ML20140C577

Rev 19 to Northeast Utilities QA Program TR for Millstone Power Station

ML20140C577
Person / Time
Site:	Millstone
Issue date:	06/03/1997
From:	Kenyon B NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20140C571	List: B16494, Forwards Rev 19 to QA Program Topical Rept Which Upgrade QA Program for Mnps Units 1,2 & 3 & Describes Certain Reporting Relationships of Regulatory Compliance & Regulatory Affairs Personnel ML20140C577
References
NUDOCS 9706090327
Download: ML20140C577 (91)

Text

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4 1 Docket Nos. 50-245 50-336 50-423 B16494 l

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At+achment 3 Millstone Nuclear Power Station, Units 1,2, and 3 Annual Reporting of Changes to the Quality Assurance Program i Proposed Revision 19 to the Northeast Utilities Quality Assurance Program Topical Report - Millstone Nuclear Power Station Proposed Revision 19 to the NUQAP Topical Report l

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June 1997 l 9706090327 970603 l PDR ADOCK 05000245 l P PDR i

I TABLE OF CONTENTS N_ORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)

TOPICAL REPORT - MILLSTONE POWER STATION Table of Contents l

Abstract Policy Statement introduction Quality Assurance Program QAP 1.0 Organization QAP 2.0 Quality Assurance Program QAP 3.0 Design Control QAP 4.0 Procurement Document Control OAP 5.0 Procedures, Instructions and Drawings QAP 6.0 Document Control QAP 7.0 Controf of Purchased Material, Equipment and Services OAP 8.0 Identification and Control of Materials, Parts and Components QAP 9.0 Controlof Special Processes QAP10.0 inspection QAP11.0 Test Control QAP12.0 Control of Measuring and Testing Equipment QAP13.0 Handling, Storage, and Shipping QAP14.0 Inspection, Test, and Operating Status QAP15.0 Nonconforming Materials, Parts, Components, or Services QAP16.0 CorrectiveAction QAP17.0 Quality Assurance Records QAP18.0 Audits Appendices A. Category i Structures, Systems, and Components B. Qualification and Experience Requirements, Vice President- Nuclear Oversight C. Regulatory Guide and ANSI //EEE Standard Commitments D. Glossary of Quality AssuranceTerms E. Program Exceptions i

i OAP Table of Contents Rev.: 19 Date:

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ABSTRACT NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)

TOPICAL R EPORT - MILLS TONE POWER STA TION l

Northeast Utilities (NU) has developed, and is implementing, a comprehensive Quality Assurance l Program for the Millstone Power Station to assure conformance with established regulatory )

requirements set forth by the Nuclear Regulatory Commission (NRC) and accepted Industry standards. The participants in this Quality Assurance Program assure that the design, l fabrication, procurement, construction, testing, operation, refueling, maintenance, repair and modification of the Station nuclear power plants are performed in a safe and effective mannei.

This Quality Assurance Program (NUQAP) Topical Report complies with the requirements set forth in Appendix B of 10 CFR 50, along with applicable sections of the Safety Analysis Report

! (SAR) for each license application, and is responsive to the United States NRC Regulatory Guide 1.70, which describes the information required to be presented in the Quality Assurance section of the SAR's for nuclear power plants.

This NUQAP is also established, maintained, and executed with regard to radioactive material transport packages as allowed by 10 CFR 71,101(f). Quality Assurance provisions for Fire Protection activities are detailed in the Northeast Utilities Fire Protection Program.

This NUQAP applies in its entirety to all activities affecting the safety-related functions of structures, systems, and components. Safety structures, systems, and components are functionallyidentified in Appendix A of this NUQAP and are designated Category I by Northeast Utilities. Applicability of Appendix A to each FSAR is addressed by existing nuclear unit specific design bases and licensing commitments, and also as specifically identifiedin each FSAR addressing Section 3.2.1 of Regulatory Guide 1. 70. This NUCAP is l

also appilcable in its entirety to materials, equipment, parts, consumables, and services designated as Category 1. This NUQAP is applicable to other quality programs including Anticipated Transient Without Scram (ATWS) Quality Assurance which is applicable to MP-1 and MP-2 only (MP-3 commits to Generic Letter 85-06) and ElectricalEquipment Qualification (EEQ) as defined by NU commitments. Portions of this NUQAP are also applicable to Fire Protection Quality Assurance (FPQA), Station Blackout Quality Assurance (SBOQA) and .

Radwaste Quality Assurance (RWQA) which are delineated in applicable procedures. Quality  ;

Assurance provisions for primary chemistry laboratory activities are detailed in the Northeast Utilities Nuclear Chemistry Laboratory Quality Assurance Manual.

This NUQAP is committed to utilize the guidance obtained from the regulatory documents and their endorsed standards identifiedin Appendix C of this NUQAP TopicalReport.

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OAP Abstract Rev.: 19 l Date:

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POLICY STATEMENT NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP) l TOPICAL REPORT- MILLSTONEPOWER STATION I

This Northeast Utilities Quality Assurance Program (NUQAP) Topical Report has been l developed to achieve quality assurance in all activities affecting the safe operation of the l M/// stone Nuclear Power Station. The policies, requirements and tasks contained in this

program description have 5een developed to ach! eve quality assurance during activities that apply l to the design, fabricatici nrocurement, construction, testing, operation, refueling, maintenance, repair, and modification of the Station's nuclearpowerplants.

Northeast Utilities procedures which implement this program are described in various manuals.

This NUQAP appIles in its entirety to all activities affecting the safety-related functions of structures, systems, and components. Safety structures, systems, and components are functionallyIdentified in Appendix A of this NUQAP and are designated Category I by Northeast Utilities AppIIcability of Appendix A to each FSAR is addressed by existing nuclear unit specific design bases and licensing commitments, and also as specifically identifiedIn each FSAR addressing Section 3.2.1 of Regulatory Guide 1.70. This NUQAP is also applicable in its entirety to materials, equipment, parts, consumables, and services designated as Category 1. This NUQAP is also applicable to other quality programs including Anticipated Transient Without Scram (ATWS) Quality Assurance which /s applicable to MP-1 and MP-2 only(MP-3 commits to Generic Letter 85-06) and ElectricalEquipment Qualification (EEQ) as defined by NU commitments. Portions of this NUQAP are also applicable to Fire Protection Quality Assurance (FPQA), Station Blackout Quality Assurance (SBOQA) and Radwaste Quality Assurance (RWQA) which are delineated in applicable procedures. Quality Assurance provisions for primary chemistry laboratory activities are detai!ed in the Northeast Utilities Nuclear Chemistry Laboratory Quality Assurance Manual.

The development and overall responsibility for this program lies with the President and Chief Executive Officer - NU Nuclear Group as delegated by the Chairman, Chief Executive Officer, and President of Northeast Utilities. Corporate authority is delegated to the Vice President- Nuclear Oversight for the preparatior, and administration of this NUQAP Topical Report Individual Vice Presidents, Recovery Officers, and Directors are responsible for the implementationof their portion of this program. Audits of this program are the responsibilityof the Vice President- NuclearOversight Any revisions or additions shall be approved by affected departments prior to the incorporation of such changes into the program. Final approval of revisions or additions to this Policy Statement rests with the President and Chief Executive Officer- NU Nuclear Group.

Al wn (

Bruce D. Kenyon President and Chief Executive Officer

\ NU NuclearGroup

, QAP Introduction Rev.: 19 Date:

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INTRODUCTION

[LORTi iEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)

TOPICAL R EPORT - MILLSTONE POWER STA TION This Northeast Utilities Quality Assurance Program (NUQAP) Topical Report contains the quality l assurance requirements which are relevant to the safety of the Millstone Station nuclear power l plants. This NUQAP Topical Report consists of three parts:

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1. Introduction,which defines the purpose of the Topical Program and summarizes its scope and applicability;

2. The NUQAP, which is applicable in its entirety to all activities affecting the safety-related functions of structures, systems, and components. Safety structures, systems, and components are functionallyidentifiedin Appendix A of this NUQAP and are designated CategoryI by Northeast Utilities Applicabilityof Appendix A to each FSAR is addressed by existing nuclear unit specific design bases and IIcensing commitments, and also as specificallyidentifiedin each FSAR addressing Section 3.2.1 of Regulatory Guide 1.70.

This NUQAP is also applicable in its entirety to materials, equipment, parts, consumables, and services designatedas Categoryl. This NUQAP is applicable to other quality programs including Anticipated Transient Without Scram (ATWS) Quality Assurance which is applicable to MP-1 and MP-2 only (MP-3 commits to Generic Letter 85-06) and Electrical Equipment Qualification (EEQ) as defined by NU commitments. Portions of this NUQAP are also applicable to Fire Protection Quality Assurance (FPQA), Station Blackout Quality Assurance (SBOQA) and Radwaste Quality Assurance (RWQA) which are delineatedin appilcable procedures.

3. Appendices,which provide supporting statements and tabulations.

This NUQAP Topical Report has been prepared to document that a quality assurance program has been established and implemented to assure that adequate quality requirements are being complied with to safeguard NU employees, contracted personnel and the public during the life of the Millstone Station nuclear power plants. In addition, there are other programs to safeguard NU employees, contracted personnel, and the public.

The controls which implement the actions identified in this NUQAP are procedures and instructions which delineate actions and steps necessary to accomplish quality requirements. Procedures and instructions are written by groups, divisions, departments, branches, or sections which have the responsibility for implementing actions as assigned by this NUQAP. Quality procedures and revisions thereto are reviewed by and concurred with by Nuclear Oversight in accordance with QAP 2.0, " Quality Assurance Program" and QAP 5.0, " Procedures, Instructions, and Drawings".

This NUQAP is responsive to applicable codes, Nuclear Regulatory Commission regulatory requirements, accepted industrial standards and revisions thereto. Provisions are established to update this NUQAP Topical Report in eccordance with revisions to codes, standards and regulatory requirements, and to inform cognizant personnel to implement appropriate action to assure the highest standard of quality is achieved for structut s, systems, components, and services for the Mllistone Station nuclear power plants.

DavidM. Goebel l Vice President. Nuclear Oversight QAP Introduction Rev.: 19 Date:

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1.0 ORGANIZATION

1.1 INTRODUCTION

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The Chairman, Chief Executive Officer, and President of Northeast Utilities (NU) has l

the ultimate responsibliity for the NU Nuclear Program. While retaining full  !

responsibility and overall authority, the Chairman has delegated the necessary authority and responsibility for all nuclear operations to the President and Chief Executive Officer - NU Nuclear Group. The NU Nuclear Group includes the Northeast Utilities Service Company (NUSCO) which provides support services to NU's nuclear plants and the Northeast Nuclear Energy Company (NNECO) which I operates Millstone Power Station Nuclear Units 1, 2, and 3. The President and Chief Executive Officer - NU Nuclear Group is also the President of NUSCO and the l President and Chief Executive Officer of NNECO. j 1.2 GENERAL.

l 1.2.1 The President and Chief Executive Officer - NU Nuclear Group directs specified nuclear related activities within NU and has the ultimate responsibility for the establishment and execution of the NU Quality Assurance Program j (NUQAP) for the Millstone Power Station. The President and CEO is overall l

responsible for engineering, construction, operation, maintenance, modification, and quality assurance for the Station.

l 1.2.1.1 Responsibilities of the President and Chief Executive Officer relating to the Quality Assurance Program are described in Nuclear

! Group Procedures. The President and CEO has contact with quality assurance activities through meetings with the Vice President -

Nuclear Oversight, the receipt of various documents such as:

periodic progress reports, Nuclear Safety Assessment Board meeting notes, other reports, and audits related to the nuclear program and nuclear plant operations activities at Millstone Power Station.

1.2.1.2 The President and CEO annually assures a Management Review of the Millstone Power Station Quality Assurance Program is 1

performed to determine program adequacy and its compliance i with Appendix B to 10CFR50 and other regulatory requirements.

1.2.1.3 The President and CEO resolves all disputes related to the implementation of this NUQAP for which resolution is not achieved at lower levels within the nuclear organization.

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1.3 RESPONSIBILITIES  ;

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l 1.3.1 Overall responsibility for the NUQAP is assigned to the Vice President -  !

l Nuclear Oversight who reports to the President and Chief Executive Officer-

NU Nuclear Group. These responsibilities include

direction of the Quality l Assurance Program; implementation of policies, plans, requirements,  !

procedures, and audits; verification to assure compliance with 10 CFR 50 1 l Appendix B and other regulatory requirements; and verification of the I l implementation of the Millstone Power Station NUQAP Topical Report I requirements.

! 1.3.2 The head of each NUSCO/NNECO Department performing quality activities is responsible for:

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a. Administering those activities within their organization which are required by this NUQAP;

b. Assuring implementation of the Quality Assurance Program;

c. Establishing and clearly defining the duties and responsibilities of personnel within their organization who perform quality activities;

d. Planning, selecting, and training personnel to meet the requirements of the l NUQAP Topical Report;

e. Performing and coordinating quality activities within their department and interfacing with the Nuclear Oversight Department.

1.3.3 Each individual performing or verifying activities affecting quality is responsible to conduct those activities in accordance with the requirements of this NUQAP and implementing procedures. These individuals shall have direct access to such levels of management as may be necessary to perform this function.

1.3.4 The responsibility, authority, and organizational relationship for performing quality activities within each organization is established and delineated in the NUSCO/NNECO organizational charts, policy statements, and written job or functional descriptions.

1.3.5 Vendors may be delegated the execution of quality assurance functions; however, NU shall retain responsibility for this Quality Assurance Program.

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4 l 1.4 PARTICIPATING GROUPS - bilLLSTONE POWER STA TION (Refer to Fleure 1.0) .

i The President and Chief Executive Officer- NU Nuclear Group, reporting to the NU Chairman, President, and Chief Executive Officer, is overall responsible for the development andimplementation of this NUQAP. The Nuclear Safety Assessment 1 Board reports to the President and Chief Executive Officer in compilance with l MIIIstone Power Station nuclear unit Technical Specifications. The President and l Chief Executive Officer has delegated the necessary authority and has assigned

, responsibility for development and implementation of this NUQAP for Millstone PowerStation to the:

• Vice President - Nuclear Oversight, l l

• Senior Vice President and Chief Nuclear Officer - Millstone Power Station, i

• Director- Special Projects.

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i 1.4.1 The Vice President - Nuclear Oversight is responsible for the preparation l l and issuance of this NUQAP Topical Report and verification of the l Implementation of its requirements and compliance with 10 CFR 50, Appendix B and other regulatory requirements by the appilcable

NUSCO/NNECO Department. Verification is performed through a planned

program of audits, surveillances, and inspections by Nuclear Oversight

Sections. The Vice President provides management with objective I evidence of the perionnance of quality activities independent of the

, individual or group directly responsible for performing the specific activity.

1 The Vice President has the authority and organizational freedom to verify i all activities affecting quality. This is performed independent of undue

Influences and responsibilities for schedules and costs. The Vice 1

} President has the responsibility and authority to stop unsatisfactory work and control further processing or installation of nonconforming materials.

1 The authority to stop work is assigned to Nuclear Oversight Department personnel and delineatedin a Nuclear Group Procedure. The Vice l

! President also has the responsibility and authority to identify quality  ;

problems, to recommend or provide solutions, and to verify their l implementation. l The Vice President - Nuclear Oversight is also responsible for the Employee Concerns Program, Independent Safety Engineering, the i Operating Experience Program, and the Independent Review Team. The Vice President (refer to Figure 1.1) has delegated the necessary authority and responsibility for these activities to the:

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• Director- Audits and Evaluation,

• Director- Performance Evaluation, e Director- Analysis and Programs,

• Director- Employee Concerns.

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1.4.1.1 Director - Audits and Evaluation is responsible for the day-to-day direction and administration of the audit program to verify compliance with 10CFR50, Appendix B and other regulatory requirements, to verify the implementation of these NUQAP requirements, and to evaluate performance against management expectations.

l 1.4.1.2 Director - Performance Evaluation is responsible for the day-to-day direction and administration of Nuclear Oversight program i

for surveillances and inspection to verify compliance with 10CFR50, Appendix B and other regulatory requirements, to

verify the implementation of these NUQAP requirements, and to evaluate performance against management expectations.

1.4.1.3 Director - Analysis and Programs is responsible for the day-to-day direction and administration of NUQAP activities including:

administration of this NUQAP Topical Report, independent trend analysis, Quality Procedure and Special Process review, and oversight of the Unit Configuration Management Programs. The Director is also responsible for the Nuclear Group Operating Experience (OE) Program, Independent Safety Engineering (ISEG), and the Independent Review Team.

1.4.1.4 Director - Employee Concerns is responsible for the day-to-day direction and administration of the Employee Concerns Program for Northeast Utilities. The Director assures that nuclear safety concerns receive appropriate management attention and concerns are addressedin a timely manner.

1.4.2 The Senior Vice President and Chief Nuclear Officer - Millstone Power Station has the overall responsibility for the implementat on of this NUQAP at the Millstone Station site and is responsible for overall operation of the Station. The Millstone Power Station Operations Review Committee (SORC) reports to the Senior Vice President and Chief Nuclear Officer in compliance with Millstone Power Station nuclear unit Technical Specifications. The Senior Vice President (refer to Figure 1.0) has delegated the necessary authority and has assigned responsibility for these activities to the:

• Recovery Officer- Millstone Unit 1, 1

• Recovery Officer- Millstone Unit 2, e Vice President - MIIIstone Unit 3, l

• Vice President - Nuclear Work Services, e Recovery Officer - Nuclear Engineering and Support, e Director- Corrective Actions, e Director- Startup.

QAP 1.0 Rev.: 19 Date:

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1.4.2.1 . The Recovery Officer - Millstone Unit 1 is responsible for implementation of this NUQAP for the Unit and is responsible for overall unit safe operation and control over those onsite activities necessary for safe operation and maintensace of the plant. The Recovery Officer (refer to Figure o'.2) has delegated

- the necessary authority and assigned respo,ssibility for these activities to the:

• Director- Unit Operations, l e Directcr- Engineering, o Director- Maintenance /I&C, o Director- Work Management, o Director- Support Services.

1.4.2.1.1 The Director - Unit Operations is responsible for the day-to-day direction and administration of the Unit i Operations, Regulatory Compliance, the Fix-It Now (FIN) Program, and Unit restar1 activities. The Plant Operations Review Committee (PORC) reports to the Director Unit Operations in compilance with Technical Specifications.

1.4.2.1.2 The Director - Engineering is responsible for the day-to-day direction and administration of the Unit Design Engineering, Technical Support, the Configuration Management Program, and for maintenance of the Unit design basis in accordance with the Unit licensing basis.

1.4.2.1.3 The Director - Maintenance /l&C is responsible for the day-to-day direction and administration of the Unit Maintenance Planning and Mechanical, Electrical, and I&C Maintenance.

1.4.2.1.4 The Director - Work Management is responsible for the day-to-day direction and administration of the Unit Scheduling, Surveillance Test Planning, and Outage Management activities.

1.4.2.1.5 The Director - Support Services is responsible for the day-to day direction and administration of the Unit Chemistry, Health Physics, the Unit Experience Assessment (Self Assessment and Corrective Action)

Program, and the Fuel Pool Recovery Project.

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1.4.2.2 The Recovery Officer - Millstone Unit 2 is responsible for implementation of this NUQAP for the Unit and is responsible for overall unit safe operation and control over those onsite activities necessary for safe operation and maintenance of the plant. The Recovery Officer (refer to Figure 1.3) has rielegated the necessary authority and assigned responsibility for these i activities to the:

• Unit Director, e Director- Engineering, e Director- Unit Services, e Director- Configuration Management Program, o Manager- Restart. ,

1.4.2.2.1 The Unit Director is responsible for the day-to-day direction and administration of the Unit Operations, Mechanical, Electrical, and I&C, Maintenance and Modifications, Work Planning and Outage Management, Health Physics, and the Unit Self.

Assessment and Corrective Action Programs. The Plant Operations Review Committee (PORC) reports to the Unit Director in compilance with Technical Specifications.

1.4.2.2.2 The Director - Engineering is responsible for the day.

to-day direction and administration of Unit Design Engineering, Technical Support, Project Engineering, and for maintenance of the Unit design basis in accordance with the Unit licensing basis.

1.4.2.2.3 The Director- Unit Services is responsible for the day-to day direction and administration of the Unit 1 Regulatory Compilance activities and the Unit procedures.

1.4.2.2.4 The Director - Configuration Management Program is responsible for the day-to-day direction and administration of the Unit Configuration Management Program activities. \

1.4.2.2.5 The Manager- Restart is responsible for the planning, l scheduling, coordinating and reporting of Unit restart l activities.

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1.4.2.3 The Vice President - Millstone Unit 3 is responsible for implementation of this NUQAP for the Unit and is responsible for overall unit safe operation and control over those onsite activities necessary for safe operation and maintenance of the i plant. The Vice President (refer to Figure 1.4) has delegated the i necessary authority and assigned responsibility for these activities to the:

e Unit Director, o Director- Engineering, o Physical Readiness Officer, l

• Regulatory Readiness Officer. l l

1.4.2.3.1 The Unit Director is responsible for the day-to-day l direction and administration of the Unit Operations, the Self Assessment and Corrective Action Programs,

, and the Flx-It-Now (FIN) Program. The Plant Operations Review Committee (PORC) reports to the

Unit Director in compilance with Technical l Specifications.

1.4.2.3.2 The Director - Engineering is responsible for the day.

to-day direction and administration of Unit Design

Engineering, Technical Support, and for maintenance i of the Unit design basis in accordance with the Unit licensing basis.

1.4.2.3.3 The Physical Readiness Officer is responsible for the day-to-day direction and administration of the Unit Electrical, and I&C, Maintenance and Modifications, l Work Planning and Outage Management, the MOV l Project, Radiation Protection, Project Management and Modification Engineering activities for Unit restart.

1.4.2.3.4 The Regulatory Readiness Officer is responsible for the day-to day direction and administration of the Configuration Management Program, Regulatory Compilance activities, and the Unit procedures for Unit restart.

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1.4.2.4 The Vice President - Nuclear Work Services has responsibility for implementation of this NUQAP in providing work related i services in support of the Station. The Vice President (refer to

.i Figure 1.5) has delegated the necessary authority and has assigned responsibility for these activities to the:

i l i e Director- Nuclear Services,

• Director-Information Technology, l

• Director - Nuclear Materials and Document Management, o Director - Contracts and Project Management,

• Director- General Services.

1 1.4.2.4.1 The Director - Nuclear Services is responsible for the  !

day-to-day direction and administration of Construction Support, Waste Management, Health Physics Support, Facilities Maintenance, and Testing Services forplant operations.

I 1.4.2.4.2 The Director - Information Technology is responsible  !

, for the day-to-day direction and administration of l

Computer Services Support. l l

1.4.2.4.3 The Director - Nuclear Materials and Document Management is responsible for the day-to-day direction and administration of Millsterte Power Station Stores, Procurement Engineering, and l Documents / Records control activities. The Director is

! also responsible for the approval of vendors and oversight of offsite vendors that provide quality related material and services including source and receipt inspection.

i 1.4.2.4.4 The Director - Contracts and Project Management is responsible for setting policy and for the day-to-day direction and administration of the Nuclear Contract l Group. The Director is also responsible for project management teams for each of the Station nuclear units.

1.4.2.4.5 The Director - General Services is responsible for the day-to-day direction and administration of Station Security, Medical, Safety, and ~ Fire Protection activities.

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k 1.4.2.5 The Recovery Officer - Nuclear Engineering and Support has responsibility for implementation of this NUQAP in providing e Engineering and Support Services to the Millstone Power Station. The Recovery Officer (refer to Figure 1.6) has delegated ,

the necessary authority and has assigned responsibility for

these activities to the

4 e Director- Nuclear Engineering, e Director- Engineering Programs, e Director - Nuclear Training Services, e Director- Regulatory Affairs, e Director- Emergency Planning.

1.4.2.5.1 The Director - Nuclear Engineering is responsible for the day-to-day direction and administration of Nuclear Fuels, Radiological Engineering and Assessment, Radwaste Engineering, Probabilistic Risk Assessment, Safety Analysis activities, and the Quality Software Program. The Director also acts as -

the chairperson of the Nuclear Safety Assessment Board.

1.4.2.5.2 The Director - Engineering Programs is responsible for the day to-day direction and administration of Engineering Programs and Standards, the Engineering Assurance Program, and the administration of the Design and Configuration Control Program and the ,

Design Control Manual for the Station nuclear units.

1.4.2.5.3 The Director - Nuclear Training Services is responsible for the day-to-day direction and administration of Nuclear Training and related support services.

1.4.2.5.4 The Director - Regulatory Affairs, is responsible for the overall direction and administration of Regulatory Affairs and the Licensing Program for the Station.

1.4.2.5.5 The Director - Emergency Planning is responsible for the development and maintenance of the onsite l Radiological Emergency Plan and the development i and coordination of required offsite Radiological l Emergency Response Plans.

QAP 1.0 .

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i 1.4.2.6 The Director - Corrective Actions is responsible for the i

development and maintenance of the Corrective Action Program implemented for the Station including reporting of program performance Indicators, analysis and Identification of trends, and identification of necessary preemptive corrective action as required.

4 1.4.2.7 The Director - Startup is responsible for the direction and

. monitoring of activities associated with the startup of the Station ,

nuclear units including: assuring nuclear unit startup plans and operations are consistent with regulatory and other requirements; assuring efficient allocation of station resources, ,

and the development, maintenance andprogress reporting of the '

Station integrated startup schedule.

i 1.4.3 The Director - Special Projects (refer to Figure 1.7) is responsible for the )

day-to-day direction and administration of Nuclear Operations Support

Services, the Station Administrative Procedure Group and the performance of special projects in support of nuclear operations.

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I QAP 1.0 Rev.: 19 Date:

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t Organizational Relationships ci,,,,,,,,, f' Chief Executive of Personnel Havin8 Omcer &

Quality Functions for President No

Millstone Power Station I President &

Chief Executive ,

Officer i NU - Nuclear Group i 5=PPort &

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see I I i Senior Vice President i Special

g. & Chief Nuclear Officer j Millstone Power Station I se l I administrathe 50RC  !

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r Figure 1.0  :

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support a l Admeinistrative l staf  !

I I I I Director Director Director Director Audits & Engineering Analysis Eniployee i Esaluation Fi 7,i x & 7igresa Concerns j unnaga manager Manneer manaan

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2.0 QUALITY ASSURANCE PROGRAM 2.1 GENERAL REQUIREMENTS Northeast Utilities (NU) has established a Quality Assurance Program (NUQAP) for the Millstone Power Station which complies with the criteria of 10CFR50, Appendix B, and follows the reguiatory documents and their endorsed ANSIllEEE standards identified in Appendix C wl.'h exceptions as identified in Appendix E. The quality assurance requirements set forth in the attached Policy Statement, supplemented by quality assurance proceoures, provide the primary basis of this program and the NU policy with regard to quality assurance for all the Millstone Station nuclear power plants. This NUQAP Topical Report is established to accomplish the required level of quality in 3 activities carried out throughoutthe life of the Station's nuclear power plants. '

This NUQAP applies in its entirety to all activities affecting the safety-relatedfunctions of structures, systems, and components. Safety structures, systems, and l

components are functionally Identified in Appendix A of this NUQAP and are  :

designated Category I by Northeast Utilities. Appilcability of Appendix A to each FSAR is addressed by existing Nuclear Unit specific Design Bases and Licensing commitments, and also as specifically identified in each FSAR addressing Section 3.2.1 of Regulatory Guide 1.70. This NUQAP is also appilcablein its entirety to materials, equipment, parts, consumables, and services designated CategoryI.

This NUQAP appIles to other quality programs including Anticipated Transient Without Scram (A1WS) Quality Assurance which is appilcable to MP-1 and MP-2 only (MP-3 commits to Generic Letter 85-06) and Electrical Equipment Qualification (EEQ) as defined by NU commitments. Portions of this NUQAP are also appilcable to Fire Protection Quality Assurance (FPQA), Station Blackout Quality Assurance (SBOQA) and Radweste Quality Assurance (RWQA) which are delineated in appIlcableprocedures.

The Materials, Equipment, and Parts List (MEPL) Program provides instructions to  ;

identify structures, systems, components, materials, equipment, parts, consumables, quality software, and activities that need to be identified as safety-relatedor augmentedquality.

The requirements of this NUQAP are implemented by Northeast Utilities Service l Company (NUSCO), the Northeast Nuclear Energy Company (NNECO) which operates Millstone Power Station, and their vendors performing activities affecting quality structures, systems, and ccmporents of the Station's nuclear power plants.

l l Procedures define the required indoctrination and training of personnel performing l activities affecting quality, as necessary,to assure that suitable proficiencyis achieved and l maintained.

QAP 2 0 l Rev.: 19 Date:

Page 1 of 6

Training sessions are documented. The content of the training sessions is described, attendees and attendanco date Indicated and the results (e.g., examination results) of the training sessions recorded, as applicable.

Periodic program review of the status and adequacy of this NUQAP is accomplished by Nuclear Overs /ght audits, surveillances and inspections, by Nuclear Safety Assessment Board (NSAB) reviews, and by the independent reviewteam which performs the annual NUQAP Management Review described herein and QAP 1.0, "Organizatiorf, Section 1.2.1.2. Organizations outside NU are required to review the status and adequacy of that part of this NUQAP for which they have been delegated responsibility.

2.2 IMPLEMENTATION 2.2.1 GOALS AND OBJECTIVES .

I a

The goals of this NUQAP are to maintain quality levels in an effective and efficient l manner and to assure a high degree of functional integrity and reliability of Station  !

nuclear power plant quality structures, systems, and components. To meet these goals, the following objectives of this NUQAP have been defined:

1 l

a. Define through procedures, the quality activities that apply to design, fabrication, l procurement, construction, testing, operation, refueling, repair, maintenance and modification of the Station nuclear power plants;

b. Establish, assign, and document the responsibilities for the conduct of those activities affecting quality structures, systems, and components;

c. Establish confidence that (a) quality activities for the Station nuclear power plants are performed consistent with NU policies and (b) quality activities are performed by qualified personnel, and are verified through a system of audits, surveillances, and inspections of those organizationswith quality responsibilities; ,

d. Apprise the President and Chief Executive Officer - NU Nuclear Group of unresolved problems and trends which could have a significant effect on nuclear '

power plant safety.

2.2.2 PROGRAM DOCUMENTATION This NUQAP defines the NU nuclear policies, goals, and objectives, and is used as guidance for the development of the various division, department, branch, or section procedures. Revisions to this NUQAP shall be made as needed to reflect current requirements and descriptions of activities prior to implementation.

These revisions shall be made in accordance with a Nuclear Group Procedure.

Revisions to this NUQAP, which reduce commitments previously accepted by the NRC, are submitted to the NRC for review and approval prior to implementation.

OAP - 2.0 Rev.: 19 Date:

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l Revisions which do not reduce previously accepted commitments are periodically submitted to the NRC as required by 10 CFR 50.54 (a)(3) and 10 CFR 50.55 (f)(3).

1 Quality procedures are developed by the departments performing quality activities. These procedures are reviewed for concurrence by the departments which are responsible for Implementing portions of these procedures and are approved by the initiating department. The Nuclear Oversight Department  :

reviews other department quality procedures for compliance with this NUQAP l and concurs with such procedures as described in QAP 5.0, " Procedures, Instructions, and Drawings". Changes to procedures are subjected to the same degree of control as that utilized in the preparation of the original document.

Each Vice President, Recovery Officer, and Director is responsible for implementation of this NUQAP within their organization which includes individual departmental procedure requirements applicable only to their respective activities. In addition, they are responsible for the preparation, approval, and distribution of those instructions, operating procedures, testing procedures, or other instructions where further guidance is necessary.

2.2.3 STRUCTURES, SYSTEMS. AND COMPONENTS This NUQAP applies to all activities affecting the safety-related functions of the structures, systems, and components as addressed in the Safety Analys.is Reports (SARs). Safety structures, systems, and components are functionally identified in Appendix A and also as specifically identified in each FSAR addressing Section 3.2.1 of NRC Regulatory Guide 1.70.

For structures, systems and components covered by the ASME Code, NNECO procedures describe the measures taken to assure that the quality assurance requirements contained in the code are supplemented by the specific guidance of the applicable regulatory guides and endorsed ANSI standards listed in Appendix C.

For structures, systems, and components, regulatory commitments and NNECO procedures describe the measures taken to assure that the quality assurance requirements are met.

The degree of control over activities affecting quality structures, systems, and components is consistent with their importance to safety. Such controls include use of appropriate equipment, establishment of suitable environmental conditions, and assurance that all prerequisites for a given activity have been ,

satisfied. This NUQAP provides controls over special processes and skills j necessary to attain the required quality, and the need for verification of quality by I inspection and test.

QAP - 2.0 Rev.: 19 Date:

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The Nuclear Overs /ght Department and applicable NNECO technical organizations jointly determine and identify the extent quality assurance controls are applied to quality structures, systems, and components. The quality assurance controls are in conformance with this NUQAP, which complies with the 18 criteria set forth in Appendix B to 10 CFR 50.

2.2.4 PARTICIPATING ORGANIZATIONS The organization for Millstone Power Station activities affecting the quality of '

structures, systems, and components is identified in QAP 1.0, " Organization",

which also briefly describes assigned responsibilities.

The Nuclear Overs /ght Department is responsible for; a)the development, coordination, and administrative control of this NUQAP including coordination of Nuclear Overs /ght Department procedure review and approval; b) assuring issuance of this NUQAP Topical Report as a controlled document (as described in QAP 6.0, '" Document Contro/', and; c) the review and concurrence with quality procedures and revisions written by other departments. Procedure reviews shall be performed in accordance with QAP 5.0, " Procedures, j Instructions, and Drawings .

Northeast Utilities (NU) requires that its approved vendors performing quality activities invoke upon their subvendors, via purchase l orders / contracts, requirements for a quality assurance program to meet the applicable criteria of Appendix B to 10 CFR 50, including the applicable elements of the regulatory guides and their endorsed ANSI //EEE standards identified in Appendix C. However, NU retains overall responsibility for the Millstone Power Station Quality Assurance Program. The specific quality activities performed by these organizations are specified in the procurement documents. Nuclear Materials and Document Management is responsible for the review and approval of these vendors' quality assurance programs prior to initiation of contracted activities.

The object of the review is to verify that these vendors have an adequate quality assurance program to meet applicable requirements of 10 CFR 50, Appendix B.

In addition to the initial review, Nuclear Materials and Document Management is responsible for the subsequent performance, as appropriate, of audits, surveillances, and inspections of approved vendor's quality assurance l programs to assure continued implementation of quality requirements. Nuclear i Materials and Document Management has contracted this function to the j Yankee Atomic Electric Company (YAEC) in accordance with this QAP. l The Nuclear Oversight Department performs audits, surveillances, and l Inspections, as appropriate, of onsite vendor quality assurance programs i to assure continued implementation of quality requirements.

Vendors may be delegated the execution of quality assurance functions by Contract. These Contracts are reviewed and apprcved in accordance with this OAP - 2.0 Rev.: 19 Date:

Page 4 of 6

i NUQAP. These vendors may be contracted to perform quality activities under their approved quality assurance program or directly under the l l requirements of this NUQAP.

I 2.2.5 INDOCTRINATION AND TRAINING l l

A program is established and maintained for quality assurance indoctrination and l training which provides confidence that the required level of personnel competence and skill is achieved and maintained in the performance of quality I activities. Quality procedures delineate the requirements for an indoctrination i program to assure that personnel responsible for performing quality activities are instructed in the purpose, scope, and implementation of quality procedures and that compliance to these documents is mandatory. Eaci) NUSCO/NNECO l Department is responsible for assuring assigned personnel who perform i quality activities have been appropriately indoctrinated r.nd trained.

Nuclear training programs shall be developed and implemented to provide training for all individuals attached to or associated with the Station nuclear I powerplants. Additional guidance is established in NNECO procedures.

Procedures describe the nuclear training program requirements which assure that;

a. Documentation of formal training and qualification programs includes the objective, content of the program, attendees, date of attendance; and results (e.g., examination results), as applicable.

I

b. Proficiency of personnel performing and verifying activities affecting quality is established and maintained. Personnel proficiency is established and maintained by training, examination / testing, and/or certification based upon the requirements of the activity. Acceptance criteria are developed to determine if individuals are properly trained and qualified;

c. Certificates or other documentation of qualification clearly delineate the l specific functions personnel are qualified to perform and the criteria used to l qualify personnelin each function.

This program also requires the head of each department to be responsible for a training plan which assures that personnel performing quality activities are  ;

trained in the principles and techniques of the activity being performed.

2.2.6 MANAGEMENT PARTICIPATION Millstone Power Station Vice Presidents, Recovery Officers, and Directors are responsible for implementing this NUQ.AP within their organization. The Vice President - Nuclear Oversight will assist in development, coordination, and review of the program. i 1

QAP - 2.0 Rev.: 10 Date:

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1 The President and Chief Executive Officer- NU Nuclear Group assures that a Management Review of this NUQAP is conducted on an annual basis by an independent team to assess the scope, status, implementation, effectiveness, and to assure compliance to NRC licensing commitments.

Actions considered by the Management Review may include, but are not limited  ;

to.

I

a. Review of selected procedures and documents;

)

b. Verification of the implementationof selected proceduralrequirements;  !

c. Review of past audit results and otherInspection/rev/ewresults such as those from previous Management Reviews, the NRC or other departments.

The Management Review's findings of deficiencies and recommendations for r program improvement are forwarded to the President and Chief Executive Officer - NU Nuclear Group, who shall assure appropriate corrective action is taken.

Nuclear Materials and Document Management assures that the quality assurance programs of vendors that perform quality activities are reviewed to assure that the vendor management regularly reviews the status and adequacy of theirprograms.

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3.0 DESIGN CONTROL 3.1 GENERAL REQUIREMENTS ,

This NUQAP provides measures to assure that the applicable design requirements, such as design bases, regulatory requirements, codes, technical standards and quality standards, are identified in design documents which are reviewed, approved and controlled in accordance with procedures. Such measures include review for suitability of application of materials, equipment, parts and processes that are essential to the functions of quality structures, systems, ,

and components. Changes to, and deviations from specified requirements are l identified, documented and controlled.

l The Director - Engineering for each nuclear unit is responsible for controlling  :

design work, administering design control activities (including design interface) and design modifications for quality structures, systems, and components.

l The responsibility for administration of the design control program for the

? Millstone Station nuclearpowerplants rests with Engineering Programs. Tbe division of responsibilities and jurisdictional boundaries for design control program implementation are set forth in NNECO procedures. Although other l

~

organizations may be delegated the task of establishing and executing the design control program or any part thereof, the Director- Engineering of each nuclear l unit shall retain the responsibility for program Implementation for the unit. The l applicable requirements of this NUQAP shall be imposed on other organizations i delegated the task of establishing or executing the des /gn control program in accordancs with QAP 4.0, " Procurement Document Contror' and QAP 7.0, Control of PurchasedMaterial, Equipment and Services".

l The interface controls, both internal and external, for organizations performing design work for quality structures, systems, and components are identified and l implemented in accordance with procedures. This identification includes those organizations providing criteria, designs, specifications and technical direction.

]

Measures are applied to verify the adequacy of design. The extent of design l verification is specified and documented by the responsible organization. The

individuals performing design verification should not (1) have immediate supervisory responsibility for the individual performing the design, (2) have i specified a singular design approach, (3)have ruled out certain design considerations, or (4) have established the design inputs for the particular design aspect being verified; The independent design verification should not dilute or replace the responsibility of the supervisors for the quality of work performed under their supervision. Where changes to previously verified designs have been made, design verifications are required for the change, including evaluation of the effects l of those changes on the overall design. Design verification may be accomplished by testing. Tests to demonstrate adequacy under adverse design conditions shall comply with the requirements of QAP 11.0, " Test Control" Design errors and

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.= - . .._ ~ . - -- .. - -. - - - -

4 deficiencies which adversely affect quality structures, systems, and components in

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the design process are documented and appropriate corrective action is taken.

These design errors and deficiencies are documented in accordance with design change procedures or as defined in QAP 15.0, " Nonconforming Material, Parfs, Components, or Services" and/or QAP 16.0, " Corrective Action".

3.2 IMPLEMENTATION The Director - Engineering of each unit is responsible for the design, design review, engineering approval of design changes, design evaluation and design control for the unit except that Nuclear Engineering performs design / design changes in support of the reactor core reload. The function may be delegated to other organizations to perform the design, or any part thereof, but the responsibility for overall design and final engineering decisions and design control of quality structures, systems, and components related to the nuclear unit is the responsibilityof the unit's Director- Engineering Nuclear Oversight perforrns audits, surveillances, and inspections, as appropriate, to verify that NUSCO/NNECO departments are effectively complying l with this NUQAP and procedural requirements for design control. Nuclear i Materials and Document Managementis responsible for the performance of 1 offslie audits, surveillances, and inspections, as appropriate, to verify that vendors are effectively complying with their quality assurance program requirements for design control. Nuclear Oversight performs audits, y surveillances, and inspections, as appropriate, of onsite vendor activities in this area.

}

3.2.1 DESIGN PROCESS i

i Design control measures are applied to design analyses, such as, reactor physics, stress, thermal, hydraulic, nuclear radiation, accident and

seismic analyses; compatibility of materials; accessibility for in-service inspection, maintenance, and repair; and delineation of acceptance l criteria for inspections and test. Measures established to control design l documents are described in QAP 6.0, " Document Controt'.

Program procedures and instructions define the method of implementing design control measures. These measures require that applicable design requirements, such as, design bases, regulatory requirements, codes and standards, are translated into specifications, drawings, procedures or instructions. Procedures and instructions further require that i

appropriate quality standards are specified and included in design documents. Materials, equipment, parts and processes, including standard "off the shelf" commercial or previously approved items i essential to quality functions are selected and reviewed for suitability of

application. The basis for selection may include industry standards,

{ material and prototype hardware testing programs, and design review.

i OAP - 3.0 Rev.: 19 Date:

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}

l Procedures assure that a documented check is performed to verify the accuracy and completeness of design drawings and specifications before l release for procurement, fabrication or construction. Design drawings receive a documented check to verify dimensional accuracy.

i Design drawings and specifications issued for design changes are reviewed for completeness and accuracy before release to operations, in accordance with design control procedures.

Procedures describe the provisions to assure that design drawings and specifications are prepared, reviewed and approved in accordance with NNECO requirements and that the documents contain the necessary quality assurance requirements, such as inspections and test requirements, acceptance requirements, and the extent of documenting inspection and test results.

3.2.2 DESIGN CHANGE CONTROL Procedures and instructions governing design change control during l modifications to the Station nuclear plants, the control of discrepant or I deficient design conditions, and the reporting of unsatisfactory I performance provide for the identification of the need for design changes l and a documented method to control these changes. Design and '

specification changes are subject to design control measures commensurate with those applied during the original design as amended by appilcable design orlicensing basis changes.

An independent review and approval of design changes is performed by ,

the organization that conducted the original design reviews, unless such I rev/ew is performed by NNFCO or another qualified organization delegated by NNECO to perforn tis function.

Proposed design change modifk ans are submitted to the appropr/ ate I nuclear units management for ocessing and review. This review includes the Plant Operatic. Review Committee (PORC)/ Site Operations Review Committee (SORC) as required by applicable procedures. PORCISORC is advisory to the Senior Vice President and Chief Nuclear Officer and Unit Directors / Unit Operations Director (Millstone Unit No.1) on matters relating to nuclear safety. The composition, responsibilities, and authority of the SORC/PORC are defined in Section 6 of each nuclear unit Technical Specification. If the change involves a quality structure, system or component, the change shall be reviewed by qualified engineering personnel for technical adequacy. Reviews of the safety evaluations associated with

, proposed design changes are performed by the Nuclear Safety l Assessment Board (NSAB). The sequence of the NSAB review depends l upon the determination of whether an unreviewed safety question is l involved (i.e., in accordance with ANSI N18.7, if a proposed change in l QAP - 3.0 Rev.: 19 Date:

Page 3 of 6

l

~ j the facility involves an unreviewed safety question then the NSAB review is conducted prior to submittal of the proposed change to the NRC for 1 review and the issuance of a license amendment for its implementation).

The combination of these independent reviews by the PORC/SORC and NSAB are performed to assure that:

a. the adequacy of the proposed change is substantiated;

b. unreviewed safety questions are properly identified and handled per 10 CFR 50.59;

c. nuclear safety requirements have been addressed.

Errors and deficiencies in design, including the design process, that could l adversely affect quality structures, systems, and components are documented and corrective action is taken in accordance with QAP 15.0,

" Nonconforming Materials, Parts, Components, or Services" and/or 1 QAP 16.0," Corrective Action'.

l Notification of design changes are transmitted to responsible plant personnel prior to implementation and as part of the design change package close out. Procedures describe this notification which assures that personnel are made aware of design change modifications which may affect the performance of their duties.

3.2.3 DESIGN INTERFACE CONTROL Procedures and instructions identify design interface controls and the resolution of design interface questions during modifications to the station nuclearpowerplants.

3.2.4 INDEPENDENT DESIGN VERIFICATION Original designs and design modifications are reviewed for adequacy and the sign-off performed by a person other than the originator of the design.

The originator's supervisor may perform this Independent review only if the supervisor: (1) did not specify a singular design approach, (2) did not estabilsh the design inputs or rule out certain design considerations, (3)is the only Individualin the organization competent to perform the review. Where the supervisor performs the design review, the next level of management shall fulfill the supervisor's responsibilities. Design verification is documented in accordance with procedures or instructions. Simplified calculations or computer programs may be utilized as alternate means of design verification. When design verification is performed by testing, the tests are performed using procedures, which specify the authority and QAP - 3.0 Rev.: 19 Date:

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l

( responsibility of design verification personnel. Responsibility for design adequacy and evaluation is retained by the Director - Engineering of each unit.

l Design verification (if other than by qualification testing) is normally

! completed prior to release for procurement, fabr/ cation, and construction, or release to another organization for use in other design activities. For those cases where design verification cannot be completed prior to release for procurement, fabrication, and construction, procedures assure that design verification is completed prior to the point when the installation is declared operational.

Procedures describe the requirements which assure the following when testing is considered as an alternate method of design verification:

a. Specifications or procedures provide criteria that specify when verificationshould be by test.

b. Prototype, component or feature testing is performed as early as possible prior to installation of plant equipment, or prior to the point when the installationis declared operational.

c. Verification by test performed under conditions that simulate the most adverse conditions as determined by analysis.

Particular emphasis is placed on assuring that designs are in ,

conformance with applicable codes, and on selecting the proper design I verification or checking method. Procedures and instructions provide the l requirements and necessary controls for design verification. These controls include a review to assure that design characteristics can be controlled, verification that there is adequate accessibility for inspection 1 or test, and that inspection and test acceptance criteria are incorporated.

Documentation of reviews is provided.

Procedures include requirements which identify the responsibility of j design verifiers, the areas and features to be verified, and the extent of the documentation.

Procedures assure that procedural control is established for design documents that reflect the commitments of the nuclear unit FSAR.

These procedural controls vary for design documents which receive formal design verification by several disciplines or organizations, and those which can be reviewed by a single individual. The specific design documents and specialized reviews are determined and used as required by the design changes and modifications.

Procedures are established to assure that verified computer programs j are certified for a specific use.

QAP - 3.0 Rev.: 19 Date:

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NNECO is responsible for assuring that the design documents generated by vendors for the Station nuclear power plants are technically correct, approved, and maintained.

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I Rev.: 19 l Date:

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4.0 PROCUREMENT DOCUMENT CONTROL 4.1 GENERAL REQUIREMENTS This NUQAP provides measures to control the procurement of materials, equipment, parts and services for quality structures, systems, and components for the MIIIstone Station nuclear power plants to assure compliance with applicable regulatory requirements, procedures, quality assurance standards, and regulations affecting procurement documents. Changes to i procurement documents are subject to the same degree of control as utilized in the preparationof the originaldocuments.

4.2 IMPLEMENTATION 4.2.1 PROGRAM A responsible engineer is selected for each modification to a Station nuclear power plant. The responsible engineer coordinates the preparation, review and approval of procurement documents for quality materials, equipment, parts and services, and assures the technical adequacy and inclusion of quality assurance requirements.

Requests for materials, equipment, parts and services are reviewed for technical adequacy and verification of the quality designation. The appropriate responsible engineer / nuclear unit management reviews and approves such requests in accordance with applicable procedures. 1 Nuclear Materials and Document Management personnel then l perform a procurement engineering evaluation to assure the inclusion l and adequacy of quality assurance requirements prior to the issuance of '

the purchase order. Materials, equipment, and parts for which ,

technical and quality assurance requirements have been previously )

estabilshed within the MaterialInformation Management System are l purchased without additionalprocurement engineering evaluations.

Vendors utilized to perform quality activities for the Station nuclear power plants are responsible to implement measures for control of associated procurement documents to assure applicable requirements including quality assurance requirements are specified. Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillances, and inspections, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for the control of procurement documents. Nuclear Oversight performs audits, ,

surveillances, and inspections, as appropriate, of onsite vendor i activities in this area.

l QAP - 4.0 '

Rev.: 19 Date: l Page 1 of 3 1

Changes to procurement documents, whether initiated by NNECO or its representative, are subjected to the same degree of control as that utilized in the preparation of the original document. The procurement of spare or replacement parts for quality structures, systems, or components is subject to the controls of this NUQAP and applicable procedure requirements. The spare or replacement parts are subject to controls equivalent to original or subsequent codes and standards. The use of subsequent codes and standards are controlled in accordance with QAP 3.0, " Design Contro/'.

Procurement engineering evaluations of requests for quality materials, equipment, parts, and services requests are performed by Nuclear Materials and Document Management personnel to assure that:

a. Adequate technical requirements are specified,

b. The quality assurance requirements are correctly stated, auditable and controllable;

c. There are adequate acceptance and rejection criteria.

4.2.2 PROCUREMENT DOCUMENT PROVISIONS Procurement documents are prepared, reviewed and approved in accordance with applicable procedures of the issuing organization or department and are available for verification. These procedures require that procurement documents consist of the following, as necessary:

a. The scope of work to be performed;

b. Technical requirements (specified or referenced) including the applicable components and materials identification requirements, drawings, specifications, procedures, instructions, codes and regulations, and the identification of applicable test, inspection and acceptance requirements, or special process instructions;

c. Quality assurance program requirements to be imposed on vendors which inc!vde the applicable requirements of 10 CFR 50, Appendix B, and the NRC regulatory position contained in the regulatory guides and their endorsed ANSI //EEE standards listed in Appendix C.

d. Right of access which provides, as appropriate, for access to vendor facilities and records for inspection or audit by NNECO or its designated representative; and provides access for events such as those requiring notification of hold points; QAP - 4.0 Rev.: 19 Date:

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e. The documentation required to be prepared, maintained, and/or submitted to NNECO or its representative for review, approval or historical record. The time of submittal of this documentation and the retention and disposition of quality assurance records which are not submitted to NNECO is prescribed, as applicable, for nuclear grade procurements.

4.2.3 SELECTION OF PROCUREMENT SOURCES The vendor is specified during the procurement process based upon the vendor approval status, qualifications and capabilities to provide the product or service, performance history, and NNECO's ability to verify the quality of the product or service being purchased. NNECO maintains an approved vendors list based upon the technical and quality capability as determined by a direct evaluation of the vendor's facilities and personnel and the implementation of the vendor's quality assurance program.

Procurement documents may be issued to vendors with unapproved 3 quality assurance programs. These procurement documents to j unapproved vendors contain detailed supplementary quality assurance l requirements and/or witness / hold points to meet NNECO requirements.

Procurement documents are reviewed by Nuclear Materials and Document Management to assure appropriate quality assurance j requirements are specified. The requirements include, as necessary,  ;

audits, surveillances, or inspections at the vendor's facilities with j scheduled witness / hold points during the fabrication process and/or prior to shipment of the procured items. Acceptance inspections and tests determined by NNECO shall be performed after receipt at Millstone Power Station but prior to installation in the plant or prior to the point when the installation is declared operat!onal.

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5.0 PROCEDURES. INSTRUCTIONS. AND DRAWINGS 5.1 GENERAL REQUIREMENTS l This NUQAP provides measures for the preparation, review, approval, control and distribution of procedures, instructions and drawings for activities affecting quality I structures, systems, and components of the Millstone Station nuclear power l plants. The documents include appropriate quantitative and qualitative acceptance l criteria which specify the activity to be performed, the methods of fabr/ cation, I construction, and testing to be employed; the materials, equipment or parts to be .

I used; a sequence of operation, and the required documentation.

5.2 IMPLEMENTATION Quality procedures provide direction for personnel performing quality activities The Nuclear Oversight Department reviews and concurs with other department quality procedures which implement this NUQAP as describedin Section 5.2.1 below. Comments concerning compliance with this NUQAP and regulatory requirements are resolved prior to issuance of the procedure. Any vendors utilized to perform quality activities for the Station nuclear power plants may be delegated responsibility for preparing, maintaining, issuing and verifying the implementation of appropriate program documents which are selectively reviewed / approved by the appropriate Director or responsible engineer. In this case, Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillances, and inspections, as appropriate to verify that these vendors are effectively complying with their quality assurance program requirements for compliance with procedures and instructions. Nuclear l Oversightperforms audits, surveillances, and inspections, as appropriate, of l onsite vendor activities in this area. Vendor quality assurance programs are i

required to clearly delineate the actions to be accomplished in the preparation, review and control of procedures, instructions and drawings and the methods for complying with 10 CFR 50, Appendix B.

5.2.1 PROCEDURES AND INSTRUCTIONS Procedures and instructions for activities affecting quality are prepared, reviewed, and approved in accordance with written procedures and instructions.

l The cognizant Director or responsible engineer assures that any

! vendors utilized to perform quality activities for the Station nuclear

, power plants implement quality assurance programs which contain

, written instructions for preparation, review and approval of procedures and instructions affecting quality, in addition, onsite vendor quality procedures and quality control inspection procedures are reviewed for i

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concurrence by Nuclear Oversight to assure compliance with the vendor's quality assurance program.

NNECO is responsible for the preparation, review and approval of station and plant quality procedures. The procedures include test procedures and overall site administrative procedures which implement the requirements of this NUQAP. Each NNECO organization is also responsible for the preparation, review and approval of procedures covering quality activities in accordance with individual license requirements. The Nuclear Oversight Department reviews and concurs with quality procedures and special process procedures. The criterla for documents requiring Nuclear Oversight review and concurrence and theiridentification are definedin qualityprocedures to assure:

1. Administrative procedures and manuals comply with this NUQAP and appilcable Appendix C regulatory guides and endorsed ANSI /IEEE standards. ,

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2. Work procedures and work documents used to perform quality \

activilles have the necessary quality assurance controls as l describedin QAP 10.0, " Inspection".

5.2.2 DRAWINGS I

The design control and verification measures described in QAP 3.0,

" Design Controf', are applicable for . the review and approval of drawings. Review and approval of new drawings or modifications to existing drawings are described in NNECO procedures. The originating organization may delegate to other organizations or departments the work of design and review activities, or any part thereof, but retains responsibility for this work.

The measures taken to assure the preparation of as-built drawings and related documentation in a timely manner to accurately reflect the actual plant are described in NNECO procedures. Drawings critical to operation are updated prior to system turnover to operation and are available to the operating personnel.

5.2.3 ACCEPTANCE CRITERIA Cognizant Department Heads review and approve departmental procedures, instructions and drawings to assure the inclusion of adequate quantitative and qualitative acceptance criteria, as appropriate, for determining satisfactory work performance and quality compliance for appilcable quality activities.

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6.0 DOCUMENT CONTROL 6.1 GENERAL REQUIREMENTS l

i This NUQAP provides measures to assure controlleddistribution of documents I pertinent to quality activities performed for the Millstone Station nuclear power plants in accordance with quality procedures.  ;

l Documents such as procedures, instructions, drawings, specifications and reports are prepared, reviewed for appropriate qualitative and quantitative acceptance i criteria, and approved by authorized personnel in the affected organization. )

Approved controlled documents are distributed to affected locations in accordance j with controlled distribution lists. Changes to controlled documents are reviewed '

and approved by the same organization which performed the original review and approval, unless otherwise specified in the applicable procedures. Measures are  !

provided for controlling documents to preclude the possibility of use of outdated l documents. i 6.2 IMPLEMENTATION 6.2.1 RESPONSIBILITY NNECO procedures and instructions delineate the measures for controlling documents including direction for the review for adequacy, approval by authorized personnel, distribution of controlled documents and verification that changes are promptly incorporated and implemented. These control measures apply to documents affecting quality structures, systems and components during the performance of quality activities for the Station nuclear power plants and include documents such as: l I

l a. Design Specifications; I

b. Design, Manufacturing, Construction and Installation Drawings;

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l c. As-Built Documents;

d. Quality Assurance Program Manuals, Procedures and Instructions;

e. Manufacturing, inspection and Testing Instructions; l f. Test Procedures;

g. Calculations; \

i h. Engineering Record Correspondence; i

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l. Design Basis Documentation (DBD)

J. Final Safety Analysis Reports;

k. Procurement Occuments; i

l. Design Change Records;

m. Topical Report;

n. Nonconformance Reports;

o. Computer Codes.

NUSCO/NNECO procedures describe the measures taken by the Nuclear Oversight Department or individuals other than the person who generated the document but qualified in quality assurance for the control of documents to assure review and concurrence, as necessary, for such documents listed above with regards to quality assurance aspects. l The requirements for control of procurement documents are contained in QAP 4.0, " Procurement Document Controf'. It is the responsibility of each organization issuing controlled documents to employ document control procedures. The issuing organization is additionally responsible for distribution of the documents to appropriate locations. There shall be provisions to assure that approved changes are included in instructions,  ;

procedures, drawings and other documents prior to implementation of the changes.

1 Any vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementing measures for review, approval, control and distribution of controlled documents to ,

assure they are effectively complying with the requirements for document l control. Nuclear Materials and Document Management is  ;

responsible for the performance of offsite audits, surveillances, and inspections, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for document control. Nuclear Oversight performs audits, surveillances, and Inspections, as appropriate, of onsite vendor activities in this area.

6.2.2 DISTRIBI) TION OF CONTROLLED DOCUMENTS NNECO procedures, specify in what manner controlled documents and revisions thereof, are distributed to appropriate locations, prior to commencing the work.

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6.2.3 DRAWING CONTROL Station Nuclear Document Services is responsible to implement a .

program, through appilcable procedures, for the retention and retrieval l of drawings and records submitted by cognizant NUSCO/NNECO i personnel. Staflon Nuclear Document Services maintains a drawing I status file which includes drawings newly issued or revised with the latest revision and current status.

Vendors utilized to perform quality activities for the Station nuclear power plants may be delegated the function of drawing control and must furnish periodic status reports listing the revisions of applicable drawings which they issue.

Nuclear Materials and Document Management is responsible for the 1 pedormance of offsite audits, surveillances, and inspections, as l appropriate, to verify that these vendors are effectively complying with I their quality assurance program requirements for control of drawings.

Nuclear Oversight pedorms audits, surveillances, and Inspections, as appropriate, of onsite vendor activities in this area.

6.2.4 PROCEDURE AND INSTRUCTION CONTROL The Nuclear Oversight Department performs audits, surveillances, and inspections, as appropriate, of NUSCO/NNECO Departments and l onsite vendors utilized to perform quality activities to verify they are l effectively complying with this NUQAP and the vendor quality i assurance program requirements, respectively, for control of l procedures and instructions.

The originating department is responsible for establishing adequate control over quality procedures and instructions issued by them. The  !

responsible organization also issues status reports or revised indices )

listing the latest revision of applicable controlled documents issued by l them.

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7.0 CONTROL OF PURCHASED MATERIAL. EQUIPMENT AND SERVICES 7.1 GENERAL REQUIREMENTS This NUQAP provides measures for the control of purchasedmaterial, equipment, parts and services utilizedin quality activities for the Millstone Station nuclear power plants to assure conformance to procurement documents. These measures include provisions for source evaluation and selection, submission of objective evidence by the vendor or subvendors, inspection at the vendor facility, and acceptance inspection and testing of the product upon delivery. Control of quality by vendors and their subvendors is assessed for effectiveness at intervals consistent with the importance, complexity and quantity of the product or service.

7.2 IMPLEMENTATION The evaluation and selection of vendors is performed in accordance with procedures, which specify that procurement source evaluation and selection measures are performed to determine vendor capability and delineate responsibilities of qualified personnel involved in the evaluation and selection process.

7.2.1 VENDOR QUALIFICATIONS Nuclear Materials and Document Management utilizes one or more of the following methods in evaluating the qualifications of a potential vendor:

a. Audits and/or coordinated review of a potential vendor utilizing one or more departments (i.e., Engineering, Nuclear Work Services, Operations and/or Purchasing);

b. Other utility vendor audits and evaluations;

c. Nuclear Procurement issues Committee (NUPIC) audits; j

d. ASME N, NA, NPT, NV, or MM/ MS Certificate of Authorization; I

e. Commercial grade surveys and/or coordinated review of a potential l vendor utilizing one or more departments, (i.e., Engineering, Nuclear Work Services, Operations and/or Purchasing);

f. Source inspection / surveillance.

Evaluations assure that vendors providing quality material, equipment, parts and services employ a quality assurance program that conforms to applicable portions of this NUQAP.  ;

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Nuclear Materials and Document Management is responsible for l assuring that documented evidence of the evaluation and acceptance of the vendor's quality assurance program /s maintained. The determination of vendor approval is based on such factors as prior performance, quality performance data, audits, commercial grade ,

surveys, surveillances and evaluations of the vendor's quality assurance '

program.

1 Vendor Certificates of Conformance are periodically evaluated by audits, I commercial grade surveys, surveillancas, independent inspections and I tests, to assure they are valid. This verifsation of Certificates of Conformance is documented.

7.2.2 SOURCE INSPECTION Nuclear Materials and Document Management is responsible for the performance of source inspect'ons at vendor facilities to assure that the I requirements of a purchase order / contract have been met.

Source inspections are performed in accordance with procedures which provide for the method of inspection, the extent of documentation required and those responsible for implementing those instructions.

Inspection of items occurs either when verifications of procurement requirements cannot be determined upon receipt or the vendor quality assurance program has not been accepted by Nuclear Materials and Document Management.

Nuclear Materials and Document Management has contracted the pedormance of the Vendor source inspection function to the Yankee Atomic Electric Company (YAEC) in :ccordance with this NUQAP.

7.2.3 RECEIPT INSPECTION ,

Receipt inspection for procured items is performed by Nuclear Materials and Document Management in accordance with quality procedures which delineate requirements and responsibilities necessary to perform .

inspection functions. The exceptions to this are Reactor Engineering l performing receipt inspection for now fuel assemblies; Chemistry performing receipt inspection for diesel / gas turbine fuel, and Unit Operations pedorming receipt inspection of bulk hydrogen / nitrogen for Millstone Power Station Unit No. 3 in accordance with quality procedures. Contractual obligation fulfiliment and specified requirements are verified during receipt inspections.

Receipt inspection of vendor-famished material, equipment, and parts is performed to assure that these Items and acceptance records are ,

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examined in accordance with predetermined inspection instructions prior to acceptance, installation and operation. Receipt inspections include, as appropriate:

a. Measures for verifying that the shipmt nt is complete, properly identified, undamaged and correspor.ds with the required documentation;

b. Measures for inspection of the item's critical characteristics and review of supporting documentation (e.g., mill test reports, NDE reports) as required by the procurementdocuments;

c. Measures for inspection and acceptance of items in accordance with predetermined methods;

d. Measures for identifying and controlling acceptable items including identification of inspection status prior to release from the receiving inspection area;

e. Measures for identifying, segregating and handling nonconforming items;

f. Measures to ascertain that inspection records or Certificates of Conformance are acceptable prior to release for installation;

g. In cases involving purchased services, the responsible engineer or Department Head shall designate the means by which services may be accepted, and is given the authority to accept services in accordance with methods defined in NUSCO/NNECO procedures. )

1 7.2.4 VENDOR FURNISHED RECORDS )

Records required to be furnished by the vendor are specified in the  !

procurement documents. Certifications or documentation provided by the vendor which attests to conformance, identifies that all the specific procurement requirements have been met (either by reference to the l purchase order or by delineation).

The vendor must furnish the following records as a minimum for nuclear grade purchases; j

a. Documentation that identifies the purchased material, equipment, or parts and the specific procurement requirements. (e.g., codes, standards and specifications)which have been met by the items;

b. Documentation that identifies any procurement requirements which have not been met, together with a description of those Nonconformances dispositioned " accept as is" or " repair."

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The responsible Nuclear Materials and Document Management and/or engineering and other appropriate department personnel shall review for acceptability those documents which pertain to the requirements in the ~ procurement document, in accordance with this NUQAP and applicable procedures.

The department that is contracting onsite quality assurance services shall be responsible for the review and acceptability of vendor personnel / equipment certifications prior to the start of work. The Nuclear Overs /ght Department shall provide oversight of these activities via audit, surveillance, or inspection, as appropriate, to verify compilance with this requirement.

7.2.5 COMMERCIAL DEDICATION NNECO procedures address the measures taken to assure that for commercial grade items, where specific quality assurance controls for nuclear applications cannot be imposed in a practicable manner, that special dedication requirements are established and implemented.

These measures follow the guidance in Regulatory Guide 1.144, paragraph C. 3. b (1) and Regulatory Guide 1.123 and applicable paragraphs of Section 10 of ANSI N45.2.13.

These measures include appropriate requirements for special categorization and identification within the procurement document, receiving inspection, and additional controls during the installation and testing process to be performed by Nuclear Materials and Document Management, other NNECO Departments, or other appropriate groups.

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8.0 IDENTIFICATION AND CONTROL OF MATERIALS. PARTS AND COMPONENTS l 8.1 GENERAL REQUIREMENTS This NUQAP provides measures for the identification and control of materials, parts and components, including partially fabricated assemblies utilizedin quality activities for the Millstone Power Station. To assure that each item can be traced to the associated documentation, the identification of the item is maintained by heat number, lot number, ,

part number, serial number, or other appropriate methods, and is physically marked on the 1 l item and/or on records traceable to the item. Documentation associated with materials, I parts, and components delineate that these items have been designed, fabricated, manufactured, tested and/or inspected in accordance with the specified requirements.

The object of these controls is to prevent the use of incorrect or defective materials, parts and components.

These measures also require NNECO assure that the identification of inspections, tests, and operation status of structures, systems, and components is known to affected organizations. I 8.2 IMPLEMENTATION NNECO procedures establish the responsibilities and requirements for the identification and control of materials, parts and components. The procedures assure that identification and control are maintained throughout fabrication, receipt, handling, storage and )

installationofitems. Provisionsinclude:

a. Requirements for traceability to appropriate documentation such as: purchase orders, contracts, manufacturing documents, drawings, specifications, certifications, inspection and test records, and nonconformance reports;

b. Controls to assure that the correct identification of an item is verified and documented prior to release for fabrication, assembly, shipping or installation;

c. Requirements which assure that the method or location of markings do not affect the function or quality of an item;

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d. Establishment of identification requirements in purchase orders, contracts, specifications, drawings, procedures or instructions.

During the performance of quality activities for the Station nuclear power plants, NNECO may delegate any portion of the implementation of the identification and control program to a vendor, if delegated, contracts require that the vendor establish an identification and control program which meets this NUQAP requirements. In this case, the Nuclear Materials and Document Management is responsible for the

! performance of offsite audits, surveillances, and inspections, as appropriate, to verify l

that these vendors are effectively complying with their quality assurance program requirements for identification and control of materials, parts and components. Nuclear OAP - 8.0 Rev.: 19 Date:

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Receipt inspections are performed to verify that materials, parts and components are properly identified in accordance with procurement requirements. Nuclear Materials and ,

l Document Management is responsible for assigning and applying necessary  ;

l identification to the items in accordance with applicable procedures to assure proper identificationand traceability.

In the event that materials, parts or components are nonconforming or the identification becomes lost or illegible, the items are considered nonconforming and are identified and  !

controlled in accordance with QAP 15.0, " Nonconforming Materials, Parts, Components, or Services" l

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9.0 CONTROL OF SPECIAL PROCESSES l 9.1 GENERAL REQUIREMENTS l

l This NUQAP provides measures to assure the control of special processes associated with quality structures, systems, and components of the Millstone Station nuclear powe ,

plants by the use of qualified procedures, equipment and personnel.

Special processes are performed under controlled conditions in accordance with special requirements and may include, but are not limited to: welding, cleaning, heat treating, and nondestructive examination and/or testing.

9.2 IMPLEMENTATION During quality activities performed for the Station's nuclear power plants, the responsible engineer assures that special process data and documentation is reviewed, and that vendor special process procedures utilized for the Station nuclear power plants are qualified and approved, and that personnel and equipment utilizing special processes are properly qualified prior to start of work. Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillances, and i inspections, as appropriate, to verify that these vendors are effectively complying with l their quality assurance program requirements for control of special processes. Nuclear Oversightperforms audits, surveillances, and inspections, as appropriate, of onsite vendoractivitiesin this area.

NNECO special process procedures utilized during quLlity activities for the Station  !

nuclear power plants are prepared, reviewed and approved in accordance with procedures )

as specified in OAP 5.0, " Procedures, Instructions, and Drawings". i 9.2.1 PROCEDURE QUAllFICATION AND CONTROL NNECO procedures specify that written process control documents are utilized and qualified, as required, in accordance with the applicable specification, codes or standarc's. I I

9.2.2 PERSON!!EL QUALIFICATION AND CERTIFICATION Codes, standards and NUSCO/NNECO procedures specify personnel qualification / certification ;equirements. Personnel responsible for the performance and verification of special processes are trained, tested, and certified as required by applicable specifications, codes and standards.

Requirements for the period of certification, retesting, and recertification of personnel are also specified. Vendors qualify personnel and maintain records of qualified personnel in accordance with applicable codes, standards, specifications, and vendor purchase order / contract requirements. The i

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l l department that is contracting services is responsible for the review of records of qualified personnel, equipment and procedures associated with special processes. The Nuclear Oversight Department shall provide an oversight function via audits, surveillances, or inspections, as appropriate.

l l The Nuclear Oversight Department is responsible for assuring the training, i l testing, and certification of all the Millstone Power Station NU NDE personnel is in accordance with the requirements of Regulatory Guide 1.58 (Rev.1,9/80) and ASNT Recommended Practice No. SNT-TC-1 A.

9.2.3 SPECIAL PROCESS RECORDS Records provide objective evidence that special processes were performed in accordance with applicable procedures, by qualified personnel, and that when required by procedures, specifications and codes, such performance was verified. Results of nondestructive examinations are recorded in accordance with applicable specifications, codes and standards. These records are retained by the vendor or supplied to NNECO as required by contract or purchase order.

If records are to be retained by the vendor, the contract or purchase order i specifies the retention period and instruction for final disposition of records.

Special process documentation such as special process procedures, qualifying data, and personnel and equipment qualification records associated with the i performance of special processes at Station nuclear power plants, are kept current and maintained in appropriate NNECO files, with final disposition to the Station Nuclear Document Services Facility.

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. i 10 INSPECTION 10.1 GENERAL REQUIREMENTS 1 This NUQAP provides measures to assure that inspections of Mi/Istone Station nuclear power plants quality structures, systems, and components to verify conformance ,

with documentedprocedures, instructions and drawings are executed in accordance l with procedures by qualified personnel independent from the individual or group performing the activity being inspected. If inspection is impossible or disadvantageous, 1 indirect controls by monitoring processing methods, equipment and personnel are providei Ir.spection notification and hold points are identified, as required, in the ,

applicable documents.

10.2 IMPLEMENTATION l

'0.2.1

. INSPECTION RESPONSIBILITIES During the performance of quality activities for the Station nuclear power plants, procedures shall define the need for inspection (e.g., receipt inspection, ,

installation, and product acceptance) to assure quality requirements are met. I Nuclear Oversight shall perform, as appropriate, audits and surveillances j as defined in Nuclear Oversight procedures to verify that procedural j requirr;ments are met. )

i The Nuclear Oversight Department shall perform inspections of modification and maintenance activities for quality structures, systems, and components. The criteria used to determine when Nuclear Oversight l inspection shall be required for these activities and for the preparation of l l

Inspection plans shall be Identified in Nuclear Oversight procedures. The Nuclear Oversight inspection function includes I

l a. Identification of inspection personnel; )

b. Review of work procedures and work documents for adequacy of inspection and mandat3ry hold points; I

c. Preparation and approval of inspection plans assuring that the necessary inspection requirements, methods, and acceptance criteria have been identified; 1

d. Documentation of inspection results.

l Nuclear Materials and Document Management is responsible for the performance of offs /te audits, surveillances, and inspections, as appropriate,

- to verify that any vendor utilized to perform quality activities for the Station nuclear power plants are effectively complying with their quality assurance program requirements for inspection and for the performance or witnessing of QAP - 10.0 i Rev.: 19 Date:

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! inspections at hold or notification points identified in procurement documents.

l Nuclear Oversight performs audits, surveillances, and inspections, as appropriate, of onsite vendor activities in this area. All audit, surveillance, and inspection activities are performed under requirements specified in quality i procedures, l

10.2.2 INSPECTION PLANS Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans are based on design l specifications, procurement documents, drawings, other specifications, or previous experience, as appropriate.

During the pedormance of quality activities, procedures provide criteria for j the determination of accuracy requirements of inspection equipment and when inspections are required. These procedures describe requirements for the

preparation of inspection plans by the Nuclear Oversight Department. Audits and surveillances are performed by the Nuclear Oversight Department, as appropriate, to verify the implementation of the inspection plans.

1 The inspection criteria, including the use of inspection equipment and their accuracy requirements, are specified in the work procedures, work documents, orinspection plans. ,

10.2.3 INSPECTION PERSONNEL AND INSPECTION DOCUMENT ACCESS Inspections are performed by individuals other than those who performed or directly supervised the activity being inspected inspection personnel are qualified and/or certified in accorc'ance with appropriate codes, standards, and/or NU training programs; Inspections are performed by Nuclear Oversight Department personnel, qualified j contracted personnel, and NNECO personnel who are independent from undue pressure such as cost, or schedule considerations Nuclear Oversight shall assure the certification ofits contractedinspection personnelis acceptable 1 prior to the performance of Inspection activities. When other departments l are contracting for onsite quality assurance inspection services, these 1 departments shall be responsible for the review and acceptability of personnel / equipment certification prior to the start of Inspection activities Nuclear Oversight shall perform audits and surveillances, as appropriate, to verify other department compliance with these requirements When vendors are contracted to perform onsite inspection services, their quality controlinspection plans / procedures are reviewed and concurred with by Nuclear Oversight in accordance with QAP 5.0, " Procedures, Instructions, and Drawings".

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Access to drawings, procedures, specifications or other documented criteria necessary for the performance of inspections is provided prior to performing the inspection activity.

10.2.4 INSPECTION PROCEDURES Required inspection or surveillance activities are performed and documented

according to procedures and/or checklists. Inspection procedures, plans or checklists contain the following

l I a. Identification of characteristics to be inspected;

b. Identification of the individual or groups responsible for performing the inspections; l

c. Requirementsfor the necessary measuring and test equipment and the required accuracy of this equipment;

d. Acceptance criteria;

e. A description of the method of inspection when other than direct visual examination using the unaided eye;

f. A record of the results of the inspection;

g. Record of inspector or data recorder.

Procedures specify surveillance of processing methods or testing and operation of equipment when inspection is impossible, inaccessible or not applicable.

Modification, repair, replacement, or rework items are inspected are inspected in accordance with original inspection requirements or approved alternatives.

10.2.5 MANDATORY HOLD AND NOTIFICATION POINTS Mandatory hold points are utilized when an inspection or operation must be performed or witnessed and signed off by the responsible personnel before work can proceed. Mandatory hold points are identified to assure attributes critical to achieving quality requirements at work completion have been verified. Mandatory notification points are used to identify the operations or completed processes that NNECO or its representatives may elect to witness and/or inspect during the fabrication, construction and' installation process.

Mandatory hold point and notification points, as required, are identified in procurement documents and onsite work procedures / work documents.

l Procurement documents and onsite work procedures / work documents are

subject to the review and concurrence for adequacy of inspection, notification i and/or mandatory hold controls by Nuclear Materials and Document l Management and Nuclear Oversight, respectively.

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i 10.2.6 INSPECTION RESULTS EVALUATION Inspection results are evaluated for. acceptability in accordance with appIlcable procedures which identify the responsible organization.

The evaluations are performed by the personnel who are qualified in accordance with the appropriate regulatory guide and endorsed ANSI standard listed in Appendix C. ]

Nuclear Oversight performs audits and surveillances, as appropriate, to verify that inspections are performed in accordance with the requirements of applicable procedures.

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11.0 TEST CONTROL l 11.1 GENERAL REQUIREMENTS l This NUQAP requires a documented test control program for Millstone Station nuclear i power plants quality structures, systems, and components be established to assure l that they will perform satisfactorily in service and that test results are documented in l accordance with applicable regulatory and technical requirements.

i The test control program identifies the quality structures, systems, and components to be l'

tested, method of conducting tests, evaluation of tests and documentation of tests by qualified personnel to assure requirements have been satisfied.

The test control program is systematic and includes proof tests prior to installation, construction tests, operational tests, surveillance tests, and retest following repairs, reworks, replacements, preventive maintenance or modifications as required to verify performance will be satisfactory during operation.

11.2 IMPLEMENTATION 11.2.1 TEST PROGRAM Test requirements to determine or to verify the capability of an item to meet specified requirements in accordance with design documents, Safety Analysis Reports (SAR), Technical Specifications, procedures or procurement documents, as appropriate, are accomplished by subjecting the item to a set of physical, chemical, environmental or operating conditions. Retest following repair, rework, replacement, preventive maintenance or modification is performed, as required, in accordance with the original design requirements of the item or acceptable alternatives, as applicable.' Retest may also be pedormed when original test results are invalidated.

NNECO procedures delineate the methods and responsibilities for controlling, accomplishing and documenting testing of the Station nuclear power plants quality structures, systems, and components.

Vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementing measures for the control of tests to assure that materials, equipment and parts used in quality structures, systems, and components will perform satisfactorily. Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillances, and inspections, as appropriate, to verify the performance of selected proof tests when hold points have been identified in purchase l order / contracts and to verify these vendors are complying with their quality l assurance program requirements for test control. Nuclear Oversight pedorms l audits, surveillances, and inspections, as appropriate, of onsite vendor activities in this area. Nuclear Materials and Document Management and l QAP - 11.0 Rev.: 19 Date:

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l Nuclear Oversight are responsible for assuring documentation associated with

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these verification activities are maintained in the appropriate files until l forwarded to the Station Nuclear Records Facility in accordance with applicable procedures.

! Proof tests, product acceptance tests, retests, and period;c surveillance tests are conducted by qualified personnel in accordance with applicable procedures.

Personnel performing tests assure that calibrated equipment and instrumentation utilized are within the calibration interval specified. Documentation including test '

procedures and approved data sheets are maintained in appropriate files until forwarded to the Station Nuclear Records Facility in accordance with applicable procedures. i 11.2.2 TEST PROCEDURE PREPARATION AND TEST PERFORMANCE <

l Testing is accomplished in accordance with approved test procedures which l incorporate or reference the requirements and acceptance criteria in the applicable design and procurement documents. The test procedure or test program documents include the following as a minimum:

a. Instructions for the testing method used;

b. Required test equipment and instrumentation;

c. Test requirements, such as acceptance criteria;

d. Hold, notification, inspection points, if required and data collection points;

e. Test prerequisites such as: calibrated instrumentation; trained, qualified, and licensed or certified personnel; preparation, condition and completeness of item to be tested; suitable and controlled environmental conditions;

f. Methods for documenting or recording test data and results;

g. Provisions for data collection and storage 11.2.3 TEST EQUIPMENT NNECO procedures provide the criteria for determining when a test is required and the accuracy requirements of test equipment. The following steps are taken for the control of test equipment:

a. To assure accuracy, test equipment is checked and calibrated in accordancewith NNECO procedures; i

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b. Plant instrumentation used in testing is calibrated. It is maintained in l calibration at regular intervals in accordance with established surveillance and/or preventative maintenance procedures; l

c. Where specialinstrumentationis required for testing, the requirements are l stated in the procedures. Instrument characteristics, including accuracy requirements, are equivalent to or better than those specified by the vendor.

l 11.2.4 EVALUATION OF TEST RESULTS The documented test results are evaluated against the predetermined i acceptance criteria by an individual or group having appropriate qualifications. l The acceptance status of the test is documented. Deficiencies noted during the  !

evaluation are documented and dispositioned in accordance with procedures. l The evaluation of test results may also be delegated to vendors. When delegated, the vendor is required to assure the use of qualified personnel, I l

evaluate the data against predetermined criteria and docurant the results of the '

evaluation and acceptance status of the test. Nuclear Materials and Document Management is responsible for the performance of offsite audits, 1 surveillances, and inspections, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for test

[ control. Nuclear Oversight performs audits, survelliances, and Inspections, }

as appropriate, of onsite vendor activities in this area.

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l 12.0 CONTROL OF MEASURING AND TESTING EQUIPMENT l

l I l 12.1 GENERAL REQUIREMENTS This NUQAP provides measures for the control of measuring and testing equipment (M&TE) used as the basis for acceptance during inspection, testing, and measurement of

\ materials, equipment, and parts affecting quality structures, systems, and components. Periodic calibration and adjustment of M&TE is performed and controlled to I assure accuracy is maintained within limits necessary to verify that design and operating condition requirements have been met. Documentationis retained such that all items of l M&TE are traceable to their calibration records.

12.2 IMPLEMENTATION 12.2.1 CALIBRATION PROGRAM Procedures delineate the methods and responsibilities for the control, maintenance and calibration of M&TE including portable and temporarily installed instruments, tools, gages, fixtures, reference and transfer standards, and nondestructive test equipment.

Documentation associated with the calibration of all M&TE is maintained in appropriate files with eventual incorporation into the NU Nuclear Records Program. When the information for the control, use, and calibration of M&TE is in electronic form, this information is controlled and protected in accordance with applicable procedures.

The calibration program is implemented in accordance with the requirements defined in NNECO procedures which describe the measures utilized to maintain the calibration of the M&TE. Functional groups are responsible for implementing these procedures which comply with the requirements contained in specifications and drawings. Procedures related to the M&TE calibration program are reviewed and approved by the PORC/SORC or the Station Qualified Reviewer Program, as defined in applicable' procedures. Nuclear Materials and Document Management or the appropriate M&TE custodian, as delineated by the purchase order, is responsible for verifying that receipt of calibrated equipment is in conformance with the requirements of procurement documents. Nuclear Materials and Document Management and Nuclear Oversight are responsible for control of calibrated M&TE used during their inspections.

Department Heads / Job Supervisors are responsible to assure that M&TE is

calibrated, issued, and controlled in accordance with the requirements of l applicable procedures, i The Nuclear Oversight Department performs audits, surveillances, and inspections, as appropriate, to verify implementation of the calibration program.

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Vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementing measures for the control of M&TE to assure the M&TE are properly caliorated, adjusted and maintained at specified intervals in order to maintain accuracy within required limits. Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillances, and inspections, as appropriate, to verify these vendors

'are effectively complying with their quality assurance program requirements for control of M&TE. Nuclear Oversight performs audits, surveillances, and inspections, as appropriate, of onsite vendor activities in this area.

12.2.2 CAllBRATION STANDARDS Measuring and test equipment is calibrated at specified intervals based on the ]

required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement. Measuring and test equipment shall be  !

permanently marked or tagged with a unique Identification number and the i date calibrated and next calibration date Indicated on the M&TE.

1 Procedures describe the measures taken to assure that reference and transfer standards are traceable to nationally recognized standards and that, where j national standards do not exist, provisions are established to document the basis  !

for calibration.

Calibration of this equipment should be against standards that have an accuracy  !

of at least four times the required accuracy of the equipment being calibrated.

When this is not possible, the standards shall have an accuracy that assures the I equipment being calibrated shall be within required tolerance and the basis of acceptance is documented and authorized by the SORC/PORC. In addition, the calibrating standards shall have greater accuracy than secondary standards i being calibrated. Calibrating standards with the same accuracy may be used if  ;

they can be shown to be adequate for the requirements and the basis of l acceptance is documented. j 12.2.3 "OUT OF TOLERANCE" CONTROL M&TE and reference standards when found out of tolerance are so identified and removed from service. A timely review is conducted to determine the validity of previous inspection or test results gained through use of the l instrument, and of the acceptability of items previously measured or tested. i l

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i 13.0 HANDLING. STORAGE AND SHIPPING 13.1 GENERAL REQUIREMENTS i i

This NUQAP provides measures to assure proper handling, storage, shipping, cleaning and preservation of materials, equipment and parts used for Millstone Station nuclear power plant quality structures, systems, and components in order to preclude damage, loss or deterioration.

13 2 IMPLEMENTATION 13.2.1 GENERAL l

Procedures, instructions and procurement documents define the requirements and responsibilities for the handling, storage, shipping, cleaning and preservation of materials, equipment, and parts required for implementation of established design and specification requirements.

Handling, storage, shipping, cleaning and preservation of materials, equipment l and parts is conducted in accordance with applicable procedures and procurement documents. Vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementing measures for handling, storage, shipping, cleaning and preservation of materials, equipment i l

and parts to preclude damage, loss or deterioration. Nuclear Materials and l Document Management is responsible for the performance of offsite audits, surveillances, and inspections, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for handling, storage, shipping, cleaning and preservation of materials, equipment and parts. Nuclear Oversight performs audits, surveillances, and inspections, as appropriate, of onsite vendor activities in this area.

13.2.2 ESTABLISHL1ENT OF SPECIAL HANDLING. STORAGE. SHIPPING.

CLEANING AND PRESERVATION REQUIREMENTS 1

Special or additional handling, storage, shipping, cleaning and preservation I requirements are to be identified and implemented as specified in procurement '

documents and applicable procedures. These established requirements are consistent with the regulatory positions of the NRC regulatory guides and their endorsed ANSI standards listed in Appendix C, or specifications and/or vendor technical manuals, and shall be consistent with accepted industry standards.

NNECO procedures describe the measures taken for the storage of chemicals, reagents (including control of shelf life), lubricants, and other consumable I materials.

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14.0 INSPECTION. TEST AND OPERATING STATUS i

14.1 GENERAL REQUIREMENTS This NUQAP provides measures for indication, by the use of marking such as stamps, tags, labels or other suitable means, the status of tests and inspections of materials, j equipment and parts to preclude the inadvertent bypassing of inspection and test requirements during quality activities performed for the Millstone Station nuclear power plants. These measures provide for the identification of items which have satisfactorily passed required inspections and tests. Measures are also established for indicating the operating status of quality structures, systems, and components to prevent inadvertentoperation.

14.2 IMPLEMENTATION 14.2.1 GENERAL Vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementing approved measures for the identification of inspection and test status of quality material, equipment and parts to preclude the bypassing of requirements. Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillances, and inspections, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for identification of inspection and test status. Nuclear Overs /ght performs audits, surveillances, and inspections, as appropriate, of onsite vendor activities in this area. Elements of this system require that vendors have a controlled fabrication and test operation in order to preclude the inadvertent bypassing of process inspections or tests, and to provide a positive identification of component status throughout all phases of fabr/ cation, testing, and inspection by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other appropriate methods.

When receipt inspections are performed at the Station, Nuclear Materials and l Document Management assures that traceability is maintained for acceptable l quality materials, equipment and parts to indicate conformance to purchase ordericontract requirements with the exception of nuclear fuel assembIles, diesel / gas turbine fuel, and bulk hydrogen / nitrogen for Millstone Power Station Unit No. 3 for which traceability is maintained by Reactor Engineering, Chemistry, and Millstone Power Station Unit No. 3 Operations, respectively. Nonconforming materials, equipment and parts are identified in accordance with QAP 15.0, " Nonconforming Materials, Parfs, Components, or Services" During tests and inspections of the Station nuclear power plants, a status 1 tagging system is implemented by procedure to prevent inadvertent operations of quality structures, systems, and components.

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NNECO procedures describe the measures taken to control the altering of the sequence of required _ tests, inspections and other operations. The review and approval for these actions is subject to the same control as taken during the original review and approval of tests, inspections and other operations.

14.2.2 STATUS IDENTIFICATION AND CONTROL Procedures and instructions describe control of the application and removal of markings such as stamps, tags, labels, and other suitable means to indicate the status of quality structures, systems, and components to prevent inadvertent operation, and to preclude omission of inspections, tests or other critical operations. These procedures and instructions delineate the requirements, methods and responsibilities for indicating the status of the affected items. The status of all items requiring calibration is recorded and maintained In accordance with appilcable procedures.

Records associated with status identification are maintained in accordance with applicable procedures.

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15.0 NONCONFORMING MATERIALS. PARTS. COMPONENTS. OR SERVICES 15.1 GENERAL REQUIREMENTS This NUQAP requires the documentation and control of nonconforming materials, parts, components, or services be performed in accordance with procedures to prevent inadvertent use or instaliation in Millstone Station nuclear power plant quality structures, systems, or components. These procedures include requirements for' identification, documentation, segregation and disposition of nonconforming items; and notification to affected organizations.

15.2 IMPLEMENTATION 15.2.1 PROGRAM Procedures define personnel responsibilities and establish various measures for identification, documentation, segregation, review and disposition of nonconforming item reports. The means for reporting nonconforming items are available to all NU and vendor personnel assigned at the Millstone Power Station and other personnelInvolved with Station quality activities.

15.2.2 DOCUMENTATION Documentation of nonconforming items requires identification of the items, description of the nonconformance, disposition of the nonconformance, inspection requirements and signature approval of the disposition.

Tagging systems are utilized to physically identify nonconforming items prior to installation. Nuclear Materials and Document Services utilizes tags for received materials, parts and components.

15.2.3 EVALUATION AND DISPOSITION Evaluations are performed to determine the disposition of nonconforming items and services. The evaluation determines whether an item or service is to be used as is, returned to vendor, iepaired, reworked, scrapped or salvaged. An engineering evaluation is performed, if necessary, prior to the resolution of nonconformances. In addition, nonconformances are evaluated for impact on quality structure, system and component operability in accordance with appl / cable procedures. These evaluations assure that the final condition does not adversely affect safety, operation or maintenance of the item or service.

Nonconforming item reports involving deviation from design bases such as "use as is" or " repair" are forwarded to the appropriate engineering organization for review, and disposition. Applicable information is accumulated and records are maintained.

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The need to release /use nonconforming materials, parts or components shall be based on such considerations as:

a. Impact on plant safety;

b. Safety of personnel;

c. Suitability of items in the "as is" condition, i.e., probability of eventual satisfactory resolution of the nonconforming condition without repair, rework or replacement.

d. Accessibilityof items after release;

e. Cost of removal and repair or replacement should items eventually have to be removed, repaired, or replaced;

f. Effect on the orderly progress of work.

Items repaired are verified by reinspecting the items as originally inspected or by a documented method which is equivalent to the original inspection method.

Items reworked may require reinspection as defined in applicable procedures.

Nuclear Oversight performs audits and surveillances, as appropriate, to verify  !

that dispositions for reports documenting nonconforming conditions are adequate.

15.2.4 RECURRENCE CONTROL A trend analysis of nonconformances documenting program / procedural problems is performed in accordance with procedures. The trend analysis results are periodically reported to upper management, including the President and Chief Executin Officer - NU Nuclear Group, Chief Nuclear Officer Millstone Power Station, and the Vice President - Nuclear Oversight for review and assessment as part of the Station Corrective Action Program reporting as describedin QAP 16.0, Corrective Action.

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l 16.0 CORRECTIVE ACTION 1

i 16.1 , GENERAL MEQUIREMENTS l I

This NUQAP requires that an effective corrective action program be established to assure '

that conditions adverse to quality at the Millstone Power Station are promptly identified,  !

corrected, and documented in accordance with procedures. These procedures include l measures for reporting to appropriate levels of management and determining the root l cause and corrective action to preclude recurrence for conditions evaluated as significant l

} conditions adverse to quality.

1 i l 16.2 IMPLEMENTATION 16.2.1 PROGRAM l Procedures define personnel responsibilities and establish various measures for l identification, documentation, review, engineering evaluat!on, disposition and correction of conditions adverse to quality. The means to identify conditions adverse to quality are available to all NU and vendor personnel assigned to the Millstone Power Station and other personnel involved with Station quality activities.

16.2.2 CORRECTIVE ACTION AND FOLLOW-UP Procedures describe the measures taken to evaluate if conditions adverse to quality exist and to determine the need for immediate corrective action or disposition. Vice Presidents and Recovery Officers are responsible for assuring their assigned personnel and their vendors working onsite j l comply with the corrective action program and for assuring that corrective l action is adequate and properly implemented in a timely manner within

! their organization. The Nuclear Oversight Depal. ment performs audits and surveillances, as appropriate, to verify that other departments and their onsite q vendors comply with the corrective action program and that corrective action is I

adequate and properly implemented in a timely manner. The President and Chief Executive Officer- NU Nuclear Group has the final authority in the event that agreement on the action to be taken is not reached at lower levels of the nuclear organization.

i 16.2.3 RECURRENCE CONTROL l

Procedures identify responsibility and provide direction for determining appropriate significance level based on actual or potential consequences for conditions adverse to quality.

The significance level determines the need for a root cause determination and for establishing the necessary action to prevent recurrence. In these cases, the

, immediate corrective action, the cause, and recurrence control actions must be

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documented. Procedures establish the responsibilities and measures taken to accomplish these actions.

An analysis of adverse conditions is performed and trends which identify program / procedure problems are periodically reported to upper management, including the President and Chief Executive Officer. NU Nuclear Group, the Chief Nuclear Officer Millstone Power Station, and the Vice President -

Nuclear Oversight by the organization responsible for controlling the problem reporting document. Adverse trends concerning specific vendor performance shall be reported to the affected vendor for resolution and recurrence control, as appropriate.

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17.0 QUALITY ASSURANCE RECORDS 17.1 GENERAL REQUIREMENTS This NUQAP requires the maintenance, identification, retention and retrieval of records to furnish evidence of quality activities performed for the Millstone Station nuclear power plants be implementedin accordance with procedures These records include but are i not limited to: operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance and material analyses. These records also include l closely related data such as qualifications of personnel, procedures and equipment.

l inspection and test records contain, as a minimum but are not limited to: identification of

inspector or data recorder and the acceptability and the action taken in connection with any deficiencies and reportable occurrences noted. Procedures establish requirements concerning record retention such as duration, location and assigned responsibility.

17.2 IMPLEMENTATION NUSCO/NNECO procedures establish the responsibilities and requirements for the maintenance, identification, retention (e.g., duration, location) and retrievability of records pertaining to rr.aterials, equipment, parts, processes or operations relating to quality structures, systems, and components which when founded on observations, measurements or tests can be fully verified, and documented by cognizant personnel.

Vendors utilized to perform quality activities for the Station nuclear power plants are responsible to implement measuo to, identification, maintenance, retention, retrieval and turnover to NNECO of dMumented and approved records which contain objective evidence of quality as specified in purchase orders / contracts. Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillances, and inspections, as appropriate, to verify that these vendors are effectively complying with their program for quality assurance records. Nuclear Oversightperforms audits, surveillances, and inspections, as appropriate, of onsite vendor activities in this area.

NUSCOWNECO quality assurance records are identified, controlled and maintained in appropriate files and are identifiable to specific structures, systems, and components within the Station nuclear power plants. When identification to a specific structure, system, or component is not practical, records are filed by category (e.g., specification, nonconformance reports, audits, etc.).

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17.3 RETENTION NUSCO/NNECO quality assurance records are classified as life records or non-life records as delineated by Nuclear Document Services. Non-life records are those documents that are maintained for a specific period of time other than the lifetime of a Station nuclear power plant or the particular component or part. Life records are those documents that are maintained for the lifetime of the in-service nuclear power plant or for the life of the particular component or part. Life records are those which would be of significantvalue in meeting one or more of the following criteria:

a. Demonstrating capability for safe operations;

b. Maintaining, reworking, repairing, replacing or modifying the item;

c. Determiningthe cause of an accident or malfunction of an item;

d. Providing required base line data for in-service inspection.

Quality assurance records are reviewed and approved by the cognizant qualified NUSCO/NNECO personnel and vendors, as appropriate, and are transmitted to the Station Nuclear DocumentRecords Facility. The responsibilityof the Nuclear Document Services Facility upon receipt of records is to maintain and provide controlled retrievability of records affecting the Station nuclear power plants, in such a manner as to prevent destruction of records by fire, flood, theft, and environmental conditions, such as temperature or humidity, as delineated in applicable procedures.

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18.0 AUDITS 18.1 GENERAL REQUIREMENTS This NUQAP requires that a comprehensive system of planned and periodic audits shall be carried out to verify that quality activities for Millstone Station nuclear power l plants are performed in compliance with this NUQAP and to determine the l effectivenessof theprogram.

l Audits are conducted in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilitiesin the areas being audited.  :

Audit results are documented and reviewed by management having responsibility in the l area audited and the responsible management takes the necessary action to address any audit findings revealed by the audit.

18.2 IMPLEMENTATION 18.2.1 PROGRAM ,

The audit program requires audits of Corporate and Station nuclear power 1 plant quality activities under the oversight of the Nuclear Safety Assessment Board. Audits are performed on activities where the requirements of 10 CFR 50, l

Appendix B and respective nuclear unit Technical Specifications are being implemented. In addition to those activities, audits are performed on areas

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l associated with indoctrination and training programs, interface control among l NNECO and vendors, and the Nuclear Materials and Document i Management procurement function. Audits are regularly scheduled on the l basis of the status and safety importance of the activities being performed.

l Regularly scheduled audits are supplemented by audits for one or more of the l following conditions l l

l a. When significant changes are made in functional areas of the quality l assurance program, such as significant reorganization or procedure

! revisions; I

b. When it is suspected that the quality of the item is in jeopardy due to deficienciesin the quality assurance program;

c. When a systematic, independent assessment of program effectiveness is considered necessary; i

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d. When necessary to verify implementation of required corrective action.

Schedules for the audit of Corporate, Station, and onsite vendor quality activities are originated and maintained by the Nuclear Oversight Department.

Audits are performed as specified in procedures by qualified personnel, using an audit plan prepared by the auditing organization. Audits may include evaluation of the work areas, activities, processes, items, and review of documents and records to determine the effectiveness of implementation and conformance to this NUQAP.

Approved vendors utilized to perform quality activities for the Station nuclear power plants are responsible for developing and implementing a system of planned and periodic audits to verify compliance with and to determine the effectiveness of all aspects of their quality assurance program. Nuclear Materials and Document Management is responsible for verifying the acceptability of vendor audit programs and for the performance of subsequent offsite audits, as appropriate, to verify that these vendors are effectively complying with their quality assurance requirements. Nuclear Materials and Document Management has contracted this audit function to the Yankee Atomic Electric Company (YAEC). Nuclear Oversight performs audits of onsite vendors, as appropriate, to verify that these vendors are effectively complying with their quality assurance requirements.

In addition to the audits, other methods, such as surveillances and inspections are used to assure that quality activities are in compliance with this NUQAP.

18.2.2 REPORTING OF AUDIT RESULTS Audit results are reviewed, approved, and reported in accordance with Nuclear Oversight Department and Yankee Atomic Electric Company procedures, as applicable. The audit reports are issued to the appropriate management of the area audited to assure appropriate and/or timely corrective action is taken to address any audit findings. In addition, audit data and reports are accumulated as part of the review for quality trends and assessed to assure the effectiveness of this NUQAP.

18.2.3 REVIEW. ACTION AND FOLLOW-UP OF AUDIT FINDINGS Audit findings are reviewed and investigated by the management having the responsibility for the area audited. The responsible management is required to take the necessary action to address any findings identified by the audit and!

report the results of such reviews and investigations, take the necessary actions to correct problems reported, and report the completion of corrective action within specified time frames.

Follow-up of audit findings is performed by the auditing organization as necessary to verify appropriate actions have been taken to resolve audit findings.

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l l Items which cannot be resolved by affected management are submitted for l resolution to the President and Chief Executive Officer- NU Nuclear Group.

i 18.2.4 RECORDS / REPORTS OF AUDITS Audit records, reports, and associated documentation are dispositioned to the Station Nuclear Document Services Facility, as specified in applicable procedures.

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APPENDIX A NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQA_P]

TOPICAL REPORT- MILLSTONE POWER STA TION CATEGORY l STRUCTURES. SYSTEMS. AND COMPONENTS The Materials, Equipment, and Parts List (MEPL) Program provides instructions to identify structures, systems, components, parts, materials, consumables, and quality software that need to be safety-relatedand designatedas CategoryI.

The following structures, systems, and components of a Millstone Station nuclear power plant, including their foundations and supports, are designated as Category 1. The pertinent quality assurance requirements of Appendix B to 10 CFR 50 are applied, to all activities affecting the safety-related function of the structures, systems, and components as listed below and to other items and services specifically identified by NU in each FSAR addressing Section 3.2.1 of NRC Regulatory Guide 1.70.

(a) The reactor coolant pressure boundary.

(b) The reactor core and reactor vessel internals.

(c) Systems or portions of systems that are required for (1) emergency core cooling; (2) post-accident containment heat removal or; (3) post-accident containment atmosphere cleanup (e.g., hydrogen removalsystem).

(d) Systems or portions of systems that are required for (1) reactor shutdown; (2) residual heat removal or; (3) cooling the spent fuel storage pool.

(e) Those portions of the steam systems of boiling water reactors extending from the outermost containment isolation up to but not including the turbine stop valve, and connected piping of 2-1/2 inches or larger nominal pipe size up to and including the first valve that is either normally closed or capable of automatic closure during all modes of normal mactor l operation. i (f) Those portions of the steam and feedwater systems of pressurized water reactors extending from and including the secondary side of steam generators up to and including the outermost containment isolation valves, and connected piping of 2-1/2 inches or larger nominal pipe size up to and including the first valve (including a safety or relief valve) that is either normally closed or capable of automatic closure during all modes of normal reactor operation.

(g) Cooling water, component cooling and auxiliary feedwater systems or portions of these systems including the intake structures, that are required for: (1) emergency core cooling; (2) post-accident containment heat removal; {3) post-accident containment atmosphere cleanup; (4) residual heat removal from the reactor or; (5) cooling the spent fuel storage pool.

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(h) Cooling water and seal water systems or portions of these systems that are required for functioning of safety-related reactor coolant system components such as PWR reactor coolant pump seals.

(i) Systems or portions of systems that are required to supply fuel for emergency equipment.

(j) All electrical and mechanical devices and circuitry between the process and the actuated devices involved in generating or responding to signals that provide protective functions of safeguard systems.

(k) Systems or portions of systems that are required for (1) monitoring of systems safety-related and; (2) actuation of systems safety-related.

" Required for monitoring,"1.e. Those parameters that provide information that is essential to permit the control room operator to take specific manually controlled actions for the direct accomplishmentof the specifiedsafetyfunction.

(I) The spent fue! storage pool structure, including the fuel racks.

(m) The reactivity control system (e.g., control rods, control rod drives, and boron injection system). j l

(n) The control room, including its associated equipment and all equipment needed to maintain the control room with safe habitability limits for personnel and safe environmentallimits for vital equipment.

(o) Primary and secondary reactor containment.

(p) Systems other than radioactive waste management systems not covered by items (a) through (o) above which contain or may contain radioactive materials and whose postulated failure would result in conservatively calculated potential offsite doses (using meteorology as prescribed by Regulatory Guides 1.3 and 1.4) which are more than 0.5 rem to the whole body or its equivalent to any part of the body.  ;

(q) The Class IE electric systems, including the auxiliary systems for the onsite electric power supplies, that provide the emergency electric power needed for functioning of plant features included in items (a) through (p) above.

(r) Those portions of structures, systems, or components whose continued function is not required but whose failure could reduce the functioning of any plant feature included in items (a) through (q) above to an unacceptable safety level or could result in incapacitating injury to occupants of the control room should be designed and constructed so that the SSE would not cause such failures.

(s) Items and services associated with Radioactive Material Transport Packages as described in 10CFR71.

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CONSUMABLES The following specific consumables when utilized in safety-related systems shall be included in those portions of this NUQAP, as applicable.

1. Emergency generatordieselfuels

2. Hydraulic snubber fluids

3. Reagents

4. Resins

5. Boric Acid

6. Lubricants

7. Gas Turbine Fuel

8. Bulk Hydrogen (For Millstone Power Station Unit No. 3)

9. Bulk Nitrogen (For Millstone Power Station Unit No. 3) l L

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APPENDIX B l

NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP) l TOPICAL REPORT- MILLSTONE POWER STA TION l 1

QUALIFICATION AND EXPERIENCE REQUIREMENTS VICE PRESIDENT- NUCLEAR OVERSIGHT l

The Vice President- Nuclear Oversight shall satisfy the following requirements:

Graduate of a four-year accredited engineering or science college or university, plus fifteen (15) or more years of industrial experience including five years in positions of leadership, such as lead engineer, project engineer, Audit team leader, etc. At least two years of this experience should be associated with nuclear Quality Assurance Activities, and at least one year of this experienceis in a Quality Assurance Organization. A masters degree in engineering or business management is considered equivalent to two years of experience.

l Note: The education and experience requirements should not be treated as absolute when i similar training or an outstanding record provides reasonable assurance that a person can perform the required tasks.

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APPENDIX C NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)

TOPICAL REPORT- MILLSTONEPOWER STA TION REGULATORYGUIDE AND ANSI //EEESTANDARDCOMMITMENTS NOTE: This NUQAP is committed to utilize the guidance obtained from the following regulatory documents and their endorsed standards. Exceptions to these positions arelistedin AppendixEof thisTopicalReport.

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

10 CFR 50, Section 50.54, Condition of Licenses.

10 CFR 50, Part 55- Operator's Licenses and its Appendix A- Requalification Programs for Licensed Operators of Production and Utilization Facilities.

Regulatory Guide 1.8 - I-R - 5/77 - Personnel Selection and Training- Endorses ANSI N18.1 -

1971.

Regulatory Guide 1.28- 2/75- Quality Assurance Program Requirements (Design and Construction) Endorses ANSI N45.2-1977.

Regulatory Guide 1.30- (Safety Guide 30), 8-11 Quality Assurance Requirements for the Installation, inspection, and Testing of Instrumentation and Electrical Equipment - Endorses ANSI N45.2.4-1972.

Regulatory Guide 1.33 - ?/78 - Quality Assurance Program Requirements (Operation)- Endorses ANSI N18.7-1976/ANS3.2.

Regulatory Guide 1.37- Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants, 3-16 Endorses ANSI N45.2.1 1973.

Regulatory Guide 1.38- Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of items for Water-Cooled Nuclear Power Plants,5/77- Endorses ANSI N45.2.2 - 1972.

Regulatory Guide 1.39- Housekeeping Requirements for Water-Cooled Nuclear Power Plants, 9/77 - Endorses ANSI N45.2.3-1973.

Regulatory Guide 1.58- Qualification of Nuclear Power Plant inspection, Examination, and Testing Personnel, Rev.1, 9/80 - Endorses ANSI N45.2.6-1978.

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j Regulatory Guide 1.64 - Quality Assurance Requirements for the Design of Nuclear Power Plants,

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6/76 - Endorses ANSI N45.2.11-1974.

Regulatory Guide 1.70 - A Guide for the Organization and Content of Safety Analysis Reports" Revision 0, June 30,1966 was utilized for Millstone Power Station Unit No. 2; however, certain revised sections are written to the Revision 3 format. Regulatory Guide 1.70 " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants- LWR Edition" Revision 3 has been used in the update process for Millstone Power Station Unit No.1 for format and to the nearest extent practical for content. No new analyses have been performed which would be required by Revision 3. Revision 3, November 1978 is utilized for Millstone Power l Station Unit No. 3.

Regulatory Guide 1.88- Collection, Sbrage, and Maintenance of Nuclear Power Plant Quality l

Assurance Records - 10/76 Endorses ANSI N45.2.9-1974.

Regulatory Guide 1.94 - Quality Assurance Requirements for Installation, Inspection and Testing l of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plant - 4/76 - Endorses ANSI N45.2.5 - 1974 and Section 6.11 of ANSI N45.2.5-1978.

Regulatory Guide 1.116- Quality Assurance Requirements for Installation, Inspection, and Testing Mechanical Equipment and Systems - 5/77 - Endorses ANSI N45.2.8-1975.

Regulatory Guide 1.123- Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Powe r Plants - 7/77 - Endorses ANSI N45.2.13-1976.

Regulatory Guide 1.144- Auditing of Quality Assurance Programs for Nuclear Power Plants-Rev.1 - 9/80 Endorses ANSI N45.2.12 - 1977.

Regulatory Guide 1.146 - Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants - 8/80 Endorses ANSI N45.2.23-1978.

Regulatory Guide 1.152 " Criteria for Digital Computers in Safety Systems of Nuclear Power l Plants", January 1996 - Endorses IEEE ANS 7 - 4.3.2 - 1993.

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I APPENDIX D l NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM fNUQAP) l TOPICAL REPORT- MILLS TONE POWER STA TION i GLOSSARY OF QUALITY ASSURANCE TERMS

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! l Accept l As is- (also known as "Use-As-Is") A disposition which may be imposed for a l

l nonconformance when it can be established that the discrepancy will result in no adverse l

conditions and that the item under consideration will continue to meet all engineering functional requirementsincluding performance, maintainability, fit and safety. ,

ADDroved Vendors - Vendors approved to provide material, equipment, parts or services under their quality assurance program.

i As-Built Documents- Documents which accurately describe the condition actually achieved in a j l system, structure, or component. These documents include: material certification and test data; l reports of inspections, examinations, and test results; drawing, specifications, procedures, and instructions; and records of nonconformance and their resolution.

Audit- A formal, documented activity performed in accordance with written procedures or checklists to verify by evaluation of objective evidence that a quality assurance program has been j developed, documented, and implemented in accordance with applicable requirements. l Auamented Quality - Nonsafety-relateditems for which a design basis or regulatory commitment has been made. The augmented quality items are included within the scope of Quality Assurance Program. These items fall under nuclear indicators such as FPQA (Fire Protection Quality Assurance), RWQA (Radwaste Quality Assurance), ATWS (Anticipated Transient \ Vithout Scram) and SBOQA (Station Blackout Quality Assurance).

Calibration- The process by which measuring and test equipment are checked against standards of known higher accuracy and adjusted as necessary to assure their compliance with designated specifications.

Cateoorv I - Designation given to safety-relatedstructures, systems, and components (SSC) of a Northeast Utilities nuclear power plant and material, aquipment, parts, consumables, and  !

services applicable to the safety-relatedfunctions of these SSCs. l l

Cateaorv 1 Structures. Systems, and Components - Defined in each unit FSAR and functionally  ;

describedin Appendix A. l QAP - Apoendix D Rev.: 19 Date:

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Cleanina - Those actions performed to maintain an item in accordance with cleanliness

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requirements.

Commercial Grade item (CGI)- A commercialgrade item per 10CFR21is a structure, system, or component, orpart thereof that affects its safety function that was not designed and manufacturedas a basic component. Commercialgrade items do not include items where the design and manufacturingprocess require in-process inspections and verifications to assure that defects or failures to comply are identifiedand corrected (i.e.,

one or more criticalcharacteristics of the item cannot be verified).

Commercial Grade Survey - Activities conducted by the purchaser to ascertain and verify that a supplier or manufacturer of commercial grade items, controls the technical and quality characteristics determined to be critical for satisfactory performance of specifically designated commercial grade items, as a method to accept those items for safety-related use.

Condition Adverse to Quality - Failures, malfunctions, deficiencies , deviations, defective materials and equipment, and nonconfc,rmances.

Contractor- Any organization under contract for furnishing items or services.

Corrective Action - Action taken to correct an identified condition adverse to quality.

Deficiencies- Departures from specified requirements.

Department- The use of the word " Department throughout this NUQAP can refer to any portion of the NUSCO/NNECO organization (i.e., Group, Division, Department, Branch, Section, or Unit, as applicable).

Desian - The technical and management process which leads to and includes the issuance of design output documents such as drawings, specifications, and other documents defining technical requirements of structures, systems, and components.

Desian Chanaes - Changes in drawings and specifications that define the design of structures, systems, and components of nuclear power plants.

Desian Documents - The drawing, calculation, specification, or other document (s) that define the technical requirements of structures, systems, or components.

Enaineerina Service Oraanization - Organizations that provide services such as analysis, computer software, testing, and inspection.

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Handlina - An act of physically moving an item by hand or by mechanical machinery, but not including transport modes.

Identification- A means by which material, equipment and parts can be traced to their associated documentation through the use of heat numbers, lot numbers, part numbers, serial numbers, or other appropriate means.

Item - Any level of unit assembly, including structures, systems, subsystems, subassembly, l component, part, or material. l l

Inspection - A phase of quality control which, by means of examination, observation, or 1 measurement, determines the conformance of material, supplies, components, parts, appurtenances, systems, processes, structures, or services to predetermined quality requirements.

i Inspection Status - Identification of material, equipment, and parts that have completed inspection, either acceptable or unacceptable.

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Life Records - Those quality documents that are maintained for the lifetime of an in-service I nuclear power plant or for the life of the particular component or part. Life records are those l which would be of significantvalue in meating one or more of the following criteria: l (1) demonstrating capability for safe operation.

(2) r aintaining, reworking, repairing, replacing or modifying the item.

(3) determiningthe cause of an accident or malfunction of an item.

(4) providing required base line data for in-service inspection.

Material Reauest - A formal electronic request for the purchase of material, equipment, parts and/orservices.

l Measurina and Test Eauipment - Those instruments, gages, tools, fixtures, reference and transfer  ;

standards, nondestructive test equipment, and measuring devices used during inspection and testing to determine that the measuring and test parameters comply with appropriate requirementsin specifications and drawings.

Nonconformance - A deficiency in characteristic documentation or procedure which renders the quality of an item unacceptable or indeterminate.

Non-Life Records - Those quality documents that are maintained for a specific period of time other than the lifetime of the in-service nuclear power plant or the particular component or part.

Northeast Utilities (NM)- A public utility holding company wNeh owns Northeast Utilities Service Company (NUSCO) and the Northeast Nuclear Energy Company (NNECO).

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Northeast Nuclear Enerav Comnany (NNECO) - The Northeast Utilities Power Operating Company responsible for the operation of the Millstone Station nuclearpowerplants.

Northeast Utilities Service Company (NUSCO)- A wholly owned subsidiary of Northeast Utilities that provides support engineering, purchasing, and quality assurance services for the Millstone Station nuclear power plants.

Northeast Utilities Quality Assurance Proaram (NUQAP) - Millstone Power Station - Consist of this NUQAP Topical Report, Nuclear Oversight Department procedures and other NUSCO/NNECO Group /DivisiorVDepartment/ Branch'Section/ Unit quality procedures.

Nuclear Document Services - The organization responsible for establishing the Corporate Nuclear Plant Records Program which is implemented at each Nuclear Document Services Facility.

Nuclear Grade - The procurement classification applied to all materials and services intended for items listed as Category / (CAT I)I in the MEPL. These may require validating documentation such as Certificate of MaterialTest Report, Certificate of Conformance, Certificate of Compliance, .

personnel qualifications, etc., as specified by codes or standards, and have been designed / qualified for a nuclear application. Nuclear Grade items are manufactured / qualified under a 10CFR50, Appendix B program with the vendorresponsible for 10CFR21. The vendor should be an " Approved Vendof.

Nuclear Document Services Facilities (NDSF) - A facility which has been established for the purpose of handling nuclear power plant records in accordance with the Nuclear Records Program.

Obiective Evidence- Any statement of fact, information, or record, either quantitative or qualitative, pertaining to the quality of an item or service based on observation, measurements, or tests which can be verified.

Preservation- Those actions performed to maintain an item in its original and usable condition.

Procedures and Instructions - Documents that specify how an activity is to be performed. They may include methods to be employed; material, equipment, or parts to be used; and a sequence of operations.

l Procurement Documents - Purchase requisitions /materialrequests, purchase orders, contracts, i drawings, specifications or instructions used to define requirements forpurchase.

Product Acceptance Test- Activities conducted as part of the receiving or source inspection process to verify acceptabilityof one or more critical characteristics of the item being inspected.

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Purchased Material. Eauipment. and Parts (MEP)- Items procured for installation in the Millstone Station nuclear power plants quality structures, systems, and components, and items procured  ;

i as spare MEP for potentialinstallationin those structures, systems, and components. '

Purchased Services - Services provided by vendor when requested under a OA Material l Request and performed under a quality assurance program other than this NUQAP. {

(Synonymous with " Services" and " Quality Services" in this NUQAP) l l

Quality Activities- All activities affecting the safety functions of structures, systems, and i

components; these activities include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying. Quality activities also include those activities I associated with Augmented Quality (including Radwaste Packaging and Shipping) and l

otherregulatedprograms to which this NUQAPis appilcable.

Quality Assurance Records- Any record pertaining to the quality of material, equipment, parts, processes, or operations relating to structures, systems, and components which are founded on observations, measurements, or tests which can be fully checked or verified. Such statements may be recorded on a written or preprinted document or tag. The statements are authorized with a signature or stamp identifiable to the person making the statement of fact.

Quality Structures, Systems and Comoonents - Structures, systems, and components V

(SSC) including Safety-Related SSCs, Augmented Quality items, and items under other regulatedprograms to which this NUQAPis appilcable.

Quality Procedures- Those Nuclear Oversight Departmentand other department procedures which implementthe requirementsof this NUQAP.

Repair- A disposition applied to nonconforming material, equipment, and parts that are unsuitable i for their intended purpose which are modified by the use of additional operations and/or I processes so that they are suitable for their intended purpose but may not meet all specified requirements.

Recortableitem: An event or condition that could affect nuclearplant safety and must be c reported to the NRC in accordance with 10CFR50.72,10CFR50.73, or 10CFR50.9(b).

Responsible Enoineer- A NNECO employee assigned the responsibility to coordinate the  ;

engineering activities addressed in NUQAP. The responsible engineer may be designatedas the project engineer.

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Retest- A test conducted prior to operation following installation inspections of work associated with maintenance and refueling to verify that structures, systems, and components will function satisfactorily when in operation. A retest may also be performed when original test results are l invalidated.

Return to Vendor - A disposition applied to nonconforming material, equipment, and parts that are unsuitable for their intended purpose but which are feasible to repair or rework at a vendo/s facility.

l l l Rework- A disposition applied to nonconforming material, equipment, and parts that are l unsuitable for their intended purpose due to incomplete operations or variations from original l engineering requirements but which are modified through the use of additional operations or processes to meet all specified requirements.

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Safetv-Related Structures. Systems. and Components- Structures, systems and components j that prevent or mitigate the consequences of postulatedaccidents that could cause undue 1 risk to the health and safety of the public. This includes systems and components required to shut down the reactor or maintain the reactorin a safe shutdown condition. (Synonymous with

" Safety" Structures, Systems, and Componentsin this NUQAP)

Sianificant Condition Adverse to Quality - A condition adverse to quality involving actual or potential consequences that a serious impact on public or personnel health and safety or plant operations, and requiring a root cause evaluation to determine corrective action to prevent recurrence.

1 Special Processes- Processes for which the desiredlevel of quality can only be assured

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through the use of additional process controls, and where control through direct l

inspection alone is inadequate, impossible, or disadvantageous. These processes are l performed under controlled conditions in accordance with special requirements utilizing qualified  !

procedures, equipment, and personnel. Special processes may include, but are not limited to I welding, brazing, soldering, cleaning, heat treating, and nondestructive testing. I Station Blackout- The complete loss of alternating current electric power to the essential and non-essential switchgear buses in a nuclear power plant as definodin 10CFR50.2 It involves the loss of offsite power concurrent with turbine trip and failure of the onsite emergency ac power system, but not the loss of available ac power to buses fed by Station batteries through inverters l or the loss of power from alternate ac sources.

Storace- The act of holding an item at the site in an area other than its permanent location in a plant.

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Surveillance- A documented record of the observation of work operations performed at the Millstone Power Station or vendor's site to assure compliance with applicable codes, standards, specifications, procedures, drawings, and procurement documents. Surveillances may be performed with a preplanned checklist.

Test and Operatina Statu_s-Identificationof material, equipment, and parts that are ready for test  !

or operation, or an existing stage of a test operation.

Testina The determination or verification of the capability of an item to meet specified I requirements by subjecting the item to a set of physical, chemical, environmental, or operating I conditions, j

Vendors- Organizations that provide material, equipment, parts, computer software, or  !

services. This includes contractors, engineering service organizations, and consultants. J (Synonymous with " Supplier" in this NUQAP) l l

Work Procedures and Work Documents- Procedures, instructions,and documents used to l control and document maintenance and modification work performed on Millstone Station j nuclear plant structures, systems, and components. j i

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APPENDlX E NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)

TOPICAL REPORT- MILLSTONEPOWER STA TION PROGRAM EXCEPTIONS

1. ANSI N45.2.9. states in part, " structure, doors, frames, and hardware should be Class A fire-related with a recommended four-hour minimum rating." The three record storage vaults at NNECO have a two-hour rating.

NNECO's vaults are used for storage of documentation that is unsuitable for filming or awaiting filming.

A records organization exists along with written procedures addressing the control of quality assurance records.

2. ANSI N18.7-1976. paragraph 4.3.2.3 " Quorum" states in part: "A quorum for formal meetings of the (Independent Review) Committee held under the provisions of 4.3.2.2 shall consist of not less than a majority of the principals, or duly appointed alternates..."

A quorum of the Nuclear Safety Assessment Board shall consist of the Chairman or Vice Chairman and at least enough members to constitute a majority of the assigned members.

No more than a minority of the quorum shall have line responsibilityfor operation of one of Northeast Utilities' nuclear units. No more than two alternates shall be appointed voting status at any meeting in fulfillment of the quorum requirements.

3. ANSI N45.2.9-1974. paragraph 1.4, definition of " Quality Assurance Records" states in part: "For the purposes of this standard, a document is considered a quality assurance record when the document has been completed."

Northeast Utilities has developed the following alternative definition to provide guidance during the interim period from the time a document is completed until it is transmitted to the Nuclear Document Services Facility:

"A record is considered a working document until it is transmitted to the Nuclear Document Services Facility (NDSF) at which time it is designated as a Quality Assurance Record.

The following maximum time limits are established for the transmittal of working documents to the NDSF:

Operations Documents - Documentation generated during plant operations may be rnaintained, as needed, by operating plant department s, for up to one year.

New Construction or Betterment Documents - Documents which evolve during new construction or betterment projects shall be transmitted to NDSF within 90 days of QAP - Appendix E Rev.: 19 Date:

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completion of a new construction project or turnover of a betterment project or l plant operations.

i Procurement Documents - Inspection / Surveillance / Audit Reports generated during l vendor oversight activities which are used to maintain vendor status for current and future procurements may be maintained, as needed, by Nuclear Materials and l Document Management for up to three years.

All Other Workina Documents - All other working documents shall be transmitted to NDSF within 6 months of their receipt or completion."

The requirements of ANSI N45.2.9-1974 do not apply to these " working documents" based on paragraph 1.1 of the ANSI standard which states:

"It (ANSI N45.2.9)is not intended to cover the preparation of the records nor to include working documents not yet designated as Quality Assurance Records."

4. Reaulatory Guide 1.64 - 6/76. the Regulatory position states, in part, "It should not be l construed that such verification constitutes the required independent design verification." I Northeast Utilities has developed the following alternative to allow for adequate l independentdesign verification:

This review may be performed by the originator's Supervisor, only if the Supervisor:

Did not specify a singular design approach; l l

Did not establish the design inputs or did not rule out certain Design l considerations; ls the only individualin the organization competent to perform the review.

Where the Supervisor performs the design review, the next level of management shall fulfill the Supervisor's responsibilities.

5. ANSI N45.2.13 - 1976. paragraph 10.3.4, states in part, " Post-Installation Test requirements and acceptance documentation (should) shall be mutually established by the purchaser and supplier." Involvement by the supplierin establishing Post-InstallationTest requirements and acceptance documentation is requested only when it is deemed necessary and proper by the responsible engineering organization.

Northeast Utilities no longer has any nuclear plants under construction. As a result, most procurements are made for spare parts from suppliers who are not the original equipment

manufacturer. In these cases, the supplier may have little or no understanding or l knowledge of either the operation of the system the component is to be installed in, or i applicable Post-InstallationTest requirements and acceptance documentation. As such, QAP - Appendix E Rev.

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Northeast Utilities assumes responsibility for establishing Post Installation Test requirements and acceptance documentation.

6. ANSI N45.2.2-1972. paragraph 1.2, states in part that, "The requirements of this standard apply to the work of any individual or organization that participates in the packaging, shipping, receiving, storage, and handling of items to be incorporated into nuclear power plants."

Since a portion of Northeast Utilities procurement activities involve commercial suppliers which do not fully comply with the requirements of ANSI N45.2.2, the Northeast Nuclear Energy Company Nuclear Materials and Document Management organization verifies through source inspections, receipt inspection, and/or survey activities that the quality of the materials,' items, components or equipment is preserved by those suppliers to the extent that packaging, shipping, storage and handling methods are employed which are commensuratewith the nature of the product.

7. ANSI N18.1-1971. paragraph 4.2.2, states in part "The Operations Manager shall hold a Senior Reactor Operator's license" NU has developed an alternative to this requirement which has been accepted by the NRC via amendment 132 for the Millstone Power Station Unit No. 3 license which allows that:

If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No. 3, then the Operations Managershall have held a Senior Reactor Operator license at a pressurized water reactor, and the Assistant Operations Managershall hold a Senior Reactor OperatorIlcense for Millstone Unit No. 3.

8. ANSI N18.1-1971, paragraph 4.2.2, states in part "The Operations Manager shall hold a Senior Reactor Operator's license". NU has developed an alternative to this requirement which has been accepted by the NRC via amendment 190 for the Millstone Power Station Unit No. 2 license which allows that:

If the Operations Manager does not hold a Senior Reactor Operator Ilcense for MIIIstone Unit No. 2, then the Operations Managershall have held a Senior Reactor Operator license at a pressurized water reactor, and an Individual serving in the capacity of the Assistant Operations Manager shall hold a Senior Reactor Operator license for Mi!Istone Unit No. 2.

9. Reaulatory Guide 1.33 - 2/78. regarding audits, states in part:

(a)"The results of actions taken to correct deficiencies..at least once per 6 months."

(b) " .. technical specifications and applicable license conditions - at least once per 12 months."

t (c) "The performance, training, and qualifications of the facility staff- at least once per 12 l months."

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NU has developed an alternative which modifies these Audit frequencies to at least once per 24 months. This alternative has previously been accepted by the NRC via license amendments 79,184, and 104 for MP1, MP2, and MP3, respectively.

10. ANSI N18.1-1971, paragraph 4.2.2, states in part "The Operations Manager shall hold a Senior Reactor Operator's license." NU has developed an alternative to this l requirement which has been accepted by the NRC via amendment 83 for the Millstone Power Station Unit No.1 license which allows that:

If the Operations Manager does not hold a Senior Reactor Operator license for l Millstone Unit No.1, then the Operations Managershall have held a Senior Reactor i Operator license at a boiling water reactor, and the Assistant Operations Manager 1 shall hold a Senior Reactor OperatorIlcense for Millstone Unit No.1.

11. ANSI N45.2.13-1976, paragraph 10.3.5., states in part, "in certain cases involving procurement of services only, such as third party inspection; engineering and consulting services, and installation, repair, overhaul or maintenance work; the 1 Purchasermay accept the service by any or all of the following methods:

(a) Technicalverification of the data produced (b) Surveillanceand/oraudit of the activity (c) Review of the objective evidence for conformance to the procurement document requirements such as certifications, stress reports, etc." \

l in order to maintain the independence requirement of the NRC's August 13,1996 Order, NNECO will not perform an acceptance review of the work produced by the vendors contracted to conduct the Independent Corrective Action Verification Program. This work will be performed in accordance with the vendor's own approved,10 CFR 50 Appendix B Quality Assurance Program.

12. ANSIN45.2.31973, Subsection 2.1 requires the estabIlshmentof five housekeeping zones. NU has developed an alternative to this requirement which establishes for the Millstone Station nuclear power plants, as a minimum, a two zone program to which ANSI Zones I through V requirements shall be applied as indicated below:

ANSI Zone I requirements are not applicable to Millstone Station nuclear power plant operations and are therefore not appIled; Millstone Station nuclear power plant foreign material exclusion (FME) procedures include provisions for implementing controls and countermeasures that meet or exceed the ANSI Zone II, Ill, IV, and V requirements with the exception that work planning and the job supervisor shall determine when the ANSI Zones II and III logging requirements for material and personnel accountability and clothing (i.e.,

gloves, shoe and head covering) are applied based upon retrievability and final inspection of the workperformed.

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13. Regulatory Guide 1.70 Revision 3, November 1978 Section 17.1.2.4 states in part:

"The PSAR shouldinclude a listing of QA program procedures or instructions that will be used to implement the QA program for each major activity such as design, procurement, construction, etc. The procedure list shouldidentify which criteria of Appendix B to 10 CFR 50 are implementedby each procedure".

NU has developed an alternative to this requirement where procedure indices are maintained which identify the procedures that implement the Quality Assurance Program for MIIIstone Power Station and which, by title and originating l organization, Indicate the Appendix B to 10 CFR 50 criterion being implemented.

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