ML20198A711

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Rev 20,Change 2 to Nuqap Topical Rept
ML20198A711
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 12/09/1998
From:
NORTHEAST NUCLEAR ENERGY CO.
To:
References
NUDOCS 9812170095
Download: ML20198A711 (89)


Text

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  • NDS DOCUMENT DISTRIBUTION *

>>>>>>> NUQAP TOPICAL REPORT. REVISION DISTRIBUTION <<<<<<<

DATE: 12/09/98 TO: DOCUMENT CONTROL DESK TRANSMITTAL # QAT-98-063 I USNRC WASHINGTON DC 20555 i

FROM: NORTHEAST NUCLEAR ENERGY COMPANY PO BOX 128 (860)447-1791 X2451 l WATERFORD, CT 06385 FAX 444-5711 l

SUBJECT:

NUQAP TOPICAL REPORT REVISION i l

THE ATTACHED NUQAP TOPICAL REPORT REVISION, IS BEING DISTRIBUTED TO YOU FOR INCORPORATION INTO YOUR CONTROLLED l DOCUMENT. PLEASE SIGN BELOW TO ACKNOWLEDGE RECEIPT OF THIS REVISION AND TO VERIFY THAT YOU HAVE INCORPORATED THIS REVISION INO.YOUR l CONTROLLED DOCUMENT. RETURN THIS FORM TO NDS, MP 433, C/O i DOCUMENT CONTROL (X2451) AS SOON AS COMPLETE.

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RECEIPTS RECEIVED AFTER
  • 01/06/98
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PLEASE RETURN RECEIPTS BEFORE THIS DATE. *** THANK YOU.

El SIGNATURE DATE TRACKING NUMBER: QATR0020 COPY NUMBER: 34  !

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9812170095 981209 PDR ADOCK 05000245 1 P PDR J I

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' l Northerst

~! Utilities System O Memo .

Nove'mber 23,1998 063-PRG-98 i TO: Northeast Utilities Quality Assurance Program Topical Report Controlled Copyholders FROM: J. E. Beauchamp s

SUBJECT:

NUQAP Topical Report Revision 20, Change 02 Enclosed is change number 2 to NUQAP revision. Please replace the entire contents of existing sections 1.0, through 14.0, and 16.0 through 18.0. with the enclosed sections.

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( t.J Change 02 changes are in bold anditalles with a revision bar in the right margin. The footer of the affected section willinclude a reference to change 02 Insert the summary of changes document in the front of your manual.

If you have any questions, contact J. E. Beauchamp at X2113.

Attachments; ,

1. Summary of changes incorporated as part of revision 20, change 02.

Enclosure:

Change 02 to the Northeast Utilities Quality Assurance program Topical Report revision 20.

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Attachment to Memo 063-PRG-098 Summary of Changes NUQAP Rev. 20, and Change 02 Section Description of Channes Reference QAP 1.0 Section 1.4.2.5.3, The Director; Second sentence, Deleto the word "offsite." Request No. 98-17, .

Dated 10/14/98 QAP 2.0 Section 2.2.4, Participating Organization; Revise 6th paragraph, change wording to clearly define the Request No. 98-17, roles of Nuclear Oversight and Nuclear Materials and Document Management, in assessing and Dated n)/14/98  ;

monitoring the performance of vendors for quality related activities. Add evaluation, review, and monitoring of vendor quality programs in accordance with section QAP 7.0, " Control of Purchased Material, Equipment and Services."

Section 2.2.6 Management Participation; Delete last paragraph, this paragraph is redundant to Request No. 98-17,  ;

section 2.2.4. Dated 10/14/98 QAP 3.0 Section 3.2 Implementation; Second paragraph, change wording to clearly define the roles of Request No. 98-17, i Nuclear Oversight and Nuclear Materials and Document Management, in assessing and monitoring Dated 10/14/98 the performance of vendors for quality related activities  !

QAP 4.0 Section 4.2.1 Program; change wording to clearly define the roles of Nuclear Oversight and Nuclear Request No. 98-17, Materials and Document Management, in assessing and monitoring the performance of vendors for Dated 10/14/98 quality related activities QAP 5.0 Section 5.2 Implementation; change wording to clearly define the roles of Nuclear Oversight and Request No. 98-17, Nuclear Materials and Document Management, in assessing and monitoring the performance of Dated 10/14/98 vendors for quality related activities Section 5.2.1 Procedures and Instructions; change wording to clearly define the roles of Nuclear Request No. 98-17, ,

Oversight and Nuclear Materials and Document Management, in assessing and monitoring the Dated 10/14/98 i performance of vendors for quality related activities ,

QAP 6.0 Section 6.2.1 Responsibility; change wording to clearly define the roles of Nuclear Oversight and Request No. 98-17, Nuclear Materials and Document Management, in assessing and monitoring the performance of Dated 10/14/98 vendors for quality related activities Section 6.2.3 Drawing Control; change wording to clearly define the roles of Nuclear Oversight and Request No. 98-17, ,

i Nuclear Materials and Document Management, in assessing and monitoring the performance of Dated 10/14/98 vendors for quality related activities  !

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Attachment to Memo 063-PRG-098 Summary of Changes NUQAP Rev. 20, and Change 02 Section Description of Channes Reference Section 6.2.4 Procedure and Instruction Control; change wording to clearly define the roles of Request No. 98-17, Nuclear Oversight and Nuclear Materials and Document Management, in asscssing and monitoring Dated 10/14/98 the performance of vendors for quality related activities QAP 7.0 Section 7.2.1 Vendor Qualifications; change wording to clearly define the roles of Nuclear Oversight Request No. 98-17, and Nuclear Materiais and Document Management, in assessing and monitoring the performance of Dated 10/14/98 s vendors for quality related activities Section 7.2.4 Vendor Fumished Records; change wording to clearly define the roles of Nuclear Request No. 98-17, Oversight and Nuclear Materials and Document Management, in assessing and monitoring the Dated 10/14/98 performance of vendors for quality related activities QAP 8.0 Section 8.2 Implementation; change wording to clearly define the roles of Nuclear Oversight and Request No. 98-17, Nuclear Materials and Document Management, in assessing and monitoring the performance of Dated 10/14/98 vendors for quality related activities QAP 9.0 Section 9.2 Implementation; change wording to clearly define the roles of Nuclear Oversight and Request No. 98-17, Nuclear Materials and Document Management, in assessing and monitoring the performance of Dated 10/14/98 vendors for quality related activities Section 9.2.2 Personnel Qualification and Certification; change wording to clearly define the roles of Request No. 98-17, Nuclear Oversight and Nuclear Materials and Document Management, in assessing and monitoring Dated 10/14/98 the performance of vendors for quality related activities QAP 10.0 Section 10.2.1 Inspection Responsibilities; change wording to clearly define the roles of Nuclear Request No. 98-17, Oversight and Nuclear Materials and Document Management, in assessing and monitoring the Dated 10/14/98 performance of vendors for quality related activities QAP 11.0 Section 11.2.1 Test Program; change wording to clearly define the roles of Nuclear Oversight and Request No. 98-17 Nuclear Materials and Document Management, in assessing and monitoring the performance of Dated 10/14/98 vendors for quality related activities Section 11.2.4 Evaluation of Test Results; change wording to clearly define the roles of Nuclear Request No. 98-17,  !

Oversight and Nuclear Materials and Document Management, in assessing and monitoring the Dated 10/14/98 performance of vendors for quality related activities

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~ Attachment to Memo 063-PRG-098 -

Summary of Changes NUQAP Rev. 20, and Change 02 Section . Description of Chanaes . Reference -

QAP 12.0 Section 12.2.1 Calibration Program; change wording to clearly define the roles of Nuclear Oversight Request No. 98-17, and Nuclear Materials and Document Management, in assessing and monitoring the performance of. Dated 10/14/98 vendors for quality related activities QAP 13.0 Section 13.2.1 General; change wording to clearly define the roles of Nuclear Oversight and Nuclear Request No. 98-17, .

Materials and Do'cument Management,'in assessing and monitoring the performance of vendors for Dated 10/14/98 quality related activities QAP 14.0 Section 14.2.1 General; change wording to clearly define the roles of Nuclear Oversight and Nuclear.- Request No. 98-17, Materials and Document Management, in assessing and monitoring the performance of vendors for - Dated 10/14/98 .

quality related activities.

QAP 16.0 Section 16.2.2 Corrective Action and Follow-up; change wording to clearly define the roles of Nuclear Request No. 98-17, Oversight and Nuclear Materials and Document Management, in assessing and monitoring the l Dated 10/14/98 -

performance of vendors for quality related activities QAP 17.0 Section 17.2 Implementation; change wording to clearly define the roles of Nuclear Oversight and . Request No. 98-17, Nuclear Materials and Document Management, in assessing and monitoring the performance of: Dated 10/14/98 vendors for quality related activities OAP 18.0 Section 18.2.1 Program; change wording to clearly define the roles of Nuclear Oversight and Nuclear F.equest No. 98-17, Materials and Document Management, in assessing and monitoring the performance of vendors for Dated 10/14/98 quality related activities 4

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. l 1.0 ORGANIZATION

1.1 INTRODUCTION

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

1.2 GENERAL 1.2.1 The President and Chief Executive Officer - NU Nuclear Group directs specified nuclear related activities within NU and has the ultimate responsibility for the establishment and execution of the NU Quality Assurance Program (NUQAP) for the Millstone Power Station. The President and CEO is overall responsible for engineering, construction, operation, maintenance, modification, and quality assurance for the Station.

1.2.1.1 Recponsibilities of the President and Chief Executive Officer relating to the Quality Assurance Program are described in this QA

(] Program Topical Report and applicable NUSCO/NNECO te procedures. The President and CEO has contact with quality assurance activities through meetings with the Recovery Officer -

Nuclear Oversight, the receipt of various documents such as:

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

1.2.1.2 The President and CEO is responsible to assess the scope, status, implementation, and effectiveness of the Millstone Power Station NUQAP. To meet this resnonsibility, the President and CEO appoints a qualified tear e individuals to perform an annual Management Quality Assuraiice Review. This Management Quality Assurance Review is:

a) A systematic evaluation; b) Preplanned toward the objective of determining the adequacy of the NUQAP and its compliance with Appendix B to 10 CFR 50 and other regulatory requirements; n

) QAP-1.0 Rev.: 20 Change 02 12/11/98 Page 1 of 18 l

r c) Capable of identifying, communicating, and tracking any

(' required corrective action; d) The team is made up of individuals knowledgeable in quality assurance, quality activities, auditing, management responsibilities, and the Millstone Power Station NUQAP Topical Report.

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

1.3 RESPONSIBILITIES 1.3.1 Overall responsibility for the N'. t1AP is assigned to the Recovery Officer -

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

NU Nuclear Group. These responsibilities include: direction of the Quality Assurance Program; implementation of policies, plans, requirements, procedures, and audits; verification to assure compliance with 10 CFR 50 Appendix B and other regulatory requirements; and verification of the implementation of the Millstone Power Station NUQAP Topical Report requirements.

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

a. Administering those activities within their organization which are required by this NUQAP;
b. Ensuring implementation of the Quality Assurance Program;
c. Estab!; thing and clearly defining the duties and responsibilities of personnel within their organization who perform quality activities;
d. Planning, selecting, and training personnel to meet the requirements of the NUQAP Topical Report;
e. Performing and coordinating quality activities within their department and interfacing with the Nuclear Oversight Department.

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

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(y' 1.3.4 The responsibility, authority, and organizational relationship for performing quality activities within each organization is established and delineated in the I

NUSCO/NNECO organizational charts, policy statements, and written job or functional descriptions.

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

1.4 PARTICIPATING GROUPS - MILLSTONE P )WER STATION (Refer to Fiaure 1.0)

The President and Chief Executive Officer - NU Nuclear Group, reporting to the NU Chairman, President, and Chief Executive Officer, is overall responsible for the i development and implementationof this NUQAP. The Nuclear Safety Assessment Board reports to the President and Chief Executive Officer in compliance with Millstone Power Station nuclear unit Technical Specifications. The President and Chief Executive Officer has delegated the necessary authority and has assigned responsibility for development and implementation of this NUQAP for Millstone Power Station to the:

. Recovery Officer - Nuclear Oversight,

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

. Director - Special Projects 1.4.1 The Recovery Officer - Nuclear Oversight is responsible for the preparation and issuance of this NUQAP Topical Report and verification of the (V a implementation of its requirements and compliance with 10 CFR 50, Appendix B and other regulatory requirements by the applicable NUSCO/NNECO Department. Verification is performed through a planned program of audits, surveillances, and inspections by Nuclear Oversight Sections. The Recovery Officer provides management with objective evidence of the performance of quality activities independent of the individual or group directly responsible for performing the specific activity.

The Recovery Officer has the authority and organizational freedom to verify all activities affecting quality. This is performed independent of undue influences and responsibilities for schedules and costs. The Recovery Officer has the responsibility and authority to stop unsatisfactory work and control further processing or installation of nonconforming materials. The authority to stop work is assigned to Nuclear Oversight Department personnel and delineated in a NNECO Procedure. The Recovery Officer also has the responsibility and authority to identify quality problems, to recommend or provide solutions, and to verify their implementation.

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l The Recovery Officer - Nuclear Oversight is also responsible for the

- Independent Safety Engineering, Operating Experience Programs, and the t independent Review Team. The Recovery Officer (refer to Figure 1.1) has l delegated the necessary authority and responsibility for these activities to the:

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. Director- Audits and Evaluation, l . Director - Performance Evaluation, l . Director- Analysis and Programs.

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

l l 1.4.1.2 Director - Performance Evaluation is responsible for the day-to-day direction and administration of Nuclear Oversight program for surveillance and 4.ispection to verify compliance with 10CFR50 Appendix B and other regulatory requirements, to verify the  ;

implementation of these NUQAP requirements, and to evaluate l performance against management expectations. )

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

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

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. \ QAP 1.0 Rev.: 20 Change 02 12/11/98 Page 4 of 18

l 1.4.2 The Senior Vice President and Chief Nuclear Officer - Millstone Power Station (q

g has the overall responsibility for the implementation of this NUQAP at the Millstone Station site and is responsible for overa!! operation of the Station.

j The Millstone Site Operations Review Committee (SORC) reports to the l Senior Vice President and Chief Nuclear Officer in compliance with Millstone Power Station nuclear unit Technical Specifications. The Senior Vice l President (refer to Figure 1.0) has delegated the necessary authority and has assigned responsibility for these activities to the:

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. Recovery Officer - Millstone Unit 1,

. Recovery Officer - Millstone Unit 2,

. Vice President - Operations, e Vice President - Human Services,

. Vice President - Nuclear Work Services,

. Recovery Officer - Technical Services.

I 1.4.2.1 The Recovery Officer - Millstone Unit 1 is responsible for implementation of this NUQAP for the Unit and is responsible for

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overall unit safe operation and control over those onsite activities necessary for safe operation and maintenance of the plant. The i Recovery Officer (refer to Figure 1.2) has delegated the necessary j authority and assigned responsibility for these activities to the Director- Unit Operations 1.4.2.1.1 The Director - Unit Operations is responsible for the day-to-day direction and administration of the Unit Operations, Maintenance, Modification, Work Planning, and Radiological Controls activities. The Plant Operations Review Committee (PORC) reports to the Director - Unit Operations in compliance with Technical Specifications. The Manager of Health Physics reports to the Director of Unit Operations to provide sufficient organizational freedom and independence from operating pressures as required by the unit technical specifications. The Director has delegated the necessary authority and assigned responsibility for Unit l activities to the: i e Manager - Operations

. Manager- Engineering

. Manager-Work Management

. Manager - Support Services

. Manager- Chemistry

. Manager - Health Physics A

OAP-1.0 Rev.: 20 Change 02 12/11/98 Page 5 of18

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

. Unit Director,

. Director - Engineering,

. Director - Startup.

1.4.2.2.1 The Unit Director is responsible for the day-to-day direction and administration of the Unit Operations, Maintenance, Modification, Work Planning, and Radiological Controls activities. The Plant Operations Review Committee (PORC) reports to the Unit Director in compliance with Technical Specifications. The Manager - Radiation Protection reports directly to the Unit Director to provide sufficient organizational freedom and independence from operating pressures as required by the unit technical specifications. The Unit Director has delegated the necessary authority and assigned responsibility for the Unit activities to the:

. The Assistant Unit Director - Nuclear Safety,

. The Assistant Unit Director - Operations &

Maintenance,

. The Manager Radiation Protection.

. Manager of Projects j 1.4.2.2.2 The Director - Engineering is responsible for the day-to- .

day. direction and administration of Unit Design  !

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

1.4.2.2.3 The Director - Startup is responsible for the planning, scheduling, coordinating and reporting of Unit restart activities.

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l 1.4.2.3 The Vice President Operations is responsible for establishing

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common policies and standards pertaining to the operating units, the safe operation of Millstone Unit 3, and implementation of this NUQAP. The Vice President of Operations has delegated the necessary authority and nos assigned responsibility for the Unit 3 activities to the Vice President - Millstone Unit 3 l The Vice President -

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

authority and assigned responsibility for these activities to the:

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. Unit Director - Unit 3,

. Director - Engineering Unit 3, e Mranager - Motor Operated Valve Project.

1.4.2.3.1 The Unit Director is responsible for the day-to-day direction and administration of the Unit Operations, Maintenance, Modification, Work Planning, and l Radiological Controls, activities. The Plant Operations

! Review Committee (PORC) reports to the Unit Director in compliance with Technical Specifications. The i e Manager - Radiation Protection reports directly to the Unit Director to provide sufficient organizational freedom and independence from operating pressures as required by the unit technical specifications. The director has delegated the necessary authority and assigned responsibility for the Unit activities to the:

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  • The Assistant Unit Director- Nuclear Safety,

. The Assistant Unit Director - Operations &

l- Maintenance,

. The Manager Radiation Protection.

I 1.4.2.3.2 The Director - Engineering is responsible for the day-to-day direction and administration of Unit Design Engineering, Technical Support, System Readiness, '

and for maintenance of the Unit design basis in i

l accordance with the Unit licensing basis.

1.4.2.3.3 The Manager - Motor Operated Valve Project is responsible for the day-to-day direction, and administration of the unit MOV project and associated Modification Engineering activities.

QAP-1.0  ;

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1.4.2.4 The Vice President - Human Services has responsibility for the n Employee Concerns and Nuclear Training Programs, and f') implementation of this NUQAP in providing Emergency Planning

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and Support Services to the Millstone Power Station. The Vice President (refer to Figure 1.5) has delegated the necessary authority and has assigned responsibility for these activities to the:

. Director - Nuclear Training Services, e Director - Emergency Planning.

  • Director - Employee Concerns 1.4.2.4.1 The Director - Nuclear Training Services is responsible for the day-to-day direction and administration of Nuclear Training and related support services. The Manager of Operator Training reports directly to the Director of Nuclear Training to provide sufficient organizational freedom and independence from operating pressures as required by the unit technical specifications.

1.4.2.4.2 The Director - Emergency Planning is responsible for the development and maintenance of the on site Radiological Emergency Plan and the development and coordination of required off site Radiological Emergency Response Plans.

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

1.4.2.5 The Vice President - Nuclear Work Services has responsibility for implementation of this NUQAP in providing work related services in support of the Station. The Vice President (refer to Figure 1.6) has delegated the necessary authority and has assigned responsibility for these activities to the:

. Director - Nuclear Services,

. Director - Information Technology,

  • Director - Nuclear Materials and Document Management,
  • Director - General Services, e Manager- Nuclear Contracts Administration l f3 k_ QAP-1.0 Rev.: 20 Change 02 12/11/98 Page 8 of 18

1.4.2.5.1 The Director - Nuclear Services is responsible for the O- day-to-day direction and administration of Construction Support, Waste Management, Health Physics Support, Facilities Maintenance, and Testing Services for plant operations. The Director is also responsible for project management for the Station nuclear units.

1.4.2.5.2 The Director - Information Technology is responsible for the day-to-day direction and administraticn of Computer Services Support.

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

the approval and oversight of vendors that provide l quality related material and services including source and receipt inspection.

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

1.4.2.5.5 The Manager - Nuclear Contracts Administration is )

N responsible for setting policy and for the day-to-day direction and administration of the Nuclear Contract Group.

1.4.2.6 The Recovery Officer - Technical Services is responsible for Engineering and Technical Support Services at Millstone Station.

The Recovery Officer is responsible for implementation of the Corrective Action, Configuration Management, and related Engineering Programs. The Recovery Officer is also responsible for Nuclear Engineering Support and the Regulatory Affairs interface. The Recovery Officer (refer to Figure 1.7) has delegated  ;

the necessary authority and has assigned responsibility for these  !

activities to the: l

. Director- Engineering Programs

. Director - Corrective Actions

. Director - Configuration Management Program l

. Director - Nuclear Engineering

. Director - Regulatory Affairs QAP-1.0 Rev.: 20 Change 02 12/11/98 Page 9 of 18

1.4.2.6.1 The Director - Engineering Programs is responsible for the day-to-day direction and administration of Engineering Programs and Standards, the Engineering

() Assurance Program, and the administration of the Design and Configuration Control Program and the Design Control Manual for the Station nuclear units.

1.4.2.6.2 The Director - Corrective Actions is responsible for the development and maintenance of the Corrective Action Program implemented for the Station including reporting of program performance indicators, analysis and identification of trends, and identification of necessary preemptive corrective action as required.

I 1.4.2.6.3 The Director - Configuration Management Program is responsible for the day-to-day direction and administration of the Unit Configuration Management Program activities.

1.4.2.6.4 The Director - Nuclear Engineering is responsible for the day-to-day direction and administration of Nuclear Fuels, Radiological Engineering and Assessment, Radwaste Engineering, Probabilistic Risk Assessment, Safety Ar.alysis activities, and the Quality Software Program.

(G) l 1.4.2.6.5 The Director - Regulatory Affairs is responsible for the overall direction and administration of Regulatory Affairs and the Nuclear Regulatory Program activities, for the day-to-day direction and administration of the Unit Regulatory Compliance activties and the Station  :

Administrative Procedures Group.

1.4.2.6.6 The Manager - Independent Review Team is  ;

responsible for conducting in depth and critical reviews of selected topics and events of criticalimportance to nuclear safety and/or organizational success. \

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1.4.3. The Director - Special Projects is responsible for the day-to-day direction and administration of Nuclear Operations Support Services and the performance of special projects in support of nuclear operations.

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OAP-1.0 Rev.: 20 Change 02 12/11/98 Page 10 of 18 i

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~ Organizational Relationships 0

of Personnel Having Quality Chairman, President j -}

Functions for Millstone - & CEO NU Power Station President & Chief .

Employee Concerns ~ "* "' *'D

_ Executive Officer of Oversight Panel (ECOP) ^*******" "' I Nuclear Group J

r Site Operations Senior Vice President Director Special Recovery Officer Review Committee - & Chief Nuclear '

Prows Nuclear Oversight '

(SORC) Officer Millstone l

Recovery Officer Recovery Officer Vice President Recovery Officer Vice President Nc r o Millstone Unit 1 Millstone Unit 2 Operations Technical Services Human Services Smices  ;

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, Vice President l Millstone Unit 3 j

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  • Nuclear Oversight Organization for Millstone Power Station Recovery Officer Nuclear Oversight Support &

Administrative Staff Director Audit & Director Performace Director Analysis &

Evaluation - Evaluation Programs l l l Manager Operations Manager Performance Manager Nuclear Safety Engineering Assessment Evaluation MP 1 Manager Maintenance Manager Perfomance

_ - Manager Programs Assessment Evaluation MP 2 ,

1 Manager Engineering 1 Manager Performace Ma nager 50.54(f)

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3 ,,, ent Evaluation MP 3 Recovery Oversight Manager Quality Manager Plant Support Controlinspection Assessment Support 4

QAP 1.0 Figure 1.1 Rev.: 20 Change 01 Date: 10/15/98 Page 12 of 18

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I Organizational Relationships of Personnel Having Quality Functions

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L Recovery Officer for Millstone Power Station Unit 1 Millstone Unit 1 'l i

Director Unit PORC- I Operations j

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Manager Manager Manager Support Manager Hepith  !

Operations Engineering ~ Services Physics .

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M anager Work Manager Chemistry Management i

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PORC - Plant Operations i Review Committee  ;

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Organizational Relationships of Personnel Having Quality Functions for Millstone Recovery Officer Power Station - Unit 2 Millstone Unit 2 i .

Unit Director Director Startup PORC Millstone Unit 2 Dire c to r ,

Engineering i

I l l Manager Radiation Asst. Unit Director A s st. U nit A sst. Director Protection N uclear Sa fety Director O& M E ngine e rin g I I I Manager of Manager Manager Manager Projects C o rre ctive -

A ction Maintenance Technical Support Manager Manager Work Manager Design PORC - Plant Operations N uclea r Safety Planning & E n gin e e rin g Review Committee O u ta g e s O&M - Operation & Maintenance Manager Manager Project M a na ge r I&C i Proce d u res En gin eering Manager Manager Project Manager C hemistry O pe ratio ns CMP l QAP 1.0 Figure 1.3 Rev.: 20 Change 01 Date: 10/15/98 Page 14 Of 18

t Organizational Relationships of Vice President  !

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_ MOV - Motor Operated Valve Engineering Proced u res PORC - Plant Operations Review Committee O&M - Operations & Maintenance I&C -Instrument & Controls e

OAP 1.0 Figure 1.4 Rev.: 20 Change 01  :

Date: 10/15/98 Page 15 of 18

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' QAP 1.0 Figure 1.5 Rev.: 20 Change 01 -

Date: 10/15/98 ,

Page 16 of 18

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2.0 QUALITY ASSURANCE PROGRAM (D

U 2.1 GENERAL REQUIREMENTS Northeast Utilities (NU) has established a Quality Assurance Program (NUQAP) for tna Millstone Power Station which complies with the criteria of 10CFR50, Appendix B, and follows the regulatory documents and their endorsed ANSl/IEEE standards identified in Appendix C with exceptions as identified in Appendix E.

The quality assurance requirements set forth in the attached Policy Statement, supplemented by quality assurance procedures, provide the primary basis of this program and the NU policy with regard to quality assurance for all the Millstone Station nuclear power plants. This NUQAP Topical Report is established to accomplish the required level of quality in activities carried out throughout the life of the Station's nuclear power plants. I l

This NUQAP applies in its entirety to all activities affecting the safety-related functions of structures, systems and components. Safety-Related structures, systems and components are functionallyidentified in Appendix A of this NUQAP l and are designated CategoryI by Northeast Utilities. Applicabilityof Appendix A to l each FSAR is addressed by existing Nuclear Unit specific Design Bases and Licensing commitments, and also as specifically identified in each FSAR addressing Section 3.2.1 of Regulatory Guide 1.70. This NUQAP is also applicable in its entirety to materials, equipment, parts, consumables and services 7 designated Category I.

(O This NUQAP applies to other quality programs including Anticipated Transient Without Scram (ATWS) Quality Assurance which is applicable to MP-1 and MP-2  ;

only (MP-3 commits to Generic Letter 85-06) and Electrical Equipment Qualification (EEO) as defined by NU commitments. Portions of this NUQAP are also applicable to Fire Proiection Quality Assurance (FPQA), Station Blackout Quality Assurnce (SBOQA) and Radwaste Quality Assurance (RWQA) which are delineated in upplicable procedures.

The Materials, Equipment, and Parts List (MEPL) Program provides instruc? ions to identify structures, systems, emponents, materials, equipment, parts, consumables, quality software and activities that need to be identified as safety-related or augmented quality.

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

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

(D

(,/ OAP-2.0 Rev.: 20 Change 02 Date: 12/11/98 Page 1 of 7

1 y

Training sessions are documented. The content of the training sessions is i (A) described, attendees. and attendance date indicated, and the results (e.g., I examination results) of the training sessions recorded, as applicable.

Periodic program review of the status and adequacy of this NUQAP is  :

accomplished by Nuclear Oversight audits, surveillances and inspections, by Nuclear Safety Assessment Board (NSAB) reviews, and by the independent l l

review team which performs the annual NUQAP Management Review described herein and QAP 1.0, "Organizatiorf', Section 1.2.1.2. Organizations outside NU are required to review the status and adequacy of that part of this NUQAP for which they have been delegated responsibility.

2.2 IMPLEMENTATION ,

l 2.2.1 GOALS AND OBJECTIVES The goals of this NUQAP are to maintain quality levels in an effective and l efficient manner and to assure a high degree of functional integrity and reliability of Station nuclear power plant quality structures, systems, and components. To meet these goals, the following objectives of this NUQAP have been defined -

1

a. Define, through procedures, the quality activities that apply to design, fabrication, procurement, construction, testing, operation, refueling, repair, O

V maintenance and modification of the Station nuclear power plants; )

b. Establish, assign, and document the responsibilities for the conduct of those activities affecting quality structures, systems, and components;
c. Establish confidence that (a) quality activities for the Station nuclear power plants are performed consistent with NU policies and (b) quality activities are performed by qualified personnel, and are verified through a system of audits, surveillances, and inspections of those organizations with quality responsibilities;
d. Apprise the President and Chief Executive Officer - NU Nuclear Group of unresolved problems and trends which could have a significant effect on nuclear power plant safety.

2.2.2 PROGRAM DOCUMENTATION This NUQAP defines the NU nuclear policies, goals, and objectives, and is used as guidance for the development of the various division, rh

( / QAP-2.0 Rev.: 20 Change 02 Date: 12/11/98 Page2 of 7

\

l department, branch, or section procedures. Revisions to this NUQAP N shall be made as needed to reflect current requirements and descriptions (V of activities prior to implementation. These revisions shall be made in accordance with a NNECO Procedure.

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

Revisions which do not reduce previously accepted commitments are ,

periodically submitted to the NRC as required by 10 CFR 50.54 (a)(3)  ;

and.10 CFR 50.55 (f)(3).  ;

Quality procedures are developed by the departments performing quality activities. These procedures are reviewed for concurrence by the  !

departments which are responsible for implementing portions of these  ;

procedures and are approved by the initiating department. The Nuclear ,

Oversight Department reviews other department quality procedures for '

compliance with this NUQAP and concurs with sucn procedures as described in QAP 5.0, " Procedures, Instructions, and Drawings".

Changes to procedures are subjected to the same degree of control as <

that utilized in the preparation of the original document. I Each Vice President, Recovery Officer, and Director is responsible for i implementation of this NUQAP within their organization which includes v individual departmental procedure requirements applicable only to their respective activities. In addition, they are responsible for the preparation, approval, and distribution of those instructions, operating procedures, testing procedures, or other instructions where further guidance is l necessary. 1 l

2.2.3 STRUCTURES. SYSTEMS AND COMPONENTS

)

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

For structures, systems and components covered by the ASME Code, NUSCO/NNECO procedures describe the measures taken to assure that l the quality assurance requirements contained in the code are l supplemented by the specific guidance of the applicable regulatory l guides and endorsed ANSI standards listed in Appendix C. l V OAP-2.0 Rev.: 20 Change 02

( Date: 12/11/98 l Page 3 of 7

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

The degree of control over activities affecting quality structures, systems, and components is consistent with their importance to safety. Such controls include use of appropriate equipment, establishment of suitable environmental conditions, and assurance that all prerequisites for a given activity have been satisfied. This NUQAP provides controls over special processes and skills necessary to attain the required quality, and the need for verification of quality by inspection and test.

The Nuclear Oversight Department and applicable NUSCO/NNECO technical organizations jointly determine and identify the extent quality I assurance controls are applied to quality structures, systems, and j components. The quality assurance controls are in conformance with this  :

NUQAP, which complies with the 18 criteria set forth in Appendix B to )

10 CFR 50. I 2.2.4 PARTICIPATING ORGANIZATIONS l

The organization for Millstone Power Station activities affecting the l

, quality of structures, systems, and components is identified in QAP 1.0, (w/ ) " Organization", which also briefly describes assigned responsibilities.

The Nuclear Oversight Department is responsible for: a) the development, coordination, and administrative control of this NUQAP including coordination of Nuclear Oversight Department procedure review  !

and approval; b) assuring issuance of this NUQAP Topical Report as a j controlled document (as described in QAP 6.0, '" Document Control", and; c) the review and concurrence with quality procedures and revisions written by other departments. Procedure reviews shall be performed in accordance with QAP 5.0, " Procedures, Instructions, and Drawings".  ;

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

( )

(/ O AP-2.0 ,

Rev.: 20 Change 02 l Date: 12/11/98 Page4 of 7 1

Document Management is responsible for the review and approval of O these vendors' quality assurance programs prior to initiation of contracted activities.

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

In addition to the initial review, Nuclear Materials and Document Management is responsible for the subsequent performance, as appropriate, of audits, surveillances, and inspections of approved vendor's quality assurance programs to assure continued implementation of quality requirements. Nuclear Materials and Document Management assures that the quality assurance programs of vendors that perform quality activities are periodically reviewed to assure that the vendors are implementing adequate programs. Evaluation, review, and monitoring of vendor quality programs is conducted in accordance with section QAP 7.0, " control of Purchased Material, Equipment and Services".

Vendors may be delegated the execution of quality assurance functions by Contract. These Contracts are reviewed and approved in accordance with this NUQAP. These vendors may be contracted to perform quality activities under their approved quality assurance program or directly under the requirements of this NUQAP, 2.2.5 INDOCTRINATION AND TRAINING A program is established and maintained for quality assurance indoctrination and training which provides confidence that the required level of personnel competence and skill is achieved and maintained in the performance of quality activities. Quality procedures delineate the requirements for an indoctrination program to assure that personnel responsible for performing quality activities are instructed in the purpose, scope, and implementation of quality procedures and that compliance to these documents is mandatory. Each NUSCO/NNECO Department is responsible for assuring assigned personnel who perform quality activities have been appropriately indoctrinated and trained.

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

O b OAP-2.0 Rev.: 20 Change 02 Date: 12/11/98 Page 5 of 7 l

l Procedures describe the nuclear training program requirements which

' /7 assure that:

U

a. Documentation of formal training and qualification programs includes the objective, content of the program, attendees, date of attendance; and results (e.g., examination results), as applicable.
b. Proficiency of personnel performing and verifying activities affecting quality is established and maintained. Personnel proficiency is established and maintained by training, examination / testing, and/or certification based upon the requirements of the activity. Acceptance criteria are developed to determine if individuals are properly trained and qualified;
c. Certificates or other documentation of qualification clearly delineate the specific functions personnel are qualified to perform and the criteria used to qualify personnelin each function.

This program also requires the head of each department to be responsible for a training plan which assures that personnel performing quality activities are trained in the principles and techniques of the activity being performed.

2.2.6 MANAGEMENT PARTICIPATION Millstene Power Station Vice Presidents, Recovery Officers, and Directors are responsible for implementing this NUQAP within their j organization. The Recovery Officer - Nuclear Oversight will assist in l development, coordination, and review of the program.

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

I l

Actions considered by the Management Review may include, but are not l limited to:

l l

a. Review of selected procedures and documents; m

QAP-2.0 Rev.: 20 Change 02 l Date: 12/11/98 Page 6 of 7 j

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

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b. Verificationof the implementationof selected procedural requirements; .
c. Review of past audit results and other inspection /reviewresults such ,

as those from previous Management Reviews, the NRC or other departments.

The Management Review's findings of deficiencies and recommendations for program improvement are forwarded to the President and Chief I Executive Officer - NU Nuclear Group, who shall assure appropriate  !

. corrective action is taken, i i

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QAP-2.0 Rev.:20 Change 02 i

Date: 12/11/98 Page7 of 7

l 3.0 DESIGN CONTROL v i 3.1 GENERAL. REQUIREMENTS This NUQAP provides measures to assure that the applicable design i requirements, such as design bases, regulatory requirements, codes, )

technical standards and quality standards, are identified in design i documents which are reviev'ed, approved and controlled in accordance

. with procedures. Such measures include review for suitability of application of materials, equipment, parts and processes that are essential to the functions of quality structures, systems, and components. Changes to, and deviations from specified requirements are identified, documented and controlled. j The Director I Manager - Engineering for each nuclear unit is responsible j for controlling design work, administering design control activities (including I design interface) and design modifications for quality structures, systems, and components.

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

Millstone Station nuclear power plants rests with Engineering Programs. l The division of responsibilities and jurisdictional boundaries for design control program implementation are set forth in NUSCO/NNECO O procedures. Although other organizations may be delegated the 'ask of establishing and executing the design control program or any part tnereof, j l

the Director / Manager - Engineering of each nuclear unit shall retain the i responsibility for program implementation for the unit. The applicable l requirements of this NUQAP shall be imposed on other organizations l delegated the task of establishing or executing the design control program in accordance with QAP 4.0, " Procurement Document Contror and QAP 7.0, " Control of Purchased Material, Equipment and Services".

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

Measures are applied to verify the adequacy of design. The extent of design verification is specified and documented by the responsible organization. The individuals performing design verification should not (1) have immediate supervisory responsibility for the individual performing the design, (2) have specified a singular design approach, (3) have ruled out certain design considerations,or (4) have established the design inputs l O

QAP-3.0 Rev.: 20 Change 02 ,

Date:12/11/98 Page 1 of 6

1 for the particular design aspect being verified. The independent design  !

(] verification should not dilute or replace the responsibilityof the supervisors )

(> for the quality of work performed under their supervision. Where changes I to previously verified designs have been made, design verifications are l required for the change, including evaluation of the effects of those I changes on the overall design. Design verification may be accomplished j by testing. Tests to demonstrate adequacy under adverse design ,

conditions shall comply with the requirements of QAP 11.0, " Test Control" l Design errors and deficiencies which adversely affect quality structures, systems, and components in the design process are documented and appropriate corrective action is taken. These design errors and deficiencies are documented in accordance with design change procedures or as defined in QAP 15.0, " Nonconforming Material, Parts, Components, or Services" and/or QAP 16.0," Corrective Action".

3.2 IMPLEMENTATION The Director / Manager - Engineering of each unit is responsible for the design, design review, engineering approval of design changes, design evaluation and design control for the unit except that Nuclear Engineering performs design / design changes in support of the reactor core reload. The function may be delegated to other organizationsto perform the design, or any part thereof, but the responsibility for overall design and final engineering decisions and design control of quality structures, systems, and components related to the nuclear unit is the responsibilityof the unit's v Director / Manager- Engineering.

Nuclear Oversight performs audits, surveillances, and inspections, as appropriate, to verify that NUSCO/NNECO departments are effectively complying with this NUQAP and procedural requirements for design control. Additionally, audits, surveillance's and Inspections are performed, as appropriate, to verify that vendors are offectively complying with their quality assurance program requirements for design control.

3.2.1 DESIGN PROCESS Design control measures are applied to design analyses, such as, reactor physics, stress, thermal, hydraulic, nuclear radiation,

~ accident and seismic analyses; compatibility of materials; accessibility for in-service inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and test.

Measures established to control design documents are described in QAP 6. 0, " Document Control".

p V QAP-3.0 Rev.: 20 Change 02 Date: 12/11/98 Page 2 of 6

Program procedures and instructions define the method of p implementing design control measures. These measures require that applicable design requirements, such as, design bases, regulatory squirements, codes and standards, are translated into specifications, drawings, procedures or instructions. Procedures and instructions further require that appropriate quality standards are specified and included in design documents. Materials, ec,Jipment, parts and processes, including standard "off the shelf" commercial or previously approved items essential to quality functions are selected and reviewed for suitability of application.

The basis for selection may include industry standards, material and prototype hardware testing programs, and design review.

Procedures assure that a documented check is performed to verify the accuracy and completeness of design drawings and

. specifications before release for procurement, fabrication or construction. Design drawings receive a documented check to verify dimensional accuracy.

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

Procedures describe the provisions to assure that design l 3 drawings and specifications are prepared, reviewed and approved l (d in accordance with NUSCO/NNECO requirements and that the documents contain the necessary quality assurance requirements, such as inspections and test requirements, acceptance requirements, and the extent of documenting inspection and test results.

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

- design control measures commensurate with those applied during i the original design as amended by applicable design or licensing i basis changes.

An independent review and approval of design changes is performed by the organization that conducted the original design O QAP-3.0

-V Rev.: 20 Change 02 Date: 12/11/98 Page 3 of 6

. . j reviews, unless such review is performed by NNECO or another qualified organization delegated by NNECO to perform this

/]

G function.

Proposed design change modifications are submitted to the appropriate nuclear units management for processing and review.

This review includes the Plant Operations Review Committee (PORC) / Site Operations Review Committee (SORC) as required by applicable procedures. PORC/SORC is advisor to the Senior Vice President and Chief Nuclear Officer and Unit Directors (Millstone Units 2 & 3)/ Unit Operations Director (Millstone Unit No.

1) on matters relating to nuclear safety. The composition, responsibilities, and authority of the SORC/PORC are defined in Section 6 of each nuclear unit Technical Specification. If the change involves a quality structure, system or component, the change shall be reviewed by qualified engineering personnel for technical adequacy. Reviews of the safety evaluations associated with proposed design changes are performed by the Nuclear Safety Assessment Board (NSAB). The sequence of the NSAB review depends upon the determination of whether an unreviewed safety question is involved (i.e., in accordance with ANSI N18.7, if a proposed change in the facility involves an unreviewed safety question then the NSA3 review is conducted prior to submittal of the proposed change to the NRC for review and the issuance of a license amendment for its implementation).

(U)

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

a. the adequacy of the proposed change is substantiated;
b. unreviewed safety questions are propcily identified and handled per 10 CFR 50.59;
c. nuclear safety requirements have been addressed.

Errors and deficiencies in design, including the design process, that could adversely affect quality structures, systems, and components are documented and corrective action is taken in accordance with QAP 15.0, "Ncnconforming Materials, Parts, Components, or Services" and/or QAP 16.0, ' Corrective Action".

' ./

( QAP-3.0 Rev.: 20 Change 02 Date: 12/11/98 Page4 of 6

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

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

3.2.4 INDEPENDENT DESIGN VERIFICATION Original designs and design modifications are reviewed for adequacy and the sign-off performed by a person other than the originator of the design. The originator's supervisor may perform this independent review only if the supervisor: (1) did not specify a singular design approach, (2) did not establish the design inputs or rule out certain design considerations, (3)is the only individual in the organization competent to perform the review. Whe e the I supervisor performs the design review, the next level of management shall fulfill the supervisor's responsibilities. Design verification is documented in accordance with procedures or

()

,-~ .

instructions. Simplified calculations or computer programs may l be utilized as alternate means of design verification. When design verification is performed by testing, the tests are performed using ]

procedures, which specify the authority and responsibility of design verification personnel. Responsibility for design adequacy and evaluation is retained by the Director / Manager - Engineering of each unit.

Design verification (if other than by qualification testing) is normally completed prior to release for procurement, fabrication, and construction, or release to another organization for use in other design activities. For those cases where design verification cannot be completed prior to release for procurement, fabrication, and construction, procedures assure that design verification is completed prior to the point when the installation is declared operational.

i ,

(V) QAP-3.0

, Revz 20 Change 02 Date: 12/11/98 Page 5 of 6

l Procedures describe the requirements which assure the following (9 when testing is considered as an alternate method of design C/ verification:

a. Specifications or procedures provide criteria that specify  !

when verification should be by test. l

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

l

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

.Particular emphasis is placed on assuring that designs are in conformance with applicable codes, and on selecting the proper design verification or checking method. Procedures and instructions provide the requirements and necessary controls for design verification. These controls include a review to assure that design characteristics can be controlled, verification that there is adequate accessibility for inspection or test, and that inspection and test acceptance criteria are incorporated. Documentation of y.

reviews is provided. l b] Procedures include requirements which identify the responsibility of design verifiers, the areas and features to be verified, and the extent of the documentation.

)

Procedures assure that procedural control is established for j design documents that reflect the commitments of the nuclear unit i FSAR. These procedural controls vary for design documents l which receive formal design verification by several disciplines or j organizations, and those which can be reviewed by a single individual. The specific design documents and specialized reviews are determined and used as required by the design l changes and modifications.

i Procedures are established to assure that verified computer l

' programs are certified for a specific use.

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

(% \

b QAP-3.0 Rev.: 20 Change 02 l Date: 12/11/98 l Page 6 of 6

8 4 l 4.0 PROCUREMENT DOCUMENT CONTROL 4.1 GENERAL REQUIREMENTS This NUQAP provides measures to control the procurement of materials, l equipment, parts and services for quality structures, systems, and components for the Millstone Station nuclear power plants to assure 1 compliance with applicable regulatory requirements, procedures, quality assurance standards, and regulations affecting procurement documents, Changes to procurement documents are subject to the same degree of control as utilized in the preparation of the original documents.

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

8 Requests for materials, equipment, parts and services are l reviewed for technical adequacy and verification of the quality l

designation. The appropriate responsible engineer / nuclear unit management reviews and approves such requests in accordance with applicable procedures. Nuclear Materials and Document Management personnel then penorm a procurement engineering evaluation to assure the inclusion and adequacy of quality j assurance requirements prior to the issuance of the purchase order. Materials, equipment, and parts for which technical and quality assurance requirements have been previously established within the Material Information Management System are purchased without additional procurement engineering evaluations.

Vendors utilized to perform quality activities for the Station nuclear

! power plants are responsible to implement measures for control of associated procurement documents to assure applicable requirements including quality assurance requirements are specified.

, Audits, .surveillances, and inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for the control of procurement documents.

QAP-4.0 2 Rev.: 20 Change 02 Date: 12/11/98 Page 1 of 3 n

4

(- Changes to procurement documents, whether initiated by NNECO

(_)] or its representative, are subjected to the same degree of control 1

as that utilized in the preparation of the original document. The procurement of spare or replacement parts for quality structures, systems, or components is subject to the controls of this NUQAP and applicable procedure requirements. The spare or replacement parts are subject to controls equivalent to original or subsequent codes and standards. The use of subsequent codes and standards are controlled in accordance with QAP 3.0, " Design )

Control".

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

. assure that:

a. Adequate technical requirements are specified; 1
b. The quality assurance requirements are correctly stated, ,

auditable and controllable; I

c. There are adequate acceptance and rejection criteria.

(

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

following, as necessary:

a. The scope of work to be performed;
b. Technical requirements (specified or referenced) including the applicable components and materials identification requirements, drawings, specifications, procedures, instructions, codes and regulations, and the identification of applicable test, inspection and acceptance requirements, or specialprocess instructions;
c. Quality assurance program requirements to be imposed on vendors which include the applicable requirements of n

( QAP-4.0 Rev.: 20 Change 02 Date: 12/11/98 Page2 of 3

10 CFR 50, Appendix B, and the NRC regulatory position 1 7s contained in the regulatory guides and their endorsed V) ANSI /IEEE standards listed in Appendix C. l l

d. Right of access which provides, as appropriate, for access to vendor facilities and records for inspection or audit by NNECO or its designated representative; and provides access for events such as those requiring notification of hold points;
e. The documentation required to be prepared, maintained, j and/or submitted to NNECO or its representative for review, approval or historical record. The time of submittal of this documentation and the retention and disposition of quality  !

assurance records which are not submitted to NNECO is l prescribed, as applicable, for nuclear grade procurements. i l

4.2.3 SEL'ECTION OF PROCUREMENT SOURCES I The vendor is specified during the procurement process based i upon the vendor approval status, qualifications and capabilities to ,

provide the product or service, performance history, and NNECO's ability to verify the quality of the product or service being purchased. NNECO maintains an approved vendors list based upon the technical and quality capability as determined by

[V.) a direct evaluation of the vendor's facilities and personnel and the implementation of the vendor's quality assurance program.

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

Procurement documents are reviewed by Nuclear Materials and Document Management to assure appropriate quality assurance requirements are specified. The requirements include, as necessary, audits, surveillances, or inspections at the vendor's facilities with scheduled witness / hold points during the fabrication

' process and/or prior to shipment of the procured items.

Acceptance inspections and tests determined by NNECO shall be performed after receipt at Millstone Power Station but prior to installation in the plant or prior to the point when the installation is declared operational. l

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5.0 PROCEDURES. INSTRUCTIONS AND DRAWINGS O

5.1 GENERAL REQUIREMENTS This NUQAP provides measures for the preparation, review, approval, control and distribution of procedures, instructions and drawings for activities affecting quality structures, systems, and components of the Millstone Station nuclear power plants. The documents include appropriate quantitative and qualitative acceptance criteria which specify the activity to be performed, the methods of fabrication, construction, and testing to be employed; the materials, equipment or parts to be used; a sequence of operation, and the required documentation.

5.2 IMPLEMENTATION Quality procedures provide direction for personnel performing quality activities.

The Nuclear Oversight Department reviews and concurs with other department quality procedures which implement this NUQAP as described in Section 5.2.1 below. Comments concerning compliance with this NUQAP and regulatory requirements are resolved prior to issuance of the procedure. Any vendors utilized to perform quality activities for the Station nuclear power plants may be delegated responsibility for preparing, maintaining, issuing and verifying the implementation of appropriate program documents which are selectively reviewed / approved by the appropriate Director or Responsible Engineer. Audits, surveillances, and y inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for compliance with procedures and instructions Vendor quality assurance programs are required to clearly delineate the actions to be accomplished in the preparation, review and control of procedures, instructions and drawings and the methods for complying with 10 CFR 50, Appendix B. l 5.2.1 PROCEDURES AND INSTRUCTIONS Procedures and instructions for activities affecting quality are prepared, reviewed, and approved in accordance with written procedures and instructions.

The cognizant Director or responsible engineer assures that any vendors utilized to perform quality activities for the Station nuclear power plants implement quality assurance programs which contain written instructions for preparation, review and approval of procedures and instructions affecting quality. In addition, vendor quality procedures and quality control inspection procedures which are to be used for onsite activities are reviewed for concurrence by Nuclear Oversight to assure compliance with the vendors quality assurance program.

/ QAP-5.0 l Rev.: 20 Change 02 Date: 12/11/98 Page 1 of 2

NNECO is responsible for the preparation, review and approval of station and plant quality procedures. The procedures include test procedures O- and overall site administrative procedures which implement the requirements of this NUQAP. Each NUSCO/NNECO organization is also responsible for the preparation, review and approval of procedures covering quality activities in accordance with individual license requirements. The Nuclear Oversight Department reviews and concurs l with quality procedures and special process procedures. The criteria for documents requiring Nuclear Oversight review and concurrence and their identification are defined in quality procedures to assure:

a. Administrative procedures and manuals comply with this NUQAP and applicable Appendix C regulatory guides and endorsed ANSI /IEEE standards.

I

b. . Work procedures and work documents used to perform quality activities have the necessary quality assurance controls as described l in QAP 10.0, " Inspection". l l

5.2.2 DRAWINGS The design control and verification measures described in QAP 3.0, I

" Design Control", are applicable for the review and approval of drawings.

Review and approval of new drawings or modifications to existing Q

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drawings are described in NUSCO/NNECO procedures. The originating organization may delegate to other organizations or departments the work of design and review acovities, or any part thereof, but retains responsibility for this work.

The measures taken to assure the preparation of as-built drawings and related documentation in a timely manner to accurately reflect the actual ,

plant are described in NUSCO/NNECO procedures. Drawings critical to I operation are updated prior to system turnover to operation and are available to the operating personnel. j 5.2.3 ACCEPTANCE CRITERIA Cognizant Department Heads review and approve departmental pro'cedures, instructions and drawings to assure the inclusion of adequate quantitative and qualitative acceptance criteria, as appropriate, for determining satisfactory work performance and quality compliance for applicable quality activities.

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6.0 DOCUMENT CONTROL 0

6.1 GENERAL REQUIREMENTS

.This NUQAP provides measures to assure controlled distribution of documents pertinent to quality activities performed for the Millstona Station nuclear power plants in accordance with quality procedures.

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

Approved controlled documents are distributed to affected locations in accordance with controlled distribution lists. Changes to controlled documents are reviewed and approved by the same organization which performed the original review and approval, unless otherwise specified in the applicable procedures. Measures are ,

provided for controlling documents to preclude the possibility of use of outdated documents.  !

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

4 l

a. Design Specifications;
b. Design, Manufacturing, Construction and Installation Drawings;
c. As-Built Documents;
d. Quality Assurance Program Manuals, Procedures and Instructions;
e. Manufacturing, Inspection and Testing Instructions;
f. Test Procedures; 4
g. Calculations;
h. Engineering Record Correspondence;

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i. Design Basis Documentation Summaries (DBDS)

J. Final Safety Analysis Reports;

k. Procurement Documents;
l. Design Change Records;
m. TopicalReport; i
n. NonconformanceReports;
o. ComputerCodes.

i NUSCO/NNECO procedures describe the measures taken by the l Nuclear Oversight Department or individuals other than the person who I generated the doeurnent but qualified in quality assurance for the control of documents to assure review and concurrence, as necessary, for such documents listed above with regards to quality assurance aspects. i I

The requirements for control of procurement documents are contained in ,

QAP 4.0, " Procurement Document Control". It is the responsibility of l

. each organization issuing controlled documents to employ document l (s control procedures. The issuing organization is additionally responsible for distribution of the documents to appropriate locations. There shall be ;

provisions to assure that approved changes are included in instructions, '

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

Any vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementing measures for review, approval, control and distribution of controlled documents to assure they are effectively complying with the requirements for document control.

Audits, surveillances, and inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for document '

control.

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NUSCO/NNECO procedures specify in what manner controlled G documents, and revisions thereof, are distributed to appropriate locations b prior to commencing the work.

6.2.3 DRAWING CONTROL Station Nuclear Document Services is responsible to implement a program, through applicable procedures, for the retention and retrieval of drawings and records submitted by cognizant NUSCO/NNECO personnel. Station Nuclear Document Services maintains a drawing status file which includes drawings newly issued or revised with the latest revision and current status.  ;

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

Audits, surveillances, and inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for control of drawings.

6.2.4 PROCEDURE AND INSTRUCTION CONTROL Nuclear Oversight performs audits, surveillances, and inspections, as appropriate, to verify that NUSCO/NNECO Departments are effectively complying with this NUQAP and procedural requirements, for control of  !

procedures and instructions. Audits, surveillances, and inspections are performed, as appropriate, to verify vendors utilized to perform quality activities are effectively complying with their quality assurance program requirements for control of procedures and instructions.

The originating department is responsible for establishing adequate control over quality procedures and instructions issued by them. The responsible organization also issues status reports or revised indices listing the latest revision of applicable controlled documents issued by the~m.

QAP-6.0 Rev.: 20 Change 02 Date: 12/11/98 Page 3 of 3

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j 7.0 CONTROL OF PURCHASED MATERIAL. EQUlPMENT AND SERVICES lO 7.1 GENERAL REQUIREMENTS This NUQAP provides measures for the control of purchased material, equipment, parts and services utilized in quality activities for the Millstone Station nuclear power plants to assure conformance to procurement documents. These measures include provisions for source evaluation and selection, submission of objective l evidence by the vendor or subvendors, inspection at the vendor facility, and l acceptance inspection and testing of the product upon delivery. Control of quality

! by vendors and their subvendors is assessed for effectiveness at intervals

! consistent with the importance, complexity and quantity of the product or service.

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

1 7.2.1 VENDOR QUALIFICATIONS

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

a. Audits performed by Nuclear Oversight or Nuclear Materials and Document Management and/or coordinated review of \

potential vendar utilizing one or more departments (i.e.,

Engineering, Nuclear Work Services, Operations and/or purchasing);

b. Other utility vendor audits and evaluations;
c. Nuclear Procurement issues Committee (NUPIC) audits; i
d. ASME N, NA, NPT, NV, or MM/ MS Certificate of Authorization; l 1
e. Commercial grade surveys and/or coordinated review of a potential vendor utilizing one or more departments, (i.e., Engineering, Nuclear Work Services, Operations and/or Purchasing);

j f. Source inspection / surveillance.

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

Nuclear Materials and Document Management is responsibla for assuring that documented evidence 'of the evaluation and acceptance of the I vendor's quality assurance program is maintained. The determination of  ;

vendor approval is based on such factors as prior performance, quality performance data, audits, commercial grade surveys, surveilances and evaluations of the vendor's quality assurance program.

Vendor Certificates of Conformance are periodically evaluated by audits, commercial grade surveys, surveillances, independent inspections and tests, to assure they are valid. This verification of Certificates of  ;

Conformance is documented. i i

i 7.2.2 SOURCE INSPECTION Nuclear Materials and Document Management is responsible for the i

performance of source inspections at vendor facilities to assure that the requirements of a purchase order / contract have been met. l Source inspections are performed in accordance with procedures which provide for the method of inspection, the extent of documentation l

required and those responsible for implernenting those instructions.

Inspection of items occurs ei Ser when verifications of procurement

! requirements cannot be determined upon receipt or the vendor quality assurance program has not been accepted by Nuclear Materials and Document Management.

7.2.3 RECElPT INSPECTION Receipt inspection for procured items is performed by Nuclear Materials and Document Management in accordance with quality procedures which delineate requirements and responsibilities necessary to perform inspection functions. The exception to this is Reactor Engineering performing receipt inspection for new fuel assemblies in accordance with quality procedures. Contractual obligation fulfillment and specified requirements are verified during receipt inspections.

l i Receipt inspection of vendor-furnished material, equipment, and parts is l performed to assure that these items and acceptance records are examined in accordance with predetermined inspection instructions prior to acceptance, installation and operation. Receipt inspections include, as appropriate:

QAP-7.0 Rev.: 20 Change 02 i Date: 12/11/98 Page 2 of 4 i

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a. Measures for verifying that the shipment is complete, properly

(~'N identified, undamaged and corresponds with the required

(,/ documentation; l

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

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c. Measures for inspection and acceptance of items in accordance with predetermined methods; j
d. Measures for identifying and controlling acceptable items including identification of inspection status prior to release from the receiving inspection area; 1
e. Measures for identifying, segregating and handling nonconforming '

items; i

f. Measures to ascertain that inspection records or Certificates of I Conformance are acceptable prior to release for installation;
g. In cases involving purchased services, the responsible engineer or Department Head shall designate the means by which services may be accepted, and is given the authority to accept services in accordance with methods defined in NUSCO/NNECO procedures.

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v 7.2.4 VENDOR FURNISHED RECORDS  :

Records required to be furnished by the vendor are specified in the procurement documents. Certifications or documentation provided by the vendor which attests to conformance, identifies that all the specific procurement requirements have been met (either by reference to the purchase order or by delineation).

The vendor must furnish the following records as a minimum for nuclear I grade purchases:

I

a. Documentation that identifies the purchased material, equipment, or l parts and the specific procurement requirements (e.g., codes, standards and specifications)which have been met by the items;
b. Documentation that identifies any procurement requirements which have not been met, together with a description of those Nonconformances dispositioned " accept as is" or " repair."

l The responsible Nuclear Materials and Document Management and/or engineering and other appropriate department personnel shall review for (h

(,) OAP-7.0 Rev.: 20 Change 02 Date: 12/11/98 Page 3 of 4 j l

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

acceptability those documents which pertain to the requirements in the

/ procurement document, in accordance with this NUQAP and applicable

(]> procedures.

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

~' 2. 5 COMMERCIAL DEDICATION NNECO procedures address the measures taken to assure that for commercial grade items, where specific quality assurance controls for nuclear applications cannot be imposed in a practicable manner, that special dedication requirements are established and implemented.

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

Th measures include appropriate requirements for special caLo rization and identification within the procurement document,

f receiving inspection, and additional controls during the installation and testing process to be performed by Nuclear Materials and Document

Management, other NUSCO/NNECO Departments, or other appropriate groups.

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8.0 IDENTIFICATION AND CONTROL OF MATERIALS PARTS AND COMPONENTS A

8.1 GENERAL REQUIREMENTS This NUQAP provides measures for the identification and control of materials, parts and components, including partially fabricated assemblies utilized in quality activities for the Millstone Power Station. To assure that each item can be traced to associated documentation, the identification of the item is maintained by heat number, lot number, part number, senal number, or other appropriate methods, and is physically marked on the item and/or on records traceable to the item. Documentation associated with materials, parts, and components delineate that these items have been designed, fabricated, manufactured, tested and/or inspected in accordance with the specified requirements.

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

These measures also require NNECO assure that the identification of inspections, tests, and operation status of structures, systems, and components is known to affected organizations, 8.2 IMPLEMENTATION l

NNECO procedures establish the responsibilities and requirements for the identification and control of materials, parts and components. The procedures assure that identification and control are maintained throughout fabrication, receipt, handling, storage and

,\

(d installationofitems. Provisionsinclude:

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a. Requirements for traceability to appropriate documentation such as: purchase orders, contracts, manufacturing documents, drawings, specifications, certifications, inspection and test records, and nonconformance reports;
b. Controls to assure that the correct identification of an item is verified and documented prior to release for fabrication, assembly, shipping or installation;
c. Requirements which assure that the method or location of markings do not affect l the function or quality of an item;
d. Establishment of identification requirements in purchase orders, contracts, specifications, drawings, procedures or instructions.

During the performance of quality activities for the Station nuclear power plants, NNECO may de!egate any portion of the implementationof the identification and control program to a vendor. If delegated, contracts require that the vendor establish an identification and control program which meets this NUQAP requirements. Audits, surveillances, and inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for identification and control of materials, parts and components.

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,- Receipt inspections are performed to verify that materials, parts and components are l properly identified in accordance with procurement requirements. Nuclear Materials and Document Management is responsible for assigning and applying necessary identification to the items in accordance with applicable procedures to assure proper identification and traceabiltiy.

In the avent.that materials, parts or components are nonconforming or the identification becomes lost or illegible, the items are considered nonconforming and are identified and controlled in accordance with QAP 15.0, " Nonconforming Materials, Parts, Components, or Services".

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QAP-8.0 i

Rev.:20 Change 02

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1 9.0 CONTROL OF SPECIAL PROCESSES 9.1 GENERAL REQUIREMENTS This NUQAP provides measures to assure the control of special processes associated with quality structures, systems, and components of the Millstone Station nuclear power plants by the use of qualified procedures, equipment and personnel.

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

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

O NUSCO/NNECO special process procedures utilized during quality activities for the )

Q Station nuclear power plants are prepared, reviewed and approved in accordance with procedures as specified in QAP 5.0, Procedures, instructions, and Drawings".

9.2.1 PROCEDURE QUALIFICATION AND CONTROL NUSCO/NNECO procedures specify that written process control documents are utilized and qualified, as required, in accordance with the applicable specification, codes or standards.

9.2.2 PERSONNEL QUALIFICATION AND CERTIFICATION 1

Codes, standards and NUSCO/NNECO procedures specify personnel l qualification / certification requirements. Personnel responsible for the performance and verification of special processes are trained, tested, and certified as required by applicable specifications, codes and standards.

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

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

The Nuclear Oversight Department is responsible for assuring the training, testing, and certification of all the Millstone Power Station NU NDE personnel is in accordance with the requirements of Regulatory Guide 1,58 (Rev.1, 9/80) and ASNT Recommended Practice No. SNT-TC-1 A.

1 9.2.3 SPECIAL PROCESS RECORDS ,

Records provide objective evidence that special processes were performed in accordance with applicable procedures, by qualified personnel, and that when required by procedures, specifications and codes, such performance was verified. Results of nondestructive examinations are recorded in accordance with applicable specifications, codes and standards. These records are retained by the vendor or supplied to NNECO as required by contract or purchase order. If records are to be retained by the vendor, the contract or purchase order specifies the retention period and instruction for final disposition of records.

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

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10. INSPECTION

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10.1 GENERAL REQUIREMENTS This NUQAP provides measures to assure that inspections of Millstone Station nuclear power plants quality structures, systems, and components to verify conformance with documented procedures, instructions and drawings are executed in accordance with procedures by qualified personnelindependent from the individual or group performing the activity being inspected. If inspection is impossible or disadvantageous, indirect controls by monitoring processing methods, equipment and personnel are provided. Inspection notification and hold points are identified, as required,in the applicable documents.

10.2 IMPLEMENTATION 10.2.1 INSPECTION RESPONSIBILITIES During the performance of quality activities for the Station nuclear power plants, procedures shall define the need for inspection (e.g., receipt inspection, .

installation, and product acceptance) to assure quality requirements are met. j i'

Nuclear Oversight sha;! oerform, as appropriate, audits and surveillances as defined in Nuclear Oversight procedures to verify that procedural requirements l l

are met.

Q, The Nuclear Oversight Department shall perform inspections of modification and maintenance activities for quality structures, systems, and components. The criteria used to determine when Nuclear Oversight inspection shall be required for these activities and for the preparation of inspection plans shall be identified in Nuclear Oversight procedures. The Nuclear Oversight inspection function includes:

a. Identification of inspection personnel;
b. Review of work procedures and work documents for adequacy of inspection and mandatory hold points;
c. Preparation and approval of inspection plans ensuring that the necessary inspection requirements, methods, and acceptance criteria have been identified;
d. Documentation of inspection results.

Audits, surveillances, and inspections, are performed as appropriate, to verify l that any vendor utilized to perform quality activities for the Station nuclear power plants are effectively complying with their quality assurance program

! requirements for inspection and for the performance or witnessing of inspections

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at hold or notification points identified in procurement documents. Nuclear 7 Oversight performs audits, surveillances, and inspections, as appropriate, of (V onsite vendor activities in this area. All audit, surveillance, and inspection activities are performed under requirements specified > c Jality procedures. l 10.2.2 INSPECTION PLANS Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans are based on design specifications, procurement documents, drawings, other specifications, or previous experience, as appropriate.

During the performance of quality activities, procedures provide criteria for the determination of accuracy requirements of inspection equipment and when inspections are require'1 These procedures describe requirements for the preparation of inspection plans by the Nuclear Oversight Department. Audits and surveillances are performed by the Nuclear Oversight Department, as appropriate, to verify the implementation of the inspection plans.

The inspection criteria, including the use of inspection equipment and their l

accuracy requirements, are specified in the work procedures, work documents, or inspection plans.

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n 10.2.3 INSPECTION PERSONNEL AND INSPECTION DOCUMENT ACCESS f  !

Inspections are performed by individuals other than those who performed or directly supervised the activity being inspected. Inspection personnel are qualified and/or certified in accordance with appropriate codes, standards, and/or NU training programs; Inspections are performed by Nuclear Oversight Department personnel, qualified contracted personnel, and NUSCO/NNECO personnel who are independent from

undue pressure such as cost, or schedule considerations. Nuclear Oversight shall

! assure the certification of its contracted inspection personnelis acceptable prior to the performance of inspection activities. When other departments are contracting for onsite quality assurance inspection services, these departments shall be responsible for the review and acceptability of personnel / equipment certification j

prior to the start of inspection activities. Nuclear Oversight shall perform audits l and surveillances, as appropriate,to verify other department compliance with these l requirements.

When vendors are contracted to perform onsite inspection services, their quality controlinspection plans / procedures are reviewed and concurred with by Nuclear Oversightin accordancewith QAP 5.0," Procedures, Instructions,and Drawings".

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l Access to drawings, procedures, specifications or other documented criteria I l ,n necessary for the performance of inspections is provided prior to performing the l

C) inspection activity.

10.2.4 INSPECTION PROCEDURES l Required inspection or surveillance activities are performed and documented i according to procedures and/or checklists. inspection procedures, plans or I checklists contain the following:

1

a. Identification of characteristics to be inspected; l 1
b. Identification of the individual or groups responsible for performing the inspections;
c. Requirements for the necessary measuring and test equipment and the required accuracy of this equipment;
d. Acceptance criteria;
e. A description of the method of inspection when other than direct visual examination using the unaided eye;
f. A record of the results of the inspection; (

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()) g. Record of inspector or data recorder. l l

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

Modification, repair, replacement, or rework items are inspected in accordance )

with original inspection requirements or approved alternatives.

10.2.5 MANDATORY HOLD AND NOTIFICATION POINTS Mandatory hold points are utilized when an inspection or operation must be performed or witnessed and signed off by the responsible personnel before work can proceed. Mandatory hold points are identified to assure attributes critical to achieving quality requirements at work completion have been verified.

Mandatory notification points are used to identify the operations or completed processes that NNECO or its representatives may elect to witness and/or inspect during the fabrication, construction and installation process. Mandatory hold points and notification points, as required, are identified in procurement ,

documents and onsite work procedures / work documents. Procurement documents and onsite work procedures / work documents are subject to the l review and concurrence for adequacy of inspection, notification and/or l

(h Q) QAP-10.0 Rev.: 20 Change 02 Date: 12/11/98 Page 3 of 4

mandatory hold controls by Nuclear Materials and Document Management and Nuclear Oversight, respectively.

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

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

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

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11.0 TEST CONTROL i

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

The test control program identifies the quality structures, systems, and components to be tested, method of conducting tests, evaluation of tests and documentation of tests by qualified personnelto assure requirements have been satisfied.

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

11.2 IMPLEMENTATION 11.2.1 TEST PROGRAM

(] Test requirements to determine or to verify the capability of an item to meet

(/ specified requirements in accordance with design documents, Safety Analysis Reports (SAR), Technical Specifications, procedures or procurement documents, as appropriate, are accomplished by subjecting the item to a set of physical, chemical, environmental or operating conditions. Tests following repair, rework, replacement, preventive maintenance or modification is performed, as required, in accordance with the original design requirements of the item or acceptable alternatives, as applicable. A Test may be repeated when original test results j are invalidated. j NUSCO/NNECO procedures delineate the methods and responsibilities for j controlling, accomplishing and documenting testing of the Station nuclear power  !

plants quality structures, systems, and components.  !

l Vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementing measures for the control of tests to assure that materials, equipment and parts used in quality structures, systems, and components will perform satisfactorily. Audits, surveillances, and inspections, are performed as appropriate, to verify the performance of selected proof tests when hold points have been identified in purchase order / contracts and to verify

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l these vendors are complying with their quality assurance program requirements

(] for test control. Nuclear Oversight performs audits, surveillances, and (j inspections, as appropriate, of onsite vendor activities in this area. Nuclear Materials and Document Management and Nuclear Oversight are responsible for  !

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

Proof tests, product acceptance tests, post maintenance or modification tests, and periodic surveillance tests are conducted by qualified personnel in accordance with applicable procedures. Personnel performing tests assure that calibrated equipment and instrumentation utilized are within the calibration 1 interval specified. Documentation including test procedures and approved data I sheets are maintained in appropriate files until forwarded to the Station Nuclear  !

Records Facility in accordance with applicable procedures. l 11.2.2 TEST PROCEDURE PREPARATION AND TEST PERFORMANCE Testing is accomplished in accordance with approved test procedures which incorporate or reference the requirements and acceptance criteria in the applicable design and procurement documents. The test procedure or test program documents include the following as a minimum:

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a. Instructions for the testing method used;
s. > b. Required test equipment and instrumentation;
c. Test requirements, such as acceptance criteria;
d. Hold, notification, inspection points,if required, and data collection points;
e. Test prerequisites such as: calibrated instrumentation; trained, qualified, and licensed or certified personnel; preparation, condition and completeness of item to be tested; suitable and controlled environmental conditions;
f. Methods for documenting or recording test data and results;
g. Provisions for data collection and storage, f3

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11.2.3 TEST EQUIPMENT NUSCO/NNECO procedures provide the criteria for determining when a test is required and the accuracy requirements of test equipment. The following steps are taken for the control of test equipment: i

a. To assure accuracy, test equipment is checked and calibrated in accordance with NUSCO/NNECO procedures;

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b. Plant instrumentation used in testing is calibrated. It is maintained in calibration at regular intervals in accordance with established surveillance ,

and/or preventative maintenance procedures;

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

11.2.4 EALUATION OF TEST RESULTS The documented test results are evaluated against the predetermined acceptance criteria by an individual or group having appropriate qualifications.

The acceptance status of the test is documented. Deficiencies noted during the evaluation are documented and dispositioned in accordance with procedures.

The evaluation of test _ results may also be delegated to vendors. When delegated, the vendor is required to assure the use of qualified personnel, evaluate the data against predetermined criteria and document the results of the evaluation and acceptance status of the test. Audits, surveillances, and inspections, are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for test control. Nuclear Oversight performs audits, surveillances, and inspections, as appropriate, of onsite vendor activities in this area. l QAP.11.0 Rev.: 20 Change 02 Date: 12/11/98 Page 3 of 3

12.0 CONTROL OF MEASURING AND TESTING EQUIPMENT p

'v 12.1 GENERAL REQUIREMENTS This NUQAP provides measures for the control of measuring and testing equipment (M&TE) used as the basis for acceptance during inspection, testing, and measurement of materials, equipment, and parts affecting quality structures, systems, and components. Periodic calibration and adjustment of M&TE is performed and controlled to assure accuracy is maintained within limits necessary to verify that design and operating condition requirements have been met. Documentationis retained such that allitems of M&TE are traceable to their calibration records.

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

Documentation associated with the calibration of all M&TE is maintained in appropriate files and retained as quality records in accordance with the NU Nuclear 7 Records Program. When the information for the control, use, and calibration of

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M&TE is in electronic form, this information is controlled and protected in accordance with applicable procedures.

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

Department Heads / Job Supervisors are responsible to assure that M&TE is calibrated, issued, and controlled in accordance with the requirements of applicable procedures.

The Nuclear Oversight Department performs audits, surveillances, and inspections, as appropriate, to verify implementation of the calibration program.

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Vendors utilized to perform quality activities for the Station nuclear power plants are

( ) responsible for implementing measures for the control of M&TE to assure the M&TE U are properly calibrated, adjusted and maintained at specified intervals in order to maintain accuracy within required limits. Audits, surveillances, and inspections, are performed, as appropriate, to verify these vendors are effectively complying with their quality assurance program requirements for control of M&TE.

12.2.2 CAllBRATION STANDARDS Measuring and test equipment is calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement. Measuring and test equipment shall be permanently marked or tagged with a unique Identification number and the date calibrated and next calibration date indicated on the M&TE.

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

Calibration of this equipment should be against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated. When this is not possible, the standards shall have an accuracy that assures the

, equipment being calibrated shall be within required tolerance and the basis of

' acceptance is documented and authorized by the SORC/PORC. In addition, the calibrating standards shall have greater accuracy than secondary standards being calibrated. Calibrating standards with the same accuracy may be used if they can be shown to be adequate for the requirements and the basis of acceptance is documented.

12.2.3 "OUT OF TOLERANCE" CONTROL M&TE and reference standards when found out of tolerance are so identified and removed from service. A timely review is conducted to determine the validity of previous inspection or test results gained through use of the instrument, and of the acceptability of items previously measured or tested. Where it is determined that use of out of tolerance measuring and test equipment may have resulted in a condition adverse to quality, the condition is promptly identified and corrective action is implemented in accordance with OAP 15, " Nonconforming Materials, Parts, Components or Services" and QAP 16, " Corrective Action" respectively as appropriate.

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13.0 HANDLING. STORAGE AND SHIPPING O

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

R2 IMPLEMENTATIOa 13.2.1 GENERAL Procedures, instructions and procurement documents define the requirements and responsibilities for the handling, storage, shipping, cleaning and preservation of materials, equipment, and parts required for implementstion of established design and specification requirements.

Handling, storage, shipping, cleaning and preservation of materials, equipment and parts is conducted in accordance with applicable procedures and procurement documents. Vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementir.g measures for handling, storage, shipping, cleaning and preservation of materials, equipment g and parts to preclude damage, loss or deterioration. Audits, surveillances, and inspections, are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for handling, storage shipping, cleaning and preservation of materials, equipment and parts. l 13.2.2 ESTABLISHMENT OF SPECIAL HANDLING. STORAGE. SHIPPING.

CLEANING AND PRESERVATION REQUIREMENTS Special or additional handling, storage, shipping, cleaning and preservation requirements are to be identified and implemented as specified in procurement documents and applicable procedures. These established requirements are consistent with the regulatory positions of the NRC regulatory guides and their endorsed ANSI standards listed in Appendix C, or specifications and/or vendor technical manuals, and shall be consistent with accepted industry standards.

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

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

14.2 IMPLEMENTATION 14.2.1 GENERAL Vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementing approved measures for the identification of inspection and test status of quality material, equipment and parts to preclude the bypassing of requirements. Audits, surveillances, and inspections, are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for identification of inspection and test status. Elements of this system require that vendors have a controlled l fabrication and test operation in order to preclude the inadvertent bypassing of l

process inspections or tests, and to provide a positive identification of component status throughout all phases of fabrication, testing, and inspection by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other appropriate methods. l When receipt inspections are performed at the Station, Nuclear Materials and Document Management assures that traceability is maintained for acceptable quality materials, equipment and parts to indicate conformance to purchase order / contract requirements with the exception of nuclear fuel assemblies, for which traceability is maintained by Reactor Engineering. Nonconforming materials, equipment and parts are identified in accordance with QAP 15.0, "

l Nonconforming Materiab, Parts, Components, or Services".

During tests and inspections of the Station nuclear power plants, a status tagging system is implemented by procedure to prevent inadvertent operations of quality structures, systems, and components.

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

l original review and approval of tests, inspections and other operations.

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l 14.2.2 STATUS IDENTIFICATION AND CONTROL Procedures and instructions describe control of the application and removal of l markings such as stamps, tags, labels, and other suitable means to indicate the l status of quality structures, systems, and components to prevent inadvertent operation, and to preclude omission of inspections,-tests or other critical I operations. These procedures and instructions delineate the requirements, '

methods and responsibilities for indicating the status of the affected items. The status of allitems requiring calibration is recorded and maintained in accordance with applicable procedures.

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

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16.0 CORRECTIVE ACTION I

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U 16.1 GENERAL REQUIREMENTS This NUQAP requires that an effective corrective action program be established to assure that conditions adverse to quality at the Millstone Power Station are promptly identified, corrected, and documented in accordance with procedures. These procedures include measures for reporting to appropriate levels of management and determining the root ,

cause and corrective action to preclude recurrence for conditions evaluated as significant .I conditions adverse to quality.

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

16.2.2 CORRECTIVE ACTION AND FOLLOW-UP y

Procedures describe the measures taken to evaluate if conditions adverse to quality exist and to determine the need for immediate corrective action or disposition. Vice Presidents and Recovery Officers are responsible for assuring their assigned personnel and their vendors working onsite comply with the corrective action program and for assuring that corrective action is adequate and properly implemented in a timely manner within their organization. The Nuclear Oversight Department performs audits and surveillances, as appropriate, to verify that NUSCO/NEECO departments are effectively complying with this l NUQAP and procedural requirements for the corrective action program and ,

l that corrective action is adequate and properly implemented in a timely l manner. Audits, surveillances, and inspections, are performed, as appropriate to assure that vendors comply with their corrective action program and that corrective action is adequate.

l The President and Chief Executive Officer - NU Nuclear Group has the final l authority in the event that agreement on the action to be taken is not reached at ,

lower levels of the nuclear organization.

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V(3 16.2.3 RECURRENCE CONTROL l

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

. The significance level determines the need for a root cause determination and for establishing _ the necessary action to prevent recurrence. In cases of significant conditions adverse to quality, the immediate corrective action, the cause, and recurrence control actions must be documented. Procedures establish the responsibilities and measures taken to accomplish these actions.

An analysis of adverse conditions is performed and trends which identify program / procedure problems are periodically reported to upper management, including the senior onsite and offsite nuclear officers and the senior manager responsible for measuring the effectiveness of the quality assurance program for review. Adverse trends concerning specific vendor performance shall be reported to the affected vendor for resolution and recurrence control, as I appropriate.

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17.0 c'  ?[Y ASSURANCE RECORDS O 17.1 GENERAL REQUIREMENTS This NUQAP requires the maintenance, identification, retention and retrieval of records to furnish evidence of quality activities performed for the Millstone Station nuclear power plants be implemented in accordance with procedures. These records include but are not '

limited to: operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance and material analyses. These records also include closely related data such as qualifications of personnel, procedures and equipment. Inspection and test records contain, as a minimum but are not limited to: identification of inspector or data recorder and the acceptability and the action taken in connection with any deficiencies and reportable occurrences noted. Procedures establish requirements concerning record retention such as duration, location and assigned responsibility.

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

Vendors utilized to perform quality activities for the Station nuclear power plants are responsible to implement measures for identification, maintenance, retention, retrieval and turnover to NNECO of documented and approved records which contain objective evidence of quality as specified in purchase orders / contracts. Audits, surveillances, and inspections, are performed, as appropriate, to verify that these vendors are effectively complying wiih their program for quality assurance records.

NUSCO/NNECO quality assurance records are identified, controlled and maintained in 1 appropriate files and are identifiable to specific structures, systems, and components within the Station nuclear power plants. When identification to a specific structure, system, or component is not practical, records are filed by category (e.g., specification, nonconformance reports, audits, etc.).

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17.3 RETENTION NUSCO/NNECO quality assurance records are classified as life records or non-life records as delineated by Nuclear Document Services. Non-life records are those documents that are maintained for a specific period of time other than the lifetime of a Station nuclear power plant or the particular component or part. Life records are those documents that are maintained for the lifetime of the in-service nuclear power plant or for the life of the particular component or part. In instances where more than one licensing basis document specifies a record retention requirement and they are different (e.g. QA Program commitment versus Unit Technical Specifications) the more restrictive requirement shall apply, Life records are those which would be of significant value in meeting one or more of the following criteria:

a. Demonstrating capability for safe operations;
b. Maintaining, reworking, repairing, replacing or modifying the item;
c. Determining the cause of an accident or malfunction of an item;
d. Providing required base line data for in-service inspection.

Quality assurance records are reviewed and approved by the cognizant qualified NUSCO/NNECO personnel and vendors, as appropriate, and are transmitted to the Station Nuclear Document Records Facility. The responsibility of the Nuclear Document Services Facility upon receipt of records is to maintain and provide controlled retrievability

.of records affecting the Station nuclear power plants, in such a manner as to prevent destruction of' records by fire, flood, theft, and environmental conditions, such as temperature or humidity, as delineated in applicable procedures.

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

Audits are conducted in accordance with written procedures or checklists by appropriately ,

trained personnel not having direct responsibilitiesin the areas being audited.

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

18.2 IMPLEMENTATION 1

18.2.1 PROGRAM The audit program requires audits of Corporate and Station nuclear power plant quality activities under the oversight of the Nuclear Safety Assessment Board.

f Audits are performed on activities where the requirements of 10 CFR 50, e

Appendix B and respective nuclear unit Technical Specifications are being implemented. In aodition to those activities, audits are performed on areas associated with indoctrination and training programs, interface control among NNECO and vendors, vendor qualityprograms and the Nuclear Materials and l Document Management procurement function. Audits are regularly scheduled on the basis of the status and safety importance of the activities being perfonned. Regularly scheduled audits are supplemented by audits for one or more of the following conditions: l

a. When significant changes are made in functional areas of the quality assurance program, such as significant reorganization or procedure revisions;
b. When it is suspected that the quality of the item is in jeopardy due to deficienciesin the quality assurance program;
c. When a systematic, independent assessment of program effectiveness is considered necessary;
d. When necessary to verify implementationof required corrective action.

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

, quality assurance activities are maintained by the Nuclear Materials and Document Management and Nuclear Oversight Department, as appropriate.

Audits are performed as specified in procedures by qu6ified personnel, using an audit plan prepared by the auditing organization. Audits may include evaluation ,

of the work areas, activities, processes, items, and review of documents and records to determine the effectiveness of implementation and conformance to this NUQAP.

4 Approved vendors utilized to perform quality activities for the Station nuclear l 4

power plants are responsible for developing and implementing a system of {

planned and periodic audits to verify compliance with and to determine the effectiveness of all aspects of their quality assurance program. Nuclear Materials and Document Management is responsible for verifying the acceptability of vendor audit programs. Audits, are performed as appropriate, l

. to verify that these vendors are effectively complying with their quality assurance l

. requirements. l

In addition to the audits, other methods, such as surveillances and inspections

, are used to assure that quality activities are in compliance with this NUQAP.

i l "3 18.2.2 REPORTING OF AUDIT RESULTS l

(O Audit results are reviewed, approved, and reported in accordance with Nuclear Oversight Department and Nuclear Materials and Document Management procedures, as applicable. The audit reports are issued to the appropriate management of the area audited to assure appropriate and/or timely corrective action is taken to address conditions adverse to quality identified by the audit l findings. In addition, audit data and reports are accumulated as part of the review for quality trends and assessed to assure the effectiveness of this NUQAP.

18.2.3 REVIEW. ACTION. AND FOLLOW-UP OF AUDIT FINDINGS Audit findings that involve conditions adverse to quality are reviewed and investigated by the management having the responsibility for the area audited.

The responsible management is required to take the necessary action to address an conditions adverse to quality identified by the audit and: report the results of such reviews and investigations, take the necessary actions to correct problems reported, and report the completion of corrective action within specified time frames.

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. ;w Follow-up of audit findings involving conditions adverse to qualny ' performed by

- b(~N the auditing organization as necessary to verify appropriate actions have been i taken to resolve audit findings. Items which cannot be resolved by affected .

management are submitted for resolution to the President and Chief Executive '

Officer - NU Nuclear Group.

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

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