrangement

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provides isolation of?iisdificationiand operational costs and scheduling in-fluences from activities performed by the Manager - Quality Assurance. lie has the duty and authority to identify quality-related problems; to recommend solu-l

.tions; and to verify the implementation and effectiveness _of corrective action taken. He has authority to "Stop Work" on design,~mainten'ance","~modifidation",7 procurement, fabrication, yn'diinstallation of safety related' structures, 'sys-tens, or components, fire protection systems and equipment, and shipping pack-ages for radioactive material. His principle duties and responsibilities include the following:

(1) Manages the OPPD Quality Assurance Program.

Y (2)'Ma'nagestandcoordinatesanindependentauditandjQAsurveillance

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! program, and Yeview;of OPPD quality activities"to assure compliarice with; and effectiveness of, the Quality Assurance Program.

(3)

Indoctrinati.on of "ap'propflate OPPD personnel in{Nie' Quality Assurance, Program.,a A-2 LR2T(4/8.52

+ f,a (4)- Prepares Quality Assurance procedures, instructions, and reports, including the description, preparation and maintenance of1 0 PPD's

QA(Plilrijand gh}ey OA programpoEpsig

-(5)- Acts as an internal consultant on Quality Assurance related matters.

(6) Maintains liaison'with vendors en quality matters.

(7) Maintains'a file of quality-related codes and standards for the

. operation,' maintenance and modification of nuclear power plants.

~(8) Reviews design data and changes, operating procedures, and test reports for quality requirements.

(9) -Serves as a' member of various comittees including the Safety Audit and Review Committee.

(10) Qualifies OPPD's vendors and suppliers.

The qualification requirements of the Manager - Quality Assurance are:

(1) A college-degree or equivalent [ix5[ishciP. Registration as l~

a professional ^ engineer in the state of Nebraska is desirable.

Advanced degree in management or work in quality related discipline is desirable.

(2) Eight (8) or more years in a supervisory or management position related to the operation, maintenance, testing, and construc-tion of nuclear power plants, including quality assurance.

(3) llorking knowledge and understanding of regulations, standards, and guides relating to nuclear power plant quality. assurance.

(4) Thorough management, administrative and supervisory skills..

(5) A very.high degree of emotional stability, maturity, and personal integrity. Must have a high degree of initiative, and the ability to make sound decisions and defend them to top management.

(6) The ability to work closely and in harmony with others. The ability to coordinate several complex operations simulta-neously.

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_n The Manager - Quality Assurance hastassignedesupervisors;and staff,# assisting him i

in the execution of his duties and responsibilities.

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-The QC. Staff.is responsible for quality control actions as specified in

{sp)lff60ri'Sta tioii?""~114abis~procidures? -The QC Staff reports to the Supervisor -lTe

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' Material Management ETh&I0191s tor (ManagFf5 MitWisEMWsigsmidtT hiQriaGVWespohsi bi l i til f6r;them iformulation and;1mplementation of" District $rocurement7 poli'cy.JImplementatioMy

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I6fithe QA;P,lanirequirementsi for procurementaisi sharedibyithose DistrictxMa'napsrs#

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jperfomt.ng;Nucleat procurementfactivities.aj LA.2.7-Section Manager - Generating Station Engineering

- The' Section Manager - Generating Station Engineering, under the Division Manager - Engineering, has primary responsibility for maintenance of as'-built develop ~ ment and"r]eview of procurement specifications; classification ofdata; l

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safety-related structures, systems and components; and the mcdifications associated with the (f, ire {p,rotectionyystem.J l

.A.2.8 Section Manager - Technical Services The Section Manager - Technical Services, under the Division Manager ( Nu'cl. ear /d l

Production, has primary responsibility for technical support for the nuclear power plant staff, including the areas of nuclear material management, radio-logical and chemical control, plant modifications, and environmental sciences.

l A.3 OA PROGRAlt A.3.1 Corporate Policy

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_ y...w iThe.0maha: Public Power District:(0 PPD),2asithe: owner and operator of To_r.. _ ?

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x Calhoun S ta tion', ? has? es tabl i shed ;aE Di s trict" pol icy to ma intain und / opera ti the 7 I

Tfacili tyiWi thi'du('rega rd "for'publ ic and plan t'sa fet9 'as' pre ~sdibid' byla riou s"*

Tegulatory requirements. Since there is a close correlation between safety and

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plant quality,ithe" control of ualitf[is"aTresponsibilityofleve"rySndiyi.dualf fassciciated'withistatienidesign]i'p~rocurement,~l modification,l maintenance, C _ operation &'*" "

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s urance Program delineates;the establishe 4

~ 7 requirements, andJstimp1_emented andropp11ed toothoseiactivities'as specified 9 3 thereiCIt ':establi's;tesithe 0PPO-Quality Assurance Plan,Jsets' forth the quality'7 P olicies,Tdeffees the requirements ~,Jandispecifies'responsibilitiesTwithin the 7

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!$Distrtet3 o6fsplamenting the program.' Compitance{with the QA1Plantas Mell-as?

f Twith theiStahding/ iflanagement gives!fu11l support. to mahtai.ninglan' effective ^

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Vquality: program.e Comp 1.tance with? applicable requirements;c'f'the.QA Plan are 3" 1

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' 9huAlity? [supanceFand R65ulatoryFAf'fairsthasfovefaldance ProgramTforTFortV khuthorit for;thelimplement'ationfof-the?QualityjAss WCalhse$tationMRevisionsitoithe QAJPlaria"re cappr6ved by(thetVicePresident?

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The{CdDMiijdil[Ckistructures, systems, and components controlled by the QA _.

yliemsfinclude consumables such as gasketi~,~pahking," lubricants',"if limited Prog ~ rain are^ identified in the CQEilijtifoEFort:Cilhodnist'ati6n and dieseT ~

~yMFrator. fuel oil among many other off-the-shelf items. With regard to fire protecti(n, the QA' Program is applicable to the fire pumps, main loop firemain piping, fire walls, penetration fire seals, automatic initiated detector systems, automatic initiated independent fire suppression systems, and all piping, valves, sprinklers, and nozzles associated with automatically, initiated applied to the f. ire p~rotectionTsystemJ to an extent consistent with safety).

water fire protection systems. The pertinent sections of the QA(Planf are Therefore, Sections A'.7, A.9, A!10,"A2.13 and A.14Cof arenotapplicabletto[the}fireprotectionipfograh.]ithi's/pFogramTdescript'idn?

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Changes tol.thM^ Fort Calhoun Station QA Progran description are included in the l

annual opdate of the USAR.

A.3.2 QAPlsh]

l The OPP) QA@lsh] requires that OPPD organizations and 8cmpanies under contract '

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to supply tectinical services or products for the plant comply with the following requirements:

a.

The authority and duties of individuals and groups performing qua-lity assurance functions are clearly established and delineated in writing. They have sufficient authority and organizational freedom to:

(1) identify' quality problems (2) recommend solutions for conditions

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adverse to quality (3) verify irrple,Tentation b.

An individual or group assigned responsibility for auditing that an activity has been correctly performed, is 'notidirectlyLresponsibidJ for

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performing the specific activity.

CopicsL of the QAM~an., are issued in a controlled manner. A!,distributi,on; lis t ismaintainedbyQAshowingrecipientsof~controlledjQA1Plancopfes'. Personnel signify the receipt of their copy of the QA(Plan hy signing and returning a s

receipt acknowledgement to the Manager - Qual'ity' Assurance. Recommended changes to this"plas are solicited and such recommendations are given due consideration by the Mads 6er - Quality Assuranceli6d OPPDTmanigemintij Necessary revisions are prepared, reviewed for adequacy, approved'and issued in a controlled manner.

These revisions are also controlled by means of a receipt acknowledgement.

Revisions are dated and identified with fornal revision numbers as they are

issued, t

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r fiiiidA! Pia (aiihl Ws' to?the'procurementiarid 'tiss[fif Jp~ackaging ~ for the 'tr;ansp'oitfoOf i

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Tradioactive material. ThisJshallLinclude" receptacles, wrappers,and th.eir li' Tcontents excluding fissile material and'other radioactive. material,Lbut includ h

'ing absorbent' materia'1, spacing; structures, thermal; insulation; ra.diatio~nE" 7i '

Tshielding, devices for cooling and for absorbing mechanical _ shock, external ' 1 0 fittings,;neutronimodeFato'rs,;nonfissile neutron absorbers, and other. supple 2

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l imentarysequipment;which?has safety significance. (TheiQu'ality'.Assbrance P.la % q

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c nrequires thatL the : packageidesign kf.abric, ation,j assembly',< testing, maintenance Q modification, and repairJconform' to thefapprov_ed; design of. each Lindividual/1 a #

[$packageandithat,thehandling,fstoring,clea_ning',; inspecting,a firidi 7 pshippingLmeet the requirements,0f210CFR:Part~71:and; Department ofsTransp rtation 7 z

n Regulationsi

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%y "d i s pu teslith i'ch ~ ca n no t" be i ~e' solved " tit $s a ti5 f ac t i on %ihe Minig/Tr1 - Y r

. -Quality Assu~rance shall be brought before' the?! ice President via' the r<ivision E

f" Manager 4 Quality Assurance and Regulatory' Affairs. 'The Vice President 7would then y

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be. responsible;f.or resolvinggthe dispute after considering all-~ aspects of thei 4

?cissue. m QA PeogFamlProcedures l

A.3.3 DTh'e QA Plan lEc'quireEthat the various QA progran proceduresIbE derived from tapproved QA policies by means of a review of these procedures, bath prior to issu'ance and during audits of the activity prescribed by the procedure.

Pro-tedure reviewstare_' accomplished in accordance with established 'rocedures.

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A. 3. <1 Training and Indoctrination 1

Personnel responsible for performing 'activitieiIaffecting qti5lity are instructed as to the purpose, scope, and implementation of theLQA Planfand QA Program?

manuals, instructions, and procedures by participation in training programs and on-the-job training.

The QA fPllr[ require @that personnel performing actiittie[8affectingluality 0 l

possess documented evidence that they are trained and qpalified in the prin-ciples and techniques of the activity being performed. Procedures provide for training and qualification in the principles and techniques of the activity being performed, including:

(1) Nondestructive evaluation (NDE) perso.inel administration (2) Auditor training and qualification (3)

Indoctrination and Iraining of quailty assurance personnel l

3stablished;oroce'dures)specifythetrainingandqualificationrequirements.

l The QA ouditing and~ surveillance programs provide assurance that the personnel are trained in the activity.

l The scope, the objective, and the method of implementing the various indoctrin-ation and training programs are prescribed in writing and records are main-tained to verify the progress and success of the programs.

This documentation I

is audited and the programs receive periodic reviews within the applicable divisions to verify their adequacy,

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The indoctrination and training programs assure that the proficiency of 'per-sonnel performingJct'isitiEF affectingMuality is maintained by specifying retraining, re-examining, Tadd/or recertifying ^in accordance with the specified requirements. The indoctrination and training programs provide for documenting the training sessions, describing the content, the date held, the attendees, and the results of any examinations conducted.

A.4 DESIGN CONTROL The OPPD quality Assurance [PlsrQprovides for several levels of design control OPPD desijri1 activities meet applicable'QA' Plan! requirements

. for modification.

f foractivities(alffecting;qualityl QA audits assure that OPPD's"d' sign control e

measures provide 3 clear definition of design interfaces, review and approval of designs *, including changes or revisions, and that those performing design-review activities are independent of those originating the design. The verification of engineeringanddesignadequacyofthecontractors'designdocumentsii{per-formed in accordance with[alDistriEtfapproved Quality Assurance program and procedures.

' FR5qiiinseMEfor_0 PPD. design development and review are contained within the QA YPlan.= AdministratiVelinstructions'for initiating 7 controlling'and ~documbnting T mbd i f_i da _t_i o. n_- o f ' s _t a ti_on_iequipmenti and lfaciliti_es-is~proVided.

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The Manager - Fort Calhoun Station is responsible for reviewing and approving designs prior toEthe M implementation at Fort Calhoun Station.

Utilization of the Plant Review Conimittee is governed by the station Operating Manual and p,lant standingfdrders for their review function.

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if an unreviewed safety question is involved, the design is further reviewed by the Safety Audit and Peview Committee as specified in the SARC Charter prior to

. submittal to the NRC for approval.

Procedures require an independent review of design documents f or CQE' LiAnited CQE s

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g designs. Procedures assure that design characteristice can be controlled, inspected, and tested.

independent design review and verification activities are required by the QAJPlak to be performed iriTc'coid5nce Nithiappioved pro-d WeduFeV by appropriatelfqualified engineers"fo/eniiiieeririg calculations,

^ specifications, and design drawings for items within'thefqA Program. boundary _.y dhe.:QAPljnfank,establishedproceduresrequire,ethataselecteddocumentshe i

reviewed to determine that they contain, as appropriate:

a.

Applicable design bases, technical requirements, regulatory requirements, component 'and material identification, drawings specifications, codes and industry standards, tests and inspection requirements, and special process instructions for such activities as fabrication, cleaning, erection, packaging, handling, shipping, storage, and inspection; l

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Requirements that identify the documentation to be prepared, maintained, submitted, and made availcble to the purchaser for review and comment, such as drawings, specifications, procedures, inspection and test records, personnel and precedure qualifications, and chemical and physical test results on mater ils; c.

Requirements for the retention, control, and mainteaance of docu-

. ments and records]f6rjactijities]affsct]n{quAlit{'j

[Tiie$IQ[$An3M^5 valuation of the elements of thd~ design with respect to established procedures requireitha't5 design adequacy he verified tiy systematic

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nents for design, safety, function, and quality. Verification may be accomp-lished by performing design reviews, by the use of alternate or simplified calculational methods, or by conducting a suitable test program. The verifying process shall be performed by individuals or groups other than those who per-

-formed the original-design.

Detailed design or design changes involving Critical Quality Elements (CQE's) that are performed by Generating Station Engineering (GSE) are performed in accordance with the GSE Procedures Manual. GSE Procedures require technical calculations and safety analyses be provided by the design engineer and describe how safety analyses and technical calculations are processed.

GSE Procedures provide design controls for compatibility of materials and accessibility for inservice inspection, maintenance, and repair.

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s fiatorials, parts,equipmentandprocessesessentialto!CQE/ Limited.CQE4thefire protection?p.rogram, and packaging for shipment of radioactive material are.

required to be selected and reviewed for suitability of application. The methods of assurance of suitability are required to include independent design verification by individuals or groups competent in the applicable field of design and related nuclear power plant requirements.

The methods of selection and review are required to provide for (as applicable):

reactor physics, stress, thermal, hydraulic and accident analyses; compatibility of materials; as low as practicable radiation levels; accessibility for in-service inspection, maintenance and repair; test requirements and delineation of acceptance criteria for inspections and tests.

$5i[QAIPfid/reisiIrei3 hate [ measures be established to assure that applicable

f f reiprotectionfprogr aml guidelines "aridfr;equirementi are included in design and i

procurenent documents prepared by their" personnel and that deviations therefrom are controlled.

Field changes and design deviations 'shallibe subject to the l

same level of controls, reviews, and approvals that weFeipplicable to the asappropriatefireprotectioncodesa'nd'} standards.

original document. Quality standards !are specified in the design documents such l

Deviations or changes from these standardsiaretindividually approved. New designs and plant modifications, including fire p'rotection systems, areireviewed by qualified personnel to assure inclusion of appropriate fire protection requirements.

These reviews include items such as:

a.

Reviews to verify adequacy of wiring isolation b.

Reviews to verify appropriate requirements for room isolation c.

Reviews to verify appropriate material is used W 8 ' ".

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~0esigncontrolmeasuresforpackagingfortransportofradioactivemateriallhq~

l applied to items such as: criticality physics, radiatinn shielding, stress,~

-thermal, hydraulic, and accident analyses; compatibility of materials; features to facilitate decontamination; and delineation of Occeptance criteria for inspections and tests. Design changes, including field changes, for packaging Fareisubject to design control measures commensurate with those applied to the

'orihinaldesign. Changes in the conditions specified in the package approval require Commission approval.

Materials, parts, and equipment for CQE/LiinifeFCQE structures, systems, and I

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components are procured in accordance with s tablished procedures regardless of~

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commercial or previous approval status. Procedures require an engineering and quality review of procurement documents for CQE and limited CQE items.

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ProceduresrequirethatCQE/l515ddiCQE3designchangesiaffecting:theadesigng.

Ybssislbe processed through the design engineer and that an independent reviewer 7dfiews the changes. The processtis documented and retainedTas7recoHs N

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The OPPD QAiPlid requires that OPPD's manufacturers' and contractors' design activities nieet' applicable pegulatory requirements for 46al'ity}related activi-ties. The OPPD QA Plin> requires verification that applicdble regulatory re-quirements.have been incorporated.in activities affecting quality design review, audit, and surveillance of manufacturers and contractors. This 'assurest that design input (applicable regulatory requirements and design bases'as"specified in the license application for safety related structures, systems, and com-ponents), for Fort Calhoun Station Unit No.1 are correctly translated into design ; output ' documents (specifications, drawings, procedures, and instruc-tions). QA audits assure that OPPD's manufacturers' or contractors' design control measures provide a clear definition of design interfaces, review and approval of initial design, including changes or revisions, and that those performing design review activities are independent of those originating the design.

The design activities of contractors for safety-related structures, systems, or components are required to comply with the:Distri'cC6pprovedjdesign deve'lopment and control requirements. The design activities'~of manufacturers of packaging for transport of radioactive material are required to comply with the applicable L

regulatory requirements and the approved package design, as specified in the license.

A.5 PROCUREMENT DOCUMENT CONTROL

_ Appropriate requirements have been established by the OPPD Quality Assurance

" Plan /to assure that procurement documentation is controlled and accurately i

Eefl'ects applicable regulatory requirements, design bases, and other appro-priate requirements, such as industry codes and standards. Procurement docu-ments and specifications require that bidders or suppliers submit for review by OPPD written quality assurance programs consistent with the importance and conplexity of the materials, equipment,,or service procured.

Suchvendorsy qualityassuranceprograms"are.requiredto]beconsistentwithpertinent'pr'o-visions of Appendix B to 10CFR,'Part 50, or Appendix E to 10CFR Part 71, as appropriate. OPPD satisfies these requirements as follows:

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'(1) Review of procurement doctuaentation for CQE and limited CQE r

, listed materials, equipment, and services its? performed in

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accordance with established procedures which require OPPD engineering and QA personnel to review CQE and limited CQE procurement documents and document their review.

(2) Procurement. documents for fire protection and radioactivq material packaging materials equjpment,andservicesiaFe3 Trevidsd7 piirovsd"an'd Mocume,ntediby qualified personnel (td 9verifylthsj adequacy' of' fire' protection and quality requirenie]nts.

This reviewths'sures?that fire protection requirements and quality requirements'are"c d rectly stated, inspectable and' controllable; that there are adequate acceptance and rejection criteria; and that the procurement document has been properly prepared, reviewed, and approved.

(3)'Procurementdocuments75@reviewedtoassurethattheitem l

is materially compatible with the environment in which it will be used and that applicable documentation is specified.

(4) Planned, periodic,anddocumentedauditsikrie?performedby l

responsible OPPD personnel to provide asstiFince that the pro-curement activities of OPPD are being carried out in accordance with approved procedures.

l TTfid[QAlfliEi~ rid {establishedproceduresrequirethatqualitydatabeincluded Tri"br'apifedded to the nrocurement' documents or engineering data attachments,

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as appropriate. The celity data prescribes as necessary:

-(1) -Quality requirements including use of procedures or instruct. ions

.(2) Requirements for a [upplier juality [ rogram and documentation l

-(3). Requirements for documentary evidence of quality to be furnished by the,s'upplier (e.g., test results, certification l

that specific requirements have been met, or traceability to the source)

(4) Access gequirements for QA surveillance, inspection, and audits atthegupplier'sworksite TheOPPDQA]I{n7requiresthatmodificationstoap'urchasedrderordocuments forming a part of the order (are/ prepared, reviewed, and approved as for new jrocurementdocuments.

The procurement process for spares and replacement parts for Fort Calhoun Station, as required by the OPPD QA:Plin7and further delineated in ' established) procedures, is~more controlled than the~6riginal procurement process. 'Th'e" ~

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. procurement process for FC1 occurred from 1967 to 1970; the 10CFR, Part 50, Appendix B, QA requirements were not invoked until 1971.

(AK (R2]4/85[

W lA.6 INSTRUCTI'ONS', PROCEDURES, AND DRAWINGS Appropriate ' requirements have been established 'in the OPPD Quality Assurance T'PlaiMto assure that tactisit1Fs'iffdctingsuilijfjare prescribed by documented withsuchdocuments,ared.areapprovedonlyWhen'aEe]ptancecriteriaaremet.iiisduc The responsibility for the development of the instructions, procedures, or drawings-is delegated to.the organization responsible for the activity; however, the developed instructions,' procedures, and drawings are subject to OPPD QA audit. The Quality Assurance!PJir6contains the specific requirements pertaining I

to the instructions, procedures, and drawings associated with activities l

affectingiqual.ity{V

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,TheEQAiPlanj requires,gthat approved changes 1De; promptly included where applicable I

Sinto instructions, procedures, and drawings associated with the Shange. The OPPD QA5P_Isn'Jrequires that changesibi reviewed for their effect ~on present i

instructibris; procedures, and/or drawings.

TheOPPDQA(Pian;#operationforfabrication, processing, assembly,inspectionand requires that procedures include a description of the sequence l

of activities"or test. -Instructions indicate the operations or processes to be performed, type l

of characteristics to be measured or observed, the methods of examination, the applicable acceptance criteria and documentation requirements. The QA(Plaii requires establishment of those inspections, tests, and holdpoints at whicti} a time conformance of parts, components, and subsystems to requirements will be veri-fied.

l The QA Department reviews such documentation to assure that it adequately

. reflects applicable quality requirements.

In reviewiny activities, the QA l

Ocpartment reviewer assnres that instructions, procedures, and drawings contain appropriate quantitative (such as dimensions, tolerances, and samples) accep-

. tance criteria for determining that important activities have been satisfac-torily accomplished.

Inspections,, tests, administrative controls, fire drills, and training that govern the fire %rotection pjrogram"arejprescribed by 'the QA" Plan"and establishedm instructions, procedures, oi drawings andr is] accomplished Tn iccordarice with^

• a these documents.

Instructions and procedures'for design, installation in-spection, test, maintenance, modification and administrative controlsVa,fd]

l reviewed in accordance with the established procedures to assure the proper inclusion of fire protection requirements.

[Allff IR2 N'985]

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A.7 DOCUMENT CONTROL

!YhEOPPD QA'.PlaFrsqiiiresTthat documents, including changes, arc reviewed for l

"adequscy^and"a'pproved for" release by authorized personnel. These requirements

'"ils& provide that contractors include, in their internal programs, measures to l

9 asstire that changes to documents wilI he reviewed and approved by the same

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organization that performed the original review and approval.

The OPPD QAEPla'n';j l

A requires that changes to documents that have been reviewed and approved by OPPD organizations be reviewed and approved by the same OPPD organizations that performed the original review and appioval. These requirements also provide that the documents are distributed to and used at the location where the pre-scribed activity is performed. The scope of these requirements apply to 0 PPD as well as.to contractors and subcontractors.

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,,_ lan:requiresia _documenticontrol system that utilizes numbering of l

o documents requiring control, predetermined distribution lists, and review and approval procedures. Controlled documents associated with Fort Calhoun Station l

have been controlled by document change transmittal letters ins.tructing the recipient to remove and destroy obsolete or superseded pages. EThefQA Plariq l

requires:

(1) maintenance of distribution lists l

(2) use of receipt acknowledgements which indicate that superseded pages/ documents are destroyed or raarked as superseded The Quality Assurance (Nardrequires that design engineering and procurement l

documentation, except for fire protection equipment, which consists of specifi-cations, drawings, USAR material, instruction, procedures, reports, and changes thereto, and manufacturing and construction documents and records required for traceability, evidence of quality, and substantiation of the as-built configu-ration, be controlled.

Instructions, proccdures, specifications, drawings, and procurement documents are controlled in accordance with the QA!Planjand established division / depart-l ment procedures.

s A '" Table of Contents" or 'Index" system is used by OPPD departments to identify the current revision number of instructions, procedures, and procurement docu-ments. The controlled copies are distributed to predetermined, responsible personnel, and a distribution list is maintained. Superseded documents 'are returned to the originator or destroyed as directed in the transmittal letter.

The QA$lan3n{esiatiiihelpfoce'dureQidentiff thoca individuals or groups responsible for reviewing, approving, and issuing documents and revisions thereto.

Call 27 R2E4/85[

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L A.8 CONTROL 0F PURCHASED MATERIAL, E0UIPMENT, AND SERVICES Measures utilized by OPPD to control purchased material, equipment, and services for an operating plant consist of individualTand!conmittee reviews,

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audits, and inspections.

These measures are described in'the OPPD Quality Assurance (Plagand the established procurement procedures.

l Potential manufacturers or contractors who are to be considered by OPPD or its l

prime contractors for the supply of items will normally be evaluated in advance i

of their use as a -District vendor. OPPD's evaluation of potential vendors is performed by QA in accordance with established procedures. The evaluation in-volves the review of available historical data on manufacturers' or contrac-tors' performance and capability; review of their quality assurance programs; or results of previous shop surveys and audits. Quality assurance program idadmintQarerequiredtobesubmittedwithbidsforCQElisteditems The l

riaiiufacturer or contractor selected to supply the material, equipment, or f

servicesiis} approved by the Manager - QA or designated QA Department personnel.

l If required', a pre-award survey at the supplier's facilitylis conducted before I

award'of contract.

Documented, objective evidence such as certifications, chemical and physical analyses, inspection reports, test results, personnel and process qualification results, code stampings and nondestructive test reports are required to be evaluated by OPPD and suppliers or contractors. This verification will assure conformance to design requirements, drawings, specifications, codes, standards, regulatory requirements and other applicable criteria. These documents become a part of the quality verification records to be retained as a QA record in accordance with Section A.18.

Source inspection, when deemed necessary, is required by the applicable procure-ment document. The purchasing organization shall require that holdpoints be determined as necessary for this activity. Manufacturers are required to give sufficient notice of approaching h91dpoints to allow scheduling of personnel.

Both in-process and final source inspections cover review of the quality verifi-cation documentation. An inspection document is used to establish the~inspec-tion sequence and for recording inspection results.

This document also becomes part of the quality verification records. Provision is made for reporting deviations and nonconformances, if any; for recommending disposition and corrective action; for reinspection, if required; and for release for shipment, if appropriate. OPPD or its contractor may elect to participate in selected source inspections.

I The OPPD QA PlanTrcquires that manufacturers or contractors provide the quality l

verification'd6cumentation at the plant prior to the scheduled time of installa-1 tion or use'of the subject material and equipment. Audits will assure that the jontractor is implementing a records management system. Use of delivered domponentswillnotoccuruntilidocumente(waiveg receipt of objective evidence of the quality verification package,Isidioutia l

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Poceivinginspectionofpoichasedproducts(is*accomplishedinaccordance l

with established procedures. These procedures require that shipments delivered to the station be checked for shipping damage, agreem%t of actual count with the purchase order and packing slip, and agreement of the individual item identification with the purchase order and packing slip.

Procedures require that receiving inspection 1recordsibe prepared by the CA Department for each purchase order reouiring ~ delivery of material to the station. Receiving inspection records' include a copy of the purchase order

'or Requisition on Purchasing, material inspection records; and a document retention checklist.

Special instructions may be ' included for complex inspec-tion requirements and tests to be performed at the plant or the supplier's work site as determined from the purchase order. Drawings and/or specifica-tion documents are included as appropriate. The inspector (s) perform (s) the receiving inspection in accordance with the above instructions and/or speci-fications.

The QA[ Plan' requires that inspection records or certificates of conformance l

attestin'g to the quality of materials and equipment be submitted to the Dis-trict for pernanent retention. Such records'ar$ available for review during audits and~arelforwarded prior to or concurrent with material or equipment shipments tii which they are related. In addition, prior to acceptance of material, the QA Department 11sinotified to verify that necessary documenta-tion has been received.

Products intended for use as CQE/ Limited CQE are inspected upon receipt in l

accordance with established procedures, which require a " rejected material" tag to be affixed to rejected material, and the material segregated in the receiving area to prevent inadvertent use. Accepted material is identified, and there are records traceable to the material indicating acceptance.

l A.9 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS Appropriate requirements have been established by the OPPD Quality Assurance

" Plan to assure accurate identificationitraceabilitj'and control of materials, l

parts, and components so that the use of iricorrect 'or defective material, parts, or components is prevented.

Material received at the storeroom for use as CQE/ Limited CQE or as packaging for radioactive material for transport are identified to prevent the u:n o.

incorrect or defective naterial. The identification of the item is mai h ined by an appropriate code, letter, or number so that the identity of the Cn -ial is maintair.ed.

Items shipped to the plant are normally identified by naiJplate or other identification marking on the item.

In those instances when it is not practical to provide identification markings on the individual items, identi-fication information {is' provided in shipping paperwork that is transmitted with l

each shipnent.

I (A-14' R2R4/85:

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'The traceability of. materials is assured through the use of established proce-dures. The receiving inspectionTrehord( contain the documentation needed for l

the traceability of the item. Those documents which are not included are referenced as to their location. The method of identification to be applied to L

. purchased materials is specified as part of the purchase dccument. Codes and standards _ referenced in the purchase document have incorporated the appropriate marking method, such that the fit, function, or c uality of the item is not affected.. The correct identification of materials is verified and documented prior-to release.

-Contractors are required to utilize procedures which establish and document a system or method of identifying the material (e.g., physical marking, tagging, labeling,colorcode). This system clearly indicateDwhether materials are i

acceptable or unacceptable for further use, as requiFed by the quality program.

Material traceability is provided as specifically required by applicable codes; otherwise, material identification, either on the iten or on records traceable totheitem,I[a're]used,asappropriate. Where identification marking of an item l

is enployed, the marking will be clear, understandable, and legible, and applied in such a manner as not to affect the function of the item.

The identification and control measures provide for relating the item of production (batch, lot, components, part) at any stage, from materials receipt through fabrication, shipment, and installation to an applicable drawing, specification, or other I

technical document.

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OPPD requires its suppliers to establish and implement a program for inspect-ing, marking, identifying and documenting material prior to use or storage.

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This program must be documented. Holdpoints are required where inspections must i

.be made and certified complete before start of the next operation.

Inspection

'of materials include the following:

(1) Verification that identification and markings are in accordance with applicable codes, standards, specifications, drawings, and purchase orders.

.(2) Visual examination of materials and components for physical damage or contamination.

(3) Examination.of quality verification record; to assure that the material received was manufactured, tested and inspected prior to shipment in accordance with applicable requirements.

(4) Actual inspection, as required, of workmanship, configuration L

and other characteristics.

These' irispections fee documented and controlled. OPPD performs surveillance l

of verdor facilities'}as necessary to assure implementation of the program.

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OPPD requires that centractors establish specific measures to assure compliance with aparoved procedures for identification and control of materials, parts, and components, including. coatings and partially fabricated assemblies. OPPD pegiesjconformancebyoneormoreofthefollowingmethods:

-l (1) Qridjprocedures.

Review and approval of contractors' quality assurance programs (2) Surveillance of selected manufacturing, fabrication, construc-tion and installation activities by quality assurance personnel.

(3) Auditing:

~(a) of contractors for satisfactory performance of committed quality actions; and (b) _ of-District activities for adherence to quality requirements.

A.10-CONTROL OF SPECIAL PROCESSES

' g m._.., requires that written procedures and controls be prepared to, assure l

wTheiQAfl_anf

.that_special processes, including welding, heat treating, special coating applications, and nondestructive testing are_ accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements. These procedures l

describe,the operations to be performed, the sequence of operations, the characteristics--involved (e.g., flow temperature, fitup, finish, hardness, and dimensions), the limits of these characteristics, process controls, measuring and testing equipment to be utilized, and documentation requirements.

~ Examination, tests,andinspections{aM}conductedtoverifyconformancetothe l

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specified requirements.

Written procedures are required to cover training; examination, qualification, certification, and verification of personnel _as well as the maintenance of required personnel records.

Compliance with these procedures is required for plant maintenance personnel, contractors, ar d vendors. Procedures for control of special processes are

. subject to review arsd approval by 0 PPD on an individual basis.

OPPD assures conformance with these requirements by:

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(1) Reviewofproceduresbythe}plantQCpersonnelIoffQADepart-ment [piVfsbnriel' for inclusion of special processes requiring controlfdefihition of requirements for training, qualification and certification; conformance to applicable codes, standards, drawings, specifications, or other criteria.

(2) Audits to verify the adequacy of selected plant and vendor shop activities and the effectiveness of the special process proce-dures being implemented.

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t A.11 INSPECTION I

OPPD will establish with its personnel and contractors a division of responsi-f

bility which will determine the services, structures, systems, components, and t

materials for~ which each is responsible. The organization having the responsi-bility for maintenance or' repair of such itemslis alsntr6sponsibis'to assure l

that adequate inspection is accomplished. OPPD QA, hcWessr W etains the responsibilit/ and authority for review, approval, and surveillance or audit of the. inspection procedures utilized by plant personnel or contractors.

l OPPD QA or QC personnel [afe] responsible for the inspection of work performrd l

by OPPD maintenance personnel on nuclear safety related structures, systems, or components, and on radioactive material packaging.

Fort Calhoun Quality Control personnel or other personnel who are independent of the individuals performing the activity.being inspected and who are qualifled in the design and installa-tion requirements for fire protection will inspect activities affecting fire protection to verify conformance with documented installation drawings and test procedures for accomplishing the activities.

The review and approval of a contractor's inspection program and procedures kii) accomplished as an integral part of OPPD's review of the organization's Ouality Assurance / Quality Control programs. The QA Department (ussslthe following criteria in evaluating inspection methods proposed by plant QC personnel or organizations under contract to OPPD:

(1) Inspection procedures for functional groups-such as procure-ment, project engineering, construction, and shop inspectors, must be described including measures to identify inspection and test status.

(2) Duties and responsibilities. of personnel performing quality activities must be clearly established.

(3) Qualifications of personnel performing quality activities must be commensurate with their duties and responsibilities.

(4) Documentation methods for inspection activities of each group must -be established (e.g... inspection forms, reports).

(5) ' Documentation centrol systems for identification and distri-buting inspection documents must be defined.

(6): Review and aporoval procedures for inspection documentation must be provided.

(7) Surveillance methods must be established to assure proper imple-mentation of inspection procedures.

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-(8) Planning of inspection sequence activities by plant main'tenance

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personnel or the contractors includes the type of characteristics l

to be measured, the methods of examination, and the criteria.

OPPD will approve inspection holdpoints in the sequence.

The'_ Manager-FortCalhounStationfssse3thattheperiodicinspectionsmade l

by his staff members. include:

~

(1) Periodic inspections of fire protection systems, breathing

-equipment, emergency lighting, and communication equipment to assure the acceptable conditions of these items.

.(2) Periodic inspections of ma'terials subject to degradation such as fire stops, seals, and fire retardant coatings to assure that such items have not been damaged or deteriorated.

Inspectionplanningds l

specifications, codes] utilized to-assure conformance to procedures, drawings,

, standards, and other documented instructions.

Inspec-tions keynot t be performed by those individuals who performed the activity

- being ispecte'd. Sufficient inspections!sFe7 conducted to verify co'nformance

.particularly.in: areas rendered inaccessibib'by further processing. Process

-monitoring may be utilized in lieu of inspection in those cases where inspectinn

~is impossible, disadvantageous, or destructive. When required for adequate co'ntrol, a combination of inspection and process monitoringQslemployed.

Holdpoints' verify (by review of' inspection reports, visits to supplier shops, and plant' surveillance) that inspections are being performed and documented by personnel'in conformance with approved procedures.

Theprovisions.whichassureinspection{idrawin'gs and specifications are covered l-in established procedures.

Modifications are inspected in accordance with established procedures.

A' plan l

for inspection'and monitoring is developed and incorporated in planning doc'u-ments of work segments, including designation of mandatory holdpoints. The inspection and monitoring plan is designed to verify conformance of work and products with the planning-documents applicable design' documents, and specific l

! quality standards and requifements. The plan provides for inspection and monitoring during critical stages in the progression of work and for inspec-tion at the conclusion of each work segment.

Repairs and replacements are inspected in process or during receiving'inspec-tion in accc Hance with established procedures. Holdpoints for inspection or witnessing are specified under the QA or QC ;r,equirements section of the maintenance order.

J0 PPD inspectors lare qualified =and maintain their qualification by participation fin the. training and indoctrination delineated in Section A.3.4.

OPPD QA,-QC,

'and maintenance personnel performing nondestructive examination are trained and qualified in accordance with established procedures. Consultant and

.inntractor inspectors' performing inspection duties for 0 PPD are required to l'

$rovide~ documentary evidence that they are qualified and that the certifica-tions are current.

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A.12 TEST CONTROL The OPPD Quality Assurance @lin]~ requires that plant personnel, contractors, and l

suppliers designate appropriate tests to be performed at specific stages of manufacturing, fabrication, construction, and operation. ConductoftestsIAfe]

governed by written procedures which incorporate requirements and acceptance limits to assure that the structures, systems, and components tested will per-form satisfactorily in service. Tests are conducted in accordance with these proceduresandfaFejproperlydocumented. Written test procedures for radioactive material packagirig incorporate the requirements and acceptance limits contained in the package approval.

OPPDIisEisithatnecessarytestsareconductedbycontractorsperformingmain-tenalice W repair service for an operating plant. Such testing li%perforraed in accordance with quality assurance and engineering test limits contained in applicable design documents. Test requirements and acceptance criteria are providedbytheorganizationresponsibleforthespecification,of.irequired l

the item under test, unless otherwise designated. The entire test programicovers testing including, as appropriate, performance testing of productio'n equipment, calibration testing of instruments, hydrostatic testing of pressure boundary components and surveillance testing.

Measures are established which assure that modifications, repairs, and replace-

'ments are tested in accordance with the original design and testing require-ments or acceptance alternatives. Documentation of tests conducted is included in the completed design package, with the completed maintenance order by special procedure, or included in the receiving inspection packet.

Following tredification, repair 7 or replacement, sufficient testingT;islperformed l

to demonstrate that fire protection systems, emergency lighting and"communica-tion equipment will perform satisfactorily in service and that design cr,iteria are met. Written test procedures for installation tests?aleTprepared by the responsible engineering group and incorporate the requirenients and acceptance limits contained in applicable design documents.

Testproceduresareevaluatedforthefollowingcriteriaandinclude$themwhere l

applicable:

(1) Requirements that prerequisites for the test have been met.

Test prerequisites may include, but are not limited to, the following:

(a) calibrated instrumentation (b) adequate and appropriate equipment (c) trained, qualified and, as appropriate, licensed or certified personnel (d) preparation, condition, and completeness of item to be tested

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p (e) suitable and,.if required, controlled environmental conditions (f).mandatoryinspectionholdpoints,whereapplicable,f;or witness by OPPD, contractor, or authorized inspector (g) provisions for~ data collection and storage l(h) acceptence and rejection criteria (i) methods of documenting or recording test data results

(2) Designation of specific test methods to adequately assess appropriate parameters.

-(3) Designation of measuring and test equipment to be used.

(4) Specific environmental considerations.

(5) Measures to prevent damage to the item or system under test.

(6) Safety considerations.

(7) Documentation requirements.

Test results E e] evaluated to verify as applicable:

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(1) Proper functioning of the system, structure, or component.

(2) Conformance to design specifications.

-(3) Compliance with stated test requirements.

(4) That test results are within allowable limits.

(5) That recording and documentation is complete and accurate.

Audits by OPPD QA,~ vendor surveillance, and witness' of specific tests serve l

to. assure the functional adequacy of, and verify compliance with, the testing program.

A.13 CONTROL OF MEASURIllG AND TEST EQUIPitENT_

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Assurance 75AMrequires' that organizations performing acti-The:0 PPD 0uali,ty,jualityllinvolving measuring and test equipment have written vities'iffigting procedu?e5"tohoverntheseactions.!The2QAPlkn?reauiresthatthestandards used fontcalibration and accuracy verifiEati6n ~of measuring and test equipment be traceable to the U. S. Bureau of Standards or other appropriate sources.

In

~ addition, only properly calibrated measuring and test equipment jsiused. A calibration g' ograsFis[ established to which the tools, instruments', gauges, and other devices shill Tonform. Records of calibrations [WeTmaintained and the calibration equipment appropriately marked to indicate"thi date and acceptance

- of the calibration. Calibration activities being performed by 0 PPD personnel Q20]

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f" are in accordance with Standing Orders.

If a standards-error exceeds the

-guaranteed ' accuracy, then the standard 'isireplaced. Calibration standards, when l

not limited by the " state-of-the-art," hM e an uncertainty (error) requirement of.no more than 1/10th of the uncertainty of the equipment being calibrated.

When ~ inspection and. testing equipment is found to be out of calibration due to use or damage, or when cut of limits at recalibration, items inspected, tested, or measured with that equipment since the latest valid calibration"afs, con-

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sidered as being potentially unacceptable. Resolutionofthesecasisijs]

determined on a case basis by treating them as a nonconformance.

A.14 HANDLING, STORAGE, AND SHIPPING-

' OPPD's-QAM requires that instructions or guidance for plant handling, l

preservation, storage, and control of products are prepared and approved prior to arrival _ of the products at the plant. These procedures specify, as required, l

that special environmental facilities, such as inert gas, humidity control, or temperature controlled storage area are established prior to the receipt of the provide procedures for the handling of products to prevent damage"6r'deteriT ~

products. Contractors performing maintenance or repair services *aEe }equiFedit6 l

ora tion. Theprocedures{arl5]reviewedandapprovedbyOPPD.

l To assure existence of the requirements for procedures in the procurement docu-ments, OPPD OANsrifiss}OPPD personnel procure, receive, store and han the inclusion during its review prior to authorization fogdocument, iisifsnce.~

td mited CQEfand radioactive material packaging products, material, and com-lonents'inaccordancewithestablishedprocedures, s

A.15' INSPECTION, TEST, AND OPERATING STATUS OPPD's OA@iirQrequires that procedures be established to identify the inspec-1 tion, test, and operating status of radioactive material packaging and safety-related structures, systems, and components.

Identification of the inspection, test, and operating status of structures, systems, and components is provided

-in the lurveillance,itest" program. Schedules and methods for periodic testing of fire pr6tection systems and components'have'.beenj developed and documented by. the Manager - Fort Calhoun' Station.

Fire pr6thctiori equipment, emergency lighting, and cowranication equipment 'isl. tested periodically to assure that the equipment l

will properly. function and continue to meet the design criteria.

Test results isire*dccen;ented, evaluated, and reviewed for acceptability.

I ma The application and removal of inspection and welding stamps and status

indicators are procedurally controlled, and nonconforming, inoperative, or.

' malfunctioning structures, systems, or components are identified in cccordance

<with established procedures. System completeness and acceptance at the end of a l

-maintenance or repair phase are determined by:

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(1) reviewing for adequacy, completeness, and conformance to quality assurance requirements for each system or component being accepted; (2) performing surveillance and monitoring of the test activities associated with the approved test program; (3) reviewing the test records to verify that test results comply with established requirements.

The suppliers' and contractors' inspection and test status of items are required to be maintained through the use of status indicators such as physical location, tags, markings, shop travelers, stamps, or inspection records. These measures provide for assuring that only items that have received the required inspections and tests are used in manufacturing and are-released for shipment.

-The procedures for control of status indicators, including the authority for applicationandremovaloftags, markings,labelsorstamps~ ave]documentedin l

approved manufacturing or quality assurance procedures.

A.' 16 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS The_ OPPD Quality AssuranceIPiWrequires that measures beTisfatiIiEed}to control I

the identification, documentation, segregation, and dispos'ition of nonconforming material, parts, or components. The implementing instructions which fulfill these requirements are prescribed in established procedures. TheQATP.lsQ l

identifies those individuals.or groups delegated the responsibility a'nd'autho-rity for the disposition and approval of nonconforming items. Nonconforming l

items are controlled and identified in accordance with written procedures to prevent inadvertent use or installation.

Control measures include tagging or I

marking and segregation when feasible. Control measures are maintained unt11 the item has been removed from the plant site or corrective work has been completed and accepted.

Established procedures cover:

(1)

Initiation of the documentation for material rejected at receiving inspection or in-plant activities including the tagging of nonconforming items. A nonconformance report identifies the nonconforming item and describes the noncon formance.

(2) Assignment of disposition and/or corrective action responsi-bilities, including the inspection requirements and signature approval of the disposition.

(3) Control of correction work planning and acceptance.

Nonconformance reports are analyzed during audits of the nonconformity control

' system to detect adverse quality trends. These reports go to management for review and assessment.

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f The OPPD Quality AssuranceflMrequires that measures be takan and docurented l

by contractors and suppliers to control the identification, documentation, segregation, and disposition of nonconforming material, parts, or components.

These measures prevent inadvertent use or installation of defective components l

and are subject to review and approval by 0 PPD. Written procedures will be required for investigation of the nonconforming iten, decisions on its dis-

. position,'and preparation of adequate reports.

Procedures also control further I

processing, fabrication, delivery, or installation of items for which disposi-tion is pending. Reportsdocumentingactionstakenonnonconformingitemsias]

l made available to OPPD for evaluation. Departures from design specifications ~ ~

and drawing requirements that are dispositioned "use as-is" and " repair"i areT reported to.affec'ted organizations and OPPD management.

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The effectiveness of nonconformance control procedures is assured by:

l (1) Contractor quality assurance and manufacturing, fabrication, or construction personnel being involved in processing nonconforming reports.

(2) OPPD participation in dispositions and approvals.

'(3) Document review at final inspection or shipping release and at receiving inspection by OPPD.

-(4) Surveillance by 0 PPD and contractor personnel.

(5) Audits.

A.17-CORRECTIVE ACTION TThsfQAllin' requiresI'tO4 measures TeisT561Tsiisto assure that conditions

~

^~

'idverse"t6" quality are promptly identified, reported, cnd corrected. -Responsi-bility for. performing corrective actioniisjassigned to JPPD personnel and con-l tractors and suppliers so that each will'be alert to those conditions adverse to quality within his own area of responsibility.

In the case of significant conditions adverse to quality, measures ThFe3taken to assure that the cause of l

the condition is determined and correctiiie'iction is implemented to preclude repetition. Corrective action procedures require thorough investigation and l

documentation of significant conditions adverse to quality. The cause and corrective action!aref* reported in writing to the appropriate levels of manage-ment. The correct'ive action to be applied;i@suoject to Veview and approval by OPPD QA. Corrective action fcilowp and'closecut precedures provide that corrective action commitments are implementeo in a systematic and timely manner and are effective.

The effectiveness of the suppliers' or contractors' corrective action program?isI l

- assessed during audits by the supplier, the contractor, and by OPPD. Stop work "

authorityQs}exercisedasrequired.

l

_.- e m m m m w w w - m.~m mm-~,,-~,- w ~,-

?A_ quarterly) report offdeficiencies s that : haveloccurred, dincluding; thel status.of 9

$allyres'ivedjdeficiency1 reports,Lis;preparedanddistri.butedby:theManage'l rim c

r

RQARThisireport isl routed ;to the; management of. OPPDJorganizations;;participati,ng]

z lQtatusj;QAl program,wTheManager(QualityAssur'ance' maintains;aEconsolida

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1.inithe s

summary;ofjall dgficiencies, y

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--A,18

. QUALITY ASSURANCE RECORDS OPPD's Quality AssuranceNaMrequires that OPPD and its contractors have a

-quality records system which povides]dricumentary evidence of the perfor-mance of activities affectingpalityj The requirements include that:

(1) Records are maintained that show evidence of performance of activities affecting q'uilityj Typical records to be maintained include quality assurance ~ programs and plans, design data and studies, design review reports, specification procurement documents, procedures, inspection and test reports, material certifications, personnel certifications, test reports, audit reports, reports of nonconformances and corrective actions, as-built drawings, operating logs, calibration history, maintenance data, and failure and incident reports.

(2). Inspection and test records, as a minimum, identify the l

date of the inspection or. test, the inspector or data recorder, the. type of observation, the results, the acceptability, and the action taken in connection with any nonconformances noted.

(3) Records' ire] protected against deterioration and damage.

l (4) Criteria ' ire 3 established for determining the classification l

of the record as well as the length of the retention period.

(5) A method of identification and indexing of records for ease of retrievability ?isijestablished.

l (6) Responsibility for recordkeeping during design, fabrication, construction, preoperational testing, and commercial operation (is] documented.

l (7) Method of transfer of records between organizations and ultimate transfer-to OPPD shall be established.

Requirements and responsibilities for the handling, storage, and retention _

of records which furnish documentary evidence of quality are prescribed by established procedures. The records are accumulated and handled in a con-

. trolled: manner in accordance with these procedures.

A.19 AUDITS TheUFPD'QA((Jhyrequ,iresthatplanned.and,periodicauditsbeperformedto verify compliar.ce of actifitiesiaffecting qualitfjand to determine the effec-1 tivenessofthe10A)pvogFari."The~0PPDQAde'artmentperformssuchauditsonOPPD p

internal activitids, contractors, suppliers, and others as necessary to provide i

an objective evaluation of the effectiveness of their programs; to determine' L

that their programs 'are in compliance with established requirements, methods, and procedures; and to verify implementation of recommended corrective action.

F_A-2_41

{R_234/857

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' The internal audit cycle for activities affectin97js51ithand the 3 ire ~protec-E tion yrogram is promulgated in establishingTprocedures"and is based on the safety importance of the activities beini perf onned. An audit schedule is distributed and updated quarterly to ensure coverage of status changes.

If, in i

the opinion of the Manager

, Quality Assurance, a given area requires added i

emphasis, the frequency of audits is increased until the situation is clarified.

'TheOPPDaudits,.bothinternalandexternal,7aiFconductedinaccordancewith

[.

zthe established. procedures. Consultants may be'dtilized by OPPD on audits as required, lJhejQAfPlas specifies that the auditing system used by OPPD,

.l its contractors,: and suppliers:

(1) utilizes an audit planning document which defines the organi-L zations and activities to be audited and the frequency of L

audits;

.(2). requires auditors to be familiar with the type 'of activities to be audited and have no direct responsibilities in the type of activities to be audited; (3) provides auditing checklists or other objective guidelines to

. identify those activities which affect quality; (4) requires examination of the essential characteristics of the quality activity examined; (5) requires an audit' report to be prepared and that it notes the extent of examination and deficiencies found.

-Established procedures provide-the means which assure that audits are performed

'in a thorough and professional manner. OPPD audits determine the existence of a fontiF6fisystem and the deficiencies of that system, and the actual practice of l

th"e" system. ~ Audit checklists are used to ensure that audits include the>objec-tive evaluation.of work areas, activities, processes ed items and the review of documents and records.

Established procedures require thatl~a73rinilTripoirt'hOpfepi'FiilkFfespliONE d

[fJiedit7iiidit? The audit report [ident'ifiesFiWy deficiencies"6F'nonc6nformahces" Sfob' rid'dufing"theaudit,andrecommEndedfsolfijsy

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_266

r-Industry Standards and Associated Regulatory Guides used as a Basis for the OPPD QA Program Introduction This attachment identifies the specific industry standards and HRC Regulatory Guides which form the base of the District's~QA Program as described in the USAR

' Appendix, and as delineated in the QA Plan. A position statement is provided for each standard / Regulatory Guide which describes the nature and extent of the District's commitments, including any alternatives used or exceptions taken.

The District interprets the verbs (shall, should and may) used in industry

' standards to mean the following:

~

Shall:

Indicates a requirement.

Should:

. Indicates a recommendation.

May:

Indicates permission or an option.

Where the below listed standards make reference to other documents to be in-cluded as a part of the referencing standard, it is assumed that the reference is to the specific standard (s) identified and. described in this attachment, or as defined in other applicable District commitment documents.

In the develop-

~

ment of the QA Plan, requirements of construction based standards were incor-porated to the extent that they are applicable to operations phase activities,

-retaining the basic quality assurance controls, but not necessarily encnmpassing L he_ specific implementation associated with that control or measure delineated t

I for the construction phase.

-Commitments

_A.

Standard: ANSI N45.2-1977, " Quality Assurance Progran Requirements for Nuclear Facilities" Regulatory Guide: RG 1.28, Revision 2, " Quality Assurance Program Requirements (Design and Construction)"

Positicn: The District's QA Program and QA Plan comply with the r;

requirements of this standard and Regulatory Guide to the extent >that these requirements apply to activities affecting quality"yperformed in

'^

the operations phase of Fort Calhoun Station.

A-27 (R22I/AG c

(

B.

Standard: ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operations Phase of Nuclear Power Plants" Regulatory Guide: RG 1.33, Revision 2. "Ouality Assurance Program Requirements (Operations)

Position: The District's QA Program and QA Plan comply with the applicable requirements of this standard and Regulatory Guide with the following alternatives _or exceptions:

1.

Preoperational testing of Fort Calhoun Station is completed, therefore, these requirements are implemented only to the extent required by the Station Technical Specifications and as applicable to preoperational testing associated with. station modification activities and post-maintenance testing.

2.

The District's audit program is a.four-tiered program consisting of (1) regularly scheduled internal and external audits conducted on a 3 year cycle by the Quality Assurance Department, (2) regularly scheduled QA surveillances conducted by the Quality Assurance Department, (3) scheduled a'Jdits performed by or under the cognizance of, the Safety Audit and Review Committee in accordance with the Station Technical Specifications, and (4) a management review to determine the adequacy and effectiveness of the District's Quality Assurance Program performed under the auspices of the Safety Audit and Review Committee.

C.

Standard: ANSI N45.2.1-1973, " Cleaning of Fluid Systens and Associated Components During the Construction Phase of Nuclear Power

. Plants" Regulatory Guide: RG 1.37, Revision 0, " Quality Assurance Require-ments for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants" r Po s i tioniBTh'e"liidriEtVQA7rogEEUrif QA ? Pl a n fc%iidlfli tOF']

~

d pplicable' req'uirementriofithis standard 'and Regulatory; Guide to:the 7

~

Yextsnt i thati thesei requi rements c applylto ac thi tie s ' a ffecting %ua l i tyy

~

Ebrformndlin!the3pnations pha'seiofi.the; Fort:CalhounL Station 7asi kdElifeated ii6the District's1QAT Plan., f " ' " "" ' "

2 r

4 D'.

Standard: ANSI N45.2.2-1972, " Packaging, Shipping, Receiving, Storage and Handlinq of Items for Nuclear Power Plants (During the Construc-

~ tionPhase)"

Regulatory Guide:

RG 1.38, Revision 2, " Quality Assurance Require-ments for Packaging, Shipping, Receiving, Storage and Handling of Items.for Water Cooled Nuclear Power Plants" Position: The District's QA Program and QA Plan comply with the requirements of this standard and Regulatory Guide to the extent that these requirements apply to activities affecting; quality l performed in l

the operations phase of Fort Calhoun Station.

~

T_R2 _I85) l A-28

s:

E.

-Standard: ANSI N45.2.3-1973, " Housekeeping During the Construction Phase of Nuclear Power Plants" Regulatory Guide: RG 1.39, Revision 2, " Housekeeping Requirements for Water Cooled Nuclear Power Plants" IPis'id6ri:T T5e]ifiitfic 6 QA W ig E nd QA7P1an"complyiithTth~eO

^

[ applicable requirements;of' this standardiandiRegulatory: Guide lto' they

extentthat'these;.requirementsapply;toactivitieslaffec. ting I; performed in the. operation.'phas'e'of the Fort.Calhou C

" We' ' y' Fort;Calhoun StationLi.sidivided;into[ zones.:forJsscurity,Tstorage, fire'?

~

y$ protection;fand;radiationprotection:andsince, zones.designatedby{

ANSli45.2.3-a~re'primarilyf esigned forEcontrol.~of units during con- 'A d

i b istruction,Jadditional zones-have not;been, established for housekeeping _..(

li t

'$ purposes; LLimit'ations:are applied onVeating, Ldrinking,Tand smoking Litt #

specified1areasLat;the Fort Calhoun Station. LHousekeeping/practicesti" LandIcontrols' have been established for the control of< activities that?

~

1 Acaniaff.ectJheTqual.itylof;CQEl related systems and; components?

F.

Standard: ANSI N45.2.4-197?, " Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations" Reculatory Guide: RG 1.30, Revision 0, " Quality Assurance Require-ments for the Installation, Inspection and Testing of Instrumentation and Electrical Equipment" Position: The applicable requirements of this standard and Regulatory huide are implemented for modification activities which meet or exceed original plant specifications and manufacturer's recommendatio'ns, as described in the QA Plan.

G.

Standard: ANSI N45.2.5-1974, " Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Pcwer Plants" Regulatory Guide: RG 1.94, Revision 1, " Quality A:surance Require-ncnts for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants" Position: The applicable requirements of this standard and Regulatory Guide are inplemented for modification activities whicn meet or exceed original plant specifications and manufacturer's recommendations, as described in the QA Plan.

A-29 l' R(4[8C e

,1 ii.

-Standard: ANSI N45.2.6-1973, " Qualifications of Inspection Exami-nation, and Testing Personnel for the Construction Phase of Nuclear

Power Plants" P

Regulatory Guide: _ RG 1.58, Revision 0, " Qualification of Nuclear

-Power Plant Inspection, Examination and Testing Personnel" LPosition: The District's QA Program and QA Plan comply with the applicable requirements of this standard and Regulatory Guide with-the following alternatives or exceptions:

1.

District and contractor inspectors performing Quality Control inspections.are certified in accordance with this standard; however, these certification requirements are not applied to personnel performing operational surveillance testing and in-spection in accordance.with the Technical. Specifications, to

. investigative -inspections or to the conduct of preliminary inspections for purpose of planning corrective or improvement actions, or to the surveillance of plant operations to verify compliance with procedures. Certification of inspectors fcr nondestructive examinations is accomplished in accordance with SNT-TC-1A.

I'.

Standard: ANSI N45.2.8-1975, " Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants"

. Regulatory Guide: RG 1.116, Revision 0, " Quality Assurance Requir-ements for Installation, Inspection and Testing of Mechanical Equip-ment and Systems" Position: The applicable' requirements of this standard and Regulatory Guide are implemented for modification activities which meet or exceed original plant specifications and manufacturer's recommendations, as described in the QA Plan.

J.

Standard:. ANSI N45.2,9-1974, " Requirements for Collection, Storage and llaintenance of Quality Assurance Records for Nuclear Power Plants" Feaulatory Guiae:

RG 1.88, Revision 2, "Collecticn, Storage, and Raintenance of Nuclear Power Quality Assurance Records" Position: The District's QA Program and QA Plan comply with the applicable requirements of this standard and Regulatory Guide with the following alternatives or exceptions:

1.

The Fort Calhoun Station File Room meets the criteria of NUREG-0800, Standard Review Plan, Part 17.1, Acceptance Criteria 17.4, Alternative (3); ANSI N45.2.9-1979; and NFPA 232.

2.

Fire rated file cabinets used for interim record storage meet a one hour or greater fire rating.

Q2['4/P) l A-30 s

pg a.

y;

$c 2

J

K.

Standard: JANSI M45.2.10-1973, " Quality Assurance Terms and.

Definitions"'-

Regulatory Guide: RG 1.74, Revision 0, " Quality Assurance Terms ~and Definitions" Position: The District's QA Program and QA Plan comply with the l general terms and definitions ~ of this standard.

L L..

1 Standard: LANSI N45.2.11-1974, " Quality Assurance Requirements for the -

' Design of Nuclear Power Plants" Regulatory Guide:.RG.I.64, Revision 2. " Quality Assurance Require-ments for the Design of Nuclear Power Plants" Position: The District's QA Program and QA Plan' comply with the

. requirements of this standard and Regulatory Guide to the extent that l these'.' requirements apply to activities affecting safety performed ~in the operations phase of Fort Calhoun Station" lM.. ;Standardi ' ANSI N45.2.'12-1977.'" Requirements for Auditing of Quality

Assurance Programs for Nuclear Power, Plants" Regulatory Guide: RG 1.144, Revision 1, " Auditing of Quality Assur-ance Programs ;for Nuclear Power Plants" Position: The District's QA Program ~and QA Plan comply with the requirements of,this standard and Regulatory Guide to the extent that these requirements apply.to activities affecting safety performed in the operations phase of Fort Calhoun Station"

. N '.

Standard: ANSI N45.2.13-1976, " Quality Assurance Requirements for-Control-of Procurement of Items and Services for Nuclear Power Plants" Peaulatory Guide: RG 1.123, Revision 1, " Quality Assurance Require-ments. for Control of Procurement of Items and Services for Nuclear Power Plants"

~ Position: 'The District's QA Program and QA Plan comply v.ith the

requirements of.this standard and Regulatnry Guide to the extent that

~

these' requirements apply to activities affecting safety performed in

,~

.thel operations phase of Fort Calhoun Station" 0.

. Standard:. ANSI N45.2.23-1978, " Qualification of Quality Assurance

. Program Audit Personnel-for Nuclear Power Plants" Regulatory Guide: RG 1.146, Revision 0, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" Position:.The' District's QA Program and QA Plan comply with the requirements of:this-standard and Regulatory Guide.-

[fti2h5Ef l

A-31

.Jr

(

-P.

-Standard: ANSI N18.1-1971, " Selection and Training of Nuclear Power l

{

Plant Personnel"

)

1 Regulatory Guide: RG 1.8, Revision 1, " Personnel Selection and Training"

-Position: The District's QA Program and QA Plan comply with the.

applicable requirements of this standard and Regulatory Guide with the following alternatives or exceptions:

1.

Qualification requirements for the Supervisor-Chemistry,and l

Radiation Protection and for the Shift Technical Advisor are in accordance with-the Fort Calhoun Station Technical ~Specifi-cations.

I

-Q.

Standard: ANSI N101.4-1972, " Quality Assurance for Protective Coatings Applied to Nuclear Facilities"

~

Regulatory Guide: RG 1.54, Revision O, " Quality Assurance Requirements for Protective Coatings Applied to Water Cooled Nuclear y

Power Plants"

~

Position: The applicable requirements of this standard and Regulatory Guide are implemented for modification activities which meet or exceed original plant specifications and manufacturer's recommendations, as described in the QA Plan.

t

-A-32 FR2]4/85]

t

_ _ _ _ _ _ _ _