ML20138H657
| ML20138H657 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/02/1997 |
| From: | Hoen G, Robinson D NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20138H654 | List: |
| References | |
| NUDOCS 9705070239 | |
| Download: ML20138H657 (89) | |
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COOPER NUCLEAR STATION i
QUALITY ASSURANCE PROGRAM i
j POLICY DOCUMENT 1
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PROPOSED REVISION 13 l
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9705070239 970502 j
PDR ADOCK 05000298 P
PDR 4
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NEBRASKA PIIBLIC POWRR nlSIRICI l
4 COOEERliUCI RAR STATION t
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QIIAI1TY ARRURANCR PROGRAM FOR OEERATION
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POLICV nOCIIMENT l
t TART F OF CONTRNIS l
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1 Corporate Policy Statement................................ v i
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' PROGRAM DEFINITION..............................
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1.1 Purpose 1-1 1.2 Policy 1-2 1.3 Objectives....................................
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1.4 Scope.......................................
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1.5 Definition of Terms..............................
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a 2.0
SUMMARY
DESCRIPTION 2-1 4
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1 2.1 Organization
..................................2-1 d
2.7 Quality Assurance Program.........................
2-2 Design Control 2-5 4
2.4 Procurement Document Control
....................2-11 4
j 2.5 Instructions, Procedures & Drawings 2-13 2.6 Document Control 2-14 4
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TAM R OF CONTENTS (Cont'd) i 2.7 Control of Purchased Material, Equipment, i
t and Services
.................................2-16 2.8 Identification and Control of Parts, Materials, and Components...............................
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i 2.9 Control of Special Processes.......................
2-18 1
2.10 Inspection 2-19 I
2.11 Test Control
.................................2-20 i
2.12 Control of Measuring and Test Equipment..............
2 -2 1 2.13 Handling, Storage, and Shipping....................
2-22 2.14 Inspection, Testing, and Operating Status...............
2-24 c
2.15 Nonconforming Materials, Parts, or Components..........
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2.16 Corrective Action..............................
2-26 2.17 Quality Assurance Records........................
2-27 2.18 A ud its......................................
2 -2 8 2.19 Additional ANSI Standards........................
2-30 3.0 ORGANIZATION AND RESPONSIBILITIES 3-1 3.1 General......................................
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3.2 Nuclear Power Group Management....................
3-2 3.2.1 Vice President - Nuclear 3-2 O
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TARIR.OF CONTENTS (Cont'd)
O 3.2.2 Division Manager, Quality Assurance..............
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3.2.3 Quality Assurrnce Operations Manager 3-4 l
3.2.4 Quality Assuruce Assessment Manager 3-6 3.2.5 Quality Assunnce Supervisors 3-7 i
3.2.6 Quality Assurance Staff.......................
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3.2.7 Senior Manager of Engineering..................
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3.2.8 Nuclear Fuels Supervisor.......................
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1 3.2.9 Site Manager...
...........................3-10 3.2.10 Plant Manager...........................
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4 3.2.11 Senior Manager - Site Support..................
3-10 3.2.12 Senior Manager of Safety Assessment.............
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i 3.2.13 Nuclear Power Group Managers.................. l1 1
O 33 cooger *=cie>rs' tie Perse==ei 3-ii l
3.4 Safety Review and Audit Board (SRAB)................
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3.5 Station Operations Review Committee (SORC)...........
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3.6 Outside Snppliers, Contractors, Subcontractors, and Consultants. 3-12 i
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TAM R OF CONTENIS (Cont'd) 4.0 QUALITY ASSURANCE DOCUMENTS.................... 4-1 2
i 4.1 NPPD Internal Documents 4-1 f
4.1.1 Quality ControlInspection 4-2 j
4.1.2 Nuclear Quality Procedures (NQP)................
4-3 i
4 4.1.3 Quality Assurance Plans (QAP).................
4-4 5.0 METHOD OF IMPLEMENTATION 5.......................
6.0 RECORDS RETENTION AND DISPOSITION 6-1
7.0 REFERENCES
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8.0 FIGURES 8-1 8.1 Quality Assurance Organizational Chart (Figure 1)..........
8-1 9.0 TABLES 9-1 9.1 Systems and Components Within Scope of the CNS QA Program (Table 1) 9-1 9.2 Three Level QA Program (Table 2) 9-5 O
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CORF ORATE POLICY STATEMENT This document establishes and describes the policies and practices of the Quality Assurance Program applicable to the operation of the Cooper Nuclear Station and the support activities of all NPPD Nuclear Divisions. The District's policy with respect to nuclear safety and quality assurance is detailed in Section 1.2 of this document.
Each Nuclear Division is responsible for the development of policies and procedures which implement this Quality Assurance Program. Other divisions and departments at NPPD may also have responsibilities under this program and shall comply as described in appropriate implementing procedures.
The Safety Review and Audit Board, Station Operations Review Committee, and the Quality Assurance Division shall monitor the District's nuclear program and provide management with evaluations and assessments regarding the effectiveness of the implementation of the program. When evaluations and assessments identify a concern, management shall take expeditious action to correct any undesirable condition (s) including, where appropriate, action to preclude repetition of such condition (s).
District personnel shall have the organizational freedom to identify concerns and propose corrective and preventive action necessary to enhance the District's nuclear program.
The assurance of safe and reliable operation of Cooper Nuclear Station is everyone's duty. Ouality shall be everyone's responsibility.
APPROVED:
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A President & CEO MY D-Division Manager - Quality Assurance V{Ppsident - Nuclear j
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COOPERS.UCLEAILSTATION
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QUAT ITY ARMURANCR PROGRAALEOILOPERATION EOLICY nOCUMENT 1.0 EROGRAhtDEEIEITION 11 In accordance with the conditions of the Nuclear Regulatory Commission construction permit and operating license for the Cooper Nuclear Station, the management of Nebraska Public Power District recognizes its responsibility for assuring that the Cooper Nuclear Station is designed, constructed, and operated in such a manner as to provide for the safety of the public. The ii..portance of Quality Assurance in contributing to this safety as well as contributing to station reliability is also recognized.
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12 The initial phases of the overall Quality Assurance Program, implemented during design and construction, provided an independent check for the work performed on components, structures, and systems of the station to assure that the design, analysis, materials of construction, manufacture, installation, erection, and construction met quality sta idards required to assure reliable and safe operation. The CNS Quality Assurance Prog' m for Operation, as described herein, is implemented to provide assurance that structures, systems, and components will perform satisfactorily, and that the public health and safety i
will be maintained.
1.1 Eurpose 11 The purpose of this policy document is to provide a description of the Quality Assurance Program to be followed during the operational phase of Cooper Nuclear Station and to identify applicability of the policies and procedures described herein. This CNS Quality Assurance Program for Operation was developed by Nebraska Public Power District in i
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response to the requirements of 10CFR50, Appendix B. It provides a general description 3(G of the Quality Assurance Program for Operation and requires that detailed instructions, procedures, and drawings, as appropriate, be set forth in writing and carried out by each of the responsible organizations or individuals within the District.
1.2 Policy 11 It is the policy of Nebraska Public Power District (NPPD) to use its best efforts to assure that the Cooper Nuclear Station is designed, constructed, maintained, and operated in a manner that will provide the highest practical degree of safety and reliability. Structures, components, and systems are designed, fabricated, erected, maintained, and modified to quality standards appropriate to their importance to the safety function. The Quality Assurance Documents will identify those structures, systems, and major components to be covered by the Quality Assurance Program in order to provide continuing compliance with
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these standards throughout the operating life of the station. Additionally, it is the policy of NPPD that activities affecting quality shall be documented by approved instructions, procedures, or drawings and such activities shall be implemented as documented. Such documentation shall contain adequate qualitative and/or quantitative acceptance criteria to provide a measure of accomplishment.
12 It is the policy of Nebraska Public Power District (NPPD) to staff the Nuclear Power Group (NPG) with properly-trained personnel in all responsible positions and job assignments. Sufficient numbers of licensed and senior licensed operating personnel will be available to assure proper operation of the station under all reasonably foreseeable circumstances including personnel turnover, vacations, and disability.
13 All District personnel, as well as non-District personnel who work independently under 1
nU NPPD's QA Program, responsible for operating, maintaining, or designing safety-related 1
systems and equipment shall receive formal instruction in Quality Assurance, including:
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basic principles of quality assurance,10CFR50 Appendix B, the contents of this policy i
73 document, and Quality Assurance documents, as applicable.
LJ 14 Trained technical, engineering, and Quality Assurance personnel shall be assigned surveillance and audit tasks to ensure compliance with the requirements of the documents which control station operation, such as the NRC license, Updated Safety Analysis Report, Technical Specifications, Operating Manual, QA Program for Operation, and other such controlling documents. During the time personnel are performing QA functions, they shall be responsible to the QA Division to maintain the organizational independence required by the QA Program.
j 15 It is the policy of Nebraska Public Power District to maintain quality standards for Cooper Nuclear Station which will ensure the high degree of reliability and safety needed to meet j
the overall objectives of supplying safe and dependable electric service to its customers.
O 16 The CNS QA Program for Plant Operations utilizes the guidance provided by NRC publications WASH-1283 (5-24-74), WASH-1284 (10-26-73), and WASH-1309 (5-10-74)
(" rainbow" series) except where specific exceptions and clarifications are noted within this document. Where specific requirements included in the standards are in conflict with original design requirements set forth in the USAR and other appropriate design documents, the original design requirements shall govern. Later revisions to standards presently committed to by CNS, may be specifically invoked by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than original" condition.
17 In summary, NPPD is committe1 to the continuous development of a Quality Assurance Program which will meet the requirements of 10CFR50, Appendix B, Quality Assurance O
Criteria for N ecieer Power Piaets,and ether aggiicebie reseiatiees es m er be gre m eisated by the Nuclear Regulatory Commission.
This commitment applies to all NPPD 1-3 Revision 13
1 organizations to assure that a high standard of quality will be maintained during nuclear G
plant operation. Section 2 of this document presents a summary discussion of the U
l QA Program as applicable to the 18 criteria of 10CFR50, Appendix B.
1.3 Objectives il The overall objective of this Policy Document and Quality Assurance Plans (QAPs) and Nuclear Quality Procedures (NQPs), is to set forth the Quality Assurance organizational structure and personnel responsibilities, and to articulate general requirements for l
implementation of the Quality Assurance Program for Cooper Nuclear Station to address 1
the following activities, at a minimum:
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a)
Regulatory criteria, codes and standards, rnd design bases for i
i safety-related systems (as defined in the CNS QA Program) are C
incorporated into the test, operating, modifications, and maintenance procedures and instructions to meet all requirements for nuclear safety and a
station reliability; b)
Results of all preoperational and operational tests of safety-related systems and components conform to the requirements of the drawings, specifications, procedures, and instructions, and that appropriate reports are prepared to document that all results of tests meet prescribed acceptance criteria; c)
Nuclear Fuel is purchased, designed, manufactured, inspected, packaged, shipped, received, installed, and operated in the reactor in accordance with approved procedures, instructions, regulatory requirements, and license O
stigeiatiees:
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d)
The Station is operated, maintained, tested, refueled, repaired, and (O
modified, in accordance with approved pmcedures, instructions, regulatory q) requirements, and license stipulations, consistent with quality standards equal to or better than those in effect during design and construction; c)
A system is established and maintained to control, safeguard, and permit ready retrieval of quality-related documentation generated for materials and cx>mponents during the design, fabrication, modification, maintenance, and operation of CNS; f)
Appropriate and complete reports, records, and logs are established and maintained so as to pmvide a continuing record of quality-related activities associated with station safety and reliability throughout the life of the station; g)
The NPG personnel are subjected to periodic training, retraining, requalification, and examination such as to maintain and improve theirjob skills which are essential to safe and reliable operation of the station; l
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Station security and nuclear fuel accountability and safeguards are maintained in accordance with approved procedures and instructions; i)
Corrective action documents / reports and associated resolutions are to be pmperly controlled and filed in the appmpriate quality-related record files; j)
Inspection reports issued by the NRC are properly resolved and documented; 1-5 Revision 13
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Spent fuel shipment activities are to be accomplished in accordance with f]
regulatory requirements (10CFR Part 71).
v 1.4 Scope 11 The QA Program for Operation applies to those nuclear station structures, systems, and components that are designed to prevent or mitigate the consequences of postulated accidents which could cause undue risk to the health and safety of the public, and to other selected systems and programs as defined in implementing QA Plans. The requirements of this program apply to all activities which effect the safety-related functions of those structures, systems, and components, including designing, purchasing, fabricating, handling, shipping, storing, cleaning, crecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service inspection, and modifying, mQ 12 This program specifically applies to, but is not necessarily limited to the nuclear fuel, the reactor coolant system and its auxiliaries and controls, the reactor protection and engineered safety systems, the reactor containment system, portions of the radioactive waste disposal system, and other systems and components required for safe, efficient, and reliable operation of the plant. A tabulation of those structures, systems, and components which are covered by the QA Program is given in Table 1.
13 The Quality Assurance activities governing those structures, systems, and major components shall be performed as described in the Quality Assurance Plans (QAPs) (see Section 4.1.3).
14 The Quality Assurance Criteria in 10CFR50, Appendix B, are oriented primarily toward engineering, manufacturing, and construction activities. Therefore, it is necessary to O
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define, by specific Quality Assurance documents, the manner in which the NRC Quality Assurance Criteria are to be applied to the station operating activities. Such Quality 1-6 Revision 13 i
Assurance documents shall be prepared in accordance with the requirements specified in
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Sections 2.0 and 4.0 of this policy document.
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'Ihe specifications, principles, and procedures which controlled the original procurement, i
fabrication, and construction have been carried over into the QA aspects of station
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operation to the greatest extent practicable. It is the intent of NPPD management to
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maintain, as a minimum, the quality level achieved in the original design and construction.
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1.5 Definitionnf_ Terms 11 Key words and phrases used to characterize this QA Program are defined herein to establish a basis for uniform and consistent interpretation of the Quality Assurance requirements. Definitions of these terms are based upon documents and standards issued j
i by the American National Standards Institute (ANSI), NRC Safety and Regulatory Guides, f]
professional societies involved in standards work (ANS, ASME, IEEE, et al.), and on the basis of contempomry usage in the nuclear power industry; or shall be defined specifically to convey the intent of this particular program. Specific to the related ANSI Standard for this subject, the following commitment applies:
ANSI N45.2.10-1973 " Quality Assurance Terms and Definitions," and the associated Regulatory Guide 1.74, are applicable to the CNS Operational QA Program, with the following clarification:
There may be instances where existing procedures contain definitions thu may not be in strict accordance with those provided by this standard.
As existing i
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procedures am revised, however, such definitions shall be evaluated to assure that all definitions meet those provided by this standard.
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s 12 To facilitate review and understanding of this policy document, the following basic terms are defined below along with appropriate QA Program requirements.
A ccecement A planned, methodical, and comprehensive examination of an event, program, process, activity, or function which may include, compliance with existing NPG documents and/or l
comparisons to existing industry information.
Audit l
An activity to determine through investigation, the adequacy of, and adherence to, established procedures, instructions, specifications, codes, and standards or other applicable contractual and licensing requirements, and the effectiveness of implementation.
I Class For piping and valves, CLASS is determined by the applicable ASME Code. For seismic considerations, CLASS is determined by the USAR. (See also Essential, Non-Essential, and Quality Commercial Grade.)
Crviec and Standards Documents issued by qualified oiganizations which contain standardized requirements for particular equipment or applications (e.g., ASTM Material Standards, ASME Pressure i
Vessel Code, etc.).
(Refer also to ANSI N45.2.10 for definition of " Standard".)
4 Condition Report Condition Report (CR) is the vehicle utilized for identifying and correcting conditions adverse to quality, and significant conditions adverse to quality as described in 10CFR50, O
Argendix 8. Condition Regerts aise provide a method rer identificetion end correction of those conditions not specifically described in 10CFR5J, Appendix B.
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Controlling nmuments O
All those drawings, specifications, procedures, instructions, manuals, data books, Updated Safety Analysis Reports (USAR), Technical Specifications, and the like, which have been approved and issued by the appropriate authorities, and which prescribe the conditions and limitations under which work is to be performed.
(Refer also to ANSI N45.2.10 for definition of " Documentation".)
Thign Change A design change (generic application) is considered to be any change to a component, equipment, or structure that changes the design criteria, configuration, or margin of safety for a system or component which could impact nuclear safety, equipment and system integrity, or personnel safety.
Designated Renrecentative An individual or organization that is authorized by the purchaser to perform a specific function as identified / described in the procurement document.
Emergency _Prmedures (Operating, Maintenance, or Repair)
Those activities which must be performed without delay in order to:
a)
Avoid further degradation of off-normal conditions which, in themselves, do not constitute an accident, but which could lead to an accident if not corrected promptly; b)
Reduce the consequences of an accident or hazardous condition which has
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Implement an emergency plan; l-9 Revision 13
d)
Prepare for an anticipated act of nature.
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Rasentini For purposes of applying and implementing this Quality Assurance Program, the term
" Essential" shall apply to the following:
a)
All systems, structures, equipment, and components which are identified in the USAR as having been designed and built to Seismic Class I requirements; b)
All systems, structures, equipment, components, instruments, and controls which are identified in the USAR as being required to shut down the plant and maintain it in a safe shutdown condition; O
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. All other systems, structures, equipment, components, instruments, and controls which are placed in the " Essential" category by NPPD.
Evaluation An assessment of smaller scope; focusing on a portion of a process, a specific industry event / experience, or a specific CNS event / issue. Primary emphasis is compliance with existing CNS management expectations and goals, and secondarily for comparisons to existing industry events / standards.
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Functionni Organintion Chan O
A pictorial description of the organization as it actually works showing actual lines of direction, supervision, responsibility, authority, and communication. Such functional lines may or may not coincide with regular administrative channels.
]nenactinn
'Ihe determination that physical characteristics meet predetermined requirements by visual checks or by other techniques such as X-ray, ultrasonic or dye penetrant examination, etc.
(See also Quality Control).
(Refer also to ANSI N45.2.10 for definition of " Inspection".)
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l A nuclear station which is designed and constructed so as to meet requirements of applicable regulatory criteria and is thereby eligible to receive a construction permit and operating license from the U.S. Nuclear Regulatory Commission.
Imwer Tier Placurement 3
Procurement by a supplier from a subsupplier of items or services.
}dainicnaner Procedures Written instructions which define a preplanned maintenance program and prescribe the O
methods. materiais, and processes to be used to assure centinuins aeeiity and centinuing I
operation of equipment within required performance characteristics.
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Major _ Maintenance,_ Repair.llr_ Modification b
J Those maintenance, repair, or modification activities performed on nuclear safety-related structures, systems, or components which involve.
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Special craft or procedure qualifications to meet Code, Standard, or Regulatory requirements; i
b)
Alterations which affect overall structural integrity, essential performance l
characteristics, or margins of safety in design for nuclear safety-related structures, systems, or components; c)
Any permanent change to the facility that requires a Technical Specification change or creation of an unreviewed safety question.
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v Minor _Maintennnee Renair, nr Modification Those maintenance or repair activities which are within a journeyman craftsman's capability, and which:
a)
Are prescribed in the equipment manufacturer's instruction books as necessary or desirable for most effective operation; b)
Are prescribed as part of a preplanned and approved routine or preventative maintenance program; c)
Any permanent change to the facility judged significant enough to warrant O
decemeetation thet deescot require e chaese ie Technicei Seeciiication er I
present an unreviewed safety question.
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Monitor O.
Periodically observe on a formal or informal basis whether work is being performed according to the requirements of the controlling documents (see also Surveillance).
Nonemential Any structures, equipment, and mmponents which may be important to reactor operation, but are not mquimd for preventing an accident which would endanger the public health and safety, and are not required for the mitigation of the consequences of these accidents. A Nonessential designated item shall not degrade the integrity of any item designated Essential.
Nimlenr Power _GroupMan2gement O
The Cooper Nuclear Station management compris(d of the Vice President - Nuclear, the Site Manager, all Senior Managers, the Division Manager of Quality Assurance, and all other Managers of NPPD's Nuclear Power Group.
Nirlanc Quality _P_rocedures (NQPs)
Nuclear Quality Assurance Division Procedures that centain requirements / guidance for QA Division activities which affect activities of other divisions within the NPG and the District. NQPs define the responsibilities for implementation of the QA Program in accordance with policies and practices herein defined as they apply to the QA Division.
In addition, they provide guidance for surveillance, audit, and assessment / evaluation activities to be performed by the QA Staff.
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Off-Normal Canditinn
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]O A condition which results when an operating variable departs from its normal range. To restore normal operating conditions following such a perturbation, action is taken under 1
off-normal procedures so as to correct the condition which, if not corrected, could a
j degenerate into a condition requiring action under an emergency procedure.
i Oneratina Procainrec j
Written instructions which define the normal method, means, and limits of operation, in j
all modes, of a nuclear power station, a system or systems within the station, or station i'
l processes.
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h Eurchaser 5iO The organization responsible for issuance or administration or both of procurement documents. (Refer also to ANSI N45.2.10 for definition of " Purchaser".)
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Quality _ Assurance
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All those planned and systematic actions performed for the purpose of establishing a high level of confidence that:
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a)
Work performed on the project conforms with the requirements of the i
l applicable codes, standards, license stipulations, safety analyses, design drawings, specifications, procedures, and instructions; 4
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d)
A structure. system. or comgeeeet wiii gerform satisfacteriiy in service:
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c)
Appropriate records, documentation and/or drawings are maintained to show compliance with a) and b) above.
Osinlity Acciirmnce Dnctiments Those documents inclusive of the QA Policy Document, Nuclear Quality Procedures, QA Plans, Procedures (and associated data sheets), logs, etc., which have been approved for use, and whose intended function is to provide direction, verification, or documentation for activities affecting quality.
Quality _ Assurance Plant Quality Assurance Plans are those documents specifically designed to provide detailed quality requirements for a given functional area. The plans are generated by applying the Q
18 criteria of 10CFR50, Appendix B, to each functional area and then deriving the specific quality requirements for that area.
i Quality Accitrunce Records
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Those records (see Reference 7.9) which have been completed and furnish documentary
- evidence of the quality ofitems and/or activities affecting quality.
Control provisions shall be established for in-process records at the point at which they i
attest to completion of quality related activities.
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Quality rammercimwrade O
I Classification of a Commercial Grade Item (CGI) intended for safety-related use, procured from a QA approved source and dedicated in accordance with approved station procedure; which meets the 10CFR21 definition of CGI.
Commercial Grade Item (CGI) - An item that meets all of the following criteria:
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4 a)
Not subject to design or specification requirements unique to nuclear facilities or activities; b)
Used in applications other than nuclear facilities or activities; and i
c)
Is ordered from the manufacturer's published product description, e.g.,
Q catalogue, as an off-the-shelf item.
i Quality _ Control Those wtivities which deal directly with the measure:nent, observation, or verification of physical characteristics of materials, components, or systems which provide a basis for controlling quality to within predetermined limits, or requirements, including adequate quantitative and/or qualitative acceptance criteria by which an activity can be measured.
Quality _ Requirements
'Ihose factors which define limits which must be met so that the product will perform its intended function reliably throughout its design life. They include, but are not limited to, O
conditions imeertant to grener materiet seiection. ->nefactere. co strectiea. a#a inspection; substantiation that material or parts conform to all specification requirements, 1 16 Revision 13
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testing to demonstrate adequacy of performance; protection of finished parts to prevent deterioration; and conditions for operation, maintenance, and repair which enable l
continuing operation within prescribed margins of safety and within prescribed l
performance limits.
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Right of Acrecc l
The right of the purchaser or designated representative to enter the premises of a supplier for the purpose of inspection, surveillance, or quality assurance audits.
Regiilainry Criterin That body of NRC publications which define the conditions which must be met to obtain and hold an NRC Construction Permit, Operating License, and Licenses for individual Q
operators.
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Review i
A deliberately critical examination. The term includes the routine monitoring of station 1
operation performed by the Vice President-Nuclear and his staff as a normal management function, and the formal independent evaluations of certain contemplated actions and after-the-fact investigation of anomalies conducted by a duly constituted review and/or audit group.
Kafegnard (of Nuclear Material)
Measure taken to prevent diversion of nuclear materials into unauthorized or illegal uses O
<seeaiseAccountabiiity).
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l Safety-Related O
i (See " Essential")
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l The performance by a supplier of activities such as design, fabrication, inspection, l-nondestructive examination, repairs, installation, or training.
1 Rienifiennt Conditions _Adverm Tn Quality I
Any conditiens that could affect safety-related structures, systems, or components ability r
i to function within design requirements or adversely alter performance characteristics.
O si e - - - - - d = =
The file which is established for the purpose of accumulating and storing all documents and records pertaining to quality-related activities throughout the life of the nuclear plant.
Kiinnlier Evaltiation Those activities which determine the effectiveness of implementation of the supplier's Quality Assurance Program. A variety of methods may be used to perform a supplier i -
evaluation and are described in the NQPs.
Surveillance O
surveiiiance is the or audit feectien censisties ef fermai aed informei ebservatiees te determine that work is being performed in accordance with the requirements of the 1-18 Revision 13
i controlling documents and drawings (see also Audit and Monitor). Surveillance activities shall be performed in accordance with requirements specified in NQPs and QAPs.
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Surveillance Texting j
Periodic testing of structures, components, and systems related to nuclear afety, for the i
purpose of verifying that such safety-related structures, components, and systems continue to function or are in a state of readiness to perform their safety functions.
i Testing i
The determination or verification of the capability of an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions. (Refer also to ANSI N45.2.10 for defm' ition of " Testing".)
O Tracenhility The capability to identify a particular component or material and to discover its entire history, back through the written records of its material formulation (heat number),
manufacture, inspection, installation, test, operation, maintenance, repair, and replacement.
f witnece l
Formal observation by a knowledgeable person of a particular, prescheduled event during manufacturing, inspection, installation, testing, operation, maintenance, or repair. The purpose of witnessing is to provide direct observation and evaluation of an event, O
independent of the oreeg performina ihe geriscuiar egeration.
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i 2.0
SUMMARY
DWRIPTION 11 his section defines the NPPD commitment for compliance to 10CFR50, Appendix B, as applied to safety-related structures, systems, and components associated with Cooper
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t Nuclear Station.
i 12 In addition to describing commitments to 10CFR50, Appendix B, this Section also identifies NPPD's commitment to selected ANSI Standanis and their associated Regulatory Guides.
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(
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11 he President and Chief Executive Officer (C.E.O.) (Figure 1) represents the highest level I
of management responsible for establishment of Quality Assurance policies, goals, and
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objectives. The responsibility and authority as the nuclear officer has been delegated to the Vice President - Nuclear through the President /CEO. This authority includes the right to dimet, enforce, and perform any action required to ensure all activities conducted at Cooper Nuclear Station are in compliance with 10CFR50, Appendix B. In addition, the Qtality Assurance Division which reports to the Vice President-Nuclear, shall have -
complete independence to perform audits, surveillances, inspections, verifications, acetunents, evaluations and shall be independent of those groups performing, designing, purchasing, fabricating, shipping, storing, cleaning, erecting, installing, inspecang, testing, operating, maintaining, repairing, refueling, in-service inspecting, and modifying.
12 Figure 1 of this document outlines the QA Division functional organization. Quality j
Assurance Personnel shall have sufficient authority and organizational freedom to:
i h
(1)
Identify quality problems; l
2-1 Revision 13
(2)
Initiate, recommend, or provide solutiwu fer coaditions adverse to quality; O
(3)
Verify implementation of solutions.
2.2 Di=lity Ammumnce Pmgnm 11 The Quality Assurance Pmgram applies to all activities which affect nuclear safety. This Policy Document identifies the industry Standards and Regulatory Guidance documents which are applicable to the implementation of the Quality Assurance Program for Cooper Nuclear Station. Specific exceptions to criteria contained within the referenced Standards are herein described in following sections, as applicable. Specific implementing criteria for the Quality Assurance Pmgram are contained in lower level implementing procedures.
Procedures are prepared for each important activity of station operation which clearly O
define the work to be performed on a step-by-step basis and identify, where appropriate, the results to be achieved. Mandatory QC inspections or tests are performed on an independent basis to verify that specific work activities are being correctly completed (correct results obtained) and are incorporated into the work procedures directly or by attachment. Management review and QA audit activities verify that the Quality Control Program is implemented. Procedures which implement the Quality Assurance Program will be reviewed periodically to assuit that the requirements of the program are being met and new requirements are being incorporated, as appropriate.
12 Specific to the related ANSI Standards for this criterion, the following commitments apply:
1.
ANSI N18.1-1971 " Selection and Training of Nuclear Power Plant Personnel,"
O shaii grevide direction fer seiectieS aed traininS of gersennei fer the Nuciear Power Group.
2-2 Revision 13
2.-
ANSI N18.7-1972 "American National Standard for Administrative Controls for Nuclear Power Plants," and the associated Regulatory Guide 1.33 (Safety Guide 33), apply to the CNS Operational QA Program with the same exceptions as those taken in other sections of this Policy Document to ANSI N45.2-12.
3Property "ANSI code" (as page type) with input value "ANSI N45.2-12.</br></br>3" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
ANSI N45.2-1977 " Quality Assurance Program Requirements for Nuclear Facilities," and associated Regulatory Guides 1.28 and 1.33, shall apply to the CNS Operational QA Program, with the following exceptions:
Where Section 11 " Inspection" identifies the reporting relationship between the inspector and the "immediate supervisors who are responsible for the work being inspected," the CNS QC Program only requires that the individual performing the verification function shall not perform or directly supervise the work being inspected.
O 13 Table 1 identifies the structures, systems, and major components associated with Cooper Nuclear Station covered by this program. Table 1 is not intended to be all inclusive. The Operations, Support and Engineering Divisions, with the assistance of the QA Division, will identify essential structures, systems, and components to be included within the scope of the QA Program. The Quality Assurance Program is designed to provide control over all activities affecting quality of essential items to a degree consistent with their safety-related importance. These activities will be governed by approved plans and instructions and these documents shall be followed under controlled conditions.
14 In addition to essential structures, systems, and components, applicable portions of this program shall be applied to selected nonessential structures, systems, and components important to station reliability and performance. Specific application will be identified in j
dedicated Quality Assurance Plans.
i 2-3 Revision 13 j
l l
15 Special pincess controls, test equipment, tools, skills (training, if required) shall be used during the conduct of inspection, verification and checking activities to assure a high j
standani of quality and reliability has been obtained on safety-related items covered by the
. Quality Assurance Program. Test equipment and special tools will be calibrated against a specified secondary standard.
f 4
4 16
. Experienmd individuals (which may include personnel from other divisions of the Nuclear l
Power Group (NPG), and/or outside qualified individuals) may be requested to assist in
{
performing audits and inspections of certain CNS quality-related activities at the direction l
]
of the Division Manager of Quality Assurance.
During these assignments, these individuals will have sufficient organizational freedom to identify and recommend corrections for quality deficiencies noted.
i 17 The Nuclear Training Department, in addition to QA Staff personnel, provides QA f
i i
lh indoctrination for NPG employees as described in nuclear training program descriptions.
Cooper Nuclear Station personnel will receive training to familiarize them with the quality assurance program. The Quality Assurance Training Program for Quality Assurance l
auditors and audit team leaders provides initial training for the performance of fundamental j
QA tasks, and provides continuing training to enhance both auditing skills and technical
^
knowledge. Quality Assurance training for QA Staff and station personnel will be i
periodically evaluated and feedback provided to ensure effectiveness and improvement.
The Quality Assurance Training Program and applicable training materials will receive management approval as required by governing programs and processes.
q 18 Training activities will be audited periodically by the QA Staff to verify its scope and 1
effectiveness.
i i
i
!O i
2-4 Revision 13 4
i
- l.. _,
2.3 naign enntrol O
'u J 11 Implementing procedures outline the method for identifying, controlling, and implementing design changes within the Cooper Nuclear Station. The procedures provide i
the mechanism for correctly translating the design changes and regulatory requirements into specifications, drawings, procedures, and instructions. They also establish the method of reviews, interface requirements (with original design organization, if required),
approvals, and the organizations delegated the authority to implement the design change.
12 Design control measures shall include the review for suitability of application of items that are essential to the safety-related function of the system involved. A necessary part of this review concerns the safety classification ofitems to be procured. In those instances where the normal methods of Section 2.7 cannot be applied and it is necessary to purchase
" commercial-grade" off-the-shelf items for use in essential applications, verification will (n) be performed to ensure that the part utilized is functionally acceptable for the essential j
application. This verification may include dedication upon receipt, analysis, or other definitive method.
13 All design changes-initiated for C00pcr Nuclear-Station, vill ix forwarded-to-the QAhsion for review and-independent evahrativu. These reviews shall-vedfy the compatibility of the design change with applicable codes; standards and Tegulatory requirements-Itesis to consider-includeveactorphysics, scssrthcinial hydraulic and accident analyses, coni mtibility of niaterials accessibility-for-in-service inspection; i
ir.ia,ionancc, mimhs, anddelineation of mytance criteriaforinspectrorrand tests.
17s QialigXundhWDIHil6591115Hudi(bilfRWMdekikjhdhjeidikirii[kijIphasiM ileNlopsiiEnWiispibhENsi6n?
14 Final acceptance of the design change will require an independent verification or check of the design adequacy such as by the performance of design reviews, by the use of alternate 2-5 Revision 13
or simplified calculational methods, or by the performance of a suitable testing program.
- O 15 Specific to the related ANSI Standards for this criterion, the following commitments apply
l l
l 1.
ANSI N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear
)
Power Plants," and the associated Regulatory Guide 1.64, shall be applied to design activities involving safety-related modification work and the revision or development of plant design documents occurring during the operational phase of l
CNS. However, where codes, standards, or design requirements are referenced, t
]
or are incorporated into the standard by reference, which are in conflict with s
original design commitments as set forth in the Updated Safety Analysis Report
{
(USAR), the USAR commitments shall govern. Later revisions of applicable codes l-and standards may be specifically invoked by the design requirements where
}
deemed appropriate, consistent with the overall commitment to maintain the plant l
in an " equal to or better than" original condition.
i 2
2.
ANSI N45.2.4-1972 " Installation, Inspection, and Testing Requirements for i
Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations," and its associated Regulatory Guide 1.30, shall be applicable to the CNS Operational QA Program for safety-related modification work, with the following exceptions / clarifications:
j (a)
The definition of Class I and Class IE electrical equipment set forth by this a
standard does not conform to the equipment categories of CNS. Electrical items upon which the Operational QA Program is based are included in i
Table 1 of this policy document and the CNS "Q" List. The scope and O
aggiicabiiity of this standard shaii necessariiv be iimited ie these delined l
areas.
2-6 Revision 13
1 (b)
Appuyriate mquimments for installation, inspection, and tests are defined in job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be i
established which specifically address the various areas of this standard.
During the development of work packages, consideration will be given to i
the areas outlined in Section 2.3, as appropriate.
=
I (c)
'Ihe mquirements for installation, inspections, verifications, and tests shall j
. be included in the work instructions.
In the development of these a
instructions, consideration will be given to the guidance provided by Seedons 4.0,5.0, and 6.0 of this standard, and appropriate requirements will be incorporated into the instructions. It is not intended that separate pmcedums be established to specifically address all of the areas referenced.
2 i
Q (d)
Application of the guidance provided by the additional codes and standards listed in Appendix B will be considered to the extent that such codes and b
standards provide useful and practical guidance for the work being performed. Commitments to the guidance of N45.2.4 shall not include l
commitments to the guidance of referenced standards.
l d
3.
ANSI N45.2.5-1974 " Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants," and its associated l
Regulatory Guide 1.94, shall be applicable to the CNS Operational QA Program i
i
[
for safety-related modification work, with the following exceptions / clarifications:
i O
i i
l J
i 2-7 Revision 13
NOTE O
With respect to structural concrete, acceptability shall be documented in accordance with the District's Dedication Procedures, which will be verified by independent QA audit.
(a)
Appropriate mquirements for installation, inspection, and tests will be set forth byjob specifications and work instructions developed as a part of the modification work package. It is not intended inat separate procedures be established which specifically address the various areas of this standard. However, in the development of the work package, consideration will be given to the areas outlined in Section 2.2, as appropriate.
O (6)
Therea" ire e=t= orca #troi a c >ibrtioa er "ri=8 #4 test equipment set forth by this standard shall be applied to all measuring and test equipment used by NPPD or their agents, test laboratories, and contractors. Such requirements, however, will not be imposed i
on commercial batch plant facilities. Instrumentation at commercial j
batch plant facilities will be evaluated by NPG construction management personnel, or their designated representative, to determine that sufficient accuracy can be obtained.
i (c)
For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch plants.
For these small quantities of concrete, it is unreasonable to expect commercial facilities to shut down normal operations to provide O
ceroned ore
, cement, adseres, ny ash, wer, e. in this respect the qualification tests required by Table A for aggregate; 2-8 Revision 13
cement, admixtures, fly ash, and pozzolans; water and ice will not pa be required. Appropriate evaluations will be made to determine that good quality and generally-acceptable materials are used. NPG-construction management evaluation, coupled with slump tests, air entrainment tests, and concrete cylinder strengths, will provide adequate control and qualification of the concrete.
(d)
Design mixes consistent with, or equivalent to, original requirements will be specified and the results of the cylinder tests will be evaluated by NPG construction management based on the acceptance criteria associated with the original design mix requirements.
(e)
The inspection requirements of Section 4.2 will not generally be O
performed as the small quar.tities of concrete involved in modification work will no doubt be mixed using materials already in the batch plant bins. Control of storage of materials would not be practicable.
(f)
If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the requirements of ACI-304, ASTM C-94. Where certifications are not available, two concrete test cylinders representing the first and j
last one-third of truck mixer contents shall be taken for evaluation of the mixer truck, over and above the norual concrete cylinders taken to evaluate the in-place concrete. The concrete batch plant facility shall be inspected by NPG construction management and the (G
CNS QA Staff to assure that reasonable controls are being exercised
)
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t c
with reference to the inspection guidelines set forth by Section 4.3 i
(1) and (2).
i 2
3 (g)
Inspection of fills and earthwork will meet the general requirements l
set forth. The extent to which individual inspection requirements i
are met will depend upon the nature and scope of the work to be l
t performed.
i i
i
[
(h)
Except for normal batch qualification tests (slump, air content, I
temperature, and compressive strength) and initial reinforcing steel l
{
certifications, the in-process tests required by Table B are generally applicable to the periodic control which must be exercised with reference to long-term construction type programs. The in-process j
test requirement of Table B are not considered applicable to short-term modification work as would be required by QA at CNS.
1 4.
ANSI N45.2.8-1975 " Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," shall be applicable to the CNS Operational QA Program for safety-related modifi ation work, with the following clarification:
(a)
Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the USAR and other appropriate design documents, the original design requirements shall govern.
O 2-10 Revision 13
_ _ _ _ _ ~..
2.4 ProcuremenLDocument Control O
11 Nuclear Power Group procedures are required to define the applicable requirements, design basis methods, and procedures for procurement of spare parts, materials, equipment, and services for essential nuclear systems. These instructions and procedures shall also include provisions for assuring that the necessary quality requirements are inwrporated directly into the procurement documents for essential spare parts, material, equipment, and services. These instructions and procedures shall also include provision for assuring that the necessary records are specified and provided to the District by the supplier.
12 The basic principles and practices included in these procedures are expected to be applicable to any purchasing activity necessary for operation of the station; however, additional special controls may be necessary for major modification or repair activities.
O 13 Procedures covering psuicment provide for independent Quality Assurance review of j
essential and quality wnimetrial grade purchasing tiocumentsrQA review and approval of suppliers; and QA Audit of contractor and supplier activities. Didiff ?MidiiiiW3 sill M!ib66(EllfNHEW5HickWWhCd6EEhiEMifdC&Ehtidllbiki%5611ty:56tirhEWidtjfddd i
ME?MR 14 Revisions issued to any procurement document will be subjected to the same review and
)
1
- approval as the original order.
15 All procurement documents issued to suppliers of safety-related items or services require that the supplier implement a Quality Assurance Program that meets the intent of 10CFR50, Appendix B (with the exception of those suppliers performing all work at O
coeger sociear station or ia the coiumbus oenerai ofisces under the District s o^
Program). The Quality Assurance Programs submitted by the suppliers will be evaluated 2-11 Revision 13
L by NPPD QA to ascertain that they meet the criteria established in 10CFR50, Appendix B.
All safety-related suppliers shall appear on the applicable section of the NPPD Suppliers List.
16 To the maximum extent practicable, the as-built drawings and specifications for Cooper Nuclear Station will be used in procurement of spare parts, material, and replacement parts.
17 Where necessary, because of design modifications, or where it is necessary or desirable to upgrade quality in replacement parts or material, necessary modifications will be made to drawings and specifications to incorporate requirements for currently appropriate quality level. These modifications or upgrading of replacement parts will be accomplished in accordance with approved instructions, procedures, and drawings. These documents will be subject to required reviews before being implemented.
O 18 Specific to the ANSI Standard related to this criterion, the following commitment applies:
1.
ANSI N45.2.13-1976 " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" and it's associated Regulatory Guide 1.123, Revision 1, is applicable to the CNS Operational QA Program, with the following clarification:
(a)
It must be acknowledged that equipment and components purchased during the design and construction phase were not purchased on the basis of present-day standards, especially with reference to supplier approval and supplier Quality Assurance Programs. In this respect, replacement parts and spare parts for existing equipment are often limited to sole-source O
surgiiers.
Such regiacement parts or se re e rts are gerchased to appropriate quality standards, verified by NPPD QA, to maintain an " equal 2-12 Revision 13
i i
l to or better than" condition but it is not considered practicable to backfit e
the requirements of this standard to all such suppliers.
l 2.5 Instwtinnt Pnminms; and Drawings
]
L i
i il Quality Assurance activities and other activities which have nuclear safety significance will
)
y be prescribed by documented instructions, drawings, and procedures as appropriate and j
i i
shall be accomplished in accordance with these instructions, procedures and drawings.
1 These instructions will be sufficiently detailed and explicit so that any supervisor, j
inspector, or auditor can, by observation, determine whether or not activities are being satisfactorily accomplished and documented. These documents shall include the qualitative and quantitative acceptance criteria necessary to assure satisfactory completion of the test t
procedure. Those acceptance criteria shall, where appropriate, require post installation 1
l testing prior to returning the component or system to service. Repair maintenance g
activities on essential systems are performed in accordance with the Maintenance Work Request process. L iquiidocumentatiortfur pial grwsws zuw furwndedio-the j.
ess44-st.ff foi ie ie.,aeog witi, s,eciai e,t,.aures and speciaanaintenance a
ys und.
MkkhhNfkMkf.
((fkk h kf M [ M kifkiiiiNeffincauiWipebfat;thsiiThiihiecial hiklidihdhciEMif9illfiHMMD*6idte leiiE#iliiWiWiistarid(iisiitydistgmaparticl&2 Document Hierarchy shall be as follows:
Level I:
License Basis Documents i
)
Technical Specifications O
- rating ucenz 2-13 Revision 13
n l
" Safety Analysis Report" O
l Updated Safety Analysis Report f
i NRC Correspondence (Commitments and SERs) l Quality Assurance Policy Document l
l LevelII:
Design Specifications and Drawings l
l Level III:
Procedures Administrative Procedures i
Operational Procedures f
l C Work Procedures 1
1 l
Nuclear Power Group Directives l
Nuclear Quality Procedures i
Ixvel IV:
Policies and Guidelines l
l 2.6 wiiment enntrol 11 Administrative control procedures shall be established by the Nuclear Power Group (NPG)
O to contrei the identiiication. indexins, fiiins. retentien, retriev>>. and distribetion of quality-related records and documents.
Control procedures shall be reviewed and i
2-14 Revision 13 l
[
approved by authorized personnel and are distributed to and used at the site of the activity.
L i
'Ihese procedures shall also ensure that changes to quality-related records and documents l
j receive the same level of review and approval as the original document.
t 12 The overall objectives of NPPD document control are to:
t i
a)
Identify those records and documents which are used to control, maintain, modify, or document quality-related activities in support of Cooper Nuclear Station.
b)
Establish an index of quality-related records to enable personnel involved in safety-related activities to determine the proper documents to be used in the activity.
Q c)
Establish a filing system.
d)
Establish periods of retention.
e)
Establish measures to control distribution and revisions.
13 Nuclear Power Group Management is responsible for establishing effective interfaces, and document control procedures.
14 Specific to the ANSI Standard related to this criterion, the following commitment applies:
1.
ANSI N45.2.9-1974 " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," and its associated O
Reseiatory Guide 1.88 shaii be aggiicabie to the CNS operatieeai o^ Prestam.
. with the following exception / clarification:
2-15 Revision 13
1 (a)
For those design, manufacturing, construction, and operating mcords generated prior to implementation of this standard, it is not our intent to backfit the detailed requirements of this standard to those records. All such records, however, have been initially designated for lifetime storage, until specific review dictates otherwise, and will be stored in the record storage facility. Record indexes and filing systems shall be established to permit reasonable identification and retrieval.
The records will be stored and preserved per the requirements of Section 6.0 of this standard.
2.7 Cnntml nf Purch2ced Material; huipment; and Services il NPPD receiving inspection instructions provide for determining that all purchased materials, equipment, and services purchased directly or through a contractor, supplier, Q
or subcontractor meet the requirements specified on the original procurement speci6 cations, such as code, standards, specifications, dedication, material identification, etc. The completed receipt inspection report will become part of the purchase order package. Procurement documents shall be available at the receiving area to identify the receiving inspections required.
13 Nuclear Quality Procedures provide for evaluation of supplier's quality program to determine effectiveness and compliance to the applicable 10CFR50 criteria as part of the supplier selection process. These instructions shall describe the methods and techniques used to evaluate the supplier's Quality Assurance Program.
14 The QA Division shall re-evaluate the supplier's quality program at intervals consistent j
l with the importance, complexity, and quantity of the item or services to effectively i
O mainiain centrei er 9uaiity. erecurement documentation wiii specify mandatory heid 2-16 Revision 13 1
points for witnessing or inspection of purchased materials, equipment, or services, if required by NPPD.
15 Upon receipt at the station, material, parts, and equipment purchased and identified as
" Essential" or " Quality Commercial Grade" will be placed in a segregated storage area until all inspections are complete and all required certifications and documentation is received.
16 Items in segregated areas will not be issued, by the Warehouse, without the written permission of the Site Manager or designee, and then only after proper arrangements have been made to assure that necessary steps will be taken to bring all aspects of the particular item into conformance with normal requirements prior to the system containing components in " Hold" status being considered operable.
17 Suppliers of essential equipment, if appropriate, shall be required to provide certified documentary evidence that the material supplied conforms to the purchase document requirements such as material test report, code required test and inspection, documentation, etc. A complete set of documentation required by the procurement document for all essential materials, equipment, and services will be filed at Cooper Nuclear Station.
i 2.8 Identifiention and Cnntrol of Partt Materials; and Cnmponents il To the maximum extent practicable, activities carried out during operation of the Cooper Nuclear Station will comply with the requirements for identification and control of materials, parts, and components as set forth in the as-built drawings and specifications for the station. Where special measures are required to assure proper identification of O
es.
. -d -m-ts. such reeuirements wiii be incergerated directiv inte the procurement documents for such parts and assemblies. Such identifications which may 2-17 Revision 13
1 include heat numbers, senal numbers, or other means of identification of the item will be incorporated into the procurement documents to provide means of traceability. Material received at the station (which has not been properly identified) will be segregated and tagged to indicate a " Hold" status. Except as indicated in Section 2.7 above, such parts will not be issued or used prior to final acceptance. CNS procedures will incorporate requirements necessary to assure that the identification measures are properly carried out at the station, that unacceptable items will not be used in essential systems, and that the
{
l components to be used in essential systems receive independent verification of component identity prior to installation.
2.9 cnntml of Snecint Pmeeuec il General maintenance procedures provide for performance of special processes by qualified personnel using qualified and approved procedures. Control procedures provide for-QA Q
res., insgden, documentation of activities, and for proper integration of QC Inspection. In most cases, the procedures will be prepared only when a specific process is required in the maintenance, repair, or modification of essential equipment at CNS.
These procedures shall also require special processes, such as welding, heat treating, and NDE, to be controlled and performed by qualified personnel in accordance with qualified procedures.
i 12 Maintenance modification control methods and Station Operating procedures are jiidiiS5iWf reviewed by CNS QA personnel. This review includes verification that necessary codes, standards, quality requirements, and acceptance criteria are incorporated i
to control special processes within established limits.
O 2-18 Revision 13
I 2.10 lapian 4
i!O il Quality Control inspections have been assigned in this policy document to the organization l
basically responsible for the performance of the activity. ' A Peer QC Program will be ll utilized in which QC inspections are normally performed by QC Inspectors who have been 4
selected from within the Nuclear Power Group, and who are many times just as qualified i
to perform the work as they are to inspect the work.
QC personnel will be qualified / certified in accordance with NPPD's commitment to ANSI N45.2.6 and will
]
conduct the QC Program inspections. Detail for the conduct of the QC Program will be procedurally established.
12 Quality Assurance Audits, Assessments / Evaluations, and Surveillance of activities such as examination ofindividual operating personnel and documentation at intervals consistent with the importance of the activity. Direct QA or QC inspection will also be conducted Q
for activities such as refueling, radiochemistry, and environmental monitoring. Special inspections, such as those requiring qualification to ASNT-TC-1 A, will be contracted to approved suppliers. If direct inspection is impossible, indirect control methods will be specified in the instructions to provide a method of monitoring process methods and equipment. The results of all inspections will be placed in permanent record storage.
13 Controlling documents pertaining to quality-related activities receive Station Operations Review Committee (SORC) approval to ensure incorporation of appropriate quality requirements. QA is a non-voting member of SORC.
14 Specific to the ANSI Standard related to this criterion, the following commitment applies:
1.
ANSI N45.2.6-1978 " Qualifications of Inspection, Examination, and Testing O
Per ennei for Nuciear Power Pieets. end its associaied Reseiatery oeide 1.58 is 2-19 Revision 13
I i
applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
i (a)
It has always been the belief of NPPD that, in order to be effective, Quality Control must be built into the operation of the plant. With this in mind, Quality Control and test functions performed at CNS are incorporated directly into the station procedures. Inspection points are i
then performed and signed off by qualified personnel not directly performing or supervising the step (s) being inspected. Selection of QC I
candidates for certification is a function of Station Management. Actual
.l certification of QC inspectors is the responsibility of the QA Division.
]
(b)
CNS does not have the in-house capability to perform nondestructive j
examinations in accordance with SNT-TC-1A.
These services are
]
I
]
currently contracted to an appmved supplier. Any required nondestructive examinations will be performed by personnel who are qualified and certified per SNT-TC-1 A.
2.11 Ted Cantrol 11 Each type of test program performed by the station operating group will be defined by written pmcedures and instructions. 'Ihese test programs include the pre-operational tests, start-up test instructions, operational testing and surveillance testing of structures, systems, and components to demonstrate their capability to perform satisfactorily as a part of an integrated system. Acceptance tests will be developed for structures, systems, and components to demonstrate their capability to perform satisfactorily following repairs or modifk:ation prior to returning to service. Test procedures will identify the inspector, test O
gerrermer, date, and data recorder. each tyve of accertaece test has individeei test pmcedures which include Quality Control provisions, acceptance criteria, and check points 2-20 Revision 13
for observation or checking ofimportant aspects. These test procedure prerequisites will Q
include the test instrumentation requirements and environmental conditions. All Special Test Procedures, Special Procedures, and Station Operating Procedures are routinely reviewed'by SORC, of which QA is a member.
12 Quality Assurance Audits, Assessments / Evaluations, and Surveillance activities will be performed by the Quality Assurance Staff members to assure that tests are being performed in accordance with the requirements of the procedures, that results are evaluated and compared to the specified acceptance criteria, and that tests are being performed by myymyristcly trained personnel. In addition, test procedures shall specify test requiremenos and quantitative and qualitative acceptance criteria where appropriate.
I i
2.12 Cantml af Maamring and Test Fnuipment O
si e>eceaeres sa ti aeri e the resei :ments eriespectie#. - i te ce. repair ano caiidr tie-of all tools, gauges, instruments, and other measuring and testing devices which are used in activities which effect quality of safety-related equipment.
12 Each permanent or temporary installed plant instrument performing an essential function has been identified and placed on a regularly-scheduled program of inspection, test, and recalibration. All test and measuring equipment required for calibration of the above equipment will also be placed on a regular program of inspection, test, and recalibration and will be appropriately tagged. Documented calibration records are reviewed, as required, to evaluate calibration performance and frequency, and changes are made as may be necessary.
i O
2-21 Revision 13
1 13 A Quality Assurance Plan will prescribe the QA functions to be performed relative to the calibration program. Quality Control and Quality Assurance practices require independent checks of calibration activities. Quality Assurance Surveillance performed by the QA Staff members will verify that procedures am being properly followed; that adequate records of calibration and testing of measuring and test equipment are being generated, maintained, and that regularly scheduled adjustments are made to maintain necessary accuracy. For j
I equipment used to calibrate process equipment, procedures will define action to be taken should regularly-scheduled calibration checks reveal an out of specification condition exists. When inspection, measuring, and test equipment are found to be out of calibration,
' an evaluation shall be made, and documented, of the validity of previous inspection or test results and of the acceptability of items previously inspected or tested. Should the evaluation determine that previous inspection or test results obtained with the affected instrument are unacceptable, a Condition Report will be issued. Reference and transfer standaids, traceable to the National Institute of Standards and Technology (formerly NBS),
O
- iti 6 - intai"ed at cus-i i
14 Scheduled and/or unannounced audits or surveillances by the Quality Assurance Staff, the Safety Review and Audit Board, or NPPD management will include review of the calibration program.
2.13 Handling,31,rnee and Rhipping 11 The procedures for procurement and control of essential spare parts, materials, replacement parts, and equipment include the requirements for the control, handling, cleaning, shipping, receiving, and storage of essential parts and material. Quality Assurance Plans and NQPs provide for surveillance and audit to assure that procedures are followed and that essential parts and materials are received, inspected, stored, and
~O controiied in seca a manner se as te greveet deeradation.
2-22 Revision 13
12 Specific to the ANSI Standard relating to this criterion, the following commitment applies:
O 1.
ANSI N45.2.2-1972 " Packaging, Shipping, Receiving, Storage, ed Handling of Items for Nuclear Power Plants," and its associated Regulatory Guide 1.38 is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
(a)
NPPD's QA program is structured to identify safety-related equipment and provide for designation of packaging, shipping, receiving, storage, and handling requirements for purchased parts and materials.
The classifications of this standard cannot be applied directly to individual spare parts or subassemblies of the parent equipment. Due to difference in volume, complexity, inspectability, etc., the packaging, shipping, handling, and storage requirements of spare parts and subassemblies will O
necessarily be different from the requirements which may be imposed on the entire component or piece of parent equipment.
(b)
The majority of items purchased for an operating plant consist of components, subassemblies, and individual spare parts which could be used in a multitude of different applications. Such items are purchased to the most stringent requirement for their intended use. The volume and characteristics of procurement during the operational phase differ significantly from those purchases made during the design and construction phase. Items requiring special storage protection will be identified on the purchasing documents. Items that must be stored outdoors (equivalent of Level D) and items that must be stored in covered but unheated conditions (equivalent of level C) will be evaluated on an individual case basis.
O However, it is not censidered gracticabie te greciessify individuai garts by levels as required by Section 2.7 of this standard. Shipping and packaging 2-23 Revision 13
1 l
requirements for such items will likewise be handled in the procurement documents, as appropriate.
r (c)
QA Audits, Assessments / Evaluations, and Surveillances are performed to verify that the requirements of N45.2.2 are met except as noted in (a) and i
i (b) above.
d i
2.14 In=nactian; Test nad Onerating 5:tatue J
}
11 The NPPD status tagging procedure, already in use throughout the system, has been l
adapted for use in the Cooper Nuclear Station. Where practical, particular emphasis shall
)!
be placed on tagging to prevent unauthorized operation or adjustment which could i
endanger the safety of personnel, damage equipment, or invalidate the results of tests
{
already performed. These tags shall indicate abnormal equipment test and inspection status 9
and reference special instructions for equipment located throughout the Cooper Nuclear j
- Station, s
a 12 Tagging procedures, where necessary, will require that equipment be tagged and that the j
associated power supplies, starters, switches and controls on the main control panel are tagged as well, to warn against operation. In some cases, power supplies will be i
disuunnected and tagged to prevent inadvertent operation. Tagging will be controlled by j
the Shift Supervisor by requiring that serially-numbered tags, obtained from the Control i
Room, be used for all tagging purposes. Records will be maintained in the Control Room to enable operators and Shift Supervisors to determine the status of the equipment tagged.
4 13 A Temporary Modifications Control Program will be maintained to provide a method for i
recording the installation and removal of jumpers, fuses, or wire terminal disconnections.
O iwis i cerd wiii inciude the iocation. reason name of persen aetherizins action. aed name of person performing the installation.
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14 Requirements for tagging are included in the applicable procedures. Status tagging will be verified by aucit and surveillance.
2.15 Nanconforming.Materiak Partg nr Comnnnents il Warehouse and maintenance procedures include requirements for the identification and tagging of nonconforming materials, parts, or components, (See Section 2.8).
b 12-Nonconforming items will be controlled in such a way as to prevent their inadvertent use c
or installation. Such parts will be reinspected and reviewed for adequacy prior to i
7 returning them to the manufactumr, scrapping them, or arranging for them to be reworked j
to conform. Disposition of a nonconforming item will be determined by the responsible
{
supervisor in conjunction with the QA Staff. Writ'en reports of decisions to repair or i
rework essential items will be reviewed and approved in accordance with maintenance
'O
==d'or desie ce=troi proced res.
I i
j 13 Any decision to reduce requirements to permit use of nonconforming parts, materials, or components in essential systems, will be documented per the Corrective Action Program,
)-
and will be subject to Station Operations Review Committee (SORC) review and approval.
l Appropriate design modification documentation will be completed, if required.
14 Approved Procedures will be utilized for repair and rework of. essential parts and l
equipment. All such rework will be thoroughly documented, including Quality Control and Quality Assurance Surveillance activities, to assure conformance with the requirements of the specifications, procedures, and other controlling documents.
i 15 Essential equipment classified as scrap will be identified and segregated in such a manner b
to prevent inadvertent use or installation in an essential system.
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1 l
i 2-25 Revision 13 i
i I
4 2.16 rwive_Achon
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O 11
'Ihe Corrective Action Program (CAP) for CNS shall provide the measures to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, i
defective materials and equipment, and nonconformances are promptly identified and corrected. Measures taken to disposition significant conditions adverse to quality shall include; immediate actions taken, the cause of the condition, action taken to preclude j
recurrence, and corrective actions. The identification of significant conditions adverse to quality shall be documented and reported to the appropriate levels of management.
12 The CAP shall be utilized by all personnel performing operation, maintenance, modification, or other quality related functions / activities at CNS, to document and report such deficiencies / discrepancies as:
f
-l a)
Deviations from approved procedures.
O 6) we#ce ror-i== < -ri is. 9 rts. er ce-Pe#e ts >c-ved tre-e#tside suppliers on essential purchase orders.
c)
Noaconforming materials, parts, or components within the plant.
d)
Nonconforming materials brought on site without following established receiving and inspection procedures.
c)
Orders or recommendations to stop work.
f)
Reportable occurrences.
g)
Any other deficiency which violates the intent of the Quality Assurance Program and which could have a significant adverse effect on quality.
h)
Deviations which could be reportable under 10CFR21.
]
13 Relevant Nuclear Action Item Tracking (NAIT) reports will be prepared and distributed to Nuclear Power Group Management on an appropriate frequency to permit timely management overview and adjustment of related performance.
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1 i
14 NRC Regulations which require formal reporting to the NRC of failures, malfunctions, deficiencies, unusual operating experiences, and deviations which may have a significant effect on quality or safety will be myiewed and evaluated by the Station Operations i
j Review Committee and, where appmpriate, by the Safety Review and Audit Board. It will be the responsibility of the Nuclear Group personnel to identify and promptly correct all i
such deficiencies or malfunctions either by improved maintenac;e, repairs, replacements, or modification. In all cases, the objective and the corrective action will not only be to correct the existing defect or deficiency, but also to include measures to determine cause i
and prevent recurrence of simbar failures. Quality Assurance activities will verify that i
l corrective action is performed in accordance with approved written procedures and that the details of the corrective action are properly documented for the permanent station records.
15 A separate report may be prepared for each nonconformance. However, nonconformances may be grouped based on known or potential common cause, so that generic application O
and comprehensive corrective actions are considered.
16 A quarterly trend report shall be issued to the Vice President - Nuclear, which may identify adverse trends that require corrective action.
17 Deficiencies and/or deviations identified by QA Staff personnel shall be reported per the guidance defined in Nuclear Quality Procedures and/or the CNS Corrective Action Program.
2.17 9mlity Amrnnce Records 11 All activities having a significant effect on quality and safety will be thoroughly O
documenied, and aii sech documentation wili be incorporated into the record storage system. Procedures will require appropriate physical storage and personnel to maintain 2-27 Revision 13
these files. Record identification, storage, retrieval, access, control, retention, and safeguaniing of all quality-related records associated with CNS will be in accordance with approved procedures. Records to be maintained include all records accumulated during engineering and construction and those records generated during station operation, maintenance, and modification as defined in the CNS Technical Specifications. These records shall also include qualification of personnel, equipment, and procedures.
Inspection and test records shall identify the inspector, data recorder, method of observation, results, Waw, and all nonconformance reports issued to document noted
' deficiencies.
12 Nuclear Power Group personnel will be allowed to maintain active working files at their work stations. 'Ihe time frame for submitting these records to record storage facilities will be determined by their respective administrative procedures.
- O 13 Administrative procedures shall provide for methods for changing records that provide clear identification of the change and must be initialed and dated by the person making the change and by persons authorized to approve the changes.
14
'Ihe program will include Audita of record storage facilities to assure that the procedures and controls are properly implemented. Detailed procedures describe processes for receiving records into the facilities and for making decisions on removal and disposal of outdated or superseded records. Refer to Section 2.6 " Document Control" for the commitment to ANSI N45.2.9.
2Property "ANSI code" (as page type) with input value "ANSI N45.2.9.</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..18 Audits il Scheduled and unscheduled audits will be performed to assess the effectiveness and O-ger<brmance of gretrams and gersonnei within the scene of the cNS Qeaiity isserance Program. Quality Assurance Plans defm' e the application of the Quality Assurance 2-28 Revision 13
Program to operations, maintenance, engineering, plani support and other diverse activities a
!. bq and programs. NPPD Management may request audits of specific activities of specific concern to them.
The scheduling of internal audits will be coordinated to avoid interference of operating activities at the station to the extent practical. The scope of each 4
audit will be planned to focus, in part, on areas of vulnerability and on the quality of the product of the programs and personnel. Audits shall be performed in accordance with written instmetions or checklists and conducted by trained personnel not directly 1
responsible for areas being audited. Upon completion of the audit, a formal report will be prepared and transmitted to the organization audited, which will include an evaluation 1
statement regarding the program's effectiveness. All audit findings identified will be 4
documented and appropriate follow-up action will be taken to assure that corrective action has been implemented. Follow-up action, including re-audits to verify corrective action, shall be fully documented. The audited organization shall review r.nd investigate any adverse audit findings to determine and schedule appropriate corrective action including O
action to preclude recurrence, and shall respond as requested by the audit report. The Division Manager of Quality Assurance is responsible to see that the requirements for audits described in this policy document are carried out. The Safety Review and Audit Board (SRAB) will provide oversight of the CNS Quality Assurance Program and audit results.
12 Specific to the ANSI Standards relating to this criterion, the following commitments apply:
1.
ANSI N45.2.12-1977 " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants," and its associated Regulatory Guide 1.144, is applicable to the CNS Operational QA Program, and to the Supplier Audit Program.
O 2.
section 4.o of AsSi Ni8.7-1972 " Administrative Centrois for Necieer Power Plants," will be used as a guide for scheduling c.ad conducting audits.
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1 3.
The frequency of audits will be in accordance with Regulatory Guide 1.33,
" Quality Assurance Program Requirements (Operation)".
2.19 AMitinaal ANSI. Standards 11 ANSI Standards applicable to the CNS QA Program for Operation, not directly related to the preceding sections, are discussed in this section:
1.
ANSI N45.2.1-1973 " Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants," and its associated Regulatory Guide 1.37, is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
(a)
Cleaning requirements for almost all maintenance, repair, and modification C
work will be considered as a part of the overall job requirements. In this respect, detailed cleaning procedures will not generally be prepared as separate documents. Necessary mquirements, consistent with the scope of the work, will be included as a part of the overall work instructions.
System cleanness is controlled at CNS by the following methods:
(1)
Parts and components are checked for cleanness during receipt inspection and stored in a manner that will ensure adequate levels of cleanness are being maintained.
(2)
Work instruction for safety-related maintenance activities will be evaluated by Shop Supervision to assure that adequate Foreign Material Exclusion (FME) controls are incorporated.
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(3)
Parts and components are inspected for cleanness prior to installation in accordance with CNS maintenance procedures.
(4)
Work areas are maintained at a cleanliness level appropriate to the maintenance or modification activity being performed.
(5)
Quality Control, Supervisory, or Engineering Inspections before, during, and after safety-related maintenance or modification-activities address system cleanness.
(6)
Random QA Audit, Assessment / Evaluations, and Surveillance of safety-related maintenance or modification activities requires verification of part, component, and system cleanness.
Q (b)
For cleanness classifications where the scope of plant modification work is such as to make application of the guidance provided by this standard practicable, the cleanness classifications and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work l
requirements.
(c)
For most modification or maintenance work, however, involving only small portions or individual components of larger systems, it is not considered practicable to conduct cleanness tests with ASTM ABBE-70 Series. Appropriate cleanness will be maintained during the work and preoperational flushing will be conducted, consistent with the scope of the work performed and the original design requirements. Controlling the parts and components and the work area has provided CNS with reasonable
.O ieveis of asseraace that system cieanness wiii de ->intained. in addition 2-31 Revision 13
l
~
i.
I to the above, the Water Chemistry Department routinely samples r.nd tests t
1 for system cleanliness, corrosion, crud buildup, etc.
l 2.
ANSI N45.2.3-1973 " Housekeeping During the Construction Phase of Nuclear i
4_
Power Plants," and its associated Regulatory Guide 1.39, is applicable to the CNS
)
1 I
Operational QA Program, with the following exceptions / clarifications:
)
1 (a)
The plant has been divided in zones for fire protection and security purposes. The zone designated for cleanness in the ANSI Standard are primarily intended for control or work during construction of the plant.
i
'Iherefore, the CNS facilities will not be classified by the zones designated in the Standard general housekeeping rules.
Limitations on eating, j
drinking, and smoking are already provided in existing CNS procedures.
[
Where special cleanliness controls, tool, and material accountability are
> Q required for particular types of work, temporary clean areas will be j
designated and defined in the procedures and work packages for i
accompliahing the work.
l
)
l (b)
Fire protection and prevention will be provided in accordance with NPPD evaluation of the CNS fire protection system as required by NRC regulations.
t
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(c)
Station procedures have been reviewed to determine the need for particular j
cleanness, housekeeping, and control provisions.
Where indicated, e
procedures have been revised to incorporate such provisions, using the guidance of ANSI N45.2.3.
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i 2-32 Revision 13
I i
l 3.
ANSI N45.2.23-1978, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants".
This standard is applicable to the
[
Operational QA Program at CNS and to the Quality Assurance Division Training
- Program, f
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1 O
1 2-33 Revision 13
3.0 ORGANIZATION _AND_ RESPONSIBILITIES O
il Nebraska Public Power District is solely responsible for the operation of the Cooper Nuclear Station and will fulfill the objectives set forth in the Quality Assurance Program for Operation through its own organization and by contract with qualified contractors and consultants.
3.1 General il The overall Quality Assurance Program for Operation shall be conducted in accordance with the three levels of responsibility: Work Performance and Quality Control, Management / Supervision Oversight, Quality Assurance Audit / Surveillance and Assessments.
Q 12 Table 2 defines the three levels of Quality Assurance as they are to be implemented for station operation. The three level concept is applicable to all safety related activities conducted at Cooper Nuclear Station.
13 It is intended that clearly separate lines of responsibility be maintained between those responsible for the operation of Cooper Nuclear Station and those responsible for Quality Assurance oversight to verify that all quality and licensing requirements are i
consistently being met. QA responsibilities will vary depending upon the type of activity involved (See Section 4.1.3).
Additional details on individual QA responsibilities are given in the paragraphs which follow, together with additional explanation of the interrelationships between the various supervisors and managers involved.
O 3-1 Revision 13
3.2 Nr. clear Power Grnnn Management il Mr gement responsibilities include assuring that activities under their control are conducted in accordance with the CNS Quality Assurance Program for Operation. This includes but is not limited to timely responses to QA Division Audit and Surveillance findings and implementation of appropriate corrective actions.
12 The responsibility and authority over the Safety Review and Audit Board has been delegated to the Vice President - Nuclear. The Vice President - Nuclear reserves the authority to conduct, or order the auditing or monitoring of any operations activity, at any time, to ascertain the effectiveness of the overall QA Program and to determine that all aspects of the QA Program are being complied with.
O 3.2.1 vice president - wuclear il The Vice President - Nuclear, under the direction of the President /CEO - NPPD is the responsible executive officer for all CNS Quality Assurance related activities.
Responsibility includes the implementation of quality assurance activities governing those structures, systems, and es.vanents that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
3.2.2 Divician Mannger-Quality _Aunrnnce il
- Ihe Division Manager of Quality Assurance, a member of the executive staff, reporting to the Vice President - Nuclear shall have the responsibility and authority for administrating and maintaining a Quality Assurance Program for Operation in O
-- with ixPR50,4ggendix B. inhereet in this reseensisiiity is the aeiserity to accept or reject any or all work, materials or equipment associated with Cooper 3-2 Revision 13
Nuclear Station.
The Division Manager of Quality Assurance shall direct the preparation of plans and procedures for defining the Quality Assurance functions associated with Cooper Nuclear Station to ensure that such activities are conducted in accordance with the Operating License and appended Technical Specifications. He shall also approve all plans and procedures for defining and auditing the safety-related activities within the Cooper Nuclear Station and General Office..The actual audit functions to be performed am defined more completely by the body of Nuclear Quality Procedures, and Quality Assurance Plans required by Section 4.0 of this policy document. He shall also have administrative responsibility for evaluating suppliers of nuclear safety-related equipment, materials, and spare parts and for auditing the QA/QC activities of such suppliers.
12 The Division Manager of Quality Assurance and Staff shall have the necessary organizational freedom and access within the Nuclear Power Group to institute the Q
necessary Quality Assurance requirements, identify problems, and pursue prompt corrective action. Figure 1 outlines the QA Division functional organization.
13 The Division Manager of Quality Assurance shall monitor the Quality Assurance activities to the extent necessary for assuring compliance with the program. He shall review the effectiveness of the Quality Assurance Program with the Vice President -
Nuclear on a regular basis. In addition, the Division Manager of QA has a direct line of communication with the President and C.E.O. He shall serve as a member of the Safety Review and Audit Board and provide additional QA Personnel to participate in SRAB activities when requested.
14 NPPD Quality Assurance StatT, under the direction of the Division Manager of Quality Assurance, shall have the responsibility and authority for implementation and ongoing O
- vew-t a the ouaiity issurance Presram for Ogeratiees. in addition, it shaii be the responsibility of the Quality Assurance Division to monitor the interface between the 3-3 Revision 13 3
1 j
l Nuclear Power Group' Divisions to evaluate the effectiveness of management to implement interdepartmental activities affecting quality.
1 15 Unless otherwise pmvided for in writing, the QA Operations Manager or the QA Assessment M& nager (depending on their availability) shall function as the Division Manager of Quality Assurance in his absence.
I i
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16 As shown in Table 2, he shall have responsibility for accomplishment of third level QA Audits and shall obtain assistance and special expertise when necessary to complete such 2
l audits effectively.
j 1
i 3.2.3 Quality _ Assurance Operatinne Manager i
i i
il The Quality Assurance Operations Manager, reporting to the Division Manager of O
Quality Assurance, shall have the responsibility and authority for implementing and l
maintaining the Quality Assurance Program for Operation as described herein.
12 He shall be responsible and have the authority to perform, direct, or coordinate Audit activities / programs within the Nuclear Power Group. QA review of the design and i
j engineering functions within the NPG, including configuration management shall be included in such programs. These activities / programs shall determine if conformance l
with the CNS QA Program for Operation and applicable federal regulations as defined in the QA Policy Document are being maintained.
1 13 The QA Operations Manager shall advise and assist Senior Management and their staff in all matters which affect the quality of the station. Similarly, he shall advise and assist j
all station personnel in matters regarding Quality Assurance and Quality Control.
i O 1
3-4 Revision 13 i
l s-
14 In addition, the QA Operations Manager shall ensure that training programs and instruction are p ovided for QA Operations personnel to enable them to effectively j
execute and monitor the Quality Assurance Program for Operation.
15 he QA Operations Manager shall designate members of the QA Operations Staff upon request to provide training and instruction programs to enable CNS personnel to effectively execute the District QA Program.
16 The QA Operations Manager is also responsible for monitoring of open audit items and interface with NRC during inspections at CNS. In addition, he shall also be responsible to verify that solutions to safety-related problems have been implemented and to perform scheduled audits of those activities as defined in Quality Assurance Plans. Additional specific duties shall be defined in the Nuclear Quality Procedures and Quality Assurance Plans, issued in accordance with Section 4.0 of this Policy Document.
O 17 The QA Operations Manager or designee shall also serve as a non-voting member of the Station Operating Review Committee (SORC).
18 nc QA Operations Manager and Staff will observe operations, maintenance, in-service inspection, special pmcesses, repair or modifications, and other safety-related activities covered by the Quality Assurance Program, and recommend that work stop when such activity, in their opinion, does not comply with approved controlling documents. The Site Manager or designee is responsible to act on that recommendation and actually stop work unless it is determined such stoppage would result in a violation of the Technical Specification or other appmved documents governing station operation or whether there are overriding considerations of safety involved.
19 De QA Operations Manager will provide for a coordination function for QC activities at CNS. His includes development and maintenance of program procedures, reviews 3-5 Revision 13
ofinspector certifications and performance, and the establishment of a training program.
The function will also provide the communication path for the resolution of QC Inspector concerns.
110 The Quality Assurance Operations Manager shall have the responsibility and authority for the controlling, administrating, distributing, and coordinating changes and revisions to the Quality Assurance Program for Operation, subject to the requirements of Section 4.0 of the Policy Document.
ill During absence of the QA Operations Manager, an individual from his staff will be designated to act on his behalf. A SORC qualified Quality Assurance representative will attend SORC meetings on behalf of the QA Operations Manager during such absences.
3.2.4 Quality A""ran" A"***"' M*""S" O
il The Quality Assurance Assessment Manager, reporting to the Division Manager of Quality Assurance, shall have the responsibility and authority for implementing and maintaining the Quality Assurance Program for Operation, as described herein.
12 This respons bility includes the authority for implementing and maintaining the QA i
Surveillance:mvaluation Program and the program for evaluating suppliers for safety-related e.tuipment, materials, spare parts, and services, and for auditing the QA/QC activities of such suppliers.
13 The QA Assessment Manager shall advise and assist Senior Management and their staff in all matters which affect the quality of the station.
i 14 The QA Assessment Manager and Staff shall have the responsibility for providing guidance to NPG personnel in all matters affecting quality. They shall also establish 3-6 Revision 13
r i
and implement the program for evaluating suppliers for safety-relatcx! equipment, materials, spare parts, and services. Additional duties are defined in the Nuclear Quality Procedures and Quality Assurance Plans.
1 15 The Quality Assurance Assessment Manager is responsible for interface, along with the Division Manager of QA, with NRC inspections conducted within the NPG.
16 In addition, the QA Assessment Manager shall ensure that training programs and instmetion are provided for QA Assessment and QA Supplier personnel to enable them to effectively execute and monitor the Quality Assurance Program for Operation.
3.2.5 Quality Aunranm Runervisors il The Quality Assurance Supervisors report to the applicable QA Manager and are O
responsible for the performance of work activities assigned. They are responsible to dimet the performance of QA activities, and to identify any condition adverse to quality to the appropriate QA Manager. The QA Supervisors are responsible for the continued maintenance and upgrading of QA Program Documents.
3.2.6 Quality _ Assurance.Staft QualityJesuranm Aueument_ Staff 11 The Quality Assurance Assessment Staff, reporting to the QA Assessment Manager, shall be responsible to assist and advise the QA Assessment Manager in all matters which could affect Quality Assurance activities within the NPG. This includes advising and assisting personnelin all matters regarding Quality Assurance, and verification that O
seietiees io safety-reiated gresiems heve seen impiemeeted. The o^ Assessment Staff 3-7 Revision 13
l r
shall assist with performance ofintemal audits upon request, as agreed between the QA Assessment Manager and the QA Operations Manager.
12 1he QA Assessment Manager has designated the QA Supplier Supervisor and Staff the responsibility for the ongoing development and implementation of the supplier evaluation program; review of procurement specifications and associated drawings to determine if special requirements such as codes, standards, materials, tools, and inspections, etc., are properly included. Responsibility for establishing and maintaining processes for the conduct of surveillances/ evaluations has been delegated to the QA Assessment Supervisor.
Quality Accurance Onerations. Staff 11 The Quality Assurance Operations Staff shall be responsible to assist and advise the O
Quality Assurance Operations Manager, and other Nuclear Power Group personnel in all matters affecting the quality of the station. These duties include: verification that solutions to safety-related problems have been implemented, and performance of J
QA activities (audits, assessments, evaluations, and surveillances) within the NPG on an announcal or unannounced basis. Responsibility for administering the internal audit program has been delegated to the Quality Assurance Audit Supervisor.
Quality _ Assurance Programt Supervisor il The Quality Assurance Programs Supervisor shall be responsible for administering and documenting the controlled QA program document distribution. This position is responsible for preparation and processing of procedures for the Division and those j
pertaining to the Quality Control Program. Additional specific duties shall be as defined in the Nuclear Quality Procedures, and Quality Assurance Plans issued in accordance with Section 4.0 of this policy document.
3-8 Revision 13
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n atutian nr_ Disagreements t
- O il Disagreements or differences o n inion on Quality Assurance matters are expected to j
]
be documented and resolved jointly by both Quality Assurance Staff and line personnel, j
Where such resolution is not achieved within a reasonable period of time, unresolved differences shall be promptly reported to the appropriate Quality Assurance Manager for i
resolution jointly with the Division Manager of Quality Assurance and Senior l
l Management personnel, as appropriate.
I i
3.2.7 Maniar Manager af Engineering i
4 l
l 11 The Senior Manager of Engineering under the direction of the Site Manager shall be responsible for plant modification activities at Cooper Nuclear Station. Those Quality i
j i
}
Assurance activities associated with such modifications will be conducted in accordance O
with the CNS Quality Assurance Program for Operations. These activities will be audited periodically by Quality Assurance Staff and quality-related problems shall be l
identified and reported to appropnate levels of management for resolution. The Quality l
j Assurance Staff will perform the necessary follow-up action to assure that corrective j
action is implemented in a timely manner.
i i
3.2.8 Nuclear Fuek Kunemisor 1
t i
il For those aspects of Fuel Management covered by the QA Program, the Nuclear Fuels Supervisor, under the direct!on of the Senior Manager of Engineering, shall be t
responsible to furnish technical assistance as required to the Plant Manager and the i
i QA Staff. Such assistance shall not replace or supersede the formal audits.
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- O 3-9 Revision 13 1
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3.2.9 Ga mangar O
11-The Site Manager and his staff, under the direction of the Vice President - Nuclear, l
t j
shall be n.+t 1sible and have the authority for assuring that Quality Assurance activities, j
as defined by this and other approved QA Pmgram documents are complied with. Some of these responsibilities are delegated to CNS management personnel and include i
Quality Control and Inspection functions as defined in Table 2. The actual functions to l
be performed shall be defined in lower tier documents such as NQPs, QAPs, NPG j
Directives, etc.
3.2.10 Plant Manager il The Plant Manager, under the direction of the Site Manager, has overall responsibility for plant Operations, Maintenance, ' Radiological, Engineering, and Scheduling O
department functions. The Plant Manager shall regularly review the activities of those areas for which he is responsible, station engineering, operation, radiological, and -
maintenance activities for the purpose of keeping abreast of significant quality activities.
3.2.11 Senior _ Manager of site Runnart 11 The Senior Manager of Site Support, under the direction of the Site Manager, has responsibility for CNS activities associated with Site Security, Administrative Support, Purchasing / Materials, Accounting, Training and Emergency Preparedness. The Senior Manager of Site Support shall regularly review the activities of those areas for which he is responsible, keeping abreast of significant quality activities.
O 3-10 Revision 13
3.2.12 Eaalar Mwter_of Safsy Aueument O
11 The Senior Manager of Safety Assessment, under the direction of the Site Manager, shall provide the management focal point for Nuclear Safety at CNS. This includes responsibility for plant and industry event analysis, nuclear licensing and safety, and nuclear safety support. The Senior Manager of Safety Assessment shall regularly review the activities of those areas for which he is responsible, keeping abreast of significant quality activities and oversight activities related to Nuclear Safety at CNS.
3.2.13 Niiclear Power Grnun Managers il Nuclear Power Group Managers are responsible for implementation of the Quality Assurance Program relating to their assigned areas of responsibility. Each Manager is responsible for assessment of the activities affecting safety and quality performance, and O
rer erovidi s ti
>v resei tie erce ditie dver te a iity-3.3 cnnner Nuclear Statinn Permanel 11
'Ihe operational duties and responsibilities of the Cooper Nuclear Station personnel are described in the CNS Procedures Manual, Reference 7.5. In addition, the Cooper Nuclear Station personnel are assigned Quality Control inspection functions. Station personnel, under the direction of the Site Manager and his staff, are responsible for assuring that the station is tested, operated, maintained, and modified in accordance with approved plans and procedures.
3.4 Safetyleview and Audit Rnard lO il The Safety neview and tedit neard (SRia) has been estabiished to grevide independent review and audit of designated activities. The board must: verify that 3-11 Revision 13
.-~ _ _._. _. _ _. _.
a i
operation of the plant is consistent with company policy and rules, approved operating 4
procedures, and operating license provisions; review important proposed plant changes, j
tests, and procedures; verify that licensee events are promptly investigated and corrected r
in a manner which reduces the probability of recurrence of such events; and detect j
trends which may not be apparent to a day-to-day observer.
12 Specific duties and responsibilities of SRAB, including auditing, are identified in the CNS Radiological Technical Specifications (Reference 7.14), and in the SRAB Reference Manual.
3.5 Kentinn onerations neview committee il The Station Operations Review Committee (SORC) has been established to advise the l
1 Plant Manager in all matters regarding operational safety.
j
.O 12 Specific duties and responsibilities of SORC are identified in Reference 7.14, CNS Radiological Technical Specifications.
i 3.6 OiitsideSuppliers; contractars,_ Subcontractors; and ennstiltants i
il During the life of Cooper Nuclear Station, it will be occasionally necessary to obtain assistance from outside suppliers and contractors. At all times, these outside suppliers, contractors, and consultants will work under the direction of the NPPD organization having primary responsibility for the particular work being performed. In those instances in which outside suppliers or contractors merely furnish personnel to augment the normal Nuclear Power Group staff for particular activities, such outside contractor personnel shall be required to perform their work in accordance with the CNS Quality Assurance Documents and other appropriate CNS procedures and instructions. In those instances in which outside suppliers, contractors, and subcontractors are assigned 3-12 Revision 13
I i
primary responsibility for a particular activity, such outside contractor shall be required to maintain a Quality Assurance and Quality Control Program and organization appropriate to the work to be performed. All suppliers, contractors, and consultants performing work classified as essential shall be maintained on the appropriate section of the CNS Approved Suppliers List. Selection of outside suppliers or contractors shall require the active participation of the Quality Assurance Division in evaluating and approving their Quality Assurance Program.md teviewing-thepocurement-documents l
prior to awarding tiie contract:
12 In every instance in which outside contractors have responsibility for work at CNS on safety-related nuclear systems, they shall be contractually required to work to procedures approved by the District's Station Operations Review Committee.
Recognized standards or existing proprietary procedures may be used, but they must be j
specifically invoked in writing and clearly identified as to their applicability to the CNS O
- er*-
13 In addition, any outside contractor performing work at Cooper Nuclear Station under their own quality assurance program shall be contractually required to prepare, prior to performing the work, a Project QA Plan specific to the work to be performed at the Station.
14 Contractors and consultants performing safety-related work under the District's Quality Assurance Program shall be contractually required to perform the work under District supervision and in accordance with the CNS Quality Assurance Program for Operation.
District personnel responsible for such work shall assure that contractor / consultant personnel are qualified to do the work and have been provided formal instruction in l
quality assurance. Additionally, any calibrated tools and equipment provided by the ll0
-ntracter sheii be recaiibrated at Cooger Neciear Stetien er by a District aggroved source, prior to use.
3-13 Revision 13
15 If any portion of work on safety-related nuclear systems is to be subcontracted, the prime contractor shall impose the appropriate QA requirements on the subcontractor.
NPPD QA shall have direct access to and communication with the contractor's i
personnel at all levels, both at their home office and in the field.
i 16 Prior to performing work at Cooper Nuclear Station which affects safety-related 1
equipment, outside suppliers, contractors, consultants, and selected representatives from 4
1 the NPPD Nuclear Operation and Nuclear Engineering Divisions shall jointly develop and enforce written agn:ements and/or procedures which clearly define the limits of the work; interface between contractor and station personnel; status and custody tagging procedures; contractor personnel dosimetry; and any other aspects which bear on station i
or personnel security and safety. Such agreements shall be reviewed by the Quality l
Assurance Division to ensure compliance with applicable Quality Assurance Program
- i.
j requirements.
!O 17 At all times when outside suppliers, contractors, and consultants are obtained to assist 1
in the execution of this QA program, the responsibility for effectiveness of these support 1
organizations activities will remain with NPPD.
j i
4 i
O 3-14 Revision 13
i 4.0 QUALITY ARRIIR ANFR TWIIMENTS f
O 11 The CNS Quality Assurance Program is defined by written policies, procedures, and plans which shall be implemented throughout the operating life of the station.
4.1 NPPD Internal Thnments 11 Work procedures are based on the requirements of the Quality Assurance Program.
Preparation and maintenance of basic work procedures is performed by engineering and operating groups, separately from the Nuclear Quality Procedures and QA Plans.
Mandatory QC checkpoints shall be incorporated directly in or attached to, the work procedums to facilitate coordination between the specific work activity and the Quality Contml function. It is nut tiieinioni to includo the iceseben of basic werk yrucsdu os v
undoi L% ingialitydQA, nur is it theintent1crincorporate-basicmua piucoduies Q
into-the-QA Prusiani Documents-Wud yiuceduies, licwever, shall bo reviewd by Quelity Assurance for piepoi iniplementation of the QA Progrem objectives-7hi kppNebMGHiittiM10CER50ApMhdliD3hbilMihb6i@italMJhiaMbhildi6#
Jir06NikkiRthifbNJdtibiid:hhdlniplehiiihiMGSich]hltidli6hldMiiWhjMiliiii FffEnliddbhyiallKdkiiiiiiEWiltWHipbhilbilitifiV6ERiiEHbidMihiXhki: Lei +.1 i
QGTRftf!Abikini66:lNbildhilfr6Ni?2K1!1ht:QialtriwikmnWWiibnizad6hTihail Mi6HdiTiiidipendikt 6WMihiM36*?pi6&dikizikhd6inlj2MH6dtibilighhd idenadonalliihtldhy]tagEbfgocedirfiinihitibNfimpleniinidischi6&l65e6sd?
12 The format and content of NQPs and QAPs, shall be as specified by a Quality Assurance Pmcedure. Significant changes shall be reviewed and approved by the same levels of management as for the original document. Each change, when approved and issued, shall be distributed through a controlled distribution system.
O 4-1 Revision 13 J
i
)
2 13 Particular circumstances may occur while some work is in progress, which necessitates
~i a change to an approved work procedure. When such circumstances arise, the changes l
must be authorized per pmcedure. The written record shall clearly show the nature and extent of the change and the reason for requiring such change.
I i
1 j
4.1.1
@mlity Cantral Inenactian j
11
'Ihe Quality Control inspection function shall be performed by individual (s) other than i
those who are actually performing the step (s) being inspected or who are providing direct, hands-on, at-the-job supervision. The Cooper Nuclear Station management, as 1
l part of their normal management function, are responsible for implementation of the
]
Quality Control requirements of the Peer QC program; however, the QA Operations Manager is responsible to review and accept control methods prior to implementation.
- h
.12 Quality Assurance Management, working with NPG Management, shall verify that i
i-adequate Quality Control inspections are incorporated directly in, or attached to, the work procedures and shall periodically inspect work performance to assure that the 1
i procedures containing Quality Control inspections are being followed. The QC Program 1
shall identify the specific work which is to be subjected to inspection or verification and I
shall provide in detail the elements of work to be inspected which include:
l 1.
Identity of the inspector or data recorder.
1 i
i j
2.
Type ofinspection or verification.
i 1
3.
Results (data to be recorded).
)
i 4.
Acceptance (suaiitativeoreuantitative> criteria.
j O e
i k
4-2 Revision 13
5.
Method of disposition of unsatisfactory inspection results.
i O
6.
Reporting requirements.
)
13 In addition, clear instructions shall be given regarding the timing, frequency or
)
scheduling, and notification requirements for such inspections so as ta obtain maximum effectiveness and to minimize delays in completion of the work.
i 14 It must be recognized that certain work, particularly in nonroutine maintenance or repair, cannot be anticipated. Therefore, procedures and Quality Control inspection requirements cannot be prepared until a particular problem has been detected and evaluated.
C
'15 Routine maintenance and repair of essential systems and components generally requires performance of a complete or partial Surveillance Procedure prior to placing the system back in service. This type of QC (actual performance or functional testing) following completion of work is considered a unique advantage on an operating facility. Such surveillance testing may be performed by the individuals who performed the maintenance activity. Records of the surveillance will be reviewed by the system engineer or other supervisory / management personnel.
4.1.2 Nuclear QualityltocedureL(NQPJ il The Quality Assurance staff shall prepare NQPs approved by the Division Manager of Quality Assurance and the Vice President - Nuclear. As described in Section 1.5 of this document, NQPs define Quality Assurance activities and responsibilities which O
- divisionai boundaries. when aggroved. noes become a vert of the CxS ouaiity Assurance Program for Operation.
4-3 Revision 13
1 4.1.3 9=lity Amirmnce Plans (QAE)
O il
- QAPs shall be developed which encompass those functional areas described within, defining the scope of the QA pmgram. Quality Assurance Staff shall develop QAPs as i
1 needed. As described in Section 1.5 of this document, these QA Plans outline specific Quality Assurance activities and shall become a part of the CNS Quality Assurance Program for Operation. Distribution of these Plans will be to those individuals who are responsible for that particular activity.
12 The format and content of QAPs shall be specified in a NQP to provide uniformity and to assure that each plan is complete and adequate for the intended purpose.
13
'Ihe QAPs shall be prepared by the Quality Assurance Staff and shall be reviewed and I
approved by the Division Manager of Quality Assurance. In addition, when significant O
changes have been made to these documents, the QAP will be routed to affected Senior Management personnel for review and comment.
14 The QAPs shall define the specific work which is to be subjected to Quality Assurance review, surveillance, and audit, and the manner in which such review, surveillance, and audit is to be implemented.
15 Checklists shall be prepared per the guidance provided in Nuclear Quality Procedures, defining the scope of QA Surveillance or QA Audit activities.
a)
Quality _ Assurance. Surveillance The Quality Assurance Surveillance function is intended to provide an O
independent verification, en a continuing basis, that werk is beieg performed in accordance with the requirements of the controlling 4-4 Revision 13
A 4
1 documents. Such surveillances may be performance-based or compliance l
oriented depending on the nature of the function being evaluated. The Quality Assurance Surveillance activities are not intended to duplicate QC I
inspection activities, however, duplication may occur, in the effort to satisfy both Quality ' Assurance Surveillance and Quality Control
}
requirements.
I d
The objectives of Quality Assurance Surveillance are to verify that the 4
Quality Control inspection program is being effectively implemented; that l
personnel performing Quality functions are properly qualified; that adequate information is recorded to provide a complete and accurate quality
-l history; and that deficiencies are identified, corrected, recorded, and
-l corrective action is taken to prevent recurrence.
- k.
This philosophy shall be taken into account in developing the checklists as guidance for the conduct of Quality Assurance Surveillance activities. QA l
Surveillance shall be as prescribed in NQPs and QAPs.
x i
l 1
The QA checklists shall identify the area of work to be subjected to surveillance and shall provide necessary instructions.
The timing, i
frequency, or schedule for the surveillance diall be coordinated with the work being evaluated to ensure maximum effectiveness with minimum i
impact on the progress of the work.
i b)
Quality Amirnnm Audits A comprehensive system including planned and periodic audits and audits O
seiected based uren indication of performance grebiems shaii be 4
implemented to verify compliance with all aspects of the Quality Assurance 4-5 Revision 13 4
4 1
]
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 responsibilities for the work being audited. Depending on the nature of the function being audited, the audits are conducted in a performanco-based manner to the
)
maximum extent practical. The audits are supplemented by performance-
]
based and compliance oriented surveillances and evaluations. Quality Assurance Management shall have the responsibility and authority for implementation of ine Quality Assurance activities to audit programs i
defined by approved QAPs. However, the SRAB, or any manager or l
extcutive in the chain of organization above the NPG Senior Managers, or i
l above the Quality Assurance Supervisors and Managers may initiate and carry out special Quality Assurance Audits within the guidelines provided by this Quality Assurance Program. Audit results shall be reported in 1!]
writing to the NPG Management in accordance with the requirements of i
NQPs and the results shall be reviewed with the Management responsible for the area of activity audited. Appropriate follow-up action shall be taken and documented as directed by the appropriate Quality Assurance Manager or Supervisor.
4 Audit Scoping Plans (ASPS) provide detail description of the scope within an audited area. NQPs describe the frequency of required audit activities, and provide guidance for audit schedules and reports.
t Each ASP will be implemented through the use of an approved checklist.
On the basis that some Quality Assurance Audits are to be conducted or directed by management, it is essential to maintain a high degree of
- O fie ibiiity in the manner of coedectins an audit. it is intended that the 4
ASPS provide audit guidelines to assure that areas to be audited are 1.
4-6 Revision 13
t 4
i i
sufficiently defined in advance and that audit personnel are adequately i
I prepared to make a meaningful audit with a minimum of interfe-rence with j.
the progress of the work. Also, flexibility is required to permit the auditor 4
i to adapt his procedures to the conditions existing at the time the audit is i
made.
4-I i
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O 4-7 Revision 13
4 5.0 METHOD _OElMEIWENTATION O
11 The Quality Assurance Program for Cooper Nuclear Station is implemented by the j
development ard implementation of procedums, by management attention and oversight, i
and by critical assessment and overview by Senior Management and independent groups.
This attention and oversight is implemented consistent with the commitments to the rainbow series WASH publications as specifically described in Sections 1.0 and 2.0 of 1
this Policy Document.
l 12 The detailed methods ofimplementation shall be as provided for in written and approved procedures prepared in accordance with Section 4.0.
13 The Quality Assurance Managers or designees shall jidiiddibillf7fiWadorkffRiiid iltadNdhillf review and comment on the NPG procedures to ascertain that necessary Q
quality requirements am included. Precedure cruuigesMllim-inwiyorete os nocosruuy to wuwt identiGod cunuul deGeiencies or nds-Pidhichifidifit#fi4byis2OfiiildW iiffdebadidd'by0GalityAkishmbe:MllK6ammwilidiid tiMilHE!6iiii?PeWMk 1
- swff3ifusividiffoj@@fscridiil Differences of opinion on QA comments shall be resolved as indicated in Section 3.2.6.
14 AfLei inicw of-the various-NPG piucdures and manuals-the-Quahty-Assurance Managers shall review the.yinuyn.io NQPs and-QAPs-fui the purposo of ssuring-that tluroveral19A Piur, rani objectives continue 10 bo.cconiplishedin each sognient ofte woi iu which this-QA Pregioni opplies-$ltkatlohdijdsd'pdidd/d}ifWbfpiocedures
>f2Diibliti!%ssiierehde1Milibonsid#tidnyatibilitilbfilbfifGtlECM06edidiFjiMds 1
ii6(pdtwhhW6hd:bomrhidhEnthMNkhEOdiklldocionehtil i
O i
5-1 Revision 13 4
15 Management is responsible for assessment of the effectiveness of implementation of
/3 piugram elements within their assigned areas, and for timely and effective resolution of V
conditions adverse to quality.
16 Quality Assurance Division activities shall be coordinated with the SRAB and SORC.
W Such activities shall be conducted in a manner and on a schedule to assure organization, supervision, communications, and technical and administrative practices clearly provide for smooth, orderly, controlled, and safe execution of all safety-related functions.
17 Written reports of all QA activities, including descriptions of deficiencies and resolution thereof, shall be incorporated into the official quality records file. Corrective action on deficiencies shall include resolution of the specific deficiency and verification that corrective action has been implemented to prevent occurrence of similar deficiencies in the future. A report of QA Audits performed (internal and external) shall be submitted O
to the Vice President - Nuclear by the Division Manager of Quality Assurance annually.
18 The Quality Assurance Staff shall maintain an up-to-date summary of the CNS Quality Assurance Policies, Procedures, and Plans, showing how this QA Program for Operation implements the NRC guidelines contained in 10CFR50, Appendix B.
O 5-2 Revision 13
i 6.0 R Ff 0RDS_RETWTION_AND_DISPOSLTlON O
11 Instructions have been prepared by the responsible organizations to provide guidelines for CNS and CGO record retention and disposition in accordance with this policy document and applicable mgulatory criteria. As a minimum, these procedures cover the following:
a)
Records content and location; b)
Principal location from which records are to be controlled; c)
Complete records inventory and master index; d)
Conditions of storage, access, and security; O
e)
System of records identification, retrieval, and control; f)
System of records transfer and disposal.
12 Quality Assurance records (reference 7.9) will be entered into the controlled records system per the requirements of stadon procedure and ANSI N45.2.9 - 1974.
2 O
6-1 Revision 13
7.0 REEERENCES i
O 11 The following documents were used in the preparation of the Quality Assurance Program for Operation of the Cooper Nuclear Station. It is intended that these documents be used on a continuing basis in the performance of Quality Assurance activities for station operation since they offer measurement criteria against which the QA P ogram can be evaluated.
(a)
Quality Assurance Criteria for Nuclear Power Plants 10CFR50, Appendix B (USNRC).
(b)
Standard of Administrative Controls for Nuclear Power Plants, American National Standard ANSI 18.7 - 1972.
(c)
Updated Safety Analysis Report, Cooper Nuclear Station, Nebraska Public Power j ]
District (NRC Docket 50-298).
i (d)
Environmental Report-Operating License Stage, Cooper Nuclear Station, Nebraska 4
l Public Power District (NRC Docket 50-298).
(e)
Cooper Nuclear Station Procedures Manual.
(f)
Safety Rules, Nebraska Public Power District.
l (g)
Safety Guides for Water-Cooled Nuclear Power Plants (USNRC), as appropriate.
(h)
Quality Assurance Requirements for Nuclear Power Plants ANSI N45.2 - 1977.
O ci)
Reautre e=ts ror cotiee1io#. stor se. >#a u i#te#>#ee or o#eiity ^sser=#ee neceras for Nuclear Power Plants ANSI N45.2.9 - 1974.
7-1 Revision 13 j
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h._
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2m J
a d44.hA a$..
a_
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_m.
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(j)
Quality Assurance Terms and Definitions ANSI N45.2.10 - 1973.
O (k)
Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI I
N45.2.11 - 1974.
I l
(1)
Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants ANSI N45.2.12 - 1977.
l (m)
Supplementary Quality Assurance Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants ANSI N45.2.13 - 1976.
l (n)
CNS Radiological Technical Specifications.
l t
i (o)
ANSI N45.2.23-1978 " Qualification of Quality Assurance Program Audit Personnel for Q
Nuclear Power Plants" l
O 7-2 Revision 13
O O
O FIGURE 1 Nebraska Public Power District President & CEO I
I NUCLEAR POWER GROUP i
I QUALITY ASSURANCE DIVISION I
I I
- Responsible for Second and Third Levels Vice President-Nuclear I
of the QA Program,as desen%d in Table 2.
l Direct Communication Vice President Nuclear I
l
! Division Manager-Quality Assurance
_ _ _ _ _I l
- QA Operations Manager
- QA Assessment Manager
- QA Audit Supervisor
- QA Progrrms Supervisor
- QA Assessment Supervisor
- QA Supplier Supervisor
- QA Audit Staff
- QA Prokrams Stati
- QA Assessment Staff
- QA Supplier StafT
~
8-1 i
TABLE _1
(
SYSTEMS AND COMPONENTS WITHIN THESCORILOE
\\.
THE OUALITY ASSIIR ANCR PROGRAM I.
NIICI.FAR STRAM SIIPPI Y SYSTEM A.
Reactor Primary Vessel B.
Reactor Primary Vessel Supports
]
C.
Control Rods and Drive System Equipment Necessary for Scram Operation D.
Control Rod Drive Housing E.
Fuel Assemblies j
F.
Core Shroud G
Steam Dryer H.
Steam Separator j
i II.
REACTORfOQLANT SYSTEMS A.
ADS - Automatic Depressurization System B.
HPCI - High Pressure Coolant Injection System C.
LPCI - Low Pressure Coolant Injection System i
D.
CS - Core Spray System E.
RCIC - Reactor Core Isolation Cooling III.
REACTOR PROTECTION _AND_ ENGINEERED SAFFGITARD SYSTEMS A.
Standby Gas Treatment i
D.
Diesel Generators 1
O 9-1 Revision 13
i Inhle 1 (Cnnt'd.)
4 \\
4 E.
Electrical Aux Power 1.
Critical 4160 V Equipment 2.
Critical 480 V Equipment F.
Neutron Monitoring Systems 1.
APRM - Average Power Range Monitor 2.
IRM -Intermediate Range Monitor 3.
LPRM - Imw Power Range Monitor 4,
RBM - Rod Block Monitor 5.
SRM - Source Range Monitor 6.
TIP - Traversing In Core Probe G.
DC Power Supply 4
i H.
Nuclear System Ink Detection O
I.
Containment Isolation System J.
Nuclear Boiler and Related Instrumentation K.
Rod Position Indicator IV.
NIICIFAR_E11FI SYSTEMS A.
Refueling Interlocks for Fuel Handling and Vessel Servicing Equipment B.
Fuel Pool Liner and Gates C.
Fuel Pool Cooling and Cleanup O
9-2 Revision 13
Tahic1(Cont'd.)
V.
RADIOACTIVE WASTE DISPOS AL SYSTEMS i
A.
Process Radiation Monitoring System 1.
Off-Gas Radioactivity Monitoring 2.
Main Steam Line Monitoring l
3.
Reactor Building Vent Monitoring (GE) l 4.
Drywell and Suppression System Leak Rate 5.
Liquid Process Radiation Monitoring B.
Radioactive Waste Processing System j
1.
Dewatering System 2.
Radioactive Wa:te Shipping l
VI.
OTHER SIJPPORT SYSTEMS A.
Reactor Equipment Cooling B.
Emergency Bypass Function on Control Room Heating, Vent, and AC D.
Reactor Recirculating (Pressure Retaining Parts Only)
E.
Class I, II, and III Code Items F.
Reactor Feed Pumps (Pressure Retaining Parts Only)
G.
Reactor Building H&V H.
Fire Protection I.
Security L
Instrument Air i
O 9-3 Revision 13
4 i
i l
Table 1 (Cnnt'd.)
i VII.
STRIICTIIRES_(SEISMICS) i A.
Reactor Building i
i' B.
Control Building l
t j
C.
Elevated Release Point j
i D.
Intake Structure j
E.
Diesel Generator Building 4
F.
Radwaste Building (Below Grade) 1
- Note -
1.
This listing is not intended to be all inclusive.
i 2.
Application of the QA Program to these systems and components shall be l
consistent with the safety-related significance of the system or component.
i i
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}
l t
k l
2 4
i isu s
j 3
i 1
t O
9-4 Revision 13
)
Table 2 4
THREE LEVEL QUALITY ASSURANCE PROGRAM EXPLANATION OF FIRST, SECOND, AND THIRD LEVEL QA RESPONSIBILITIES 4
a)
EIRST I FVRI - Watk Performance activities are properly perf0rmed and nad Onnlity Cantrol.
procedures are adequate for the activity they prescribe. Persons Each person performing work for performing these activities are not i
CNS is charged with the first-line directly involved in the day-to-day 4
responsibility for adherence to quality Inspection or Quality Control
}
practices and procedures.
An functions. Audits, surveillances and individual other than the one doing evaluations will normally be the work (not to include immediate performed by or under the direction supervision at the task site) will have of the appropriate QA Manager. In j
primary responsibility for Quality addition, SRAB shall be responsible i
Control. Personnel at this level are for reviewing the results of audits and j
charged with the responsibility for follow-up audits as described in j
direct inspection, witnessing, and Technical Specifications. The Quality sign-off, attesting that work has been Assurance Staff is also responsible j
performed in accordance with the for the evaluation of audit results and 1
quality requirements of the for verifying that identified j.
controlling documents.
corrective action requirements have been implemented.
b)
SECOND I R V E I.
j Manneemmt/ Supervision Oversight.
Personnel performing assessments are not directly involved in the day-i Supervision and management to-day Inspection or Quality Control personnel are responsible for functions. Assessments will normally
{
providing workers and QC people be perforraed under the direction of with the proper procedures and Senior line Management personnel, 4
guidance for performing quality or at the discretion of on-site or off-l work.
These Managers-and site safety review bodies.
Such Supervisors are then responsible for assessments are conducted to provide second level oversight as appropriate the highest level of overview of for work involved. The Qualit implementation of the Quality l
l Assurance DlW.disyllW ~
Assurance Program as herein j
RZ Moe.s is.re iespuesible fui described.
e aesnii...fety-related ihot controlling documents i
for sa activities id l
M mclu#dsfif appropriate I
quality requirements.
c)
THInn i EVRI.-Quality Assurance i
i Audit / Surveillance and Aueuments.
1 l
QA Staff is responsible for conducting surveillances, evaluations and audits of activities which affect 5
quality to assure that Quality Control and inspection programs are being
(
implemented and that quality requirements are in fact being met.
j This includes verification that 9-5 Revision 13
-.. ~.
_... _ _ _ _.