ML20138G779
| ML20138G779 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 12/18/1996 |
| From: | Amundson T, Watzl E NORTHERN STATES POWER CO. |
| To: | |
| Shared Package | |
| ML20138G776 | List: |
| References | |
| NUDOCS 9701020259 | |
| Download: ML20138G779 (106) | |
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NORTHERN STATES POWER COMPANY i
414 Nicollet Mall Minneapolis, MN 55401 j
i OPERATIONAL QUALITY ASSURANCE PLAN REVISION 20 Reviewed By:
Whb Date: l'ck M 9(c T. E. Amundson Director, Generation Quality Services
{ lou Date:
/A ~/b 2[
Approved By:
E. MVAtkl
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Vice President Nucrear Generation i
Effective Date:
l (NRC Acceptance Date) 9701020259 961219 PDR ADOCK 05000263 p
Oper:tinti Qu lity Assurcnce Pim Revision 20 l
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Table of Contents i
1 Pace
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1.0 Policy Statement 1
l 2.0 Introduction 6
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3.0 Organization 7
l 4.0 Operational Quality Assurance Program i1
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5.0 Modification Control 16 6.0 Procurement Document Control 17 I
7.0 Instructions, Procedures and Drawings 19 j
l 8.0 Document Control 21 9.0 Control of Purchased Material, Equipment and Senices 25 l
1 10.0 Identification and Control of Materials, Parts and Components 27 i
11.0 Control of Special Processes 28 j
12.0 Inspection and Examination 29 13.0 Test Control 34 i
14.0 Control of Me.suring and Test Equipment 36 i
15.0 Handling, Storage and Shipping 37 16.0 Inspection, Test and Operating Status 39 17.0 Nonconforming Materials, Parts or Components 42 i
18.0 Corrective Action 44 19.0 Quality Assurance Records 45 20.0 Audits 49 21.0 Prairie Island Safety Audit Committee (SAC) 51 l1 22.0 Prairie Island Operations Committee (OC) 55 l2 l
Appendix A - Monticello Structures, Systems, and Components Subject to Appendix B of 10CFR50 59 l
Appendix B - Prairie Island Structures, Systems, and Components Subject to Appendix B of 10CFR50 65 Appendix C - Nuclear Plant Fire Protection Program 75 Appendix D - Resision 20 Change Summary 91 l3
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1 Operatist Qrlity Assura:ce Plan Revision 20 1
1,0 Policy Statement 1.1 Northern States Power Company (NSP) has established and is implementing an Operational Quality Assurance Program. This quality assurance program is applicable to NSP nuclear 1
plants that are regulated under provisions of an NRC Operating License.
1.2 The quality assurance program, as applied to activities affecting safety related functions, shall comply with and be responsive to applicable regulatory requirements and applicable industry codes and standards including:
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2.
NRC Operating Licenses.
3.
The ASME Boiler and Pressure Vessel Code,Section XI, Inservice Inspection.
4.
10CFR21, Reporting ofDefects andNoncompliance.
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5.
10CFR71, Subpart H, Quality Assurance.
6.
Nuclear Plant Fire Protection Program, Operational Quality Assurance Plan, Appendix C.
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NSP Plant Security Plans.
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NSP Radiation Environmental Monitoring Program.
9.
ANSI N45.2.6-1978, Qualifications ofInspection, Examination, and Testing Personnelfor Nuclear Power Plants, as modified by Regulatory Guide 1.58, Revision 1. (See sections 12 and 13.)
10.
ANSI N45.2.12-1977, Requirementsfor Auditing of Quality Assurance Programsfor Nuclear Power Plants.
11.
ANSI N45.2.23-1978, Qualification ofQuality Assurance Program Audit Personnel for Nuclear Power Plants, as modified by Regulatory Guide 1.146, August,1980.
1.3 The Operational Quality Assurance Program shall incorporate: (1) the requirements.of ANSI N18.7-1976, as modified by Table 1-1 and (2) the requirements of the following standards to
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the extent specified by ANSI N18.7-1976, as modified by the regulatory position of the l
Regulatory or Safety Guides referenced below.
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1.
ANSI N18.1-l971, Selection and Training ofNuclear Power Plant Personnel (Regulatory Guide 1.8, Rev.1).
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Operatim! Qnlity Ass:ra:ce Pl=:i Revision 20 2.
ANSI N45.2-1971, Quality Assurance Program Requirementsfor Nuclear Power Plants.
3.
ANSI N45.2.1-1973, Cleaning ofFluid Systems and Associated Components During Construction Phase ofNuclear Power Plants (Regulatom Gulde 1.37, 3-16-73).
4.
ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage andHandling ofItems for Nuclear Power Plants (During the Construction Phase) (kegulatory Guide 1.38, Rev. 2).
5.
AN5I N45.2.3-1973, Housekeeping During the Construction Phase ofNuclear Power Plants (Regulatoy Guide 1.39, Rev.1).
6.
ANSI N45.2.4-1972, Installation, inspection, and Testing Requirementsfor Instrumentation andElectric Equipment During the Construction ofNuclear Power Generating Stations (Safety Guide 30, August 11,1972).
t 7.
ANSI N45.2.5-1974, Supplementary Quality Assurance Requirementsfor Installation, Inspection and Testing ofStructural Concrete and Structural Steel During the Construction Phase ofNuclear Power Plants (Regulatory Guide 1.94, Rev.1).
8.
ANSI N45.2.8-1975, Supplementary Quality Assurance Requirementsfor Installation, Inspection and Testing ofMechanicalEquipment andSystemsfor the Construction Phase ofNuclear Power Plants.
9.
ANSI N45.2.9-1974, Requirementsfor Collection, Storage andMaintenance of Quality Assurance Recordsfor Nuclear Power Plants (Regulatory Guide 1.88, Rev. 2).
10.
ANSI N45.2.10-1973, Quality Assurance Terms and Definitions (Regulatory Guide 1.74, February,1974).
I 1.
ANSI N45.2.11-1974, Quality Assurance Requirementsfor the Design ofNuclear Power Plants (Regulatory Guide 1.64. Rev. 2).
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12.
ANSI N45.2.13-1976, Quality Assurance Requirementsfor the Control of Procurement ofItems and Servicesfor Nuclear Power Plants.
13.
ANSI N101.4-1972, Quality Assurancefor Protective Coatings Applied to Nuclear Facilities (Regulatory Guide 1.54. June,1973).
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Operati:nzl Qu:lity Assurance PI:n Revision 20 1.4 Management directives and departmental instructions and procedures shall provide for compliance with appropriate regulatory, statutory, license and industry requirements. Specific quality assurance requirements and organizational responsibilities for implementation of these requirements shall be specified in implementing directives and instructions.
1.5 Compliance with this policy and the provisions of the Operational Quality Assurance Program is mandatory for NSP personnel with respect to nuclear plant operational activities or activities which suppon nuclear plant operation. Personnel shall therefore, be familiar with the requirements and responsibilities of the program that are applicable to their individual activities and interfaces.
1.6 The Vice President Nuclear Generation, through an independent organization, shall periodically have the Operational Quality Assurance Program reviewed to assure its adequacy.
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Operati=al Qu lity Assurcnce Pir.n Revision 20 Table 1-1 Exception to ANSI N18.7-1976 1.
Documentation required by ANSI N18.7-1976 may be deferred for emergency work.
Emergency work is defined as that work that must be completed immediately and which, if delayed, may result in an unsafe condition or significantly interfere with reliable plant operation.
2.
Exceptions to Regulatory Guides and ANSI Standards are acceptable for those principal contractors, retained by NSP, such as NSSS contractors and A/E firms, which exceptions have been approved by the NRC.
3.
Section 5.1; delete this section. The provisions associated with identification of the Operational Quality Assurance Program scope are explicitly identified in Section 4 of the Operational Quality Assurance Plan.
4.
Section 5.2.2; replace the third sentence with the following " Temporary changes to 4
approved procedures shall be reviewed and approved as required by Section 8.4 of the Operational Quality Assurance Plan." Delete the fourth sentence.
I 5.
Section 5.2.5; replace the second and third sentences with " Temporary procedures shall be reviewed and approved as required by Section 8.4 of the Operational Quality Assurance 5
Plan."
6.
Section 5.2.9; delete the reference to ANSI N18.17. The Plant Security Plans contain required security provisions.
7.
Section 5.2.11, first sentence; change " abnormal occurrences" to " reportable events."
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8.
Section 5.2.13.2, fourth paragraph; change the first sentence to read ". installation or use of l6 such items that serve a safety function."
9.
Section 5.2.15 of ANSI N18.7-1976 shall govern review, approval, and control of required procedures except that, for procedures required by the Plant Technical Specifications, the 7
review and approval requirements stipulated in Section 8.4 of the Operational Quality 8
Assurance Plan shall be utilized rather than those contained in Section 5.2.15.
10.
Section 5.3; change the last sentence to read " Procedures shall be prepared and approved prior to implementation as required by ANSI N18.7-1976, Section 5.2.15."
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Op:ratiz=ct Qu:lity Asser:nce Plis Revision 20 Table 1-1 (continued) l 10
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11.
Sections 5.3.9 and 5.3.9.1; delete these sections. Emergency Operating Procedures shall be consistent with Supplement I to NUREG - 0737 - Requirements for Emergency Response Capability (Generic Letter 82-33).
12.
Section 6; delete this section. The referenced documents are explicitly referenced in the Operational Quality Assurance Plan. NSP will evaluate new or revised ANSI Standards if appropriate for inclusion in the Operational Quality Assurance Plan.
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Operatirnr1 Qurlity Assurence Pirn Revision 20 2.0 Introduction Northern States Power Company (NSP) is involved in the construction and operation of fossil-fueled and hydro power plants, and the operation of nuclear power plants. NSP's nuclear plant operational activities are conducted under the Operational Quality Msurance Program. The Operational Quality Assurance Program is formulated on a company-wide basis, to govern nuclear plant operational activities and associated support activities as required by NRC Operating License provisions and associated regulations.
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Oper;ti:n:1 Qurlity Assur:nce Pirn I
Revision 20 I
4 3.0 Organization l
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3.1 General Requirements
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NSP shall be responsible for the establishment and execution of the Operational j
Quality Assurance Program. NSP may delegate to other organizations the work of
'1 establishing and executing the Operational Quality Assurance Program, or any part l
thereof, but shall retain responsibility therefor.
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2.
The authority and duties of persons and organizations performing quality assurance functions shall be clearly established and delineated in writing. Such persons and organizations shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify 1
implementation of solutions.
J 3.
Assurance of quality requires management measures which provide that the individual i '
or group assigned the responsibility for checking, auditing, inspecting, or otherwise verifying that an activity has been correctly performed is qualified and does not have responsibility for performing or directly supervising the work except that:
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The individual or group assigned the responsibility for auditing is independent of the individual or group directly responsible for performing the specific activity.
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j 3.2 Organization Summary 1
i Figure 1, NSP Organi:ation with Operational Qw.lity Assurance Responsibilities, presents an organizational chart ofNSP show' g a st.mmary of functional responsibilities.
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Operati:n:1 Quality Assurance PI:n Revision 20 i
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oPerati.as Q=4ity Asnemee Plan Revisen 20 Figure I NSP Orgrintio'a with Operation;I Quility Assura:ce Responsibilities Chaimwi & Chief Executve Of5cier i
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preeksent President h President Vice Premdent NSP Dectic NSp Generasen Pteac & Govt Affairs Humart Resources i
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Transmission System Operaton vice prendert Director Director Director Drector ".J. _....;.;
-Filnese for Duty Program Nuclear Generston Genera 5an Queaty Services Producson Services Fuel Resources
& Regulatory Affaks i
Drector PM Manager Intemet Audits ModScatons
-Reactor Core Reload Design
-Corporate Emergancy Planning
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-Quality Contro4 W Services Core & Safety Analysis
-Rada6cn Program Stepart Stop Work Authenty Drawing Contrd
-Spert Fuel Managemert
-Chemkey Program Support
-Control of OQAP
-lSI High Level Radaton
- Low Level Redetion Weste Management iI Waste Managemere
-Supplier Quagfica9en
-Technical Support Operaton (Welding. ASME Code, NDE)
Administrative Control 12 D
ofACDs
-Testing Laboratory Serv 4ces Radanon Protech Fr' e Protection REMP ISFSI (Pt ordy)
Design Documentation Trairung Page 9 of I04 I
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I Operatic 2tl Qurlity Assur nce Plan 1
l Revision 20 i
4.0 Operational Quality Assurance Program 4.1 General Requirements 1.
The Operational Quality Assurance Program shall be:
a.
Documented by written Directives, Instmetions, or Procedures.
b.
Carried out throughout plant operating life in accordance with those Directives, Instmetions, or Procedures.
2.
The Program shall include identification of:
a.
The structures, systems, and components to be covered.
b.
The major organizations participating in the Program, together with the -
i designated functions of these organizations.
3.
The Program shall provide control over activities affecting the quality of the identified structures, systems, and component's to the extent consistent with their importance to safety.
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4.
Activities affecting quality shall be accomplished under suitably controlled conditions.
Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanliness; and assurance 4
that all prerequisites for the given activity have been satisfied.
5.
The Program shall take into account the need for special contm!s, processes. ;st equipment, tools, and skills to attain the requ red quality, and the need for.:rification l
of quality by inspection and test.
6.
The Program shall provide for indoctrination a nd training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
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The adequacy and status of the Program shall be regularly reviewed.
8.
Management of other organizations participating in the Program shall regularly review the status and adequacy of that part of the Program which they are executing.
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J Opsr ti:n:I Quility Anurznce Pl::n Revis'on 20 4.2 General Description 1.
The Operational Quality Assurance Program has been established to govern the
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operational activities and the activities necessary to support operation of the company's nuclear plants operated under an NRC Operating License. The Operational Quality Assurance Program is thus an overall integrated company-wide prograrn which governs all safety related, fire protection related and 1^CFR71 related activities as they pertain to operating nuclear plants.
2.
The Program has been initiated by Senior NSP management issuing a single directive to the President NSP Generation establishing him as being responsible for formulating l13 and implementing an Operational Quality Assurance Program and identifying the e
program objectives.
3.
The Operational Quality Assurance Program shall utilize the following documents to 1
meet the program objectives:
Operational Quality Assurance Plan (Plan),
a.
b.'
Administr ative Control Directives (Directives) at the Corporate level.
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Administrative Work knstmctions (Instmetions) at the Site level.
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c.
d.
Required Procedures (Procedures) at the Plant and Depanment level.
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The Plan shall be consideted an overall document which governs the implementing j
documents (i.e., Directives, Instructions, and Procedures).
t 5.
For ease of administration, implementing documents shall be issued at the fo.llowing program levels:
a.
Cp_rporate: Approving Authority, President NSP Generation, Vice President Nuclear Generation and Director Generation Quality Semces.
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Sites (Prairie Island and Monticelloh Approving Authority, Plant Manager.
c.
Decanments Providinu Nuclear Plant Sunnort: Approving Authority, k
Department Manager.
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Operational Quality Assurance Plan Revision 20 6.
Corporate Administrative Directives establish the minimum requirements for Site Administrative Instructions and other supporting departmental instructions and l14 procedures.
There need not be a corre?ponding Site level Instructions for every Corporate l14 a.
level Directive. Corporate level directives may also be implemented at the Site level through Site level Procedures.
l15 4.3 Operational Quality Assurance Plan 1.
The Operational Quality Assurance Plan shall be a document which describes in general terms how compliance with the quality requirements presented in 10CFR50, Appendix B and 10CFR71, Subpart H is accomplished with respect to company nuclear plants regulated by an NRC Operating License.
2.
The Operational Quality Assurance Plan shall be issued under the authority of the Vice President Nuclear Generation and shall be reviewed periodically.
3.
The Operational Quality Assurance Plan shall be controlled to assure current copies are made available to personnel responsible for the revision, review and approval of Corporate Administrative Directives.
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All changes to the Operational Quality Assurance Plan shall be approved by the Vice j
President Nuclear Generation or equivalent management position.
4.4 Administrative Control Directives i
1.
Administrative Control Directives (Directives) shall be documents which establish responsibility and requirements governing activities associated with plant operation.
Directives shall be first. tier implementing documents and shall receive a quality review prior to issuance. The quality review shall assure compliance with the Operational Quality Assurance Program objectives. Required Directives shall be controlled and reviewed periodically.
2.
Administrative Control Directives shall be issued as necessary. It is mandatory that the Directives at the Corporate level assure compliance with all applicable requirements of 10CFR50, Appendix B and 10CFR71, Subpart H.
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Operati:n:1 Qudity Assur nca PI:n Revision 20 l
4.5 Administrative Work Instructions 1.
Administrative Work Instruct..ns (Instructions) shall be documents which provide guideli es or instmetions for the implementation of the requirements of Administrative l
Control Directives. Instructions shall be second tier implementing documents and shall receive a quality review prior to issuance. The quality review shall assure l
compliance wi',h pertinent Dir2tive requirements and assigned responsibilities.
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l Required Instiuct ons shall be controlled and reviewed periodically.
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i 4.6 Procedures j
1.
Procedures shall be documents which provide specific instmetions for performing an activity. Procedures shall be second or third tier documents utilized to perform safety related, fire protection, arcl 10CFR71 related activities as required by the applicable NRC Operating Lic.ense Technical Specifications.
2.
Procedures shall be provided where applicable, to assure that activities important to safety are performed in the required manner.
l 19 4.7 Program Administrat'.on 1.
Administration of the Corporate level of the Operational Quality Assurance Program shall be performed by the Director Generation Quality Services.
2.
Disputes between Generation Quality Services personnel and other organizations relative to Program requirements shall be referred to the Approving Authority (as identified in Section 4.2 of this Plan) responsible for establishing the pertinent requirement.
3.
Program administration shall include the following activities:
Review olCorporate Administrative Control Directives.
a.
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Performance of required audits.
20 Reporting to management concerning:
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Program status.
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Program discrepancies including quality trenas.
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Oper:ti:nri Qu:lity Assur:nce Pirn Revision 20 4.8 Program Boundary 1.
The structure, systems, components, and other items requiring quality assurance are listed in Appendices A and B. The Program shall also include shipment ofradioactive materials as required by 10CFR71 and systems and activities associated with fire protection as identified in Appendix C.
2.
An index shall be established and maintained by the Director Generation Quality Services which identifies the Directives that are utilized to implement the requirements l 21 of ANSI N18.7-1976 that are committed to in Section 1.0 of this plan and the requirements identified in the remaining sections of this plan.
4.9 Quality Assurance Training.
t Training programs shall be established for those personnel performing quality-affecting activities such that they are knowledgeable in the quality as,urance documents and their requirements and proficient in implementing these requirements. These training programs shall assure that:
1.
Personnel responsible for performing quality-affectiug activities are instructed as to the purpose, scope, and implementation of the quality-related Directives, Instructions, and Procedures.
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Personnel performing quality-affecting activities are trained and qualified, as appropriate, in principles and techniques of the activity being performed.
3.
The scope, the objective, and the method ofimplementing the training programs are documented.
4.
Proficiency of personnel performing quality-affecting activities is maintained by retraining, re-examination, and/or recertification as appropriate.
5.
Methods are provided for documenting training sessions describing content, i
attendance, date of attendance, and the results of the training session, as appropriate.
6.
Fire protection training is accomplished in accordance with Appendix C.
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l Operational Quality Assurance Plan i
Revision 20 5.0 Modification Control l
1 5.1 General Requirements Modifications shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the company designates another responsible organization.
5.2 Uniform Modification Process A uniform process for controlling modifications to nuclear plants shall be provided in the Operational Quality Assurance Program. Measures shall be established to assure that:
1.
The requirements of ANSI N45.2.11-1974 are implemented.
2.
Reviews and approvals are performed.
3.
Plant documentation is updated.
4.
Appropriate installation procedures are prepared and utilized.
5.
Tests and inspections are performed as necessary.
6.
Site procedures are reviewed and revised as appropriate.
7.
10CFR50.59 is complied with.
8.
Fire protection reviews are performed as required by Appendix C.
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I Operational Quality Assurance Plan l
Revision 20 1
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6.0 Procurement Document Control l
6.1 General Requirements i
Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by NSP or by its contractors or subcontractors. To the extent necessary, procurement documents shall require contractors or subcontractors to provide a quality I
assurance program consistent with the pertinent provisions of 10CFR50, Appendix B or 10CFR71, Subpart H.
6.2 Technical and Quality Requirements 1.
The Operational Quality Assurance Program shall contain provisions for controlling procurement of material, equipment, components, and services that are safety related, fire protection related, or 10CFR71 related and utilized at or for an operating nuclear plant.
2.
Procurement documents shall contain specific technical and quality requirements.
Renewal, spare, and replacement pans shall be required to meet the original specification (or properly reviewed and approved revision) or construction code, quality assurance documentation requirements, and vendor quality assurance program requirements.
3.
Quality assurance requirements that are required of the vendor shall be included.'
Quality assurance requirements shall be based on ANSI N45.2-1971 (or equivalent -
standard). Documentation requirements shall include, as applicable, chemical analysis reports, material certification, testing results, and testing reports. Time and frequency of submittals should be included.
4.
Procurement documents shall contain provisions which establish the right of access to j
vendor facilities and records for source inspection and audits as appropriate.'
S.
Procurement documents for contracting packages for transport of radioactive materials shall require a copy of the package license, certificate, or other NRC approval authorizing use of the package. The procurement documents shall also require copies of all documents referred to in the license, certificates, or other NRC approval as applicable.
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Operational Quality Assurance Plan Revision 20 l
6.3 Review and Approval Documents, and changes thereto initiating procurement of safety related, fire protection related,10CFR71 related material, equipment, components or services shall be approved by appropriate management personnel and shall be subject to a quality review to insure applicable regulatory requirements, design bases, quality assurance, and other requirements are adequately satisfied prior to release.
6.4 Fire Protection Procurement Control The additional procurement controls identified in Appendix C shall be applied to purchasing fire protection systems and equipment.
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Operational Quality Assurance Plan Revision 20 1
7.0 Instructions, Procedures and Drawings 7.1 General Requirements 1.
Directives, Instructions, Procedures, and drawings of a type appropriate to the i
circumstances shall be provided for the control and performance of activities which affect quality.
2.
Directives, Instnictions, Procedures, and drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities 1
have been satisfactorily accomplished.
7.2 Directives and Instructions Directives and Instructions shall be issued which establish procedural requirements for appropriate ftmetional areas. Such procedural requirements shall include the following as appropriate:
]
1.
Procadure review and approval requirements.
2.
Procedure control requirements.
3.
Procedure content requirements.
7.3 Procedures 1.
Procedures of a type appropriate to the circumstances shall be provided for the performance of activities which affect the quality of safety related, fire protection related, or 10CFR71 related structures, systems, or components.
2.
The following procedures shall be provided:
a.
Operating procedures.
b.
Emergency procedures.
c.
Surveillance test procedures.
d.
Routine or preventive maintenance procedures.
e.
Calibration procedures.
f.
Plant chemistry and count room procedures.
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Operational Quality Assurance Plan Revision 20 g.
Radiation protection procedures.-
h.
Emergency plan procedures.
i.
Special process procedures.
j.
Preoperational and operational test procedures.
k.
Audit procedures.
1.
Fire fighting procedures.
m.
Document control procedures.
n.
Radioactive material shipment procedures.
o.
Inspection and examination procedures.
6 7.4 Drawings and Technical Manuals Drawings and technical manuals of a type appropriate to the circumstances may be used as procedural documents for conducting activities that affect the quality of safety related, fire protection related, or 10CFR71 related structures, systems, or components.
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Operatio::1 Qu lity Assurseco Pl:n Revision 20 8.0 Document Control 8.1 General Requirements
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1.
Measures shall be established to control the issuance of documents, such as Directives, Instmetions, Procedures, and drawings, including changes thereto, which prescribe activities affecting quality.
2.
These measures shall assure that documents, including changes, are:
I Reviewed for adequacy and approved for release by authorized personnel, and a.
b.
Are distributed to and used at the location where the prescribed activity is performed.
3.
Changes to documents shall be reviewed and approved by the same organization that performed the original review and approval or another designated responsible.
organization.
8.2 Administrative Control Directive Control 1.
Directives issued to implement the Operational Quality Assurance Program shall be controlled to assure that current copies and appropriate indexes are made available to personnel performing the prescribed activities. Directives shall be reviewed to assure their compatibility with the Operational Quality Assurance Program objectives and shall be approved by the designated management.
2.
Changes to Directives shall be reviewed and approved in the same manner as the original.
8.3 Administrative Work Instmction Control 1.
Instmetions issued to implement provisions of Directives shall be controlled to assure that current copies and appropriate indexes are made available to personnel performing the prescribed activities. Instmetions shall be reviewed to assure that they are compatible with pertinent Directive provisions and shall be approved by designated management.
2.
Changes to Instructions shall be reviewed and approved in the same manner as the original.
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Operati:xt Qnlity Ass;rance Pim Revision 20 8.4 Procedure Control 1.
Required procedures shall be controlled to assure that current copies are made available to personnel performing the prescribed activities. Appropriate indexes of l 22 standing procedures shall be formulated and made available to personnel responsible 23 for performing the prescribed activities.
2.
Except as specified in Sections 8.4-3 and 8.4-4, required procedures shall:
a.
Be reviewed by an independent knowledgeable individual and be approved by a 19 member of management responsible for the prescribed activity.
22 b.
Have significant changes to required procedures reviewed and approved in the 24 same manner as the original.
c.
Be periodically reviewed.
19 3.
Monticello Procedure Control 19 23 a.
Required procedures, procedurt, changes and temporary changes shall be 25 reviewed and approved as required by the Technical Specifications.
4.
Prairie Island Procedure Control 19 23 a.
Required procedures and procedure changes shall be reviewed as specified by Section 22.4-8 and approved by a member of plant management designated by i
the Plant Manager except that maintenance procedures shall be reviewed and approved in accordance with Section 8.4-5.
b.
Temporary changes to Operations Committee reviewed procedures, which do 26 not change the intent of the original procedure may be made with the concurrence of two members of the unit management staff, at least one of I
whom holds a Senior Reactor Operator License. Such changes shall be documented, reviewed by the Operations Committee and approved by a member of plant management designated by the Plant Manager within one i
month.
c.
Non-safety related procedures which govern work activities exclusively 27 t
applicable to or performed by security personnel shall be reviewed and approved by the Superintendent Security. Temporary changes to such 26 procedures shall be reviewed by two individuals knowledgeable in the area affected by the procedure.
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Operatir=1 Quality Assurance PI:n Revisiom 20 5.
Prairie Island Maintenance Procedures.
28 Maintenance work orders and their associated maintenance and test procedures 29 a.
for the activities listed below shall be prepared, reviewed and approved. Each procedure or procedure change shall be reviewed by a qualified individual (s) other than the individual (s) who prepared the procedure or procedure change.
The appropriate superintendent (as previously designated by the Plant Manager) shall approve these procedures.
The following maintenance and test procedures will be developed to satisfy 30 routine inspection, preventive maintenance programs, and operating license requirements.
i.
Routine testing of Engineered Safeguards and equipment as required by the facility License and the Technical Specifications.
ii.
Routine testing of standby and redundant equipment.
4
. iii.
Preventive or corrective maintenance of plant equipment and.ystems that could have an effect on nuclear safety.
iv.
Calibration and preventive maintenance ofinstmmentation that could affect the nuclear safety of the plant.
v.
Special testing of equipment for proposed changes to operational procedures or proposed system design changes.
b.
Individuals responsible for reviews performed in accordance with the requirements of Section 8.4-5.a shall meet or exceed the qualifications '
described in section 4.2 or 4.4 of ANSI N18.1-1971 and shall be previously designated by the Plant Manager. Such reviews shall include a determination of whether or not additional cross disciplinary review is necessary, c.
All reviews shall include a determination of the need for a safety evaluation to establish whether or not an unreviewed safety question is involved.-
8.5
' Drawing Control-1.
Drawings which represent the physical and functional aspects of the operating nuclear plants and which are critical to safe plant operation or safety of personnel shall be maintained in a current status. Appropriate indexes shall be formulated and made available to personnel responsible tbr plant operation, maintenance, and modification.
Page 23 of 104
Operati:s:1 Qurlity Assura ce Pirn Revisi:n 20 2.
Measures shall be established for revising site drawings and for distributing revised drawings. Proposed revisions to drawings shall be reviewed by a knowledgeable individual to determine the safety significance and appropriateness of the change.
8.6 Specifications Plant design specifications shall be controlled to assure that current copies and appropriate indexes are made available to personnel responsible for plant operation, maintenance, and l
modification.
8.7 Radioactive Shipment Package Documents All documents related to a specific shipping package for radioactive material shall be
- controlled by appropriate instructions; all significant changes to such documents shall be similarly controlled.
8.8 Updated Safety Analysis Reports Updated Safety Analysis Reports shall be updated in a:cordance with the applicable provisions of10CFR50.
8.9 Technical Manuals 1
Technical manuals that are used as procedural documents shall be controlled.
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Operational Quality Assurance Plan Revision 20 l
9.0 Control of Purchased Material, Equipment and Services 9.1 General Requirements 1.
Measures shall be established to assure that purchased material, equipment and services conform to the procurement documents. These measures shallinclude provisions, as appropriate, for vendor evaluation and selection, objective evidence of quality furnished by the vendor, inspection at the vendor source, and examination of products upon delivery.
2.
Documentary evidence that material and equipment conform to the procurement requirements shall be available at the site prior to installation or use of such material and equipment. This documentary evidence shall be retained at the site and shall be sufficient to indicate that the purchased material and equipment meet the specific I
requirements of the codes, standards, or specifications.
3.
The effectiveness of the control of quality by vendors shall be assessed at intervals consistent with the importance, complexity and quantity of the product or service.
9.2 Procurement Review 1.
Documents initiating procurement of safety related, fire protection related, and 10CFR71 related material, equipment and services shall be subject to a review to ensure applicable regulatory requirements, design bases, quality assurance, and other requirements are adequately satisfied.
2.
Quality assurance requirements shall include identification of applicable elements of ANSI N45.2-1971 (or equivalent) that are required to be included in the vendor's quality assurance program.
9.3 Vendor Evaluation and Verification 1.
The adequacy of vendor's quality assurance program specified in procurement documentation shall be verified prior to use of the procured material, equipment, or service. Vendor's adherence to their quality assurance program to the extent appropriate for the procured material, equipment or service shall be verified.
2.
Vendor evaluations shall include inspections, audits, or surveillances as appropriate.
These activities shall be planned and performed in accordance with written procedures based upon procurement document requirements.
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Page 25 of 104
I Operational Quality Assurance Plan Revision 20 3.
Material and equipment may be procured and used based on appropriate certificates of conformance, provided the validity of such certificates are periodically evaluated by audits, independent inspection or tests and that such certificates comply with j
applicable code provisions.
1 9.4 Receipt htspection 1.
Material and equipment shall be inspected upon receipt at the site prior to use or storage to determine that procurement requirements are satisfied. This inspection shall i
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include verification that required documentation is complete.
l 2.
Nonconforming material and equipment shall be controlled to assure such material or i
equipment is not utilized to fulfill a safety related, fire protection related or 10CFR71 related function prior to an acceptable resolution of the discrepancies.
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Operational Quality Assurance Plan Revision 20 10.0 Identification and Contro! of Materials, Parts and Components 10.1 General Requirements 1.
Measures shall be established for the identification and control of materials, parts and components, including partially fabricated assemblies. These measures shall assure that identification of the item is maintained by heat number, part number, serial number or other appropriate means, either on the item or on records traceable to the item, as required throughout fabrication, erection, installation and use of the item.
2.
These identification and control measures shall be designed to prevent the use of incorrect or defective material, parts and components.
10.2 Spare Parts Control 1.
Spare parts held for future use on safety related, fire protection related, and 10CFR71 related components shall be controlled in such a manner that assures they will perform their safety function when utilized.
2.
Measures shall be taken which assures these items are in an appropriate condition for use or will be placed in such a condition prior to use.
10.3 Material Control Material held in storage for use on safety related, fire protection related, and 10CFR71 related systems, stmetures or equipment shall be controlled in such a manner as to prevent its degradation and to assure the rejection ofincorrect or defective material. This material shall be identified by heat number or other appropriate means, either on the item or on records traceable to the item. The method utilized in identification shall not significantly affect the fit, function, or quality of the item being identified.
10.4 ReceiptInspection Material, pans and components that are to be utilized to fulfill a safety related, fire protection.
related, and 10CFR71 related function or used for shipment of radioactive materials shall be inspected upon receipt to assure that associated procurement document provisions have been satisfied. Measures shall be established for identifying nonconforming material, parts and components.
10.5 Nuclear Fuel Control Measures shall be established to protect special nuclear material against theft or diversion in accordance with applicable NRC regulations.
Page 27 of 104
Operational Quality Assurance Plan Revision 20 i
11.0 Control of Special Processes
{
11.1 General Requirements Measures shall be established to assure that special processes, including welding, heat treating, l
and non-destructive examination are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, i
criteria and other special requirements.
11.2 Welding Procedures 1.
Safety related welding and brazing shall be performed in accordance with qualified i
procedures. Safety related welding and brazing procedures shall be qualified in i
accordance with applicable codes and standards and shall be reviewed to assure their technical adequacy and approved by management.
l 2.
Measures shall be established for controlling welding and brazing procedures that assure such procedures are qualified, reviewed and approved, as required, prior to use.
11.3 Welder Qualification i
1.
Measures shall be established that assure safety related welding and brazing is performed by quahfied personnel. Welders and brazers shall be qualified, and l
requalified, in accordance with applicable codes and standards.
2.
Measures shall be established for controlling welder and brazer qualification and requalification that assure qualified personnel are uti'ized to perform safety related welding and brazing.
11.4 Heat Treating Procedures 1.
Heat treating shall be performed in accordance with procedures formulated and approved in accordance with applicable codes and standards.
2.
Measures shall be established for controlling heat treating procedures that assure such l
procedures are qualified, reviewed, and approved, as required, prior to use.
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Page 28 of104 4
l Operational Quality Assurance Plan Revision 20 12.0 Inspection and Examination 12.1 General Requirements 1.
Measures shall be established for the inspection and examination ofitems or activities affecting quality to verify conformance to specified requirements for the purpose of determining acceptability.
2.
Verification ofitems shall be performed for each work operation where necessary to assure quality. Ifverification of processed items is impossible or disadvantageous, j
indirect control by monitoring processing methods, equipment and personnel shali be provided.
3.
Both verification and process monitoring shall be provided when control is inadequate without both.
4.
If mandatory inspection hold points, wliich require withessing or inspection and beyond which work shall not proceed without prior consent are required, the specific hold points shall be indicated in appropriate documents.
5.
Personnel performing required inspections or examinations shall be qualified in accordance with applicable codes, standards and training programs.
6.
Inspections and examinations shall be performed by individuals other than those who
)
performed or directly supervised the activity being inspected or examined.
12.2 Plant Operation 1.
Measures shall be established that assure periodic inspection of safety related and fire protection related systems, components, and stmetures. Such inspection of plant systems and equipment shall be performed to assure that such systems and equipment are in the required status and configuration. Routine general inspections of the accessible plant facilities to verify appropriate safety measures are maintained including fire protection shall also be performed.
2.
An inspection of the core shall be performed prior to startup followir.g refueling to assure specified fuel and reactor internal configuration.
3.
Personnel performing plant operation inspections shall be qualified based upon experience, training applicable to area ofinspection and training in inspection methods.
Page 29 of 104
...-em Operational Quality Assurance Plan Revision 20 12.3 Inservice Inspection
)
1.
Measures shall be established that assure inservice inspection examinations are performed in accordance with applicable provisions of the ASME Boiler and Pressure Vessel Code,Section XI as required by 10CFR50.55a.
2.
Personnel performing inservice inspections shall be qualified in accordance with ANSI N45.2.6-1978, as modified by Regulatory Guide 1.58, Revision 1.
12.4 Inspection of Maintenance and Modifications 1.
Measures shall be established which assure that activities associated with plant maintenance and modifications are inspected when determined appropriate by quality or other qualified personnel. Such inspections shall include verification that:
a.
Appropriate procedures are available, b.
Plant equipment control exists, c.
Applicable procedures are adhered to, d.
Qualified personnel are utilized, e.
Fire protection measures are established, f.
Radiation protection measures are established, g.
Appropriate materials and replacement parts are utilized, h.
Work is completed as required, i.
Plant equipment is returned to service as required, J.
Activities are appropriately documented, and k.
Redundant equipment is available.
2.
Personnel performing inspections of plant maintenance and modifications shall be qualified based upon experience, training applicable to area ofinspection and training in inspection methods.
Page 30 of 104
Operational Quality Assurance Plan Revision 20 12.5 Modifications and Non-Routine Maintenance :
1.
Measures shall be established which assure that non-routine maintenance and modification receive prior review by a qualified individual to identify applicable inspections. Such reviews shall include considering: (1) required mechanical inspections, electrical inspections, instmmentation and control inspections, structural inspections, and inspection of non-NDE special processes, (2) appropriate inspection procedures, and (3) appropriate qualification ofinspection personnel.
2.
Measures shall also be established which assure that the results ofidentified inspections are evaluated by a qualified individual to verify their adequacy.
3.
Personnel performing inspections of modifications and non-routine maintenance shall be qualified in accordance with ANSI N45.2.6-1978, as modified by Regulatory Guide 1.58, Revision 1.
1 12.6 Technical Services 1.
Measures shall be established which assure that activities associated with technical
' services (such as surveillance testing, instrument calibration, laboratory services, etc.)
are inspected when determined appropriate by quality c,r other qualified personnel.
~
2.
Personnel performing inspections of technical services shall be qualified based upon experience, training applicable to area ofinspection and training in inspection methods.
12.7 Receipt Inspection Measures shall be established which assure that received items are inspected by personnel qualified in accordance with ANSI N45.2.6-1978, as modified by Regulatory Guide 1.58, i
Revision 1.
12.8 VendorInspection Measures shall be established which assure that verifications and process monitoring specified in appropriate procurement documents for items are performed by personnel qualified in accordance with ANSI N45.2.6-1978, as modified by Regulatory Guide 1.58, Revision 1.
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I Page 31 of104
Operational Quality Assurance Plan Revision 20 12.9 Fire Protection Inspections Measures shall be established which assure that fire protection inspections are performed in l 32 accordance with Appendix C, Section 14.0.
12.10 Radioactive Material Packages 1.
Measures shall be established which assure that packages utilized to ship licensed radioactive material off-site are inspected in accordance with the applicable provisions of 10CFR71.
2.
Personnel performing inspections of radioactive material packages shall be qualified based upon experience, training applicable to area ofinspection and training in inspection methods.
12.11 Emergency Equipment 1.
Measures shall be established which assure that emergency equipment required to implement emergency plans is inspected when determined appropriate by qualified personnel.
2.
Personnel performing emergency equipment inspections shall be qualified based upon experience, training applicable to area ofinspection and training in inspection methods.
12.12 Handling Equipment i
1.
Measures shall be established which assure that plant handling equipment (such as cranes, lift trucks, fuel handling tools) is inspected when determined appropriate by Generation Quality Services personnel or other qualified personnel.
2.
Personnel performing inspections of handling equipment shall be qualified based upon experience, training applicable to area ofinspection and training in inspection methods.
12.13 Nondestructive Examination Measures shall be established which assure that the following examinations are performed by personnel qualified in accordance with the American Society of Nondestructive Testing Recommended Practice No. SNT-TC-1 A.
1.
Radiographic Testing (RT).
2.
Ultrasonic Testing (UT).
Pc 32 of104
Operati:rri Qrlity Assurance Plan Revision 20 3.
Magnetic Particle Testing (MT).
4.
Liquid Penetrant Testing (PT).
i 5.
)
+
1 6.
Neutron Radiographic Testing (NRT).
7.
Leak Testing (LT).
12.14 Inspection and Examination Procedures 1.
Required inspections and examinations shall be performed in accordance with
{
appropriate instructions, procedures, and checklists. Such instructions, procedures, 4
and checklists shall contain a description of objectives, acceptance criteria and prerequisites for performing the inspections or examinations. These procedures shall also specify any special equipment or calibrations required to conduct the inspection or i
examination. Inspection and examination results shall be documented and evaluated
{
by responsible aLthority to assure that inspection and examination requirements have been satisfied.
- 2. -
Where activities are to be inspected or examined, the activity procedure shall identify hold points in the activity sequence to permit inspection or examined. The activity procedure shall require appropriate approval for the work to continue beyond the designated hold point and identification of those performing the inspection. The -
procedure or checklist shall require recording the date, identification of those performing the inspection or examination, and as-found condition.
1 Page 33 of104
Operational Quality Assurance Plan Revision 20 13.0 Test Control 13.1 General Requirements 1.
Measures shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable documents. Proof tests prior to installation, preoperational tests, and operational tests during nuclear power plant operation, of structures, systems and components shall be included as appropriate.
2.
Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. Test results shall be documented and evaluated to assure that test requirements have been satisfied.
13.2 Surveillance Tests 1.
A surveillance test program shall be established to assure that testing required to demonstrate that safety related and fire protection related structures, systems, and components will perform satisfactorily in service. Surveillance tests shall be identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable documents. The surveillance test program shall include, as a minimum, those surveillance tests specified in applicable Technical Specifications and functional Inservice Inspection testing of pumps and valves. Surveillance requirements for fire detection and protection systems in other areas of the plants shall be developed using appropriate NFPA for guidance.
2.
Surveillance test results shall be documented and evaluated to assure that test requirements have been satisfied or deficient items satisfactorily resolved. Functional Inservice Inspection tests shall be performed by personnel qualified in accordance with applicable requirements.
13.3 Preoperational and Operational Tests Measures shall be established to assure that appropriate preoperational and operational tests are performed on safety related and fire protection related structures, systems and components that have been subject to modification or significant maintenance. Such tests shall be performed in accordance with the original design and testing regnrements or acceptable alternatives. Test results shall be documented and evaluated to assure that test requirements have been satisfied or deficient items satisfactorily resolved.
Page 34 of 104
l Opercti:n:1 Qurlity Assurcnce Plan l
Revision 20 l
l 13.4 ProofTests Measures shall be established to assure that appropriate proof tests are specified in procurement documents for safety r:, lated and fire protection related replacement material and equipment and that such tests are performed and documented prior to installation.
13.5 Special Tests 1.
Monticello - Measures shall be established that assure safety related tests are reviewed l 33 1
and approved as required by 10CFR50.59 and applicable Technical Specifications.
Such tests shall be performed in accordance with appropriate procedures. Test results shall be documented and evaluated to assure test requirements have been satisfied.
2.
Prairie Island - Measures shall be established that assure safety related tests are 33 reviewed and approved as required by 10CFR50.59 and applicable requirements of this document. Such tests shall be performed in accordance with appropriate procedures. Test results shall be documented and evaluated to assure test requirements have been satisfied.
13.6 Personnel Qualincation Personnel performing. ;uired tests shall be qualified based upon experience, training applicable to area of testing and training in testing methods, unless otherwise specified by applicable codes.
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Page 35 of 104
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Operational Quality Assurance Plan i
Revision 20 i
14.0 Control of Measuring and Test Equipment 1
t 14.1 General Requirements Measures shall be established to assure that tools, gauges, instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated and adjusted at specified periods to maintain accuracy within necessary limits.
14.2 Installed Plant Instnunentation t
Measures shall be established to assure that installed safety related plant instrumentation is maintained and calibrated at specified periods to maintain accuracy within necessary limits.
i Maintenance and calibration of safety related instrumentation shall be performed in i
accordance with appropriate procedures and shall be controlled and documented.
l 14.3 Measuring and Test Instrumentation Measures shall be established to assure that tools (micrometer, calipers, etc.), gauges, instruments and other inspection, measuring, test equipment and devices used to verify conformance to established requirements are maintained and calibrated at specified periods to l
maintain accuracy within necessary limits. Calibration of such measuring and test eqmpment i
shall be controlled and shall be traceable to the National Institute of Standards and j
Technology or where national standards are not available, the basis of calibration shall be documented, i
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Page 36 of 104
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Operati:nal Quality Assurance Plan Revision 20 15.0 Handling, Storage and Shipping 15.1 General Requirements 1.
Measures shall be established to control the handling, storage, shipping, cleaning and preservation of safety related material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.
2.
When necessary for particular products, special protective environments such as inen gas atmosphere, humidity levels, and temperature levels, shall be specified and identified.
15.2 Storage Facilities Storage facilities shall be provided at each operating nuclear plant for storage of safety related i
and fire protection related operating and maintenance supplies, spare parts, replacement parts, replacement equipment, materials and tools. These storage facilities shall assure physical protection and protection from environmen:al conditions including temperature and moisture as appropriate. Storage facilities shall be arranged and equipped to facilitate control of the stored safety related items.
15.3 Nuclear Fuel Storage Areas shall be provided for storage of nuclear fuel which assure physical protection, subcritical arrangement, adequate cooling, adequate radiation shielding and containment of radioactive material as appropriate for the condition of the stored fuel.
15.4 Radioactive Material Storage j
1.
Areas shall be provided for storage of radioactive material which assure physical protection, as low as reasonably achievable radiation exposure to personnel, control of i
the stored material, and containment of radioactive material as appropriate.
2.
Handling, storage, and shipment of radioactive material shall be controlled based upon the following criteria:
Established safety restrictions concerning the handling, storage, and shipping of a
packages for radioactive material shall be followed.
b.
Shipments shall not be made unless all tests, certifications, acceptances, and final inspections have been completed.
Work instructions shall be provided for handling, storage, and shipping c.
operations.
4 Page 37 of 104
- d emp Operational Quality Assurance Plan Revision 20 15.5 Storage Control Stored material, parts and equipment shall be controlled in a manner that assures safe plant operation when and if the items are utilized. Stored safety related and fire protection related items shall be controlled to assure that the item will perform its safety function when utilized.
15.6 Material Handling Safety related material, supplies, equipment and parts shall be handled in accordance with procurement documentation and in accordance with appropriate material handling practices.
Material handling equipment shall be subject to periodic testing and preventive maintenance which assures its operability Appropriate operating instnictions and procedures shall be provided for handling equipment.
15.7 Shipping and Packaging 1.
Shipping and packaging requirements shall be prepared for material, equipment, and components that are to be shipped off-site and returned for use at a nuclear plant to perform a safety related function. Such requirements shall assure that the item's safety related function is not significantly degraded while in transit.
2.
Shipping and packaging documents for radioactive material shall be consistent with pertinent requirements of 10CFR71.
Page 38 of104
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Revision 20 l
16.0 Inspection, Test and Operating Status l
1 16.1 General Requirements l
1.
Measures shall be established to indicate, by the use of markings such as stamps, tags, l
labels, routing cards, or other suitable means, the status ofinspections and tests l
performed upon individual items of the nuclear plant. These measures shall provide for the identification ofitems which have satisfactorily passed required inspections and tests, where necessary to preclude inadvertent bypassing of such inspections and tests.
2.
Measures shall also be established for indicating the operating status of structures, systems and components of the nuclear power plant, such as by tagging valves and switches to prevent inadvertent operation.
16.2 Maintenance Control 1.
Measures shall be established for the control of maintenance to safety related and fire protection related structures, systems and components that assure that:
a.
Affected structures, systems and components are removed from service and secured in a manner consistent with operability and isolation requirements of the Technical Specifications.
b.
Repair and modification activities are performed in a manner consisten: with its importance to safety.
c.
Upon completion of repairs and modifications the affected structures, systems and components are inspected and tested to determine that the required work was performed satisfactorily and that they will perform their safety function in the required manner.
2.
In addition, measures shall be established to control maintenance activities that assure resulting radiation exposure to personnel is maintair.ed as low as reasonably achievable (ALARA) and consistent with pertinent NRC regulations.
3.
The aLye measures shall be implemented by utilizing appropriate work authorization processes, work procedures, safety tagging, bypass control, key control and area j
l posting, as appropriate, for the involved activity.
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Page 39 of 104
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Opercti::tl Qurlity Assurcece PI:n l
Revision 20 16.3 Test Control
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1.
Measures shall be established for the control of tests to safety related and fire protection related structures, systems and components that assures that:
a.
Proposed tests are reviewed and approved as required prior to performance.
I b.
The plant is placed in an acceptable status prior to the test, maintained in an acceptable status during the test, and returned to its normal status upon completion of the test.
l c.
- Test results are reviewed and approved as appropriate.
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2.
The above measures shall be implemented by utilizing appropriate work authorization processes, test procedures, safety tagging, bypass control, and key control, as -
L appropriate, for the involved test.
16.4 Safety Tagging A safety tagging program shall be developed and utilized for control of nuclear plant equipment. This program shall contain provisions for uniquely identifying components whose operation is restricted or prohibited based upon safety considerations. Provisions shall be made for review, application, independent verification, removal, and documentation of such tagging.
16.5 Key Control l
Measures shall be established for controlling keys for safety related and fire protection related l
switches or key devices important to plant security. These measures shall include restricted l
distribution and periodic inventory of such keys or key devices.
16.6 ' Bypass Control l
1.
Measures shall be established for controlling the application of devices utilized to bypass component functions that are important to safety. Such measures shall assure l
that:
Proposed bypasses to safety related and fire protection related items are a.
reviewed to determine that the plant will be placed in an acceptable status when the bypass is applied.
b.
Applied bypasses are independently verified.
Page 40 of 104 l
Oper:tioni Qu-lity Assurnce Pla Revision 20 c.
Removal of bypasses from safety related and fire protection related items are reviewed prior to removal.
d.
Application of bypasses to safety related and fire protection related items is autherized by responsible personnel.
2.
The application of safety related and fire protection related bypasses shall be considered a temporay measure and shall be reviewed periodically.
3.
All required activities associated with the application, review, approval snd removal
.(
shall be documented.
16,7 Radioactive Material Control Inspection, test, and operating status of equipment and components associated with shipment of radioactive material shall be established based upon the following ' criteria:
1.
Inspection, test, and operating status of packages for radioactive material shall be indicated and controlled by established procedures.
2.
Status shall be indicated by tag, label, marking or log entry.
3.
Status of non-conforming parts or packages shall be positively maintained by established procedures.
16.8 Reactor Startup and Restart Control Measures shall be established for controlling reactor startups and restarts. Such measures shall assure that safety related systems, components and stmetures have been placed in the required status and reviews have been completed to assure that the cause of any reactor trip (scram) has been investigated and satisfactorily resolved.
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Page 41 of 104 1
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"4fM Operational Quality Assurance Plan Revision 20 17.0 Nonconforming Materials, Parts or Components i
17,1 General Requirements 1.
Measures shall be es' alished to control materials, parts, or components which do not conform to requirernents in order to prevent their inadvertent use or installation.
These measures sht11 include, as appropriate, procedures for identification, t
documentation, segregation, disposition and notification to affected organizations.
l 2.
Nonconformance items shall be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures.
17.2 Receipt Inspection i
i 1.
Measures shall be established which assure that safety related and fire protection related material, supplies, equipment, and components are inspected to determine that they conform to specified requirements of pertinent procurement documents upon i
receipt at the site. The absence of required documentation or discrepant documentation shall constitute nonconformance.
2.
Provisions shall be made for identifying nonconforming items and for segregation of nonconforming items. Nonconforming items shall not be used to fulfill a safety related and fire protection related function until the discrepancy is satisfactorily resolved.
17.3 Maintenance Inspection Equipment, components or parts found nonconforming in a manner that could significantly affect its ability to fulfill its safety related and fire protection related function shall be identified as a nonconforming item and shall be segregated or otherwise controlled to prevent inadvertent use or installation when physical segregation is not practical. Nonconforming items shall not be used until the discrepancy is satisfactorily resolved.
17.4 Disposition of Nonconforming Items j
1.
Measures shall be established which assure that noncer. forming items are disposer', of i
in a manner which prohibits their inadvertent use or installation. Provisions shalt be made for reviewing the nonconformance and correcting discrepancies by repair or i
rework if appropriate.
Page 42 of 104
Operational Quality Assurance Plan Revision 20 2.
The acceptability of such rework or repair of materials, parts, components, systems, and stmetures shall be verified by reinspection and retesting the item as originally inspected and tested or by a method which is equivalent to the originalinspection and i
testing method. Inspection, testing, rework, and repair procedures shall be documented.
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3.
Normally, nonconforming safety related and fire protection related items shall not be l
installed prior to satisfactory resolution ofoutstanding discrepancies. In exceptional cases nonconforming items may be installed provided specific action is taken, which assures the item is not utilized to fulfdl a safety function, prior to resolution of the discrepancy.
17.5-Nonconformance Documentation l.
Nonconformance reports shall be initiated for significant deviations from specified requirements. Such reports shall identify the nonconforming item, describe the nonconformance, the disposition of the nonconformance, and the inspection requirements. Nonconformances shall be reviewed and approved.
2.
Nonconformance reports shall b periodically analyzed to show quality trends and the results of this review shall be reported to the appropriate level of management for review and assessment.
17.6 Reporting Measures shall be established which assure that defects as defined in 10CFR21 and failures to comply with the Atomic Energy Act of 1954, as amended, or any applicable rule, regulation, order or license of the NRC relating to a substantial safety hazard are reported in accordance with the applicable requirements of 10CFR21.
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Page 43 of104
Op:rcti:n:1 Qurlity Assurance Plan Revision 20 18.0 Corrective Action 18.1 General Requirements 1.
Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, discrepancies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude recurrence.
2.
The identification of the condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reponed to appropriate levels of management.
18.2 Operating Occurrences and Events 1.
Monticello - Measures shall be established which assure that operating occurrences l 34 and events that could have a significant safety effect are investigated, reviewed, and reported as required by the Technical Specifications. Such measures shall assure that appropriate coirective action is taken and that the event or occurrence is reponed to responsible levels of management. Corrective action includes provisions which preclude recurrence.
2.
Prairie Island - Measures shall be established which assure that operating occurrences 34 and events that could have a significant safety effect are investigated and reviewed in accordance with the requirements of this document, and reported as required by the 35 Technical Specifications. Such measures shall assure that appropriate corrective action is taken and that the event or occurrence is reported to responsible levels of management. Corrective action includes provisions which preclude recurrence.
i 18.3 Administrative Control Discrepancies Measures shall be established which assure that significant discrepancies identified during quality assurance program audits are reported to those responsible for the activity and to appropriate levels of management. These mecsures shall include corrective action designed to preclude recurrence of the discrepancies identified and verification ofimplementation.
Page 44 of 104
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i Operational Quality Assurance Plan j
Revision 20 1
19.0 Quality Assurance Records 19.1 General Requirements 1.
Sufficient records shall be maintained to furnish evidence of activities affecting quality.
These records shall include at least the following:
a.
Operating logs and the results of reviews, inspections, tests, audits, monitoring -
of work performance and material analysis.
b.
The records shall also include closely related data such as qualifications of
)
personnel, procedures, and equipment.
c.
Inspection and test records shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.
j 2.
Records shall be identifiable and retrievable.
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3.
Requirements shall be established concerning record retention, such as duration, location, and assigned responsibility which are consistent with applicable regulatory requirements.
19.2 Operating Records i
Measures shall be established which assure that records as they apply to plant operation are generated and retained as required by Section 19.12, (applicable to Prairie Island only), the 36 Monticello Technical Specifications or other regulatory requirements.
i 19.3 Plant Modification Records Measures shall be established which assure that adequate records are generated and retained to reconstruct plant modifications that are safety related or fire protection related.
19.4 Plant Maintenance Records Measures shall be established which assure that records pertaining to maintenance of plant safety related and fire protection related structures, equipment and components are generated and retained.
19.5 Personnel Qualification Records Measures shall be established which assure personnel qualification records are generated and retained.
Page 45 of 104
1 Operational Quality Assurance Plan l
Revision 20 19.6 Procurement Records Measures shall be established which assure that safety related, fire protection related, or
)
10CFR71 related procurement documents and associated documents are generated and retained.
j I
19.7 Surveillance Test Records j
Measures shall be established which assure that records associated with Surveillance Testing, including Inservice Inspections, are generated and retained.
19.8 Audit Reports Measures shall be established which assure records pertaining to audits of quality activities are generated and retained.
l 19.9 Radioactive Material Control Measures shall be established which assure that records associated with radicactive material control are generated and maintained.
19.10 Drawings Measures shall be established which assure that records of drawing changes made to plant safety related and fire protection related structures, equipment and components are generated and retained.
19.11 Records Management 1.
Records management systems shall be established which assure that the required records are collected, stored, and maintained in accordance with ANSI N45.2.9-1974.
Such records shall at least be stored in insulated filing devices (rated 350-1 hour oy UL as to fire resistance only) located in areas hav'mg combustible loading ofless than 5 lb/sq ft, or duplicate records shall be maintained in remote locations. Specific records j
shall be identified in implementing or source documents. Identification shall indicate records required by Technical Specifications, committed to standards, and other regulatory documents.
2.
Records management systems shall be established which assure that those records used to demonstrate program implementation are collected, stored, and maintained in accordance with good records management practices. Such systems shall assure that these records are made available to auditors and inspectors in a timely manner.
4 Page 46 of 104
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i I
I Operational Quality Assurance Plan j
Revision 20 19.12 Prairie Island Operating Records 37 1.
Records Retained for Five Years I
Records and logs relative to the following items shall be retained for at least five years:
a.
Normal plant operation including such items as power level, period of operation at each level, fuel exposure and shutdown.
b.
Written shift supervisory and reactor logs.
c.
Periodic checks, inspections, tests and calibrations of components and systems, j
as related to Technical Specifications 1
)
d.
Reviews of changes made to procedures or equipment or reviews of tests and i
experiments.
e.
Principal maintenance activities, including inspection, repairs and substitution or replacement of principal items of equipment pertaining to nuclear safety.
f.
Records of changes to plant procedures and records of special tests and experiments.
g.
Records of wind speed and direction.
I h.
Records ofinditidual plant staff members showing qualifications, training and re-training.
i.
Reportable occurrences.
2.
Records Retained for the Life of the Plant Records and logs relative to the following items shall be retained for the life of the plant:
Liquid and airborne radioactive releases to the environs.
a.
b.
Radiation exposures for all plant personnel, visitor and contract personnel, c.
Off-site environmental monitoring surveys.
d.
Fuel accountability including new and spent fuel inventories and transfers and fuel assembly histories.
e.
Radioactive shipments.
Page 47 of 104 4
-. -. ~.. -.-.. =.
-_ Operational Qurlity Assure:ce Pl:a Revision 20 '
- f. -
Plant radiation and contamination surveys.
37 g.
Changes made to the plant as it is described in the Final Safety Analysis Report, reflected in updated, corrected and as-built drawings.
h.
Cycling beyond normal limits for those components that have been designed to operate safely for a limited number of cycles beyond such limits.
l f
i.
Reactor coolant system in-service inspections.
l j.
Minutes of meetings of the Safety Audit Committee.
I t
k.
Records of the service lives of all safety related snubbers, including the date at j
which the service live commences and associated installation and maintenance records.
4 i
i 4
i i
i Pagd48 of104 -
.x
l Oper tirri Qu-lity Assurcnce PI:n Revision 20 20.0 Audits 20.1 General Requirements A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the Operational Quality Assurance Program and to determine the effectiveness of the program. The audits shall be performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibility in the areas being audited. Audit results shall be documented and reviewed by management having responsibility in the area audited. Follow-up action, including re-audit of discrepant areas, shall be taken where indicated.
20.2 Required Audits Measures shall be established which assure that the provisions of the Operational Quality Assurance Program are audited periodically. In addition, an overall audit shall be performed periodically which determines the adequacy of the program with respect to requirements contained in the Operational Quality Assurance Plan. This overall audit shall be performed by an organiation other than that responsible for administration or implementation of the program.
20.3 Audit Schedules 1.
Required audits shall be performed with a frequency adjusted to objective evaluation 38 of plant functional area performance provided that the maximum audit interval does not exceed two years, except where audit intervals are defined by regulation, commitment, or by Appendix C, Section 14, for fire protection audits.
39 2.
Special audits may be scheduled on the initiative of Generation Quality Services l39 personnel based upon suspected or known discrepancies or as directed by management.
3.
Appropriate audit schedules shall be prepared each year.
l 39 20.4 Audit Procedures Require i m...: shall be performed in accordance with appropriate audit procedures.
Checklists may be used as audit procedures or in conjunction with audit procedures.
i Procedures shall include auditing requirements at various levels of the Operational Quality l
Assurance Program.
l l
Page 49 of104
.g.
..f Operational Quality Assurance Plan i
' Revision 20 20.5 ' Audit Reports j
i A
1.
Reports of the results of each audit shall be prepared. These reports shall include a j
description of the area audited, identification ofindividuals responsible for j
implementation of the audited provisions and for performance of the audit,
' i identification of discrepant areas, and recommended corrective action as appropnate.
1 2.
Audit reports shall be distributed to the appropriate management level and to those
'l individuals responsible for implementation of audited provisions.
i 3.
Audit reports and associated nonconformance reports shall be periodically analyzed for j
quality trends and the results reported to the appropriat' level of management for l
review and assessment.
j i
-20.6 Corrective Action l
1 Measures shall be established which assure that discrepancies identified by audits or other l
means are resolved. These measures shall include notification of the manager responsible for the discrepancy, recommended corrective action, and verification of satisfactory resolution.
j Discrepancies shall be resolved by the manager responsible for the discrepancy. Line
?
. management shall resolve disputed discrepancies.
l l
4
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l
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' Page 50 of 104
I Operctiomal Quality Assurance Plan Revision 20 21.0 Prairie Island Safety Audit Committee (SAC) 1 21.1 General Requirements The Safety Audit Committee provides the independent review of plant operations from a nuclear safety standpoint. Audits of plant operation are conducted under the cognizance of the SAC.
21.2 Membership i
1.
The SAC shall consist of at least five (5) persons.
2.
The SAC chairman shall be an NSP representative, not having line responsibility for plant operation, appointed by the Vice President Nuclear Generation. Other SAC members shall be appointed by the Vice President Nuclear Generation or by such other person as he may designate. The Chairman shall appoint a Vice Chairman from the SAC membership to act in his absence.
3.
No more th:m two members of the SAC shall be from groups holding line responsibility for operation of the plant.
4.
A SAC member may appoint an alternate to serve in his absence, with concurrence of the Chairman. No more than one alternate shall serve on the SAC at any one time.
The alternate member shall have voting rights.
j 21.3 Qualifications 1.
The SAC members should collectively have the capability required to review activities in the following areas: nuclear power plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, instrumentation and control, radiological safety, mechanical and electrical engineering, quality assurance practices, and other appropriate fields associated with the unique characteristics of the nuclear power plant.
i 2.
When the nature of a particular problem dictates, special consultants will be utilized, as necessary, to provide expert advice to the SAC.
21.4 Meeting Frequency The SAC shall meet on call by the Chairman but not less frequently than twice a year.
Page 51 of 104 W
Operational Quality Assurance Plan Revision 20 21.5 Quorum 1
1.
No less than a majority of the permanent members or their alternates, including the SAC Chairman or Vice Chairman.
2.
No more than a minority of the quorum shall be from groups holding line responsibility for the operation of the plant.
21.6 Responsibilities The following subjects should be reported to or reviewed by the SAC:
1.
Written safety evaluations of(l) changes in the facility, (2) changes to procedures, and (3) tests or experiments completed without prior NRC approval under the provisions of 10 CFR 50.59 to verify that such changes, tests or experiments did not involve a change in the Appendix A Technical Specifications or an unreviewed safety question as defined in 10 CFR 50.59.
2.
Proposed changes to procedures, changes in the facility, tests and experiments which may involve a change in the Appendix A Technical Specifications or an unreviewed safety question as defined in 10 CFR 50.59. Matters of this kind shall be referred to the SAC following their review by the onsite operating organization.
1.
Proposed changes in Appendix A Technical Specifications or proposed license amendments relating to nuclear safety.
4.
Violations of applicable codes, regulations, orders, Appendix A Technical Specifications, and license requirements or internal procedures or instructions having nuclear safety significance.
1 5.
Significant operating abnormalities or deviations from normal and expected performance of plant safety-related structures, systems, or components.
l 6.
Investigation of all Reportable Events and events requiring Special Reports to the Ccmmission.
7.
Revisions to the Facility Emergency Plan, Facility Security Plan, and the Fire Protection Program.
8.
Operations Committee minutes to determine if matters considered by that Committee involve unreviewed or unresolved safety questions.
9.
Other nuclear safety matters referred to the S AC by the Operations Committee, plant management or company management.
Page 52 of104
Operati=1 Qu:lity Assurarce Pim Revision 20 l
10.
All recognized indications of an unanticipated deficiency in some aspect of design or I
operation of safety related stmetures systems, or components.
I 1.
Reports of special inspections and audits conducted in accordance with Appendix C, 40 Section 14.0.
12.
Changes to the Offsite Dose Calculation Manual (ODCM).
13.
Review ofinvestigative reports of unplanned release of radioactive material to the environs.
21.7 Audit l
The operation of the nuclear power plant shall be audited formally under the cognizance of the SAC to assure safe facility operation.
1.
Audits of selected aspects of plant operation, as delineated in Paragraph 4.5 of ANSI 41 N18.7-1976, shall be performed with a frequency commensurate with their nuclear safety significance and in a manner to assure that an audit of all nuclear safety related activities is campleted within a period of two years. The audits shall be performed in accordance with appropriate written instmetions and procedures.
2.
Audits of aspects of plant radioactive efIluent treatment and radiological environmental monitoring shall be performed as follows:
a.
Implementation of the Offsite Dose Calculation Manual at least once every two
- years, b.
Implementation of the Process Control Program for solidification of radioactive wastes at least once every two years.
c.
The Radiological Environmental Monitoring Program and the results thereof, including quality controls, at least once every year.
3.
Periodic review of the audit program should be performed by the SAC at least twice a year to assure its adequacy.
4.
Written reports of the audits shall be reviewed by the Vice President Nuclear Generation, by the SAC at a scheduled meeting, and by members of management having responsibility in the areas audited.
l Page 53 of 104
Operztirn:1 Qutlity Assurcnce PI:n Revision 20 21.8 Authority i
The SAC shall be advisory to the Vice President Nuclear Generation.
21.9 Records Minutes shall be prepared and retained for all scheduled meetings of the Safety Audit Committee. The minutes shall be distributed within one month of the meeting to the Vice President Nuclear Generation, each member of the SAC and others designated by the Chairman. There shall be a formal approval of the minutes.
21.10 Procedures A written charter for the S AC shall be prepared that contains:
1.
Subjects within the purview of the group.
2.
Responsibility and authority of the group.
I 3.
Mechanisms for convening meetings.
4.
Provisions for use of specialists or subgroups.
5.
Authority to obtain access to the nuclear power plant operating record files and operating personnel when assigned audit functions.
6.
Requirements for distribution of reports and minutes prepared by the group to others in the NSP organization.'
Page 54 of104
. ~ _..
Opercti:ml Qurlity Assurcnce Plan Revision 20 22.0 Prairie Island Operations Committee (OC) 2 22.1. Membership i
1.
The Operations Committee shall consist of at least six (6) regular members drawn i
from the key supervisors of the onsite staff. The. key supervisors include, at least, the j
following positions: Plant Manager, General Superintendent Plant Operations, General
{
Superintendent Plant Maintenance, General Superintendent Radiation Protection and
{
Chemistry and plant engineering supervisors.
l 2.
Alternates to the regular members shall be designated in writing by the Chairman to I
serve on a temporary basis. No more than two alternates shall participate as voting members of the Operations Committee at any one time.
3.
The Plant Manager shall serve as Chairman of the OC and shall appoint a regular member to act as Chairman in his absence.
22.2 Meeting Frequency The Operations Committee will meet on call by the Chairman or as requested by individual members and at least. monthly.
22.3 Quonim A majority of the membership, including the Chairman.
22.4 Responsibilities 1
The following subjects shall be reviewed by the Operations Committee:
1.
Proposed tests and experiments and their results.
2.
Modifications to plant systems or equipment as described in the Updated Safety Analysis Report and having nuclear safety significance or which involve an unreviewed l
safety question as defined in Paragraph 50.59 (c), Part 50, Title 10, Code of Federal Regulations.
i l
3.
Proposals which would effect permanent changes to normal and emergency operating l
procedures and any other proposed changes or procedures that will affect nuclear l
safety as determined by the Plant Manager.
4.
Proposed changes to the Technical Specifications or operating licenses.
Page 55 of104
i Operati::ci Qu:lity Ass ra ce Pla Revision 20 5.
All reported or suspected violations of Technical Specifications, operating license 2
requirements, administrative procedures, operating license requirements, administrative procedures, operating procedures. Results ofinvestigations, including i
evaluation and recommendations to prevent recurrence will be reported in writing to the Vice President Nuclear Generation and to the Chairman of the Safety Audit Committee.
6.
Investigations of all Reportable Events and events requiring Special Reports to the Commission.
7.
Drills on emergency procedures (including plant evacuation) and adequacy of communication with offsite support groups.
8.
Procedures required by Technical Specifications, including implementing procedures of the Emergency Plan, the Security Plan, and the Security Contingency Plan (except 27 as exempted in Section 8.4-4.c), shall be reviewed initially and periodically with a 43 frequency commensurate with their safety significance but at an interval of not more than two years. Maintenance work orders and their associated procedures shall be 29 reviewed per the requirements of Section 8.4-5.
44 9.
Special reviews and investigations, as requested by the Safety Audit Committee.
10.
Review ofinvestigative reports of unplanned releases of radioactive material to the environs.
I1.
All changes to the Process Control Program (PCP); and the Offsite Dose Calculation Manual (ODCM).
12.
The n eview of safety evaluations, when safety evaluations are required by 10 CFR Part 50, Section 50.59, for procedures or procedure changes to verify that such actions do not constitute an unreviewed safety question.
13.
Fire Protection Program and implementing procedures and the submittal of recommended changes to the Safety Audit Committee.
22.5 Authority The OC shall be advisory to the Plant Manager. In the event of a disagreement between the recommendations of the OC and the Plant Manager, the course determined by the Plant Manager to be the more conservative will be followed. A written summary of the disagreement will be sent to the Vice President Nuclear Generation and the Chairman of the SAC for resiew.
Page 56 of104 e
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I Oper ti::ci Qurlity Assur nce Pl:2 Revision 20 t
22.6 Records 2
Minutes shall be recorded for all meetings of the OC and shall identify all documentary
}
material reviewed. The minutes shall be distributed to each member of the OC, the Chairman i
and each member of the Safety Audit Committee, the Vice President Nuclear Generation and j
others designated by the OC Chairman.
22,7 Procedures A written charter for the OC shall be prepared that contains:
1.
Responsibility and authority of the group 2.
Content and method of submission of presentations to the Operations Committee 3.
Mechanism for scheduling meetings 4.
Provision for meeting agenda 5.
Use of subcommittees 6.
Review and approval, by members, of OC actions 7.
Provision for distribution of minutes l
)
l Page 57 of 104 1
Operati:n:1 Q ality Assure:ce Pir.n Revision 20 l
[This page intentionally blank]
l Page 58 of 104 4
Oper;ti:=1 Qu:lity Assur=ce PI:n Revision 20 Appendix A APPENDIX A Monticello Structures, Systems, and Components Subject to Appendix B of10CFR50 l
1.
STRUCTURES Reactor Building Plant Control and Cable Spreading Structure Off Gas Stack
)
Intake Structure (Service Water pump area)
Diesel Generator Building j
Diesel Fuel Oil Day Tank Rooms i
Turbine Building (parts which house, support and/or protect safety related equipment)
Off Gas Compressor and Storage Building (parts which house, support and/or protect safety related equipment) i Emergency Filtration Train (EFT) Building
)
d Underground Duct Bank (EFT 3 Floor to Reactor Building) l 45 l
- 2. -
MECHANICAL SYSTEMS AND COMPONENTS 2.1 Reactor Coolar.t System Reactor Vessel Reactor Vessel Support Skirt Reactor Vessel Stabilizer Recirculation System Piping Recirculation System Pumps and Valves Main Steam Piping (to and including outermost containment isolation valve)
Main Steam Safety Relief Valves Main Steam Safety Relief Valve Discharge Piping Feedwater Piping (to and including outermost containment isolation valve)
Control Rod Drive Housing Supports 2.2 Reactor Vessel Internals Fuel Assemblies Core Support Structure j
Jet Pumps t
Liquid Poison Pipe Core Spray Sparger l
Page 59 of l04
Operttinti Qu:.lity Assurcnce PI:n Revision 20 Appendix A i
2.3 Control Rod Drive System Control Rod Drives Control Rod Drives Accumulators Scram Discharge Volume Scram Piping l
2.4 Standby Liquid Control System SLC Tank SLC Pumps SLC Explosive Valves SLC Piping 2.5 Primary Containment l
Drywell
^
Torus i
Drywell Vent Piping / Vacuum Breakers Torus Ring Header and Downcemers Containment Penetrations Containment Piping and Valves (to and including outermost isolation valve) 2.6 Secondary Containment l
RB Ventilation Isolation Dampers Standby Gas Treatment Filters and Fans j
i 2.7 Residual Heat Removal System RHR Piping, Pumps and Valves RHR Heat Exchangers (shell side)
{
2.8 Core Spray System Core Spray Piping, Pumps, and Valves
)
2.9 High Pressure Coolant Injection System l
HPCI Steam Piping and Valves Inside Containment (to and including outermost isolation valve)
HPCI Steam Supply and Exhaust Piping and Valves (outside containment)
]
HPCI Pump-Turbine HPCI Injection Piping and Valves IFCI Suction Piping Page 60 of 104
Op rati:cti Qurlity Assurance Pl:n Revision 20 Appendix A 2.10 Reactor Core Isolation Cooling System RCIC Steam Piping and Valves Inside Containment (to and including outermost i
isolation valve).
l RCIC Steam Supply and Exhaust Piping and Valves (outside containment)
RCIC Pump-Turbine RCIC Injection Piping and Valves RCIC Suction Piping
)
2.11 Service Water System t
i Emergency Service Water Pumps Emergency " / ice Water Piping and Valves RHR Service Water Pumps i
RHR Heat Exchanger (tube side)
RHR Service Water Piping and Valves i
EFT Emergency Service Water Pumps, Piping, and Valves
(
4 2.12 Reactor Water Cleanup System RWCU Piping and Valves (to and including outermost isolatie i valve) 2.13 Spent Fuel Storage Systems Spent Fuel Pool j
2.14 Diesel Generator Support System Air Start System from Receivers to Air Start Solenoids Fuel Oil System from Day Tank to injectors Diesel Coolers and Associated Piping and Valves (water side)
Diesel Fuel Oil 2.15 Heating and Ventilating System Emergency Filtration Train (EFT) for Control Room and EFT Building Combustible Gas Control System i
SECTION 2 NOTES:
1.
Mechanical components included within each mechanical system include hangers (up to and including the first anchor supporting a safety related section of piping),
fittings, flanges, vessels, tanks, etc. as necessary to perform the system safety functions.
Page 61 of 104
Opercti:n:1 Quility Assurance Plin 5
Revision 20 Appendix A 3.
ELECTRICAL SYSTEMS AND COMPONENTS i
1 I
3.1 4160 Volt Bus 16 1
Breaker 152-602, 601, 609, 610, Feed Breaker 408 RHR Service Water Pump B Motor RHR Service Water Pump D Motor RHR Pump B Motor RHR Pump D Motor i
Core Spray Pump B Motor 480 Volt Load Center 104 No.12 CRD Pump Feed Breaker 152-606 i
3.2 4160 Volt Bus 15 Breaker 152-502, 501, 509, 511, Feed Breaker 308
)
RHR Service Water Pump A Motor RHR Service Water Pump C Motor RHR Pump A Motor RHR Pump C Motor Core Spray Pump A Motor 480 Volt Load Center 103 No. I1 CRD Pump Feed Breaker 152-506 3.3 480 Volt Switchgear Load Center 104 480 V MCC 142 (1)(Essential) 480 V MCC 143A (1) 480 V MCC 143B (1) 480 V MCC 144 - (1) 3.4 480 Volt Switchgear Load Center 103 i
480 V MCC 133A (1) 480 V MCC 133B (1) 480 VMCC 134 (1) 3.5 Diesel Generator No.1I (1) 3.6 Diesel Generator No.12 (1) 3.7 250 V DC (Division 1) Distribution Panel D31 (1) 3.8 250 V DC (Division 2) Distribution Panel D100 (1)
Page 62 of 104 1-
Operctizatl Qu lity Assurcnce Pirn Revisi:n 20 Appendix A 3.9 125 V DC Distribution Pai el D-11 (1) 3.10 125 V DC Distribution Panel D-21 (1) 3.11 120/240 Volt AC Instnimentation Distribution Panel (1)
SECTION 3 NOTES:
1.
For those electrical systems or components designated with the Note (1) above, quality assurance electrical program requirements are applicable only to those portions of systems as defined in Secs. 2 as necessary to perform the system safety function.
2.
Electrical components included within each electrical system include power source, breaker, control circuit, cable, reh,ving and operating device (motor, solenoid, heater, relay, etc.) as necessary to perform the system safety function.
3.
Cenain components are excluded from the quality assurance program requiremenM if they meet the criteria described in Section 5.
4.
INSTRUMENTATION SYSTEMS AND COMPONENTS l
4.1 Reactor Protection System 4.2 Primary Containment Isolation System 4.3 High Pressure Coolant Injection System Initiation and Isolation 4.4 Reactor Core Isolation Cooling System Initiation and Isolation 4.5 Core Spray System Initiation 4.6 Low Pressure Coolant Injection System Initiation 4.7 Automatic Blowdown System 4.8 Neutron Monitoring System (IRM and APRM) 4.9 Standby Gas Treatment System Initiation 4.10 SJAE OfrGas Radiation Monitor Page 63 of 104
Oper ti:n 1 Qurlity Assurance PI:n Revision 20 Appendix A 4.11 EFT System Initiation and Operation 4.12 Combustible Gas Control System SECTION 4 NOTES:
1.
. For those instrumentation systems designated above, quality assurance instmmentation program requirements are applicable only to those portions of systems dermed in Section 2 as necessary to perform the system safety function.
2.
Instmmentation components included within each instmmentation system include power supply, sensors, relays, wiring and final operating device (solenoid, relay, etc.) as necessary to perform the system safety function.
3.
Cedain components are excluded from the quality assurance program requirements if they meet the criteria described in Section 5.
5.
ELECTRICAL AND INSTRUMENTATION SYSTEM COMPONENT EXCLUSION CRITERIA 5.1 Any component of an electrical system in Section 3 or instrumentation system in Section 4 is excluded from the quality assurance program requirements ifit meets the following criteria:
A failure of the component by electrical shorting, open circuiting, grounding or a.
mechanical failure would not render the system incapable of performing its intended safety function.
b.
A failure of the fluid pressure boundary of the component would not render the system incapable of performing its intended safety function.
i 1
5.2 Small spare parts having no traceability, such as commercial off-the-shelfitems, may be purchased as nonsafety-related and then qualified for use in equipment requiring quality i
assurance. Examples of such items are resistors, capacitors, switches, indicators, coils, wire, connectors, solid state devices and miscellaneous hardware.
1 Page 64 of 104
.w
Operati : 1 Quality Assurance PI:n Revision 20 A ipendix B l
l APPENDIX B Prairie Island Structures, Systems, and Components Subject to Appendix B of 10CM50 1.
REACTOR SYSTEM AND FUEL
)
1.1 Reactor Vessel and Coolant System
)
i Reactor vessel Reactor vessel support Reactor vesselinternals Full length control rod drive mechanis m housing Part length control rod drive mechanism housing Steam generator (tube side and shell side)
Pressurizer, including instmmentation, piping, and components i
Reactor coolant hot and cold leg piping, fittings Surge pipe, fittings Loop bypass line Temperature detector bypass manifold Reactor coolant thermowell
)
Reactor coolant thermowell boss Safety valves Reliefvalves Reactor coolant system boundary valves Control rod drive mechanism head adapter plugs j
Reactor coolant pump j
Pump casing i
Main flanges Thermal barrier Seal housing Pressure retaining bolting Reactor coolant pump motor Shaft coupling Flywheel Reactor coolant pump internals RCC thimble plug (rod control clur,rs)
Primary and secondary sources Electric modules with safety function Cable with safety function 1.2 Fuel Assemblies Fuel assemblies, sub-assemblies, components and materials, including fuel material Page 65 of104
i Oper:tir:tl Qu:lity Assur:nce Pirn Revision 20 Appendix B 2.
REACTIVITY CONTROL SYSTEMS Drive mechanisms including:
l
=
Control rod cluster drive shaft assembly, including latch assembly l
Reactor trip breakers Control rods and rod cluster assemblies i
Control rod guide tube Control rod drive housing Electric modules with safety function 1
Cable with safety function 3.
CHEMICAL AND VOLUME CONTROL SYSTEM ~
q Regenerative heat exchanger Letdown heat exchanger Reactor coolant filter Volume control tank Dositive displacement charging pump pressure boundary l 46 Seal water filter Letdown orifices and letdown valves Excess letdown heat exchanger l
Seal water heat exchanger Boric acid tanks Boric acid transfer pump Boric acid filter Reactor coolant pump seal and bypass orifice Piping, inboard ofisolation valves Electric modules with safety function Cable with safety function Heat tracing 4.
INCORE INSTRUMENTATION Thimble guide tubes
. Seal table 5.
BORON RECYCLE SYSTEM Recycle holdup tanks, piping and valves associated with gaseous radioactive waste Page 66 of 104 T
I j
Oper:tir:cl Qu lity Assurance PI:n
_ Revision 20 Appendix B i
6.
EMERGENCY CORE COOLING SYSTEM 4
Accumulators High head safety injection pumps 4
j Piping, inboard ofisolative valves j
Motors, electric modules, with safety function I
Cable with safety function j
7.
CONTAINMENT SPRAY SYSTEM Refueling water storage tank Spray additive tank 4
Spray pumps Spray sings and nozzles Piping and valves Pump motors
[
Electric modules with safety function Cable with safety function 2
8.
RESIDUAL HEAT REMOVAL SYSTEM Pumps and motors j'
Heat exchanger l
Piping and valves with safety function Electric modules with safety function Cable with safety function
(
9.
SPENT FUEL POOL COOLING SYSTEM i
l Piping and valves whose failure could result in significant release of pool water i
?
10.
CONTAINMENT FAN COOLER SYSTEM
)
i Ductwork
-l l
Fans Dampers F
Fan coolers Electric modules with safety function j_
' Cable with safety function i
!~
Page 67 of 104
1 Oper:ti:n:1 Qurlity Assurance Pirn Revision 20 Appendix B t
11.
WASTE PROCESSING SYSTEM l
Gaseous and liquid waste piping and valves forming part of containment boundary Systems handling gaseous radioactive materials e
Electric modules with safety function Cable with safety function l
NOTE:The Waste Gas Disposal System shall be maintained in accordance with the f
. guidance established in Regulatory Guide 1.143, Revision 1, October 1979.
12.
SAMPLING SYSTEMS Valves and piping from the reactor coolant system up to the second isolation valve outside l
containment Valves and piping to the first isolation valve from other safety related systems 13.
STEAM GENERATOR BLOWDOWN i
Piping from steam generator to containment isolation valves 14.
REACTOR PROTECTION SYSTEM Electrical modules l
Cable 15.
PROCESS RADIATION MONITORS i
Radiation Monitors, including electric modules and cable with a safety function, associated i
with the Shield Building, Auxiliary Building, Spent Fuel Pool and Control Room j
Ventilation Systems i
16.
CONTAINMENT HYDROGEN CONTROL SYSTEM Piping and valves with safety function j
Electric modules and cable 1
17.
REACTOR VESSEL SERVICE EQUIPMENT Containment polar crane Vessel head handling equipment Crane structural supports Crane electrical, cable, controls and instrumentation with safety function Page 68 of104 a
Operati:=1 Qu lity Assurance PI:n Revision 20 Appendix B 18.
REFUELING EQUIPMENT 2
Spent fuel cask Auxiliaq Building crane Auxiliary Building crane stmetural supports 2
Crane electrical, cable controls and instmmentation with safety function Fuel transfer tube Spent Fuel Bridge Crane i
Manipulator Crane 19.
FUEL STORAGE New fuel racks Spent fuel racks Spent fuel pool structure and enclosure Spent fuel storage casks Independent spent fuel storage installation concrete pads 20.
CONTROL ROOM PANELS Electric modules, with safety function Cable with safety function 21.
LOCAL PANELS AND RACKS Electric modules with safety function j
Cable with safety function i
22.
MAIN STEAM SYSTEM Main steam piping and valves from steam generators up to and including piping restraints downstream of the main steam isolation valves Main steam piping and valves from main steam lines to auxilian feedwater pump turbine Steam line flow restrictor Safety and relief valves Piping to first isolation valves and safety and relief valve discharge Electric modules with safety function Cable with safety function 23.
FEEDWATER SYSTEM Feedwater piping and valves inside containment stmeture up to and including first isolation valve outside containment structure Electric modules with safety function i
Cable with safety function Page 69 of 104 i
i Operzti:xl Qurlity Assur=ce Pirn Revision 20 Appendix B l
24.
AUXILIARY FEEDWATER SYSTEM Piping and valves supplying auxiliary feedwater from and including containment isolation valves to connections with feedwater lines Auxiliary feedwater pumps (turbine and motor-driven)
Piping and valves supplying auxiliary feedwater from the cooling water system f
. Electric modules with safety function Cable with safety function i
25.
COOLING WATER SYSTEMS Component cooling water systems (essential) l Piping (except to turbine building and non-essential equipment) j Heat exchangers, with safety function Pumps Pump motors Surge tank Valves, isolation Valves, other, with safety function Electric modules with safety function Cable with safety function Cooling water systems (essential)
Piping (except to turbine building and non-essential equipment)
Diesel engine pumps Strainers, with safety function Valves, isolation Valves, other, with safety function Screen wash systems, with safety function Traveling screens, with safety function Electric modules with safety function Cable with safety function Diesel engine pump auxiliaries as follows:
Diesel oil storage tanks Day tanks Fuel oil transfer pumps and motors Fuel oil piping and valves with a safety function Starting air compressors Air receivers
_ Starting air piping and valves with a safety function.
Cooling water piping and valves with a safety function Electric modules with safety function Cable with safety function Diesel engine, lubricating oil and jacket cooling systems Diesel fuel oil Page 70 of104 E
t Opersti:nal Qurlity Assurcnce Plan Revision 20 - Appendix B r
1 26.
INSTRUMENT AIR SYSTEM Piping and valves associated with containment penetration 27.
DIESEL GENERATOR (DI, D2, D5, D6) l 47 l
1 Diesel oil storage tanks i
Day tanks Pumps and motors, fuel oil transfer Diesel filter Valves, with safety function l
Piping / Supports except vent and fill piping downstream oflast valve Cooling water system pipe and valves Diesel generatorjacket cooling water system components with a safety function Diesel generator lubricating oil system components with a safety function Air intake and exhaust, and compo'nents with a safety function Electric modules with safety function Cable with safety function Diesel fuel oil Compressor (D1 and D2 only)
Air receivers Compressor Piping / Supports and valves from receiver to diesel generator 47 Compressor Piping between compressor and receiver (D1 and D2 only)
I h
p t
f i
d i
i; Page 71 of104 v
=
Oper;ti:rl Quility Assur nce PI:n Revision 20 Appendix B 28.
ELECTRICAL SYSTEMS l 48 Switchgear, transformers, motor control centers, load centers, batteries and chargers, and associated equipment with safety function NOTE: Point ofinterface with onsite electric power systems (i.e., at point ofinterface with Class IE breakers which isolate main Class IE onsite buses from the offsite power system; and including components and circuitry interfaces that affect the proper performance of such interfacing breaker).
4,160 - 480 V switchgear from enginee ed safety systems (ESF), including ESF buses 4,160 - 480 V transformers (ESF load centers) 480 - 120/208 V transformers (control room and ESF area emergency lighting) 480 V switchgear (ESF load centers) 480 V motor control and motor control centers 125 V station batteries and racks (control and vital instrumentation power supplies) 125 V de panels and switchgear (vital de power distribution) 120 V ac instrument bus panels (vital instrumentation ac power distribution)
Containment penetration assemblies Main control board Radiation monitor panel Hot shutdown panel Control room air conditioning control panel Post LOCA Hydrogen control panel Emergency lighting Emergency communications Diesel generator and accessories Diesel generator control panels Relay boards and racks Wire and cable raceway system Underground electrical duct bank system Cable system (power, control and instmmentation)
Instrument racks Electrical supports Heat tracing / freeze protection 29.
INSTRUMENTATION AND CONTROL SYSTEM COMPONENTS l 48 Reactor trip system Engineered safety features (ESF) actuation system Systems required for safe shutdown Safety related instmments, tubing and fittings Page 72 of 104 m
4 Oper ti: nil Qurlity Assur:nce Plzn Revision 20 Appendix B 30.
HEATING, VENTILATION AND AIR CONDITIONING SYSTEMS (HVAC) l 48 Control and Relay Room HVAC System Air handling units Fans, ductwork and dampers Filters 3
Chillers and chilled water pumps j
Auxiliary Building Special Ventilation System
.. Fans, ductwork and dampers
]
Filters Screenhouse Ventilation System -
Fans and dampers associated with diesel engine ventilation Shield Building Ventilation System i~
Fans, ductwork and dampers Filters I
Battery Room'Special Ventilation System Fans, ductwork and dampers Spent Fuel Pool Special Ventilation System Exhaust fans, ductwork, dampers Exhaust filters
~
l Dl/D2 Diesel Generator Rooms Cooling System 1
Fans, ductwork and dampers.
Auxiliary Building Normal Ventilation System 3
q
]
Ductwork and dampers associated with steam exclusion j
. Turbine Building Ventilation System 1-Ductwork and dampers associated with steam exclusion i
D5/D6 Building Heating, Ventilation, Cooling and Exhaust Systems with safety functions -
l l
Electric modules with safety function i
Cable with safety function i
HVAC sensors and monitors having safety function -
i j.
4 4
4 3
J 1
4 1
j Page 73 of104
Operati:nr1 Quility Assurance PI:n -
Revision 20 Appendix B l
l 31.
CIVIL STRUCTURES AND FOUNDATIONS l 48 l
l Containment and structures l
Containment airlocks l
Containment isolation (valves, piping, canisters) i Containment penetrations Shield building Auxiliary building Control room Diesel generator room (D1 and D2)
Radwaste building Cooling water intake structure Electrical tunnels, with safety function Pipe tunnels, with safety function Shielding structures Turbine Building (housing emergency diesel generator, cooling wz r pipes, batteries, safeguards switchgear, auxiliary feedwater pumps)
D5/D6 Building I
32.
OTHER l 48 A.
Fire protection system piping associated with the safeguards ventilation exhaust filters and containment penetration B.
Turbine building crane Crane stmetural support Crane electrical, cable, controls and instrumentation with safety function l
Page 74 of 104 3
Op:rcti:n:1 Qurlity Assurance PI:n Revision 20 Appendix C APPENDIX C Nuclear Plant Fire Protection Program 1.0 Policy Statement Northern States Power Company (NSP) has established a system of Administrative Control Directives (ACDs) that implement the Operational Quality Assurance Plan. This system shall be used to implement the requirements of the operating nuclear power plant fire protection program. The basic requirements of the fire protection program are specified in this appendix to the Operational Quality Assurance Plan.
2.0 Organization 2.1 General Requirements 1.
NSP shall be responsible for the establishment and implementation of the fire protection program. NSP may delegate to other organizations the work of establishing and implementing the fire protection program, or any part thereof, but shall retain responsibility for the program.
2 The authority and duties of persons and organizations involved in the fire protection program shall be clearly established and delineated in writing.
l 3.
To assure adherence to the fire protection program, management measures shall be established which provide that the individual or group assigned the responsibility for checking, a'iditing, inspecting, or otherwise verifying that an activity has been correctly performed is qualified and does not have responsibility for performing or directly supervising the work except that:
a.
The individual or group assigned the responsibility for auditmg is independent of the individual or group directly responsible for perfornung i
the specific activity.
2.2 Fire Protection Organization Summary The NSP organization is summarized in Section 3.0 of the Operational Quality Assurance Plan. In addition to that summary, the following additional responsibilities shall pertain to the fire protection program.
1.
Director Generation Quality Services a.
Scheduling and assuring completion ofindependent off-site fire protection inspections and audits.
Page 75 of 104
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Operzti:n:1 Qu:lity Assurence PIIn Revision 20 Appendix C =
' 2.
Monticello and Prairie Island Plant Managers 1
a.
Routine inspection of the plant for fire hazards.
I l
b.
Establishing plant fire brigades.
L.
1 l
_ c.
Ensuring that fire brigade members receive required training and physical '
i evaluations.
d.
Coordinating fire drills and determining their effectiveness.-
Establishing cooperation with the local fire department,' including joint-i e.
drills and training sessions to familiarize fire department personnel with plant access routes, layout, equipment, and special hazards.
i f.
Establishing storage requirements to insure no additional fire hazards are created.
j 4
g.
Establishing a surveillance program for fire protection systems and fire
]
fighting equipment.
1 h.
Establishing a system to control nonconforming items.
)
[
i.
' Reviewing required work processes for fire hazards and possible reduction -
of fire protection system effectiveness.
I j.
Reviewing modifications to determine if they would cause an unreviewed fire hazard or reduce the effectiveness of the fire protection systems.
k.
Establishing a fire salvage program (when required).
1.
Reviewing purchase requisitions that are related to fire protection.
Developing instmetions for fighting fires in specific areas and identifying m.
effects of fires in specific areas.
Preparing news release information for NSP's Communications
' n.
Department.
o.
Procurement of equipment for the Sre brigades.
p.
Establishing a policy for the security acthns to be taken by the guard force during a fire.
i 1
Page'76'of104 5
~,._;---...---,
i
.Op:re.ti:nr1 Qurlity Assuranca Plin I
j Revision 20 Appendix C f
)
3.
Manager Training (Monticello and Prairie Island) l 49 l
i 4
[
a.
Establishing a training program for the fire brigades.-
2.3 Fire Protection Engineer
{'
l.
A fire protection engineer (or engineering consultant) shall be used to provide the l
following types ofservices:
{
Review of design for a significant modification to a fire protection system.
a.
4 1
l b.~
Review ~of proposed plant modifications which would introduce major
-)
hazards not analyzed in the Fire Hazards Analysis.
i t-I.
c.
- Triennial independent fire protection inspections (see Section 14.2).
9 1
2.
The fire protection engineer (or engineering consultant) shall meet the following qualifications:
a.
A graduate of an engineering curriculum of accepted' standing who has a.
completed not less than six years of engineering attainment indicative of growth in engineering competency and achievement, three of which shall have been in responsible charge of fire protection engineering work, QC b.
A member in the Society of Fire Protection Engineers.
3.0 Nuclear Plant Fire Brigades 3.1 Monticello 1.
A fire brigade shall be established in accordance with the requirements of 10CFR50, Appendix R, Section III.H, and the requirements listed below:
a.
Fire brigade composition may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate the unexpected absence of fire brigade members. Under this circumstance, immediate action shall be taken to restore the fire brigade to within the minimum requirements.
Page 77 of 104
Operatiscal Qu:lity Assurance Pirn Revision 20 Appendix C 3.2 Prairie Island 1.
A fire brigade of five persons shall be on-site at all times in addition to the
)
minimum shift crew complement needed to safely shut down the unit (s).
Fire brigade composition may be less than the minimum requirements for a a.
period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate the unexpected absence of fire brigade members. Under this circumstance immediate action shall be taken to restore the fire brigade to within the j
minimum requirements.
j i
2.
Each fire brigade shall have an appointed leader. This leader shall not be the Shift Supervisor (the Unit No.1 Shift Supervisor at Prairie Island).
i 3.
All new members of the fire brigades shall have an initial physical examination for j
strenuous physical activity as experienced in fire fighting. Annual follow-up physical examinations shallinclude respiratory protection qualification testing which screens all respirator users (including fire brigade members) for cardiopulmonary deficiencies. Physical examinations shall be conducted by a physician. A program shall be established by NSP's corporate physician to ensure that all respirator users, when subject to even the most severe working conditions, are physically fit to wear a respirator. The program shall include pulse, blood pressure, and spirometry testing, and a medical history review in which the possibility of past or present heart disease is determined. The program shall be administered by nursing personnel who will perform the necessary cardiopulmonary screening function.
t 4.0 Fire Protection Training
)
4.1 Monticello and Prairie Island 1.
Level I fire protection training shall be general training given to operations and maintenance personnel assigned to nuclear power plants. Following initial training, these topics shall be reviewed at least annually with required personnel. Level I shall cover, as a minimum, the following areas:
a.
Basic principles of fire chemistry and physics.
b.
Fire hazards.
1)
Common fire hazards.
2)
Combustibles, general.
Page 78 of 104 A
i
Oper tical Qu lity Assur:nce Pl:n Revision 20 Appendix C 3)
Flammable liquids.
l 4)
Flammable gases.
I c.
Fire detection systems.
)
d.
Types of extinguishing systems.
l e.
Special fire hazards associated with nuclear power plants.
f.
Emergency Plan with emphasis on fire emergency.
i 2.
Basic instruction in fire protection shall be given to contractor personnel before granting them unescorted access to safety related areas of the plant.
4.2 Monticello 1.
Fire brigade training shall be conducted in accordance with the requirements of
)
10CFR50, Appendix R,III.I.
4.3 Prairie Island 1
1.
Level II fire protection training shall be given to all fire brigade members. An initial training program with annual retraining shr.ll be conducted. Retraining shall repeat all Level II subject material over a period of approximately two years.
Level II shall include a detailed treatment of the subject matter in Level I. In addition, the following items shall be covered:
a.
The identification and location of fire hazards and associated types of fires that could occur in the plant.
b.
The identification and location of fire fighting equipment in each fire area.
c.
Familiarization with layout of the plant including access and egress routes in each area.
d.
The proper use of fire fighting equipment.
e.
Methods of fighting each type of fire.
f.
Review of the plant fire fighting strategies with specific coverage of each individual's responsibilities.
i Page 79 of 104
Oper;ti:n:1 Qu:lity Assur:nca PI:n Revision 20 Appendix C g.
Proper use of communication, lighting, ventilation and emergency breathing equipment.
h.
Considerations of radiation and contamination in fire areas.
2.
Level III training shall be presented to the fire brigade leaders. Initial training with annual retraining shall be provided. Included will be a detailed review of Level I and II training and the following additional material:
a.
The direction and coordination of fire fighting activities.
b.
The proper method of fighting fire inside buildings and confined areas.
c.
Evaluation of fire hazards.
3.
Training Documentation Classroom training sessions, practice sessions, and drills for the fire brigade shall be documented. The following should be included in the documentation for 4
persons participating:
a.
Name.
b.
Date.
c.
Summary of what was done.
d.
Evaluation by observer.
5.0 Drills and Practice 5.1 Monticello 1.
Fire protection drills and prac':< shall be conducted in accordance with the requirements of 10CFR50, A pr ndix R,Section III.I, and the requirements listed beloci:
a.
A meeting shall be held after each drill to discuss the drill and the need to repeat portions of the training program that are applicable to the type of drill performed.
b.
Preplanned strategies, and the proficiency of brigade members and control room operators in their use shall be tested during drills.
Page 80 of104
OpIratim! Qu:lity Assurance PI:n Revision 20 Appendix C c.
Each year, one drill, conducted with any fire brigade, shall involve the local on-duty fire department.
t 5.2 Prairie Island 1.
Drills i
Drills shall be scheduled so that each fire brigade will participate in at least a.
four drills per year. The following types of drills shall be scheduled:
1)
Involve local on-duty fire department. This shall be done at least oned a year, with any fire brigade.
2)
At three year intervals, a randomly selected, announced drill shall be critiqued by qualified individuals independent of NSP's staff.
3)
Back shift, conducted by the fire brigade leader on duty at the time.
This shall be scheduled at least once per year for each brigade.
b.
Except as required above, drills may be announced and may involve only the shift fire brigade members (to preclude the disruption of essential plant activities).
c.
All drills shall be preplanned and critiqued. A meeting shall be held after each drill to discuss the drill and the need to repeat portions of the training program that are applicable to the type of drill performed.
d.
To the extent practical, fire brigade members shall use protective equipment, suppression systems, and other equipment used to fight an actual fire during all drills. Preplanned strategies shall be tested during.
drills as well as the proficiency of brigade members and Control Room operators in their use.
2.
Practice a.
Practice sessions shall be held at least once every year. These sessions shall involve actually fighting fires which are similar to those which might be encountered in the plant. These sessions shall include:
1)
Use of fire fighting equipment.
l 2)
Use of breathing equipment under strenuous conditions.
i l
l I
Page 81 of 104
Operatirn:1 Qurlity Assurance PI:n j
. Revision 20 Appendix C j
3)
Extinguishment of fire.
I 4).
Best method by which to approach each type of fire, to the extent possible.
b.
Brigade members missing a practice session shall be rescheduled to attend a later session with another brigade. If this is not possible, they shall be r
required to review the training material covered during the practice session.
i I
i i
. 6.0 Control of Combustibles and Ignition Sources 6.1 Monticello 1
i 1.
Control of combustibles and ignition sources shall be in accordance wit, the l
requirements of 10CFR50, Appendix R, Section III.K, and the requirements listed below:
l a.
All areas containing safety related equipment or cables shall be surveyed i
once each working day for fire hazards by a member of the plant staff.
l b.
Storage of combustible materials shall be permitted only in posted areas or.
in approved cabinets and containers.
c.
Transient combustibles in any safety related area, or area containing safe'
' shutdown equipment, shall be limited to the equivalent of 2 gallons of combustible liquid. Use oflarger amounts of combustible material shall be l
governed by written procedures which specify augmented fire protection
.}
measures.
l i
d.
A person designated as a fire watch and equipped to prevent and combat fire shall be assigned to safety related areas where cutting, welding, grinding and open flame work is involved.'
e.
The fire watch shall remain in the assigned area for 30 minutes after work involving the cutting,' welding, grinding, or open flame is completed.
1)
When excessive radiation exposure to the fire watch is a concern, alternate fire watch measures may be implemented if these alternate measures address how to detect, prevent and combat a fire in the fire watch area.
Page 82 of 104 Y
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Oper tirnil Quility Assurance Pl:n Revision 20 Appendix C l
f.
Where feasible, all movable combustible material below or within 35 feet of l
cutting, welding, grinding, or open flame work shall be removed, and all immovable combustibles below or within 35 feet shall be protected.
g.
Smoking shall be prohibited in all safety related areas, except those specifically designated by the plant management.
6.2 Prairie Island 1
1.
Permanent and Temporary Storage Measures shall be established to minimize fire hazards in areas cor.taining a.
safety related equipment or equipment required to safely shut down the reactor (s) which:
)
1)
Govern the handling and limitation of the use of ordinary combustible materials, combustible and flammable gases and liquids, high efficiency particulate air and charcoal filters, dry ion exchange resins, or other combustible supplies in safety related areas.
2)
Govern the removal from the area of all waste, debris, scrap, oil spills, or other combustibles resulting from the work activity immediately following completion of the activity, or at the end of each work shift, whichever comes first.
1 3)
Govern the handling of transient fire loads such as combustible and i
flammable materials during maintenance, modification, or refueling operations.
4)
Govern the use of specific combustibles in safety related areas.
a)
All wood used in safety related areas during maintenance, modification, or refueling operations (such as laydown blocks or scaffolding) shall be treated with a flame retardant.
b)
All untreated wood in safety related areas (during operations other than maintenance, modification or refueling) shall be limited to less than 2 cubic feet per area.
l c)
Equipment or supplies (such as new fuel) shipped in untreated l
combustible packing containers may be unpacked in safety I
related areas if required for valid operating reasons.
However, all combustible materials shall be removed from the area immediately following the unpacking.
t Page 83 of104
Oper:.ti:n:1 Q=lity Assurcnce Plan Revision 20 Appendix C d)
Large amounts of combustible material shall not be left unattended during lunch breaks, shift changes, or other similar periods.
e)
Loose combustible packing material such as wood or paper and excelsior shall be placed in metal containers with tight-fitting self-closing metal covers.
b.
All areas containing safety related equipment or cables shall be surveyed once each working day for fire hazards by a member of the plant staff.
Storage of combustible materials shall be permitted only in posted areas or in approved cabinets and containers. Unnecessary transient combustibles shall not be stored in areas containing safety related equipment or areas containing safe shutdown equipment or other essential auxiliary equipment area (e.g., HVAC equipment room).
c.
Transient combustibles in any safety related area or area containing safe shutdown equipment shall be limited to the equivalent of 2 gallons of combustible liquid. Use oflarger amounts of combustible material shall be governed by written procedures which specify augmented fire protection measures.
2.
Cutting, Welding, Grinding and Open Flame Cutting, welding, grinding and open flame work in safety related areas shall a.
be administratively controlled. A person designated as fire watch and equipped to prevent and combat fire shall be assigned to safety related areas where cutting, welding, grinding and open flame work is involved.
The fire watch shall remain in these assigned areas for 30 minutes after the work involving the cutting, grinding or open flame is completed.
1)
When excessive radiation exposure to the fire watch is a concern, alternate fire watch measures may be implemented if these alternate measures address how to detect, prevent and combat a fire in the fire watch area.
b.
Where feasible, all movable combustible material below or within 35 feet of cutting, welding, grinding, or open flame work shall be removed and all immovable combustibles below or within 35 feet shall be protected.
Page 84 of 104 1
r l
Operati:nti Qu:lity Assurance Pirn -
Revision 20 Appendix C I
l Smoking shall be prohibited in all safety related areas, except those c.
i
- specifically designated by.the plant management.
j d.
Fire barrier penetration leak testing shall be done with approved and reviewed procedures. Permission to do this leak testing shall be obtained from the Shift Supervisor.
7.0 Fire Fighting Procedures
[
.7.1-Monticello l
Fire fighting procedures shall be established in accordance with the requirements of '
10CFR50, Appendix R, Section III.K.
7.2 Prairie Island i
1.
Fire fighting procedures or instructions shall be developed to cover the following
(
areas:
J l
}
- a. -
Discovery of fire including:
1 p
1)
Notification.
3 1
j 2)
Attempts to extinguish fire.
4 l
b.
Action of Control Room operator including:
b 1)
Announcement.
2)
Sounding of fire alarm.
3)
Who to notify.
4 c
Selection and delineation of responsibilities of fire brigade members.
l I
d.
Coordination of off-site fire department activities.
e.
Actions of security guards during a fire emergency.
j i
f.
Delineation of responsibilities of other plant personnel.
i 1
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f.y
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Operati:nal Qu:lity Assurcnce Plen Revision 20 Appendix C g.
Instmetions and preplanned strategies for fighting fires in specific areas of the plant when the generalinstructions are not adequate. These instructions shallinclude:
1)
Identification of combustibles in area.
2)
Identification of safe shutdown equipment in area and alternate equipment available for performing that function.
3)
Fire suppression equipment available in the area.
4)
Information showing ventilation control (power sources), access hallways, stairs,'and doors.
5)
Identification of plant systems that should be managed to reduce the damage potential from a fire in the area.
6)
Identification of radiological and toxic hazards in the area.
7)
Ventilation system lineups to minimize spread of smoke and to remove smoke from the area.
8)
Identification of actions which must be coordinated with operations personnel.
2.
Instructions and preplanned strategies shall be tested during drills.
8.0 Modification Control (Monticello and Prairie Island) 8.1 Review of modifications for possible impact on plant fire protection provisions shall be performed if determined required by a designated member of the plant technical staff. The following guidelines shall be used in making this determination:
1.
Could the modification present a hazard not considered in the Fire Hazards Analysis? Will additional analysis be required?
2 Could the modification have the potential to interfere with installed fire protection equipment or does it modify existing fire protection equipment?
3.
Could the fire protection system require modification because of the change?
Page 86 of104 i'
Oper:ti:n:1 Qu:lity Assurance Pirn Revision 20 Appendix C 8.2 If a fire protection review is required, the individual assigned to perform the review shall use the following as a guide:
1.
Does the modification reduce the fire protection provisions for safety related or
" safe shutdown" equipment?
2.
, Will it be necessary to do a fire hazards analysis?
3.
'Does the design present an obstruction to installed fire protection equipment?
4.
Will the installation of the equipment temporarily remove a fire protection system from service?
5.
Does the modification involve thermal stress relieving and, if so, have precautions been taken?
6.
Will any fire barriers be affected by the modification?
8.3 A modification shall be allowed to proceed only after satisfactory resolution of these.
concerns.
9.0 Procurement Control (Monticello and Prairie Island) 9.1 Underwriters Laboratories (UL) and Factory Mutual (FM) directories shall be reviewed to determine if the item is listed as being UL or FM approved. If the item is listed, a manufacturer shall be identified and the item procured in accordance with NSP's procurement process for nuclear plants.
The one exception for not buying an item that is UL or FM listed is ifit is a replacement of --
original equipment or NSP standard type, then it shall be identified as such and procured
. from the original supplier or manufacturer. As a minimum, the item or equipment shall, by
- appropriate testing, meet NFPA standards.
9.2 If the item is not listed by UL or FM, the following process shall be used:
1.'
- An evaluation shall be made to determine the compatibility of the item to the existing system or component, or 2.
If the item has been manufactured for a long period of time, and a.
The item is standardized, and Page 87 of 104
I Operati:nal Qurlity Assurcnce PI:n Revision 20 Appendix C i
b.
The item has a satisfactory performance history, and c.
Appropriate receipt inspection is identified in the procurement documents, then an evaluation is unnecessary. The fact that the supplier and item meets these requirements shall be documented in the procurement files.
9.3 Parts of components and equipment that have UL or FM approval as a unit shall be I
pro:ured as follows.
j i
1.
The part shall be manufactured by the original manufacturer of the component or equipment whenever possible.
l 1
2.
The model number of the component or equipment shall be identified.
3.
The specific part number shall be identified.
l 4.
Documentation from the supplier shall be requested that indicates the part delivered meets the specification of the part used in the original component or equipment. If the pan has been changed, the manufacturer shall be asked to indicate any changes in the operation of the ccc.aponent or equipment. In lieu of this documentation, the acceptance of the pan shall be based on inspection or testing.
j 9.4 All purchase requisitions pertaining to fire protection systems and equipment shall be reviewed by an individual designated by the Plant Manager.
10.0 Instnictions, Procedures, and Drawings (Monticello and Prairie Island) 10.1 The system of Administrative Control Directives (ACDs) shall be used to delineate responsibilities and requirements for the fire protection program.
10.2 Departmental instructions and procedures shall be revised or issued to implement the fire protection program responsibilities and requirements contained in the ACDs.
i 10.3 Fire protection maintenance, modifications, inspections, tests, administrative controls, drills, and training shall be prescribed by written instructions, procedures, and drawings.
Page 88 of104 r
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i Operatis=1 Quility Assurance Plan Revision 20 Appendix C j
11.0 Surveillance and Inspection (Monticello and Prairie Island) 1
. I 1.1 Monticello l 50 1.
. The Technical Specifications specify the surveillance and inspection requirements i
for the fire protection system. Surveillance shall be scheduled, performed, and i.
documented in accordance with standard directives governing the surveillance j
' testing program.
L 3'
j.
2.
Procedures shall be developed to assure adequate preventive maintenance of fire protection equipment. including fire suppression water system pumps and '
hydrants.
?
1 11.2 Prairie Island
' l 50 -
1.
The Fire Protection Program specifies the surveillance and inspection requirements l 51 l
for the fire protection system. Surveillance shall be scheduled, performed, and l
documented in accordance with standard directives governing the surveillance testing program.
l l
2.
Proceduies shall be developed to assure adequate preventive maintenance of fire i
protection equipiacnt, including fire suppression water system pumps and hydrants.
1 I
12.0 Conditions Adverse to Fire Protection (Monticello and Prairie Island) l I'
12.1 Administrative Control Directives shall establish criteria for housekeeping.
12.2 Work control process procedures shall be used to correct equipment failure, malfunctions, deficiencies, and defective components of fire protection systems.
l
[
12.3 As part of the training process, site personnel shall be instructed on how to identify fire
.l l
hazards and report them to their supervisor.
j t
13.0 Records (Monticello and Prairie Island) i j
Site instructions and Corporate directives establish nuclear plant records, creation, and l.52 1~
retention requirements. Fire protection records requirements shall be included in the
[
scope of these instructions and directives.
l 52 1
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Operati:nri Qurlity Assurtnce Pirn Revision 20 Appendix C 14.0 Audits (Monticello and Prairie Island) 14.1 In addition to normal quality assurance audits (at least biennial), an independent fire
- protection and loss prevention inspection and audit shall be performed annually at each plant utilizing either qualified off-site NSP personnel or an outside fire protection engineer or engineering consultant (annual independent inspection).
14.2 An inspection and audit by an outside qualified fire protection engineer or engineering consultant (see Section 2.3) shall be performed at each plant at least every three years j
(triennial independent inspection).
14.3 Inspection and audit results shall be reported to levels of management having fire l
protection program responsibilities in those areas audited or inspected.
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Operati=:1 Qu lity Assurance PI:n
' Revisim 20 Appe: dix D APPENDIX D i
Revision 20 Change Summary This appendix summarizes the changes made in Revision 20 to the Operational Quality Assurance Plan.
The intent of this appendix is to fulfill the requirements for identifying changes in accordance with 10CFR50.54(a)(3), Conditions of Licenses. This appendix is not a part of the Operational Quality Assurance Plan.
Change Number identifies the change number next to the sideline on the affected pages.
Page identi6es the page numbers containing the change.
Reason (R) identifies the reason for the change.
Basis (B) identifies the basis for concluding that the revised program incorporating the change continues to satisfy 10CFR50, Appendix B and the quality assurance program description commitments previously accepted by the NRC.
Change Reason (R):
Number Page(s)
Basis (B):
1
-i, 51-54 R:
Added new OQAP section 21.0, Prairie IslandSafety Audit Committee (SAC).
B:
This change supports the Prairie Island license amendment, dated December 14,1995. Technical specification section 6.2.A was deleted and relocated in j
the OQAP as new section 21.0. As this change is only a relocation of requirements, it does not reduce previous commitments.
2
-i, 55-57 R:
Added new OQAP section 22.0, Prairie Island Operations Committee (OC).
B:
This change supports the Prairie Island license amendment, dated December 14,1995. Technical specification section 6.2.B was deleted and relocated in the OQAP as new section 22.0. As this change is only a relocation of requirements, it does not reduce previous commitments.
3
-i-R:
Revision number updated to 20.
B:
Not required; editorialitem.
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' Oper:ti:n:1 Qurlity Ass:r::ce Pir.a
(
Revision 20 Appendix D Change Reason /
l Number '
Page(s)
Basis l
4 4
R:
Revised the exception wording to the third sentence of l
ANSI N18.7-1976, section 5.2.2 to (1) clarify that it is L
temporary changes to approved procedures that is the l
topic of the exception and (2) that review and approval is -
l L
per OQAP section 8.4 instead of the technical i
- specifications.
j B:
This change supports the Prairie Island license l
amendment,' dated December 14,1995. With the.
l relocation of Prairie Island technical specification l
requirements for procedure control, review and approval to OQAP section 8.4-5, the reference to technical l
specifications is applicable only to Monticello. The l
reference to Mont'icello temporary changes is maintained i
in OQAP section 8.4-4, while'the corresponding Prairie Island technical specifications are relocated to OQAP section 8.4-5. As there is no change to the original i
exception other than a c!srification, this change does not reduce previous commitments.
j 5
4 R:
Revised the wording so the exception taken to the second -
. ?
and third sentences of ANSI N18.7-1976, section 5.2.5, l
is per OQAP section 8,4 instead of the technical j
B:
This change supports Prairie Island's license amendment,-
~
specifications' dated December 14,1995. With the relocation of Prairie.
Island technical specification requirements for procedure control, review and approval to OQAP section 8,4-5, the 1
reference to technical specifications is applicable only to Monticello. The reference to Monticello temporary changes being reviewed and approved per technical j
specifications is maintained in OQAP section 8.4-4, while the corresponding Prairie Island technical specifications are relocated to OQAP section 8.4-5. As there is no t
change to the original exception, this change does not reduce previous commitments.
6 4
R:
Corrected punctuation by placing period inside the close-quotation marks.
B:
Not required; editorialitem.
Page 92 of 104 5
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Operati=ct Qnlity Assur:cce Pl;:n
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Revisiom 19 Appe dix D Change:
Reason /
Number Page(s)
Basis 1
7 4
R:
Added comma after the phrase "...and control of required procedures except that,...." to correct punctuation.
B:
Not required, editorialitem.
8 4
R:
Revised the wording so that the exceptions taken to j
ANSI N18.7-1976, section 5.2.15, is per OQAP section l
8.4 instead of the technical specifications.
B:
This change supports Prairie Island's license amendment, I
dated December 14,1995, With the relocation ofPrairie Island technical specification requirements for procedure control, review and approval to OQAP section 8.4-5, the reference to technical specificatiot.s is applicable only to
(
Monticello. The reference to Monticello procedures i
being controlled, reviewed and approved per technical j
specifications is maintained in OQAP section 8.4-4, while the corresponding Prairie Island technical specifications are relocated to OQAP section 8.4-5. As there is no l change to the original exception, this change does not i
reduce previous c.ommitments.
i9
-4 R:
Added the words " ANSI N18 7-1976,'Section" in front j
of the section number for clanGcation and consistency.
B:
Not required; editorialitem -
c i
j 10-5 R:
'Added Table header to second page ofTable 1-1.
B:
Editorialitem, not required.
f 11 9
R:
The responsibility for low level radiation waste l
management now assigned to the Director Environmental j
& Regulatory Affairs.
B:
This is a responsibility change only. It does not reduce 4
l previous commitments.
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Oper:timi Quility Assurance PI:n l
Revision 20 Appendix D 1
Change Reason /
i Number Page(s)
Basis 12 9
R:
Clarified the functional responsibility of the corporate 1
j administrative control directives (ACDs) and removal of I
reference to corporate administrative work instructions l
(AWIs).
B:
This change reflect; the restmeturing of the ACDs and AWIs to improve efficiency and effectiveness. Under the restructuring, there are corporate ACDs and site AWIs; i
corporate AWIs were either absorbed into the corporate ACDs or delegated to the site while site ACDs were j
l converted to site AWIs. Requirements for ACDs and AWIs remain unchanged. Where appropriate, the process owner is now responsible for the content of the ACD aligned with that process. Generation Quality Services maintains responsibility for select ACDs as process l
owner, and overall administrative control, including reviews, over all the ACDs. As such, this change does not reduce previous commitments.
13 12 R:
Changed the management position responsible for l
formulating and implementing an Operational Quality Assurance Program from the Vice President Nuclear Generation.
B:
This is a responsibility change only. It does not reduce previous commitments.
14 12, 13 & 14 R:
Removed references to corporate administrative work instructions (AWIs) and site administrative control directives (ACDs).
B:
This change reflects the restructuring of the ACDs and AWIs to improve efficiency and effectiveness. Under the restructuring, there are corporate ACDs and site AWIs; corporate AWIs were either absorbed into the corporate ACDs or delegated to the site while site ACDs were converted to site AWIs. Requirements for ACDs and AWIs reme imchanged. As such, this change does not reduce previous commitments.
Page 94 of104
Operati=1 Qurlity Assurance PI:n Revision 19 Appendix D Change Reason /
Number Page(s)
Basis i
15 13 R:
Removed reference to site level instructions in the second sentence.
B:
This change is an editorial clarification. The reference to j
site level instructions was redundant with the revised first sentence now referencing site level instmetions. It does not reduce previous commitments.
16 13 R:
Removed reference to site level directives.
B:
This change reflects the restmeturing of the ACDs and AWIs to improve efficiency and effectiveness. Under the restructuring, there are corporate ACDs and site AWIs; corporate AWIs were either absorbed into the corporate ACDs or delegated to the site while site ACDs were converted to site AWIs. Requirements for ACDs and 1
AWIs remain unchanged. Reference to site level directions in this section on administrative control directives is no longer applicable. As such, this change does not reduce previous commitments.
17 14 R:
Eliminated the first two sentences of old section 4.5-2.
B:
This change reflects the restmeturing of the ACDs and -
AWIs to improve efficiency and effectiveness. Under the restructuring, there are corporate ACDs and site AWIs; corporate AWIs wue either absorbed into the corporate ACDs or delegated to the site while site ACDs were converted to site AWIs. Requirements for ACDs and AWIs remain unchanged. The direction for AWIs to be used primarily for department interfacing is no longer applicable with the restructuring (this direction was meant for corporate AWIs). As such, this change does not reduce previous commitments.
j 18 14 R:
Moved the last sentence of old section 4.5-2 to section 4.5-1 thus eliminating old section 4.5-2.
B:
Not required; after the elimination of the first two sentences of section 4.5-2, the last sentence was i
combined with section 4.5-1 for editorial reasons. It does not reduce previous commitments.
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. Operatiort Qurlity Assur:nce Pl:n Revision 20 Appendix D -
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' Change Reason /
Number Page(s)
Basis.
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f 19-14 & 22 R:
Relocated the procedure control requirements portion of
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section 4.6-2 to section 8.4.
B:
Not required; editorial decision to consolidate the j
procedure control requirements to section 8.4 for clarity.
20 14 R:
Renumbered old sections 4.7-3.c and -3.d as new sections 4.7-3.b and -3.c respectively, due to the elimination ofold j
section 4.7-3.b.
l B:
Editorialitem, not required..
j 21 15 R:
Removed reference to Instructions..
B:
This change reflects the restructuring of the ACDs and AWIs to improve efficiency and effectiveness. Under the restructuring, there are corporate ACDs and site AWIs; corporate AWIs were either absorbed into the corporate
)
ACDs or delegated to the site while site ACDs were converted to site AWIs. Requirements for ACDs and AWIs remain unchanged. As there are no longer corporate instructions this reference no longer made sense and was removed. The index continues to identify the corporate directives utilized to implement the requirements of ANSI N18.7, which in turn identify requirements / commitments that site AWIs must implement.
22 22 R:
The second sentence of old section 8.4-1 relocated as new section 8.4-2.
B:
Not required; editorial decision to relocate requirement for clarification.
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l Operatimi Qurlity Assurarce Pl:n Revision 19 -- Appendix D Change Reason /
Number Page(s)
Basis 23 22 R:
Relocated the third sentence of old section 8.4-1 to reformatted Monticello and Prairie Island specific sections, new sections 8.4-3 and 8.4-4 respectively.
Removed the reference to technical specifications as it pertains to Prairie Island to clarify the differences between Prairie Island and Monticello.
B:
This change supports the Prairie Island license amendment, dated December 14,1995. With the removal of the administrative controls from the Prairie Island technical specifications, the reference to technical j
specifications is applicable only to Monticello. Prairie Island technical specification requirements for procedure L
control are relocated in new section 8.4-5. As there is no change to requirements, it does not reduce previous
(
commitments.
24 22 R:
Renumbered old section 8.4-2 as section 8.4-2.b and removed reference to technical specification.
B:
This change supports Prairie Island's license amendment, dated December 14,1995, With the relocation of Prairie Island technical specification requirements for procedure changes to section 8.4-4, the requirement that procedures changes comply with technical specifications is applicable only to Monticello. This is stated as such in section 8.4-3 to reflect its specific applicability to Monticello. As there is no change to the requirements, it does not reduce previous commitments.
25 22 R:
Included procedure changes and temporary changes as activities to be reviewed and approved in accordance with licensee technical specifications.
4 B:
This is a clarification of the document control activities addressed by licensee technical specifications. It does not
'i reduce previous commitments.
Page 97 of 104
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Operati:nr.1 Qaility Assura ce Plan l
Revision 20 Appendix D L_
' Change '
Reason /
)
Number Page(s)
Basis
'26 22 R:
Added Prairie Island requirements for temporary changes to procedures.
l B:
This change supports the Prairie Island license l
amendment, dated December 14,1995. Technical i
- specification section 6.5.G was deleted and relocated to j
OQAP section 8.4-4, subparts b and c. The original l
technical specification wording referencing Operations Committee reviewed procedures described in sections A, B, C, D, E (of TS 6.5) was changed to simply reference j
" Operations Committee reviewed procedures" in order to fit within the context of the OQAP. As this change is
)
j only a relocation of requirements, it does not reduce i
l previous commitments.
i 27 22,56 R:
Added Prairie Island requirements for security
' procedures.
B: - This change supports the Prairie Island license amendment, dated December 14,1995. Technical specification section 6.5.F.was deleted and relocated to OQAP sections 8.4-4.c and 22.4-8. Sentence 1 is captured by OQAP section' 22.4-8. Requirements'for security procedures required to be reviewed by the l
Operations. Committee is captured in OQAP sections 8.4-l 4.a and 22.4-8. The requirements for non-safety related procedures that govern work activities have been relocated in OQAP section 8.4-4.c. As this change is only a relocation of requirements, it does not reduce i
previous commitments.
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28 23 R:
Added Prairie Island requirements for maintenance procedures.
j B:
This change suppoits the Prairie Island license i
amendment, dated December 14,1995. Technical specification section 6.2.C was deleted and relocated to OQAP section 8.4-5. As this change is only a relocation j
. of requirements, it does not reduce presious commitments.
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s Operdlyml Qu:lity Assurance Plan Revision 19 Appendix D Change Reason /
Number Page(s)
Basis 29 23 & 56 R:
Changed the phrase " work requests" to " work orders" to reflect current Prairie Island terminology.
B:
This is a terminology change only. It does not reduce previous commitments.
30 23 R:
Added Prairie Island requirements for maintenance and test procedures.
B:
This change supports the Prairie Island license amendment, dated December 14,1995. Technical specification 6.5.C was deleted and relocated to OQAP section 8.4-5.a. As this change is only a relocation of requirements, it does not reduce previous commitments.
31 R:
Not Used.
B:
32 32 R:
Removed references to technical specifications and personnel qualifications for fire protection inspections..
B:
This change supports Prairie Island's license amendment, dated December 14,1995. OQAP Appendix C, section i
14, identifies the same fire protection inspection and personnel qualification requirements listed in both Prairie Island and Monticello technical specifications. As there is i
no change to requirements, it does not reduce previous commitments.
33 35 R:
Removed references to technical specifications as it pertains to Prairie Island and reformatted section to clarify difference between Prairie Island and Monticello.
B:
This change supports Prairie Island's license amendment, dated December 14,1995. As part of the license amendment, the technical specification review and approval requirements for tests and procedures were removed and relocated to the OQAP. As this change is only a reference change, it does not reduce previous commitments.
34 44 R:
Reformatted section 18.2 to clarify difference between Prairie Island and Monticello.
B:
Not required; editorialitem.
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1 Operati=al Quility Assura:ce Plu ~
Revision 20 Appendix D
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Change Reason /
]
Number Page(s)
Basis i
35 44 R:
Removed the reference to technical specifications as it i
penains to Prairie Island and B:
This change supports Prairie Island's license amendment, dated December 14,1995, As part of the license amendment, the technical specification investigation and review requirements for operating occurrences and events were removed and relocated to the OQAP. The reporting function is still addressed by Prairie Island technical specifications, though relocated from technical l
specification section 6.4 to technical specification section
]
2.2 by Prairie Island license amendment dated May 4,
.J 1995. As this change is only a reference change, it does not reduce previous commitments.
]
36 45 R:
Changed the source requirement for Prairie Island record generation and retention from technical specifications to OQAP Section 19.12.
B:
This change supports the Prairie Island license i
amendment, dated December 14,1995. As pan of the j
license amendment, the administrative requirements for l
record generation and retention were removed from j
Section 6.6 of the Prairie Island Technical Specifications
.j and relocated to OQAP Section 19.12. As this change only corrects a reference to the source requirements, it does not reduce previous commitments.
37 47,48 R:
Added Prairie Island requirements for records and record retention.
B:
This change supports the Prairie Island license amendment, dated December 14,1995. Technical specification section 6.6 was deleted and relocated to OQAP section 19.12. As this change is only a relocation of requirements, it does not reduce previous commitments.
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Page 100 of 104
i Operati::=1 Qu:lity Assurance PI:n Revisi:219 Apperdix D Change Reason /
Number Page(s)
Basis 38 49 R:
Clarified the basis for the audit schedule.
i B:
This change supports Prairie Island's license amendment, l
dated December 14,1995, and is an improvement to the j
quality assurance plan by allowing resources to be focused on plant functional areas that require the most i
attention. As a mature audit program, the frequency of the audit functional areas has been adjusted based upon past experience. The revised wording is consistent with l
current quality practices and the requirements of the licensee's technical specifications and ANSI N18.7-1976.
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39 49 R:
Reformatted section 20.3 for clarification. The last sentence of old section 20.3-1 was relocated as new section 20.3-2 and old section 20.3 2 renumbered as i
section 20.3-3.
I B:
Not required; editorialitem.
l 40 53 R:
Corrected reference for special inspections and audits.
B:
This change supports the Prairie Island license amendment, dated December 14,1995. The original reference to technical specification 6.3 was no longer accurate due to the deletion of technical specification 6.3 by the license amendment. The same requirements of j
technical specification section 6.3, existed in OQAP l
Appendix C, section 14.0, so the reference was changed.
As such, this change does not reduce previous commitments.
l 41 53 R:
Corrected the typos in the reference to N18.7. NSP is committed to N18.7-1976, not 1972. The appropriate N18.7 section is 4.5 (Audit Program), not 4.4.
B:
This are typographical error corrections only. It does not reduce any previous commitments.
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Operatinal Qarlity Assurance Pimo Revision 20 Appendix D Change Reason /
Number Page(s)
Basis 42 Not Used 43 56 R:
Corrected reference for security procedures exempted from OC review criteria.
B:
This change supports the Prairie Island license amendment, dated December 14,1995. The original reference was to technical specification 6.5.F. Since this technical specification was deleted and the exemption part of the requirement relocated to OQAP section 8.4-4.c, the reference was appropriately changed. As this isjust a reference change, it does not reduce previous commitments.
t 44 56 R:
Corrected reference for review requirements for maintenance work requests and associated procedures.
B:
This change supports the Prairie Island license amendment, dated December 14,1995. The original reference was to technical specification 6.2.C. Since this technical specification was deleted and the relocated to OQAP 8.4-5, the reference was appropriately changed.
As this isjust a reference change, it does not reduce previous commitments.
45 59 R:
Added the Underground Duct Bank as a safety related structure.
1 B:
Site determination to include stmeture in Appendix A;it does not reduce previous commitments.
46 66 R:
Removed the charging pump motors from the Prairie Island Q-List and clarified the safety related aspect of the charging pumps.
B:
Reduction in commitment per 50.54(a)(3) per Submittat of Proposed Change to Revision 18 of the OQAP, dated June 14,1995 (NRC approval letter dated January 8, 1996).
Page 102 of104
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- Operati:n:3 Qulity Assurcnce Plin Revisita 19 Apperdix D i
Change Reason /
Number Page(s)
Basis 47 71 R:
Clarified boundary of safety related components for the air starting system for the diesel generators by combining section 28 with section 27, and by clarifying that boundary description is for " compressor" piping and supports.
B:
This is a clarification requested by the NRC in their approval letter of revision 19 of the OQAP, dated September 8,1995. It does not reduce previous commitments.
48 72 - 74 R:
Renumbered sections old 29 through old 33 to support the combining of sections 27 and old 28.
B:
Not required; editorialitem.
49 77 R:
Title change from Manager Nuclear Training.
B:
This is a title change only. It does not reduce previous commitments.
50.
89
' R:
Renumbered section 11.0 to reflect changes due to Prairie Island's technical specification amendment (Unit I license amendment 120, Unit 2 license amendment 113) removing fire protection requirements from technical specifications; no similar change in Monticello's program.
B:
This is an editorial change only. It does not reduce previous commitments.
51 89 R:
Removed reference to Prairie Island technical specifications.
B:
The reference to technical specifications is no longer applicable. Surveillance requirements were removed from the technical specification by Prairie Island Unit I license amendment 120 & Unit 2 license amendment 113 (NRC approval date October 6,1995). This change also supports Prairie Island's license amendment, dated December 14,1995, in that the inspection requirements of technical specification 6.3 were deleted in its entirety.
The inspection requirements are contained in the Prairie Island Fire Protection Program. They also remain as requirements of Section 14.0 of OQAP Appendix C. As such, this change does not reduce previous commitments.
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Operati:nr1 Qu:lity Assurance Plan Revision 20 Appendix D Change Reason /
Number Page(s)
Basis 52 89 R:
Clarified that it is site instmetions and corporate directives that establish record retention requirements.
B:
This change reflects the restructuring of the ACDs and AWIs to improve efficiency and effectiveness. Under the restructuring, there are corporate ACDs and site AWIs; corporate AWIs were either absorbed into the corporate ACDs or delegated to the site while site ACDs were converted to site AWIs. Requirements for ACDs and AWIs remain unchanged. The reference to site directives no longer made sense and was clarified. As such, this change does not reduce previous commitments.
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