ML20148M101

Rev 4 to QA Program for Operation

ML20148M101
Person / Time
Site:	Cooper
Issue date:	03/28/1988
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20148M100	List: ML20148M101
References
NUDOCS 8804050330
Download: ML20148M101 (85)

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Attachment "B" C 3 NEBRASKA PUBLIC PCUER DISTRICT COOPER NUCLEAR STATION OUALITY ASSURANCE PRCCRAM FOR OPERATION POLICY DOCUMENT TABLE OF CONTENTS Corperate Policy Statement . . . . . . . . . . . v 1.0 FROGRAM DEFINITION . . . . . . . . . . . . . . . . 1-1 1.1 Purpose . . . . . . . . . . . . . . . . . 11 1.2 Policy . . . . . . . . . . . . . . . . . . . . 12 1.3 Objectives . . . . . . . . . . . . . . . . . . . . 14 1.4 Scope . . . . . . . . . . . . . . . . . . . . . . . . 1-6 1.5 Definition of Terms . . . . . . . . . . . . . . . . . 17 i

2.0 SU! CMP.Y DESCRIPTION . . . . . . . . . . . . . . . . . . 2-1 2.1 Organi:ation . . . . . . . . . . . 21 2.2 Quality Assurcece Prograis . . . . . . 22 2.3 Design Control . . . . . . . . . . . . . . 25 i

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1 8804050330 880329 PDR ADOCK 05000293 1

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2.4 Procurement Document Control . . . . . . . . . . . . . 2 12 2.5 Instructions, Procedures & Drawings . . . . . . . . . . 2 14 2.6 Document Control . . . . . . . . . . 2 15 2.7 Control of Purchased Material, Equipment, and Services . . . . . . . . . . . . . . . . . . 2 16 2.8 Identification and Control of Parts, Materials, and Components . . . . . . . . . 2 18 2,9 Ccntrol of Special Processes . . . . . . . . 2 19 2.10 Inspection . . . . . . . 2-19 2.11 Test Control . . . . . . . . . . . . . . . . . . . 2 21 2.12 Control of Measuring and Test Equipment . . . . . . 2 22 2.13 Handling, Storage, and Shipping . . . . . . . . . 2 23 2.14 Inspection, Testing, and Operating Status . . . 2 25 2.15 Nonconforming Materials, Parts, or Components . . . . . 2 26 2.16 Corrective Action . . . . . . . . . . . . . . 2 29 2.17 Quality Assurance Records . . . . . . . . . . . . 2 30 2.18 Audits . . . . . . . . . . 2 31 2.19 Additional ANSI Standards. . . . . . . . . 2 33 3.0 CRCANIZATION AND RESPONSIBILITIES . . . . 31 3.1 General . . . . . . . . . . . . 31 3.2 Nuclear Power Group Management . . . 3-2 11 Revision 4

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3.2.1 Vice President - Power Production . . . . . 32 3.2.2 Nuclear Power Group Manager . . . . . . . . 32 3.2.3 Division Manager, Quality Assurance . . . . 33 3.2.4 Quality Assurance Manager CNS , . . . , 3-5 3.2.5 Quality Assurance Supervisor - G.O. . . . . . 36 3.2.6 Quality Assurance Supervisors - CNS. . . . . . . . 38 3.2.7 Quality Assurance Staff. . . . . . . . . 38 3.2.8 Division Manager Nuclear Engineering and Construction . . . . 3 10 5 3.2.9 Division Manager Nuclear Operations . . . . . . . . . . . . . 3-11 3.2.10 Division Manager - Nuclear Support . . . . . . 3 11 3.2.11 G.O. Department Managers . . . . . . . . . . 3-12 3.2.12 CNS Department Managers. . . . . . . . 3 12 s

3.3 Cooper Nuclear Station Personnel . . . . . . . , . . . . 3 12 3.4 G.O. Personnel . . . . . . . . . . . . . . 3-13 3.5 Safety Review and Audit Board (SRAB) . . . . . . . 3-13 3.6 Station Operations Review Committee (SCRC) . . . . 3-13 3.7 Outside Suppliers, Contractors, Subcontractors, i l

and Consultants . . . . . . . . . . . . . . . . . 3-14 i i

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4.0 QUALITY ASSURANCE DOCUMENTS . . . . . . . . . . . . 4-1 4.1 NPPD Internal Documents . . . . . . . . . . . . 4-1 4.1.1 Quality Control Inspection . . . . 4-2 4.1.2 Quality Assurance Instructions (QAI) . . . . 44 4.1.3 Quality Assurance Plans (QAP) . . 4-4 5.0 METHOD OF IMPLEMENTATION . . . . . . . . . . . . . . . . 51 6.0 RECORDS RETENTION AND DISPOSITION . . . . . 61

7.0 REFERENCES

. . . . . . . . . . . . . . . . . . . . 71 3.0 FICL*RES . . . . . . . . . . 8-1 1

8.1 Quality Assurance organi:ational Chart (Figure 1) . . . 8-1 8.2 Nuclear Power Croup Organizational Chart (Figure 2) . . . 82 l

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TABLE OF CONTENTS (Cont'd.)

9.0 TABLES . . . . . . . . . . . . . . . . . . . . . . . . 9-1 9.1 Systems and Cornponents k'ithia Scope of the CNS QA Program (Table 1) . . . . . . . . . 91 9.2 Three Level QA Program (Table 2) , , . . . . . . . . . . . . 9-4 I

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• s CORPORATE POLICY STATEMENT This document establishes and describes the policies and practices of the Quality Assurance Program applicable to the operation of the Cooper Nuclear Station and the support activities of all NPPD Nuclear Divisions. The District's policy with respect to nuclear safety and quality assuranca is detailed in Section 1.2 of this document.

Each Nuclear T.tvision is responsible for the development of policies and procedures which implement this Quality Assurance Program. Other divisions and departments at NPPD may also have responsibilities under this program and shall comply as described in appropriate implementing procedures.

The Quality Assurance Division and established Safety Committees shall monitor the District's nuclear program and provide management with evaluations and assessments regarding the effectiveness of the implementation of the program.

'.then evaluations and assessments identify a concern, management shall take expeditious action to correct any undesirable condition (s) including, where appropriate, action to preclude repetition of such condition (s).

District personnel shall have the organitational freedom to identify l

concerns and propose corrective and preventive action necessary to enhance the l l

District's nuclear program.

The assurance of safe and reliable operation of Cooper Nuclear Station is everyone's duty. Quality shall be everyone's responsibility.

APPROVED:

M b u.M W / I/d _

tresident '

Nuclear Power Group Manager

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Viie 'Pregdsnt - Power Production g ivision Manager - Quality Assurance vi Revision 4 l

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s COOPER NUCLEAR STATION QUALITY ASSURANCE PROGRAM FCR OPERATION POLICY DOCUMENT 1.0 PROGRAM DEFINITION In accordance with the conditions of the Nuclear Regulatory Commission construction permit and operating license for the Cooper Nuclear Station, the management of Nebraska Public Power District recognizes its responsibility for assuring that the Cooper Nuclear Station is designed, constructed, and opera'ted in'such a manner as to provide for the safety of the public. The importance of Quality Assurance in contributing to this safety as well as contributing to station reliability is also recognized.

The initial phases of the overall Quality Assurance Program, implemented during design and construction, provided an independent check for the work performed on components, structures, and systems of the station to assure that the design, analysis, materials of construction, manufacture, installation, erection, and construction met quality standards required to assure reliable and safe operation. The CNS Quality Assurance Program for Operation, as described herein, is implemented to provide an independent quality check on all phases of station operation.

l 1.1 Purpose The purpose of this policy document is to provide a description of the Quality Assurance Program to be followed during Cooper Nuclear Station 1-1 Revision 4

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• operational phase and to provide guidelines for implementation of the policies and procedures described herein. This CNS Quality Assurance Program for Operation was developed by Nebraska Public Power District in response to the requirements of 10CFR50, Appendix B. This policy document provides a general description of the Quality Assurance Program for Operation and requires that detailed Quality Assurance Documents be set forth in writing and carried out by each of the responsible organitations or individuals within the District.

1.2 Poliev It is the policy of Nebraska Public Power District (NPPD) to use its best efforts to assure that the Cooper Nuclear Station is designed, constructed, maintained, and operated in a manner that will provide the highest practical degree of safety and reliability. Structures, components, and systems are designed. fabricated, and erected to quality standards appropriate to their importance in the safety function. The Quality Assurance Documents will identify those structures, systems, and components to be covered by the Quality Assurance Program in order to provide continuing compliance with these standards throughout the operating life of the station. Additionally, it is the policy of NPPD that activities affecting quality shall be documented by approved instructions, procedures, or drawings and such activities shall be implemented as documented.

And further, such documentation shall contain adequate qualitative and/or quantitative acceptance criteria to provide a measure of accomplishment.

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• regard to assurance of quality in all phases of station operation, it is the policy of Nebraska Public Power District (NPPD) to staff the plant with properly trained personnel in all responsible positions and j ob assignaents .

Sufficient rumbers of licensed and senior licensed operating per onnel will be 12 Revision 4

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available to assure proper operation of the station under all reasonably foreseeable circumstances of personnel turnover, vacations, disability, and the like.

All District personnel responsible for operating, maintaining, or designing safety related systems and equipment shall receive formal instruction in Quality Assurance, including basic principles, 10CFR50, Appendix B, the contents of this policy document, and Quality Assurance Documents as applicable.

Trained technical, engineering, and Quality Assurance Personnel shall be assigned surveillance and audit tasks to ensure compliance with the requirements of the documents which control station operation, such as the NRC license, Safety Analysis Report. Technical Specifications, Operating Manual, QA Program for Operation, and other such controlling documents. Personnel assignnents shall be made by the normal line organization management and will be verified by the QA Division. However, during the time personnel are performing QA functions, they shall be responsible to the QA Division to effect the organi:ational independence required by the QA Program.

It is the policy of Nebraska Public Power District to maintain quality standards for the entire station which will ensure the high degree of reliability and safety needed to meet the overall objectives of supplying dependable electric service to its customers.  ;

l The CNS QA Program for Plant Operations will utilize the guidance provided by NRC publications VASH 1283 (5-24 74), VASH 1284 (10 26 73), and WASH 1309 (5 10 74) ("rainbow" series) except where specific exceptions and clarifications are noted within this document.

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l In sumary, NPPD is committed to the continuous development of a Quality Assurance Program which will meet the requirements of 10CFR50, Appendix S, Quality Assurance Criteria for Nuclear Power Plants, and other applicable regulations as may be promulgated by the Nuclear Regulatory Com; tis s ion. This commitment applies to all NPPD organi:ations to assure that a high standard of quality will be maintained during nuclear plant operation.

Section 2 of this document presents a sumary discussion of the QA Program as applicable to the 18 criteria of 10CFR50, Appendix B, 1.3 Objectives In accordance with the policy statements above, the overall objective of the CNS Quality Assurance Program for Operation, as defined in Quality j Assurance Instructions (QAI's) and Quality Assurance Plans (QAP's), is to set forth the Quality Assurance organi:stional structure and personnel responsibilities and to set forth guidelines for the preparation of written l procedures and controls necessary for qualicy surveillance and auditing to verify the following:

a) Regulatory criteria, codes and standards, and design bases for safety-related systems (as defined in the CNS QA Pro. ram) are incorporated into the test, operating and maintenance procedures and instructions to meet all l requirements for nuclear safety and station reliability; b) Results of all preoperational and operational tests of

! safety related systems and components conform to the requirements of the drawin5s, specifications, procedures, and instructions , and appropriate reports are prepared to docu=ent that all results of tests me.et prescribed acceptance criteria; l4 Revision 4

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c) Nuclear Fuel is purchased, designed, manufactured, inspected, ,

packaged, shipped, received, installed, and operated in the reactor in accordance with approved procedures and instructions, and in compliance with regulatory requirements and license stipulations, d) The Station is operated, maintained, tested, refueled, repaired, and modified, in accordance with approved procedures and instructions, and in co=pliance with regulatory requirements and 1! cense stipulations and consistent with quality standards equal to or better than those in effect during design and construction; e) A system is set up and maintained to control, safeguard, and permit ready retrieval of quality related doew.entation generated for materials and components during the design, fabrication, construction, and operation of CSS, f) Appropriate and complete reports, records, and logs are initiated and maintained so as to provide a continuing record of quality related activities associated with station safety and reliability throughout the life of the station.

g) The station personnel are subjected to periodic training, retraining, requalification, and examination such as to maintain and improve their job skills which are essential to safe and reliable operation of the station; l

h) Station security and nuclear fuel accountability and safeguards are maintained in accordance with approved procedures and instructions.

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i i) Nonconformance reports are to be properly resolved and filed in the quality related record files.

j) Inspection reports issued by NRC are properly resolved and 4

documented. '

k) Spent fuel shipment activities are to be accomplished in accordance with regulatory requirements (10CTR Part 71).

1.4 Scope The QA Program for Operation applies to those nuclear station structures, systems, and components that are designed to prevent or mitigate the consequences of postulated accidents which could cause undue risk to the health ,

t and safety of the public, and to other selected systems as defined in implementing QA Plans. The requirements of this program apply to all activities which affect the safety-related functions of those structures, systems, and components, including designing, purchasing, fabricating, handling, shippin5, storing, cleaning, erecting, installing, inspecting, testing, operating, i

maintaining, repairing, refueling, in-service inspection, and modifying. '

This program specifically applies to, but is not necessarily limited to the nuclear ft.el, the reactor coolant system and its auxiliaries and controls, l

the reactor protection and engineered safety systems, the reactor containment system, portions of the radioactive waste disposal system, and other systems and i ,

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components required for safe, efficient, and reliable operation of the plant. A tabulation of those structures, systems, and components which are covered by the QA Program is given in Table 1.

The Quality Assurance activities governing those structures, systems, and components shall be performed as described It' tha Quality Assurance Plans (QAP's) of Section 4.1.3.

The Quality Assurance Criteria la 10CFRJJ, Appendix h, are oriented primarily toward engineering, manufacturir,, and construction activities.

Therefore, it is necessary to defit.e, 'of ipecific Quality Assurance Gncumente.

the manner in which the NRC Quality AssurJ,nte Criteria are to be a'pplied to tl.e station operating activities. a uch ^uality Asse.ance Documents shall be prepared in accordance with the reoutrements specif'11 in Sectiobs 2.0 and 4,0 of this policy document.

The Specificatl>ns, principles, and proced.:tes which controlled the original procurement, fabrication, and esnatuuction h ne been carried over into the QA aspects of station op i.aston to the gisatest extent practicable. It is the intent of NPPD management to maintain, as a aintm3), tbs quility level achieved in the original design and construction.

1.5 De finition of Terms Key words and phrases which are used to characterizs this QA Program are definad in a Quality Assurance Instruction to establish a b. sis for u.,1 form 1

and consistent interpretation of the Quality Aesnru,ee rey'iremeri:s and La j l

provide some insight into the intent of these requirements. DJfiaitions of these j l

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terms are based upon documents and standards issued by the American National Standards Institute (ANSI), by the NRC Safety and Regulatory Guides, and by the several professional societies involved in standards work (ANS, AS.ME , IEEE, et al.); or shall be defined on the basis of contemporary usage in the nuclear power industry; or shall be defined specifically to convey the intent of this particular program. Specific to the related ANSI Standard for this subject, the following commitment applies:

1. ANSI N45.2.10 1973 "Quality Assurance Terms and Definitions," and the associated Regulatory Guide 1.74, are applicable to the CNS Operational QA Program, with the following clarification:

i There may be instances where existing procedures contain definition that may not be in strict accordance with those provided by this standard. As existing procedures are revised, however, such definitions shall be evaluated to assure that all definitions meet those provided by this standard.

To facilitate review and understanding of this policy document, the following basic terms are defined below along with appropriate QA Program

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Design Change l

A design change is considered to be any change to a component, squipsnt, or structure that chs.1ges .he design criteria or margin of safety for a cysne or component which coud 1 pact nuclear safety, equipment and system intepity, or personnel safety.

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(See definition for "safety related.")

Quality Assurance All those planned and systematic actions performed for the purpose of establishing a high level of confidence that:

a) k'ork performed on the project conforms with the requirements of the applicable codes, standards, license stipulations, safety analyses, design drawings, specifications, procedures, and instructions; and b) A structure, system, or component will perform satisfactorily in s e rvic e ,

c) Appropriate records, documentation and/or drawings are maintained to show compliance with a) and b) above, 4

Quality Assurance Documents l Those documents inclusive of the QA Policy Document. QA Plans, QA Instructions, Procedures (and associated dats sheets), logs, etc., which have been approved for use, and whose intended function is to provide direction, verification, or documentation for activities affecting quality.

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Quality Assurance Instructions L

Quality Assurance Instructions shall provide guidelines for ,

surveillance and audit activities of functional areas to be performed by the i QA Staff. In addition, they shall define the responsibilities for implementation of the QA Program in accordance with policies and practices herein defitted.

Quality Assurance Plans Quality Assurance Plans are those documents specifically designed to provide detailed quality requirements for a given funce.ional area. The plans are generated by applying the 18 criteria of 10CFR50, Appendix B, to each functional area and then deriving the specific quality requirements for that area.

Quality Assurance Records Those quality-related records (see Reference 7.10) which have been completed and furnish documentary evidence of the quality of items and/or activities affecting quality.

A document becomes a Quality Assurance Record when it is dedicated, This dedication occurs when the activity related to the document becomes part of l the operating condition of the plant.

Quality control 1

I Those activities which deal directly with the measurement, observation, I

or verification of physical characteristics of materials, components, or systems  !

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which provide a basis for controlling quality to within predetermined limits, or requirements, specifically including adequate quantitative and/or qualitative j acceptance criteria by which an activity can be measured, i

l Safetv Related All activities which affset structures, systems, or components that l

prevent or mitigate the consequences of postrelated accidents that could cause 4

undue risk to the health and safety of the public.

Significant Conditions Adverse To Quality l

Any conditions that could affect safety related structures, systems, or l

j components ability to functi- witnin design requirements or alter performance i characteristics.

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Supplier Evaluation  ;

i Those activities which determine the effectiveness of implementation of '

I the supplier's Quality Assurance Program. A variety of methods may be used to

perform a supplier evaluation and are described in QA Instructions.  !

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I 2.0 StlMMA4tY DESCRIPTION i

! This section defines NPPD commitment to meet the requirements of the 18 criteria of 10CTR50, Appendix B, as it applies to safety related structures, 1  !

j systems, and components associated with Cooper Nuclear Station. In addition, it

includes NPPD interpretation of the 18 criteria as they apply to an operating l

nuclear power plant.

4 In addition to describing commitments to 10CFR50, Appendix B, this Section also identifies NPPD's commitment to selected ANSI Standards and their l associated Regulatory Guides.

2.1 Organization .

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)t The President and Chief Executive Officer (C.E.O.) (Figure 1) represents the highest level of management for establishment of Quality Assurance policies, goals, and objectives. The responsibility and authority for nuclear l facility and Ceneral Office support activities (including QA) has been delegated '

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) to the Nuclear Power Croup Manager through the Vice President - Power Production.

1 This authority includes the right to direct, enforce, and perform any action i required to ensure all activities conducted at Cooper Nuclear Station are in 3

compliance with 10CTR50, Appendix B. In addition, the personnel assigned to the Quality Assurance Division shall have complete independence to perform audits, inspections, verifications and shall be independent of those groups performing, designing, purchasing, fabricating, shipping, storing, cleaning, erecting.

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l installing, inspecting, testing, operating, maintaining, repairing, refueling,  !

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L in service inspecting, and modifying. Figure 1 of this document outlines the QA Division functional organi:ation, Quality Assurance Personnel shall have j sufficient authority and organizational freedom to:

(1) Identify quality problems; i

(2) Initiate, recommend, or provide solutions for conditions adverse to quality; (3) Verify implementation of solutions.

2.2 Quality Assurance Program i

The program shall be implemented in accordance with written, approved  ;

Quality Assurance Plans and the guidelines developed by the Quality Assurance

, Division. The District's QA Program vill comply with the Quality Assurance

Cuidelines contained in the Grange Book VASH, 1284- 10 26 73. Design Control.

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I Procurement Control, Quality Control, and Quality Assurance activities associated

) with plant modifications will similarly conform to the guidances provided within i

the Cray Book - VASH, 1283- Rev. -1 and the Creen Book VASH,1309- 5-10 74 l

Procedures will be prepared for each important activity of station operation which will clearly define the work to be performed on a step-by step basis and i

4 vill identify, where appropriate, the results to be achieved. Mandatory QC or i

QA Inspections or Tests will be performed on an independent Fasis to verify that procedures are being followed (corre:t results obtained) and vill be incorporated 4

into the work procedures directly or by attachment. QA Audit activities vill accomplish the function of verifying that the Quality Control Program is in i effect and that QC activities are being carried out as prescribed.

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Specific to the related ANSI Standards for this criterion, the l following commitments apply:  !

1. ANSI N18.1 1971 "Selection and Training of Nuclear Power Plant Personnel," shall provide guidance for selecting and training of personnel for the Nuclear Power Group.

2. ANSI N18,7 1972 "American National Standard for Administrative Controls for Nuclear Power Plants," and the associated Re$ulatory Guide 1.33, ,

apply to the CNS Operational QA Program with the same exceptions as those taken in other sections of this Policy Document to ANSI N45.213,

3. ANSI N45.2-1977 "Quality Assurance Program Requirements for i Nuclear Facilities," and associated Regulatory Guides 1,28 and 1.33, shall apply to the CNS Operational QA Program, with the following exceptions:

(a) ktore codes or standards are referenced, or are incorporated into this standard by reference, which are in conflict with original design commitments as set forth in the USAR, the USAR commitments shall govern. 1.a t e r '

revisions of applicable codes and standards may be specifically invoked by the design requirements where deemed appropriate, consistent with the overall com=irment to maintain the plant in an "equal to or better than original"  !

condition.

(b) klare Section 11 "Inspection" identifies the reporting relationship between the inspector and the "immediate supervisors who are l

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responsible for the work being inspected," the CNS QC Program only requires that

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the individual performing the verification function shall not perform or directly supervise the work being inspected. '

i l Table 1 lists structures, systems, and major cornponents associated with I

l Cooper Nuclear Station to be covered by this program. The Nuclear Operations and  ;

i "uclear Engineering and Construction Divisions, with the assistance of the  :

QA Division, will identify essential structures, systems, and components to be included within the scope of the QA Program. The Quality Assurance Program is designed to provide control over all activities affecting quality of essential i j items to a degree consistent with their safety related importance. These activities will be governed by approved plans and instructions and these documents shall be followed under controlled conditions. The Quality Assurance '

Plans and Instructions will be reviewed periodically to assure that the requirements of the prograra are being met and new requirements are being incorporatad, In addition to essential structures, systems, and components, y applicable portions of this program shall be applied to selected nonessential 1^

structures, systems, and components important to station reliability and i I

perfor=ance. Specific application will be identified in dedicated Quality Assurance Plans, i

l Special process controls, test equipment, tools, skills (training, if required) shall be used during the conduct of inspection, verification and

j. checking activities to assute a high standard of quality and reliability has been i

obtained on safety related items covered by the Quality Assurance Program. Test l 4

equipment and special tools will be calibrated against a specified secondary l standard.

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Experienced designated individuals (which may include personnel from other divisions of the Nuclear Power Group (Np0), and/or outside qualified individuals) may be requested to assist in performing audits and inspections of certain CNS quality related activities at the direction of the Division Manager of Quality Assurance. During these assignments, these individuals will have

l. sufficient organizational freedom to identify and recommend entractions for i

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quality deficiencies noted.

The Nuclear Training Department, in addition to QA Staff personnel, provides QA indoctrination and on.the. job training for NPG employees as described in nuclear training program descriptions. In addition, QA Staff members will attend a minimum of one training seminar per year by a qualified agency and/or school. For the purposes of meeting this requirement, activities such as attendance at national conventions, participation in owners group committee's activities, and other such related items may be considered equivalent to a seminar. Such instances shall be specifically approved by the Division Manager of Quality Assurance. Ongoing QA training for personnel with nuclear plant responsibilities will be provided. Training activities will be audited periodically by the QA Staff to verify its scope and effectiveness.

2.3 Design control Implementing procedures outline the method for identifying, controlling, and implementing design changes within the Cooper Nuclear Station.

The procedures provide the mechanism for correctly translating the design changes and regulatory requirements into specifications, drawings, procedures, and instructions. They also establish the method of reviews, interface requirements s

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! (with original design organization, if required), approvals, and the organizations delegated the authority to implement the design change. l

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Design control measures shall include the review for suitability of l application of items that are essential co the s fety.related function of the i system involved. This review will normally occur during the normal design change i

f review or during review of the procurement document by Quality Assurance and the 1

Engineering and/or Maintenance Departments. A necessary part of this review concerns the safety classification of items to be procured. In those instances where the normal methods of Section 2.7 cannot be applied and it is necessary to purchase "commercial grade" off the shelf items for use in essential applications, verification vill be performed to ensure that the part utilized is functionally acceptable for the essential appiteation. This verification may include acceptance testing upon receipt, analysis, or other definitive method. ,

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All design changes initiated for Cooper Nuclear Station vill be I forwarded to the QA Division for review and independent evaluation. These  ;

reviews shall verify the compatibility of the design change with applicable j codes, standards, and regulatory requirements. Items to consider include reactor physics, stress, thermal hydraulic and accident analyses, compatibility of

, =aterials, accessibility for in service inspection, maintenance, repairs, and

, delineation of acceptance criteria for inspection and tests.

Final acceptance of the design change vill require an independent verification or check of the desir. adequacy such as by the performance of design

! reviews, by the use of alternate or simplified calculational methods, or by the i

l performance of a suitable testing program.

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Specific to the related ANSI Standards for this criterion, the following commitments apply:

1. ANSI N45.2.ll 1974 "Quality Assurance Requirements for the Design of Nu;1 ear Power Plants," and the associated Regulatory Guide 1.64, shall be applied to design activities involving safety related modification work and the revision or development of plant design documents o: curring during the operational phase of CNS. The following clarification statement is provided:

Where codes, standards, or design requirements are re fe renced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the Updated Safety Analysis Report (USAR), the USAR commitments shall govern. Later revisions of applicable codes and standards may be specifically invoked by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an "equal to or better than" original condition. I i

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2. ANSI N45.2.4 1972 "Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations," and its associated Regulatory Guide 1.30, shall be applicable to the CNS Operational QA Program for safety related modification work, with the following exceptions / clarifications:

(a) Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the USAR and other appropriate design documents, the original design requirements shall govern.

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(b) The definition of Class I and Class IE electrical equipment set forth by this standard does not conform to the equipment categories of CNS.

Electrical itema pon which the Operational QA Probras is based are included in Table 1 of this policy document. The scope and applicability of this standard shall necessarily be limited to these defined areas.

(c) Appropriate requirements for installation, inspection, and tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the various areas of this standard.

During the development of work packages, considetation vill be given to'the areas outlined in Section 2.3, as appropriate.

(d) The requirements for installation, inspections, verifications, and tests shall be included in the instructions. In the development of these instructions, consideration vill be given to the guicance provided by 1 Sections 4.0, 5.0., and 6.0 of this standard, and appropriate requirements will be incorporated into the instructions. It is not intended that separate procedures

)1 by established which specifically address all of the areas referenced.

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i j (e) Application of the guidance provided by the additional codes and i

standards listed in Appendix B will be considered to the extent that such codes l

j and standards provide useful and practical guidance for the work being performed, j Commitments to the guidance of $45.2.4 shall not include commitments to the

! guidance of referenced standards.

I r

i.

i l

1 28 Revision 4

o k .

8 i

3. ANSI N45.2.5 1974 "Supplementary Quality Assurance Requirements  ;

for Installation, Inspection, and Testing of Structural Concrete and Structural I

Steel During the Construction Phase of Nuclear Power Plants," and its associated [

l Regulatory Guides 1.94, shall be applicable to the CSS Operational QA Program for l

! safety related modification work, with the following exceptions / clarifications: f j

t j

! (a) Appropriate requirements for installation, inspection, and tests I

will be set forth by job specifications and work instructions developed as a part 1

1 of the modification work package. It is not intended that separate procedurew be established which specifically address the various areas of this standard. l l However, in the development of the work package, consideration will be given to [

l l the areas outlined in Section 2.2, as appropriate. i I

2 l

(b) The requirements of control and calibration of measuring and test i

! f j equipment set forth by this standard shall be applied to all measuring and test equipment used by NPPD or their agents, test laboratories, and contractors. Such [

1 requirements, however, will not be imposed on com:nercial batch plant facilities.

Instrumentation at commercial batch plant facilities will be evaluated by NPC l

, construction management personnel. or their designated representative, to I j determine that sufficient accuracy can be obtained and will be verified by an l t

j independent QA Audit, j i I (c) For small quantitics of concrete involved in modification vork, l all concrete must be purchased from commercial concrete batch plants. For these small quantities of concrete, it is unreasonable to expect commercial facilities

} I j to shut down normal operations to provide certified aggregate, cement, a

l ad:sixture s , fly ash, water, etc. In this respect the qualification tests j 29 Revision 4

)

i l i

. _m _ . . _ _ _ _ . . _. _ _ . _ _ _ _ _ . _ . _ _ _ _

L - .  ;

i f

I required by Table A for aggregate; cement, admixtures, fly ash, and pozzolans; ,.

?

i water and ice will not be required. Appropriate evaluations vill be made to  !

i

. determine that good quality and generally acceptable materials are used. NPC [

construction management evaluation, coupled with slump tests, air entrainment (

f 3

tests, and concrete cylinder strengths, vill provide adequate control and qualification of the concrete. The results of evaluation vill be verified by an  !

]

independent QA Audit. l

! i' 1

l (d) Design mixes connis cent with, or equivalent to, original i i requirements vill be specified and the results of the cylinder tests vill be evaluated by ' NPc ' construction management based on the acceptance criteria t

associated with the original design mix requirements and will be verified by an i independent QA Audit.

I l

6

(e) The inspection requirements of Section 4.2 vill not generally be  !

i .

j performed as the small quantities of concrete involved in modification work will I

no doubt be mixed using materials already in the batch plant bins. Control of l i )

l storage of materials would not be practicable.

! i i  !

I l (f) If available, appropriate certifications shall be obtained from  !'

4 l the concrete supplier which verify the adequacy of truck mixers per the l

) requirements of ACI 304, ASTM C 94 here

. certifications are not available, two l 1

1 concrete test cylinders representing the first and last one third of truck mixer contents shall be taken for evaluation of the mixer truck, over and above the normal concrete cylinders taken to evaluate the in place concrete. The concrete batch plant facility shall be inspected by NPG construction management and the i

I 1

2 10 Revision 4 I

~ . . . _ - - _ - _ -- __- -. _ __ - , . - . .__ __ -__ . --

I

.o . j

. . j CNS QA Staff to assure that reasonable controls are being exercised with ,

reference to the inspection guidelines set forth by Section 4.3(1) and (2),  !

I i

(g) Inspection of fills and earthwork will meet the f,ene ral l; rewirements set forth. The extent to which individual inspection requirements  ;

are met vill depend upon the nature and scope of the work to be performed.

(h) Except for normal batch qualification tests (slump, air content, ,

temperature, and compressive strength) and initial reinforcing steel certifications, the in process tests required by Table B are generally applicable  ;

to the periodic control which must be exercised with reference to long term I l

construction type programs. The in process test requirement of Table B are not  !

~

considered applicablo to short term modification work as I ould be required by F

QA at CNS.

I

4. ANSI N45.2.81975 "Supplementary Quality Assurance Requirements j for Installation, Inspection, and Testing of Mechanical Equipment and Systems for i I

the Construction Phase of Nuclear Power Plants." shall be applicable to the CNS  !

i operational QA Program for safety-related modification work, with the following i 1

clarification:

(a) Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the USAR and other appropriate desiEn documents, the original design requirements shall govern.

2 11 Revision 4

.. i o ,

2.4 Procureeent Document Control 1

Cooper Nuclear Station Procedures. Nuclear Engineering Department Procedures, and Quality Assurance Plans and Instructions are required to define the applicable requirements, design basis methods, and procedures for procurement i

of spare parts, matesials, and equipeent for essential nuclear systems, These instructions and procedures shall also include provisions for assuring that the necessary quality requirements are incorporated directly into the procurement documents for essential spare parts, material, and equipment. These instructions l

l and procedures shall also include provision for assuring that the nect , ery  !

records are supplied to the purchaser by the supplier,  !

t The basic principles and practices included in these procedures are -

expected to be applicable, in general, to any purchasing activf.y necessary for i operation of the station; however, in the event that procurement is necessary for  ;

i major modification or repair activities, some additions may be necessary to r i:

provide adequate control. t Procedures covering procurement provide for independent Quality Assurance review of the essential purchasing documents; review and approval of suppliers; and QA Audit of contractor and supplier activities. I Change Orders issued on any procurement document will be subjected to 1

l the same review and approval as the original order. ,

i l

In addition, all procurement documcnts issued to suppliers of safety related items or services require that the supplier have a Quality 2-12 Revision 4

m .

Assurance Program that meets the intent of 10CFR50, Appendix B. The Quality Assurance Program submitted by the supplier will be evaluated by NPPD QA to ascertain that they meet the criteria established in 10CFR50, Appendix B, or an equivalent program which assures the necessary level of quality (as determined by NPPD QA).

To the maximu:n extent practicable, the as built drawings and specifications for Cooper Nuclear Station will be used in procurement of spare parts, material, and replacement parts.

l l

Where necessary, because of design ~ modifications , or where it is 1

necessary or . desirable to upgrade quality in replacement parts or material, necessary modifications will be made to drawings and specifications to incorporate requirements for currently appropriate quality level. These l

modifications or upgrading of replacement parts will be accomplished in l

l accordance with approved instructions, procedures, and drawings. These documents I will be subject to ctation Operations Review Committee (SORC) review before being  ;

implemented.

Specific to the ANSI Standard related to this criterion, the following commitment applies:

1. ANSI N45.2.13-1976 "Quality Assurance a.quirements for Control of Procurement of Items and Services for Nuclear Power Plants," is applicable to the CNS Operational QA Program, with the following clarification:

2 13 Reva tan 4

(a) It must be. acknowledged that equipment and components purchased during the design and construction phase were not purchased on the basis of present-day standards, especially with re fe rence to supplier approval and supplier Quality Assurance Programs. In this respect, replacement parts and spare parts for existing equipment are often limited to sole-source suppliers.

Such replacement parts or spara parts are purchased to appropriate quality standards, verified by NPPD QA, to maintain an "equal to or better than" condition but it is not considered practicable to backfit the requirements of this standard to all such suppliers.

2.5 Instructions, Procedures, and Drawings Quality Assurance activities and other activities which have nuclear safety significance will be prescribed by documented instructions, drawings, and procedures as appropriate and shall be accomplished in accordance with these instructions, procedures and drawings. These instructions will be sufficiently detailed and explicit so that any supervisor, inspector, or auditor can, by ob s e rva tio n , determine whether or not activities are being satisfactorily accomplished and documented. These documents shall include the qualitative and quantitative acceptance criteria necessary to assure satisfactory completion of the test' procedure. Those acceptance criteria shall, where appropriate, require post installation testing prior to returning the component or system to service.

Repair maintenance activities on essential systems are performed in accordance with the Maintenance Work Request process. The required docwnentation for special processes are forwarded routinely to the CNS QA Staff for review along with special test procedures and special maintenance procedures, i

2 14 Revision 4

o .

2.6 Document Control Administrative control procedures shall be established by the Columbus General Office (G.O.) and Cooper Nuclear Station (CNS) to control the identification, indexing, filing, retention, retrieval, and distribution of quality-related records and documents, Control procedures shall be reviewed and apprvved by authorized personnel and are distributed to and used at the site of the activity. These procedures shall also ensure that changes to quality-related records and documents receive the same level of review and approval as the original document.

The overall objectives of NPPD document control are to:

a) Identify those records and documents which are used to control, maintain, modify, or document quality-related activities both at the G.O. and at CNS.

b) Establish an index of quality related records located at the Columbus G.O. and at CNS so that personnel involved in a safety-related activity can determine which documents are applicable to the activity and whether the documents at hand are of the latest revision.

c) Establish a filing system, d) Establish periods of retention.

e) Establish measures to control distribution and revisions.

2-15 Revision 4

The G.O. Records Manager, CNS station management, and the Quality Assurance Division will jointly establish lines of specific responsibility, interfaces, and document control procedures.

Specific to the ANSI Standard related to this criterion, the following commitment applies:

1. ANSI N45.2.9-1974 "Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," and its associated Regulatory Guide 1.88 shall be applicable to the CNS Operational QA Program, with the following exception / clarification: ~

(a) For those design,. manufacturing, construction, and operating records generated prior to implementation of this standard, it is not our intent to backfit the detailed requirements of this standard to those records. All such records, however, have been initially designated for lifetime storage, until specific review dictates otherwise, and will be stored in the record storage facility. Appropriate record indexes and filing system shall be established to permit reasonable identification and retrieval. The records will be stored and preserved per the requirements of Section 6.0 of this standard.

2.7 Control of Purchased Material, Equipment, and Services NPPD receiving inspection instructions provide for determining that all purchased materials, equipment, and services purchased directly or through a contractor, supplier, or subcontractor meet the requirements specified on the original procurement specifications, such as code, standarda, specifications, 2-16 Revision 4

special acceptance testing, material identification, etc. The completed receipt inspection report will become part of the purchase order package. Procurement documents shall be available at the receiving area to identify the receiving inspections required.

NPPD procedures covering procurement provide for supplier evaluation to determine the supplier's quality program effectiveness and their compliance to the applicable 10CFR50 criteria as part of the supplier selection process. These procedures shall describe the methods and techniques used to evaluate the supplier's Quality Assurance Program.

The QA Division shall re evaluate the supplier's quality program at intervals consistent with the importance, complexity, and quantity of the item or services to effectively maintain control of quality. Procurement documentation will specify mandatory hold points for witnessing or inspection of purchased materials, equipment, or services, if required by NPPD.

I Upon receipt at the station, material, parts, and equipment purchased and identified as "Essential" or "Escential Commercial Grade" will be placed in a segregated storage area until all inspections are complete and all required certifications and documentation is received.

Items in segregated areas will not be issued, by the k'arehouse, without the written permission of the Division Manager of Nuclear Operations or designee i and only then after proper arrangements have been made to assure that neesssary steps will be taken to bring all aspects of the partictlar item into conformance with normal requirements prior to the system containing components in "Hold" status being returned to service.

2 17 Revision 4

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

i. -

"Suppliers of essential. equipment.shall be required to-provide certified-documentary evidence that the material supplied conforms to the purchase document requirements .such as material test report,-code required test and inspection, documentation, ete'. A complete set of documentation required by the procurement document for all essential materials, equipment, and- services will be filed at Cooper Nuclear Station.

2.8 Identification and Control of Parts, Materials, and Components To the maximum er. tent practicable, activities carried out during operation of the Cooper Nuclear Station will comply with the requirements for.

identification and control of materials, parts, and components as set forth in i

the as built drawings and specifications for the station. Where special measures j are required to assure proper identification of materials, parts, and components, such requirements will be incorporated directly into the procurement - documents  !

for such parts and assemblies. Such identifications which may include heat numbers. serial numbers, or other means of identification of the item will be incorporated into the procurement documents to provide means of traceability.

Material received at the station (which has not been properly identified) will be segregated and tagged to indicate a "Hold" status. Except as - indicated -in Section 2.7 above, such parts will not be issued or used prior to final acceptance. CNS procedures will incorporate requirements necessary to assure that the identification measures are properly carried out at the station, that unacceptable items will not be used in essential systems,.and that the components to be used in essential systems receive independent verification of component identity prior to installation.

2 18 Revision 4 4

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. . . - ~ _ - . .. - _..- - - . _ - . . . . - .. . .-. . - . . ~ . . . . ,

= .

2.9 Control of Special Processes 4- General maintenance procedures will provide for performance of any special processes by qualified personnel using qualified and approved procedures.

Control procedures provide for QA review, inspection and documentation of activities, and for proper integration of QA/QC Inspection as necessary. In most >

cases, the procedures will only be prepared in specific detail when it becomes necessary to apply a specific process in the maintenance, repair,.or modification of some portion of the essential equipment for the station. These procedures shall also require that special processes, such as welding and heat treating, are controlled and completed by qualified personnel in accordance with qualified procedures, codes, and standards. -

Maintenance modification control methods and Station Operating procedures are reviewed by CNS QA personnel and such review includes verification  !

that necessary codes, standards, quality requiremants, and acceptance criteria are incorporated to control special processes within the limits necessary for satisfactory accomplishment of design objectives, j

l 2.10 Inspection ,

l l

1 i

Quality Control inspections have been assigned in this policy document '

to the organization basically responsible for the performance of the activity. 'A Peer QC Program will be utilized in which QC inspections are normally performed by QC Inspectors who have been selected from within the Nuclear Power Group, and who are many times just as qualified to perform the work as they are to inspect I the work. QC personnel will be qualified / certified, and will conduct the QC a

2 19 Revision 4 r

, _ , , . , - - - _ , _ . - _ _ _ _ _ , _ . . _ _ . _ - .. -,_,I

Program, in accordance with NPPD's commitment to ANSI N45.2.6. This conduct of the QC Program will be within the detail established in the CNS Operations Manual, Volume 12.

Quality Assurance Audits and Surveillance of activities such as maintenance, repair and modifications will include direct observation; whefeas operating functions will be monitored indirectly by observation and examination of individual operating personnel and documentation at intervals consistent with the importance of the activity. Special inspections, such as those requiring qualification of performers to ASNT-TC-1A, will be contracted to approved suppliers. If direct inspection is impossible, indirect control methods will be specified in the instructions to provide a method of monitoring process methods and equipment. The results of all inspections will be placed in permanent record storage.

Controlling documents pertaining to quality related activities receive QA approval to ensure incorporation of appropriate quality requirements.

Specific to the ANSI Standard related to this criterion, the following commitment applies:

1. ANSI N45.2.6-1973 "Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants," and its associated Regulatory Guide 1.58 is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:

1 (a) It has always been the belief of NPPD that, in order to be effective, Quality Control must be built into the operation of the plant. 'w'i th 2 20 Revision 4 l l

i

= .

l this in nind, Quality Control and test -functions performed at CNS are incorporated directly into the station procedures. Inspection points are then performed and signed off by qualified personnel not directly performing or supervising the step (s) being inspected. Selection of QC candida.;es for .

certification is a function of Station Management. Actual certification of QC inspectors is the responsibility of the QA Division.

(b) CNS does not have the in house capability to perform nondestructive examinations in accordance with SNT TC-1A. These services are currently contracted to an approved vendor. Any required nondestructive examinations will be performed by personnel who are qualified and certified per SNT TC-1A.

2.11 Test Control Each type of test program carried out by the station operating group will be defined 'oy written procedures and instructions. These test programs include the preoperational tests, steart up test instructions, operational testing and surveillance testing of structures, systems, and components to demonstrate I their capability to perform satisfactorily as a part of an integrated system.

Acceptance tests will be developed for structures, systems, and components to demonstrate their capability to perform satisfactorily following repairs or modification prior to returning to service. Test procedures will identify the inspector, test performer, and data recorder. Each type of acceptance test has individual test procedures which include Quality Control provisions, acceptance l l

criteria, and check points for observation or checking of important aspects, such as prerequisite conditions for tests or results. I These test procedure i

2 21 Revision 4

.. a l

l l

prerequisites will include the test instrumentation requirements, environmental conditions, and performance by appropriately trained personnel. All Special Test Procedures, Special Maintenance Procedures, and Station Operating Procedures are routinely reviewed by SORC, of which QA is a member.

Quality Assurance Audit and Surveillance activities will be carried out by the station Quality Assurance Staff members to assure that tests are being performed in accordance with the requirements of the procedures and that results are evaluated and compared to the limits prescribed for acceptance criteria. In addition, test procedures shall specify test requirements and quantitative and qualitative acceptance criteria where appropriate.

2.12 Control of Measuring and Test Equipment Procedures shall define the requirements of inspection, maintenance, repair and <- tion of all tools, gauges, instruments, and other measuring and testing ds ..leh are used in connection with activities which' affect quality of safety related equipment.

Each installed plant instrument performing an essential function has been identified and placed on a regularly scheduled program of inspection, test, and recalibration. All test and measuring equipment utill:ed in calibration of the above equipment will be appropriately tagged. Documented calibration records will be reviewed, as required, to evaluate calibration performance and frequency, and changes made as may be necessary.

l l

2 22 Revision 4

A Quality Assurance Plan will prescribe the QA functions to be carried out relative to the calibration program. Quality Ceutrol and Quality Assurance practices require independent checks on the calibration activities and will be-verified by Quality Assurance Surveillances performed by the QA Staff members to assure that procedures are being properly carried out, that adequate records of calibration and testing of measuring equipment are being generated, maintained, and that regularly scheduled adjustments are made to maintain necessary accuracy.  ;

For equipment used to calibrate process equipment, procedures will define action to be taken should regularly-scheduled calibration checks reveal an out of specification condition exists. When inspection, measuring, and test equipment are found to be out of calibration, an evaluation shall be made, and documented, i of the validity of previous inspection or test results and of the acceptability of items previously inspecte or tested. Should the evaluation determine that previous inspection or test results obtained with the af fected instrument are unacceptable, a Nonconfo rmance Report (NCR) will be issued. Re ference and transfer standards, traceable to the National Bureau of Standards for the i calibration of applicable instrument at the CNS, will be maintained at CNS.

Scheduled and unannounced audits or surveillances by the Quality Assurance Staff, the Safety Review and Audit Board, or NPPD management will include review of the calibration program.

2.13 Handling, Storage, and Shipping The procedures for procurement and control of essential spare parts, materials, replacement parts, and equipment will include the necessary requirements to control handling, cleaning, shipping, receiving, and storage of 2-23 Revision 4

)

I

essential parts and material. The Quality Assurance Plans and Instructions include provisions for inspection and audit activities to assure that these ,

procedures are followed and that essential parts and materials maintained at the station are received, inspected, stored, and controlled in such a manner as to ,

prevent degradation. Warehouse personnel shall have the responsibility for carrying out all the requirements specified by the approved station precedures to assure that specific quality requirements are met.

Specific to the ANSI Standard relating to this criterion, the following commitment applies:

1. ANSI N45.2.2-1972 "Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants," and its associated Regulatory Guide 1.38 is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:

(a) Our program is structured to identify safety related equipment and provide for designation of packaging, shipping, receiving, storage, and handling requirements for purchased parts and materials. The classifications of this standard cannot be applied directly to individual spare parts or subassemblies of the parent equipment. Due to difference in volume, complexity, inspectability, I

etc., the packaging, shipping, handling, and storage requirements of spare parts j and subassemblies will necessarily be different from the requirements which may be imposed on the entire component or piece of parent. equipment.

(b) The majority of itecs purchased for an operating plant consist of i components, subassemblies, and individual spare parts which could be used in a l

2 24 Revision 4

s .

multLtede of di fferent applications. Such items are purchasad to the highest requirement of intLnded iss. The volume and characteristics of purchases during tha operttronal ;Dase differ significantly from those purchases made during the design nnd construction phase, and storage facilities are considerably different.

Items tha t require special measures of storage protection will be identified as a part of the purchasing documents. Items that must be stored outdoors (equivalent of Level D) or items that must be stored in covered but unheated conditions (equivalent of Level C) will be evaluated on an individual case basis. However, it is not considered practicable to preclassify individual parts by levels as required by Section 2.7 of this standard. Shipping and packaging requirements for such items will likewise be handled in the purchtse order documents, as appropriate.

l (c) The NPPD procurement procedures for safety-related items includes a checklist to verify that the ANSI N45.2.2 requirements for packaging, shipping, l receiving, storago, and handling are included in the procuremert document.

l QA Audits and Surveillance are performed to verify that the requirements of N45.2.2 are met except as noted in (a) and (b) above.

l i

i l 2.14 Inspection, Test, ,and Operating Status The NPPD status tagging procedure, already in use throughout the system, has been j adapted for use in the Cooper Nuclear Station. '4he re practical, particular emphasis shall be placed on tagging to prevent unauthorized operation or adj us tment which could endanger the safety of personnel, damage equipment, or invalidate the results of tests already performed. In addition, these tags shall indicate abnormal equipment test and inspection status and reference special instructions for equipment located throughout the Cooper Nuclear Station.

2 25 Revision 4

. m Tagging procedures, where necessary, will require that equipment be tagged and that the associated power supplies, starters, switches and controls on the main control panel be tagged as well to warn against operation. In some cases, power supplies will be disconnected and tagged to prevent inadvertent operation. Tagging will be controlled by the Shift Supervisor by requiring that serially-numbered tags, obtained from the Control Room, be used for all tagging purposes. Records will be maintained in the Control Room to enable operators and Shif; Supervisors to determine the status of the equipment tagged.

A Temporary Modifications Control Program will be maintained to provide a method for recording the installation and removal of jumpers, fuses, or wire terminal disconnections. This record will include the location, reason, name of person authorizing action, and name of person performing the installation.

Requirements for tagging are included in the applicable procedures, and status tagging will be one of the aspects of the work that will be verified by audit and surveillance.

2.15 Nonconforming Materials . Parts. or Components Procedures for control of the warehouse and for control of maintenance activities provide for identification and tagging of materials, parts, or components which do not conform to requirements (See Section 2.8).

The Nonconformance Reporting Program shall be used by all persons performing operation, maintenance, and Quality Control functions to record and report:

2 26 Revision 4

• . 1 j

a) Deviations from approved procedures; l

l b) Nonconforming materials, parts, or components received'from outside suppliers on essential purchase orders; c) Nonconforming materials, parts, or components within the plant; d) Nonconforming materials brought on site without following established receiving and inspection procedures; e) Orders or recommendations to stop work; f) Reportable occurrences; g) Any other deficiency which violates the intent of the Quality Assurance Program and which could have a significant adverse effect on quality; h) Deviations which could be reportable under 10CFR21.

A separate report shall be prepared for each nonconformance. The intent of this separate report requirement is to simplify follow-up, corrective action, and record keeping. In addition, a status log of all assigned Nonconformance Reports (NCR's) shall be maintained by the CNS QA Staff.

Nonconforming items will be controlled in such a way as to prevent their inadvertent use or installation. Such parts will be reinspected and 2 27 Revision 4

• O reviewed for adequacy prior to returning them to the manufacturer, scrapping them, or arranging for them to be reworked to conform. Disposition of a nonconforming item will be de te r:nined by the responsible supervisor in conjunction with the QA Staff. k*ritten reports of dacisions to repair or rework essential items will be reviewed and approved in accordance with maintenance and/or design control procedures.

Any decision to reduce requirements to permit use of nonconforming parts, materials, or components in essential systems, will be treated as a design modification and will be subject to Station Operations Review Committee (SORC) review and approval.

Approved Procedures will be utilized for repair and rework of essential parts and equipment. All such rework will be thoroughly documented, including Quality Control and Quality Assurance Surveillance activities, to assure confermance with the requirements of the specifications, procedures, and other l

controlling documents. 1 Any item of essential equipment which is classified as scrap will be identified and segregated in such a manner to prevent inadvertent use or installation in an essential system.

l The G.O. QA Department will compile a nonconformance report quarterly to enable the Nuclear Power Group . Manager to establish adverse trends and implement the appropriate corrective action.

2 23 Revision 4

e 2.16 Corrective Action NRC Regulations which require formal reporting to the NRC of failures, malfunctions, deficiencies, unusual operating experiences, and deviations which may have a significant effect on quality or safety will be reviewed and evaluated by the Station Operations Review Committee and, where appropriate, by the Safety Review and Audit Board. It will be the responsibility of the Nuclear Group personnel to identify and promptly correct all such deficiencies or malfunctions either by improved maintenance, repairs, replacements, or modification. In any case the objective and the corrective action will not only be to correct the existing defect or deficiency, but also to include measures to determine cause and prevent repetition of similar failures elsewhere in the station. Quality Assurance activities will verify that ccrrective actior. is performed in accordance with approved written procedures and that the details of the corrective action are properly documented for the permanent station records.

A monthly status report of open NCR's and LER's shall be prepared by the CNS QA Staff and routed to the following:

Vice-President Power Production Nuclear Power Group Manager SRAB Administrator Division Manager - Nuclear Operations 2 29 Revision 4

Division Manager - Engineering and Construction Division Manager - Quality Assurance Division Manager - Nuclear Support G.O. Quality Assurance Supervisor CNS Regulatory Compliance Specialise CNS Department Managers

~~2.17 Quality Assurance Records All activities having a significant effect on quality and safety will be thoroughly documented, and all such documentation will be incorporated into the record storage system. Procedures will require appropriate physical storage and personnel to maintain these files. Record ideutification, storage, retrieval, access, control, retention, and safeguarding of all such station records will be with approved procedures. Records to be maintained will consist of all records accumulated during engineering and construction plus the records generated during station operation and maintenance as defined in the CNS Technical Specificacians. These records shall also include qualification of 1 i

l personnel and status of equipment and procedures. Inspection and test records

)

shall identify the inspector, data taker, method of observation, results, acceptance, and all nonconformance reports used to document nonconformances.

2 30 Revision 4

1 CNS and/or Columbus Ceneral Office personnel will be allowed to maintain active working files at their work stations. The time frame for submitting these records to record storage facilities will be determined by their respective administrative procedures.

Administrative control of the flies and/or records chall include methods for changing records. Such changes to as-built drawings, operating logs, and the like, must provide clear identification of the change and must be initialed and dated by the person making the change and by persons authorized to approve such changes.

The program will include Audits of record storage facilities to assure that the procedures and controls are properly implemented. The C.O. Records Manager and CriS station management will prepare detailed procedures for incorporating material into the files and for making decisions on removal and disposal of outdated or superseded material from the files. Refer to Section 2.6 "Document Control" for the commitment to ANSI N45.2.9.

2.18 Audits Quality Assurance Plans for each principal segment of the station operating activities have been or will be prepared. These QA Plans will identify the nature and extent of Quality Assurance Audit activities which are to be carried out by or under the direbtion of higher echelons of management. Audit

{

responsibilities are assigned to the Division Manager of Quality Assurance. l Audits performed under this direction (working with the Safety Review and Audit l Board (SRAB) as referenced in Section 3.4) will be conducted according to tho l l

l l

2 31 Revision 4

, r e

1 QA Plans to verify compliance with the Quality Assurance Program. Audits shall be performed in accordance with written instructions or checklists and conducted by trained personnel not responsible for areas being audited. In addition, other members of the NPPD Executive Management staff may audit or request audits of specific activities of particular concern to them. However, all such internal audits will necessarily be coordinated in such a way as to avoid unnecessary interference with the operating activities at the station. The provisions of ANSI N45.2.12 shall be applied to supplier audit programs. It is expected that some unannounced audits will be conducted, particularly with regard to those operating activities such as emergency procedures and operator qualifications.

~

Upon completion of the audit, a formal report will be prepared and transmitted to the organization audited which will include an evaluation statement regarding the program's effectiveness.

All nonconformances identified as a result of these audits will be documented and appropriate follow up action will ba taken to assure that corrective action has been implemented.

Follow up action, including reaudits of any identified nonconformance area and verification of corrective

, action, shall be fully documented.

Specific to the ANSI Standards relatin6 to this criterion, the following commitments apply:

I

1. ANSI N45.2.12 1977 "Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants," and its associated Regulatory Guide 1.33, is applicable to the CNS Operational QA Program, i

2.

Section 4.0 of ANSI N18.7-1972 "Administrative Controls for Nuclear Power Plants," will be used as a guide for scheduling and conducting audits.

2 32 Revision 4

2.19 Additional ANSI Standards .

Other ANSI Standards which are applicable to the CNS Operational QA Program, which are not necessarily related to any of the previously identified criteria of this section, are identified as follows:

1. ANSI N45.2.1-1973 "Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants," and its associated Regulatory cuide 1.37, is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:

(a) Cleaning requirements for almost all maintenance, repair, and modification work will be considered as a part of the overall job requirements.

In this respect, detailed cleaning procedures will not generally be prepared as separate documents. Necessary requirements, consistent with the scope of the work, will be included as a part of the overall work instructions. System cleanness is controlled at CNS by the following methods:

(1) Parts and components are checked for cleanness during receipt inspection and stored in a manner that will ensure adequate levels of cleanness are being maintaineJ.

(2) k*ork instruction will be reviewed by Quality Control to assure that adequate cleaning and access controls are incorporated into sork instruction and associated safety related activities.

(3) Parts and components are inspected for cleanness prior to installation in accordance with CNS maintenance procedures.

2 33 Revision 4

(4) The work area is maintained at a cleanliness level appropriate to the maintenance or modification activity being performed.

(5) Quality Control Inspections before, during, and after safety-related maintenance or modification activities address system cleanness.

(6) Random QA Audit and Surveillance of safety related maintenance or modification activities requires verification of part, component, and system cleanness.

(a) For cleanness classifications where the scope of plant modification work is such as to make application of the guidance provided by this standard practicable , the cleanness classifications and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work requirements.

(b) For most modification or maintenance work, however, involving only small portions or individual components of larger systems, it is not considered practicable to conduct cleanness tests with ASTM Ell 70 Series. Appropriate cleanness will be maintained during the work and preoperational flushing will be conducted, consistent with the scope of the work performed and the original design requirements. Flushing is an additional precaution to ensure system cleanness. Controlling the parts and components and the work area has provided CNS with reasonable levels of assurance that system cleanness will be maintained.

In addition to the above, the '.'ater Chemistry Department routinely samples and tests for system cleanliness, corrosion, crud buildup, etc.

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1. ANSI N45.2.3 ' '73 "Housekee' ping During the Construction Phase of Nuclear Power Plants," and its .ssociated Regulatory Cuide 1.39, is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:

(a) The plant has been divided in zones for fire protection and security purposes. The zone designated for cleanness in the A'iSI Standard are primarily intended for control or work during construction of the plant.

Therefore, the CNS facilities will not be classified by the zones designated in the Standard general hoasekeeping rules. Limitations on eating, drinking, and smoking are already provided in existing CNS procedures. Where special cleanliness controls, tool, and material accountability are required for particular types of work, temporary clean areas will be designated and defined in the procedures for accomplishing the work.

(b) Fire protection and prevention will be provided in accordance with NPPD evaluation of the CNS fire protection system as required by NRC regulations.

(c) Station procedures have been reviewed to determine the need for particular cleanness, housekeeping, and control provisions. Where indicated, I procedures have been revised to incorporate such provisions, using the guidance of ANSI N45.2.3.

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3.0 ORGANIZATION AND RESPONSIBILITIES Nebraska Public Power District is solely responsible for the operation of the Cooper Nuclear Station and will fulfill the obj ectives set forth in the Quality Assurance Program for Operation through its own organization and by contact with qualified contractors and consultants.

3.1 General The overall Quality Assurance Program for Operation shall be conducted in accordance with the three divisions of responsibility which provides for Quality Control, independent Quality Assurance Surveillance, and Quality Assurance Audits.

Table 2 defines the three levels of QA as they are to be carried out for station operation and also shows the comparison with similar principles which shall apply to nuclear fuel procurement and any future major engineering and construction activities for t.he Cooper Nuclear Station.

The Cooper Nuclear Station organization is presented in Figure 2, showing the relationship of the Cooper Nuclear Station organization to other support functions. This chart also shows the relationship of the Quality Assurance functions to other functions in the department and identifies the three levels of Quality Assurance activities. It is intended that clearly separate lines of responsibility be maintained between those responsible for operating the l l

nuclear station and those responsible for auditing to verify that all quality and '

licensing requirements are consistently being met, 3-1 Revision 4

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l QA cesponsibilities within each QA level will vary depending upon the type of activity involved (See Section 4.1.3). Additional details on individual QA responsibilities are given in the paragraphs which follow, together with additional explanation of the interrelationships between the various supervisors and managers involved.

3.2 Nuclear Power Group Management 3.2.1 Vice-President - Power Production The Vice-President -

Power Production is the responsible executive officer for all CNS Quality Assurance related activities. He may delegate responsibility to the Nuclear Power Group Manager as in 3.2.2 below.

3.2.2 Su219ar Power Group Manager As delegated by the Vice President - Power Production, this responsibility includes the Quality Assurance requirements governing those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. Pertinent activities include designin5 purchasing, fabrication, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in service inspection and )

modifications that are associated with Cooper Nuclear Station.

The responsibility and authority over the Safety Review and Audit Board has been delegated to the Nuclear Power Group Manager. The Nuclear Power Group I l

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Manager reserves the authority to conduct, or order the auditing or monitoring of any operations activity, at any time, to ascertain the effectiveness of the overall QA Program and to determine that all aspects of the QA Program are being complied with.

3.2.3 Division Manager, Quality Assurance The Division Manager of Quality Assurance, a member of the executive staff, reporting to the Nuclear Power Group Manager, shall have the responsibility and authority for administrating and maintaining a Quality Assurance Program for Operation which is in accordance with 10CFR50, Appendix B.

Inherent in this responsibility is the authority to accept or reject any or all work, materials or equipment associated with Cooper Nuclear Station and Columbus 0.0. The Division Manager of Quality Assurance shall direct the preparation of plans and instructions for defining the Quality Assurance functions associated with Cooper Nuclear Station to ensure that such activities are conducted in accordance with the operating License and appended Technical Specifications. He shall also approve all plans and instructions for defining and auditing the safety related activities within the Cooper Nuclear Station and General Office.

The actual audit functions to be performed are defined more completely by the body of Qunlity Assurance Instructions and Plans required by Section 4.0 of this policy document. He shall also have direct responsibility for evaluating suppliers of nuclear safety related equipment, materials, and spare parts and for auditing the QA/QC activities of such suppliers.

The Division Manager of Quality Assurance and Staff shall have the necessary organizational freedom and access within Columbus C.O. and Cooper 33 Revision 4

Nuclear Station to institute the, necessary Quality Assurance requirements, identify problems, and pursue prompt corrective action. Figure 1 outlines the QA Division functional organization.

The 'ivision Manager of Quality Assurance shall personally monitor the Quality Asst , activities to the extent necessary for assuring himself that the District is complying with the program. He chall review the effectiveness of the Quality Assurance Program with the Nuclear Power Group Manager on a regular basis. In addition, the Division Manager of QA has a direct line of communication with the President and C.E.O. He shall serve as a member of the Safety Review and Audit Board and provide additional QA Personnel to participate in SRAB activities when requested.

NPPD Quality Assurance Staff, under the direction of the Division Manager of Quality Assurance, shall have the responsibility and authority for implementation and ongoing development of the Quality Assurance Program for operations which will meet the requirements of applicable federal regulations, codes, quality standards and other safety and environmental conditions that are required to assure safe and reliable nuclear power plant operations. In addition, it shall be the responsibility of the Quality Assurance Division to monitor the interface between the Nuclear Operations and Nuclear Engineering and Construction Division to ensure that plant modification and repairs receive the proper design reviews and approvals.

As shown in Table 2, he shall have responsibility for accomplishment of third level QA Audits and shall obtain assistance and special expertise when necessary to comple*e such audits effectively.

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3.2.4 Quality Assurance Manager CNS The CNS Quality Assurance Manager, reporting administratively to the Division Manager of Quality Assurance, shall have tha responsibility and authority for implementing and caintaining the Quality Assurance Program for CNS Operation which will meet the requirements of applicable federal regulations, codes, quality standards, and other safety and environmental conditions that are required to assure safe and reliable nuclear power plant operations.

He shall also be responsible and have the authority to perform, direct,

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or coordinate QA Survei1 lance and Audit activities within Cooper Nuclear Station to determine if conformance with NPPD Quality Assurance Manual and applicable federal regulations as defined in the NPPD QA Manual are being maintained. The CNS QA Manager shall advise .nd assist the Division Manager of Nuclear Operations in all natters which affect the quality of the station. Similarly, he shall advise and assist all station pcrsonnel in matters regarding Quality Assurance and Quality Control. The CNS QA Manager shall designate members of the CNS QA Staff upon request to provide training and instructiori programs to enable CNS personnel to effectively execute the District QA Program. CNS QA Manager is also responsible for tracking open audit iteus identified at CNS to the station and interface with NRC during I&E inspections at CNS. In addition, he sha'1 also be responsible to verify that solutions to safety related problems have been implemented and to perform scheduled audits of those accivities listed in Section 4.1.3 on an announced basis. Additional specific duties shall be defined in the Quality Assurance Instructions and Flans issued in ace.ordance with Section 4.0 of this Policy Document. The CNS QA Manager or designee shall also s e rve as a non voting member of the Station Operating Review Committee (SORC). In addition, 35 Revision 4

.e administrative functions associated with the CSS QA Staff are under the direction of the CSS QA Manager.

The CNS QA hanager and Staff will observe operations, maintenance, in service inspection, special processes, repair or modifications. and other safety related activities covered by the Quality Assurance Program, od to recommend that work stop when such activir.y, in their opinion, does not comply with approved controlling document as defined in Section 3.2.2 The Division Manager of Nuclear Operation or designee is responsible to act on that recorraendation and actually stop work unless he has determined such stoppage would result in a violation of the Technical Specification or other approved documents governing station operation or whether there are overriding

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considerations of safety involved.

The CNS QA Manager will provide for a coordination function for QC activities at CNS. This includes reviews of inspector certifications and performance and the establishment of a training program. The function will also provide th6 communication path for the resolution of QC Inspector concerns.

During absence of the CNS QA Manage:, one of the CNS Qt.Suparvisors I

will be designated to act on his behalf and serve as the nonvoting membee of SORC.

3.2.5 Quality Assurance Supervisor - G.O.

The General Office Quality Assurance Supervisor, reporting administrative 1y to the Division Manager of Ouality Assurance, shs11 have the 36 Revisien 4

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responsibility and authority for implementing and maintaining the Quality Aasurance Program within the G.O. which will meet the requirements of applicable federal regulations, codes, quality standards, 2nd other safety and environmental conditions that are required to assure safe and reliable nuclear power plant operations.

The General Office Quality Assurance Supervisor shall have the responsibility and authority for the controlling, administrating, distributing, and coordinating changes and additions to the Quality Assurance Program for Operation, subj ec t to the requirements of Section 4.0 of the Policy Document regarding authority to initiate, review, comment and issue the various plans and instructions. The General Office Quality Assurance Staff shall support the CNS QA Staff in quality matters such as internal audits and outage coverage upon request, as agreed between the General Office Quality Assurance Supervisor and QA Manager. The General Office QA Supervisor and Staff shall have the responsibility for providing guidance to the G.O. Nuclear Divisions in all matters affecting quality. They shall also establish and implement the program for evduating suppliers for safety related equipment, materials and spare parts.

They shall also be responsible to perform scheduled surveillances within the General Office and verify that corrective action has been implemented. In addition, the administrative functions associated with the General Office QA Staff are under the direction of the General Office QA Supervisor.

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The G.O. QA Supervisor shall a stablish a program in the G.O. for l

QA review of the design / engineering function. This will incluce configuration management, l

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• i Additional specific duties shall be defined in the Quality Assurance Ins truc tions and Plans issued in accordance with Section 4.0 of this Policy Document.

The General Office Quality Assurance Supervisor is responsible for interface, along with the Division Manager of QA, with NRC I&E inspections at the General Office. In addition, he shall also provide training and instruction programs to enable General Office personnel to effectively exec 2ce the District Quality Assurance Program.

3.2.6 Quality Assurance Supervisors - CNS The CNS Quality Assurance Supervisors, reporting administratively to the CNS QA Manager, are responsible to assist in carrying out the duties assigned to the CNS QA Manager. They are responsible to direct the performance of audits and surveillances , and to identify any condition adverse to quality to the CNS QA Manager. The CNS QA Supervisors are responsible for the continued maintenance and upgrading of QA Program Documents as they apply to the daily operation of the Department.

3.2.7 Quality Assurance Staff l

General Office Quality Assurance Staff 1

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The General Office Quality Assurance Staff shall be responsible to assist and advise the General Office Qcslity Assurance Supervisor in all matters which could affect the Quality Assurance activities within the General Office.

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This includes advising and assis, ting Generai Office personnel in all matters regarding Quality Assurance, verify tha: solutions to safety-related problems have been implemented, and perform audits and surveillances of work activities within the General Office on an announced or unannounced basis.

The G.O. QA Supervisor has designated a C.O. Staff member the responsibility for the ongoing development and implementation of the supplier evaluation program. This includes the review of procurement specifications and associated drawings to determine if special requirements such as ' codes ,

standards, materials, tools, and inspections, etc., are included with safety-related systems or equipment requisitions generated by Nuclear Engineering and Construction or Nuclear Support.

CNS Quality Assurance Staff The CNS Quality Assurance Staff shall be responsible to assist and advise the CNS Quality Assurance Supervisors in all matters which could affect the quality of the station. These duties include procedure preparation, performing QA activities within the station, advise and assist all station personnel in all matters regarding Quality Assurance and Quality Control, verify that solutions to safety related problems have been implemented, perform audits l

and surveillances of work activities within CNS on an announced or unannounced i basis. Additional specific duties shall be as defined in the Quality Assurance Plans and Instructions issued in accordance with Section 4.0 of this policy I document.

Disagreements or differences of opinion on Quality Assurance matters are expected to be documented and resolved jointly by either the CNS or General 39 Revision 4

Office Quality Assurance Staff and appropriate CNS or General Office supervisory

$ personnel. Where such resolution is not achieved within a reasonable period of a time, unresolved differences shall be promptly reported to the appropriate Quality Assurance Manager for resolution jointly with the Division Manager of

Quality Assurance and the other respective Division Manager.

I General Office Quality' Assurance Secretary The General Office Quality Assurance Secretary shall be responsible for administering the controlled document distribution and retrieval and records of distribution retrieval. In addition, the Secretary shall be responsible for the preparation of administrative procedures which control and maintain NPPD Columbus G.O. QA files. Additional specific duties shall be as defined in the Quality Assurance Instructions and Quality Assurance Plans issued in accordance with Section 4.0 of this policy document.

3.2.8 Division Manager Nuclear Engineering and Construction The Division Manager of Nuclear Engineering and Construction under the direction of the Nuclear Power Group Manager shall provide technical assistance for plant modification activities at Cooper Nuclear Station. Those Quality Assurance activities associated with such modifications will be conducted in accordance with the CNS Quality Assurance Program for operations. These activities will also be audited periodically by Quality Assurance Staff and identified nonconformances will be reported to appropriate lovels of management for resolution. The Quality Assurance Staff will perform the necessary follow-up action to assure that corrective action is implemented in a timely mannnr.

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

. (

) Nuclear Fuel Manager  !

For those aspects of fuel Management QA covered by the QA Program, the i

Nuclear Fuel Manager, under the direction of the Division Manager of Nuclear  !

Engineering and Construction,- shall be responsible to furnish technical assistance as required to the Division Manager Nuclear Operation and the  ;

l QA Staff. Such reviews shall not replace or supersede the formal audits. i 1 ' ,

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3.2.9 Division Manager - Nuclear Operations i

i The Division Manager of Nuclear Operations, under the direction of the '

F Nucient Power Group Manager, shall be responsible and have the authority for i

assuring that Quality Assurance activities, as defined by this and other approved '

l '

) QA Program Documents are complied with. Some of these responsibilities are ,

t

] delegated to CNS management personnel and include Quality Control and Inspection [

i

] functions as defined in Table 2. The actual functions to be performed shall be l j defined in the QAP's.

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1 The Division Manager of Nuclear Operations shall regularly review i

station activities for the purpose of keeping abreast of significant quality 1 .

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activities. -

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. 3.2.10 Division Manager - Nuclear Support l

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i The Division Manager of Nuclear: Support, under the direction of the  !

l Nuclear Power Group Manager, shall be responsible and have the authority for  !

4 3 11 Revision 4

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assuring that QA activities as defined by this and other approved QA Prograrn i Documents are complied within his areas. This will include timely responses to QA Division Audit and Surveillance findings and implementation of appropriate corrective actions.

3.2.11 c.0. Department Managers G.O. Departmental Managers report to either the Division Manager -

Nuclear Engineering and Construction or the Division Manager Nuclear Support as described in the USAR and are responsible for implementation of QA Program objectives within their area of responsibility.

3.2.12 CNS Departrnent Managers  !

I CNS departmental managers report to the Division Manager - Nuclear Operations as described in the CNS USAR and are . ssponsible for implementation of a

QA Program objectives within their area of responsibility. '

3.3 Cooper Nuclear Station Personnel l

The operational duties and responsibilities of the Cooper Nuclear -

Station personnel are fully described in Reference 7.6. In addition, the Cooper Nuclear Station personnel are assigned Quality Control and inspection functions.

5.ation personnel, under the direction of the Division Manager -

Nuclear Operation, are char 5ed with the responsibility for assuring that the station is tested, operated, and maintained in accordance with approved plans and procedures, and such responsibilities include Quality Control functions.

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3.4 G.O. Pe r s ot.nel The duties and responsibilities of G.O. personnel are described herein and in the appropriate implementing documents. These documents address the G.O.

responsibility for such items as design, procurement, and licensing. Reporting through department and division managers described previously, theirs is the first line responsibility for implementing this program in the G.O.

3.5 Safety Review and Audit Board

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The board must: verify that operation of the plant is consistent with company policy' and rules, approved operatint, procedures, and operating license provisions; review important proposed. plant changes, tests, and procedures; verify that licensee events are promptly investigated and corrected in a manner which reduces the probability of recurrence of such events; and detect trends which may not be apparent to a day to day observer.

Specific duties and responsibilities of SRAB, including auditing, are identified in Referenes 7.15, CNS Radiological Technical Specifications, and in the SRAB Instructions and Guidelines.

3.6 Station Operations Review Committee The Station Operations Review Committee (SORC) has been established to advise thu Division Manager -

Nuclear Operation in all matters regarding operational safety.

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• Specific duties and responsibilities of SORC are identified in Reference 7.15, CNS Radiological Technical Specifications.

3.7 Outside Suppliers, Contractors, Subcontractors, and Consultants During the life of Cooper Nuclear Station, it vill be occasionally necessary to obtain assistance from outside suppliers and centractors. At all times, these outside suppliers, contractors, and consultants vill work under the direction of the NPPD organization having primary responsibility for the particular work being performed. In those instances in which outside suppliers or contractors merely furnish personnel to augment the normal station staff for particular activities, such outside contractor personnel shall be required to perform their work in accordance with the CNS Quality Assurance Documents and l

other appropriate CNS procedures and instructions. In those instances in which outside suppliers, contractors, and subcontractors are assigned primary responsibility for a particular activity, such outside contractor shall be required to demonstrate that it has a Quality Assurance and Quality Control Program and organi:ation appropriate to the work to be performed. Selection of f outside suppliers or contractors shall require the active participation of the Quality Assurance Department in evaluaf.ing and approving their Quality Assurance Program ana reviewing the procurecent documents prior to awarding the contract.

In every instance in which outside contractors have responsibility for l vork on safety related nuclear systems, they shall be contractually required to 1

work to procedures previously approved by the NPPD organization having primary responsibility for the particular work being performed. In addition, they shall be contractually required to prepare, prior to performing the work, QA/QC Procedures specific to the work to be performed for the Cooper Nuclear 3-14 Revision 4

Station. Recognized standards or existing proprietary procedures may be used, but they must be specifically invoked in writing and clearly identified as to their applicability to the CNS work.

If any portion of work on safety-related nuclear systems is to be subcontracted, the prime contractor shall impose QA requirements on the subcontractor consistent with this program.

Additionally the NPPD QA organi:ation shall have direct access to and com:aunication with the contractor's personnel at all levels, both at their home office and in the field.

Prior to outside suppliers or contractor performing work at the Cooper Nuclear Station, the suppliers or contractor and selected representatives from the NPPD Nuclear Operation and Nuclear Engineering and Construction Divisions shall jointly develop and enforce written agreements and procedures which clearly define the limits of the work; interface coordination between contractor personnel and station staff; status and custody tagging procedures; contractor personnel dosimetry; and any other aspects which bear on station or personnel security and safety. Such agreements shall be reviewed by the Quality Assurance l Department to ensure compliance with applicable Quality Assurance Program.

As necessary to execute this QA Program, the District may obtain the se rvice s of a qualified consultant. When non NPPD support is obtained, total responsibility for effectiveness of support organitations activities will remain with NPPD.

3 15 Revision 4 1

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4.0 QUALITY ASSURANCE DOCUMENTS In conformance with 10CFR50 Appendix S, Criterion II, written policies, plans, and instructions shall be prepared to define the Quality Assurance Program to be carried out over the operating life of the station.

4.1 NPPD Internal Documents The Quality Assurance Program Documents are based on work procedures which are prepared by engineering and operating groups. It is necessary to establish clear lines of distinction between the work procedures and the QA Plans and Instructions. 10CFR50, Appendix B, identifies certain work procedures and documents which are required in order to have an effective QA Program. However, it is not intended that QA responsibilities include preparation of basic work procedures; it is not intended that basic work procedures be incorporated into the QA Program Documents.

The work procedures are kept separate from the QA Plans and Instructions in engineering, manufacturing, and construction, and it is intended that they be kept separate for operations activities. However, mandatory QA/QC checkpoints shall be incorporated directly into, or by attachment to the work procedures to facilitate coordination between the work and its Quality Control.

k'ork procedures shall be reviewed by Quality Assurance for proper implementation of this Quality Assurance Program for Operation and for compliance with the criteria of 10CFR50, Appendix 3.

41 Revision 4

Quality Assurance Plans and Instructions shall be developed in accordance with written guidelines. The format and content shall be as specified by the Division Manager of Quality Assurance and shall be documented by a quality Assurance Instruction. Significant changes shall be reviewed and approved via the same channels as for the original document. Each such change, when approved and issued, shall be accompanied by a Transmittal Notice.

Particular circumstances may occur while some work is in progress, which necessitates a change to an approved work procedure. When such circumstances arise, the changes must be authorized per procedure. The written record shall clearly show the nature and extent of the change and the reason for requiring such change.

4.1.1 Quality control Inspection The Quality Control Inspection function must be performed by individual (s) other than those who are actually performing the step (s) being inspected or who are providing direct, hands-on, at the-j ob supervision. The l Cooper Nuclear Station management, as part of their normal management function, are responsible for preparation of the Quality Control requirements of the Peer l

QC program; however, the CNS QA Manager is responsible to review and accept i control methods prior to implementation. l The CSS Quality Assurance Manager, working with the CNS station  ;

management, shall verify that Quality control inspections have been incorporated directly into, or by attachments to, the work procedures and shall periodically inspect work performance to assure that the procedures containing Quality Control 42 Revision 4

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inspections are being followed. The QC Program-shall identify the specific work which is to be subj ected to inspection or verification and shall provide in detail the elecents of work to be inspected which include:

1. Identity of the inspector or data recorder.

2. Type of inspection or verification.

3. Results (data to be recorded).

4. Acceptance (qualitative or quantitative) criteria.

5. Method of disposition of unsatisfacotry inspection results.

6. Reporting requirements.

In addition, clear instructions shall be given regarding the timing, frequency or scheduling, and notification requirements for such inspections so as to obtain maximum effectiveness and to minimi:e delays in completion of the work.

It must be recognized that certain work, particularly in nonroutine maintenance or repair, cannot be anticipated. Therefore, procedures and Quality Control Inspection requirements cannot be prepared until a particular problem has ,

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been detected and evaluated.

Routine maintenance and repair of essential systems and components generally requires pe rfo rmance of a complete or partial Surveillance Procedure 4-3 Revision -

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l prior to placing the system back in service. This type of QC (actual performance or functional testing) following completion of work is considered a unique advantage on an operating facility. Such surveillance testing may be performeG by the individuals who performed the maintenance activity.

4.1.2 Quality Assurance Instructions (QAI) '

a e

In order to comply with 10CFR50, Appendix B, and this policy document, J

the Quality Assurance Staff shall prepare additional QAl's which shall be approved by the Division Manager of Quality Assurance.

i F.ach QAI shall clearly identify the purpose, conditions, problem, or

uncertainty which generated the need for clarification. The authority, policy, regulation, specification, code or standard applicable to the particular problem shall be cited in the Instruction.

4 2

'a.en approved, QAI's shall become a part of the CNS Quality Assurance  ;

i Progran for Operation.

1 a 4.1.3 Quality Assurance Plans (OAP) i 1

i i

Concurrent with the preparation of work procedures, and during l operations or maintenance activities, Quality Assurance Staff shall develop additional QAP's as needed. These QA Plans will outline specific Quality

, Assurance activities and shall become a part of the CNS Quality Assurance Program for Operation. Distribution of these Plans will be to those individuals who are responsible for that particular activity. As a general guideline in defining the 4

f scope of the QA Program, there shall be a QAP for each functional area.

! 44 Revision 4 i

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A guide for the foruat and content of QAP's shall be specified in a QAI to provide uniformity and to assure that each plan is complete and adequate for the purpose intended.

The QAP's shall be prepared by the Quality Assurance Staff and shall be reviewed and approved by the Division Manager of Quality Assurance. In addition, when significant changes have been made to these documents, the QAP will be routed to the following for review and comment:

Division Manager - Nuclear Operations Division Manager Nuclear Engineering and Construction Division Manager - Nuclear Support The QAP's shall define the specific work which is to be subjected to Quality Assurance review, surveillance, and audit, and the manner in which such review, surveillance, and audit is to be carried out.

Checklists shall be prepared after reviewing the work procedures describing the QA Surveillance or QA Audit guidelines.

a) Quality Assurance Surveillance ,

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i The Quality Assurance Surveillance function is intended to provide an i

independent check, on a continuing basis, that work is being performed in i l

accordance with the require =ents of the controlling documents. The Quality I

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Assurance Surveillance activities should not duplicate, one for one , the activities performed for Quality Control Inspection purposes. However, some duplication will occur, incidental to the ' performance of independent observations made to satisfy both Quality Assurance Surveillance and Quality Control requirements.

The obj ectives of Quality Assurance Surveillance are to verify that the Quality Control !nspection Program is in effect and is functioning as intended; that personnel performing Quality functions are properly qualified; that adequate information is being recorded to provide a complete and accurate quality history; and that deficiencies are identified, corrected, and recorded; and corrective action taken to prevent recurrence of those types of deficiencies.

This philosophy shall be taken into account in developing the checklists for Quality Assurance Surveillance activities to be carried out under i

QA Surveillance shall be as prescribed in appropriate QAP's and QAI's.

each QAP.

The QA checklists shall identify the area of work to be subjected to surveillance and shall provide necessary instructions. The timing frequency, or schedule for the surveillance shall be coordinated with the schedule of the work being evaluated so that the QA Surveillance will have maximum effectiveness with minimum impact on the progress of the work.

i b) Ouality Assurance Audits

'I As required by 10CFR50, Appendix B, a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the Quality Assurance Program and to determine the effectiveness of the program.

46 P.evision 4

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The audits shall be performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities for the work being audited. The General Office Quality Assurance Supervisor and CNS Quality Assurance Manager shall have the responsibility and authority for planning and executing Quality Assurance Audits identified by approved QAP's.

However, the SRAB, or any manager or executive in the chain of organization above the Division Manager - Nuclear Operations, or above the Quality Assurance Supervisors and Managers may initiate and carry out special Quality Assurance Audits within the guidelines provided by this Quality Assurance Program. Audit results shall be reported in writing to the Division Manager of Quality Assurance and the results shall be reviewed with the Management responsible for the area of activity audited. Appropriate follow up action shall be taken and documented as directed by the appropriate Quality Assurance Manager or Supervisor.

Internal instructions include descriptions and timing of types of audits to be performed; guidelines for performing audits, procedures for initiating an audit, and guidelines for preparing audit reports.

Each QAP will be implemented through the use of the appropriate checklist. On the basis that some Quality Assurance Audits are to be conducted or directed by eanagement, it is essential to maintain a high degree of flexibility in the manner of conducting an audit. It is intended that the QAP's provide audit guidelines to assure that areas to be audited are sufficiently defined in advance and that audit personnel are adequately prepared to make a meaningful audit with a minimum of interference with the progress of the work.

Also, flexibility is required to permit the auditor to adapt his procedures to the cenditions existing at the time the audit is made.

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5.0 METHOD OF IMPLEMENTATION The CNS QA Program for Plant Operations will utili::e the guidance provided by NRC publications VASH 1283 (5 24-74), WASH 1284 (10 26 73), and l VASH 1309 (5 10 74) ("rainbow" series) except as noted in the "Specific i,

Exceptions" of this section.

l The existing operational QA Program does not address all of the l detailed requirements set forth in the "rainbow books." A detailed review has 1

been made to determine where the CNS QA Program differs from the ANSI Standards cited in the "rainbow books."

1 j With respect to the applicability of the "rainbow books" and the l associated standards, it is impracticable to apply all of the requirements see I

ferth by these documents to a plant for which important, and (in some respects) s

, irreversible ccmmitments, were made at the start of commercial operation (1974).

1 i It is also impracticable to apply requirements to an operating plant which were intended solely for the design and construction phase. In the event that 1 i

( construction activities are undertaken, the District will commit to compliance i with the applicable portions of the VASH Series ANSI Standards. It is NPPD's intent to apply quality standards to maintenance, repair, and modification I

activities which will provide results which are equal to or better than the original construction.

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] The detailed methods of implementation of this Three Level Quality Assurance Program for Operation shall be as provided for in the body of QAI's and j QAP's pr3 pared in accordance with Section 4.0, 1

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51 Revisicn 4

, e The Quality Assurance Managers and Supervisors or designees shall ,

review and comment on the NPC procedures to ascertain that necessary quality i requirements are included. Procedure changes vill be incorporated as necessary to correct ider.cified control deficiencies or needs. Differences of opinion on

! T QA comments shall be resolved as indicated in Section 3.2.3.

s Af ter review of the various NPG procedures and manuals, the Quality Assurance Manager or Supervisor shall review the appropriate QAI's and QAP's for the purpose of assuring that the overall QA Program objectives continue to be I accomplished in each segment of the work to which this QA Program applies, I

Quality Assurance activities shall be coordinated with the SRAB and with the SORC. QA activities shall be conducted in a manner and on a schedule

.hich vill assure that the organi:ation, supervision, communications, and technical and administrative practices clearly evidence smooth, orderly, I

]

controlled, and safe execution of all safety related functions.

I

, t k'rit te n reports of all QA activities, including descriptions of 2 deficiencies and resolution thereof, shall be incorporated into the official

]

QA file. Corrective action on deficiencies must include resolution of the l specific deficiency and verification that corrective action has been implemented

to prevent occurrence of similar deficiencies in the future. A report of QA Audita performed (internal and external) shall be submitted to the j Vice President Nuclear by the Division Manager of Quality Assurance yearly.

)

l I  !

l The Quality Assurance Staff shall maintain an up to date summary of the l i

l CNS Quality Assurance Policies, Instructions, and Plans, showing how this j QA Program for Operation implements the NRC guidelines contained in 10CFR50, Appendix 3.

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6.0 RECORDS RETENTION AND DISPOSITION Instructions have been prepared by the responsible organizations to provide guidelines for CNS and G.O. record retention and disposition in accordance with this policy document and applicable regulatory criteria, As a minimum, these procedures cover the following:

a) Records content and location; b) Principal location from which records are to be controlled; c) Complete records inventory and master index; d) Ccnditions of storage, access, and security; e) System of records identification, retrieval and control:

f) System of records transfer and disposal.

l Quality Assurance records (reference 7.10) will be entered into the controlled recorils system after they have been dedicated. This dedication occurs when the activity to the document becomes part of the operating condition of the plant.

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7.0 REFERENCES

The following documents were used in the preparation of the Quality Assurance Program for Operation of the Cooper Nuclear Station. It is intended that these documents be used on a continuing basis in the performance of Quality Assurance activities for station operation since they offer measurement criteria against which the QA Program can be evaluated.

7.1 Quality Assurance Criteria for Nuclear Power Plants 10CPR$0, Appendix B (USNRC).

7.2 Standard of Administrative Controls for Nuclear Power Plants, American National Standard ANSI 18.7 1972.

7.3 Updated Safety Analysis Report, Cooper Nuclear Station, Nebraska Public Power District (NRC Docket 50 293).

7.4 Environmental Report Operating License Stage, Cooper Nuclear Station, Nebraska Public Power District (NRC Docket 50 298). .

l I

l 7.5 Quality Assurance Program for Engineering, Design, and Construction, Cooper Nuclear Station.

7.6 Cooper Nuclear Station Procedures Manual.

4 7.7 Safety Rules, Nebraska Public Power District. l l

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t 7.8 Safety Guides for k*ater. cooled Nuclear Power Plants.(USNRC), as

appropriate. ,

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-i' J 7.9 Quality Assurance Requirements for Nuclear Power Plants ANSI N45.2 1977.

t 7.10 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants ANSI N45.2.9 1974 i

l I l l 7.11 Quality Assurance Terms and Definitions ANSI N45.2.10 1973. '

i e.12 Quality Assurance Requirements for the Design of Nuclear Power Plants

1. -

1 4 ANSI N45.2.ll - 1974 t

4 t

i 7.13 Requirements for Auditing of Quality Assurance Programs for Nuclear

' l Power Plants ANSI N45.2.12 1977.

7.14 Supplementary Quality Assurance Requirements for Control of Procurement

of Equipment, Materials, and Services for Nuclear Power Plants ANSI 1 i i 545.2.13 1976.  !

t a  !

7.15 CNS Radiological Technical Specifications, i

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-i (Anility Assurance

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^

Supervisor . C.O. Staff President and Vice.Prealdent

• Chief Executive - Power.

Officer Production l l Nuclear Power

- l Group Hanager

Absinistrative l Secretary 11 l

Divleton Henager

---

Quellty Assurance I

theratlons *

- Quality Assurrace Steff t

• Supervisor l

Wellty  ;

~ Assurance {

Hanage r-CNS I i

I Secretary

)

P Audit and

• Steno. Procurement *

• l

~

Secretery -

0. A. Smervisor Staff

. l l

I l

ricunt 1

• Responsible for 0. A. Secneni level Surveitt neres ani Ibird level Q.A. Aallte.

- - - - - Di r ec t Conuoun ic at t ons 8-! Revision 4 i w _ _ _ _

'[.,,,,o tL .

e F1 CURE 2 l i Board of Directors i I

l

_ _ _ _ _ _ _ _ _ _ _ ___ _ _ _ __ _ _ _ _._ _ _ _ _ _ _ _ _ _1 cresident & CEo I I 1 a

l e (Vice-President. Power Production l I 8 ,

IIAI k%: clear Power Group Manager )

e t

8 l t 1 I Division N nager Division N nager Division N nager Division N nager 2

< Osality Assurance belear Sepport I helear Engineering helear Operations

' & Construction '

4 L I I - l Sr. Naager ---

i C35 @ (m @ hetear - Tech. Support Program I N nager Sepervisor Progras helear Serv. , Control l k 2 k 2 Overview - Coefiguration - L_J j N nager Manager E

- Operations -

C35 CA GO @ Manager Outage Staff Staff helear he tear A .- & N difi-k k _ Training - Engineering - cations manger Manager Radiological -- Manager 2 2 Manager J

helear Nuclear Projects -- Engineering Licen sing - & Construction - Ma intenance Manager Y

" & Safety - Manager - Manager _ M Manager J Flant Services helear Fuels - Manager Corporate .- Manager J-Security

. Nnager 1 J F

hc1 ear Support aucteer Engsneering helear Operations Pros as Division Staff * & Construction Division Staff

• Division Staff * { Control Sta l

L _ _ff_ _J

- Direct Line Ecsponsibility 1. SRAE Chairman M

= .

=

]i ______ - Direct Coordination 2. SORC Qairman 4 I - Responsible for First level Program Implementation 5

• I

- Responsible for Second lawel Program Implementation k I - Responsible for Third Level Program Implementation b _ b - ret rirectly Responsible for @ Program Implementation

• Supervisors (not shown) are also seaponsible for Secoed Level Frogram Implementatios 4

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TABLE 1 SYSTEMS AND MAJOR COMPONENTS ,

COVERED BY THE QUALITY ASSURANCE PRCCRAM l i

I. UUCLEAR STEAM SUPPLY SYSTEM  ;

A. Reactor Primary Vessel i

3. Reactor Primary Vessel Supports j C. Control Rods and Drive System Equipment Necessary for Scram Operatina i

D. Control Rod Drive Housing j i

E. Fuel Assemblies j F. Core shroud G. Steam Dryer '

H. Steam Separator II. REACTOR COOIANT SYSTEMS A, ADS -

Automatic Depressuricacion System l l

B. HPCI High Pressure Coolant Injection System l

C. LPCI Low Pressure Coolant Injection System i D. CS -

Core Spray System E. RCIC Reactor Core Isolation Cooling i

l III. REACTCR PROTECTION AND ENGINEERED SAFECUARD SYSTEMS A. Reactor Protection System

3. Rod Sequence Control Sysrem C. Standby Liquid Control D. Standby Cas Treat =ent E. Diesel Generators F. Electrical Aux Power

1. Critical 4160 V Equipment 1

2. Critical 480 V Equipment 1

3 91 Revision 4 4

, o s s Tabla 1 (Cont'd.)

C. Neutron Monitoring Systems

1. AFRM

2. IRM

3. LFRM 4 RE't

5. SRM

6. TIP H, DC Power Supply I. Nuclear System Leak Detection J. Containment Isolation System K Nuclear Boiler and Related Instrumentation L. Primary Containment M. Rod Position Indicator IV i'L' CLEAR Ft'EL SYSTE'iS A. Refueling Interlocks for Fuel Handling and Vessel Servicing Equipment B. Fuel Pool Liner and Cates C. Fuel Pool Cooling cad Cleanup V. RADI0 ACTIVE VASTE DTSPOSAL SYSTEMS A. Process Radiation Monitoring System

1. Off Cas Vent Pipe Radiation Monitoring

2. Off Cas :tonitoring

3. Aug Off Cas Monitoring

4. Main Steam Line !!onitoring l

5. Reactor Euilding Vent Monitoring (CE) l

6. Drywell and Suppression System Leak Rate ,

1 1

7. Liquid Process Radiation Monitorin5 l

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l Table 1 (Cont'd.)

VI. OTHER SUPPORT SYSTE?tS A. Reactor Equipeent Cooling B. Service Water C. Emergency Bypass Function on Control Room Heating, Vent, and AC D. Reactor Recirculating (Pressure Retaining Parts only)

E. Class I, II, and III Code Items F. Reactor Feed Pumps (Pressure Retaining Parts Only)

G. Reactor Building H&V H. Fire Protection I. Security VII. STRUCTURES (SEISMICS)

A. Reactor Building B. Control Building C. Elevated Release Point D. Intaks Stt'acture E. Diesel Generator Building F. Radwaste Building (Below Crede)

• Note -

1. This listing is not intended to be all inclusive.

2. Application of the QA Progran to these systems and components shall be consistent with the safety related significance of the system or component.

93 Revision

• e Table 2 THREE LEVEL QUALITY ASSURANCE FRCCRAM EXPIA ATION OF FIRST, SECOND. A';D TH7RD LEVEL QA RESPONSIBILITIES a) FIRST LEVEL Oualltv Control & c) THIRD LEVEL-Quality Assurance Audit Inapection.

Persons performing these audits are An individual other than the one generally not involved in the day-doing the work (not to include to day Inspection or Quality immediate supervisor) will have Control, functions. Audits and/or primary responsibility for Quality surveillances will normally be Control. Personnel at this level performed by or under the direction are charged with the responsibility of the appropriate QA Manager or for direct inspection, witnessing, Supervisor. In addition, SRAB and sign off, attesting that work shall be responsible for reviewing has been performed in accordance the results of audits and folicw-with the quality requirements of up audits as described in the controlling documents. Reference 15. The Quality Assurance Staff is alsc. responsible b) S ECC:'D LEVEL-Quality Assurance for the evaluation of audit results Surveillance / Audit. and for verifying that identified corrective c: tion requirements have The Quality Assurance Managers, been implemented.

Supervisors, and Staff are responsible for seconu level s u rze illanc e/audi t as appropriate for work involved. The CSS Quality Assurance Manager and G.O. QA Supervisor are responsible for assuring that controlling docunents for safety related activities include appropriate quality requirements.

QA Staff is responsible for maintaining surzeillance and audits of the work at CSS and the G.O. to assure that Quality Control and inspection programs are being impleaented and that quality requirements are in fact being met.

94 Revision 4 i