ML20198G910

Proposed Rev 2 of Cyap QAP for Haddam Neck Plant. Marked Up Rev 1 Included

ML20198G910
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/22/1998
From:	CONNECTICUT YANKEE ATOMIC POWER CO.
To:
Shared Package
ML20198G884	List: CY-98-142, Forwards Proposed Rev 2 of Cyap QAP for Info & Approval of Exception Number 8 of App E of Cy Qap.Copy of Rev 2 Showing Changes from Rev 1 Also Included ML20198G910
References
NUDOCS 9812290194
Download: ML20198G910 (168)

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9812290194 981222 PDR ADOCK 05000213-W PDR

I e -a TABLE OF CONTENTS CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM (CYOAP)

HADDAM NECK PLANI Abstract Policy Statement Quality Assurance Program Chapters QAP 1.0 Organization; Organizational Charts QAP 2.0 . Quality Assurance Program QAP 3.0 Design Control QAP 4.0 Procurement Document Control QAP 5.0 Procedures, Instructions and Drawings QAP 6.0 Document Control QAP 7.0 Control of Purchased Material, Equipment and Services QAP 3.0 Identification and Control of Materials, Parts and Components QAP 9.0 Control of Special Processes QAP 10.0 Inspection QAP 11.0 Test Control QAP 12.0 Control of Measuring and Testing Equipment QAP 13.0 Handling, Storage, and Shipping QAP 14.0 Inspection, Test, and Operating Status i QAP 15.0 Nonconforming Materials, Parts, Components, or Services QAP 16.0 Corrective Action QAP 17.0 Quality Assurance Records QAP 18.0 Audits Appendices L

A. Category I Systems, Structures and Components B. Qualification and Experience Requirements, Vice l' resident - Operations and Decommissioning i

C. Regulatory Guide and ANSI Standard Commitmenis D. Glossary of Quality Assurance Temis E. Program Exceptions F. CYQAP Administrative Controls l

i TABLE OF CONTENTS i CYQAP l REV: 02

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l CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT ABSTRACT l

Connecticut Yankee Atomic Power Company (CYAPCo)has developed and is implementing a comprehensive Quality Assurance Program for the lladdam Neck Plant (IINP) to assure confbrmance with established regulatory requirements as set fbrth by the Nuclear Regulatory l Commission (NRC). The participants in this Quality Assurance Program assure that the maintenance and modification of the Haddam Neck Plant is performea in a safe and efTective l manner.

This Connecticut Yankee Quality Assurance Program (CYQAP) complies with the requirements set forth in 10 CFR 50 Appendix B, along with applicable sections of the Safety Analysis Report (SAR), and is responsive to the NRC Regulatory Guide 1.70, that describe the information required to be presented in the Quality Assurance Section of the SARs for nuclear power plants.

This CYQAP is also established, maintained and executed for Radioactive Material Transport Packages as allowed by 10 CFR 71.101(f).

l This CYQAP applies to the safety functions of systems, structures, and components and are l considered quality activities as defined in the CYQAP. Safety Systems, Structures and l Components are discussed in Appendix A herein. Applicability of Appendix A te the CY Updated Final Safety Analysis Report (UFSAR) is addressed by the specific design bases and licensing commitments. Portions of the CYQAP are also applicable to the Fire Protection Quality Assurance l (FPQA), the Radwaste Quality Assurance (RWQA), and Spent Fuel Quality Assurance (SFQA) l programs.

l This CYQAP is committed to utilize the guidance obtained from the regulatory documents and I their endorsed standards as referenced in Appendix C.

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4 POLICY STATEMENT OUALITY ASSURANCE PROGRAM CYAPCo has established a Quality Assurance Program for the Haddam Neck Plant. This QA program has been developed to achieve quality assurance in all activities affecting the safe operation / decommissioning of the Haddam Neck Plant.

The program described herein is the Connecticut Yankee Quality Assurance Program for the Haddam Neck Plant. The policies, requirements and tasks contained in this program description have been developed to achieve a recognized need for quality assurance for maintenance and modification activities during the decommissioning of the HNP to ensure that adequate quality requirements are being complied with to safeguard employees (CYAPCo and contract)and the public. l I

CY procedures which implement the program at the Haddam Neck Plant are developed and approved in accordance with Connecticut Yankee administrative procedures.

The CYQAP is responsive to applicable codes, Nuclear Regulatory Commission regulatory requirements, accepted industrial standards and revisions thereto. Provisions are established to update the CYQAP in accordance with revisions to codes, standards and regulatory requirements and to inform cognizant personnel to implement appropriate action to assure that the highest standard of quality is achieved for systems, structures, components and services for the HNP.

The controls which implement the actions identified in the CYQAP are station and departmental l procedures and instructions which delineate actions and steps necessary to accomplish quality requirements. Procedures and instructions are written by company groups, divisions, departments, branches, or sections, which have the responsibility for implementing actions assigned to them as delineated by the CYQAP.

The development and overall responsibility for this Quality Assurance Program lies with the j Chairman, Chief Executive Officer and President. Corporate authority is delegated to the Vice President - Operations and Decommissioning for the preparation and administration of the Connecticut Yankee Quality Assurance Program (CYQAP). The Vice President - Operations and Decommissioning for Connecticut Yankee and the CY Directors are responsible for the l implementation of the Quality Assurance Program within their Departments.

POLICY STATEMENT ill CYQAP j

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4 QAP 1.0 ORGANIZATION

1.1 INTRODUCTION

THE CHAIRMAN, ClllEF EXECUTIVE OFFICER, AND PRESIDENT OF CYAPCO HAS THE ULTIMATE RESPONSIBILITY FOR THE HADDAM NECK PLANT.

1.2 PROGRAM RESPONSIBILITY

1.2.1 The Chairman, CEO and President has overall responsibility for the development of the CYQAP for the Haddam Neck Plant. While retaining full responsibility and overall authority, the Chairman, CEO and President I has delegated corporate authority for the preparation and administration of l the CYQAP to the Vice President - Operations and Decommissioning.

(See Figure 1-1) 1.2.1.1 The Chairman, CEO and President maintains contact with the quality assurance activities through meetings with the Vice President -

Operations and Decommissioning, and, the receipt of various documents, such as: periodic progress reports, Nuclear Safety Assessment Board meeting notes, and audits related to CY's nuclear program implementation at the Haddam Neck Plant.

1.2.1.2 The Chairman, CEO and President resolves all disputes related to the l l implementation of this CYQAP for which resolution is not achieved at the appropriate organizational levels within the nuclear organization.

1.3 GENERAL RESPONSIBil ITIES 1.3.1. The head of each CY department performing quality activities is responsible for:

a. Administering those activities within their organization which are required by the CYQAP;

b. Ensuring implementation of the CY Quality Assurance Program;

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

d. Planning, selecting, and ensuring that personnel are trained to meet the requirernents of the CYQAP; and

e. Performing and coordinating quality activities within their l organization and interfacing with the CY Oversight organization as l

required in program implementation.

QAP 1.0 1 CYQAP REV: 02 l

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l 1.3.2. Each individual performing or verifying activities affecting quality is responsible to conduct those activities in accordance with the requirements of l

the CYQAP and implementing procedures.

l 1.3.3 The responsibility, authority, and organizational relationship for perfonning

! quality activities within each organization is established in CY organizational charts, policy statements, and written job or functional descriptions. j 1.4 ORGANIZATION CONNECTICUT YANKEE AT Tile IIADDAM NECK PLIANT l The Chairman, CEO and President reports to the CYAPCo Board of Directors. lie has overall responsibility for the development and implementation of the CYQAP.

Employee Concerns is responsible for the direction and administration of the Employee Concerns Program for CYAPCo. The position assures that nuclear safety concerns receive appropriate management attention and that concerns are addressed in a timely manner. The Chairman, CEO and President has delegated the necessary authority and has assigned responsibility for development and implementation of the CYQAP for the liaddam Neck Plant to the Vice President - Operations and Decommissioning. (See Figure 1-1). I 1.4.1 The Vice President - Operations and Decommissioning responsibilities include:

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a. Direction of the CY Quality Assurance Program; I

b. Implementation of policies and procedures:

c. Verifications through a planned program of audits, surveillances, and inspections to assure compliance with 10 CFR 50, Appendix B and other I regulatory requirements; and l

d. The implementation of the CYQAP requirements.

The Vice President - Operations and Decommissioning has the overall responsibihty to implement the CYQAP at the IINP and in providing support services to the operating staff. The Vice President - Operations and Decommissioning is responsible for the IINP's safe operation and has control over those support activities necessary for safe operation, maintenance and deconunissioning of the plant.

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QAP 1.0 2 CYQAP j REV: 02

The Vice President - Operations and Decommissioning provides management l with objective evidence of the performance of activities affecting quality, independent of the individual or group directly responsible for performing the specific activity. This individual has the authority and organizational freedom l to verify activities affecting quality. This is performed independent of undue influences and responsibilities for schedules and costs through the Manager -  !

CY Oversight. The Manager - CY Oversight has the responsibility and authority, delineated in writing, to stop unsatisfactory work and control further processing, delivery, or installation of nonconforming materials. The i individual also has the responsibility and authority to identify quality I problems, to recommend or provide solutions, and to verify their implementation.

The Vice President - Operations and Decommissioning is also responsible for the Industry Experience Program and the Audit Program.

1.4.1.2 Manaecr- CY Oversight The Manager - CY Oversight manages the audit, surveillance and inspection activities of the HNP.

Responsibilities include:

a. Directing and Administering Oversight's program for  :

audits, surveillances and inspections; ,

b. Verifying compliance with 10 CFR 50, Appendix B and other regulatory requirements;

c. Verifying the implementation of the CYQAP requirements;

d. Evaluating performance and identification of strengths and weaknesses-i

e. Providing recommendations for improving nuclear l

performance at the HNP;

f. Serving as the primary CY Oversight management l interface with HNP management; and

g. Stopping unsatisfactory work. l

h. Administering the Corrective Action Program.

The Manager - CY Oversight is an active participant on the CY Nuclear Safety Assessment Board.

QAP 1.0 3 CYQAP REV: 02 l

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l The Manager - CY Oversight has direct communication with the CY Staff, Directors, the Vice President - Operations and Decommissioning and the Chairman, CEO and President and provides the daily interaction on matters afTecting quality, nuclear safety, and nuclear related activities.

1.4.3 Unit Director The Unit Director is responsible for the direction and administration l of the unit's Operations, Mechanical, Electrical, and I&C, Technical Specification Surveillance Planning and Scheduling, Security, Engineering Programs, Training and Emergency Planning. The Plant Operations Review Committee (PORC) reports to the Unit Director in compliance with Technical Specifications.

1.4.4 Ilecommissioning Director The Decommissioning Director is responsible for the administration of Engineering, Decommissioning Planning and Implementation, Configuration Management, Management of Safety, IIcalth Physics, Chemistry / Environmental and Radwaste.

Ile is responsible for maintaining the Design Bases in accordance with the Licensing Bases.

1.4.5 Rm! ness Mananer The Business Manager is responsible for managing and coordinating the financial reporting and control functions for CYAPCO during decommissioning. He oversees materials, inventory reduction and salvage and the administration of contracts.

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CONNECTICUT YANKEE ATOMIC POWER COMPANY

. ORGANIZATIONAL STRUCTURE

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1 I I I l Vice President - Operations and Decomm Vice President and Chief Financial Officer Human Resources g n. ~ .:. . . . . = . , :. : . . m : - c .:. +

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- Nuclear Safety Assessment Board 6 Decommissioning Director -

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Lines of Communication Figure 1-1 QAP - 1.0 Rev.1 Figure 1-1 5 QAP - 1.0 Rev.2

2.0 QUALITY ASSURANCE PROGRAM 2.1 GENERAL REOUIREMENTS

'CYAPCo has established the CYQAP for the HNP which complies with the criteria of 10 l CFR 50, Appendix B and fbliows the guidance referred to in Appendix C and Appendix E, herein. The quality assurance requirements set forth herein, supplemented by Oversight Quality Procedures (OQPs) provide the primary basis of the Program with regard to quality assuiance. This program is established for the HNP in a manner intended to accomplish the required level of quality and is carried out throughout the life of the plant. It includes quality activities during the maintenance, modification and storage of spent fuel at the HNP. l The CYQAP is also established, maintained and executed with regard to Radioactive Material Transport Packages described in 10 CFR 71.101(f).

The CYQAP applies in its entirety to activities affecting the safety functions of systems, structures and components. Such activities are quality activities as defined in Appendix A herein. Portions of the CYQAP are also applicable to the Fire Protection Quality Assurance (FPQA), the Radwaste Quality Assurance (RWQA), and Spent Fuel Quality Assurance (SFQA) programs. The level of CY QAP applicability is delineated in established administrative documents.

The requirements of this Program are implemented by Connecticut Yankee Atomic Power Company which operates the HNP and their vendors performing activities affecting quality systems, structures, and components at the HNP.

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

Training sessions are documented. The content is described, attendees and attendance date(s) indicated, and the results of the haining session (s)(e.g., satisfactory examination results) recorded.

A periodic program review of the status and adequacy of the CYQAP is accomplished by:

e audits, surveillances and inspections; e CY Nuclear Safety Assessment Board (NSAB) reviews; and

. Independent Assessment of the CYQAP audit program.

Vendors are required to review the status and adequacy of that part of the Quality Assurance Program fbr which they have designated responsibility.

QAP 2.0 6 CYQAP REV: 02 l

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l 2.2 IMPLEMENTATION 2.2.1 GDALS AND OBJECTIVES The goals of the CYQAP are to maintain quality levels in an effective and efficient manner and to assure a high degree of functional integrity and reliability of quality l systems, structures and components. To meet this goal, the following objectives of l

the CYQAP have been defined: J l a. Define through documented procedures, the quality activities that apply to the l maintenance and modification of the llNP; l

b. Establish, assign, and document the responsibilities for the conduct of those l activities affecting quality systems, structures and components; I l c. Establish confidence that:

e The maintenance and modification of the HNP is performed in a manner l i

consistent with CY Policies, and '

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e Quality activities are perfomied by responsible personnd, and are verified I through a system of audits, surveillances, and inspections of those organizations with quality responsibilities; I

d. Appraise the Chairman, CEO and President of unresolved problems and trends which could have a significant effect on nuclear safety.

2.2.2 PROGRAM DOCUMENTATION The CYQAP defines the CY nuclear goals and objectives and is used as guidance for the development of the various. implementing procedures. Revisions to the CYQAP will be made as needed to reflect current requirements and descriptions of activities prior to implementation. These revisions will be made in accordance with CY procedures.

Revisions to the CYQAP, which reduce commitments previously accepted by the NRC, are submitted to the NRC for review and approval 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, reviewed and approved by the departments l ' performing quality activities. The CY Oversight Department reviews other l department quality procedures for compliance with the CYQAP and concurs on such i procedures. Changes to procedures are subjected to the same degree of control as that ,

utilized in the preparation of the original document.

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2.2.3 SYSTEMS. STRUCTURES. AND COMPONENTS The requirements of the CYQAP shall apply, as a minimum, to all safety related systems, structures, and components, as addressed in the Safety Analysis Reports (SARs). Safety systems, structures, and components are identified in Appendix A of the CYQAP and also as specifically identified in the CY UFSAR that address Section 3.2.1 of NRC Regulatory Guide 1.70. (Reference Appendix A) Currently, the Materials, Equipment, and Parts List (MEPL) program provides instructions to identify stmetures, systems, components, parts, materials, and consumables that need to be safety-related or augmented quality. (The CY Engineering organization is considering an altemate process that can be utilized by the CY organization in place of the MEPL piogram that will provide the necessary guidance to perform and document determinations of systems and components in order to comply with the quality requirements contained herein. Process changes will be performed in accordance with CY administrative procedures and QAP 5.0).

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

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

The degree of control over activities affecting quality systems, structures, and components is consistent with their importance to safety. The CYQAP provides controls that include the use of appropriate equipment; establishment of suitable controls over special processes and skills necessary to attain the required quality; and the need for verification of quality by inspection and test.

CY Oversight and applicable CY line organizations jointly determine and identify the extent quality assurance controls are to be applied to quality structures, systems, and components. The quality assurance controls are in conformance with this CYQAP, which complies with 10 CFR 50, Appendix B.

2.2.4 1%RTICIPATING ORGANIZATIONS CYAPCo requires that its vendors invoke upon their subcontractors, via Purchase Orders / Contracts, requirements for a quality assurance program to meet the applicable criteria of 10 CFR 50, Appendix B, including the applicable elements of the Regulatory Guides and their endorsed Standards identified in Appendix C herein. IIowever, CY retains overall responsibility for the implementation of the QA Program. The specific quality activities performed by these organizations are snecified in the procurement documents. CY is responsible for the review and approval of vendor quality assurance programs prior to initiation of contracted QAP 2.0 8 CYQAP REV: 02 j

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

In addition to the initial review, CY Management is responsible for the subsequent performance, as appropriate, of audits, surveillances, and inspection of a vendor's quality assurance program to assure continued implementation of quality requirements. CYAPCo has contracted the performance of this function to the Duke Engineering and Services (DE&S).

CY Jversight also performs on-site audits, surveillances, and inspections, as appropriate, of the vendor activities.

Vendors may be delegated the execution of quality assurance functions by contract. These contracts are reviewed and approved in accordance with program requirements.

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 ard 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 instructions and that compliance to these documents is mandatory. Each CY Director is responsible for ensuring appropriate indoctrination and training of assigned personnel performing quality activities.

Nuclear Training Programs shall be developed and implemented to provide training for individuals attached to or associated with the iINP. Additional guidance is established in procedures.

Implementing procedures describe the nuclear training program requirements which assure that:

• Documentation of fonnal training and qualification programs includes the objective, content of the program, attendees, date of attendance, and examination results, as applicable; e Proficiency of personnel perfomaing 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 ifindividuals are properly trained and qualified; and i

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• Certificates or other documentation of qualification clearly delineate the specific functions personnel are qualified to perfonn and the criteria used to qualify personnel in each function.

2.2.6 MANAGEMENT OVERSIGIIT OF Tile OUALITY ASSURANCE PROGRAM The Vice President - Operations and Decommissioning ensures that a management review of the CY Quality Assurance Program is conducted annually to assess the efTectiveness of the QA program. This is accomplished by performing an independent assessment of the program. In addition, the CY Nuclear Safety Assessment Board performs oversight of the program in accordance with the approved charter.

Results of the assessments and reports are forwarded to the Vice President -

Operations and Decommissioning and the Chairman, CEO and President for appropriate corrective action, as necessary.

QAP 2.0 10 CYQAP REV: 02 l

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QAP3.0 DESIGN CONTROL 3.1 GENERAL REOUIREMENTS i

[ The CY Decommissioning Director is responsible for controlling design work, administering l design control activities (including design interface), and design modifications for quality systems, structures and components.

The CYQAP for design control is established to assure that the applicable design requirements, such as design bases, regulatory requirements, codes, technical standards and quality standards are identified in design documents which are reviewed, approved and controlled in accordance with established procedures. Such controls include a review for suitability of application of materials, equipment, parts and processes that are essential to the l functions of the systems, structures and components. Changes to, and deviations from, specified requirements are identified, documented and controlled.

l The responsibility for the design control program rests with the CY Decommissioning l Director. The division of responsibilities andjurisdictional boundaries for program j implementation are set forth in the appropriate CY administrative procedures. Although other l organizations may be delegated the task of establishing and executing the design control program or any part thereof, the CY Decommissioning Director will retain the ultimate l

l responsibility for the program. The applicable requirements of the CYQAP will be imposed l on other organizations delegated the task of establishing or executing the program in accordance with QAP 4.0, " Procurement Document Control" and QAP 7.0, " Control of l Purchased Material, Equipment and Services," herein.

l The interface controls, both internal and external, for organizations perfomling design work ,

for quality systems, structures and components are identified and implemented in accordance l

with documented procedures. This identification includes those organizations providing

! criteria, designs, specifications and technical direction. 1 i

l Measures are applied to verify the adequacy of design. The extent of design verification is l specified and documented by the responsible organization. The individuals performing l design verification should not:

l (1) have immediate supervisory responsibility for the individual performing the design; 1 (2) have specified a singular design approach; (3) have ruled out certain design considerations; or (4) have established the design inputs for the particular design aspect being verified.  !

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1 The independent design verification should not dilute or replace the responsibility of the l supervisors for the quality of work performed under their supervision. Where changes to l previously verified designs have been made, design verifications are required for the change, including evaluation of the effects of those changes on the overall design. I Design verification may be accomplished by testing. Tests to demonstrate adequacy under adverse design conditions shall comply with the requirements of QAP 11.0," TEST CONTROL. l Design errors and deficiencies which adversely affect quality systems, structures and components in 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 16.0," Corrective Action." l 3.2 IMPLEMENTATION ,

l The CY Director is responsible for the design, design review, engineering approval of I design changes, design evaluation and design control at the IINP. The function may be l delegated to other organizations to perfonn the design activity, or any part thereof, but the l responsibility fbr overall design remains with the CY Decommissioning Director. in all l cases, final engineering decisions and ultimate design control of systems, structures and l components related to the IINP is the responsibility of the CY Decommissioning Director.

l The CY Oversight department perfonns audits, surveillances, and inspections, to verify that Departments are effectively complying with the CYQAP and procedural requirements for design control.

CYAPCo is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspections, to verify that vendors are effectively complying with the CYQAP and procedural requirements for design control.

CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of l these vendor activities.

3.2.1 DESIGN PILOCESS Design control measures are applied to design analyses, such as: stress, ther:m 1, hydraulic, nuclear radiation, accident and seismic analyses; compatibility of materials; accessibility for required 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."

QAP 3.0 12 CYQAP REV: 02 l

Program procedures and instructions define the method ofimplementing design control measunc. These measures require that applicable design requirements, )

such as, design bases, regulatory requirement.s, codes and standards, are translated i into specifications, drawings, procedures or insttuctions. Instructions further require that appropriate quality standards are specified and included in design i documents. All materials, equipment, parts and processes, including standard " oft the shell" cornmercial or previously approved items essential to the 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. ,

CY procedures assure that a documented check is perf<mned to verify the

[ accuracy and completeness of design drawings and specifications before release j for use.

l Design drawings and specifications issued for design changes are reviewed for ,

l completeness and accuracy before being released to operations, in accordance j l with CY procedures. '

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CY procedures describe the provisions to assure that design drawings and specifications are prepared, reviewed and approved in accordance with company l procedures, and that the docurnents contain the necessary quality assurance j l requirements, such as inspections and test requirements, acceptance requirements, I l and the extent of documenting inspection and test results. 1 3.2.2 DESIGN CHANGE CONTROL i

Procedures and instructions govern design change control during modifications to  !

the HNP. Control of discrepant or deficient design conditions, and reported i

unsatisfactory performance, provide for the identification of design changes and a documented method to control these changes. Design and specification changes are subject to design control measures commensurate with those applied during i the original design.

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An independent review and approval of desiga changes is performed by the organization that conducted the original design reviews, unless another qualified organization is designated to perfonn this function.

I Proposed design change modifications are submitted to management for processing and review. This review includes the review by the Plant Operations l Review Committee (PORC). PORC advises the CY Unit Director on matters j relating to nuclear safety. Composition, responsibilities, and authority of the QAP 3.0 13 i CYQAP REV: 02 l

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committee are defined in Section 6 of the CY Technical Specifications. If the proposed change involves a quality system structure or component, the change will be reviewed by qualified engineering personnel for technical adequacy.

Reviews of the safety evaluations associated with design change requests are 4

perfonned by the CY Nuclear Safety Assessment Board. The sequence of the NS AB review depends upon the detennination of whether an unreviewed safety question is involved (i.e., in accordance with 10 CFR 50.59, if a proposed change in the facility involves an unreviewed safety question then the NSAB and NRC approval is required prior to implementation).

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

a. The adequacy of the proposed change is substantiated;

b. Unreviewed safety questions are properly identified and dispositioned per 10 CFP 50.59; and

c. Nuclear safety requirements have been addressed.

Errors and deficiencies in design, including the design process, that could adversely alTect quality structures, systems, and components are documented and corrective action is taken in accordance with QAP 16.0, " Corrective Action."

Notification of design changes are transmitted to responsible plant personnel as part of the design package close out. CY procedures describe this notification which assures that personnel are made aware of design change modifications.

3.2.3 DESIGN INTERFAG_ CONTROL The CY Decommissioning Director is responsible for review, coordination and documentation of design interfaces. Procedures provide for the method for identifying design interfaces, changes, and modifications affecting drawings and design documents.

3.2.4 INDEPENDENT DESIGN VERIFICK[lON Design changes are reviewed for adequacy and the sign-off perfbrmed by a person other than the originator of the design. Design verification is documented in accordance with procedures or instructions. Simplified calculations or computer programs may be utilized as alternate means of design verification. When design verification is performed by testing, the tests are perfomied using approved procedures, which specify the authority and responsibility of design verification personnel. Ultiraate responsibility fbr design adequacy and evaluation is retained l by the CY Decommissioning Director.

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Design verification (if other than by qualification testing) is normally completed prior to release for procurement, manufacturing, and construction, or to another organization for use in other design activities. For those cases where design verification cannot be completed prior to release for procurement, manufacturing, and construction, procedures ensure that design verification is completed prior to

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the point when the installation is declared operational.

CY procedures describe the requirements which assure the following when testing )

is considered as an alternate method of design verification:

a. Specifications or procedures provide criteria that specify when l 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.

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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 confonnance 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 reviews is provided.

CY procedures include requirements which identify the responsibility of design verifiers, the areas and features to be verdied, and the extent of the documentation. .

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

CY procedures are established to assure that verified computer programs are certified for a specific use.

The CY Decommissioning Director is responsible for assuring that design t

l documents provided by vendors are adequately approved and maintained.

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_QAE_4.0 PROCUREMENT DOCUMENT CONTROL 4.1 GENERAL REOUIREMENTS l

The procurement of materials, equipment, parts and/or services required during the maintenance and modification of quality systems, structures and components at the IINP is performed in a controlled manner which assures compliance with applicable regulatory requirements, procedures, quality assurance standards and regulations affecting procurement documents. Changes to procurement documents are subject to the same i degree of control as utilized in the preparation of the original documents.

4.2 IMPI EMENTATION 4.2.1 PROGRAM Material and service requests are reviewed for technical adequacy and verification of the quality designation. The appropriate engineering management reviews and approves material and service requests, as applicable.

CYAPCo is responsible for ensuring performance of a procurement engineering l i

evaluation to ensure the inclusion and adequacy of technical and quality assurance requirements prior to the issuance of the Purchase Order. Material for which technical and quality assurance requirements have been previously established are procured without additional procurement engineering evaluation. 1 i

Vendors utilized in the maintenance and modification of the HNP are responsible  ;

to implement measures for control of procurement documents associated with  !

quality material, equipment, parts and services to ensure applicable requirements including quality assurance requirements are specified. i CYAPCo is responsible for ensuring the performance, as appropriate, of off-site )

audits, surveillances, and inspections to ensure that vendors are effectively j complying with the requirements for the control of procurement documents.  :

CY Oversight performs, as appropriate, on-site audits, surveillances, and j inspections of these vendor activities. J Changes to procurement documents are subjected to the same degree of control as that utilized in the preparation of the original document. The procurement of spare or replacement parts for quality systems, structures, or components is subject to the controls of the CYQAP and implementing 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 the design change control requirements in QAP 3.0,

" Design Control."

QAP 4.0 16 CYQAP REV: 02 l

CYAPCo ensures the perfbrmance of procurement engineering evaluations of quality related material and service requests by personnel to ensure that:

a. Adequate technical requirements are specified;

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

c. There are adequate acceptance and rejection criteria.

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

a. The scope of work to be performed;

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

c. CYQAP requ rements to be imposed on contractors which include the applicable requirements of 10 CFR 50, Appendix B, and the NRC regulatory position contained in the Regulatory Guides and their endorsed ANSI Standards listed in Appendix C, herein;

d. Right of access which provides, as appropriate, for access to contractor facilities and records for inspection or audit by CYAPCo or its l designated representative; and provides access for events such as those requiring notification of hold points; and/or

e. The documentation required to be prepared, maintained, and/or submitted i

to CYAPCo 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 CYAPCo is prescribed, as applicable, fbr Nuclear Grade procurements. l QAP 4.0 17 CYQAP i REV: 02 l

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4.2.3 SELECTION OF PROCUREMENT SOURCES l

l l The function of procurement source selection is the responsibility of CYAPCo.

l Purchasing verifies that the procurement document has been reviewed and approved, and that the vendor has been approved for procurement prior to issuing the purchase order for the material, equipment, parts and services.

Purchase Orders / Contracts may be issued to organizations with unapproved quality assurance programs. These procurement documents to unapproved organizations contain detailed supplementary quality assurance requirements and/or witness / hold points to verify CY requirements. l t

Material requisitions are reviewed to ensure appropriate quality assurance l  !

i requirements are specified. These requirements, included in the procurement l document, as necessary, include acceptance criteria, audits, surveillances and/or l inspections at the vendor's facilities with scheduled witness / hold points during the fabrication process and/or prior to shipment of the procured item. Acceptance inspections and tests determined by CYAPCo shall be performed after receipt at i l the HNP, but prior to operability.

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_QM 5.0 PROCEDURES. INSTRUCTIONS. AND DRAWINGS 5.1 GENERAL REOUIREMENTS The CYQAP provides measures for the preparation, review, approval, control and distribution of procedures, instructions and drawings of activities affecting qualit, systems, structures and components during maintenance, modification, and decommissiom"3 of the HNP. The documents include appropriate quantitative and qualitative acceptance criteria which specify the activity to be perfbrmed; the methods of construction and testing to be employed; material, 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 functions. CY Oversight reviews and concurs wkh quality procedures as defined in the CY administrative control procedures. Comments concerning compliance with the CYQAP and regulatory requirements are resolved prior to issuance of the procedure.

Vendors utilized in the r .intenance and modification of the llNP may be delegated responsibility for preparing, maintaining, issuing and verifying the implementation of program documents which are selectively reviewed / approved by the appropriate Director.

CYAPCo is responsible for the perfbrmance, as appropriate, of off-site audits, surveillances, l and inspections of the quality assurance programs to ensure the vendors are effectively complying with the requirements for procedures and instructions.

CY Oversight perfonns, as appropriate, on-site audits, surveillances, and inspections of these vendor activities. Vendor 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.

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.

1 The appropriate CY Director ensures that any vendors utilized in the maintenance and modification of the IINP, implement quality assurance programs which contain written instructions for preparation, review and approval of procedures and instructions affecting quality. In addition, vendor's site quality procedures and quality control inspection procedures are reviewed for concurrence by CY Oversight to assure compliance with the vendor's QA Program.

QAP 5.0 19 CYQAP REV: 02

The CY line organization is responsible for the preparation, review and approval of plant quality procedures. The procedures include test procedures and overall site administrative procedures whien implement the requirements of the CYQAP.

CY Oversight reviews and concurs with quality procedures and special process manuals and procedures. The criteria for documents requiring CY review are defined in CY administrative procedures to ensure that:

a. Administrative manuals and procedures which implement the CYQAP are reviewed for compliance with the CYQAP and applicable Appendix C guides and standards, and

b. Work Procedures / Work Documents used to perform quality activities are reviewed to assure appropriate quality assurance controls have been specified.

5.2.2 DRAWINGS The design control and verification measures described in QAP 3.0, are applicable for the review and approval of drawings. Resiew and approval of new drawings or changes to existing drawings are described in CY procedures. The originating organization may delegate to other organizations or departments the work of design and review activities, or any part thereof, but retains responsibility for this work.

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

5.2.3 ACCEPTANCE CRITERI A Review and approval of departmental procedures, instructions and drawings is described in CY procedures to ensure the inclusion of adequate quantitative and qualitative acceptance criteria for determining satisfactory work performance and quality compliance. These criteria apply to quality activities as defined in the CYQAP.

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1 QM 6.0 DOCUM ENT CONTROL 1

6.1 GENERAL REOUIREMENTS

! 1 The CYQAP provides measures to assure controlled distribution of documents pertinent to Quality Activities affecting the safety related functions of structures, systems, and ,

components in accordance with CY quality procedures and 10 CFR 50, Appendix B. l 1

1 Documents such as procedures, instructions, drawings. specifications and reports are l l

prepared, reviewed for appropriate qualitative and quamitative acceptance criteria, and approved by authorized personnel in the afTected organization. Approved controlled documents are distributed to affected locations in accordance with a controlled distribution l list. Changes to controlled documents are reviewed and approved by the same organization  !

l which performed the original review und approval, unless otherwise specified in the implementing procedures. Measures are provided for controlling documents to preclude the possibility of the use of outdated documents.

6.2 IMPLEMENTATION  :

6.2.1 RESPONSIBILITY CY procedures and instructions delineate the measures for controlling documents 1 including direction for the review for adequacy, approval by authorized personnel, j distribution of controlled documents and verification that manges are promptly I incorporated and implemented. These centrol measures apply to applicable documents affecting systems, structures and components for the maintenance and modification of the IINP, such as:

a. Design Specifications;

b. Design Manufacturing, Construction and Installation Drawings; 1

c. As-Built Documents; j

d. Quality Assurance Program Manuals, Procedures and Instructions;

e. Manufacturing, Inspection and Testing Instructions;

f. Tv Procedures,

g. Calculations; I

h. Engineering Record Correspondence; QAP 6.0 21 CYQAP REV: 02 l

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i. Design Basis Documentation;

j. Final Safety Analysis Reports;

k. Procurement Documents;

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1. Design Chnge Records;

! -e m. CY Quality Assurance Program; 1

n. Nonconformance Reports; and i

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o.: Computer Codes.- 1 CY proc ~ e dures describe the measures taken for the control of documents to assure i

. review and concurrence, as necessary, with regards to quality assurance aspects. i i

l The requirements for control of procurement documents are contained in QAP l 4.0, " Procurement Document Control." - During all phases of plant life, it is the responsibility of each organization issuing controlled documents to employ j document control procedures. The issuing organization is additionally 1 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.

Vendors utilized by CY in the maintenance and modification of the HNP are responsible for implementing measures for review, approval, control and

. distribution of controlled documents, to ensure they are effectively complying

-with the requirements for document control.

CYAPCo is responsible for the pe.<ormance, as appropriate, of off site audits, l j surveillances, and inspections of the vendors to verify compliance with their approved quality assurance programs.

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CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of these vendor activities.

6.2.2 ~ DISTRIBUTION OF CONTROLLED DOCUMENTS l CY precedures, specify in what manner controlled documents and revisions ,

thereof, are distributed to appropriate locations, prior to commencing the work.

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6.2.3 DRAWING CONTROL CYAPCo is responsible to implement a program for the retention and retrieval of Jrawings and records submitted by cognizant CY personnel. CYAPCo maintains a drawing status file which includes drawings (newly issued or revised) with the latest revision and current status.

The vendors utilized during the maintenance and modification of the HNP may be delegated the function of drawing control and must furnish periodic status reports listing the revisions of applicable drawings issued.

Nuclear Materials and Document Management is responsible forihe performance of off-site audits, surveillances, and inspections of vendors to verify they are effectively complying with their programs for document control of drawings.

CY Oversight performs, as appropriate, on-site audits, surveillances, and inspet tions of vendor activities.

6.2.4 INSTRUCTION AND PROCEDURE CONTROL CY Oversight performs audits, surveillances, and inspections of departments and, as appropriate, any on-site vendors utilized in maintenance and modification to the IINP to ensure they are effectively complying with their QA program for control of procedures and instructions. l The originating department is responsible for establishing adequate control over quality procedures and instructions issued by the vendor. The responsible organization also issues status reports or revised indices listing the latest revision of applicable controlled documents issued by the vendor. Procedures identify requirements for assuring controlled documents are available at the work location prior to commencing work.

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QAP7.0 CONTROL OF PURCII ASED MATERIAL. EQUIPMENT.

AND SERVICES 7.1 GENERAL REOUIREMENTS Measures for the control of procured material, equipment, parts and services by or for CY related to the safety of nuclear power plants are established and imposed by the CYQAP during maintenance and modification to the HNP to ensure conformance to procurement documents. These measures include provisions for source evaluation and selection, submission of objective evidence by the contractor or subcontractor, inspection at the vendor source and examination ofitems upon delivery. Control of quality by vendors and subcontractors is assessed for effectiveness at intervals consistent with the importance, complexity and quantity of the product or service.

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

7.2.1 VENDOR OUALIFICATIONS CYAPCo utilizes one or more of the following methods in evaluating the l qualifications of a potential vendor:

a. Audits and/or coordinated review of a potential vendor utilizing CY personnel and/or DE&S personnel;

b. Other utility vendor audits and evaluations;

c. Nuclear Procurement issues Committee (NUPIC) audits;

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

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

f. Vendorinspection/ surveillance.

Evaluations ensure that vendors employ a quality assurance program that conforms to applicable portions of the CYQAP.

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CYAPCo is responsible for maintaining documented evidence of the evaluation and acceptance of the vendor's quality assurance program. The determination of vendor approval is based on such factors as prior performance, quality performance data, audits, commercial grade surveys, surveillances and evaluations of the supplier's quality assurance program.

l Vendor Certificates of Conformance are periodically evaluated by audits, commercial grade surveys, surveillances, independent inspections and tests, to assure the vendor processes are valid. This verification of the process is documented.

7.2.2 SOURCE INSPECTION CYAPCo is responsible for the performance of source inspections at suppliers' facilities to ensure that the requirements of a Purchase Order / Contract have been m et.

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

Inspection ofitems occurs either when verifications of procurement requirements cannot be determined upon receipt or the vendor's QA program has not been accepted by CYAPCo.

CYAPCo has contracted the performance of the vendor source inspection function to DE&S. CY has accepted the vendor QA process on audits performed to accept the DE&S process.

7.2.3 RECEIPT INSPECTION CYAPCo ensures the performance of receipt inspections. Receipt inspection for procured items is performed in accordance with quality procedures which delineate requirements a-d responsibilities necessary to perform inspection functions. Contractual omigation fulfillment and specified requirements are verified during receipt inspections.

Receipt inspection of vendor-fumished material and equipment is performed to assure that material, components, equipment and acceptance records are examined l in accordance with predetermined inspection instructions prior to acceptance, l

mstallation and operation. Receipt inspections include, as appropriate: 1

! l l a. Measures for verifying that the shipment is complete, properly identified, i undamaged and corresponds with the required documentation; l

b. Measures for inspection of the item and review of supporting documentation (e.g., mill test reports, NDE reports) as required by the purchase documents; QAP 7.0 25 CYQAP REV: 02 I

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c. Measures for inspection and acceptance ofitems in accordance with i predetermined methods; l

d. Measures for identifying and controlling acceptable items includmg '

identification ofinspection status prior to release from the receipt inspection area;

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

f. Measures to ascertain that inspection records or certificates of confonnance are acceptable prior to release for installation; and/or

g. In cases involving procurement of services, the project engineer or department head shall designate the means by which services may be I accepted, and is given the authority to accept services in accordance with methods defined in CY procedures.

l 7.2.4 VENDOR FURNISHED RECORDS Records required to be furnished by the vendon are sp :cified in the procurement document. Certifications or documentation provided bj the supplie r which attests to conformance, identifies that all the specific procurement requiren.ents have been met (either by refeence to the purchase order or by delineation).

The vendor must furnish the following records as a minimum:

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

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."

CYAPCo is responsible for ensuring reviews for acceptability, those documents which pertain to the requirements in the procurement document, in accordance l with the CYQAP and its applicable procedures.

l The Department that is contracting on-site QA services shall be responsible for l the review and acceptability of vendor personnel / equipment certifications prior to the start of work. CY Oversight will provide oversight of these activities via audit, surveillance, or inspection.

QAP 7.0 26 CYQAP REV: 02 l l

1 7.2.5 COMMERCIAL DEDICATION CYAPCo procedures address the measures taken to assure that 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 I N45.2.13.

These measures include appropriate requirements for special categorization and identification within the procurement document, receipt inspection, and additional controls during the installation and testing process to be performed by the CY organization and/or other appropriate groups.

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. 1 l-QAf 8.0 IDENTIFICATION AND CONTROL OF MATERIALS.

, PARTS AND COMPONENTS 8,1 GENERAL REOUIREMENTS j l

The CY organization assures that the identification ofinspections, tests, and operation status of structures, systems, and components is known by affected organizations.

The CYQAP provides measures for the identification and control of material, parts and components, including partially fabricated assemblies, during maintenance and modification to the HNP. To ensure that each item can be traced to associated documentation, the identification l

of the item is maintained by heat number, lot number, part number, serial number, or other ,

appropriate methods, and is physically marked on the item and/or on records traceable to the l item. Documentation associated with material, equipment, and components delineated that these items have been designed, fabricated, manufactured, tested and/or inspected in accordance 1 with the specified requirements. The object of these controls is to prevent the use ofincorrect I or defective materials, parts and components, in accordance with 10 CFR 50, Appendix B.

8.2 IMPLEMENTATION 1

CY procedures establish the responsibilities and requirements fbr the identification and l

control of materials, parts and components. The procedures assure that identification and control is maintained throughout fabrication, receipt, handling, storage ar.d installation of items. Provisions include:

a. Requirements for traceability to appropriate documentation, such as:

. Purchase orders / contracts, e Manufacturing documents, l e Drawings,

. Specifications, e Certifications, e Inspection and test records, and

. Nonconfbrmance reports.

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b. Controls to assure that the correct identification of an item is verified and l documented prior to release for fabrication, assembly, shipping or installation, l c. Requirements which assure that the method or location of markings do not l afTect the function or quality of an item, or

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

l^ During the maintenance and modification of the HNP, CY may delegate any portion of the implementation of the identification and control program to a vendor contracted to perform related quality activities. If delegated, contracts require that the vendor establish an identification and control program which meets the CYQAP requirement.

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CYAPCo is responsible for the performance, as appropriate, of off-site audits,  !

rourveillances, and inspections of the vendor's quality assurance program, to ensure they are efTectively complying with the requirements for identification and control of material, l equipment and cc- -

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CY Oversight performs, as appmpriate, on-site audits, surveillances, and inspections of the vendor activities.

Receipt inspections are performed to verify that materials, equipment and components are properly identified in accordance with procurement requirements. CYAPCo is responsible l for assigning and applying pennanent identification to the items in accordance with procedures. If the application of a serial number is not practical, other means of identification are implemented to assure proper identification and traceability.  ;

l In the event that the equipment, material or component is 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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OAP9.0 CONTROL OF SPECIAL PROCESSES 9.1 GENERAL REOUIREMENTS The CYQAP provides measures to assure control of special processes associated with quality systems, structures and components by the use of qualified procedures, equipment and personnel during maintenance and modification of the HNP.

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 maintenance and modification of the HNP, CY Engineering ensures that special process data and documentation is reviewed; vendor's special process procedures used at the HNP are qualified and approved; and that personnel and equipment utilizing special processes are properly qualified prior to the start of work.

CYAPCo is responsible for the performance, as appropriate, of off-site audits, surveillances, l and inspections to ensure the vendors are effectively complying with their quality assurance program requirements for control of special processes.

l CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of the vendor activities.

CY special process procedures utilized during maintenance and modification of the HNP l are prepared, reviewed and approved in accordance with procedures as specified in QAP 5.0, " Procedures, Instructions, and Drawings."

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

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l 9.2.2 PERSONNEL OUALIFICATION AND CERTIFICATION l Codes, standards CYAPCo procedures specify personnel qualification / certification requirements. Personnel responsible for the ,

performance and verification of special processes are traid tested, and certified  !

as required by applicable specifications, codes and stanoas. Requirements for the period of certification, retesting, and recertification of personnel are also specified. Vendors qualify personnel and maintain records of qualified personnel ,

in accordance with applicable codes, standards, specifications, and vendor

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Purchase Order / Contract requirements. The departrnent that is contracting services is responsible for the review of records of qualified personnel, equipment I and procedures associated with special processes.  !

l CY Oversight performs, as appropriate, audits, and surveillances of the personnel qualification process.

The CY Oversight Department is responsible for ensuring that the training, l testing, and certification of NDE personnel at the HNP is in accordance with the requirements of Regulatory Guide 1.58 (.Rev.1,9/80) and ASNT Recommended Practice No. S'NT-TC-1 A.

l 9.2.3 SPECIAL PROCESS RECORDS Records provide objective evidence that special processes were performed in accordance with procedures, by qualified personnel, and that when required by ,

procedures, specifications, and codes, such performance was verified Results of I nondestructive examinations are recorded in accordance with applicable I specifications, codes and standards. These records are retained by the vendor or I supplied to CY as required by contract or purchase order. If records are to be retained by the supplier, 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 data, and personnel and equipment qualification records associated with the performance of special processes at nuclear power plants, are kept current and maintained in appropriate CY files, with final disposition to the Nuclear Document Services Facility.

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QAP 10.0 INSPECTION 10.1 GENERAL REOUIREMENTS l'

Inspection of activities to verify the quality of systems, structures and components, which are performed by or for CY are executed in accordance with :be CYQAP and appropriate procedures, instructions and drawings by qualified personnel independent from the individual or group performing the activity being inspected. Ifinspection is impossible or disadvantageous, indirect controls by monitoring processing methods, equipment and personnel are provided. Inspection notification and hold points are identified, as required, l in the applicable documents.  ;

J 10.2 IMPLEMENTATION I l

10.2.1 INSPECTION RESPONSIBILITIES l

During maintenance and modification of the HNP, procedures shall define the I need for inspections (e.g., receipt inspections, installation, and product 1 acceptance).

CY Oversight shall ensure procedural requirements are met by means of audits and surveillances as defined in CY Oversight Department procedures.

CY Oversight shall perform inspections of modification and mamtenance activities on systems, structures, and components governed by the CYQAP. The criteria used to determine when CY Oversight inspection shall be required for these activities and for the preparation ofinspect;on plans shall be identified in appropriate procedures. CY Oversight shall be responsible for this inspection function which includes:

a. Identification ofinspection personnel;

b. Review of work procedures and work documents to identify QA " hold" points associated with the work;

c. Preparation and approval ofinspection plans ensuring that the necessary inspection requirements, methods, and acceptance criteria have been identified; and

d. Documentation ofinspection results.

CYAPCo is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspections to verify that any vendor utilized in the maintenance and modification of the HNP are effectively complying with their quality assurance program requirements for inspection and for performing / witnessing inspections at " hold" or " notification" points identified in procurement documents.

QAP 10.0 32 CYQAP REV: . 02 l

, l CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of vendor activities.

i 10.2.2 INSPECTION PLANS l

l j Documented inspection plans may be either a separate document or an integral I

part of work instruction documents. The plans are based on design specifications, procurement documents, drawings, other specifications, or previous experience, as appropriate. I I

l l During the performance of CY work activities, procedures provide criteria for the l determination of accuracy requirements ofinspection equipment and when

! inspections are required. These procedures describe requirements for the i

preparation of surveillance and/or inspection plans by CY Oversight.

i j The inspection criteria, including the use ofinspection equipment and their i

accuracy requirements, are specified in the CY Oversight surveillance / inspection plans.

10.2.3 INSPECTION PERSON ~NEL AND INSPECTION DOCUMENT ACCESS l 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 training programs.

( Inspections are performed by CY Oversight personnel or qualified contract l personnel. The Department that is contracting on-site QA inspection services shall L be osponsible for the review and acceptability of vendor personnel / equipment l certification prior to the initiation of the activity.

When vendors are contracted to perform inspection services, their inspection plans / procedures are reviewed and concurred upon by CY Oversight in accordance with QAP 5.0," Procedures, Instructions, and Drawings."

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

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10.2.4 INSPECTION PROCEDURES (a) Required inspection or surveillance activities are performed and documented in accordance with procedures and/or checklists.

Inspection procedures, plans oc checklists contain the following:

(1) Identification of characteristics to be inspected; (2) Identification of the individual or groups responsible for performing the inspections; (3) Requirements for the necessary measuring and test equipment and the required accuracy of this equipment; 1

(4) Acceptance criteria;  ;

(5) A description of the method ofinspection when other than direct l visual examination using the unaided eye, l l

(6) A record of the results of the inspection; and/or (7) Record ofinspector or data recorder.

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

(c) Modification, repair, replacement or rework items are inspected in accordance with original inspection requirements or approved alternatives. i l

10.2.5 MANDATORY IIOLD AND NOTIFICATION POINTS l Mandatory hold points are utilized when an inspection / operation must be performed or witnessed and signed off by the responsible personnel before work can proceed.

Notification points are used to identify the operations or completed processes that CY Oversight or its representatives may elect to witness and/or inspect during the manufacturing or installation process. Mandatory hold and notification points, as required, are identified in procurement documents and work procedures / documents.

Purchase Order / Contracts and work procedures / documents are subject to the review and concurrence for adequacy ofinspection, notification and/or mandatory hold controls by CYAPCo and CY Oversight, respectively.

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

The evaluations are performed by the responsible personnel who are qualified in accordance with the appropriate Regulatory Guide / ANSI Standard commitments listed in Appendix C.

j; ' CY Oversight performs audits and surveillances to assure that inspections are performed per the requirements of applicable CY procedures.

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QAP11.0 TEST CONTROL 11.1 GENERAL REOUIREMENTS ,

l A documented test control program is established by the CYQAP for systems, structures and components to ensure that they will perfonn satisfactorily in service and that test results are documented in accordance with 10 CFR 50, Appendix B and other pertinent regulatory .

and/or technical requirements. l l

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

The test control program is systematic and includes proof tests prior to installation, construction tests, operational tests, surveillance tests, and retest follmving repairs, replacements, preventative maintenance or modifications.

11.2 IMPLEMENTATION 11.2.1 TEST PROGRAM Test requirements to detennine or to verify the capability of an item to meet specified requirements in accordance with engineering / 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, envirenmental or operating conditions. Retest following repair, replacement or modification is perfonned in accordance with the original design requirements or acceptable alternatives and is performed when original test results are invalidated.

CY procedures are written and approved to delineate the methods and l responsibilities for controlling, accomplishing and documenting testing during maintenance and modification of the IINP.

Vendors utilized in the maintenance and modification of the HNP are responsible for implementing measures for the control of tests to ensure that materials, equipment and parts will perform satisfactorily.

CYAPCo is responsible for the performance, as appropriate, of off-site audits, l

surveillances. and inspections of selected proof tests when hold points have been identified in Purchase Order / Contracts of vendors to verify they are complying with their quality assurance program requirements for test control.

CY Oversight performs, as appropriate, on-site audits, surveillances, and

inspections of the vendor activities.

QAP 11.0 36 CYQAP REV: 02 1

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1 Proof tests, product acceptance tests, retests, and periodic surveillance test.s are conducted by qualified personnel in accordance with procedures. Personnel performing tests ensure that calibrated equipment and instrumentation utilized are within the calibration interval specified. Documentation including test procedures and data sheets are maintained in appropriate files.

I1.2.2 TEST PROCEDURE PREPARATION AND TEST PERFORMANCE Testing is accomplished in accordance with 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:

a. Inskuctions for the testing method used;

b. Required test equipment and instrumentation;

c. Test requirements, such as acceptance and rejection criteria; d.1loid, notification, inspection and data collection points;

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

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

g. Provisions for data collection and storage.

I1.2.3 TEST EOUIPMENT CY procedures provide the criteria for determining when a test is required and the accuracy requirements of test equipment.

The following steps are taken in the control of test equipment:

a. Test instrumentation is checked and calibrated in accordance with CY procedures to ensure accuracy;

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

c. Where special instrumentation is 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.

QAP 11.0 37 CYQAP REV: 02 l l

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. j I1.2.4 EVALUATION 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 approved procedures.

The evaluation of test results may also be delegated to vendors. When delegated, contracts require the vendor 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.

CYAPCo is responsible for the performance of ofr-site audits, surveillances, and l

inspections, as appropriate, to verify that these vendors are efTectively complying with their quality assurance program requirements for test control.

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of the activities.

QAP 11.0 38 CYQAP REV: 02

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t QAE 12.0 CONTROL OF MEASURING AND TESTING EOUIPMENT

, 12.1 GENERAL REOUIREMENTS l

The CYQAP provides measures for the control of measuring and testing equipment (M&TE) used as the basis for acceptance in activities affecting quality during inspection, l testing and measurement ofmaterials, equipment and parts. Periodic calibration and l adjustment of measuring and test equipment is performed and controlled to assure acct. racy

( is maintained within limits necessary to verify that design and operating condition l requirements have been met. Documentation is retained such that all items of M&TE are l traceable to their calibration records.

L 12.2 IMPLEMENTATION i

? l 12.2.1 GENERAL l

!- Procedures delineate the methods and responsibilities for the control,

! maintenance and calibration of M&TE including portable and temporarily installed test instruments, tools, gages, fixtures, reference and transfer standards,

and nondestructive test equipment.

1 i

I Documentation associated with M&TE is maintained in appropriate files, with l

eventual incorporation into the Nuclear Records Program. When the information for the control, use, and calibration of M&TE is in electronic form, this information is controlled and protected in accordance with procedures.

l l~ The calibration program is implemented in accordance with the requirements l defined in CY procedures which describe the measures utilized to maintain l M&TE. Functional groups are responsible for implementing these procedures l which comply with the requirements contained in specifications and drawings.

l The Plant Operations Review Committee (PORC) reviews and approves M&TE i administrative procedures related to the M&TE calibration program.

CYAPCo or the appropriate M&TE Custodian, as delineated by the Purchase l Order, is responsible for verifying that receipt of calibrated equipment is in t

conformance with the requirements of procurement documents. CYAPCo and CY Oversight are responsible for the calibrated M&TE used during their inspections, respectively.

l QAP 12.0 39 CYQAP REV: 02 l

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i Departmer.t lleads / Supervisors are responsible to ensure that M&TE equipment is calibrated, issued, and controlled in accordance with the requirements of the procedures. The " activity" Supervisor shall ensure that the users of the M&TE are properly instructed in the use and control of the M&TE. IINP Departments are responsible for calibrating M&TE within the required interval or removing the M&TE from service until the required calibration can be performed. CY l departments are also responsible for reviewing calibration data associated with l M&TE calibration by outside vendors in accordance with the procedures.

l CY Oversight performs audits, surveillances, and inspections to verify I implementation of the M&TE program. l l

Vendors utilized in the maintenance and modification of the HNP are responsible l for implementing measures for the control of M&TE to ensure they are properly calibrated, adjusted and maintained at specified intervals in order to maintain I accuracy within required limits. I CY APCo is responsible for the performance of off-site audits, sm cillances, and inspections, of the quality assurance programs of vendors to verify that they are effectively complying with their requirements for control of McTE.

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of vendor activities.

12.2.2 CALIBRATION STANDARDS Measuring and test equipment is calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other l conditions affecting the measurement. Measuring and test equipmem shall be

. permanently marked or tagged with a unique identification number and the date calibrated and next calibration date indicated on the M&TE.

CY 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.

i n

QAP 12.0 40 CYQAP REV: 02 l

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i Calibration of this equipment should be against standards that have an accuracy of i 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 will be within required tolerance and the basis of acceptance is documented and authorized by the manager of the applicable group or the 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.

I 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 l previous inspection or test results gained through use of the instrument, and of the acceptability ofitems previously measured or tested.

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i QAP 12.0 41 CYQAP REV: 02 l l l

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QAE 13.0 HANDLING. STORAGE AND SHIPPING l 1

l 13.1 flENERAL REOUIREMENTS l

l Measures are established by the CYQAP using procedures, instructions and procurement i L

documents to ensure proper handling, storage, shipping, cleaning and preservation of material, equipment and parts. These measures are imposed during maintenance and modification ,

activities in order to preclude damage, loss or deterioration of materials, equipment and parts. l 13.2 IMPLEMENTAT][}N l 13.2.1 GENERAL Procedures, instructions and procurement documents define the requirements and responsibilities for the handling, storage, shipment, cleaning and preservation of material, equipment, and parts required for implementation of established design  ;

and specification requirements. l l  !

Handling, storage, cleaning and preservation requirements of material, equipment i p and parts is conducted in accordance with procedures and procurement documents.

Vendors utilized in the maintenance and modification to the HNP are responsible )

for implementing measures for handling, storage, shipping, cleaning and preserving materials, equipment and parts to preclude damage, loss or deterioration. ,

l l CYAPCo is responsible for oft-site audits, surveillances, and inspections, as l  ;

l appropriate, to verify that vendors are effectively implementing and complying with i the approved procedures and instructions for handling, storage, shipping, cleaning and preservation of materials, equipment and parts.

l CY Oversight performs on-site audits, surveillances, and inspections, as l appropnate, of the activities.

! 13.2.2 ESTABLISHMENT OF SPECIAL HANDLING. STORAGE. SHIEEINfG, I CLEANING AND PRESERVATION REOUIREMENTS Special or additional handling, storage, shipping, cleaning and preservation l requirements are to be identified and implemented as specified in procurement i

documents and approved procedures. These established requirements are consistent with the regulatory positions of the NRC Regulatory Guides and their endorsed ANSI Standards listed in Appendix C herein, or specifications and/or vendor technical manuals, and will be co isistent with accepted industry standards.

CY procedures describe the mea mres taken for the storage of chemicals, reagents (including control of shelflife), lubricants, and other consumable materials.

, QAP 13.0 42 CYQAP l

REV: 02 o

l QAP14,0 INSPECTION. TEST AND OPERATING STATUS

[ _14.1 GENERAL REOUIREMENTS h

l The CYQAP provides measures for indication, by the use of marking such as stamps, tags, j labels or other suitable means, the status of tests and inspections of material, equipment and parts throughout the maintenance and modification of the IINP to preclude the inadvertent bypassing ofinspection and test requirements. These measures provide for the identification ofitems which have satisfactorily passed required inspections and tests. Measures are also

, established for indicating the operating status of systems, structures and components to prevent inadvertent operation.

l 14.2 IMPLEMENTA'llQN ,

14.2.1 GENERAL Vendors utilized in the maintenance and modification of the HNP are responsible for implementing approved measures for the identification ofinspection and test status of material, equipment and parts to preclude the bypassing of requirements.

l CYAPCo is responsible for the performance of offsite audits, surveillances, and j

l.- inspections of vendors, as appropriate, to verify that they are effectively l complying with their requirements for identification ofinspection and test status, in compliance with procedures and instructions.

Elements of this system require that vendors have a controlled manufacturing and ,

l test operation, in order to preclude the inadvertent bypassing of process I L inspections or tests, and to provide a positive identification of component status throughout all phases of manufacturing, 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 Millstone Station or the IINP, l

L CYAPCo ensures that traceability is maintained for acceptable materials, l equipment and parts, to indicate conformance to Purchase Order / Contract requirements. Material used at CY that requires traceability to be maintained is delineated in the appropriate CY procedure.

Nonconforming materials, equipment and parts are identified in accordance with QAP 15.0," Nonconforming Materials, Parts, Components, or Services" and/or

, QAP 16.0," Corrective Action."

QAP 14.0 43

CYQAP REV

02 l

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During tests and inspections of operating systems required to support the storage of the spent fuel, a status tagging system is implemented, as per approved procedures and instructions, to prevent inadvertent operations of systems, structures and components.

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

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of the activities.

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

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

l QAP 14.0 44 CYQAP REV: 02 l

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.QAE 15.0 NONCONFORMING MATERI ALS. PARTS. COMPONENTS.

OR SERVICES l 15.1 GENERAL REOUIREMENTS j l

The CYQAP requires that documentation and control of nonconforming materials, parts, components, or services utilized in systems, structures and components during maintenance and modification of the HNP be performed in accordance with procedures in order to i prevent inadvertent use or installation. These procedures include appropriate requirements I for identification, documentation, segregation and disposition of nonconforming items, and i notification to afTected organizations.

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1 15.2 IMPLEMENTATION 15.2.1 PROGRAM Procedures define personnel responsibilities and establish various measures for i identification, documentation, segregation, review and disposition of nonconforming item reports. Report mechanisms are available to all CY and l

contractor personnel I i

l 15.2.2 DOCUMENTATION '

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

Tagging systems are utilized to physically identify nonconfonning items prior to installation. CYAPCo utilizes tags for received material, parts and components.

l 15.2.3 EVALUATION AND DISPOSITION Evaluations are performed to determine the impact on system, structures and component operability and to determine the disposition of nonconforming items and services. The evaluation determines whether an item or service is to be used as is, returned to vendor, repaired, or scrapped. An engineering evaluation is performed, if necessary, prior to the resolution of nonconformances. These evaluations assure that the final condition does not adversely affect safety, operation or maintenance of the item or service, or of the component or system.

Reports involving deviation from design bases such as "use as is" or " repair" are forwarded to the appropriate engineering organization for review, and disposition.

Applicable infonnation is accumulated and records are maintained.

. QAP 15.0 45 CYQAP l

REV: 02

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

a. Impact on plant safety; i

b. Safety of personnel;

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

d. Accessibility of material or items afler release; o e. Cost of removal and repair or replacement should material or items l

eventually have to be removed, repaired, or replaced; and

f. Effect on the orderly progress of work.

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

Items repaired may require reinspection as defined in procedures.  !

CY Oversight perLrms audits and surveillances to verify that dispositions for

, reports docume,nting nonconforming conditions are adequate.

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OAP 16.0 CORRECTIVE ACTION

!6.1 GENERAL REOUIREMENTS The CYQAP requires that an effective corrective action program be established for CY and their vendors to ensure that conditions adverse to quality are promptly identified and corrected as soon as practicable and documented in accordance with approved procedures.

These procedures include measures for determining the cause and corrective action to preclude recurrence for conditions identified as significant conditions adverse to quality. l 16.2 IMPLEMENTATION l

16.2.1 PROGRAM i

Procedures define personnel responsibilities and establish various measures for identification, documentation, evaluation / review, disposition and correction of conditions adverse to quality and significant conditions adverse to quality.  ;

Reporting mechanisms are available to station personnel. l l

16.2.2 CORRECTIVE ACTION AND FOLLOW-UP Procedures describe the measures taken to evaluate if conditions adverse to quality exist and to determine the need for immediate corrective action or j disposition. The Vice President - Operations and Decommissioning is responsible l for ensuring that the assigned personnel and their vendors working at IINP comply with the corrective action program and for ensuring that corrective actie is adequate and properly implemented in a timely manner at the HNP.  !

l CY Oversight, Corrective Actions,is responsible for ensuring that conditions adverse to quality are promptly identified and corrected in accordance with l approved procedures. I CY Oversight, Quality Assurance, performs audits and surveillances to verify that organizations working at the llNP comply with the corrective action program and that corrective action is adequate and properly implemented in a timely manner.

The Vice President - Operations and Decommissioning has the final authority in l the event that agreement on the action to be taken is not reached at the appropriate organization levels within the CY organization QAP 16.0 47 CYQAP REV: 02 l l

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16.23 RECURRENCE CONTROL

, Procedures provide responsibility and the process for determining appropriate j significance based on actual or potential consequences for conditions adverse to l quality and requirements for evaluation and corrective action.

l Procedures also establish the responsibilities and measures taken to accomplish these actions. l i

i An analysis of conditions identified as adverse to quality is developed and adverse trends are periodically reported to management by the organization responsible l for controlling the problem reporting program. Trends concerning specific vendor  ;

performance shall be reported to the affected contractor for resolution, if I appropriate.

I CY Oversight performs audits and surveillances to verify that the corrective l action program is adequate and controlled in accordance with procedures.

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! QAP 16.0 48 CYQAP I REV: 02 i

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1 QAP 17.0 OUALITY ASSURANCE RECORDS )

17.1 GENERAL REOUIREMENTS i The CYQAP provides for the naimenance, identification, retention and retrieval of records  ;

to furnish evidence of activities affecting quality during maintenance and modification of the HNP. The records include but are not limited to:

a. Operating logs and the results of reviews; I 1

b. Inspections; I

c. Tests;

d. Audits; l

e. Monitoring of work performance; and

f. Material analyses.

I The 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 ofinspector or data recorder; and, the acceptability and the action taken in connection with any deficiencies and reportable occurrences no:ed. Procedures establish requirements conceming record retention such as duration, location and assigned  !

responsibility.

17.2 IMPLEMENTATION Procedures and instructions establish the responsibilities and requirepents for the maintenance, identification, retention and retrievability of records pertaining to materials, equipment, parts, processes or operations relating to systems, structures and components which when founded on observations, measurements or tests can be fully verified, and documented by cognizant personnel.

CY procedures define the documentation requirements for inspection and test records, as appropriate.

Vendors utilized in the maintenance and modification of the HNP are responsible to implement measures for identification, maintenance, retention, retrieval and tumover of records to CY personnel which contain objective evidence of quality, as specified in Purchase Order / Contracts.

u CYAPCo is responsible for oft-site audits, surveillances, and inspections, of vendors, as l l appropriate, to verify they are effectively complying with their program for quality l assurance records.

l QAP 17.0 49 CYQAP L REV: 02 L

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CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of these activities.

Quality Assurance records are idendfied, controlled and maintained in appropriate files and j are identifiable to specific systems, structures and components at HNP. When identification I to a specific system, structure or component is not practical, records are filed by category (e.g. specification, nonconformance reports, audits, etc).

17.3 RETENTION CY quality assurance records are classified as life records or nontife records as delineated by Nuclear Document Services. Nonlife records are those documents that are maintained l

for a specific period of time other than the lifetime of the in-service 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 pLnt or for the life of the particular component or part. Life records are those which would be of significant value in meeting one or more of the following criteria:

a. I)emonstrating capability for safe operations;

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

c. Determining the cause of an accident or malfunction of a: item; or 1

d. Providing required base line data fbr in-service inspection. l Records are reviewed and approved by the. ognizant qualified personnel and vendors as i

appropriate, and are transmitted to Nuclear Docurnent Services. The responsibility of the '

Nuclear Document Services upon receipt of records, is to maintain and provide controlled l retrievability of records affecting the llNP 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 procedures.

l QAP 17.0 50 CYQAP REV: 02 l 1

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QAP 18.0 AUDITS 18.1 GENERAL REOUIREMENTS The CYQAP requires that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with the CYQAP during the maintenance and modification of the IINP.

Audits are conducted in accordance with written procedures or check!!sts by appropriately trained personnel not having direct responsibilities in the areas being audited.

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 18.2.1 PROGRAM The audit program requires audits of corpomte and IINP quality activities under the oversight of the CY Nuclear Safety Assessment Board. Audits are performed on activities where the requirements of 10 CFR 50 and the IINP Technical Specifications are being implemented.

Audits are regularly scheduled on the basis of the status and safety importance of the activities being performed. Regularly scheduled audits are supplemented by audits for one or more of the following conditions:

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 Ja jeopardy due to deficiencies in the quality assurance program;

c. When a systematic, independent assessment of program effectiveness is considered necessary; and / or

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

QAP 18.0 51 CYQAP REV: 02 l

Schedules for the audit of CY activities are originated and maintained by CY Oversight. Schedules are approved by the CY Oversight Manager. l Audits are performed as specified in CY Oversight procedures by qualified l personnel, using a pre-established written audit plan prepared by the auditing organization. Audits may include evaluation of the work areas, activities, processes, items, and review documents and records to determine the effectiveness ofimplementation and conformance to the CYQAP.

Approved vendors utilized in the maintenance and modification activities to the HNP are responsible for developing and implementing a system of planned and periodic audits to verify compliance with the effectiveness of all aspects of their quality assurance programs.

CYAPCo is responsible for verifying the acceptability of vendor audit programs l and for the perfomlance of subsequent oft-site audits, as appropriate, to verify compliance with the effectiveness of all aspects of their quality assurance programs. CYAPCo has contracted this audit ftmetion to the DE&S. l CY Oversight performs audits / sun eillances of on-site vendors, as appropriate, to verify the effectiveness of appropriate aspects of their quality assurance programs.

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

I8.2.2 REPORTING OF AUDIT RESULTS Audit results are reviewed, approved, and reported in accordance with CY Oversight and/or DE&S procedures, as applicable. The audit reports are issued to j the appropriate management of the area audited to ensure appropriate and/or timely conective action is taken to address any audit findings. In addition, audit data and reports are included as part of the review for quality trends and assessed in accordance with QAP 16.0," Corrective Action."

18.2.3 REVIEV/. ACTION. AND FOLLOW-UP OF AUDIT FINDINGS Audit findings are reviewed and invest igated by the management having the responsibility for the area audited. Tlie responsible management is required to:

a. Take the necessary action to addresses any findings identified by the audit; 1

b. Report the results of such reviews and investigations; QAP 18.0 52 CYQAP REV: 02

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c. Take the necessary actions to correct problems reported; and

d. Report the completion of corrective actions within specified time frames.

Follow-up of audit findings is performed by the auditing organization, as necessary, to verify that appropriate actions have been taken to resolve audit findings. Actions on audit findings which cannot be resolved by affected management and the Vice President - Operations and Decommissioning are submitted for resolution to the Chairman, CEO and President.

18.2.4 RECORDS / REPORTS OF AUDITS Audit records, reports, and associated documentation pertinent to audits are  ;

dispositioned to the appropriate Nuclear Document Services Facility, as specified i in procedures. -

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1 QAP 18.0 53 CYQAP ,

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APPENDIX A CONNECTICU.T YANKEE OUALITY ASSURANCE PROGRAM CATEGORY I SYSTEMS. STRUCTURES. AND COMPONENTS The pertinent quality assurance requirements of 10 CFR 50, Appendix B will be applied, as a minimum, to all quality activities affecting the safety function of the Systems, Structures, and Components (SSCs) of a defueled nuclear power plant, including their foundations and supports. These SSCs will be listed in Chapter 3.2 of the CY Defueled UFSAR and will l

address Section 3.2.1 of NRC Regulatory Guide 1.70.

I NOTE The safety classification of the systems, structures and components may be revised based

~

on engineering evaluations and a revision to the CY UFSAR during the decommissioning process.' Revision of the' safety classification in accordance with the CY Design Control -

process is not considered a reduction in the commitmerits to the CYQAP.

In addition to these SSCs, items and services associated with Radioactive Material Transport Packages as described in 10 CFR 71 will also fall under the requirements of the CYQAP.

APPENDIX A 54 CYQAP REV: 02

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l l APPENDJXH CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM OUALIFICATION AND EXPERIENCE REOUIREMENTS M ANAGER - CY OVERSIGHT l

The Manager - CY Oversight shall satisfy the fbliowing requirements: ,

1 l

Graduate of r. fbr:.c . . credited engineering or science college or university, plus fiReen (15) or mLre years ofindustrial experience including five years in positions ofleadership, such r, lead engineer, project engineer, audit team leader, etc. At least two years of this l experience should be associated with nuclear Quality Assurance Activities, and at least one year of this experience is in a Quality Assurance Organization. A masters degree in I engineering or business management is considered equivalent to two years of experience.

I 1

NOTE The education m;.flxperience requirements should not be treated as absolute when similar -

training or an ouh+.anding record will provide reasonable assumnce that a person can perform the .

required tasks.

l APPENDIX B 55 CYQAP REV: 02

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APPENDIX C CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM REGULATORY GUIDE AND A~NSI STANDARD COMMITMENTS NOTE The CYQAP is committed to utilize the guidance obtained from the following regulatory documents and their endorsed standards. Exceptions to these positions are listed in Appendix E, herein.

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

10 CFR 50, Section 50.54, Condition of Licenses.

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

1971.

Regulatory Guide 1.28 - 2/79 - Quality Assurance Program Requirements (Design and Construction)

Endorses ANSI N45.2-1977.

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

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

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

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

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

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

l APPENDIX C 56 l l

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t Regulatory Guide 1.64 - Quality Assurance Requirements for the Design of Nuclear Power Plants, 6/76 - Endorses ANSI N45.2.11-1974.

Regulatory Guide 1.70 "A Guide for the Organization and Content of Safety Analysis Reports" Revision 2, September,1975 was utilized for CY, however, certain revised sections of the CY l

UFSAR are written to the Revision 3 fomiat. No new analyses have been perfomled which would be required by Revision 3.

Regulatory Guide 1.88 - Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records - 10/76 Endorses ANSI N45.2.9-1974.

Regulatory Guide 1.94 - Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plant -

4/76 - Endorses ANSI N45.2.5 - 1974 and Section 6.11 of ANSI N45.2.5-1978.

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

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

Regulatory Guide 1.144 - Auditing of Quality Assurauce Programs for Nuclear Power Plants - Rev.

1 - 9/80 Endorses ANSI N45.2.12 - 1977.

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

Regulatory Guide 1.152 " Criteria for Digital Computers in Safety Systems of Nuclear Power l Plants," January 1996 - Endorses IEEE-ANS 7.4.3.2 - 1993. I APPENDIX C 57 CYQAP REV: 02

APPENDIX D CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM GLOSSARY OF OUALITY ASSURANCE TERMS Accent As Is -(also known as "Use-As-Is") A disposition which may be imposed fbr a nonconformance when it can be established that the discrepancy will result in no adverse conditions and that the item under consideration will continue to meet all engineering functional requirements including performance, maintainability, fit and safety.

Annroved Venders - Contractors, suppliers, and engineering senice organizations who have been approved to ; oside quality related material, equipment, parts, and services, or computer software to the Nuclear Group under their QA Program.

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

Audit - A formal, documented activity perfomied in accordance with written checklists or procedures to verify by evaluation of objective evidence that a quality assurance program has been developed, documented, and implemented in accordance with applicable requirements.

Augmented Ouality - Nonsafety related items for which a design basis or regulatory commitment has been made. The augmented quality items are included within the scope of CY Quality Assurance Program. These items are the Fire Protection Quality Assurance (FPQA), Radwaste Quality Assurance (RWQA), and Spent Fuel Quality Assurance (SFQA) programs.

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

Catepary_1 - Designation given to systems, structures, and components of the IINP that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

Category I Systems. Structures. and Comoonents - Defined in the CY UFSAR and functionally described in Appendix A., herein.

Cleaning - Those actions performed to maintain an item in accordance with cleanliness requirements.

APPENDIX D 58 CYQAP REV: 02

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Commercial Grade Item (CGI)- A commercial grade item per 10CFR21 is a structure system, or

! component, or part thereof that affects its safety function, that was not designed and manufactured as a basic component. Commercial grade items do not include items where the design and manufacturing process require in-process inspections and verifications to ensure that defects or  ;

failures to comply are identified and corrected (i.e., one or more critical characteristics of the item l cannot be verified).

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

Condition Adverse to Ouality - Failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconfomiances. l Connecticut Yankee Ouality Assurance Program (CYOAP)- Consists of the CYQAP, Nuclear Oversight Department Procedures and other CY Gmup/ Division / Department / Branch /Section quality procedures.

1 Contractor - Any organization under contract for fumishing items or services. It includes the tenns Vendor, Supplier, Subcontractor, Fabricator and subtier levels of these where appropriate.

The Nuclear Steam Supply System (NSSS) Supplier is included in this category.

Corrective Actjan - Action taken to correct identified conditions adverse to quality. I Decommission - Means to remove (as a facility) safely from service and reduce residual radioactivity to a level that permits release of the property for unrestricted use and termination of license.(10 CFR 50.2)

Deficiencic - Departures from specified requirements.

Denartment - The use of the word department, throughout the CYQAP, can refer to any portion of the CY organization or support organizations from NU Nuclear (i.e., Group, Division, Department, Branch, Section, or Unit as applicable).

Dcign - Technical and management processes which lead to and include the issuance of design output documents such as drawings, specifications, and other documents defining technical requirements of systems, structures, and components.

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

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APPENDIX D 59 CYQAP REV: 02

Design Dot ynis - The drawing, calculation, specification, or other document (s) that define the Technical requirements ofsystems, structures, or components.

Duke Engineering and Services (DE&S) - is a company that provides contract services, in the areas such as design, construction, engineering, quality assurance, licensing, operation, decommissioning support services, etc.

Handling - An act of physica:ly moving an item by hand or by mechanical machinery, but not including tmnspoit modes.

IINP - Iladdam Neck Plant is used throughout this document to define the Connecticut Yankee plant site.

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

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

Insnection - A phase of quality control which, by means of examination, observation, or >

measurement, detennines the conformance ofmaterial, supplies, components, parts, appurtenances, systems, processes, structures, or services to predetermine quality requirements.

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

Maintenance and Modifications - Refers to the required functions for design, construction, testing, maintenance, operation, and modification of facilities at the llNP during decommissioning activities.

Material Reauest - The computerized format used for identifying material and services to be procured using the Materials Infbrmation Management System (MIMS)

Measuring and Test Eauioment - Those instruments, gages, tools, fixtures, reference and transfer standards, nondestructive test equipment, and measuring devices used during inspection and testing to determine that the measuring and test parameters comply with appropriate requirements in specifications and drawings.

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

APPENDIX D 60 CYQAP j REV: 02 l

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Northeast Utilities (NU)- A public utility holding company which owns Northeast Utilities Service Company and The Northeast Nuclear Energy Company and through its operating subsidiaries has a controlling interest in The Connecticut Yankee Atomic Power Company.

Northeast Utilities Service Comoany (NUSCO)- A wholly owned subsidiary of Northeast g ,

Utilities that provides various services for the IINP. >

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

Nuclear Grade - The procurement classification applied to all materials and services intended ibr items listed as Cat.1 in the MEPL. ~1hese may require validating documentation such as i

Certiticate of Material Test Report, Certificate of Confomlance, Certificate of Compliance,  !

Personnel Qualifications, etc., as specified by codes or standards, and have been designed / qualified for a nuclear application. Nuclear Grade items are manufactured / qualified I under a 10 CFR 50, Appendix B program, with the vendor responsible for 10 CFR 50, Part 21.

The vendor should be approved and listed in the Approved Vendor List.

Nuclear Document Services Facilities (NDSE)- A facility which has been established for the l purpose of handling IINP records in accordance with the Nuclear Records Program. l l

Qintlity Assttmace Vendor List - A list identifying the approval status of the quality assurance l prognuns of vendors; commonly referred to as the Approved Vendors List (formally entitled the Approved Suppliers List)

Obiective Evidence - Any statement of fact,information, or record, either quantitative or 1 qualitative, pertaining to the quality of an item or service bas.ed on observation, measurements, or tests which can be verified.

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

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

Procurement Documents - Purchase requisitions / material requests, purchase orders, contracts, drawings, specifications or instructions used to define requirements fbr purchase.

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

APPENDIX D 61 CYQAP REV: 02

i Project Engineer - An employee assigned the responsibility to coordinate the engineering activities addressed in CYQAP.

Purchased Material Eauinment. and Parts List (MEPil- Items procured for installation in nuclear power generating facilities systems, structures, and components, and items procured as spare MEPL parts for potential installation in those systems, structures, and components.

Purchase Order / Contract - The document which provides the contractual basis for vendor material and services provided in accordance with CYQAP requirements.

Purchased Service - Services provided by a vendor or consultant on a QA requisition when activities are performed under a quality assurance program other than the CYQAP.

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

signature or stamp identifiable to the person making the statement of fact.

Quality Activities - Activities governed by this CYQAP are those that affect safety-related functions of structures, systems, and components; these activities include designing, analyzing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining. repairing, and modifying. Quality Activities also include activities associated with i computer sonware used in implementing the CYQAP and Augmented Quality items as defined herein.

Ouality Procedures - The Nuclear Oversight Department procedures and other department procedures which implement the requirements of the CYQAP that are reviewed by CY Oversight. l Repair - A disposition applied to nonconfomling material, equipment, and parts that are unsuitable for their intended purpose which are modified by the use of additional operations and/or processes )

so that they are suitable for their intended purpose but may not meet all specified requirements. l l

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

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

l APPENDIX D 62 l

CYQAP l REV: 02

Safety Related Systems. Structures. and Comoonents - Systems, Structures, and components required to mitigate the consequences of postulated accidents.

Soccial Processes - Processes for which the desired level of quality can only be assured through the use of additional process controls, and where control through direct inspection alone is inadequate, impossible, or disadvantageous. These processes are performed under controlled ,

conditions in accordance with special requirements utilizing qualified procedures, equipment, and j personnel. These special processes may include, but are not limited to welding, brazing, l

~ soldering, cleaning, heat treating, and nondestructive testing.

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Storage - The act of holding items at the HNP or in an area other than its permanent location in the plant. j l

Surveillance - A documented record of the observation of work operations performed at CY or a l J

vendor's site to assure compliance with applicable codes, standards, specifications, procedures, drawings, and procurement documents. Surveillances are not performed to a preplanned checklist.

Test and Operating St;gus - Identification of material, equipment, and parts that are ready for test or operation, or an existing stage of a test operation.

Testing - The determination or verification of the capability of an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions.

Vendor - Organizations that provide material, equipment, parts, and services, or computer software.

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I APPENDIX D 63 CYQAP l REV: 02

APPENDIX E CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM PROGRAM EXCEPTIONS

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

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

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

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

A quorum of the Nuclear Safety Assessment Board shall consist of the Chairman or Vice Chairman and at least enough members to constitute a majority of the assigned members. No more than a minority of the quorum has line responsibility for operation / decommissioning of the llNP. No more than two alternates have voting status at any meeting in fulfillment of the quorum requirements.

3. ANSI N45.2.9-1224, paragraph 1.4. defmition of" Quality Assurance Records" states in part: "For the purposes of this standard, a document is considered a quality assurance record when the document has been completed."

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

"A record is considered a working document until it is transmitted to the appropriate Nuclear Document Services Facility (NDSF) at which time it is designated as a Quality Assurance Record. The following maximum time limits are established for the transmittal of working documents to the NDSF:

Operations Documents - Documentation generated during Plant Operations may be maintained, as needed, by operating plant departments, for up to one year.

New Construction or Betterment Documents - Llocuments which evolve during new construction or betterment projects shall be transmitted to NDSF within 90 days of completion of a new construction project or tumover of a betterment project or plant operations.

! APPENDIX E 64 CYQAP l

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• Procurement Documents - Inspection / Surveillance / Audit Reports generated during vendor oversight activities which are used to maintain vendor status fbr current and future procurements may be maintained, as needed, by CYAPCo for up to three l

years.

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

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

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

4. Regulatory Guide 1.64 - 6/76, the Regulatory position states, .in part, "It should not be construed that such verification constitutes the required independent design verification."

CYAPCo has developed the following alternative to allow for adequate independent design verification:

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

Did not specify a singular design approach:

Did not establish the design inputs or did not rule out certain design considerations; Is the only individual in the organization competent to perfomi the review.

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

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

CYAPCo no longer has any nuclear plants under construction. As a result, most l procurements are made for spare parts from suppliers who are not the original equipment manufacturer. In these cases, the supplier may have little or no understanding or knowledge of either the operation of the system the component is to be installed in, or applicable Post-Installation Test requirements and acceptance documentation. As such, CYAPCo assumes

responsibility for establishing Post Installation Test requirements and acceptance documentation.

APPENDlX E 65 CYQAP l REV: 02 l

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6. ANSI N45.2.2 1972, paragraph 1.2, states in part that,"The requirements of this standard apply to the work of any individual or organization that participates in the packaging, l

shipping, receiving, storage, and handling ofitems to be incorporated into nuclear power L plants."

Since a portion of CYAPCo procurement activities involve commercial suppliers which do l not fully comply with the requirements of ANSI N45.2.2, Northeast Utilities Nuclear ,

Materials and Document Management organization verifies through source inspections, receipt inspection, and/or survey activities that the quality of the materials, items, components or equipment is preserved by those suppliers to the extent that packaging, shipping, storage and handling methods are employed which are commensurate with the nature of the product.

7. Regulatorv Guide 1.33 - 2/78. regarding audits, states in part:

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

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

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

(CYAPCo) has developed an alternative which modifies these audit frequencies to at least l l once per 24 months. This attemative has previously been accepted by the NRC via license  !

amendments 181 for CY.

This alternative also takes exception to (c) above. It delets the requirement for Nuclear Oversight (CY Oversight) to audit the performance of the facility staff. This function will l be performed by the Nuclear Safety Assessment Board.

8. ANSI N18.7-1976. Paragranh 4, states that " Plant procedures shall be reviewed by an j individual knowledgeable in the area afTected by the procedure no less frequently than i every two years to determine if changes are necessary or desirable."

CYAPCo has developed the following attemative for plant procedure reviews.

Plant procedures will be periodically reviewed in accordance with administrative controls.

These controls will establish a schedule (in no case less frequently that every five years) for these periodic reviews. Applicable plant procedures will be reviewed following an unusual incident, such as an accident, unexpected transient, operator error, or equipment failure l (malfunction) as determined through the Corrective Action process and following a l

modification to a system.

i APPENDIX E 66 CYQAP j REV: 02

Non routine procedures such as Abnormal Operating Procedures, Emergency Plan Implementing Procedures, or other procedures whose use may be event driven, will be reviewed every two years and revised as defined in administrative procedures.

The Quality Assurance (or other independent) organization shall periodically audit a sample ofroutine plant procedures that are used more frequently than every two years. The audit is to ensure the acceptability of the procedures and verify that the procedure review and revision program is being implemented effectively. The root cause of significant deficiencies is to be detennined and corrected.

The current requirement to review each plant procedure on a biennial cycle results in the expenditure of significant technical and administrative resources. Pmgrammatic controls and practices are in place to provide adequate reviews, including the following:

• The plant modification processes require that procedures alTected by the modification be identified during tiie design change preparation, and revised prior to closure of the modification package.

. The Industry Experience Program involves the review ofindustry infomiation for applicability and the determination of further actions. This review includes an evaluation of applicable CY documents, such as procedures and the initiation of required changes.

. Administrative controls currently exist requiring that if a procedure cannot be performed as written, a procedure change must be completed prior to continuation of the procedure.

• Temporary changes are occasionally generated during, or prior to procedure use. Current administrative controls require that those changes that are permanent shall be incorporated into the procedure via the procedure revision process.

. As part of the audit and surveillance process, procedures are evaluated as to adequacy, ease of use, proper technical content, and compliance with applicable plans and programs.

e The Condition Resolution Program may require that a root cause analysis be performed for some events, violations and nonconforming conditions. Where identified as contributing factors, procedure changes are initiated.

. Changes to Technical Specifications and the FSAR are reviewed for potential impact on, and initiation of changes to plant procedures.

• Plant procedures are approved by appropriate personnel prior to initial use. Current administrative controls also require pre-job briefings for procedures identified as infrequent.

! This modification meets the intent of published regulatory requirements involving activities important to safety.

APPENDIX E 67 CYQAP REV: 02 l

I 9.- ANSI N18.1 - 19'71 " Selection and Training of Nuclear Power Plant Personnel" Section 4.2.2 states that "the operations manage shall hold a Senior Reactor Operator's License."

CYAPCO is permanently defueled and is no longer required to maintain Senior Reactor Operator's L.icenses, as previously approved by the NRC with the issuance of Amendment 193 to the CY Technical Specifications. Since CYAPCO is permanently defueled the Operations Manager is no longer required to maintain a Senior Reactor Operator's License.

l' CYAPCO will continue to maintain the Tecimical Specifications requirement for minimum shift crew composition which includes a Certified Fuel Handler.

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APPENDIX E 68 CYQAP REV: 02 l

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I Appendix F CYQAP Al)MINISTRATIVE CON 1ItOLS l

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1.0 ADMINISTRATIVE CONTROLS 1.0 REVIEW AND AUDIT l

1.1 PLANT OPERATIONS AND REVIEW COMMITI'EE (PORC) 1 1

FUNCTION  !

i 1.1.1 The PORC shall function to advise the Unit Director on all matters related to I nuclear safety. ,

l COMEORTION l 1

1.1.2 The PORC shall be composed of at least seven members. Member shall collectively j have experience and expertise in the following areas:

Plant Operations, Decommissioning,

• l Engineering, Maintenance, Ilealth Physics, Chemistry / Radiochemistry, ,

Quality Assurance,and l' Security.

• The minimum qualifications of PORC members shall be that all members have an academic degree in an engineering or physical science field, or hold a management position, and have a minimum of five years technical experience in their respective field of expertise. The members of PORC shall be appointed in writmg by the Unit Director, who is the PORC Chairperson. T'ie alternate Chairpersons of the PORC shall be drawn from the PORC l members and be appointed in writing by the Unit Director.

1 ALTERNATES l 1

1.1.3 All alternate members shall be appointed in writing by the PORC Chairperson to serve on a temparary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.

• These areas are exempt from the 5-year experience requirement.

l APPENDIX F 70 CYQAP REV: 02 l

l h1EETING FREOUENCY l 1.1.4 ' The PORC shall meet at least once per calendar month and as convened by the PORC Chairperson or his/her designated altemate.

OUORUM

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1.1.5 The. quorum of the PORC shall consist of the Chairperson of his/her designated alternate and four members including alternates.

RESPONSIBILITIES 1.1.6 The PORC shall be responsible for:

a) Review of: 1) all procedures required by Specification 6.8 and changes thereto,  ;

and 2) any other proposed procedures or changes thereto as determined by the i Unit Director to affect nuclear safety; i b) Review of all proposed tests and experiments that affect nuclear safety; c) Review of all proposed changes to the Technical Specifications; d) Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety; l

, e) Investigation of all violations of the Tecimical Specifications, including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence, to the VP - Operations and Decommissioning and to the k Nuclear Safety Assessment Board; f) Review of all REPORTABLE EVENTS; g) Review of facility operations to detect potential safety hazards; h) Perfomiance of special review, investigations or analyses and reports thereon as requested by the Nuclear Safety Assessment Board or the Unit director.

i) Not used.

j) Not used.

k) Review of the Fire Protection Program and implementing Procedures.

APPENDIX F 71 CYQAPl l REV: 02

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AUTIIORITY 1.1.7 The PORC shall:

a) Report to and be advisory to the Unit Director on those areas of responsibility ,

specified in Section 6.5.1.6 (a) through (k)- I i

b) Render determination in writing to the Unit Director if any item considered under Specification 6.5.1.6a. though d, above, as appropriate and as provided by 10CFR50.59 or 10CFR50.92 constitutes an unreviewed safety question or requires a significant hazards consideration determination.

c) Provide written notification, meeting minutes may be used for this purpose, to the VP - Operations and Decommissioning and the Chairperson of the Nuclear Safety Assessment Board of disagreement between PORC and the Unit I Director; however, the VP - Operations and Decommissioning shall have )

responsibility for resolution of such disagreements pursuant to Specification 6.1.1.

1 IWCORDS l 1

1 1.1.8 The PORC shall maintain written minutes of each meeting that, at a mimmum, 4 document the results of all PORC activities perfomled under the responsibility and authority provisions of these Technical Specifications. A copy shall be provided to the Nuclear Safety Assessment Board.

1.2 NUCLEAR SAFETY ASSESSMENT BOARD (NSAB) 1.2.1 The minimum qualifications of NSAB members are as follows:

a) The Chairperson and NSAB members shall have:

1. An academic degree in an engineering or physical science field, or hold a senior management position, and

2. A minimum of five years tecitnical experience in their respective field of expertise.

b) The NSAB shall have experience in and shall function to provided independent ,

oversight review and audit of designated activities in the areas of: l l

Plant Operations, 1 Decommissioning, Engineering, Radiological Safety, Chemistry / Radiochemistry Quality Assurance,and Environmental Protection.

APPENDIX F 72 CYQAP REV: 02 l

The NSAB serves to advise the VP - Operations and Decommissioning on matter related to i nuclear safety and notify the VP - Operations and Decommissioning within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a safety significant issue and/or a safety significant disagreement between the NSAB and the organization or function being reviewed.

COMPOSITION 1.2.2 The VP - Operations and Decommissioning shall appoint, in writing, a minimum of five members to the NSAB and shall designate from this membership, in writing, a Chairperson and a Vice Chairperson. The membership shall function to provide independent review and audit in the areas listed in Specification 6.5.2.1.

l ALTERNATES  ;

l 1.2.3 All attemate members shall be appointed, in writing, by the VP - Operations and l Decommissioning; however, no more than two alternates shall participate as  !

members in NSAB activities at any one time. l MEETING FREOUENCY 1.2.4 The NSAB shall meet at least once per calendar quarter.

OUORUM )

1.2.5 The quorum of the NSAB shall consist of a majority of NSAB members including )

I the Chairperson or Vice chairperson. No more than a minority of the quorum shall have line responsibility for operation of the same IIaddam neck Plant. No more than two alternates shall be appointed as members at any meeting in fulfillment of the quorum requirements.

REVIEW RESPONSIBILrflES 1.2.6 The NSAB shall be responsible fbr the review of:

a) The safety evaluations for changes to procedures, equipment, or systems, and tests or experiments completed under the provisions of 10CFR50.59, to verify that such actions did not constitute an unreviewed safety question as defined in 10CFR50.59; b) Proposed changes to procedures, equipment, or systems that involve an unreviewed safety question as defined in 10CFR50.59; c) Proposed tests or experiments that involve and unreviewed safety question as defined in 10CFR50.59; d) Proposed changes to Technical Specifications and the Operating License; e) Violations of applicable codes, regulations, orders, license requirements, or internal procedures having nuclear safety significance; APPENDIX F 73 CYQAP REV: 02 l

l f) All License Event Reports required by 10CFR50.73; l g) Indications of significant unanticipated deficiencies in any aspect of design or

operation ofstructures, systems, or components that could alTect nuclear safety; l

h) Significant accidental, unplanned, or uncontrolled radioactive releases, including corrective actions to prevent recurrence;

i) Significant operating abnomialities or deviations from normal and expected performance of equipment that could affect nuclear safety; j) The performance of the corrective action program; and k) Audit and the Annual Audit Plan.

L Reports or records of these reviews shall be forwarded to the VP - Operations and l Decommissioning within 30 days following completion of the review.

AUDIT PROGRAM RESPONSIBIIIflES 1.2.7 The NSAB audit program shall be the responsibility of the Nuclear Oversight organization. NSAB audits shall be performed at least once per 24 months in accordance with appropriate administrative procedures and shall encompass; a) The conformance of unit operation to provisions contained with the Technical Specifications and applicable license conditions; b) The training and qualifications of the unit staff; c) The implementation of programs required by Specification 6.8; d) The Fire Protection Program and implementing procedures; l e) The fire protection equipment and program implementation utilizing either a qualified offsite license fire protection engineer or an outside independent fire protection consultant.

f) Actions taken to correct deficiencies occurring in equipment, structures, systems, components, or method of operation that affect nuclear safety; and g) Other activities and documents are requested by the VP - Operations and l Decommissioning.

RECORDS 1.2.8 Written records of reviews and audits shall be maintained. As a minimum, these records shall include results of the activities conducted under the provisions of Section 6.5.2.  ;

i-APPENDIX F 74 CYQAP REV: 02

i 2.0 RECORD RETENTION 2.1 In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated.

2.2 The following records shall be retained for at least 5 years:

a) Records and logs of facility operations; b) Records and logs of principal maintenance activities, inspections, repair, and )

replacement of principal items of equipment related to nuclear safety; c) ALL REPORTABLE EVENTS; d) Records of surveillance activities, inspections, and calibrations required by these Technical Specifications; e) Records of tests and experiments; f) Records of changes made to the procedures required by Specification 6.8.1; g) Records of radioactive shipments; h) Records of sealed source and fission detector leak tests and results; i) Records of annual physical inventory of all sealed source material of record; and 2.3 The following records shall be retained for the duration of the facility Operating License:

a) Record and drawing changes reflecting facility design modifications made to systems and equipment described in the FS AR; b) Records of new and irradiated fuel inventory, fuel transfers, and assembly bumup histories; c) Records of facility radiation and contamination surveys; 1

d) Records of radiation exposure for all individual entering radiation control areas, .

e) Records of gaseous and liquid radioactive material released to the environs; f) Records of transient or operational cycles of the reactor vessel:

g) Records of training and qualification for current members of the facility staff; h) Records ofinservice inspections perfbnned under previous amendments to these Technical Specifications; i) Records of quality assurance activities required by the Quality Assurance l Manual not listed in Specification 6.10.2; APPENDIX F 75 CYQAP REV: 02 l

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

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j) Records ofreviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR Part 50.59; p k) Records of meetings of the PORC and the NSAB; l ,

l 1) Records for Environmental Qualification; m) Records of reviews performed for changes made to the RADIOLOGICAL l EFFLUENT MONITORING AND OFFSITE DOSE CALCULATION MANUAL (REMODCM) and the Process Control Program.

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l APPENDIX F 76 CYQAP~

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Connecticut Yankee 4

Quality Assurance Program l I l i

for the l 4

4 Haddam Neck Plant 1

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l TABLE OF CONTENTS CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM (CYOAP)

IIADDAM NECK PLANT Abstract Policy Statement Quality Assurance Program Chapters QAP 1.0 Organization; Organizational Charts QAP 2.0 Quality Assurance Program QAP 3.0 Design Control QAP 4.0 Procurement Document Control QAP 5.0 Procedures, Instructions and Drawings QAP 6.0 Document Control QAP 7.0 Control of Purchased Material, Equipment and Services QAP 8.0 Identification and Control of Materials, Parts and Components QAP 9.0 Control of Special Processes QAP 10.0 Inspection QAP 11.0 Test Control QAP 12.0 Control of Measuring and Testing Equipment QAP 13.0 llandling, Storage, and Shipping QAP 14.0 Inspection, Test, and Operating Status QAP 15.0 Nonconforming Materials, Parts, Components, or Services QAP 16.0 Corrective Action QAP 17.0 Quality Assurance Records QAP 18.0 Audits Appendices A. Category I Systems, Structures and Components B. Qualification and Experience Requirements, Vice President - Onerations and DecommissioningF= lear Ov=ight C. Regulatory Guide and ANSI Standard Commitments D. Glossary of Quality Assurance Terms E. Program Exceptions F. CYOAP Administrative Controls l

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1 CONNECTICUT YANKEE ATOMIC POWER COMPAN'Y HADDAM NECK PLANT l ABSTRACT Connecticut Yankee Atomic Power Comnany (CYAPCo1Nenheast Utilitie @!U) has developed i and is implementing a comprehensive Quality Assurance Program for the Gennecticut Y= Lee A4emic Pcwer Ce.np=y's 11addam Neck Plant (IINPi to assure conformance with established regulatory requirements as set forth by the Nuclear Regulatory Commission (NRC). _The participants in this Quality Assurance Program assure that the maintenance and modification of the IIaddam Neck Plant is performed in a safe and effective manner.

This Connecticut Yankee Quality Assurance Program (CYQAP) complies with the requirements set forth in 10 CFR 50 Appendix B, along with applicable sections of the Safety Analysis Report (SAR), and is responsive to the NRC Regulatory Guide 1.70, that describe the information required ,

to be presented in the Quality Assurance Section of the SARs for nuclear power plants. I This CYQAP is also established, maintained and executed for Radioactive Material Transport Packages as allowed by 10 CFR 71.101(f). Quality A=rance Proi. ;ica ; fer Fire Pretectian activities are detailed in th: Connecticut Y"nhee Fire Protectica Prograaw This CYQAP applies to the safety functions of systems, structures, and components and are considered quality activities as defined in the CYQAP. Safety sSystems, sStructures and eComponents are discussedf= etic =lly ident:fied in Appendix A hereia. . Applicability of Appendix A to the CY Updated Final Safety Analysis Report (UFSAR)is addressed by the specific design bases and licensing commitments. Portions of the CYQAP are also q scable to the Fire l Protection Quality . Assurance (FPQA), and-the Radwaste Quality Assurance (RWQA). and Snent Fuel Ouality Assurance (SFOA) programs.

This CYQAP is committed to utilize the guidance obtained from the regulatory documents and their endorsed standards as referenced in Appendix C.

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POLICY STATEMENT OUALITY ASSURANCE PROGRAM CYAPCcNortheaa: Util!!!es has established a Quality Assurance Program for the Iladdam Neck Planteaeh nucle = s!!e ope =ted by the Ferieast U !!!!!cs system. This%ese QA programoregrams hashave been developed to achieve quality assurance in all activities affecting the safe operation / decommissioning of the Haddam Neck Planta:-ce:ated nue!er units.

%tstualhy assur=ce programs establirled at-each nue!er site by Nerecas: Utilitie: are as S!!rV::

Mi!! rte = Statica, Units 1,2,3 =d S!!e Nor$ east Util!!!e: Qua!!!y Assur=ce Program (NUQAP)

Seabreak Static.. Opem:ic=! Quality A :==ce Program (OQAP)

Had J.=: Nech Pl=t (HNP) Cenaecticut Y=kee Quality A :ur=ce Program fer Se Haddam Nech Pl=:( CYOAP)

The program described herein is the Connecticut Yankee Quality Assurance Program for the IIaddam Neck Plant._ The policies, requirements and tasks contained in this program description l have been developed to achieve a recognized need for quality assurance for maintenance and modification activities during the decommissioning of the HNP to ensure that adequate quality requirements are being complied with to safeguard employees (CYAPCo and contragt(NU =d centract) and the public.

CY procedures which implement the program at the Haddam Neck Plant are developed and approved in accordance with Connecticut Yankee administrative procedures.

The CYQAP is responsive to applicable codes, Nuclear Regulatory Commission regulatory requirements, accepted industrial standards and revisions thereto. _ Provisions are established to l

, update the CYQAP in accordance with revisions to codes, standards and regulatory requirements and to infonn cognizant personnel to implement appropriate action to assure that the highest standard of quality is achieved for systems, structures, components and services for the HNP.

- The controls which implement the actions identified in the CYQAP are station and departmental procedures and instructions which delineate actions and steps necessary to accomplish quality requirements.fProcedures and instructions are written by company groups, divisions, departments, l branches, or sections, which have the responsibility for implementing actions assigned to them as delineated by the CYQAP.

The development and overall responsibility for this Quality Assurance Program lies with the Chairman. Chief Executive Officer and Presidentpresident =d Chief E=cutive OfEcer NU Nucle Orcup. Corporate authority is delegated to the Vice President - Onerations and DecommissioningF=!:= Oversight for the preparation and administration of the Connecticut POLICY STATEMENT lily CYQAP l REV: 024 l l

Yankee Quality Assurance Program (CYQAP). _The Vice President - Ooerations and DecommissioningEr.::::! ce ic: Pr:dhr: :::d Chief N !::: 05eer for Connecticut Yankee and the CY Directors are responsible for the implementation of the Quality Assurance Program within their Departments, i

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QAP 1.0 ORGANIZATION 1,1 INTRODUCTION i

1 The Chairman, Chief Executive Omcer, and President of I CYAPCoNorthens: Uti!!:ies (NU) has the ultimate responsibility for the Haddam l Neck PlantNU Nuclear Progra:n. "'hile reta:n:ng full responsibility end everall authority, the Chair: nan h .; delegated the necessary-autimrity :.nd reopensibility fer a!! NU Nuclear Operaticas te the President and Chief Executive Omcer NU Nuclear Group. The NU Nue! ear Group include::he Forthear: Utilities Ser" ice l Co.npany (NUSCO) " hich previden :,upport serv:ces e FU' :.uclear-plaats ineluding4henmeetkmt4'anhee Ato:n:e Pc .er C+npany (CYAPCO)"-hich aperaten the Hadda n Neck Plant (!!NP). '":e President and Chief Execu:ive Omcer Nue! ear Orcup is n!:a the President of NUSCO and the President and cis...

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1.2 PROGRAM RESPONSIBILITY 1.2.1 The Chairman. CEO and PresidentPresident end Chief Exee=tive Offie r NU N=e!:ar Craup has overall responsibility for the development of the CYQAP for the Haddam Neck Plant. While retaining full responsibility and overall authority, the Chairman. CEO and PresidentPresiden: and Chief Executi .e Omcer has delegated corporate authority for the preparation and administration of the CYQAP to the Vice President - Ooerations and DecommissioningMuelear Overs:ght. (See .

l Figure 1-1) 1.2.1.1 The Chairman. CEO and PresidentPresident and Chief Executive Offieer maintains contact with the quality assurance activities through meetings with the Vice President - Onerations and Decommissioning. andNuclear Oversght, the receipt of various documents, such as: periodic progress reports,' Nuclear Safety Assessment Board meeting notes, and audits related to CY's nuclear program implementation at the Haddam Neck Plant.

1.2.1.2 The Chairman. CEO and PresidentPresiden' end Chief Executive Offieer resolves all disputes related to the implementation of this

! CYQAP for which resolution is not achieved at the appropriate organizational levels within the nuclear organization.

1.3 GENERAL RESPONSIBILITIES 1.3.1. The head of each CY department performing quality activities is responsible for:

QAP 1.0 16 CYQAP REV: 024 l

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a. Administering those activities within their organization which are required by the CYQAP;

b. Ensuring implementation of the CY Quality Assurance Program; 1

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

d. Planning, selecting, and ensuring that personnel are trained to meet the requirements of the CYQAP; and i

c. Performing and coordinating quality activities within their organization and interfacing with the CY Oversight organization as l required in program implementation.

I 1.3.2. Each individual performing or verifying activities affecting quality is responsible to conduct those activities in accordance with the requirements of the CYQAP and implementing procedures.

1.3.3 The responsibility, authority, and organizational relationship for performing quality activities within each organization is established in CY organizational charts, policy statements, and written job or functional descriptions.

1 1.4 ORGANIZATION-CONNECTICUT YANKEE AT TIIE HADDAM NECK l l PI. ANT The Chairman. CEO and PresidentPre:! dent :::d Chief Ex ::tive Of5 r NU N :!:ar Cr er reports to the CYAPCo Board of DirectorsNU Chairman; President, and Chief ExecaholT+eer. Ile has overall responsibility for the development and implementation of the CYQAP._ Emnlovec Concerns is resnonsible for the direction and administration of the Emnloyee Concerns Program for CYAPGo. The nosition assures that nuclear safety concerns receive annronriate management attention and that concerns are addressed in a timely manner. The Chairman. CEO and PresidentFreddent and Chief Executive OfEcer  ;

has delegated the necessary authority and has assigned responsibility for l development and implementation of the CYQAP for the IIaddam Neck Plant respecti.e!y to the Vice President - Onerations and Decommissioning ^^-

Overs:ght, rnd the Executive Vice Presdent and Chief Nue! ear Off+eer--

Cennecticut Yankee. (See Figure 1-12).

1.4.1 The Vice President - Operations and DecommissionineNue!:ar Oversi;;ht responsibilities include:

a. Direction of the CY Quality Assurance Program; I 1

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b. Implementation of policies and procedures;

c. Verifications through a planned program of audits, surveillances, and inspections to assure compliance with 10 CFR 50, Appendix B and other regulatory requirements; and

d. The implementation of the CYQAP requirements.

The Vice President - Operations and Decommissionine has the overall resnonsibility to imnlement the CYOAP at the HNP and in nrovidine

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signort services to the onerating staff. The Vice President - Onerations and Decommissioning is resnonsible for the HNP's safe oneration and has control over those supnort activities necessarv for safe oneration.

maintenance and decommissionine of the nlant.

The Vice President - Onerations and Decommissioning nrovides provides management with objective evidence of the performance of activities affecting quality, independent of the individual or group directly responsible for perfonning the specific activity. This individualHe has the authority and organizational freedom to verify activities affecting quality.

This is performed independent of undue influences and responsibilities for l schedules and costs through the Manager - CY Oversight. The Manager -

CY OversightHe has the responsibility and authority, delineated in writing, to stop unsatisfactory work and control further processing, delivery, or installation of nonconforming materials._ The individualHe also has the l

responsibility and authority to identify quality problems, to recommend or provide solutions, and to verify their implementation.

The Vice President - Onerations and DecommissioningNuclear Oversight is also responsible for the Industrvthe Emp!cyee Concern Progranw h: dependent Safety Engineering and Operating Experience Program and the Audit pErogram. Specif'ea!!y, the key upport activities for the Nuclear Oversght program at the !!NP are pre-ided by:

11.1.1 Diree:e- F=7 qver  ! Ceneer=s He Directer Emp!cyee Concern:! respensib!e fer the directien and adminictratica ef the Emp!cyee Cencern- Program fer Ner*hea-: Utilities. The Director a::ures that nuc! car safety concerns rece:ve appropriate management ettentie.: and that concern: nre addressed la e :imely manner 4.1 1.2 Directe:- ' edits and Ev !:::'n ne Directer Audits and E clua !cn i: responsiMe for-the directien and administralian of the audit-program ic verify:

QAP 1.0 36 CYQAP REV: 024 l

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1.4.1.24 Manager - CY Oversight The -Manager - CY Oversight manages the audit, surveillance and insnectionand inspeetion activities of the IINP Resnonsibilities include:!!e is responsible fer-

a. Directing and AdministeringManaging the Nuelear Oversight's program for audits, surveillances -and inspections;

b. Verifying compliance with 10 CFR 50, Appendix B and other regulatory requirements;

c. Verifying the implementation of the CYQAP requirements;

d. Evaluating performance and identification of strengths and weaknesses;

e. Providing recommendations for improving nuclear performance at iht.HNP; l

f. Serving as the primary GNU Fue!eer Oversight _. l management interface with IINP management; and

g. Stopping unsatisfactory work.

h. Administering the Corrective Action Program.

The Manager - CY Oversight is an active narticinant on irra member-ef the CY Nuclear Safety Assessment Board.

The Manager CY Oversight has direct communication withte the CY staff, Directors mand 4hecutweihe Vice President - Onerations and Decommissioning and the Chairman. CEO and President and providesprevides the daily interaction on matters affecting quality, nuclear safety, and nuclear related activities.

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He Manager Nuclear Safety Eng:neering managewhe-day-te day activitier, cf the Northeast Utilitie: Independent Safety Engineering Program and the Operating Fnperience Program in compliance "4 th the appropriate unit Technica! Specifications and QAP 1.0 56 CYQAP REV: 024 l

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b. Coneols 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 de not afTect the function or quality of an item, or

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

During the maintenance and modification of the HNP, CY may delegate any portion of the implementation of the identification and control program to a vendor contracted to perfonn related quality activities. If delegated, contracts require that the vendor establish an identification and control program which meets the CYQAP requirement.

CYAPCcMuc4 ear-Material =d Daeument Ma..agement is responsible for the performance,

, as appropriate, of off-site audits, surveillances, and inspections of the vendor's quality assurance program, to ensure they are cfTectively complying with the requirements for identification and control of material, equipment and components.

CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of the vendor activities.

Receipt inspections are performed to verify that materials, equipment and components are i properly identified in accordance with procurement requirements. CYAPCoNuelear l Materk.hend Occument-M=agement is responsible for assigning and applying permanent identification to the items in accordance with procedures. If the application of a serial  !

number is not practical, other means ofidentification are implemented to assure proper identification and traceability. l In the event that the equipment, material or component is nonconfomling or the f identification becomes lost or illegible, the items are considered nonconfonning and are identified and controlled in accordance with QAP 15.0," Nonconforming Materials, Parts, Components, or Services."

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l l QAP9.0 CONTROL OF SPECI AL PROCESSES l l

9.1 GENERAL REOUIREMENTS The CYQAP provides measures to assure control of special processes associated with quality systems, structures and components by the use of qualified procedures, equipment and personnel during maintenance and modification of the HNP.

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 exarmnation and/or testing.

l 9.2 IMPLEMENTATION

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During maintenance and modification of the HNP, CY Engineering ensures that special process data and documentation is reviewed; vendor's special process procedures used at the HNP are qualified and approved; and that personnel and equipment utilizing special processes are properly qualified prior to the start of work.

CYAPCcNuclear Materialr and Document Management is responsible for the perfonnance, l l as appropriate, of off-site audits, surveillances, and inspections to ensure the vendors are  !

effectively complying with their quality assurance program requirements for control of special processes.

I CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of the vendor activities.

NUSCO/CY special process procedures utilized during maintenance and modification of l the HNP are prepared, reviewed and approved in accordance with procedures as specified in QAP 5.0, " Procedures, Instructions, and Drawings."

I 9.2.1 PROCEDURE OUALIFICATION AND CONTROL  !

NUSCO/CYAPCo procedures specify that written process control documents are l utilized and qualified, as required, in accordance with the applicable specification, codes or standards.

9.2.2 PERSONNEL OUALIFICATION AND CERTIFICATION Codes, standards and NUSCO/CYAPCo 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 QAP 9.0 3433 CYQAP.

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the period of certification, retesting, and recertification of personnel are also specified. Vendors qualify personnel and maintain records of qualified personnel in accordance with applicable codes, standards, specifications, and vendor Purchane Order / Contract requirements. The department that is contracting services is responsible for the review of records of qualified personnel, equipment and procedures associated with special processes.

CY Oversight performs, as appropriate, audits, and surveillances of the personnel qualification process.

The CY.NU Nue! ear Oversight Department is responsible for ensuring that the l training, testing, and certification of NDE personnel at the HNP is in accordance with the requirements of Regulatory Guide 1.58 (Rev.1,9/80) and ASNT Recommended Practice No. SNT-TC-1 A.

9.2.3 SPECIAL PROCESS RECORDS Records provide objective evidence that special processes were performed in accordance with 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 CY as required by contract or purchase order. If records are to be retained by the supplier, the contract or purchase order specifies the retention ,

period and instruction for final disposition of records. '

I Special process documentation such as special process procedures, qualifying data, and personnel and equipment qualification records associated with the l

performance of special processes at nuclear power plants, are kept current and I maintained in appropriate CY files, with final disposition to the Nuclear Document Services Facility.

QAP 9.0 afi33 CYQAP REV: '024 l

l QAP 10.0 INSPECTION 10.1 GENERAL REOUIREMENTS Inspection of activities to verify the quality of systems, structures and components, which are performed by or for CY are executed in accordance with the CYQAP and appropriate procedures, instructions and drawings by qualified personnel independent from the individual or group performing the activity being inspected. Ifinspection is impossible or disadvantageous, indirect controls by monitoring processmg methods, equipment and personnel are provided. Inspection notification and hold pomts are identified, as required, j in the applicable documents. '

10.2 IMPLEMENTATION I 10.2.1 INSPECTION RESPONSIBILITIES During maintenance and modification of the IINP, procedures shall define the  ;

need for inspections (e.g., receipt inspections, installation, and product acceptance).

CY Oversight shall ensure procedural requirements are met by means of audits l and surveillances as defined in C(_ Nuclear Oversight Department procedures. l CY Oversight shall perform inspections of modification and maintenance activities on systems, structures, and components governed by the CYQAP. The criteria used to determine when CY Oversight inspection shall be required for these activities and for the preparation ofinspection plans shall be identified in appropriate procedures. CY Oversight shall be responsible for this inspection function which includes:

a. Identification ofinspection personnel;

b. Review of work procedures and work documents to identify QA " hold" points associated with the work ;

c. Preparation and approval ofinspection plans ensuring that the necessary inspection requirements, methods, and acceptance criteria have been identified; and

d. Documentation ofinspection results.

CYAPCcNuc!:ar ' Ster!6 and Document Manage:nent is responsible for the l performance, as appropriate, of off-site audits, surveillances, and inspections to verify that any vendor utilized in the maintenance and modification of the IINP are effectively complying with their quality assurance program requirements for inspection and for performing / witnessing inspections at " hold" or " notification" points identified in procurement documents.

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CY Oversight performs, as appropriate, on-site audits, surveillances, and I inspections of vendor activities.

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 sxperience, as appropriate.

During the performance of CY work activities, procedures provide criteria for the determination of accuracy requirements ofinspection equipment and when i inspections are required. These procedures describe requirements for the preparation of surveillance and/or inspection plans by CY Oversight.

The inspection criteria, including the use ofinspection equipment and their accuracy requirements, are specified in the CY Oversight surveillance / inspection

. plans.  !

10.2.3 INSPECTION PERSONNEL AND INSPECTION DOCUMENT ACCESS '

Inspections are performed by individuals other than those who performed or directly supervised the activity being inspected. Inspection personnel are qualified and/or certified in accordance with appropriate codes, standards, and/or training programs; Inspections are perfomied by CY Oversight personnel or qualified contract personnel. The Department that is contracting on-site QA inspection services shall be responsible for the review and acceptability of vendor personnel / equipment certification prior to the initiation of the activity; When vendors are contracted to perform inspection sersices, their inspection plans / procedures are reviewed and concurred upon by CY Oversight in accordance with QAP 5 0, " Procedures, Instructions, and Drawings."

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

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1 10.2.4 INSPECTION PROCEDURES (a) Required inspection or surveillance activities are performed and l documented in accordance with procedures and/or checklists. Inspection procedures, plans or checklists contain the following:

(1) Identincation of characteristics to be inspected; (2) Identincation of the individual or groups responsible for performing the inspections; (3) Requirements for the necessary measuring and test equipment and the required accuracy of this equipment; (4) Acceptance criteria:

(5) A dercription of the method ofinspection when other than direct visus. xamination using the unaided eye; .

i (6) A record of the results of the inspection; and/or i (7) Record ofinspector or data recorder.

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

(c) ModiGeation, 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 / operation must be performed or witnessed and signed off by the responsible personnel before work can proceed. Notincation points are used to identify the operations or completed processes that CY Oversight or its representatives may elect to witness and/or inspect during the manufacturing or installation process. Mandatory hold and notincation points, as required, are identiDed in procurement documents and work procedures / documents. Purchase Order / Contracts and work procedures / documents are subject to the review and concurrence for adequacy ofinspection, notincation and/or mandatory hold controls by CYAPCoby Nuclear Materia end Document Management and CY Oversight, respectively.

QAP 10.0 2837 CYQAP REV: 024 l

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10.2.6 INSPECTION RESULTS EVALUATION l

l Inspection results are evaluated for acceptability in accordance with procedures

{ which identify the responsible organization.

The evaluations are performed by the responsible personnel who are qualified in accordance with the appropriate Regulatory Guide / ANSI Standard commitments listed in Appendix C.

CY Oversight performs audits and surveillances to assure that inspections are performed per the requirements of applicable CY procedures.

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! QAP 10.0 312M t- CYQAP REV: 024 l

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l l QAP 11.0 TEST CONTROL <

11.1 GENERAL REOUIREMENIS l ~A documented test control program is established by the CYQAP for systems, structures  !

and components to ensure that they will perfonn satisfactorily in service and that test results are documented in aaordance with 10 CFR 50, Appendix B and other pertinent regulatory l and/or tec;mical requirements. l The test control program identifies the systems, structures and ccmponents to be tested, method of conducting tests, evaluation of tests and documentation of tests by qualified personnel to assure requirements have been satisfied. l The test control program is ' systematic and includes proof tests prior to installation, construction tests, operational tests, surveillance tests, and retest following repairs, replac'ernents, preventative maintenance or modifications.

11.2 IMPLEMENTATION 11.2.1 TEST PROGRAM Test requirements to detennine or to verify the capability of an item to meet specified requirements in accordance with engineering / design documents, Safety Analysis Reports (SAR), technical specifications, procedures or procurement

- documents, as appropriate, are accomplished by subjecting the item to a set of  !

physical, chemical, environmental or operating conditions. Retest following l repair, replacement or modification is performed in accordance with the original design requirements or acceptable alternatives and is perfonned when original test results are invalidated.

l CY procedures are written and approved to delineate the methods and responsibilities for controlling, accomplishing and documenting testing during maintenance and modification of the IINP.

Vendors utilized in the maintenance and modification of the IINP are responsible for implementing measures for the control of tests to ensure that materials, equipment and parts will perform satisfactorily.

CYAPCcNue!:ar Material and Decument Menagement is responsible for the l performance, as appropriate, of off-site audits, surveillances, and inspections of selected proof tests when hold points have been identified in Purchase Order / Contracts of vendors to verify they are complying with their quality assurance program requirements for test control.

i L CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of the vendor activDies, i

QAP 11.0 4240 CYQAP REV: 024 l

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Proof tests, product acceptance tests, retests, and periodic surveillance tests are conducted by qualified personnel in accordance with procedures. Personnel performing tests ensure that calibrated equipment and instrumentation utilized are within the calibration interval specified. Documentation including test procedures and data sheets are maintained in appropriate files.

. I1.2.2 TEST PROCEDURE PREPARATION AND TEST PERFORMANCE

l. Testing is accomplished in accordance with test procedures which incorporate or

j. reference the requirements and acceptance criteria in the applicable design and L procurement documents. The test procedure or test program documents include the following as a minimum:

a. Instructions for the testing method used; L

b. Required test equipment and instrumentation;

c. Test requirements, such as acceptance and rejection criteria; l d. Hold, notification, inspection and data collection points,

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

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

g. Provisions for data collection and storage.

l 11.2.3 TEST EOUIPMENT CY procedures provide the criteria for determining when a test is required and the accuracy requirements of test equipment.

The following steps are taken in the control of test equipment:

a. Test instrumentation is checked and calibrated in accordance with CY procedures to ensure accuracy;

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

preventative maintenance procedures; and,

c. Where special instrumentation is 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.

L . QAP 11.0 4140 l

CYQAP

~ REV: ~024 l

I 11.2.4 EVALUATION OF TEST RESULIS 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 approved procedures.

The evaluation of test results may also be delegated to vendors. When delegated, contracts require the vendor to assure the use of qualified personnel, evaluate the l data against predetermined criteria and document the results of the evaluation and acceptance status of the test.

CYAPCcMue! ear " ate:ial aad Document Meragement is responsible for the l j

performance of off-site audits, surveillances, and inspections, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for test control.

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of the activities.

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l QAP 11.0 4240 CYQA.P REV: 024 l

OAP 12.0 CONTROL OF MEASURING AND TESTING EOUIPMENT 12.1 GENERAL REOU!REMENTS l

The CYQAP provides measures for the control ofmeasuring and testing equipment (M&TE) used as the basis for acceptance in activities affecting quality during inspection, testing and measurement of materials, equipment and parts. Periodic calibration and adjustrnent of measuring and test equipment is perfonned and controlled to assure accuracy is maintained within limits necessary to verify that design and operating condition requirements have been met. Documentation is retained such that all items of M&TE are traceable to their calibration records.

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

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

The calibration program is implemented in accordance with the requirements defined in CY procedures which describe the measures utilized to maintain M&TE. Functional groups are responsible for implementing these procedures which comply with the requirements contained in specifications and drawings.

The Plant Operations Review Committee (PORC) reviews and approves M&TE administrative procedures related to the M&TE calibration program.

CYAPCcMuclear Materials and Document Management or the appropriate l 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. CYAPCoNuelear Materials and Deeumen* Management and CY Oversight are responsible for the calibrated i

M&TE used during their inspections, respectively.

QAP 12.0 4143 CYQAP REV: 024 l

Department Heads / Supervisors are responsible to ensure that M&TE equipment is calibrated, issued, and controlled in accordance with the requirements of the procedures. The " activity" Supervisor shall ensure that the users of the M&TE are properly instructed in the use and control of the M&TE. HNP Departments are responsible for calibrating M&TE within the required interval or removing the M&TE from service until the required calibration can be performed.

CY departments are also responsible for reviewing calibration data associated with M&TE calibration by outside vendors in accordance with the procedures.

CY Oversight performs audits, surveillances, and inspections to verify l implementation of the M&TE program.

Vendors utilized in the maintenance and modification of the HNP are responsible for implementing measures for the control of M&TE to ensure they are properly  !

calibrated, adjusted and maintained at specified intervals in order to maintain accuracy within required limits. )

1 CYAPCcNuc! ear Materials and Document Management is responsible for the l perfonnance of off-site audits, surveillances, and inspections, of the quality assurance programs of vendors to verify that they are effectively complying with their requirements for control of M&TE.

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of vendor activities.

12.2.2 CALIBRATION STANDARDS Measuring and test equipment is calibrated at specified intervals based on the I 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.

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

QAP 12,0 4443 CYQAP REV: 024 l

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l Calibration of this equipment should be against standards that have an accuracy of l at least four times the required accuracy of the equipment being calibrated. When l this is not possible, the standards shdi have an accuracy that assures the i equipment being calibrated will be within required tolerance and the basis of I acceptance is documented and authorized by the manager of the applicable group I or the 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. l I

12.2.3 "OUT OF TOLERANCE" CONTROL l l

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 ofitems previously measured or tested. l l

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l QAP 12.0 4543 CYQAP REV: 024 l

- j QAP 13.0 HANDLING. STORAGE AND SHIPPING l

i 13.1 GENERAL REOUIREMENTS Measures are established by the CYQAP using procedures, instructions and procurement documents to ensure proper handling, storage, shipping, cleaning and preservation of material, equipment and parts. These measures are imposed during maintenance and modification activities in order to preclude damage, loss or deterioration of materials, equipment and parts.

13.2 IMPLEMENTATION 13.2.1 GENERAL Procedures, instructions and procurement documents define the requirements and l responsibilities for the handling, storage, shipment, cleaning and preservation of l material, equipment, and parts required for implementation of established design l

and specification requirements.  !

Handling, storage, cleaning and preservation requirements of material, equipment and parts is conducted in accordance with procedures and procurement documents.

Vendors utilized in the maintenance and modification to the HNP are responsible for implementing measures for handling, storage, shipping, cleaning and preserving materials, equipment and parts to preclude damage, loss or deterioration.

i CYAPCcNue! ar Mater! and Document Manc;;ement is responsible for off-site l audits, surveillances, and inspections, as appropriate, to verify that vendors are effectively implementing and complying with the approved procedures and instructions for handling, storage, shipping, cleaning and preservation of materials, equipment and parts.

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of the activities.

13.2.2 ESTABLISHMENT OF SPECIAL HANDLING. STORAGE. SHIPPING.

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

CY procedures describe the measures taken for the storage of chemicals, reagents (including control of shelflife), lubricants, and other consumable materials. l QAP 13.0 4646 CYQAP REV: 024 l

QAP 14.0 INSPECTION. TEST AND OPERATING STATUS  !

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14.1 GENERAL REOUIREMENTS I The CYQAP 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 material, equipment and parts throughout the maintenance and modification of the HNP to preclude the inadvertent bypassing ofinspection and test requirements. These measures provide for the identification ,

ofitems which have satisfactorily passed required inspections and tests. Measures are also l established for indicating the operating status of systems, structures and components to prevent inadvertent operation. I i

14.2 IMPLEMENTATION I 14.2.1 GENERAL i

Vendors utilized in the maintenance and modification of the llNP are responsible I for implementing approved measures for the identification ofinspection and test  ;

status of material, equipment and parts to preclude the bypassing of requirements.

CVAPCcNuclear '!aterials and Document Management is responsible for the l perfonnance of offsite audits, surveillances, and inspections of vendors, as appropriate, to verify that they are effectively complying with their requirements for identification ofinspection and test status, in compliance with procedures and instructions.

Elements of this system require that vendors have a controlled manufacturing and test operation, in order to preclude the inadvertent bypassing of process  ;

inspections or tests, and to provide a positive identification of component status I throughout all phases of manufacturing, testing, and inspection by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other appropriate methods.

When Receipt Inspections are performed at Millstone Station or the HNP, CYAPCcNuclear Materials and Document Management ensures that traceability l is maintained for acceptable materials, equipment and parts, to indicate conformance to Purchase Order / Contract requirements. Material used at CY that requires traceability to be maintained is delineated in the appropriate CY procedure.

Nonconforming materials, equipment and parts are id' ' dlied in accordance with QAP 15.0, " Nonconforming Materials, Parts, Componente or Services" and/or QAP 16.0," Corrective Action."

QAP 14.0 4Z47 CYQAP REV: 024 l

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During tests and inspections of operating systems required to support the storage of the spent fuel, a status tagging system is implemented, as per approved l l procedures and instructions, to prevent inadvertent operations of systems, l

structures and components. '

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

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of the activities.

14.2.2 STATUS IDENTIFICATION AND CONTROL i

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Procedures and instructions describe control of the application and removal of markings such as stamps, tags, labels, and other suitable means to indicate the status of systems, structures and components to prevent inadvertent operation, and to preclude omission ofinspections, tests or other critical operations. These procedures and instructions delineate the requirements, methods and l responsibilities for indicating the status of the affected items. The complete status of all items under the calibration system is recorded and maintained.

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

I QAP 14.0 1847 CYQAP l REV: 024 l l

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OAP 15.0 NONCONFORMING M ATERI ALS. PARTS. COMPONENTS.

OR SERVICES 15.1 GENERAL REOUIREMENTS The CYQAP requires that documentation and control of nonconforming materials, parts.

l components, or services utilized in systems, structures and components during maintenance

! and modification of the HNP be performed in accordance with procedures in order to prevent inadvertent use or installation. These procedures include appropriate requirements for identification, documentation, segregation and disposition of nonconforming items, and notification to affected organizations.

15.2 IMPLEMENTATION 15.2.1 PROGRAM Procedures define personnel responsibilities and establish various measures for identification, documentation, segregation, review and disposition of nonconforming item reports. Report mechanisms are available to all CY and contractor NU-personnel.

15.2.2 DOCUMENTATION l

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

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

15.2.3 EVALUATION AND DIFPOSITION 1

Evaluations are performed to determine the impact on system, structures and component operability and to determine the disposition of nonconforming items and services. The evaluation determines whether an item or service is to be used as is, returned to vendor, repaired, or scrapped. An engineering evaluation is perfomied, if necessary, prior to the resolution of nonconformances. These evaluations assure that the final condition does not adversely affect safety, l operation or maintenance of the item or service, or of the component or system.

Reports involving deviation from design bases such as "use as is" or " repair" are forwarded to the appropriate engineering organization for review, and disposition.

Applicable information is accumulated and records are maintained.

QAP 15.0 4949 CYQAP REV: 024 l

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

a. Impact on plant safety; j b. Safety of personnel; i

l c. Suitability of material or items in the "as is" condition, i.e., probability of L

eventual satisfactory resolution of the nonconforming without repair, rework or replacement;

. d.- Accessibility of material or items after release;

e. Cost of removal and repair or rerf acem.;nt should material or items eventually have to be removed, ri. paired, or replaced; and

f. Effect on the orderly progress of work.

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

Items repaired may require reinspection as defined in procedures.

CY Oversight performs audits and surveillances to verify that dispositions for reports documenting nonconforming conditions are adequate.

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l QAP 15.0 5040 CYQAP REV: 024 l

OAP 16.0 CORRECTIVE ACTION r

16.1 GENERAL REOUIREMENTS The CYQAP requires that an effective corrective action program be established for CY and l their vendors to ensure that conditions adverse to quality are promptly identified and corrected as soon as practicable and documented in accordance with approved procedures.

These procedures include measures for determining the necause and corrective action to l

preclude recurrence for conditions identified '-'" as significant conditions adverse to L quality.

16.2 IMPLEMENTATION 16.2.1 PROGRAM Procedures define personnel responsibilities and establish various measures for identification, documentation, evaluation / review, disposition and correction of conditions adverse to quality and significant conditions adverse to auality.

Reporting mechanisms are available to stationNU personnel.

16.2.2 CORRECTIVE ACTION AND FOLLOW-UP L

Procedures describe the measures taken to evaluate if conditions adverse to quality exist and to determine the need for immediate corrective action or disposition. The Vice President - Onerations and DecommissioningExecutive Vice President and Chief Fuelear Omcer is responsible for ensuring that the assigned personnel and their vendors working at ilNP comply with the corrective action program and for ensuring that corrective action is adequate and properly implemented in a timely manner at the IINP.

CY Oversight. Conective Actions. is resnonsible for ensuring that conditions adverse to anality are nromntiv identified and corrected in accordance with annroved nrocedures.

CY Oversight. Quality Assurance. performs audits and surveillances to verify that l organizations working at the HNP comply with the corrective action program and that corrective action is adequate and properly implemented in a timely manner.

The Vice President - Onerations and DecommissioningExecutive Vice President i and Chief Nuclear 05cer has the final authority in the event that agreement on the action to be taken is not reached at the appropriate organization levels within the CY organization

- QAP 16.0 fi164 4

-CYQAP REV: 024 l

16.2.3 RECURRENCE CONTROL

! Procedures provide responsibility and the process for determining afpropriate significance based on actual or potential consequences for conditions adverse to quality and requirements for evaluation and corrective action.

l .. Procedures also establish the responsibilities and measures taken to accomplish 1

( these actions.

An analysis of conditions identified as adverse to quality is developed and adverse i

trends are periodically reported to management by the organization responsible for controlling the problem reporting program. Trends concerning specific vendor performance shall be reported to the affected contractor for resolution, if

! appropriate.

l l CY Oversight performs audits and surveillances to verify that the corrective action program is adequate and controlled in accordance with procedures.

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QAP 16.0 5264

CYQAP.

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i OAP 17.0 QUALITY ASSURANCE RECORDS  ;

l 17.1 GENERAL REOUIREMENTS The CYQAP provides for the maintenance, identification, retention and retrieval of records I to furnish evidence of activities afrecting quality during maintenance and modification of i l the IINP. The records include but are not limited to:

a. Operating logs and the results of reviews;

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b. Inspections;

c. Tests;

d. Audits; i

e. Monitoring of work performance; and,

f. Material analyses.

The 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 ofinspector 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.

l 17.2 IMPLEMENTATION Procedures and instructions establish the responsibilities and requirements for the l maintenance, identification, retention and retrievability of records pertaining to materials, equipment, parts, processes or operations relating to systems, structures and components L which when founded on observations, measurements or tests can be fully verified, and documented by cognizant personnel.

CY procedures define the documentation requirements for inspection and test records, as appropriate. ,

Vendors utilized in the maintenance and modification of the liNP are responsible to implement measure'. for identification, maintenance, retention, retrieval and tumover of l records to CY personnel which contain objective evidence of quality, as specified in l - Purchase Order / Contracts.

j< CYAPCcNuclea- Material: and Document Management is responsible for off-site audits, l l surveillances, and inspections, of vendors, as appropriate, to verify they are effectively coinplying with their program for quality assurance records.

QAP 17.0 1353 CYQAP REV: 024' l l

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of these activities.

Quality Assurance records are identified, controlled and maintained in appropriate fdes and are identifiable to specific systems, structures and components at IINp. When identification to a specific system, structure or component is not practical, records are filed by category (e.g. specification, nonconfomaance reports, audits, etc.).

17.3 RETENTION CY quality assurance records are classified as life records or nonlife records as delineated by NU-Nuclear Document Services. Nonlife records are those documents that are l maintained for a specific period of time other than the lifetime of the in-service nuclear power 14 ai.' or the particular component or part. Life records are those documents dat are maintainea for the lifetime of the in-service nuclear power plant or for the life of the particular component or part. Life records are those which would be of significant value in meeting one or more of the following criteria:

a. Demonstrating capability for safe operations;

b. Maintaining, reworking, repairir.g, replacing or modifying the item;

c. Determining the cause of an accident or malfunction of an item; or l

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

Records are reviewed and approved by the cognizant qualified personnel and vendors as appropriate, and are transmitted to NU-Nuclear Document Services. The responsibility of l the NU-Nuclear Document Services upon receipt of records, is to maintain and provide I controlled retrievability of records alTecting the llNP 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 procedures.

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QAP 18.0 AUDITS 18.1 GENERAL REOUIREMENTS The CYQAP requires that a comprehensive system of planned and periodic audits shall be l carried out to verify compliance with the CYQAP during the maintenance and modification l

of the HNP. '

Audits are conducted in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities in 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 sddress any audit findings revealed by the audit.

I 18.2 IMPLEMENTATION 18.2.1 PROGRAM The audit program requires audits of corporate mid HNP quality activities under the oversight of the CY Nuclear Safety Assessment Board. Audits are performed on activities where the requirements of 10 CFR 50 and the HNP Technical Specifications are being implemented.

Audits are regularly scheduled on the basis of the status and safety importance of the activities being performed. Regularly scheduled audits are supplemented by audits for one or more of the following conditions:

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

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

c. When a systematic, independent assessment of program effectiveness is considered necessary; and / or,

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

Schedules for the audit of CY activities are originated and maintained by CY Oversight. Schedules are approved by the CY Oversight Manager Director Audits

=d Eva!= tion.

QAP 18.0 5568 i

CYQAP REV: 024 l

Audits are performed as specified in GNue! ar Oversight procedures by l ,

qualified personnel, using a pre-established written audit plan prepared by the auditing organization. Audits may include evaluation of the ivork areas, activities,  :

processes, items, and review documents and records to determine the I effectiveness ofimplementation and conformance to the CYQAP. l l Approved vendors utilized in the maintenance and modification activities to the l

IINP are responsible for developing and implementing a system of planned and l periodie audits to verify compliance with the effectiveness of all aspects of their

! quality assurance programs.

CYAPCcNuclear Materi6 and Document Management is responsible for l verifying the acceptability of vendor audit programs and for the performance of subsequent off-site audits, as appropriate, to verify compliance with the effectiveness of all aspects of their quality assurance programs. CYAPCcNuclear Materi& and Document Menagement has contracted this audit function to the DE&S. Yankee Atomic E!:e:ric Company (YAEC).

CY Oversight performs audits /surveillances of on-site vendors, as appropriate, to I verify the efTectiveness of appropriate aspects of their quality assurance programs. I l

in addition to the audits, other methods, such as surveillances, and inspections are used to ensure that quality activities are in compi iance with the CYQAP.

18.2.2 REPORTING OF AUDIT RESULTS l Audit results are reviewed, approved, and reported in accordance with G Muelear Oversight and/or DE&S Yankee Atc.nic Electric Ce.npany procedures, as applicable. The audit reports are issued to the appropriate management of the  !

area audited to ensure appropriate and/or timely corrective action is taken to address any audit fimdings. In addition, audit data and reports are included as part of the review for quality trends and assessed in accordance with QAP 16.0,

" Corrective Action."

l 18.2.3 REVIEW. ACTION. AND FOLLOW-UP OF AUDIT FINDINGS l

Audit findings are reviewed and investigated by the management having the responsibility for the area audited. The responsible management is required to:

! a. Take the necessary action to addresses any findings identified by the audit;

! b. Report the results of such reviews and investigations;

! c. Take the necessary actions to correct problems reported; and, QAP 18.0 5166 CYQAP l

REV: 024 l V

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d. Report the completion of corrective actions within specified time frames.

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

findings. Actions on audit findings which cannot be resolved by affected l management and the Vice President - Onerations and DecommissioningNuc! ar Overnight are submitted for resolution to the Chairman. CEO and President. Pres!&n

and Chief Executive Office: NU Nuclear Orcup.

i 18.2,4 RECORDS / REPORTS OF AUDITS Audit records, reports, and associated documentation pertinent to audits are dispositioned to the appropriate Nuclear Document Services Facility, as specified in procedures.

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i QAP 18.0 fi166 CYQAP REV: 024 l

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l APPENDIX A CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM CATEGORY IJ.YSTEMS. STRUCTURES. AND COMPONENTS I The pertinent quality assurance requirements of 10 CFR 50, Appendix 11 will be applied, as a minimum, to all quality activities affecting the safety function of the systems, structures,  !

and components (SSCs) of a defueled nuclear power plant, including their foundations and i suonorts. Thesesupports.The';e SSCs will be listed in Chapter 3.2 of the CY Defueled l UFSAR and will address Section 3.2.1 of NRC Regulatory Guide 1.70.

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on engineering evaluations and a revision to the CY UFSAR during the decommissioning i process. Revision of the safety classification in accordance with the CY Design Control l process is not considered a reduction in the commitments to the CYQAP.  ;

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(ab Th^ pent fuel ';temge poc! structure, :ncluding the fuel racks.

APPENDIX A E68 l CYQAP REV: 024 l

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APPENDIX A fi268 l CYQAP REV: 024 l

)

1 I

APPENDIX B CONNECTICUT YANKEE OUAI ITY ASSURANCE PROGRAM OUALIFICATION AND EXPERIENCE REOUIREMENTS MANAGER - CY OVERSIGIFI'!!CE PRFSIDE" NUC! n ^ R OVFRglG44T l

The Manager - CY OversightVie: Pre:&;;! N::  ::r Overr.!;;ht shall satisfy the following l requirements:

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

NOTE The education and experience requirements should not be treated as absolute when similar training or an outstanding record will provide reasonable assurance that a person can perform the required tasks.

APPENDIX B SD69 l CYQAP REV: 024 l 1

APPENDIX C CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS NOTE i The CYQAP is committed to utilize the guidance obtained from the following regulatory  ;

documents and their endorsed. standards. Exceptions to these positions are listed in Appendix E, i herein.-

i 10 CFR 50, Appendix 13- Quality Assurance Criteria for Nuclear Power Plants and Fuel l Reprocessing Plants.

10 CFR 50, Section 50.54, Condition of Licenses.

10 CFR 50, Section 55, Operator':; Licence: and it: Appendix A Requa!!Ecatica Progra= for Licen:;ed Operaten; cf Productien end Uti!!=:!cn Faci!!!!es. ,

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

1971.

l Regulatory Guide 1.28 - 2/79 - Quality Assurance Program Requirements (Design and l

Construction) Endorses ANSI N45.2-1977. i 1

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

Regulatory Guide 1-.33 - 2/78 - Quality Assurance PrograntRequirements (Operation)- Endorses ANSI N18.7-1976/AN33.2.

(

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

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

! l l

Regulatory Guide 1.39 - flousekeeping Requirements for Water-Cooled Nuclear Power Plants, )

9/77 - Endorses ANSI N45.2.3-1973. l APPENC'M C fi164 l CYQAP l REV: 024 l l

i

I '

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

Regulatory Guide 1.64 - Quality Assurance Requirements for the Design of Nuclear Power Plants, 6/76 - Endorses ANSI N45.2.11-1974.

Regulatory Guide 1.70 "A Guide for the Organization and Content of Safety Analysis Reports" Revision 2, Scotember.1975 S ;" ember,1975 was utilized for CY, however, certain revised l

sections of the CY UFSAR are written to the Revision 3 format. No new analyses have been performed which would be required by Revisim 3.

Regulatory Guide 1.88 - Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records - 10/76 Endorses ANSI N45.2.9-1974.

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

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

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

Regulatory Guide 1.144 - Auditing of Quality Assurance Programs for Nuclear Power Plants - Rev.

1 - 9/80 Endorses ANSI N45.2.12 - 1977.

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

Regulatory Guide 1.152 " Criteria for Digital Computers in Safety Systems of Nuclear Power Plants, " January 1996 - Endorses IEEE-ANS 7.4.3.2 - 1993.

i APPENDIX C fi264 l CYQAP REV: 024' l

l APPENDIX D l

CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM GLOSSARY OF OUALITY ASSURANCE TERMS I

Accent As Is -(also known as "Use-As-Is") A disposition which may be imposed for a nonconformance when it can be established that the discrepancy will result in no adverse conditions and that the item under consideration will continue to meet all engineering functional requirements including perfbrmance, maintainability, fit and safety, i

Apnroved Vendors - Contractors, suppliers, and engineering service organizations who have been  !

approved to provide quality related rnaterial, equipment, parts, and services, or computer software j l to the Nuclear Group under their QA Program. l l

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

Aud11 - A formal, documented activity performed in accordance with written checklists or procedutes to verify by evaluation of objective evidence that a quality assurance program has been developed, documented, and implemented in accordance with applicable requirements.

Augmented Ouality - Nonsafety related items for which a design basis or regulatory commitment )

has been made. The augmented quality items are included within the scope of CY Quality Assurance Program. These items are the Fire Protection Quality Assurance _(FPQA), =d RWQA Radwaste Quality Assurance.(RWQA). and Snent Fuel Ouality Assurance (SFOA) programs.

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

Categorv 1 - Designation given to systems, structures, and components of the HNP that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

Category I Systems. Structures. and Comnonents - Defined in the CY UFSAR and functionally described in Appendix A., herein.

Cleaning - Those actions performed to maintain an item in accordance with cleanliness requirements.

L APPENDIX D SlS7 l CYQAP

l. REV: 024 l

l Commercial Grade Item (CGil- A commercial grade item pei 10CFR21 is a structure, system, or component, or part thereof that affects its safety function, that was not designed and manufactured as a basic component. Commercial grade items do not include items where the design and manufacturing process require in-process inspections and verifications to ensure that defects or failures to comply are identified and corrected (i.e., one or more critical characteristics of the item

)

cannot be verified). l l

Commercial Grade Survev - Activities conducted by the purchaser to ascertain and verify that a supplier, or manufacturer of commercial grade items, controls the technical and quality characteristics determined to be critical for satisfactory performance of specifically designated commercial grade items, as a method to accept those items for safety-related use. l Condition Adverse to Ouality - Failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances.

1 l

Connecticut Yankee Ouality Assurance Program (CYOAP)- Consists of the CYQAP, Nuclear Oversight Department Procedures and other CY Group / Division / Department / Branch /Section l quality procedures.

l Contractor - Any organization under contract for fumishing items or services. It includes the l temis Vendor, Supplier, Subcontractor, Fabricator and subtier levels of these where appropriate.

The Nuclear Steam Supply System (~NSsS) Supplier is included in this category.

Corrective Action - Action taken to correct identified conditions adverse to quality.

Decommission - means to remove (as a facility) safely from service and reduce residual i radioactivity to a level that permits release of the property for unrestricted use and termination of I license.(10 CFR 50.2)

Deficiencies - Departures from specified requirements.

Department - The use of the word department, throughout the CYQAP, can refer to any portion of the CY organization or support organizations from NU Nuclear (i.e., Group, Division, Department, Branch, Section, or Unit as applicable).

Design - Technical and management processes which lead to and include the issuance of design autput documents such as drawings, specifications, and other documents defining technical requirements of systems, structures, and components.

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

APPENDIX D E467 l CYQAP REV: 024 l 1

1 Design Documents - The drawing, calculation, specification, or other document (s) that define the Technical requirements of systems, structures, or components. l l

Dalke Engineering and Services (DE&S)- is a comnany that nrovides contract services. in the l areas such as design. construction. engineering. anality assurance. licensing. operation.

decommissioning sunnort services.etc.

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

HNP- Haddam Neck Plant is used throughout this document to define the Connecticut Yankee plant site.

)

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

1 11cm - Any level of unit assembly, including structures, systems, subsystems, subassembly, ,

I component, part or material.

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

1 Insnection Status - Identification of material, equipment, and parts that have completed j inspection, either acceptable or unacceptable. l l

Maintenance and Modifications - Refers to the required functions for design, construction, testing, I maintenance, operation, and modification of facilities at the HNP during decommissioning activities.  ;

1 Material Reauest - The computerized format used for identifying material and services to be procured using the Materials Information Management System (MIMS)

Measuring and Test Eauinment - Those instruments, gages, tools, fixtures, reference and transfer standards, nondestructive test equipment, and measuring devices used during inspection and testing to determine that the measuring and test parameters comply with appropriate requirements in specifications and drawings.

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

APPENDIX D 6167 l CYQAP REV: 024 l l

l t

j -4 Northeast Utilities (NU)- A public utility holding company which owns Northeast Utilities Service Company and The Northeast Nuclear Energy Company and through its operating subsidiaries has a controlling interest in The Connecticut Yankee Atomic Power Company, l

i Northeast Utilities Service Comnany (NUSCO)- A wholly owned subsidiary of Northeast i Utilities that provides management, qual!!y assurance, and various services forcupport function:

for the Nertheast Utilities nue! ar pc /.er p! ant: including the IINP.

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

1 Nuclerr Grade - The procurement classification applied to all materials and services intended for I items !isted as Cat. I in the MEPL. These may require validating documentation such as Certificate of Material Test Report, Certificate of Confonnance, Certificate of Compliance,  ;

Personnel Qualifications, etc., as specified by codes or standards, and have been designed / qualified for a nuclear application. Nuclear Grade items are manufactured / qualified under a 10 CFR 50, Appendix B program, with the vendor responsible for 10 CFR 50, Part 21.

The vendor should be approved and listed in the Approved Vendor List.

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

NUSCO Ouality Assurance Vendor List - A list identifying the approval status of the quality l assurance programs of vendors; commonly referred to as the Approved Vendors List (formally entitled the Approved Suppliers List)

Objective Evidence - Any statement of fact, infom1ation, or record, either quantitative or qualitative, pertaining to the quality of an item or service based on observation, measurements, or tests which can be verified.

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

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

I Procurement Documents - Purchase requisitions / material requests, purchase orders, contracts, drawmgs, specifications or instructions used to define requirements for purchase.

I i Product Accentance Test - Activities conducted as part of the receiving or source inspection l 3

process to verify acceptability of one or more critical characteristics of the item being inspected.

APPENDIX D 61U l CYQAP REV: 024 j i

i

hoiect Engineer - An N" or contmet-employee assigned the responsibility to coordinate the l engineering activities addressed in CYQAP, Purchased Material. Equinment. and Parts List (MEPIJ - Items procured for installation in nuclear power generating facilities systems, structures, and components, and items procured as spare MEPI, parts for potential installation in those systems, structures, and components.

Purchase Order / Contract - The document which provides the contractual basis for vendor material and services provided in accordance with CYQAP requirements.

Purchased Service - Services provided by a vendor or consultant on a QA requisition when activities are performed under a quality assurance program other than the CYQAP.

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

Quality Activities - Activities governed by this CYQAP are those that a!Tect safety-related functions of structures, systems, and components; these activities include designing, analyzing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, and modifying. Quality Activities also include activities associated with computer software used in implementing the CYQAP and Augmented Quality items as defined herein.

Ouality Procedures - The Nuclear Oversight Department procedures and other department procedures which implement the requirements of the CYQAP that are reviewed by Nuclear Overaght er CY Oversight.

Repair - A disposition applied to nonconforming material, equipment, and parts that are unsuitable for their intended purpose which are modified by the use of additional operations and/

or processes so that they are suitable for their intended purpose but may not meet all specified requirements.

Retesi- A test conducted prior to operation following installation inspections of work associated with maintenance and refueling to verify that systems, structures, and components will function satisfactorily when in operation. A retest may also be performed when original test results are invalidated Return to Vendor - A disposition applied to nonconfonning material, equipment. and parts that are unsuitable fbr their intended purpose but which are feasible to repair or rework at a vendor's APPENDIX D SZ67 l CYQAP REV: 024 l

i l

)

facihty.

Safety Related Systems. Structures. and Comnonents - Systems, Structures, and components required to mitigate the consequences of postulated accidents.

1 Soccial Processes - Processes for which the desired level of quality can only be assured through the use of additional process controls, and where control through direct inspection alone is inadequate, impossible, or disadvantageous. These processes are performed under controlled i conditions in accordance with special requirements utilizing qualified procedures. equipment, and  !

personnel. These special processes may include, but are not limited to welding, brazing, soldering,

)

cleaning, heat treating, and nondestructive testing. '

Storage - The act of holding items at the HNP or in an area other than its permanent location in the plant.

Surveillance - A documented record of the observation of work operations perfomied at CY or a <

vendor's site to assure compliance with applicable codes, standards, specifications, procedures, drawings, and procurement documents. Surveillances are not performed to a preplanned checklist.

Test and Ooerating Status - Identification of material, equipment, and part.s that are ready for test i or operation, or an existing stage of a test operation.

Testing - The determination or verification of the capability of an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental. or operating conditions.

Vendor - Organizations that provide raaterial, equipment, parts, and services, or computer software.

Venhee Atom!c Peetric Comnanv "^ 901 :: _n inecrporated company :n Mazachusetts sponsored by New England utilities that providewegoing support to nine-eemmercial nuclear plants in Ne. ' England for design, construction, engineering, quality a=urance, licensing operatiers, and decemrnissioning serv:ees.

APPENDIX D fiH67 l CYQAP REV: 024 l

_ . _ m_ _ > - . _ _ _ _ _. . _ _ _ . . . _ . _ _ _ . . . . . .. _ _ _ . . . _ . .

l l~

APPENDlX E f

CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM PROGRAM EXCEPTIONS

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

Both NNECO and CYAPCo'sCYAPCO's vaults are used for storage ofdocumentation that l is unsuitable for filming or awaiting filming.

A records organization exists along with written procedures addressing the control of  !

quality assurance records.

. 2. . ANSI N18.7-1976. paragraph 4.3.2.3 " Quorum" states in part: "A quorum for formal  !

- meetings of the (Independent Review) Committee held under the provisions of 4.3.2.2 shall consist of not less than a majority of the principals, or duly appointed attemates..."

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

No more than a minority of the quorum has line responsibility for operation / decommissioning of the IINP. No more than two alternates have voting status at any meeting in fulfillment of the quorum requirements.

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

CYAPCcNc-S=t Utilitie: has developed the following attemative definition to provide l guidance during the interim period from the time a document is completed until it is transmitted to the Nuclear Document Services Facility:

l "A record is considered a working document until it is transmitted to the appropriate Nuclear Document Services Facility (NDSF) at which time it is designated as a Quality Assurance Record. The following maximum time limits are established for the transmittal of working documents to the NDSF:

Ooerations Documents - Documentation generated during Plant Operations may be maintained, as needed, by operating plant departments, for up to one year New Construction or Betterment Documents - Documents which evolve during new

~

construction or betterment projects shall be transmitted to NDSF within 90 days of completion of a new construction project or turnover of a betterment project or plant operations.

APPENDIX E fiF0 l

CYQAP

! REV: 024 l l

Emcurement Documents - Inspection / Surveillance / Audit Reports generated during vendor oversight activities which are used to maintain vendor status for current and future l procurements may be maintained, as needed, by the Fuele= Ovemight Dep=tment CYAPCo for up to three years.

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

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

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

4. Regulatorv Guide 1.64 - 6/76. the Regulatory position states, in part, "It should not be construed that such verification constitutes the required independent design verification."

CYAPCcNerthe=t U "!!!= has developed the following attemative to allow for adequate independent design verification:

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

Did not specify a singular design approach:

Did not establish the design inputs or did not rule out certain design considerations; Is the only individual in the organization competent to perform the review.

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

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

CYAPCcNorthe=t Uflities no longer has any nuclear plants under construction. As a l result, most procurements are made for spare parts from suppliers who are not the original equipment manufacturer. In these cases, the supplier may have little or no understanding or knowledge of either the operation of the system the component is to be installed in, or applicable Post-Installation Test requirements and acceptance documentation. As such, CYAPCcNc-the=t Utilitic assumes responsibility for establishing Post Installation Test l l requirements and acceptance documentation.

i APPENDIX E ZQ70 l I

CYQAP

, REV: 024 l

l l

l

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

l Since a portion of CYAPCoNort'" Thies procurement activities involve commercial l l

suppliers which do not fully comply with the requirements of ANSI N45.2.2, Northeast Utilities Nuclear Materials and Document Management organization verifies through  ;

source inspections, receipt inspection, and/or survey activities that the quality of the materials, items, components or equipment is preserved by those suppliers to the extent that packaging, shipping, storage and handling methods are ernployed which are commensurate j with the nature of the product. l l

7. Regulatorv Guide 1.33 - 2/78. regarding audits, states in part:

)

(a) "The results of actions taken to correct aeliciencies...at least once per 6 months." 1 (b) "... technical specifications and applicable license c onditions - at least once per 12 months."

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

NU-(CYAPCo) has developed an altemative which modifies these audit frequencies to at l least once per 24 months. This alternative has previously been accepted by the NRC via license amendments 181 for CY.

This alternative also takes exception to (c) above. It deletes the requirement for Nuclear Oversight (CY Oversight) to audit the performance of the facility staff. This function will be performed by the Nuclear Safety Assessment Board.

8. ANSI N18.7-1976. Paragranh 4. states that " Plant nroegdures shall be reuew:ed by an individual knowledeeable in the area af&cted by the nrocedure no less freauently than every two years to determine if changes are necessarv or desirable" CYAPCo has developed the following alternative for olant nrocedure reviews.

Plant nrocedures will be neriodically reviewed in accordance with administrative controls.

These controls will establish a schedule (in no case less freauently that exery five years) for these neriodic reviews. Anplicable niant crocedures will be reviewed followine an unusual incident. such as an accident. unexnected transient. onerator error. or cauinment failute (mDlftmetion) as determined through the Corrective Action nrocess and following a i mndification to a system.

APPENDIX E 1170 l CYQAP REV: 024 l

Non routine nrocedures such as Abnomial Onerating Procedures. Emergency Plan Imnlementine Procedures. or othe.nprocedures whose use may be event driven. will be reviewed everv two years and revised as defined in administrative nrocedures.

The Ouality Assurance (or other indenendent) organization shall neriodically audit a samnle of routine nlant nrocedures that are used mDre freauently than everv two vears. The audit is to ensure the accentability of the nrocedures and verify that the nrocedure review and revision orogram is being imnlemented effectively. The root cause of significant deficiencies is to be determined and corrected.

The current reauirement to review each niant nrocedure on a biennial cvele results in the exnenditure of significant technical and administrative resources. Programmatic controls and nractices are in place to nrovide adeauate reviews. including.the following:

. The nlant modification nrocesses reouire that nrocedures affected by the modification be identified during the design change orenaration. and revised nrior to closure of the modification package.

• The Industry Exnerience Program involves the review ofindustry information for annlicabilit_v and the determination of further anlions. This review includes an evaluation of annlicable CY documents. such as nrocedures and the initiation of reauired changes.

. Administrative controls currentiv exist reauiring that if a nrocedure cannot be nerformedas i written. a nrocedure change must be comnleted orior to continuation of the procedure.

e Temnorary changes are occasionally generated during. or nrior to nrocedure use. Current administrative controls reauire that those changes that are nermanent shall be incornorated into the procedure via the nrocedure revision nrocess.

As nart of the audit and surveillance nrocess. nrocedures are evaluated as to adeauaev. ease of use. proner technical content. and comoliance with annlicable nians and nrograms.

e The Adverse Condition Resolution Program may reauire that a root cause analysis be nerfbrmed for some events. violations and nonconforming conditions. Where identified as contributing factors. nrocedure changes are initiated.

. Changes to Technical Snecifications and the FSAR are reviewed for notential imnact on. and initiation of changes to nlant nrocedures.

• Plant nrocedmes are annroved by annronriate personnel orior to initial use. Current administrative controls also reauire ore-iob briefings for nrocedures identified as infreauent.

This modification meets the intent of nublished regulatory reauirements involving activities imnortant to safety.

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9. ANSI N18.1 - 1971 " Selection and Training of Nuclear Power Plant Personnel" Section 4.2.2 states that "the operations manage shall hold a Senior Reactor Ooerator's License."

CYAPCO is nermanentiv defueled and is no longer reauired to maintain Senior Reac10I Ooerator's Licenses. as oreviously aonro,ed by the NRC with the issuance of Amendment 193 to the CY Technical Snecifications. Since CYAPCO is nermanently defueled the l Ooerations Manacer is no loncer reauired to maintain a Senior Reactor Ooerator's License.

CYAPCO will continue to maintain the Technical Specifications reouirtment for minimum shift crew comnosition which includes a Certified Fuel llandler.

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Anoendix F - '

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CYOAP ADMINISTRATIVE CONTROLS l-l l

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AfPkNOiX EE I470 l l - CYQAP

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1.0 ADMINISTRATIVE CONTROLS 1.0 REVIEW AND AUDIT 1.1 PLANT OPERATIONS AND REVIEW COMMITTEE (PORC)

FUNCTION 1.1.1 The PORC shall function to advise the Unit Director on all matters related to nuclear safety.

COMPOSITION 1.1.2 The PORC shall be comnosed of at least seven members. Member shall collectively have exnerience and exnertise in the following areas; Plant Onerations.

Decommissioning.

• Engineering.

Maintenance.

Health Physics.

Chemistrv/ Radiochemistry.

Quality Assurance. and Security.

• The minimum aualifications of PORC members shalLly. that all members have an academic degree in an engineering or nhysical science field. or hold a management nosition. and have a minimum of five years technical exnerience in thei resnective field of exnertise. The members of PORC shall be annointed in writing by the Unit Director. who is the PORC Chairnerson. The alternate Chairnersons of the PORC shall be drawn from the PORC members and be annointed in writing by the Unit Diiector.

ALTliRNATES 1.1.3 All alternate members shall be annointed in writirn by the PORC Chairnerson to serve on a temnorary basis: however. no more than (wo alternates shall narticinate as voting members in PORC activities at any one time.

• These areas are exemnt from the 5-vear exnerience reauirement.

APPENDIX EE Z570 l CYQAP REV: 024 l

- t MEETING FREOUENCY 1.1.4 The PORC shall meet at least once ner calendar month and as convened by the PORC Chairnerson or his/her designated altemate.

OUORUM t

1.1.5 The auorum of the PORC shall consist of the Chairnerson of his/her designated

- ahernate and four members including alternates.

l RESPONSIBILITIES 1.1.6 The PORC shall be resnonsible fon  ;

a) Review of: 1) all nrocedures reauired by Snecification 6.8 and changes thereto.

and 21 any other nroposed procedures or changes thereto as determined by the Unit Director to affect nuclear safety:

I b) Review of all nronosed tests and exneriments that affect nuclear safety c) Review of all nronosed changes to the Technical Snecifications:

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' d) Review of all pronosed changes or modifications to niant systems or caninment j that affect nuclear safety: '

e) Investigation of all violations of the Technical Snecifications. including the prenaration and forwarding of renorts couring evaluation and recommendations j to nrevent recurrence. to the VP - Onerations and Decommissioning and to the Nuclear Safety Assessment Board:

f) Review of all REPORTABLE EVENTS:

g) Review of facility onerations to detect notential safety hazards:

h) Performance of snecial review. investigations or analyses and renorts thereon as l reauested by the Nuclear Safety Assessment Board or the Unit director.

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i) Not used.

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k) Review of the Fire Protection Procram and Imnlementing Procedures.

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AUTHORITY ,

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I 1.1.7 The PORC shall:

a) Report to and be advisory to the Unit Director on those areas of resnonsibility specified in Section 6.5.1.6 (a) through (kh b) Render determination in writing to the Unit Director if ane item considered under Snecification 6.5.1.6a. though d.. above. as appronnate and as nrovided l by 10CFR50.59 or 10CFR50.92 constitutes an unreviewed safety ouestion or reauires a significant hazards consideration determination. I c) Provide written notification. meeting minutes may be used for this nurnose. to the VP - Operations and Decommissioning and the Chaimerson of the Nuclear Safety Assessment Board of disagreement between PORC and the Unil Director: however. the BP - Onerations and De commissioning shall have l resnonsibility for resolution of such disagreements nursuant to Snecification 6.1.1.

RECORDS 1.1.8 The PORC shall maintain written minutes of each meeting that. at a minimum.

document the results of all PORC activities nerformed under the resnonsibility and i authority nrovisions of these Technical Snecifications. A cony shall be nrovided to the Nuclear Safety Assessment Board.

1.2 NIICI. EAR SAFETY ASSESSMENT BOARD (NSAB) 1.2.1 The minimum aualifications of NSAB members are as follows:

a) The Chairperson and NSAB members shall have:

1. An academic degree in an engineering or nhysical science field. or hold a senior management nosition. and

2. A minimum of five years technical exnerience in their resnective licld of exnertise.

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b) The NSAB shall have exoerience in and shall function to provided indeoendent l oversight review and audit ofdesignated activities in the areas of:

Plant Operations.

Decommissioning.

l Encineerine.

i Radiclogical Safety. l Chemistry / Radiochemistry Ouality Assurance.and l

Environmental Protection.

The NSAB serves to advise the VP - Ooerations and Decommissioning on matter related to l f nuclear safety and notify the VP - Ooerations and Decommissioning within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a l l

safety significant issue and/or a safety significant disagreement between the NSAB and the organi7 ition or function being reviewed.

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1.2.2 The VP - Ooerations and Decommissioning shall annoint. in writing. a minimum of five members to the NSAB and shall designate from this membershio. in writing. a Chalmerson and a Vice Chalmerson. The membershin shall function to orovide indeoendent review and audit in the areas listed in Soecification 6.5.21 ALTERNATES l

1.2.3 All alternate members shall be annointed . in writing. by the VP - Ooerations and Decommissioning: however. no more than two alternates shall narticipate as members in NSAB activities at any one time.

MEETINO FREOUENCY 1.2.4 The NSAB shall meet at least once oer calendar auarten OUORUM i

1.2.5 The cuorum of the NSAB shall consist of a maiority of NS AB members including the Chairoerson or Vice chaimerson. No more than a minority of the auorum shall have line resnonsibility for oneration of the same Haddam neck Plant. No more than two altemates shall be annointed as members at any meeting in fulfillment of t the cuorum reauirements.

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REVIEW RESPONSIBILITIES I l

1.2.6 The NSAB shall be resnonsible for the review of: 1 1

a) The safety evaluations for changes to orocedures. eauinment. or systems. and igsts or exneriments comnleted under the nrovisions of 10CFR50.59. to verify that such actions did not constitute an unreviewed safety auestion as defined in ,

10CFR50.59- I 1

l b) Pronosed changes to nrocedures. eauinment. or systems that involve an unreviewed safety auestion as dermed in 10CFR50.59:

l c) Pronosed tests or exneriments that involve and unreviewed safety auestion as I defined in 10CFR50.59-1 d) Pronosed changes to Technical Snecifications and the Onerating License:

e) Yiolations of annlicable codes. regulations. orders. license reauirements. or I I

internal nrocedures having nuclear safety significance:

f) All Licenss_ Event Renotts reauired by 10CFR50.73:

g) Indications of significant unant'.cinated deficiencies in any asnect of design or oneration of structures. systems. or comnonents that could affect nuclear safety: l l

h) Significant accidental. unnlanned. or uncontrolled radioactive releases. i includine corrective actions to nrevent recurrence:

i) Significant onerating abnormalities or deylations from normal and exnected performance ofcquinment that could afTect nuclear safety:

l j) The nerformance of the corrective action nrogram: and k) Audit and the Annual audit Plan.

Renorts or records of these reviews shall be forwarded to the VP - Onerations and Decommissioning within 30 days fbilowing comnletion of the review.

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! AUDIT PROGRAAi RESPONSIBILITIES l

1.2.7 The NSAB audit program shall be the resnonsibility of the Nuclear Oversight l l orgam7ntion. NSAB audits shall be nerformed at least once ner 24 months in accordance with annronriate administrative nrocedures and shall encomnass:

a) The conformance of unit oneration to nrovisions contained with the Technical Snecifications and anplicable license conditions:

l b) The training and analineat ions of the unit staff:

c) The imnlementation of nrograms reauired by Snecincation 6.8:

d) The Fire Protection Program and imniementing procedures:

e) The fire protection cauinment and program imnlementation utilizing either a cualified offsite license fire nrotection engineer or an outside indenendent fire l nrotection consultant. l l

f) Actions taken to correct deficiencies occurring in couinment. structures.

systems. comnonents. or method of oneration that affect nuclear safety: and g) Other activities and doc.uments are reauested by the VP - Onerations and j Decommissioning.

RECORDS 1.2.8 Written records of reviews and audits shall be maintained. As a minimum. these records shall include results of the activities conducted under the provisions of Section 6.5.2.

2.0 RECORD RETENTION 2.1 In addition to the annlicable record retention reauirements of Title 10. Code of Federal Regulations. the following records shall be retained for at least the minimum neriod indicated.

2.2 The following records shall be retained for at least 5 years:

a) Records and logs of facility onerations:

l l b) Records and logs of nrincinal maintenance activities. insnections. renair. and i renlacement of nrincinal items of couinment related to nuclear safety:

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i c) AI L REPORTABLE EVENTS:

l d) Records of surveillance activities. inspections. and calibrations reauired by these Technical Snecifications:

e) Records of tests and exneriments:

f) Records of changes made to the orocedures reauired by Snecification 6.8.1:

g) Records of radioactive shinments:

h) Records of sealed source and fission detector leak tests and results:

i) Records of annual nhysical inventory of all sealed source material of record: and i

2.3 The following records shall be retained for the duration of the facility Onerating License; ,

1 a) Record and drawing changes reflecting facility design modifications made to systems and cauinment described in the FSAR:

b) Records of new and irradiated fuel inventory. fuel transfers. and assembly

, burnun histories:

c) Records of facility radiation and contamination surveys:

d) Records of radiation exnosure for all individual entering radiation control areas:

e) Records of gaseous and liauid radioactive material released to the environs:

f) Records of transient or onerational eveles of the reactor vessel:

g) Records of training and aualification for current members of the facility stafT:

h) Records ofinservice insnections nerformed under nrevious amendments to these Technical Snecifications:

l i) Records of auality assurance activities reauired by the Ouality Assurance Manual not listed in Snecification 6.10.2:

j) Records of reviews nerfbrmed for changes made to nrocedures or cauinment or reviews of tests and exneriments nursuant to 10 CFR Part 50.59:

APPENDIX EE 690 l i CYQAP REV: 024 l

k) Records of meetings of the PORC and the NSAB:

l l) Records for Environmental Oualification:

m) Records of reviews nerformed for changes made tegi: RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOR CALCUI ATION MANUAL (REMODCM) and the Process Control Program.

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