ML20199K321

Rev 13 to Maine Yankee Atomic Power Co,Qa Program

ML20199K321
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Site:	Maine Yankee
Issue date:	01/27/1998
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f MAINE YANKEE ATOMIC POWER COMPANY QUALITY ASSURANCE PROGRAM Revision 13

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A:\00AP.R13

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I TABLE OF CONTENTS Approval Sheet Policy Statement

1. Organization ll. OA Program l

Ill. Design Control l

IV. Procurement Document Control l i

V. Instructions, Procedures and Drawings VI, Document Control Vll. Contml of Purchased Material, Equipment and Services Vill. Identification and Control of Material, Parts and Components

. lX. Control of Special Processes

. X, inspection XI. Test Control Xil. Control of Measuring and Test Equipment' Xlli. - Handling, Storage and Shipping XIV, inspection, Test and Operating Status XV. Nonconforming Materials, Parts and Components XVI. Corrective Action  ;

XVil. Quality Assurance Records XVill Audits Appendix A Qualification Requirements Appendix B Maine Yankee C!assifications

-[- Appendix C Ouality Assurance Program For Packaging Radioactive Material For

[- Transport A:\oQAP.R13

R0v. No.: 13 Date: 1/22/98 MAINE YANKEE ATOMIC POWER COMPANY QUALITY ASSURANCE PROGRAM l

PREPARED BY: I D

kanager Quality Programs Maine Yankee Atomic Power Company

REVIEWED BY: #/47 9E

[ Director,' Operations Maine Yankee Atomic Power Company

./ ..

REVIEWED BY: # #A /M7/MM'

[ Director, Engineering '

Maine Yankee Atomic Power Company REVIEWED B' N As4.A M5 //.4a4ve ~ 7 7 d' VKPresident,'Fihanfe &'Administratl6n Maine Yankee Atomic Power Company o - # 7 I APPROVED BY: -

\Iice si lent, Nuclear Safety and Regulato'ry Affairs

. ine Yankee Atomic Power Company

[ APPROVED BY:  % .

[ Director, Decommissioning

[ Maine Yankee Atomic Power Company i

APPROVED BY: A E" ---

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/ 2 7 ff(

) President

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] Yankee Atomic Power ompany A:\00AP.R13

POLICY STATEMENT QUALITY ASSURANCE PROGRAM The ."alne Yankee Atomic Power Company Quality Assurance Program shall comply with the requirements of the Code of Federal Regulations, Title 10, Part 50, Appendix B.

The Company policy of a firm commitment to quality is best reflected in a memorandum to all cmployees from its President and incorporated into this program as Attacht nent 1.

A:\00AP.R13

ATTACHMENT 1 August 13,1997 TO: ALL PERSONNEL FROM: Michael B. Sellman, President THE QUALITY MISMDB l

The designers, builders and management of Maine Yankee Atomic Power Company have been committed to high standards of engineering and operational quality from the beginning. Duilng the ensuing years we have installed substantial plant modifications, conducted special operational performance tests, and dramatically expanded personnel training programs and staffing to insure continued quality improvements in plant reliability and safety.

Uncompromising dedication to continuous quality improvement must continue and be vigorously pursued by every member of our organization if we are to deserve the public confidence that is necessary for continued success. Among other things, uncompromising dedication to quality improvement requires:

Not only full understanding and compliance with requirements, but a willingness to continually question, upgrade and improve the requirements.

Thorough understanding of yourjob functions and an understanding of v.hy yourjob is important.

• Producing, expecting and accepting nothing but the highest standards of performance. Make sure that the right things are done correctly the first time.

Identification, repair or reporting of any equipment, process or material in the plant that is nonconforming, deficient or otherwise not up to an acceptably high level of performance.

A:\00AP.R13

ATTACHMENT 1 (Centinu:d) l The Quality Assurance Program (QAP)is the regulatory basis for the processes and i

controls we need to achieve a high level of quality and safety in plant operation.

' <ahlevement and verification of quality are line management functions which are prescribed by the OAP and its implementing procedures. The QAP has provided for the Quality Programs Department to be the principle coordinator and consultant for quality verification activities.

i I challenge every employee to actively cooperate and support our fundamental quality L objectives of continuous quality improvement, safe operation and high public confidence.

You are the key to successful pursuit of excellence in all Maine Yankee activities.

f -

3

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'b dPresident Q l

A300AP.R13 e

Titb: Section I - Oraanization Paga: 1 of 3 Rev,No. 13 Dato: 1/22/98

1. ORGANIZATION A. SCOPE This section describes the functions and relationship of personnel responsible for establishing and implementing the Quality Assurance Program.

B. RESPONSIBILITY r

The President has the overall responsibility for all aspects of the OA Program. Maine Yankee Management retains full responsibility for establishing, executing and measuring the overa'l effectiveness of the administrative controls and quality assurance program.

[ The Vice Presidents of Nuclear Safety and Regulatory Affairs, and of Finance and

[ Administration,9nd the Directors of Operations, Engineering and Decommissioning shall

[ execute the Quality Assurance Program in those organizctional units assigned responsit,ility for operation, procurement, design and construction, quality assurance and technical support activities.

[ The Vice President, Nuclear Safety and Regulatory Affairs, shall provide an

[ independent overview of Plant Operation through the Quality Programs Department.

[ The Director of Operations is the Individual with day to day responsibility for implementing the operational Quality Assurance Program within the operating

[ organization during all modes of plant operation. The Director of Operations will

[ assume the responsibkities of the generic title," Plant Manager", as defined in ANSI N 18.7-1976.

The Quality Programs Department Manager is the individual who retains overall authority and responsibility for establishing and measuring the effectiveness of the Quality Assurance Program. As a direct report of the Vice President, Nuclear Safety and Regulatory Affairs, he shall have direct access to other senior management positions and shall maintain effective communications with them on quality matters under their cognizance. The Quality Programs

[ Manager shall report regularly to the Director of Operations and Vice President Nuclear Safety

[ and Regulatory Affairs on the effectiveness of the Program.

Quality Programs Department personnel, in the pursuit of their official duties, have authority for access to all records necessary to fulfill their responsibilities, to stop unsatisfactory work and to control further processing, delivery or installation of non-conforming material.

[ The corporate officers, Directors and Quality Programs Department Manager shall review changes to the Quality Assurance Program that concern their areas of responsibility. The President and Quality Programs Department Manager shall approve all changes.

A:\00AP.R13

Titla: _Section 1 Oroanization Pcge: 2 of 3 Rsv.No. 13 Date: 1/22/98 C. ~ ORGANIZATIONAL RELATIONSHIPS l

The organizational chart on page 3 of 3 of this section shows the lines of authority, responsibility and communication from the highest managemeint level to the Intermediate levels of management.

The Quality Programs Depa;tment Manager reports directly to the Vice President, Nuclear Safety and Regulatory Affairs. The Quality Programs Manager will maintain a direct line of communications with the President. As such, Quality Programs Department personnel have:

1. Sufficient independence from cost and scheduling considerations when opposed to safety considerations.

2. Direct access to responsible management at a level where appropriate action can ba accomplished.

3. Sufficient authority and organizational freedom to identify quality problems, to initiate, recommend or provide solutions through designated channels and to verify implementation of solutions.

D. REVIEW AND AUDIT COMMITTEES As required by the Technical Specifications, two committees have been established to ensure that the plant is operated in accordance with regulatory requirements and the standards established by this Program.

1. Plant Ooerations Review Committee This Committee is composed of experienced and qualified plant personnel having direct line responsibility for plant operation. See Section 5.5," Review and Audit" of Technical Specifications.

2, Nuclear Safety Audit and Review Committee This Committee is composed of experienced and qualified personnel not having line responsibility for plant operation. See Section 5.5, " Review and Audit" of Technical Specifications.

A:\00AP.R13

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Title:

Section 11 - OA Program Page: - 1 of 17 Rev.No. 13 Date: - 1/22/98 II. QUALITY ASSURANCE PROGRAM A. SCOPE The Quality Assurance Program applies to activities affecting the quality of the identified structures, systems and components classified and designated by the

[ Director, Engineering and which are necessary to ensure the capability to prevent of  !

[ mitigate the consequences of an accident. The Director, Engineering is responsible for i establishing and maintaining documentation which designates the safety classification of plant systems. The program takes into account the need for special controls, processes, environmental conditions, equipment, tools and skills to attain the required I quality and the need for verification of quality by inspections, evaluations or tests.

B. RESPONSIBILITIES I

Compliance with the requirements of the Quality Assurance Program is the responsibility of all personnelinvolved with activities affecting safety. Individuals i responsible for establishing and executing the Quality Assurance Program are I

delineated in Section I," Organization". The Quality Programs Department shall regularly review the status and adequacy of the Quality Assurance Program, to the requiremento of 10CFR50, Appendix B, and ANSI N18.7-1976.

C. IMPLEMENTATION The Quality Assurance Program is established as required by, and to assure conformance with, Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants.

Establishment of an effective Quality Assurance Program is assured through conformance with ANSI Standards and the regulatory position of regulatory guides as specified in Paragraph F of this section, implementation of this Program is assured through procedures derived from those standards and guides.

NOTES:

1) The plant Technical Specifications shall be the governing document when determining reqv rements to be imposed in all areas, which are addressed in both technical specifications and the specified standards and guides.

2) Revisions to the specified standards and guides will be considered for applicability to the Maine Yankee Quality Assurance Program upon written direction thereof by the Nuclear Regulatory Commission.

e AAOOAP.R13

Titlo: S. action ll - OA Procram

. Page: 2 of 17 Rov. No. . 13

) Date: 1/22/98

3) ANSI Standard N18.71978 is the endorsing document for all other specified ANSI Standards. All such endorsed ANSI Standards will be implemented to the e degree of applicability indicated in ANSI N18.71976 or as modified herein.

4) Changes to the Quality Assurance Program shall be handled as follows:

a) This program shall be applicable to those activities requiring quality i,

assurance which occur commencing 90 days after acceptance of the program by the Nuclear Regulatory Commission. ,

i b) Changes that reduce commitments in the accepted description of the QA

Program, shall be submitted in accordance with 10CFR 50.4(b)(7) and 50.54 (a)(3) for NRC review and acceptance prior to implementation. Acceptance  :

will be assumed 60 days after submittal unless notified otherwise, l c) Changes that do not reduce QA Program commitments shall be submitted to

i. the NRC in accot Jance with 10 CFR 50.54(a)(3) and 10 CFR 50.71(e)(4).

1

d) Editorial changes or personnel reassignments of a minor nature do not

, require NRC notification.

I i

D. MANAGEMENT EVALUATION The Nuclear Safety Audit and Review Commi. tee (NSARC), under the direc, tion of the President, Maine Yankee, conducts evaluations of the Quality Assurance Program for compliance and effectiveness. The Chairman, (NSARC) shall bring unresolved issues to the attention of the Maine Yankee President.

4 E. TRAINING -

1. The Indoctrination and training programs shall provide the following quality assurance related activities:

t

a. Instruction as to the purpose, scope, and implementation of quality assurance manuals, instructions, and procedns, l b. Training and quelification in the principlet. and techniques of the activity being performed.

c, Maintenance of proficiency by retraining, reexamining, and/or recertifying i personnel.

l d. Documentation of the training sessions including centent, attendance, dates and results where applicable.

i A:\oOAP.R13

Tit l3: Section ll - QA Prooram Page: 3 of 17 Rev.No. 13 Date: 1/22/98

[ 2. The President, Vice Presidents and Directors of Maine Yankee Atomic Power Company shall be responsible for the overall direction of the retraining and replacement tralning programs for the facility staff to ensure they moet or exceed the requirements of Section 5.5 of ANSI 18.1 1971 and 10CFR 50.120.

3. All department managers shall be responsible for training and qualifying personnel assigned to their department.

F. ANSI STANDARDS AND REGULATORY GUIDES The Quality Assurance Program is written to conforrr, ;v the ANSI standards and regulatory guldes listed below, as modified herein.

1. ANSI N18.1 1971, Selection and Trainino of Nuclear Power Plant Personnel, as modified by Regulatory Guide 1.8, Revision 1.

a. EXCEPTION:

Maine Yankee takes exception to the provisions of Paragraph 4.5.2 which requires technicians in responsible positions to have a minimum of two years of working experience in their specialty.

ALTERNATIVE:

[ Maine Yankee will adhere to the following:

[ Technicians shall meet or exceed the minimum qualifications of:

( 1. Two years experlene o applicable to their specialty, or

( 2. Two years of related academic training in engineering or science and

[ one year experience applicable to their specialty and successful

[ completion of a qualification program applicable to their specialty.

(-' b. EXCEPTION:

[ Maine Yankee takes exception to the provisions of paragraphs 4.2.1,4.2.2,

[ 4.3.1,4.5.1,5.1,5.2 and 5.5.1 which requires the identified positions to have

[ NRC licenses.

.(_ _ ALTERNATIVE:

[ In lieu of the above, no personnel are required to hold NRC licenses. I A:\OQAP.R13

Title:

Section ll - 0A Prooram Pagx 4 of 17 Rev.No. 13 Date: 1/22/98

[ c. EXCEPTION:

-[ Maine Yankee takes exception to the provisions of paragraphs 5.2 and 5.5.1

[ which discusses training of candidates for NRC eraminations and retraining,

[ respectively.

[ ALTERNATIVE:

[ Maine Yankee will provide Certified Fuel Handler (CFH) training on subjects _

( applicable to the permanently defueled mode, in addition, CFH training

[ need only maintain proficiency in allowed activities.

[

l

2. ANSI N18.7 - 1976, Administrative Controls and Qualltv Assurance for the i Qocrational Phase of Nuclear Power Plants, as modified by Regulatory Guide 1.33, Revision 2, and the following exceptions, i

a. EXCEPTION:

The following exception is taken by Maine Yankee.

ANSI standards not referenced in ANSI N18.7-1976, but which are referenced in an ANSI standard endorsed by N18.71976 shall not be considered as applicable to the Maine Yankee Quality Assurance Program.

ALTERNATIVjt Maine Yankee may use the noted standards as guides, as necessary.

b. EXCEPTION:

Maine Yankee takes exception to Section 4.3 " Independent Review Program" and Section 4,4 " Review Activities of the Onsite Operating Organization".

ALTERNATIVE:

Section 4.3 refers to requirements for the Nuclear Safety and Audit Review Committee (NSARC). Technical Specification 5.5 B establishes appropriate requirements for independent review for NSARC.

Section 4.4 refers to requirements for the Plant Operations Review Committee (PORC). Technical Specification 5.5.A establishes appropriate

requirements for review activities of the onsite operating organization.

1 A:\00AP.R13

Titl3: Section ll - QA Program Pcga: 5 of 17 Rev.No. 13 Date: 1/22/98

[ c. EXCEPTION:

4

( Maine Yankee takes exception to Paragraph 5.2.1.1 of ANSI N18.71976 -

. [ which discusses the RO authority and responsibility and Paragraph 5.2.1.3  ;

[ which discusses the SRO responsibilities.

[ ALTERNATIVE:

]

[ No personnel are required to hold RO or SRO licenses.

4

[ d. EXCEPTION:

Maine Yankee takes exception to the provision of paragraph 5.2.2, which requires that one of the two individuals providing approval of temporary 1 (procedure) changes "... sha!! be the supervisor in charge of the shift."

ALTERNATIVE:

Maine Yankee will adhere to Section 5.8.4 of the Plant Technical Specifications.

[ e. EXCEPTION; Maine Yankee takes exception to the application of paragraph 5.2.16, as applied to control of measuring and test equipment for radiological controls equipment. Paragraph 5.2.16 requires that an evaluation be made and documented concerning the validity of previous tests from the time of the last -

calibration when the device is found out of calibration.

ALTERNATIVE: -

It is impractical to log everywhere that a survey Instrument is used.

[ Personnel anv a pocket electronic Secondary Dosimetry Device and TLD for monitorir ..; rc.Jiation levels.

[ f. EXCEPTION:

[ Maine Yankee takes exception to Section 5.3 of ANSI N18.7-1976 which

[ requires procedures for starting up the reactor, steady-state power

[ operations and load changing, shutting down and trippino the reactor, and

[ changing modes.

ALTERNATIVE:

[ Procedures are not required for these actions in a decommissioning mode.

AAoOAP.R13

Title:

Section 11. QA Proaram Paga: 6 of 17 ,

Rev.No. 13 Date: 1/22/98 i

[ g. EXCEPTION:

Maine Yankee takes exception , application of paragraph 5.3.v '

4 Emergency Procedure Format a i Content.

i ALTERNAT!VE:

NRC Order dated July 10,1981 confirmed Maine Yankee's commitment concerning NUREG 0737, supplement 101 for TMI related items. Maine Yankee's Emergency Operating Procedures (EOP) will be written to the 1 requirements of the EOP Writer's Guide, based on NUREG 0899, submitted .

to the NRC for review on March 18,1986.

l [ h. EXCEPTION:

Maine Yankee takes exception to the provisions of paragraph 4, Section 5.2.15, REVIEW, APPROVAL AND CONTROL OF PROCEDURES, which

,. requires that " Plant Procedures shall be reviewed no less frequently than every two years to determine if changes aro necessary or desirable."

ALTERNATIVE:

. Programmatic controls will ensure that applicable plant procedures will be reviewed following an unusual incident, such as an accident, an unexpected ,

transient, significant operator error, or equipment malfunction and following any modification to a system, as specified by Section 5.2 of ANSI N18.7/ANS 3.2 which is endors 3d by RG 1.33.

i L Non routine procedures (procedures such as emergency operating procedures, off-normal procedures, procedures which implement the emergency plan, and other procedures whose usapa may be dictated by an event) will be reviewed at least every two years ano revised as appropriate.

At least every three years, the Quc!!ty Programs (or other " independent")

i organization will audit a sample of the routine plant procedures that are used more frequently than every two years.

3. ANSI N18.17 - 1973, Industrial Security for Nuclear Power Plants.

a. EXCEPTION:

7 Maine Yankee takes exception to the application of ANSI N18.17 for Security.

_ . - . _ . . . _ A:}oOAP.R13 _ _ _ _ _ _ , _ _ , _ _ _ _ __ _, _ , _ , _ , _

Titl2: Section ll - QA Procram Page: 7 of 17 Rcv.1,'o. 13 Date: 1/22/98 ALTERNATIVE:

10CFR73 requires that Security Plans be established and approved by the NRC. This provides adequate assurance that an acceptable Security Plan is established and implemented that meets or exceeds ANSI N18.17 requirements.

4. ANSI N45.2.1 - 1973, Cleanina of Fluid Systems and Associated Comoonents

~ i Durina Constniction Phase of Nuclear Power Plants, as modified by Regulatory Guide 1.37, March 16,1973.

5. ANSI N45.2.2 - 1972, Packaging. Shlooing. Receiving. Storage & Handlina of Rems for Nuclear Power Plants (During the Construction Phase), as modified by l Regulatory Guide 1.38, Revision 2, and the following exceptions, i

a. EXCEPTION:

Subsection 3.7.1 & A3.7.1 - Containers Maine Yankee takes exception to the specific requirements for containers.

ALTERNATIVE:

Containers shall be of suitable construction to assure material is received undamaged.

JUSTIFICATION:

Containers shipped by closed carrier, stored inside and net subjected to a wet environment do not require weather resistant fiberboard. Therefore, this is an unnecessary expense. Additionally, numerous vendors utilize shipping containers that do not comply with the specific requirements of this section, i.e., flaps overlap. The acceptance criteria for a shipping container should be established based on the capability of the container to maintain the component /materialin a scfa condition. Technology has advanced beyond the standard,

b. EXCEPTION:

Subsection 3.7.2 - Crates and Skids

._ Maine Yankee takes exception to the requirement that skids and runners shall be used on boxes with a gross weight of 100 pounds or more.

AAOQAP.R13

Title:

Section 11 - QA Program Pag 3: 8 of 17 Rsv.No. 13 Date: 1/22/98 ALTERNATIVE:

Skids or runners shall be used on boxes with a gross weight of 100 pounds or more if prac.ical.

JUSTlFICATION:

Storage methods and container design frequently are such that runners or skids are not feasible,

c. EXCEPTION:

Subspction 5.2.1 - Shlopina Damage insoection Maine Yankee takes exception to the requirement that a preliminary visual inspection or examination be performed prior to unloading.

ALTERNATIVE:

Maine Yankee shall perform those required inspections after unloading, in special instances, pre-unloading inspections shall be performed.

JUSTIFICATION:

Post unloading inspection is adequate to determine any damage that may have been incurred during shipping and handling,

d. EXCEPTION:

Subsection 5.2.2 - Item Insoection Maine Yankee takes exception to the requirement, that "The inspections shall be performed in an area equivalent to the level of storage requirements for the item."

ALTERNATIVE:

Maine Yankee shall perform receiving inspection in a manner and in an environment which does not endanger the requisite quality of the item; however, receiving area environmental controls may be less stringent than storage environmental controls for that item. When inspections are performed in receiving areas with environmental controls less stringent than storage area environmental controls, a time limit shall be established on a case basis for retention of items in the receiving area. Retention time shall be such that deterioration is prevented and applicable manufacturer recommendations are addressed.

Af00AP.R13

Title:

Section 11 - QA Program Page: 9 of 17 Rev.No. 13 Date: 1/22/98 JUSTIFICATION:

Receipt inspection activities are for a much shortar duration and therefore should not be subjected to the same stringent requirements as required for storage. ,

e. EXCEPTION:

Subsection 5.2.3 - Soecial Insoectl0D Malt e Yankee takes exception to attaching special inspection procedures to the item or container.

ALTERNATIVE:

Special inspection procedures shall be readily available to personnel performing inspections.

JUSTIFICATION:

! Procedures are subject to less abuse and more stringent controls when maintained on file and not attached to the item. Inspection status is maintained by tagging and procedure control,

f. EXCEPTION Subsection 6.1.2 - Levels of Storage Maine Yankee takes exception to two specific requirements associated with fuel storage (classified level A).

ALTERNATIVE:

Maine Yankee shall meet the requirements of level A storage for new fuel with the exception of special air filtering; and temperature and humidity controls.

JUSTIFICATION:

The existing storage conditions at the Maine Yankee plant is consistent with the protection provided to the fuel while in storage at the manufacturer (vendor) and while in transit to the plant site and are judged to provide adequate protection to the fuel assembly structure which is of highly corrosion resistant materials. We believe that the above listed requirements are intended for applica an at the manufacturing facility (vendor) where the uranium pellets may be exposed to the atmosphere and not in its fully A:\oCAP,k13

Title:

Section II - OA Proaram Page: 10 cf17 R:v.No. 13 Date: 1/22/98 encapsulated, and therefore, fully protected form in a completed fuel assembly.

g. EXCEPTION:

Accendix A 3 Subsection A3.5.1(1)- Caos & Plugs Maine Yankee takes exce, tion to the requirement that non metallic plugs and caps shall be brightly colored.

ALTERNATIVE:

Non metallic plugs and caps shall be of a contrasting color.

JUSTlFICATION:

l The purpose of utilizing brightly colored plugs and caps is to assist in assuring obstructions are not inadvertently placed in operating components or systems. By using plugs and caps of a contrasting color this objective can be achieved,

h. EXCEPTION:

Accendix A-3 Subsection A3.9(1)-_Second Grouo. MMkinga Maine Yankee takes exception to the requirement that container markings shall appear on a minimum of two sides.

ALTERNATIVE:

Containers shall be adequately marked to provide identification and retrievability.

JUSTIFICATION:

Containers are tagged to provide identification and inspection status.

Employment of two tags on small containers adds bulk and confusion and does not provide for better identification or traceability.

i. EXCEPTION:

Aooendix A-3. Subsection A.3.9(4)- Second Grouo. Markina Maine Yankee takes exception to the requirement that container markings shall be no less than 3/4" high container permitting.

AAOQAP.R13

Titla: Section 11_ QA Procram

~

Pcge: 11 of 17 Rev.No. 13 Date: 1/22/98 ALTERNATIVE:

Container markings shall be of a size which permits easy recognition.

JUSTIFICATION:

Markings were intended to provide Identification and instructions. The criteria should be that the markings clearly provide the same.

J. EXCEPTION:

Accendix A-3 Subsecilon A.3.9(6)- Second Groun. Markhg Maine Yankee takes exception to the information required for container marking.

ALTERNATIVE:

Marking shall be adequate in each case to provide identification, traceability  ;

and instmetions for special handling, as applicable.

JUSTIFICATION:

The information required is excessive. Cluttering a container with excessive markings oniy reduces the main objectives, maintaining identification, and establishing special controls.

- 6.

ANSI N45.2.3 - 1973, Housekeeoing Durina the Construction Phase of Nuclear Power Plants, as modified by Regulatory Guide 1.39, Revision 2, and the following exceptions.

a. EXCEPTION; Subsection 2.1 - Planning Maine Yankee takes exception to the five zone requirements specified in the subject standard.

ALTERNATIVE:

Maine Yankee shall establish as a minimum a three zone program as follows:

A:\00AP.R13

P g3: 12 of 17 R:;v. No. 13 Date: 1/22/98 Zone 111

[ Zone lli criteria shall be applied to ine Spent Fuel Pool anL opporting

( systems which are opened for inspection, maintenance, or repa;r.

j (1) Access control over personnel shall be required.

(2) Cleanliness shall be maintained, commensurate with the work being performed, so as to preclude the entry of foreign material into the systems.

(3) A documented cleanliness inspection shall be performed immediately prior to closure.

[ NOTE: The Zone lll requirements may be expanded for certain

[ maintenance / repair activities if deerced appropriate by

[ plant management. In such Instances applicable

[ sections of Zones I & il may be specified.

Zone IV i

Zone IV criteria shall be applied to the radiation control areas of the plant.

(1) Standard janitorial and work practices shall b6 utilized to maintain a 4 level of c'eanliness commensurate with company policy in the areas of Housekeeping, Plant and Personnel Safety, and Fire Protection.

I (2) Additional housekeeping requirements shall h implemented as

required for the control of radioactive contamination.

(3) Smoking and eating shall be controlled consistent with good health physics practices and to maintain cleanliness, Zone V Zone V criteria shall be applied to the remainder of the plant.

(1) Standard Janitorial and work practices shall be utilized to maintain a level of cleanliness commensurate with company policy h the areas of Housekeeping, Plant and Personnel Safety, and Fire Protection.

b. EXCEPTION:

Subsection 2.4 - Personnel Qualifications Maine Yankee takes exception to the word "all" in the subject paragraph.

A:\00AP.R13

Titlo: Section ll - OA Proaram POge: 13 of 17 RQv.No. 13 Date: 1/22/98 ALTERNATIVE:

Personnel, with unescorted access, working in zone controlled areas shall be familiar with housekeeping requirements for the various zones.

Personnel working in zoned controlled areas with escorted access will be escorted by a person with unescorted access who is famillar with the requirements,

c. EXCEPTION:

l Subsection 5.2 - Control of Facilities Maine Yankee takes exception to the control of tools, equipment, materials and supplies used in Zone Ill.

l ALTERNATIVE:

l Maine Yankee shall verify control for Zone lll as indicated in the previous exception.

7. ANSI N45.2.4 1972, Instellation. Insoection. and Testina Reaulrements for Instrumentation and Electric Eauloment Durina the Construction of Nuclear Power Generating Stations, as modified by Safety Guide 30, August 11,1972.

8. ANSI N45.2.5 1974, Sucolementarv Qualltv Assurance Reauirements for Installation. Insoection. and Testina of Structural Concrete and Structural Steel Durino the Construction Phase of Nuclear Power Plants, as modified by Regulatory Guide 1.94, Revision 1.

9. ANSI N45.2.6 - 1978, Qualifications of Insoection. Examination. and Testing Personnel for Nuclear Power Plants, as modified by Regulatory Guide 1.58, Revision 1, and the following exception.

a. EXCEPTION:

Maine Yankee takes exception to the application of the Standard to all Maine Yankee personnel performing inspection, examination and testing.

AL*[ERNATIVE:

Maine Yankee personnel identified in ANSI N18.1 1971 who perform inspect!on, examination, and testing will be qualified to ANSI N18.1 1971.

A300AP.R13

Title:

Section II - OA Prooram 14 of 17 Page:

Rev.No. 13 Date: 1/22/98 Maine Yankee personnel not identified in ANSI N18.1 1971 who perform inspection, examination, and testing will be qualified to ANSI N45.2.6.-1978.

Contractor personnel who perform inspection, examination, and testing at Maine Yankee will be quelified to ANSI N45.2.6-1978.

10. ANSI N45.2.8 - 1975, Sucolementaty_ Quality Assurance Readirements for Inslallation. insoection and Testing.gf Mechanical Equioment and Systems for Construction _ Phase of Nuclear Power Plants, as modified by Regulatory Guide 1.116, Revision 0.

11. ANSI N45.2.9 - 1974, Beautrements for Collection. Storage and Maintenance of 1 Quality Assurance Records for Muclear Power Plants. as modified by Regulatory Guide 1.88, Revision 2.

a. EXCEPTIQR

\ Maine Yankee takes exception to the requirement of " protection equivalent i of a NFPA Class A, four hour minimum rated facility, p

f ALTERNATIVE:

Door, structures, frames and hardware shall be designed to comply with the requirements of a minimum of a two (2) hour fire rating, meeting NFPA No.

232 guidelines.

12. ANSI N45.2.10 - 1973, Q.yality Assurance Terms and Definitions, as modified by Regulatory Guide 1.74, February 1974, and the following exception.

a. EXCEPTION:

Subsection 2 - Terms and Definitions Maine Yenkee takes exception to the definitions of " Certificate of

< C.:nformance" and " Certificate of Compliance".

ALTERNATIVE:

r f.. .ine Yankee shall reverse the definitions of the above terms so our Program will be in compliance with the implied definitions in the ASME B&PV Code and Maine Yankee specifications.

A:\OOAP.R13

Title:

Section ll - OA Procram Page: 15 of 17 Rev.No. 13 Date: 1/22/98

13. ANSI N45.2.11 - 1974, Quality Assurance Reaulrements for the Design of Nuclear Power Plants, as modified by Regulatory Guide 1.64, Revision 2.

3 14. AMSI M45.2.12 - 1977, Reauirements for Auditina of Quality Assurance Proarams

(

for Nuclear Power Plants, as modified by Regulatory Guide 1.144, January 1979, and the following oxceptions, 1

]

a. EXCEPTION:

Subsection 4.2.2 Team Selection Maine Yankee takes exception to the requirement that a " Lead Auditor" be appe,inted as team leader.

ALTERNATIVE:

Team Selection Audits will be performed under the cognizance of a lead auditor,

b. EXCEPTION:

Subsection 3.5.3 Maine Yankee takes exception to the requirement for supplemental audits.

ALTERNATIVE:

Maine Yankee Intemal Audits are performed on a calendar year frequency and preclude the need for supplemental audits. Supplemental Audits will be initiated by the Manager, Quality Programs as deemed necessary for significant changes in the OA Program or procedures.

c. EXCEPTION:

Maine Yankee takes exception to the thirty day requirement for issuance of the audit report.

ALTERNATIV.F; Maine Yankee will issue audit reports within thirty working days.

A:\oOAP.fd3

Title:

Section il - OA Procram Page: 16 of 17 Rev.No. 13 Date: 1/22/98

d. EXCEPTION:

Subsection 4.5.1 Maine Yankee takes exception to the thirty day requirement for corrective action.

ALTERNATIVE:

Maine Yankee will specify corrective actions and provide management M approval within thirty working days. Corrective action completion dates will

] be as specified in the audit documentation approved by management.

15. ANSI N45.2.13 - 1976, Quality Assurance Reouirements for the Control of Procurement of items and Services for Nuclear Power Plants, as modified by Regulatory Guide 1.123, Revision 1.

1G. ANSI N45.2.23 - 1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants, as modified by Regulatory Guide 1.146, August 1980,

17. ANSI N101.4 - 1972, Quality Assurance for Protective Coatings Aeolied to Nuclear Facilities, as modified by Regulatory Guide 1.54, June 1973.

18. ANSI N323 - 1978, Radiation Protection Instrumentation Test and Calibration,

a. EXCEPTION:

Subsection 6.1 Maine Yankee takes exception to the requirement that for photon and neutron monitoring instrument calibrations, tne source-to-detector distance shall be seven times the maximum dimensbn of the source or detector, whichever is larger, or suitable corrections shall be used.

ALTERNATIVE:

Maine Yankee will comply with the monitoring equipment manufacturer's technical manual recommendations for calibration using a pulse generator.

19. Regulatory Guide 1.26, Revision 3, Quality Grouo Classifications and Standards for Water. Steam and Radioactive - Waste - Containing Comoonents of Nuclear Power Plants.

A30 GAP.R13

Title:

Section II - QA Program Page: 17 of 17 Rev.No. 13 Date: 1/22/98

a. EXCEPTION:

Maine Yankee takes exception to the Guide in its entirety.

ALTERNATIVE:

Maine Yankee shall continue to classify structures, components and systems in accordance with ANSI Standard N18.2," Nuclear Safety Criteria for the Design of Stationery Pressurized Water Reactor Plants" as in the past. l l 20. Regulatory Guide 1.29, Revision 3, Seismic Desian Classification,

a. EXCEPTION:

Maine Yankee takes exception to the application of Reg. Guide 1.29, Rev. 3, (9/78).

ALTERNATIVE:

Maine Yankee shall apply Reg. Guide 1.29, Rev. 3 (9/78) to those structures, systems, and components as defined in the Maine Yankee DSAR Section 2,5.

-1 A:\00AP.R13

Title:

Section 111 - Desian Control Pags: 1 of 3 Rsv.No. 13 Date: 1/22/98 Ill. DESIGN CONTROL A. SCOPE This section establishes measures to assure that the design of and changes to structures, systems, and components covered by the Quality Assurance Program are controlled.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for evaluation and/or audit of the design control system.

[ 2. The Engineering Division shall be responsible for:

a. The control of design activities for changes to structures, systems, or components,

b. Preparation, review and approval of des',gn documents including the correct translation of applicable regulatory requirements and design bases into specifications, drawings and written documents,

c. Application of suitable design controls to such activities as: field design engineering; physics; seismic, stress, thermal, hydraulic, radiation, and

, accident analyses; compatibility of materials; accessibility for inservice inspection, maintenance and repair; and quality standards,

d. Identification, documentation, and control of deviations from specified design requirements and/or quality standards,

e. Delineation of acceptance criteria for inspections and tests.

f. Design reviews to assure that des;ge characteristics can be controlled, inspected and tested,

g. Proper selection and performance of design verification processes such as design reviews, alternate calculations, qualification testing or test programs, if the verification method is only by test, procedures shall provide: criteria that specify when verification should be by test; that prototype, component or feature testing is performed as early as possible prior to installation of plant equipment, or prior to the point when installation would become irreversible; and verification by test is performed under conditions that simulate the most adverse design conditions.

A:\OOAP.R13

Title:

Section lli - Design Control Page: 2 of 3 Rsv.No. _ 13 Date: 1/22/98

h. Subjection of design and specification changes to the same design controls and approvals that were applicable to the original design, unless designated in writing to another responsible organization. Minor changes may be performed without original design controls using approved procedures which provide appropriate alternate controls.

l. Selection of suitable materials, parts, equipment, and processes for safety classified structures, systems, and components.

J. Control of Fire Protection in accordance with YA GEN-9.

k. Notification to responsible personnel that a design change may affect perforrnance of their duties.

I. Maintenance of records which correctly identify the as-built condition of the facility for the life of the item while installed,

m. Establishing design control program procedures which prescribe:

(1) Impismentation of the provisions delineated above.

(2) Organizational responsibilities for preparing, reviewing, verifying, including independent verification and approving design documents such as system descriptions, design input and criteria, design drawings / sketches, design analyses, specifications, and procedures / instructions.

(3) Identification of internal and extemal design interface controls including lines of communication among participating design

, organizations and across technical disciplines for the review, approval, release, distribution and revision of design documents.

(4) Provisions to satisfy Regulatory Guide 1.64, Rev. 2 (ANSI Standard N45.2.11 - 1974), except as modified in Section 11 of this program,

n. Managentnt overview and overall direction and coordination of safety ,

analysis activities supporting license amendments, FSAR, and demonstration that design bases are met. l

[ o. Imposing requirements equivalent to the above on contract organizations

[ that ccnduct design change activities independent of the Maine Yankee

[ processes.

3. The Fire Protection Coordinator shall be responsibie for review of preposed design changes of fire protection systems in accordance with the Yankee Nuclear Services Division General Specifications YA-GEN-9.

A:\oQAP.R13 m

Title:

Section lli- Deslon Control-Pago: 3 of 3 Rcv.No. 13 Date: 1/22/98

4. The Director of Operations shall be responsible for;

a. Evaluation of the recommendations of the Plant Operations Review Committee,

b. Review and approval of proposed design changes.

[ 5. The M.' nager, Engineering Support, via YNSD services shall be responsible for:

[ a. Establishing and implementing a system for processing design changes.

[ b. Independent design verification of proponed design changes to assure the adequacy of design.

[

[ 6. The Vice President, Operations shall be responsible for the review and approval of all design changes.

(

A:\oOAP.P13

Title:

Section IV - Procurement Document Control Page: iof 2 Rev.No. 13 Date: 1/22/98 l

IV. PROCUREMENT DOCUMENT CONTROL A. SCOPE This section establishes measures to assure that applicable requirements necessary to assure adequate quality are included or referenced in procurement documents for material, equipment, and services.

B. RESPONSIBILITIES E 1. The Quality Programs Department shall be responsible for:

O a. Evaluation and/or audit of procurement document control, including the preparation, review, and approval of purchase requests for material, equipment, and services covered by the Quality Assurance Program.

E b. Review and specifying Quality Assurance requirements for material, equipment, and service purchases.

c. Review of safety classified purchase specifications for inclusion of proper inspection requirements and acceptance criteria.

[ 2. The Decommissioning Division shall be responsible for:

a. Proc % sing and control of requisitions for purchase orders.

b. Assuring adequate control and temporary storage of quality assurance documentation of purchased material.

c. Establishing procedures which prescribe:

(1) Preparation of procurement documents.

(2) Documentation of the review and approval of procurement documents prior to release and availability of this documentation for verification.

(3) Identification of the vendor's quality assurance requirements applicable to the items or services procured.

(4) Identification in the procurement docurnents of the documentation to be prepared, maintained, and submitted to the purchaser prior to use, such as:

(a) drawings, specifications, procedures (b) inspection and fabrication plans (c) inspection and test records (d) personnel and procedure qualifications A:\OQAP.R13

Titis: Section IV - Procurement Document Control Pags: 2of 2 Rev.No. 13 Date: 1/22/98 (e) chemical and physical test results of material (f) the company's right of access to the vendor's facilities and records for surveillance to procurement specifications. l (5) Assuring that changes and revisions to procurement documents receive reviews and approval at least equivalent to those of the original documents.

(6) Control of procurement documents for spare and replacement parts such that the tecnn; cal requirements are equal to or better than the original and that all current QA Program requirements are satisfied.

(7) Controls for procurement of commercial grade items (CGI) to be used in safety class applications such thct appropriate assurance of quality is achieved.

(8) Inclusion of 10CFR21 reporting requirements in procurement documents when applicable.

(9) Provisions to satisfy Regulatory Guide 1.123, Revision 1 (ANSI Standard N45.2.13 - 1976), as it pertains to procurement document

{ control.

(10) Selection of qualified vendors for purchasing material from the

} Approved Vendor's List.

[ 3. The Engineering Division shall be responsible for:

a. Review of purchasing specifications which detail the techn!:al requirements for material, equipment, and service purchases.

b. Reviewing and specifying technical rea ements for material, equipment, and service purchases,

c. Evaluation of commercial "off-the-shelf" items for suitability for use in safety classified systems, components or structures prior to use.

4 All departments shall be responsible for adhering to the procurement procedures established per 2.c.

A:\oOAP.R13

Titis: Section V - Instructions.

Procedures. and Drawinos Pago: 1 of 1 Rev.No. 13 Date: 1/22/98 V. INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS A. SCOPE This section establishes measures to assure that activities affecting quality are prescribed and implemented by instructions, procedures, or drawings appropriate to the circumstances.

l B. RESPONSIBILITIES

1. The Quality Programs Depar* .( shall be responsible for evaluation and/or audit of instructions, procedures, e.. Jrawings.

l 2. The Operations Division shall be responsible for establishing procedures which l prescribe preparation and use of, and adherence to procedures.

! [ 3. The Engineering Division shall be responsible for establishing procedures which prescribe preparation and implementation of design change installation instructions and drawings, including changes.

4. All departments shall be responsible for;

a. Preparing and implementing instructions and procedures associated with activities affecting quality, including computer programs controlled by Maine Yankee.

b. Assuring that specifications, instructions, procedures, and drawings include appropriate quantitative and qualitative acceptance criteria, as applicable, for determining that activities have been satisfactorily accomplished.

AdoOAP T13

Title:

Section VI - Document Control-Page: _ 1 of 2 -

Rev. No.- 13 Date: 1/22/98 q

VI. DOCUMENT CONTROL A. SCOPE i

This section estabilshes measures to assure that proper documents, such as procedures, instructions and drawings, are available for use in activities affecting quality. The measures provide for review, approval, issuance and control of documents, including revisions thereto.

B. RESPONSIBILITIES l 1. The Quality Programs Department shall be responsible for:

[ a. Evaluation and/or audit of document control systems,

b. Review and approval of all Quality Assurance implementing procedures l (0-series),

c. Review of maintenance, modification and inspection procedures for inclusion of quality assurance requirements,

2. The Finance and Administration Division shall be responsible for establishing document control procedures which prescribe:

a. Establishment of distribution lists,

b. ' Action to be taken for obsolete or superseded documents.

c. Availability of proper and current documents at the location where th activity is to be performed prior to commencing the work.

d. Establishment, revision, and distribution of a master list or equivalent to identify the current revision number of procedures, specifications, or other quality assurance documents as applicable.

e. Identification of documents to be controlled which shall include, as a minimum:

(1) Design documents, including calculations, drawings, specifications and analyses.

(2) Design, manufacturing, construction, and installation drawings (3) Procurement documents A:\oOAP.R13

Titic: Section VI - Document Control Pago: 2 of 2 Rev.No. 13 Date: 1/22/98 (4) Quality Assurance Program and Manual and maintenance and operating procudures (5) . Maintenance, modification, inspection, and test instructions (6) Test documents (7) Design change requests -

l (8) FSAR 9

(9) Nonconformance reports

[ f. Establish storage maintenance and document retention requirements for

-[ - Quality Assurance records as applicable,

[ - 3. The Engineering Division shall be responsible for:

a. Controlling the issuance of engineering drawings, general specifications, welding and non-destructive examination procedures.

b. Revision and distribution of welding and non-destructive examination procedures,

c. Maintenance and distribution of general specifications, controlled drawings and installation instructions.

d. Establishing procedures which prescribe the receipt, distribution, revision and use of Vendor Instruction Manuals.

4. All departments shall be responsible for adhering to the document control procedures established per 2, above.

5. The Operations Division shall be responsible for establishing document control procedures with prescribe:

a. Sequence of actions and responsibilities for review, approv61, and control of procedures.

b. P.eview of procedures by appropriately qualified personnel.

)

c. Review and approval of document changes by the same organizations that performed the original review and approval pI by other responsible organizations delegated by Maine Yankee.

d. Inclusion of approved changes in procedures and other applicable documents prior to placing the system in operating status.

AAOOAP.R t3

Titl@: Section Vll - Control of

_ Purchased Material. Eculoment

& Services Pace: 1 of 3 Rev.No. 13 Date: 1/22/98 Vll. CONTROL OF PURCHASED MATERIAL. EQUIPMENT AND SERVICFJ  !

A. SCOPE This section establishes measures to assure that purchased material, equipment and services, witether purchased directly or through contractors and subcontractors, conform to the procurement documents.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for;

a. Performing audits of vendor quality programs, via YNSD Quality Assurance department based on one or more of the following:

(1) Vendors capability to comply with the applicable criteria of 10CFR50 Appendix B and/or ANSI N18.7.

(2) Review ol vendors previous records and performances.

(3) Surveillance of vendors fccilities/ services and QA Program to determine vendors ability to produce the item to the purchesa specifications.

(4) Review of the suppliefs current quality records supported by qualitative and quantitative Information which can be objectively evaluated. The evaluation may include review and evaluation of the suppliefs Quality Assurance Program, Manual and Procedures, as appropriate,

a. Planned vendor surveillances, in conjunction with YNSD-OA which provide for:

(1) Specification of processes to be witnessed or verified, the surveillance method and documentation required, and personnel responsible for performing the surveillance.

(2) Assurance that the vendor complies with the quality requirements by surveillance of in-process work at intervals consisten~ with the importance, complexity and quality of the item.

AnoOAP.R13

Titla: Jection VII - Control of Purchased Material. Eouloment

& Services Page.. 2 of 3 Rev.No. 13 Date: 1/22/98

c. Documentation and maintenance of the results of vendor audits, and surveillances, including a listing of qualified vendors, in conjoction with l YNSD-QA. '

d. Surveillance of material and/or services control,

e. Surveillance of bids to assure adequacy of QA requirements,

f. Receipt inspection of vendor furnished material to assure:

(1) Material is identified and conforms with receiving documentation.

(2) Material and documentation are inspected in accordance with predetermined instructions or recognized standards and are determined acceptable prior to use.

(3) Inspection, test and other records (or certificates of conformance testing to material acceptability) are on-site prior to use.

Certificates of conformance shall contain as a minimum:

(a) Identification of purchased material or equipment, such as by the purchase order number.

(b) Specific procurement requirements met by the purchased material or equipment, such as codes, standards and other specifications.

(c) Purchase requirements not met and the resolution of the nonconformance.

(d) Attested to by a person responsible for the quality assurance function including their title.

l (4) Items are identified as to their inspection status prior to release for l

controlled storage, installation or further work.

g. Verifying the validity of supplier certificates of conformance.

h. Establishing procedures in conjunction with YNSD-QA to satisfy Regulatory Guides 1.38, Revision 2 (ANSI Standard N45.2.2 - 1972) and 1.123, Revision 1 (ANSI Standard N45.2.13 - 1976), as pertains to vendor audit, surveillance and receipt inspection.

A:\OOAP.R13 s

Titig: _S.ection Vil - Control of Purchased Material. Eauloment

& Services Page: 3 of 3 Rev.No. 13 ,

Date: 1/22/98

[ 2. The Decommissioning Division shall be responsible for:

a. Control of material and equipment until issued,

b. Establishing procedures to satisfy Regulatory Guides 1.38, Revision 2 (ANSI Standard N45.2.2 - 1972) and 1.123, Revision 1 (ANSI Standard N45.2.13 - '

1976), as pertains to control of purchased material, equipment and services.

3. All departments shall be responsible for,

a. Control of material and equipment after issuance from Stores. -

b. Bld evaluation as app;icable.

c. Evaluation of purchased services during and/or after completion of the service.

t A:\OOAP.R13

Titlo: - Section Vill - Identification &

Control of Material. Parts and Comoonents Page: ._ 1 of 1 Rev.No. 13 q Date: 1/22/98 I Vlli. IDENTIFICATION AND CONTROL OF MATERIAL. PARTS. AND COMPONENTS A. SCOPE This section establishes measures for identification and control necessary to prevent the use of incorrect or defective material, parts, and components.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for:

[ a. The evaluation, audit and/or inspection of the control and issuance of

[ materials, parts, and components.

[ b. Review of vendor C. ~ !ity Assurance Programs for traceability of materials through the use of heat number, part number, or serial number, either on the item or on records traceable to the items.

[ 2. The Decommissioning Division shall be responsible for establishing procedures for the identification and control of materials, parts, and components, including partially fabricated subassemblies and consumables, to prevent the use of incorrect, defective or outdated items. The procedures shall require tha following:

5

a. Identification is maintained either on the item, in a location and with a method which does not affect its fit or function, or on records traceable to the item.

b. Maintenance of traceability of materials and parts to the appropriate documentation s Jch as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and chemical mill test reports.

c. Identification of materials, parts, and components is verified and documented prior to release for use.

l 3. All departments shall be responsible for adhering to the iden'/ cation and control procedures established per 2, above.

AdoOAP.R13

Titic: Section IX - Control of Soecial Processes Pcge: 1 of 2 Rev.No. 13 Date: 1/22/98 IX. CONTROL OF SPECIAL PROCESSES A. SCOPE This section establishes measures to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified

, personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria and other special reqt'irements, l i B. RESPONSIBILITIES l

1. The Quality Programs Department shall be responsible for:

1

a. Evaluation, audit and/or inspection of the control of special processes.

l b. Performance and/or evaluation of certain nondestructive tests in accordance with Yankee Nuclear Services Division Welding and Nondestructive Examination Procedures.

c. Training, qualification, and requalification of Maine Yankee personnel in nondestructive examination,

d. Review of special process documents provided by vendors for use on-site and when otherwise specified.

2. The Engineering Division shall be responsible for establishing procedures which

. prescribe control of special processes, including:

i. Verification that qualification records of procedures, equipment, and personnel connected with special processes are in accordance with applicable codes, standards, and specifications as applicable.

b. Special processes are accomplished in accordance with written process sheets or equivalent with recorded evidence of verification.

c. Maintenance and updating of qualification records of special process procedures, equipment, and personnel as applicable.

3. The Yankee Nuclear Services Division shall be respotisible for approving documents for welding, and non-destructive examinations.

A:\OOAP.R13

Title:

Section IX - Control of Soecial Processes Paga: 2 of 2 Rev.No. 13 Date: 1/22/98

4. All departments shall be responsible for:

a. Assurance that work involving special processes is perfonncd by qualified personnel in accordance with approved documents,

b. - Control of material used in special processes.

c. Review of special process documents, as applicable, provided by vendors for use on-site and wilen otherwise specified.

4 i

AdoOAP.R13

Titla: Section X - Insoection Pags: 1 of 2 Rsv.No. 13 Date: */22/98 X. INSPECTION.

A. SCOPE This section establishes measures for inspection of activities affecting quality, to verify I conformance with approved instructions, procedures, drawings, and specification for accomplishing the activities.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for:

i

e. Review of documentation pertinent to the Inservice inspection Program,

b. Evaluation of inspection activities and personnel,

c. Establishing and/or reviewing hold and/or notification points for plant activities,

d. Establishing and/or reviewing hold and/or notification points for vendor activities,

e. Writing and approving inspection instructions and check lists,

f. Establ shing procedures which prescribe:

(1) Independence of personnel performing the inspection from the personnel performing the activity.

(2) Use of procedures, instructions or check lists which incorporate the J following as applicable:

1 (a) A description of the type of inspection.

(b) Date and results of the inspection.

(c) Information related to conditions adverse to quality.

(d) Inspector identification.

(e) Evidence as to acceptability of the results.

(f) Action taken to resolve any discrepancies noted.

A:\oOAP.R13

Titb: Section X - Insoection Pcgn: 2of2 Rov.No. 13 Date: 1/22/98 i

(3) Use of drawings and specifications when performing inspections.

(4) Inspection of repairs and replacements in accordance with applicable design and inspection requirements or acceptable alternatives.

(5) Evaluation of processing methods, equipment, and personnel when direct inspection is not possible.

(6) Qualification of inspectors in accordance with applicable codes, standards, and company training programs; and maintenance of -

qualifications and certifications.

(7) Review of maintenance documents by qua:ified personnel knowledgeable in quality assurance to determine the need for inspection, identification of inspection pc rsonnel, and documenting inspection results.

(8) When inspections associated with routine maintenance, surveillance, and tests are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following controls _shall be met:

(a) The quality of the work can be demonstrated through a functional test when the activity involves breaching a pressure retaining item.

(b) The qualification criteria for Irispection personnel are reviewed and found acceptable by the OA organization prior to initiating the inspection.

2. All departments shall be responsible for;

a. Assuring that activities requiring quality assurance meet predetermined requirements.

A:\OOAPR13

Titlo: Section XI - Test Control Page: 1 of 2 Rev.No. 13 Date: 1/22/98 XI. TEST CONTROL A'. SCOPE This section establishes measures for a test program to demonstrate that etructures, systems, and components will perfoim satisfactorily in service.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for:

a. Evaluation of the control of the test program.

b. Evaluation of the documentation generated during the test program.

2. The Ecgineering Division shall be responsible for:

a. Preparation or review of specifications, requirements, and acceptance criteria for testing following plant changes and maintenance activities.

l b. Determination of whe, testing is requ' ed following plant changes and maintenance activities,

c. Establishing proceduros which prescribe that test documents incorporate or reference the following, as appropriate:

(1) Purpose (2) Test date (3) Requirements and acceptance criteria contained in applicable design and procurement documents.

(4) Reference sources, such as vendor's literature.

(5) Instructions for performing the test.

(6) Precautions 1

AdoOAP.R13

-A

Titla: Section XI - Test Control Pag 3: 2 of 2 Rev.No. 13 Date: 1/22/98 (7) Tast prerequisites, such as:

(a) Calibrated instrumentation (b) Adequate and appropriate test equipment and instrumentation including accuracy requirements (c) Trained, qualified, and licer. sed / certified personnel (d) Completeness of item to be tested (e) Suitable and controlled environmental conditions (f) Provisions for data collection and storage (g) Completion of other procedures (8) Mandatory inspection hold points for witness by owner, contractor or inspector, when applicable.

(9) :dentificaticn of test prerequisites that must be met.

(10) Acceptance and rejection criteria.

(11) i..ethod of documenting test data and results.

(12) Identity of person recording the data and approving test results.

[ 3. The Operations Division i tall be responsible for establishing procedures to satisfy the surveillance testing anJ inspection program provisions of ANSI Standard N18.7 - 1976 (Section 5.2.6;. Documents to implement this program shall be consistent with the requirements of 2.c, above, and shall also require recording the as-found condition, corrective actions performed, if any, and as-left condition.

4. All departments shall be responsible for:

a. Supplying qualified personnel and calibrated equipment for testing.

b. Establishing test programs, procedures and acceptance criteria to satisfy the procedures established per 2.c and 3, above.

c. Scheduling and performing tests.

d. Documenting, evaluating, and approving test rem:'ts.

A:\oOAP.R13

Measurina and Test Eauloment Pcgo: 1 of 2 Rev. No,' 13 Date: 1/22/98 Xll. QONTROL OF MEASURING AND TEST EQUIPMENT A. SCOPE This section establishes measures to assure that tools, gages, instruments, and other measuring and test equipment, used in activities affecting quality, are controlled and at specified periods calibrated and adjusted to maintain accuracy within necessary limits.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for evaluation and/or sudit of the established program for the control of measuring and test equipment.

2. The Operations Division shall be responsible for establishing procedures which prescribe:

a. Identification of measuring and test equipment and traceability to the calibration data.

b. Labeling or tagging of measuring and test equipment to indicate due date for

-calibration. (Other means may be employed provided there is adequate assurance out-of-calibration devices will not be used).

c. Calibration of installed plant instrumentation and control systems to assure conformance with the Plant Technical Specifications,

d. Calibration of measuring and test equipment (other than c.,

above) at specified intervals based on type of equipment, required accuracy, purpose,- degree of usage, reliability, stability characteristics, and other conditions affecting the measurement,

e. Traceability of reference standards to nationally recognized standards; or, documentation of the basis for calibration where national standards are nonexistent.

f. Calibration accuracy requirements shall be as follows:

(1) Measuring and test equipment shall be of equal or greater accuracy as the installed instrumentation, i

~

A:\oOAP.R13

Titig: Section Xil - Control of Measuring and Test Eauloment Pege: 2 of 2 Rev.No. 13 Date: 1/22/98 (2) In general, the inaccuracy of the reference standards shall contribute no more than one fourth of the allowable measuring and test equipment tolerr.nce. However, when the actual inaccuracy of the measuring and test equipment is less than one fourth of the installed plant equipment tolerance, the requirement of one fourth the tolerance between the reference standards and measuring and test equipment may not be necessary.

(3) Referer.ce standards shall be calibrated against standards of equal or greater accuracy.

When the foregoing accuracy requirements cannot be attained, the rationale for deviating from these requirements shall be justified, documented and authorized by responsible management. The management authorized to perform this function shall be identified.

l l g. Documentation and maintenance of the status of allitems under the calibration system,

h. Documentation of measures taken to determine the validity of previous inspections performed when measuring and test equipment is found to be out of calibration.

3. All departments shall be responsible for:

a. Developing implementing documents for control of measuring and test equipment including identification and calibration for equipment under their control.

b. Providing calibrated tools, gages and instruments.

c. Maintaining calibration records.

d. Preparing and reviewing specifications for measuring and test equipment, to applicable requirements,

e. Adhering to the measuring and test equipment control procedures established per 2, Lbove.

t J

l A:\OQAP.R13

Titi:: Section XIll - Handling. Storage and Shiocina Paga: i of 2 Rev.No. 13 Date: 1/22/98 i

Xill. HANDLING. STORAGE AND SHIPPING A. SCOPE This section establishes measures to control the handling, storage, shipping, cleaning and preservation of material and equipment to prevent damage or deterioration.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for:

a. Evaluation, audit and/or inspection of the handling, storage and shipping of materials, parts, and components,

b. Evaluation and/or audit of handling, storage, and shipping documents.

c. Review of engineering specifications and procurement documents to assure that proper handling, storage, and shipping requirements have been specified.

[ 2. The Decommissioning Division shall be responsible for establishing procedures which prescribe:

a. Specification and accomplishment of special handling, preservation, storage, cleaning, packaging, and shipping requirements by suitably trained individuals in accordance with predetermined work and inspection instructions for critical, sensitive, perishable or high value items,

b. Preparation of instructions in accordance with design and specification requirements to control the cleaning, handling, storage, packaging, shipping and preservation of safety classified materials, components and systems to preclude damage, loss or deterioration by environmental conditions such as temperature or humidity.

c. Provisions for the storage of chemicals, reagents (including shelf life),

lubricants, and other consumable :6terials under their control.

d. Provisions to satisfy Regulatory Guide 1.38, Revision 2 (ANSI Standard N45.2.2 - 1972), as pertains to handling, storage and shippirg,

e. Provisions for a Preventive Maintenance Program for materials, items and components, as applicable, under their control.

A:\oOAP.R13 g , . -

Titis: Section Xill - Handling. Storage and Shlooing Page: 2 of 2 Rev.No. 13 Date: 1/22/98  ;

3. The Chemistry Section is responsible for establishing procedures which prescribe provisions for the storage of chemicals and reagents (including shelf life) under their control.

4. All departments shall be responsible for:

a. Developing implementing documents for handling, storage and shipping of materials and equipment to satisfy the procedures established per 2, above as necessary.

b. Providing suitable facilities and equipment for handling, storage, and shipping of materials as necessary.

c. Inspecting and testing special handling tools and equipment.

d. Providing and controlling special handling tools and equipment to ensure safe and adequate handling.

A \OQAP.R13

Oceratina Status Page: 1 of 1 t- Rev.No. 13 Date: 1/22/98 XIV. INSPECTISN. TEST AND OPERATING STATUS A. SCOPE This section establishes measures for indicating the status of items undergoing inspections and tests (via tags, labels, log books, etc.), to prevent the unintentional bypass of required tests, in addition, this section establishes measures for indicating ,

the operating status of components and systems to prevent their inadvertent operation.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for the evaluation of inspection, test and operating status of systems and components throughout fabrication, installation, and test.

2. The Operations Division shall be responsible for;

a. The status of operating equipment or systems removed from service for maintenance, test, inspection, repair, or change,

b. Periodic review and update of standing orders,

c. Periodic review, updating and cancellation of special orders,

d. Periodic review to evaluate plant operations and plan future activities. The important eleinents of the reviews shall be documented,

e. Establishing procedures to satisfy the equipment control provisions of ANSI Standard N18.7 - 1976 (Section 5.2.6).

3. All departments shall be responsible for:

a. Informing the Operations Division of the current status of equipment or systems removed for repair, maintenance, test, inspection, or change.

b. Designating personnel who are responsible for the status of equipment and -

systems.

A:\OOAP.R13 m

Titis: Section XV - Nonconformina Materials. Parts and Comoonents Pags: 1 of 2 Rev.No. 13 Date: 1/22/98 XV. NONCONFORMING MATERIALS. PARTS. AND COMPONENTS i i

A. SCOPE I l

This section establishes measures to control items, services or activities which do not conform to requirements.

B. RESPONSIBILITIES

[ 1. The Operations Director shall be responsible for the reviewing significant nonconformance reports.

2. The Quality Programs Department shall be responsible for;

a. Evaluation of the system for controlling nonconforming material, parts and components.

b. Review and concurrence of dispositions and corrective actions of nonconformance reports provided by the applicable department,

c. Establishment of measures to provide for the documented control of nonconforming materials, parts, and components in order to prevent their inadvertent use or installation.

d. Followup and closecut of nonconformances.

e. Establishing procedures which prescribe:

(1) Identification, documentation, disposition, inspection and segregation of nonconforming items.

l (2) Identification of those individuals or groups delegated the responsibility and authority for the disposition and written approval of nonconforming items.

(3) Inspection and test of reworked or repaired items which require reinspection and retest to odginal methods or methods equivalunt thereto.

(4) Inclusion of nonconformance reports dispositioned " accept as is" or

" repair" as part of the inspection records furnished to the plant.

AAOOAP.R13

Title:

Section XV o Nonconformina Materials. Parts and Comoonents Page: 2 of 2 Rev.No. 13 Date: 1/22/98 (5) Periodic analysis of nonconformance reports to show quality trends with the results reported to management for review and assessment.

(6) Documentation of the identification, description, disposition, inspection and signature approval of the disposition for nonconformances in a nonconformance report.

f. Stopping unsatisfactory work. I

3. The Engineering Division shall be responsible for:

g. Review of nonconforming items which cannot be corrected by vendor action, l.. Preparation or approvol of implementing documents wr repair and/or rework of nonconforming items.

4. The Finance and Administration Divicion shall be responsibla for establishment of a feedback system betwe'ni Maine Yankee and Vendor Represeisatives in regard to nonconforming material.

I A:\00AP.R13 W v

Titla: Section XVI- Corrective Action Page: 1 of 1 Rcv. No. 13 Date: 1/22/98 XVI. CORRECTIVE ACTION A. SCOPE This section establishes measures to assure that conditions adverse to quality are promptly identified and corrected. For significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and documented, and corrective action taken is to preclude repetition.

B. RESPONSIBILITIES

1. The Quality Programs Department shai, be responsible for:

a. Evaluation and/or audit of plant activities which identify, review and correct j conditions adverse to quality,

b. Evaluatior, and/or review of documentadon of corrective action, l

c. Establishing procedures which prescribe:

(1) Identification and correction of conditions adverse to quality.

(2) - Significant conditions adverse to quality, the cause, and action taken to preclude repetition are documented and reported to management.

L The Engineering Division shall be responsible for:

a. Revlewing significant or recurring design deficiencies to determine the cause,

b. Instituting apropriate enanges in the design process to prevent similar deficiencies 60m recurring.

3. All departments shall be responsible for:

a. Identification and correction of conditions adverse to quality,

b. Identification and documentation of the cause and preparation of recommendations to preclude repetition of cignificant conditions adverse to quality,

c. Implementation of corrective action including, as appropriate, action to proclada repetition,

d. Documentation of corrective action taken.

A:\00AP.R13

Titlo: Section XVil- Quality Assurance Records.

Page: 1 of 2 Rev.No. 13 Date: 1/22/98 XVil. QUALITY ASjiUE6NCE RECORDS A. SCOPE

1. This section establishes measures for maintenance of records which provide documentary evidence of the quality of items and of activitles affecting quality.

Requirements shall be established for identification, transmittal, retrievability and retention of quality assurance records including duration, location, protection and assigned responsibility.

2. The quality assurance records shall include plant history; operating logs; principal maintenance; design change activitle;; reportable occurrences; nonconformance reports: results of reviews, inspoction, tests, audits and material analyses; monitoring of work performance; qualification of personnel, procedures and equipment; drawings; specifications; procurement documents; calibration documents and reports; corrective action reports; and other records required by Technical Specifications.

B, HESPONSIBILITIES

1. The Quality Programs Dopartment shall be responsible for:

a. Evaluation and/or audit of quality assurance record review, control and retention.

b. Maintenance of audit, evaluation, inspection, and venaor sumeilluce records generated by the Quality Programs Department.

2. The Yankee Nuclear Services Division shall be responsible for:

a. Maintenance of audit, inspection and vendor suNeillance records generated by YNSD.

b. Maintenance of design documents generated by YNSD and not retained by Maine Yankee.

AnoQAP R13

Title:

Section XVll . Quality Assurance RtgOrds.

Page: 2 of 2 Rev.No. _. 13 Date: _ 1/22/98 .

3. The Finance and Administration Division shall be responsiblJ for;

a. Providing for the receipt, storage, preservation, safekeeping, retrieval and final disposition of QA records,

b. Maintaining facilities for the permanent and temporary storage of records to prevent destruction of the records by fire, floodlnt . and deterioration I caused by a combination of extreme variations in ten,pature and humidity 4 conditions. Duplicate records shall be stored in a separain remote location when the type of document is not included in the record storage facility,

c. Establishing procedures to satisfy Regulatory Guide 1.88, Revision 2 (ANSI Standard N45.2.9 1974,.

4. All departments shall be responsible for: I

s. Adhering to the records controls procedures established per 3.c, above,

b. Identifying 6 apartment QA records and establishing retention periods in accordance with Regulatory Guide 1.88, Rev. 2 (ANSI N45.2.91974) and Maine Yar* 3e Technical Specifications.

AdoOAP.R13

, n + - ,, -

Title:

Section XVill Aud".s .

Page: _ 1 of 2 Rev.No. 13 Date: 1/22/98 XVill. AUDITS A. SCOPE This section establishes measures for a system of planned and documented audits to  !

verify compliance with all aspects of the Program and to assess the effectiveness of the Program. ,

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for:

a. Providing approved audit procedures or check lists for audit of activities ,

encompassed by the 18 criteria of 10CFR50 Appendix B, ANSI N18.7 and Plant Technical Specifications,

b. Providing for training of audit personnel,

c. - Scheduling and coordinating of the In plant Audit Program.

d. Preparing, reviewing and/or approving implementing documents for In-plant audits which prescribes:

(1) Documentation of audit results and review with management having responsibility in the area audited. .

(2) Necessary action to be taken by responsible management to correct deficiencies revealed by the audit.

(3) inclusion of an objective evaluation of quality-related practices, procedures and instructions and the effectiveness of implementation in the audit.

(4) inclusion of an objective evaluation of worl; areas, activities, processes and items and the review of documentation in the audit.

(5)

Reaudit of deficient areas until corrections have been accomplished to preclude repetition of the deficiencies, as appropriate.

(6) Performance of audits where the requirements of Appendix B to 10CFR Part 50 and ANSI N18.7 are being implemented.

(7) Perforraance of audits as required by the Plant Technical Specifications.

AdoOAP.R13

i

Title:

Section XVill- Audits Pago: 2 of 2 _

Rsv.No. 13 Date: 1/22/98 (8) Scheduling of audits regularly on the basis of the status and safety importance of the activities being performed.

(9) Regularly scheduled audits shall be supplemented by audits as determined by the Manager, Quality Programs for one or rore 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 in jeopardy due to deficiencies in the quality assurance program.

(c) When a systematic, independent assessment of program effectiveness is considered necessary.

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

(10)- Independence of the auditors from direct responsibility for the area being audited and independence from reporting to a management representative of the aret being audited,

e. Conducting, reporting and following up on audits to satisfy Regulatory Guide '

1.144 - January 1979 (ANSI Standard N45.2.12 - 1977).

f. Preparing information regarding the In plant Audit Program for review by the Nuclear Safety Audit and Review Committee. -

g. . Performing random informal evaluations of plant activities,

h. Providing for audits of vendors.

2. The Manager of each audited organization shall be responsible for;

a. Providing reasonable and timely access of audit personnel to facilities, documents and personnel,

b. Evaluation and approval of recommended corrective action for in plant Audit

[ issues.

3. All departments shall be responsible for:

[ a. Investigation and response to audit issues,

b. Implementation of corrective action approved by management.

A \oCAP.R13

Title:

Accendix A-Qualification Beauirements Pago: 1 of 1 Rev.No. 13 _

Date: 1/22/98 QUALIFICATION REQUIREMENTS FOR THE MANAGER, QUALITY PROGRAMS The Manager, Quality Programs must treet the below listed qualif! cation requirements:

EDUCATION: Bachelor Degree in Engineering or related science, or the equivalent in practical I experience.

EXPERIENCE: Four (4) years experience in the field of quality assurance, or equivalent number of years of nuclear plant experience in a supervisory position preferably at an operating nuclear plant or a combination of the two. At leact (1) year of this four years experience shall be nuclear power plant experience in the implementation of the quality assurance pogram. Six (6) months of tL one year experience shall be obtained within a quality assurance organization.

An additional year of quality assurance program implementation experience may be substituted for G months experience within a quality assurance organization.

AAOOAP.R13

Classifications Pa00: 1 of 4 Rev.No. 13 Date: 1/22/98 MAING YANKEE CLASS!FICATION OF STRUCTURES, COMPONENTS AND SYSTEMS APPLICABILITY This Appendix lists the systems, structures and components (SSC) associated with the storage, control and maintenance of spent fuelin a safe condition which are subject to QA Program controls. Items added to the list will be subject to QA Program control beginning on the date the addition is approved.

I. STRUCTURES None, ll. ELECTRICAL SYSTEMS AND COMPONENTS Electrical and Instrumentation systems and components designed in accordance with IEEE Standard 279, " Criteria for Protection Systems for Nuc' ear Power Generating Stations" and IEEE Standard 308, "Criterb for Class IE Electric Systems for Nuclear Power Generating Statinns" have been classified as safety class, and aio ."sted below:

[ None.

SECTION 11 NOTES:

1. For those electrical and instrumentation systems designated above, Quality Assurance electrical and instrumentation program requirements are applicable only to those portions of sy..ams defined in Section IV as necessary to perform the system safety function.

2. Instrumentation components included within each instrumentation system include power supply, sensors, relays, wiring and final operating device (solenold, relay, etc.)

as necessary to perform the system safety function.

3. Electrical components included within each electrical system include power source, breaker, control c!rcuit, cable, relaying and operating device (motor, solenold, heater, relay, etc.) as necessary to perform toe system safety function.

4. Certain components are excluded from the QA program requirements if they meet the criteria described in Section 111.

Af.OQAP.R13

Title:

Accendix B Maine Yankee .

Classifications Pago: 2 of 4 Rev.No. 13 Date: 1/22/98 111. ELECTRICAL AND INSTRUMENTATION SYSTEM COMPONENT EXCLUSION CRITERIA

1. Any component of an electrical or instrumentation system (Section 11)is excluded from the OA Program requirements if it meets the following criteria:

a. A failure of the coinponent by the electrical shorting, open circuiting, grounding or mechanical failure would not render the system incapable of performing its intended safety function.

i

b. A failure of the fluid pressure boundary of the component would not render the i system ircapable of performing its intended safety function,

c. It is not used to operate or control a dev!ce required by Technical Specifications.

2. Small spare parts having no traceability, such as commercial off the shelf items, may be purchased as non-safety related and then accepted for use in equipment requiring Quality Assurance. Examples of such items are resistors, capacitors, switches, indicators, coils, wire, connectors, solid state devices and miscellaneous hardware, i IV. MECHANICAL SYSTEMS AND COMPONENTS Mechanical systems and components have been nuclear safety classified in accordance with ANSI Standard N18.2,

• Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants". Certain mechanical systems and components no longer have safety functions due to M. Sellman submittal to the NRC dated August 7,1997, and the regulations that reference the certifications contained in the submittal. As such, ANSI N18.2 does not apply to these systems and components.

Instruments, controls, motors, sensors, etc. associated with the nuclear safety classified components which assist the components in performing a safety function are in the same safety class as the componeni to which they are associated except as noted in Section 11 aoove.

Corresponding component supports that provide a safety function are in the same safety class as the comoonents for which they provide support.

Component safety class designations are listed in the attached Table C.1.

V. OTHER ITEMS REQUIRING QUALITY ASSURANCE Items which require a degree of quality between non-nuclear safety class, and IE or safety class 1,2 or 3, shall be designated as OA Related (OAR). OAR materials and components shall be in compliance with those parts of the OA program necessary to achieve the desired intermediate level of quality. A partial list of OA Related items follows:

ASOQAP.R13

Title:

Anoendix B Maine Yankee

. Clasrlfications i Page: 3 of 4 _

l Rev.No. 13 f i Date: 1/22/98 i

i 1. Fuel Assemblies l

l 2. Boric Acid ,

[ 3.- Weld Rod ,

)

[ 4. Reagents for SFP purification and liquid radwaste processing.

4

[

[ 5. Packaging of radioactive material for transport. (As required by 10CFR71)  ;

[ 6. Structures (Seismic only)*

i [

!- [ a. Primary Auxiliary Building (PAB) t C

[ b. Fuel Building i

[

[ c. Service Building a

~

[

[ d. Containment Spray Building

[ 7. Fixed fire protection systems such as piping, valves and sprinkler heads for safety i related areas, '

.[ 8. Special Nuclear Material

[ 9. Calibration Services for Controlled Measuring and Test Equipment 4

[ 10. Liquid penetrant materials

• Limited to the portion of each structure designed to safely resist hypothetical earthquake i loads, i

-l

- A:\OQAP.R13

~ . . . _ _ _ . _ . _ . _ . . _ _ _ . _ _ . _ _ _ . _ . _ _ _ _ _ _ . _ . . . _ _

Title:

Anoendix B Maine Yankee Classifications 4 of 4 Pags:

Rev.No. 13 Date: 1/22/98 1

TABLE C.1 l l

MECHANICAL SYSTEMS AND COMPONENTS CLASSIFICATION LIST l l

SAFETY  !

COMPONENT CLASS

[

Spent Fuel Pool Cooling and Cleanuo System Spent Fuel Pool Cooling Loop Suction Piping 3 (from the pool wall up to and including the siphen protection)

[

- Handlina Eautoment for Fuel arid Reactor Vessel Internals -

Fuel Transfer Tube Outer Sleeve 3

[

3 l

1 F

4 A:\00AP.R13

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

Titb; Anoendix C - Packaaina Radioactive Material For Transoort Pags: 1 of 2 i Rev.No. 13 Date: 1/22/98

[ QUALITY ASSURANCE PROGRAM

[

[ FOR PACKAGING RADIOACTIVE MATERIAL FOR TRANSPORT The Nuclear Quality Assurance Program (QA Program) assures that the requirements for packaging of radioactive material for transpoit as specified in 10 CFR 71 and the quality assurance criteria for shipping packages for radioactive material are satisfied. The QA Program will assure that waste materials intended for disposal at a land disposal facility are properly classified, Identified, and documented as required by 10 CFR 20 and 10 CFR 61.55,61.56, and 61.57. Activities involving the receipt and shipment of Type A packages under the requirements of 49 CFR 172173 are prescribed in written procedures, instructions, or drawings.

The chapters of the OA Program applicable to Packaging Radioactive Materials for Transpor:

activities are described and modified below.

Sections 1.0 and 2.0 Fully applies in addition to Section a. of this appendix.

3.0 Fully applies.

4.0 Fully applies in addition to Section b. of this appendix.

. 5.0 Fully applies.

6.0 Fully applies.

7.0 Fully applies.

8.0 Fully applies.

9.0 Fully applies.

10.0 Fully applies.

11.0 Fully applies.

12.0 Fully applies.

13.0 Fully applies.

14.0 Fully applies.

. A:\OoAP.R13

_ _ _ _ . _ _ _ _ _ _ _ . _ . _ _ . ~ _ . _ _ _ . _ . _ _ _ . _ . _ . _ _ _

Titla: Anoendix C - Packaalna Radioactive Material For Transoort l Page: 2 of 2 {

Rev.No.._ 13 l

Date: 1/22/98 15.0 Fully applies.

16.0 Fully applies.

17.0 Fully applies in addition to Section c. of this appendix.

-18.0 Fully applies,

a. QA Proaram Controls are established over activities affecting the quality of materials and components as necessary to ensure conformance to the approved design of each individual package used for the shipment of radioactive material. OA requirements and procedures are based on the following considerations conceming the complexity and proposed use of the package and its components.

(1) The impact of malfunction or failure of the item to safety; (2) The design and fabrication complexity or uniqueness of the item; (3) The need for special controls and surveillances over processes and equipment; (4) The degtee to which functional compliance can be demonstrated by inspection or test; and (5) The quality history and degree of standardization of the item, b, Procurement Document Control Measures are established to assure that the applicable requirements of 10 CFR71 are included or referenced in documents for procurement of materials, equlpment, and services for the design, fabrication, and use of packaging for radioactive material, and that packages I and procedures for use of these packages have been authorized by the NRC and documented in the NRG Certificate of Conipliance,

c. QA Records in addition to the records required by the definition of Ovality Assurance Records in this OA Program, the records must include the instructions, procedures, and drawings required by 10 CFR 71.111 and must include closely related records such as required qualifications of personnel, procedures, and equipment. The records must include the procedures which establish the records retention program. These records shall be retained for three years beyond the date when the last pa %ging and shipping of radioactive materials occurs.

/dOQAP.R13

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_ _ _ _ _ . , . _ _ _ .