ML20199K347

Rev 14 to Maine Yankee Atomic Power Co QA Program

ML20199K347
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Issue date:	01/22/1998
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i ENCLOSURE 3 Maine Yankee Oumilh' Annurance Pronram Revision jf g20601699g0418,"

u ^== 0 o 30 PDR

i MAINE YANKEE ATOMIC POWER COMPANY QUALITY ASSURANCE PROGRAM Revision 14 ,.

_. = _ = =

A \00AP.R14

TABLE OF CENTENTS Approval Sheet Policy Statement

1. Organization

11. QA Program 111. Design Control IV. Procurement Document Control V. Instructions, Procedures and Drawings VI. Document Control Vll. Control of Purchased Material, Equipment and Services Vill. Identification and Control of Material, Parts and Components IX. Control of Special Processen X. Inspection XI. Test Control Xil. Control of Measuring and Test Equipment X!!!. 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 Classifications Appendix C Quality Assurance Program For Packaging Radioactive Matarial For l'ransport A:\OOAP.R14

Rev. No.: 14 Date: 1/22/98 MAINE YANKEE ATOMIC POWER COMPANY QUALITY ASSURANCE PROGRAM PREPARED BY:

Manager Quality Programs Maine Yankee Atomic Power Company REVIEWED BY:

Director, Operations Maine Yankee Atomic Power Company REVIEWED BY:

Director. Engineering Maine Yankee Atomic Power Company I REVIEWED BY: _ ..

{ Vice President, Finance & Adminletration Maine Yankee Atomic Power Company APPROVED BY:

Vice President, Nuclear Safety and Regulatory Affairs Maine Yankee Atomic Power Company APPROVED BY:

Director, Decommissioning Maine Yankee Atomic Power Company APPROVED BY:

President Maine Yankee Atomic Power Company l

A:\oOAP.R14

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

The Ccmpany policy of a firm commitment to quality is best reflected in a memorandum to all-employees from its President and incorporated into this program as Attachment 1.

1 c

A:\00AP.R14 i

ATTACHMENT 1 August 13. .397 TO: ALL PERSONNEL FROM: Michael B. Sellman, President .

l THE QUALITY MISSION l

l The designers, builders and management of Maine Yankee Atomic Power Company have been cornmitted to high standards of engineering and operational quality from the beginn!ng. During 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 l pursued by overy member of our organization if we are to deserve the public confidence that is necessary for continued success. Among other things, uncompromising dedication to qua!ity improvement requires:

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

Thorough understanding of your job functions and an understanding of why your job 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.R14

ATTACHMENT 1 (Ccntinu:d)

The Quality Assurance Program (QAP)is the regulatory basis for the processes and controls we need to achleve a high level of quality and selety in plant operation.

Achievement and verification of quality are line management functions which are prescribed by tbs OAP and its implementing procedures. The OAP has provided for the Quality Programs Department to be the principle coordinator and consultant for quality verification activities, I challenge every employee to actively cooperate and support our fundamental quality 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, President A:\00AP.R14

Titis: .Section I - Organization

' Pag 3: 1 of 3 Rev.No. 14 Date: 1/22/98 1, ORGANIZATION 1

A. SCQEE Thlt, section desMbes the functions and relationship of personnel responsible for establishing and implementing the Quality Assurance Program. l B. RESPONSidlLITY l The President has the overall respon.;lbility for all aspects of the QA Program. Maine Yankee Mc.nagement retains ful!,esponsibility 'or establishing, executing and measuring the overall effectiveness of the administrative corsrols and quality assurance program.

The Vice Presidents of Nuclear Safety and Regulatory Affairs, and of Finance and Administration, and the Directors of Operations, Engineering and Decommissioning shall execute the Quality /ssurance Fiogram in those organizational units assigned responsibility

- 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 Iriplementing the operational Quality Assurance Program within the operating organization during all mooes of plant operation. The Director of Operations will assume the responsibilities 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 fJlfill 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 'o the Quality Assurance Program that concem their aress of responsibility. The President and Quality Programs Department Manager shall approvo all changes.

AAOQAP.R14

Titla: Section 1 -Organization Page: 2 of 3 Rev.No. 14 Date: 1/22/98 0

C. ORGANIZATIONAL RELATIONSHIPji The organizational chart on page 3 of 3 of this section shows the lines of authority, respensibility and communication from the higheet management level to the intermediate levels of management. -

l The Quality Programs Department Manager repods 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 =cheduling considerations when opposed I to safety considerations.

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

3. Sufficient authority and crganizational 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 Committeu This Committee is composed of experienced and qualified plant personnel having direct line responsibility for plant operation. See Section 5.5, " Review and Au61t" 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.R14

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- - g January 28,1998

Title:

Section 11 3 QA Progtam Pcge: 1 of 17 R v.No. 14 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 establishing and maintaining documentation which designates the safety classification of plant systems. The program takes into eccount the need for special controls, processes, environmental conditions, equipment, tools and skills to attain the required quality and the need for verification of quality by 'nspections, evaluations or tests.

B. RESPONSIBILITIES Compliance with the requirements of the Quality Assurance Program is the responsibility of all personnelinvolved with activities affecting safety. Individuals responsible for establishing and executing the Quality Assurance Program are delineated in Section I," Organization". The Quality Programs Department shall regularly review the status and adequacy of the Quality Assurance Program, to the requirements of 10CFR50, Appendix B, and ANSI N18.71976.

C. IMPLEMENTATION The Quality Assurance Program is established as required by, and to assure conformance with, Title 10 of the Code of Federal Regul-"ane, Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants. l 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 requirements 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, AA00AP.R14

Titla: Section ll - QA Program Paga: 2 of 17 Rsv.No. 14 Date: 1/22/98

3) ANSI Standard N18.7-1976 is the endorsing document for all other specified ANSI Standards. All such endorsed ANSI Standards will be implemented to the degree of applicability indicated in ANSI N18.7-1976 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 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 implementatk,n. Acceptance will be assumed 60 days after submittal unless notified otherwise, c) Changes that do not reduce QA Program commitments shall be submitted to the NRC in accordance with 10 CFR 50.54(a)(3) and 10 CFR 50.71(e)(4).

d) Editorial changes or personnel reassignments of a minor nature do not require NRC notification.

D. MANAGEMENT EVALUATION The Nuclear Safety Audit and Review Committee (NSARC), under the direction 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.

E, TRAINING

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

a. Instruction as to the purpose, scope, and implementation of quality assurance manuals, instructions, and procedures.

b. Training and qualification in the principles and techniques of the activity being performed,

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

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

s

- A:\00AP.R14

Title:

Section 11 - OA Proaram Page: 3 of 17 Rev, No. 14 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 training programs for the facility staff to ensure they meet 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 Maloned to their department.

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

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

l

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 experience 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.

A:\00AP.R14

Titis: Section ll - OA Procram Paga: 4 of 17 R3v. No. 14 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 examinations and retraining, respectively.

M.IERNATIVE:

I Maine Yankee will provide Certified Fuel Handler (CFH) training on subjects applicable to the permanently defueled mode. In addition, CFH training '

l need only maintain proficiency in allowed activities. l

2. ANSI N18.7 - 1976, Administrative Controls and Quality Assurante for the Ooerational Phase of Nuclear Power Plants, as modified by Regulatory Guide 1.33, Revision 2, and the following exceptions,

s. 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 N18.7-1976 shall not be considered as applicable to the Maine Yank 3e Quality Assurance Program.

ALTERNATIVE:

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

b. EXCEPTION:

Maine Yankee takes exception to Section 4.3 " Independent Review Program" ana 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.

- A:\OQAP.R14

Titla: Section ll - QA Proaram Pcge: 5 of 17 R::v. No. 14 Date: ,. 1/22/98

c. EXCEPTION:

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.

d. EXCEE001 Maine Yankee takes exception to the provision of paragraph 5.2.2, which requires that one of the two individuals providing approval of temporary (procedure) changes "... shall 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 conceming 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 su'vey instrument is used.

Personnel cany a pocket electronic Secondary Dosimetry Device and TLD for monitoring radiation 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 tripping the reactor, and i

, changing modes.

ALTERNATIVE:

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

AAOQAP.R14

Title:

Section ll - OAproaram Page: _ 6 -;' 17 Rev. No. 14 Date: 1/22/98

g. EXCEPTION:

A Maine Yankee takes exception to application af paragraph 5.3.9.1, Emergency Procedure Format and Content.

3 ALTERNATIVF:

NRC Order dated July 10,1981 anfirmed Malna Yankee's commitment concerning NUREG 0737, suppl 3 ment 1C1 for TMI related items. Maine Yankee's Emergency Operating Procedures (EOP) will be written to the requirements of the EOP Writer's Guide, based on NUREG 0899, submitted -

to the NRC for review on March 18,1986.

+

li. EXCEPTION: $

Maine Yankec takes exception to the provisions of paragraph 4, 4 ..u n

• 5.2.15, REVIEW, APPROVAL AND COFTRCL OF PROCEDURi .which requires that " Plant Procedures shall be reviewed no less frequently than

• every two years to determine if changes are necessary u desirable."

ALTERNATIV.E; Programmatic Controls will ensure thbt applicable plant procedures will be reviewed following an unusualincident, such as on 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 endorsed by RG i.33.

Non-routine procedures (procadures such as emergency operating r

procedures, off-normal piocCJures, procedures which implement tha emergency plan, and other procedures whose usage may be dictated by an d event) will be reviewed at least every two year., and revised as appropriate.

At least every three years, the Quality Fregrams (or othe r ndependent")

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

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

a. EXCEPTION:

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

A:\oOAP.R14

Titb! Section II- QA Prooram Pago: 7 - of 17 _

Rev.No. 14 Date: 1/22/98 ALTERNATi%.

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 ANS! N18.17 requirements. '

4. ANSI N45.2.1 - 1973, Cleaning of Fluid Systems and Associated Comoonents During Construction Phase of Nuclear Power Plants, as modified by Regulatory l Guide 1.37, March 16,1973.

5. ANSI N45.2.2 - 1972, Packaging. Shlooing. Receivina. Storage & Handling of items for Nuclear Power Plants (During the Construction Phase), as modified by P.egulatory Guide 1.38, P,evision 2, and the following exceptions,

a. EXCEPTION:

l- Subsection 3.7.1 & A3.7.1 - Containers Maine Yankee takes exception to the specific requirements for conte;nnrc.

ALTERNATIVE:

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

JUSTlFICATION:

Containers shipped by closed carrier, stored inside and not subjected to a -

wet environment do not require weather resistant fiberboard. Therefore, this is an unnecessary expense. Additionally, numerous vendors utilize shipping containes 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 safe condition. Technology has advanced beyond the standard,

b. EXCEPTION:

Subsection 3.7.2 - Crates and Skids Meine Yankee takes exception to the requirement that skids and runners shall be used on boxes with a gross weight of 100 pounds or more.

A:\OQAP.Ri4 x -

m

Titis: Section II - OA Proomm Pcgs: 8 of 17 Rcv.No. - 14 Date: 1/22/98 ALTERNATHE; Skids or runners shall be used on boxes with a gross weight of 100 pounds or more if practical, j JUSTIFICATION:

Storage methods and container design frequently are such that runners or ,

skids are not feasible.  ;

c. EXCEPTION:

Subsection 5.2.1 - Shinoino Damaoe 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 specialinstarices, pre-unloading inspections shall be performed.

JUSTIFICATION:

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

d. EXCEPTION:

Subse.ction 5.2.2 - ltemjosoection Maine Yankee tah s exception to the reqt:rement, that "The inspections shall be performed in an area equivalent to the level of storage requ:rements for the item."

ALTERNATIVE:

Maine Yankee shall perform receiving inspeci n 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 iteo 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.

AdoOAP.R14

~

Title:

Section il - QA Proaram Pags: 9 of 17 Rev. No. 14 Date: 1/22/08 JUSTIFICATION:

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

e. EXCEPTION:

I Subsection 5.2.3 - Soecial Insoection Maine Yankee takes exception to attachi.1g specialinspection procedures to the item or container.

ALTERNATIVE:

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

JUSTIFICATION:

Procedures are cubject 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 meat the requirements of level A storage for new fuel with the exception of special air filtering; and temperature and humidity controls.

JLISTiFICATION:

The existing storags conditions at the Maine Yankee plant is consistent with the protection provided to the fusi whl:e 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 application at the manufacturing facility (vendor) where the uranium pellets may be exposed to the atmosphere and not in its fully AnoOAP.R14 1 9 n v# -

Title:

Section II - OA Program Page: 10_of 17 Rev.No. 14 Date: 1/22/98

{

encapsulated, and therefore, fully protected form in a completed fuel (

assembly. l

o. EXCEPTIOtt Anoendix A-3 Subsection A3.5.1(1)- Caos & Plugs Maine Yankee takes c.vcep'.icn to the requirement that non-metallic plugs and caps shall be brightly colored.

ALTERNATIVE:

Non metallic plugs and caps sh911 be of a contrasting color.

JUSTIFICATION:

The purpose of utilizing brightly colored plugs r.o i caps le to assist in assuring obstructions are not inadvertently piace . 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. Markings Maine Yankee takes exception to the requirement that contaiaer markings shall appear on a minimum of two sides.

ALTERNATIVE:

Containers shall be adequately marked to provide identification and retrievability.

JUSTlf.1 CATION:

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:

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

AAOQAP.R14

Titla: Section ll - OA Program Pago: 11' of 17 Rsv.No.__ 14 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:

Aonendix A-3 Subsection A.3.9(6)- Second Grouo. Markina Maine Yankee takes exception to the inferrnation required for container marking.

^

ALTERNATIVE:

Marking shall be adequate in es.ch case to provide identificeuen, traceability and instructions for special handling, as applicable.

1QSTIFICATION:

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

6. ANSI N45.2.3 - 1973,liousekeeoina Durino 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 - Plannina Maine Yankee takes exception to the five-zone requirements specified in the subject standard.

ALTERNATIVE:

Maine Yar,kee shall establish as a minimum a three-zone program as follows:

AdoOAP.R14

Title:

Section 11 - OA Prooram-Pago: 12 of 17 Rcv. No. 14 Date: 1/22/98 Z0112.111 Zone ill criteria shall be applied to the Spent Fuel Pool and supporting systems which are opened for inspection, maintenance, or repair.

(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 e systems.

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

s NOTE: The Zone ill requirements may be expanded for certain I maintenance / repair activities if deemed appropriate by i plant management. In such Instances applicable sections of Zones I & 11 may be specified.

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

(1) Standard Janitorial and work practices shall be utilized to maintain a

[ level of cleanliness commensurate with company policy in the areas of Housekeeping, Plant and Personnel Safety, and Fire Protection.

(2) Additional housekee?i g requirements shall be implemented as required for the control of radioactive contamination.

(3) Smoking and eating shall be controlled consistent with good health j physics praciices 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 cleankness commensurate with company policy in the areas of )

Housekeeping, P! ant 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.

AAOQAP.R14 o

w

Titb: Section ll - OA Prooram Pags: 13 of 17 Rev.No. 14 Date: 1/22/98 ALTERNATIVE:

l 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 familiar with the requirements,

c. EXCEPTION:

Subsection 3.2 - Control of Facilities Maine Yankee takes exception to the control of tools, equipment, materials and supplies used in Zone Ill.

ALTERNATIVE:

Maine Yankec shall verify control for Zone lli as indicated in the previous exception.

7. ANSI N45.2.4 - 1972, installation. Insoection. and Testino Reauirements for Instrumentation and Electric Eauioment During the Construction of Nuclear Power Generating Stations. as modified by Safety Guido 30, August 11,1972.

8. ANS' N45.2.5 - 1974, Sucolementarv Quality Assurance Reauirements for Installation. Insoection. and Testing of Structoral Concrete and Structural Steel Durina the Construction Phase of Nuclear Pcwer 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.

ALTERNATIVE:

Maine Yankee personnelidentified in ANSI N18.1-1971 who perform inspection, examination, and testing will be qualified to ANSI N18.1-1971.

A:\OOAP.R14

Title:

Section ll - QA Proaram Pags: 14 of 17 Rev.No. 14-Date: 1/22/98 Maine Yankee personnel not identified in ANSI N18.1-1971 who perform inspection, examination, and testing will be qualifit.d to ANSI N45.2.6.-1978.

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

10. ANSI N45.2.8 - 1975, Sucolementarv Quality Assurance Reautrements for Installation. Insoection and Testing of Mechanical Eauioment and Systems for Construction Phase of Nuclear Power Plants, as modified by Regulatory Guide 1.116, Revision 0.

l

11. ANSI N45.2.9 - 1974, Reauirements for Collspion. Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants, as modified by Regulatory l Guide 1.88, Revision 2.

a. EXCEPTION:

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

ALTERNATIVE:

Door, structures, frames and hardwaro 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, Quality Assurance Terms and Definitions, as modified by Regulatory Guide 1.74, February 1974, and the following exception.

a. E)'CEPTION:

Subsection 2 - Terms and Definitions Maine Yankee takes exception to the definitions of " Certificate of Conformance" and " Certificate of Compliance".

ALTERNATIVE:

Maine Yankee shall reverse the definitions of ti,e 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.R14

Title:

Section 11 - OA Proaram Page: 15 of 17 Rsv.No.._ 14 Date: 1/22/98

13. ANSI N45.2.11 - 1974, Quality Assurance Reauirements for the Deslan of Nuclear PowetPlaDis, as modified by Regulatory Guide 1.64, Revision 2.

14. ANSI N45.2.12 - 1977, Reauirements for Auditing of Quality Assurance Programs for Nuclear Power Plants, as modified by Regulatory Guide 1.144, January 1979, anc the following exceptions,

a. EXCEPTION:

Subsection 4.2.2 Team Selection Maine Yankee takes exception to the requirement that a " Lead Auditor" be appointed 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 QA Program or procedures,

c. EXCEPTION:

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

- ALTERNATIVE:

Maine Yankee will issue audit repods within thirty working days.

AAOOAP.R14

Titis: Sect!on 11 - QA Program Pago: 16 of 17 Rev No. 14 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

[ approvalin accordance with the time frames contained in the Corrective

[ Action Program.

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

16. ANSI N45.2.23 - 1978, Qpgfication of Quality Asr,urance Proaram Audit Personqql for Nuclear Power Plants, as modified by Regulatory Guide 1.146, August 1980, i

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

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

I

a. EXCEPTION:

Subsection 6.1 Maine Yankee takes exception to the requirernent that for photon and neut on monitoring instrument calibrations, the source-to-detector distance shal be seven times the maximum dimension 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.

AdOQAP.R14

Titb: Section II - OA Proaram Pcge: 17 of 17 _.

Rcv.No. 14 Date: _ 1/22/98

)

19. Regulatory Guide 1.26, Revision 3, Quality Grouo ClassiRqdions and Standards for Water. S'eam and Radioactive - Waste - Containina Comoonents of Nuclear Power Plants,

a. EXCEPTION:

Maina Yankee takes exception to the Guide !n 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 Stationary Pressurized Water Reactor Plants" as in the past.

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 4.29, Rev. 3 (9/78) to those structures, systems, and components as defined in the Maine Yankee DSAR Section 2.5.

I r

AAOOAP.R14

Titis: Section lli - Design Control Pags: 1 of 3 Rnv.No. 14 Date: 1/22/98 111. DESIGN CONTROL A. SCOPE This section establishes mearures to assure that the design of and changes to structures, systems, and components covered by the Quality Aseurance Program are controlled.

B. RESPONSIQJLITIES

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.

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

c. Application of suitable design controls to such act!vities as: field design engineering; physics; seismic, stress, thermal, hydraulic, radiation, and i accident analyses; compatibility of materials; accessibilit/ for inservice inspection, maintenance and repair, and quality standards.

d. Identification, documentation, and control of deviations from sp"ified design requirements and/or quality standards.'

e. Delineation of acceptance criteria for inspections and tests.

f. Design reviews to ast ra that design characteristics can be controlled, inspected and tested,

g. Proper selection and performance of design verification processes such as design reviews, attemate 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 l feature testing is performed as early as possibie prior to installation of plant )

equipment,-or prior to the point when installation would become irreversible; l and verification by test is performed under conditions that simulate the most  ;

adverse design conditions.

ASOoAP.R14

Title:

Section 111 - Design Control Page: 2 of 3 Rev.No. 14 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.

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

[

[ J. Notification to responsible personnel that a design change may affect performance of their duties.

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

i

[ 1. Establishing design control program procedures which prescribe:

(1) Implementation of me provisions delineated above.

1 L (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) idcntification of internal and edmal design interface controls including lines of communication among participating design oroanizations and across ' technical disciplines for the review, approval, release, distribution and revision of design ciocuments, f (4) Providons to satisfy Regulatory Guide 1.64, Rev. 2 (ANSI Standard i

N45.2.11 - 1974), except as modified in Section 11 of this program.

[ m. Management overvin and overall direction and coordination of safety analysis activities supporting license amendments, FSAR, and demonstration that design bases are met.

[ n. Imposing requirements equivalent to the above on contract organizations that conduct design change activities independera of the Maine Yankee processes.

[ 3. The Director, Operations shall be responsible for review of proposed design

[ changes.

[

A:\oQAP.R1 %

, ~-

Titla: . Section 111 - Deslan Control Pago: 3 of 3 Rsv.No. 14 Date: 1/22/98

4. The Director of_ Operations shall be responsible for:

a. Evaluation of the recommendations of the Plant Operations Revievi Committee.

b. Review and approval of proposed dulgn changes.

E.

[-

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l A:\OOAP.R14 .

n p: ,

Title:

Section IV - Procurement Document Control Page: iof 2 R9v.No. 14 Date: 1/22/98 IV. PROCUREMENT DOCUMENT CONTROL A. SOOPE This section establ.:hes measures to assure that applicable requirements necessary to assure adequate quality ar6 included or referenced in procurement documents for material, equipment, and services.

B. RESPONSIBILITIES 1, The Quality Programs Department shall be responsible for;

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.

b. Review and specifying Qua'ity Assurance requirements for material, equipment, and service purchases.

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

2. The Decommissioning Division shall be responsible for:

a. Processing and control of requisitions for purchase orders,

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

c. Estab!ishing 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 vendcr's quality assurance requirements applicable to the items or services procured.

(4) Identification in the procurement documents 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 tect records (d) personnel and procedure qualifications (e) chemical and physical test results of material ASOOAP.R14 ,

Titig: Section IV - Procurement Document Control Page: 20f 2 Rev.No. 14 Date: 1/22/98 (f) the company's right of access to the vendor's facilities and records for surveillance to procurement specifications.

(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 technical requirements are t qual 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 that 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 l control.

I (10) Selection of qualified vendors for purchasing material trom the Approved Vendor's List.

F 3. The Engineering Division shall be responsible for:

[

[ a. Reviewing and specifying technical requirements for material, equipment, and service purchases.

[ b. Evaluation of commercial "off-the-shelf" items for suitabliity 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.R14

Title:

Section V - Instructions.

Proceduros. and Drawings Page: 1 of 1 Rev.No. 14 Date: 1/22/98

- V. INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS A. S_ COPE This section establishes measures to assere that activities affecting quality are prescribed and implemented by instructions, procedures, or drawings appropriate to

the circumstances.

6

!. B._ BESPONSIBILITIES

1. The Quality Programs Departroent shall be responsible for evaluation end/or audit -

3 of inatructicns, procedures, and drawings.

, 2. The Operations Division shall be responsible for establish'ag procedures which

{ prescribe preparation and use of, and adherence to procedures, s

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

, prescribe preparation and implementation of design change installation L instructions and drawings, including changes.

4. All departments shall be responsible for:

a. Preparing and implementing instructions and procedures associateu 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 tpplicable, for determining that activities have been satisfactorily accomplished.

AAOQAP.R14

Titlo: Section VI - Document Control P gs: 1 of 2 Rev.No. 14 Date: 1/22/98 VI QQGUMENT CONTROL '

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

B. RESPONSIBILITIES '

1. The Quality Programs Department shall to responsible for:

a. Evaluation and/or audit of document contrcl systems,

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

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

2. The Finance and Administration Divls!an 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 the activity is to be performed prior to ccmmencing 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 at applicable,

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

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

(2) Design, manufacturing, construction, and installation drawings (3) Procurement documents A:\oOAPR14

Tius: Ecction VI- Document Control P gs: 2 of 2 Rcv.No. 14 .

Date: 1/22/98 (4) Quality Assurance Program and Manual and maintenance and operating procedures (5) Maintenance, modification, inspection, and test it.structions -

(6) Test documents (7) Design change 13 quests (8) FSAR (9) Nonconformance reports

f. Establish storage maintenance and document retention requirements for i

Quality Assurance records as applicable.

3. The Engineering Divisir shall be responsible for:

a. Cc,ntrolling the isst.ance 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 procecures established per 2, above.

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

a. Sequence of actions and respor-ibilities for review, approval, and control of procedures.

b. Review uf crocedures by sppropriately qualified personnel,

c. Revie. .ad approval of document changes by the same organizations that performed the original review and approval or 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.R14

Titla: Section Vil - Control of Purchased Material. Eautoment

& Services Page: 1 of 3 Rev.No. 14 Date: 1/22/98 I

Vll. CONTROL OF PURCHASED MATERIAL. EQUIPMENT AND SERVICES l

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

B. RESPONSIBILITIES

1. The Quality Progr.ws Department shall be responsible for:

[ a. Performing audits and surveys of vendor quality programs 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 of vendofs previous records and performances.

(3) Surveillance of vendofs facilities / services and QA Program to determine vendofs ability to produce the item to the purchase 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.

[ b. Planned vendor surveillances, 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 survc" lance of in-process work at intervals consistent with the impenance, complexity and quality of the item.

AdOQAP.R14

Titis: Section Vll - Control of

. Purchased Material. 'Eautoment

& Services Page: 2 of 3 Rev.No. 14 Date: 1/22/98

[ c. Documentation and maintenance of the results of vendor audits, sGNeys and

[ surveillances, including a listing of qualified vendors.

d. Surveillance of materia: and/or services control,

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

f. Receipt inspection of vendor fumished 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.

1 i

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 purchaced 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.

(4) Items are identified as to their inspection status prior to release for controlled storage, installation or further work.

g. Verifying the validity of supplier certificates of conformance.

[ h. 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 vendor audit, surveys survei!!ance and receipt inspection.

A:\oOAP.R14

_N

Titis: Section Vil - Control of Purchased Material. Eautoment

& Services Page: 3 of 3 Rev No. 14 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. Bid evaluation as applicable,

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

f.

l AAOQAP.R14 Y

Title:

Section Vill-Identification &

Control of Material. Parts and

.Comoonents Page:  :

1 of 1 Rev.No. 14 Date: 1/22/98 Vill. IDENTIFICATION AND CONTROL OF MATERIAL. PARTS. AND COMPONENT _S A. SCOPE This sec+ ion 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 Quality 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 the folicwing:

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 documcatation such 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.

3. All departments shall be responsible for adhering to the identification and control procedures established per 2, above.

AAOQAP.R14

Titlo: .Section IX - Control of Soecial Processes Page: ' 9 of 2 Rev. No. 14 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, spec;fications, criteria and other special requirements.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for:

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

b. Performance and/or evaluation of certain nondestructive tests in accordance

[ with approved procedures,

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

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

2. The Engineering Division shall be responsible for establishing procedures which prescribe control of special processes, including:

a. Verification that qualification records of procedures, equipment, and personnel connected with special processes are in accordance with applicable co6as, 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 procedules, equipment, and personnel as applicable.

_[ d. The Engineering Division shall be responsible for approving

[ documents for welding, and non-destructive examinations.

AAOQAP.R14

m._ _. _ . - _.. _ _._.-_..__._..__.__.__._-..._...___.-._._..._m... ._._..__..m__

Titlo: Section IX - Control of Soecial .

Processes -

Pag @: 2 of 2 Rev.No. -14 Date: 1/22/98

[- -3. All departments shr.ll be responsible for:

a. Assurance that work involving special processes is performed by qualified personnelin accordance with approv: J documents. -

b.- Control of material used in special procs ases,

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

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3-l A:\00AP.R14

Title:

Section X - Insoection 1 Page: 1 of 2 Rcv.No. 14 Date: 1/22/98 X. INSPECTION

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

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for:

a. Review of documentation pertinent to the insorvice 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. Establishing procedures which prescribe:

(1) Indepandence of personnel performing the inspection from the persor6nel performing the activity.

(2) Use of procedures, ir,structions or check lists which incorporate the follow!ng as applicable:

(a) A description of the type of inspection.

(b) Date ard 'esults of the inspection.

(c)- Inforne i 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.R14

Title:

Section X - Insoection Pags: 2cf2 Rev.No. 14 Date: 1/22/98 4

(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 i

direct inspection is not possible.

4 (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 qualified personnel knowledgeable in quality assurance to determine the need for 4

inspection, identification of inspection personnel, and documenting '

inspection results.

1

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

i- (a) The quality of the work can be demonstrated through a __

3 functional test when the activity involves breaching a pressure retaining item.

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

2. All departments shall be responsible for:

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

1 A:\OOAP.R14

1

Title:

Section XI - Test Control Page: J of 2 Rev.No. 14 Date: 1/22/98 XI. TEST CONTROL A. SC_ OPE This section establishes measures for a test program to demonstrate that structures, systems, and components will perform satisfactorily in service.

v B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for:

a. Evaluation of the control of the test prograrn.

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

2. The Engineering Division shall be responsible for:

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

b. Determination of when testing is required following p' ant changes and maintenance activ' ties,

c. Establishing procedures 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 scurces, such as vendor's literature.

(5) Instructions for performing the test.

(6) Precautions A:\OQAP.R14 w,ae q _ . . - . . .

Titis: Section XI - Test Control Pcgs: 2 of 2 E

i R:v.No. 14 Date: 1/22/98 i

(7) Test prerequisites, such as:

(a) Calibrated Instrumentation (b) Adequate and appropriate test equipment and instrumentation including accuracy requirements

(c) Trained, qualified, and licensed /certifled personnel 4

(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 4 inspector, when applicable.

(9) Identification of test prerequisites that must be met.

(10) Acceptance and rejection criteria.

(11) Method of documenting test data and results.

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

3. The Operations Division shall be responsible for establishing procedures to satisfy the surveillance testing and inspection program provisions of ANSI Standard

- N18.7 - 1976 (Section 5.2.8). 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.

l d. Documenting, evaluating, and approving test results.

4 AdoOAP.R14

Titi:: Section XII - Control of Measuring and Test Eouloment Paga: 1 of 2 Rev.No. 14 Date: 1/22/98 I

XII. CONTROL OF MEASURING AND TEST EQUIPMENT 1 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 audit 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. Calibraticn 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; gr, 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.

AAOQAP.R14

Title:

- Section Xil - Control of Measurina and Test Eautoment -

Pcgo: 2 of 2 Rev.No. 14 Date: 1/22/98 (2) ' general, the inaccuracy of the reference standards shall contribute no more than one fourth of the allowable measuring and test equipment tolerance. However, when the actualinaccuracy 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) Reference 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.

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 chall 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, above.

AdoOAP.R14

Titis: Section Xill - Handlina. Storaae i and Shinoina l Paga: 1 of 2 Rev.No. 14 Date: 1/22/98 l

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 shipoing 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 snelf life),

lubricants, and other consumable materials 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 shipping.

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

AAOOAP.R14

Title:

Section Xill - Handling. Storage and Shlooing Pcge: 2 of 2 Rev.No. 14 Date: 1/22/98 l

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 1 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. Inspec'ing and testing special handling tools and equipment.

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

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Titis: Section XIV - Insoection. Test &

Ooerating Status Page: 1 of 1 Rev No. 14 Date: 1/22/98 __

XIV. INSPECTION. TEST AND OPERATING STATUS A. SCOPE l

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

B. RESPONS BILITIES

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, repuir, 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 elements 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.

AAOOAP.R14

Title:

Section XV - Nonconformina Materials. Parts and Comoonents._

Pag @: 1 of 2 Rev.No. 14 Date: 1/22/98 XV. NONCONFORMING MATERIALS. PARTS. AND COMPONENTS A. SCOPE 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 shal! 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.

(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 original methods or methods equivalent thereto.

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

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

A:\oOAP.R14

Titig: Section XV - Nonconforming Materials. Parts and Comoonents Pago: 2 of 2 Rev.No. 14 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.

3. The dngineering Division shall be responsible for:

g. Review of nonconforming items which cannot be corrected by vendor action,

h. Preparation or approval of implementing documents for repair and/or rework of nonconforming items.

4. The Finance and Administration Division shall be responsible for establishment of a feedback system between Maine Yankee and Vendor Representatives in regard to nonconforming material, 1

A:\oQAP.R14

Title:

Section XVI- Corrective Action Page: i of i R;v.No. 14 Date: 1/22/98 XVI. CORRECTIVE ACTION A. SCQEE 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 shall be responsible for:

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

b. Evaluation and/or review of documentation of corrective action,

c. Establishing procedures which prescribe:

(1) Iden'ification 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.

2. The Engineering Division shall be responsible for:

I l a. Reviewing significant or recurring design deficiencies to determine the cause,

b. Instituting appropriate changes in the design process to prevent similar

• deficiencies from recurring.

3. All departments shall be responsible for:

a. Identification and correction of conditions adverse to quality,

b. Identificathn and documentation of the cause and preparation of recommendations to preclude repetition of significant conditions adverse to quality.

c. Implementation of corrective action including, as anpropriate, action to preclude repetition,

d. Documentation of correct:ve act!on taken.

AnoOAP.R14 w ___

Title:

Section XVil-Quality Assurance Records.

Page: 1 of 2 Rev.No. 14 Date: 1/22/93 l

XVil. QUALITY ASSURANCE RECORDS A. SCOPE 1 This section establishes measures for maintenance of records which provide documentary evidence of the quality of items and of activities affecting quality. ,

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

2. The quality assurance records shall include plant hictory; operating logs; principal maintenance; design change activities; reportable occurrences; nonconformance reports; results of reviews, inspection, tests, audits and material analyscs; 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. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for:

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

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

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

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

b. 14intenance of design documents generated by YNSD ant, not retained by Maine Yankee.

A:\oOAP.R14

Titis: Section XVil . Quality Assurance Records.

Pag 3: 2 of 2 -

Rev.No. 14 Date: 1/22/98

3. The Finance and Administration Division shall be responsible for:

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

b. Maintaining facilities for the permanent and temporry storage of records to prevent destruction of the records by fire, flooding, theft, and deterioration caused by a combination of extreme variations in temperature and humidity conditions. Duplicate records shall be stored in a separate 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:

a. Adhering to tha records controls procedures established per 3.c, above.  ;

b. Identifying department QA records and establisriing retention periods in accordance with Regulatory Guide 1.88, Rev. 2 (ANSI N45.2.9-1974) and Maine Yankee Technical Specifications.

AnoOAP.R14 o

Titla: Sr-tion XVilla Audits Paga: 1 of 2 Rsv.No. =14 Date: 1/22/98 l

XVill. AUQlIS A, SCOPE This section establishes measures for a system of planned and documented aucits to verify compliance with all aspects of the Program and to assess the effectiveness of ths Program.

B. RESPONSIBILITIES

1. The Quality Programs Department shall be responsible for,

a. Providing approved audit procedures n. check lists for audit of activities encompassed by the 18 criteria of 10CFR50 Appcadix 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 work areas, activitle' processes and items and the review of documentation b cc audit.

(5) Reaudit of deficient areas tantil 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) Performance of audits as required by the Plant Technical Specifications.

AnoOAP.R14

-Titis: Section XVill- Audits:

Pago: 2 of 2 Rev.No, 14 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 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 in jeopardy due to deficiencies in the quality assurt.n": program, (c) When a systematic, independent ascessment 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 area being audited.

4

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. 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 actiors 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, i-i

A

\oOAP.R14

Titla: - Anoendix A - Qualification Reauirements Pcgs: 1 of 1 Rev.No. 14 Date: 1/22/98 QUALIFICATION REQUIREMENTS FOR THE MANAGER, QUALITY PROGRAMS -

The Manager, Quality Programs raust meet the below listed qualification requirements:

EDUCATION: Bachelor Degree ir. Engineering or related science, or the equivalent in practical 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 least $

(1) year of this four years experience shall be nuclear power plant experience ^

in the implementation of the quality assurance program. Six (6) months of the one year experience shall be obtained within a quality assurance organization.

An additione! year of quality assurance program implementation experience '

may be substituted for 6 months experience within a quality assurance organization, i

1 i

A:\ooAP.R14 1

- - _ _ a

Titb: Apoendix B - Maine Yankee -

Classifications Pag 3: __.1 of 4 _

Rev.No. 14 Date: 1/22/98 MAINE YANKEE CLASSIFICATION OF STRUCTURES, COMPONENTS AND SYSTEMS APPLICABILITY This Appendix lists the systems, structures and components (SSC) associated with the storage, control and maintenance of spent fuel in 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 Nuclear Power Generating Stations" and IEEE Standard 308," Criteria for Class IE Electric Systems for Nuclear Power Generating Stations" have been classified as safety class, and are listed 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 systems 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 operan ap device (solenoid, relay, etc.)

as necessary to perform the system safety function

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

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

AnooAP.R14

Title:

Aooendix B - Maine Yankee Classifications Page: 2 of 4 Rev.No. 14

, 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 QA Program requirements if it meets the following criteria:

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

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

c. It is not used to operate or control a device 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 resistor;, capacitors, switches, indicators, coils, wire, connectors, solid state devices and miscellaneous hardware.

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 abmittal to the NRC dated August 7,1997, and the regulations that reference the certifications centained in the submittal. As such, ANSI N18.2 does not apply to these sy-tems and components.

Instruments, controls, motors, sensors, etc. associated with the nuclear safety classified componants which assist the components in performing a safety function are in the same safe'.y class as the component to which they are associated except as noted in Section 11 above.

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

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

V. OTHER ITEMS REQUIRING OUALITY ASSURANCE ltems 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). QAR materials and components shall be in compliance with those parts of the QA program necessary to achieve the desired intermediate level of quality. A partiallist of QA Related items follows:

A:\ooAP.R14

Title:

Accendix B - Maine Yankee .

Classifications Page: 3 of 4 Rev.No. 14 Date: 1/22/98 i

1. Fuel Assemblies

2. Boric Acid

3. Weld Rod

4. Reagents for SFP purification and liquid radwaste processing.

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

6. Structures (Seismic only)*

a. Primary Auxiliary Building

b. Fuel Building

c. Service Building

d. Containment Spray Building

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

8. Special Nuclear Material 9, Ca!ibraticn Services for Controlled Measuring and Test Equipment

10. Liquid penetrant materials Limited to the portion of each structure designed to safely rasist hypothetical earthquake loads.

A:\OOAP.R14

Titl3: Anoendix B - Maine Yankee I

Classifications Pags: 4 of 4 Rev No. 14 Date: 1/22/98 TABLE C.1-MECHANICAL SYSTEMS AND COMPONENTS CLASSIFICATION LIST SAi:ETY COMPONENT CLASS Soent Fuel Pool Coolino and Cleanuo Svstem Spent Fuel Pool Cooling Loop Suction Piping 3 (from the pool wall up to and including the siphon protection)

Handling Eauioment for Fual and Reactor Vessel Internals Fuel Transfer Tube Outer Sleeve 3 A:\OOAP.R14

Titlo: Anoendix C - Packaoino Radioactive.

Material For Transoort ,

Pege: 1 of 2 Rev.No. 14 Date: _ . 1/22/98 QUALITY ASSURANCE PROGRAM FOR PACKAGING RADIOACTIVF. MATERIAL FOR TRANSPORT 3 V

The Nuclear Quality Assurance Prograni (QA Program) assures that the requirements for packaging of radioactive material for transport as specified !n 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 172-173 are prescribed 8n 'uritten procedures, instructions, or drawings.

The chapters of the QA Program applicable to Packaging Radioactive Materials for Transport 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.R14 ,

_____a

Titb: Spendix C - Packaging Radioactive Material For Transoort i Page: 2 of 2 I Rev.No._- 14

. Date: 1/22/98 15.0 Fully applies.

16.0 Fully applies. )

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

18.0 Fully applies,

a. OA Program 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. QA requirements and procedures are based on the following considerations concerning 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 eqaipment; (4) The degree 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, equipment, and services for the design, fabrication, and use of packaging for radioactive material, and that packages and procedures for use of these packages have been authorized by the NRC and documented in the NRC Certificate of Compliance,

c. OA Records in addition to the records required by the definition of Quality 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 packaging and shipping of radioactive materials occurs.

A$OQAP.R14

ENCLOSURE 4 Maine Yankee Ouality Assurance Program Revision 14 Changes The following changes are submitted in accordance with 10CFR50.54(a)(3), as reductions in commitments to the Operational Quality Assurance Program (OQAP). Therefore, included with this change as required are the following:

All pages afheted by the change are included in enclosure 3 of this letter and indicated by brackets.

- Identification of the changes.

- The reason for the change.

The basis for concluding that the revised program incorporating the changes continues to satisfy the cd teria of 10CFR$0, Appendix B and the Safety Analysis Report quality essurance Isogram description commitments previously accepted by the NRC.

In a letter to the Nuclear Energy Institute (NEI) dated October 24,1996, the Nuclear Regulatory Commission elaborated a die staff's opinion about what type ofQA program changes constitute a reduction in commitment.

Although Maine Yankee does not believe that all of the items listed below constitute a reduction in commitment, we are submitting them as such since they could meet the criteria as elaborated in the above referenced staff opinion,

l. IDENTIF' CATION OF CilANGE in Section 11. OUALITY ASSURANCE PROGRAM. Subsection F. ANSI Standards and Reculatory -

Gmdes item 14.d ALTERNATIVE, page 16 of 17 is modified as follows:

Maine Yankee will specify corrective actions and provide management approval ;,i:hin thiny ;<ssking days. Correc: rec ac:ica con;piction da:ca ;,ill be as specined in the audi: docunica:a .on approved by nianage nicah in accordance with the time frames contained in the Corrective Action Program; REASON FOR CllANGE The cppropriate location for these requirements is the Corrective Action Program.

BASIS FOR CONCLUDING TilAT TIIE REVISED PROGRAM INCORPORATING TIIE CIIANGE CQHTINUES TO SATISFV TIIE CRITERIA OF APPENDIX B AND TIIE SAFETY ANALYSIS REPORT OUALITY ASSURANCE PROGRAM DESCRIPTION COMMITMENTS PREVIOUSLY ACCEPTED BY Tile PRC:

Measures are established in the Corrective Action Program to assure conditions adverse to quality are promptly identified and corrected and additionally significant conditions adverse to quality are evaluated to determine the cause of the condition and the corrective action to preclude repetition. The Corrective Action Program specifies the proper documentation and reporting to appropriate levels of management of the identification of the condition, the cause of the condition and the corrective action taken. Therefore, this change continues to satisfy the criteria of Appendix B and the SAR QAP commitments previously accepted by the NRC.

m Page 4-1

i l

I

2. IDENTIFICATION OF CllANGE in Section Ill. DESIGN CONTROL, Subsection B. R11SPONSIBILITIES, item 2.J. page 2 of 3, the following is deleted:

"j. Control of Fire Protection in accordance with YNSD YA GEN 9."

REASON FOR CIIANGE lt is not appropriate to specify the vendor of choice in the Quality Assurance Program. Our relationship with certain vendors is changing s.s a result of vendor corporate transactions. The requirement document, YA-GEN 9, no longer apphes to hiaine Yan~we in its permanently shutdown and defueled condition.

BASIS FOR CONCLUDING Til AT Tile REVISED PROGRAM INCORPORATING Tile Cll ANGE CONTINUES TO SATISFY Tile CRITERIA OF APPENDIX B AND TIIE SAFETY ANALYSIS REPORT OUALITY ASSURANCE PROGRAM DESCRIPTION COMMITMENTS PREVIOUSLY ACCEPTED BY Tile NRC:

Fire Protection is not covered by 10 CFR Appendix B; it is covered by 10 CFR 50.48 and Appendix R.

On August 7,1997, Maine Yankee submitted to the NRC a certification of permanent cessation of operations and a certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1). In issuing the Decommissioning Rule, the Nuclear Regulatory Commission modified 10 CFR 50.48 to explicitly address the Fire Protection Requirements for 10 CFR 50.82(a)(1) certified facilities. YA-GEN-9 no longer applies to Maine Yankee in its permanently shutdown and defueled condition. Maine Yankee will continue to control fire protection in accordance with its Fire Protection Program and 10 CFR 50.48(f).

3. IDENTIFICATION OF CII ANGI!

In Section 111. DESIGN CONTROL, Subsection B. RESPONSIBILITIES. Item 3, page 2 of 3, the following is deleted.

"3. The Fire Protection Coordinator YNSD shall be responsible for review of proposed design changes of fire protection systems in accordance with the Yankee Nuclear Services Division General Specification YA-GEN 9.

REASON FOR CII ANGE It is not appropriate to specify the vendor of choice in the Quality Assurance Program. The requirement document, YA-GEN 9, no longer applies to Maine Yankee in its permanently shutdown and defueled condition.

BASIS FOR CONCLUDING TilAT Tile REVISED PROGRAM INCORPORATING TIIE CIIANGE CONTINUES TO SATISFY TIIE CRITERIA OF APPENDIX B AND Tilli SAFETY ANALYSIS REPORT OUALITY ASSURANCE PROGRAM DESCRIPTION COMMITMENTS PREVIOUSLY ACCEPTED BY Tile NRC:

See the basis for item no. 2 above.

Page 4-2

4. IDENTIFICATION OF Cll ANGE in Section 111. DESIGN CON 11tOL, Subsection 11. RESPONSilllLITIES, item 5, page 3 of 3, the foltowing is deleted.

"5. 'the Manager. !!ngineering Support, via YNSD servicer, shall be responsible for.

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

b independent design verfication of proposed design changes to assure the adequacy of design, lil2 SON I OR CllANGE lt is not appropriatno specify the vendor choice it, the Quality Assurance Program.

IIASIS FO%NCLUDING '111AT Tile REVISED PROGRAM INCORPORATING Tile Cll ANGl!

CONTINUES TO SATFly.]11E CRITEP!A OF APPENDIX 11 AND TIIE SAFETY ANALYElfi 1(lil'CJtT OUAl llYAMURANCE PROGRAM DESClu2 TION COMMITMENTS PREVIOUSLY ACCEPTED llY Tile NRC:

The functions of establi hing and implementing a sys'em for processing design changes and performing independent design venfications are performed by the !!nginwing Division. Therefore, this change will not adversely affect the satisfaction of the criteria of 10 CFR 50 Appendix 11.

5. 1DENTIFICATION OF Cll ANGE in Section 111. DESIGN CONTROL. Subsection 11. IMPONSillll ITIES. Item 6, page 3 of 3 is modified as follows:

"The Director, Operations shall be responsible for the review and approval of all design changes."

REASON FOR Cll ANGE Responsibility for the review and approval of all design changes is already specified under the responsibilities of the Director of Operations. Review and approval design changes has been consolidated under one individual as a result of eliminating one layer of mt.nagement, llASIS FOR CONCI UDING Til AT Tile REVISED PROGRAM INCORPORATING Tile Cil ANGE CONTIN'31 TO SATISFY Tile CRITERIA OF APPENDIX B AND Tile SAFETY ANAL YSIS REPORT,ty)ALITY ASSURANCS PROGRAM DESCRIPTION COMMITMENTS PREVIOUSLY ACCEPTED fly Tile NRC:

10 CFR 50 Appendix ll., Criterion 111. Design Control requires that dnign changes be approved by the organization that performed the original design unless the a# mt designates another responsible organization. The Maine Yankee organizations designatel Quality Assurance Program for the

' approval of design changes, including design changr ,c , are the Operations Division and the Engineering Division 'lhis change rnaintains the appmmi of )perations Division and does not impact the Engineering Division's approval of design documents. r e tore, this change continues to sa'isfy the criteria of Appe, dix 13 and the SAR QAP commitments r , iously accepted by the NRC.

Page 4-3

! 6. IDENTIFICATION OF CllANGE in Section IV. PROCUREMENT DOCUMENT CONTROL ltem 3a is deleted:

" Review of purchasing specifications which detail the technical requirements for material, equipmre 1, and service purchases" Rl!ASON FOR CllANGl!

This statement is unnecessarily redundant to item 3b.

HASIS FOR rONCLUDING TilAT TIIE REVI3ED PROGRAh! INCORPOR ATING Tile CllAN'IE -

CONTINUES TO SATISFY Tile CRITERIA OF APPENDIX 11 AND Tile SAFETY ANALYSIS REPORT OUALITY ASSURANCE PROGRAM DESCRIPTION COMMITMENTS PREVIOUSLY ACCIIPTED llY Tile NRC:

This requirement is covered by item 3b and continues to satisfy the criteria (IV) of Appendix 11, 7, IDENTIFICATION OF ClI ANGE in Section Vll. CONTROL OF PURCllASED MNTERIAL EOUIPMENT AND SERVICES, Subsectior.

11. RESPONSIBILIIF;S, item 1 is modified as follrces:

"a. Performing audits %nd surveys of vendor quality programs, ,i; YNSO Ou;U;y Au.. ..;c D,i,.;tncn;, based a one or more of the following:"

"b. Planned vendor surveillancest M conjune: en oi;h YNSO-QA, which provide for:"

"c. Documentation and maintenance of the results of vendor audits; surveys and suntillances, including a listing of qualified vendors, in canjune;.m. eid. YNSO-QA."

"h Establishing procedurest ' ^ " ~~ ^ ^ 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, surveys and surveillance and to receipt inspection."

REASON FOR CllANGE It is not appropriate to specify the vendor of choice in the Quality Assurance Program.

BASIS FOR CONCLUDING Til AT Tile REVISED PROGRAM INCORPORATING Tile Cll ANGE CONTINUES TO SATISFY Tile CRITERIA OF APPENDIX B AND Tile SAFETY ANALYSIS in / ORT OUALITY ASSURANCl! PROGRAM DESCRIPTION COMMITMENTS PREVIOUSLY ACCEPTED BY TIIE NRC:

Maine Yankee has been and continues to be ultimately responsible for these functions.

Page 4-4

i

8. IDENTIFICATION OF CllANGE in Section IX. CONTROL OF SPECI AL PROCl!SSES, Subsection it RESPONSil31LITIES, is modified as follows:

"l.b Performance and/or evaluation of certain nondestructive tests in accordancc ;vith-Wmkce Nuc! car Seme&lHmica Wciding and Nandcs;ractive Examinatica Proccdsr '."

".' The Enkcc Nac! car Scr. ,cis Div;;.an :hdi bc icgeibic for appieving document--for ;vcl ding, and non-destmetiwnaminations."

IWASON FOR CllANGE It is not appropriate to specify the vendor of choice in the Quality Assurance Program.

IsASIS FOR CONCLUDING TilAT TIIE REVISED PROGRAhi INCORPORATING Tile CllANGE CQlfl1NUES TO SATISFY Tile CRITERIA OF APPENDIX 11 AND Tile SAFETY ANALYSIS REPORT OUAl ITY ASSURANCE PROGRAh! DESCRIPTION COMhilTh1ENTS PREVIOUSLY ACCEPTED IlY Tile NRC:

Maine Yankee has been and continues to be ultimately responsible for these functions.

9, IDENTIFICATION OF Cll ANGE in Section XVil. AUDITS, Subsection RESPONSilllLITIES, item 1.g page 2 of 2, the following is deleted:

"1.g Performing random informal evaluation of plant activities."

REASON FOR CllANGE This is not a requirement of 10 CFR 50, Appendix IL IIASIS FOR CONCLUDIN( lilAT Tile REVISED PROGRAhi INCORPORATING Tile Cll ANGE CONTINUES TO SATISFY Tile CRITERIA OF APPENDIX 11 AND TIIE SAFETY ANAL YSIS REPORT OUALITY ASSURANCE PROGRAhi DESCRIPTION COhihilTh1ENTS PREVIOUSLY ACCEPTED fly Tile NRC:

This is not a requirement of 10 CFR 50, Appendix 11. He Quality Assurance organization does perform other evaluations and surveys beyond that required by 10 CFR 50 Appendix 11 in order to provide effective oversight. nese other evaluations and surveys are not requirements of 10 CFR 50 Appendix 11 or ANSI N 18.2.

Page 4-5

ENCLOSUltE5 CllANGES SU31.%1 AltY TAllLE 17011 ItEVISIONS 12.13 ASD 14 Attached is a summary table identifying all of the changes associated with llevisions 12,13, and 14 to the Operational Quality Assurance Program (OQAP) document. Except for the changes which reference Enclosure 4, these changes do not constitute a reduction in commitment to the Operational Quality Assurance Program (OQAP) document. Therefore, included with these changes, as required, are the following:

All pages affected by the change are enclosed and indicated by brackets.

. Identification of the changes.

. The reason for the change.

Page 51

i REV.12 REV.13 REV.14 REASON t

! TITLE PAQE Deleted "Operationar from Reflects status of plant "OperationalQuality Assurance following submission of 10

,  ; Program" CFR 50.82 certificatons.

! TABLE OF CONTENTS l Appendix C modified as follows: Reflects the incorporation of I " Quality Assurance Program Approva! the OA Program for i { For Radioactive Material Packages i For Transport' I SIGNATURE PAGE

! Deleted "Operationar from Reflects status of plant j " Operational Quality Assurance" following submission of 10 j Changed" Plant Manager"to"Vice CFR 50.82 certifications.

i President Operations ~ Reflects a title change.

Changed,"Vice President Reflects title changes.

i Operations" to " Director Operations-Changed. "Vice President i Engineering to

• Director Engineering

• Added. " Director, Decommissioning'

! POLICY STATEMENT l HEADING: Deleted "Operationar Reflects status of plant i from " Operational Quality Program' follow *ng submission of 10 j Paragraph 1, Deleted "with respect CFR 50.82 certifications.

! to the operation maintenance of, and Reflects a title change.

l changes to the nuclear generaiing

facility ~

l Attachment 1 fThe Quality Reflects status of plant j Mission) Page 2, Paragraph 3 following sulnisinicri of 10

Line 1 Deleted "Operationar CFR 50.82 certifications.

Line 2, Deleted "in plant operation

• Reflects a title change.

! Line 3, Changed "OOAP~ to "OAP~

Page 5-2 I

l

Mu MW#GN J i REV.12 REV.13 REV.14 REASON

! Section 1. ORGANIZATION Subsection A. Scope Reflects status of plant  : -

PEragraph 1, Line 2: Deleted following submission of 10 i " Operational"from "Operailonal CFR 50.82 certifications. t

Quality Assurance Program' 'r l Subsection B. Responsibilities EditorialChange. This

Deleted Paragraph 1: This paragraph does not belong

Opcraticnc! Ouc!ity Assurance in this section and its l Program is adopted to ensure that contents are covered l ecmpany activitics related ic safety elsewhere in the OAP.

l etc in fu'l comp'icnce v.ith regule*ery i requircments, mcci c" applicable j industry standards-end-ere

! ccasistent v.ith good engincedng and raenegm...m.u y ices.

l Subsection B. Responsibilities Reflects status of plan

> Formerly Paragraph 2 following submission of 10

! Line 2, Changed " Operational CFR 50.82 certifications.

- Quality" to "the OA Program" l

Subsection B. 'asoonsibilities Editorial Change.

Paragraph 1,

Line 1, Replace "is the Corporate

! Officer with~ with "has' l Reflects status of plant i Subsection B. ResDonsibilities following subm:sson of 10

Formerly Paragraph 3, i Line 2, Replace " implement the CFR 50.82 certifications and editorial changes.

l Operational Quality Assurance l Program ~ with " execute the Quality l Assurance Program ~

' Line 3, Delete "Off-Site and On-Site" Page 5-3 L--- -

.e ..

I REV.12 REV.13 REV.14 REASON l Section I. ORGANIZATION (Continued)

Subsection B. RessGesE:% Reflects title changes and l

Pw.y.,4. 2, Line 1, Deleted adds the Director of

" Operations. Engineering- Deuniuiussiordng.

Line 2, Added "and the Directors of Operations. Engineering and

Decci usiissioning."

Subsection B. Responsibilities The STA function is no l longer required as appromd i P ray.,4i 3, Line 1, Deleted "Vice President of Operations and* by the NRC in Amendment Line 3, Deleted "STA's" and No.160.

". respectively~

l Subsection B. Responsibilities Reflects status of plant l Formerly Paragraph 5 Line 2, foltoeng submission of 10 CFR 50.82 certifications.

l Deleted" Operational"from

! " Operational Ot,ality Assurance ~

Subsection B. Responsibilities Reflects a title ch a,e and l implements a commitment Par.y.pii 4, Add: "The Director of

' Operation assumes the made in Proposed Change responsibilities of the generic title No.207.

l j

• Plant Manager

• as defined in ANSI N i 18.7" l Subsection B. Responsibilities Reflects editorial changes

' Formerly Paray.pii 6,

Line 2, modified as follows

" responsibility for dcEn:ng the Program esi iAiddrig and measuring hthe effectiveness of the Quality Assurance Ficy.iii."

Subsection B. Responsibilities Reflects title changes P .y.,A 5, Line 7. Replace ~ Plant Manager"with " Director of Operations

• Page 5-4

l REV.12 REV.13 REV.14 REASON l Section 1. ORGANIZATION (Continued) l Subsection B. Responsibilities This paragraph is redundant Pws si ph 8, Deleted: and unnecessary.

• In addition to the general authorities and duties of persons and organizations listed in this section, j more specific responsibilities for i performance of activities affecting the safety-related functions of structures, systems, and components are delegated to other persons and organizations as indicated in

Se%ons li-XVill of this Program' l

Subsection B. Responsibilities Reflects title changes P rinf.ph 7, Modify as follows:

"The Cviperide Officers and Drectors

?,c P:e-a ".";.wr. O -

Ofbr; and Ouc!?y Pref e c.s Depertmef*Meneger shall review changes to the Quality Assurance

! Program that concem their areas of l responsibility. The President and j Ouality Programs Department j Manager shall approve a!! changes."

l Page 5-5 1

i REV.12 REV.13 REY.14 REASON i

i Section I. ORGANIZATION (Continued)

Subsection B. Responsibilities Itis inappuviste to speofy Paragraph 10, Deleted: the vendor of choice in the j "The Nuclear Services Division of Quality Assurance Program.

j Yankee (YNSD) has a continuing l contractualobligation to provide -

l services to the Maine Yankee Atomic

+

l Power Company. These services i include those quality verification services, as requested by Maine Yankee Atomic Power Company, i l which are necessary to implement i i the Operational Quality Assurance -

l Program. The Maine Yankee i Engineering Support Manager is  !

I assigned responsibility to ensure that YNSD provides the services assigned.'

! Subsection C. Oraanizational Reflects status of plant l Relationships following submission of 10 Paragraph 1. modified as follows: CFR 50.82 certifications.

" highest management level through to intermediate levels of management to and including the o r ede-cperating organizatic ; (includirrg thosc of' sit: organizatic .a! units assigned responsibiliti for

precurcracnt, dcsign and j construction, quc!iti assurancc and  !

j technical sup-# acticitics.)

i Subsection C. Oraanizational Reflects editorial changes l

Relationships l Paragraph 1 Replace:"page 4"with i

• page 3 of 3*

i Page 5-6 [

f REV.12 REV.13 REV.14 REASON f Section i. CRGANIZATION (Continued)

I Subsection C. Orcanizational Reflects editorialchanges Relationships Paragraph 2. Line 3 modified as

{ follows:"As such hefc c, Quality

! Programs" Oraanization Chart Revised tc reflect j Oraanization Chart

! Revised to reflect decorrimissio-Jng Revised to reflect decommissioning reorganization due to

[ organization. organization. decommissoning.

f Section II. QUALITY ASSURANCE PROGRAM Section

Title:

Deleted: " Operational ~ Reflects status of p! ant i

from

• Operational Quality Assurance following subivahi of 10 l

Program' CFR 50.82 cenJications.

Reflects status of plant l Subsection A.Scooe fo!!owing subirm of 10 i Paragraph 1, CFR 50.82 certifications.

l Line 1 Deleted:" Operational ~

! Line 3 thru 5, Deleted:"the integrity l of the Reactor Coolant Pressure l Boundary, or the capability to l shutdown the reactor and maintain a i safe shutdown condition or,"

Subsection A. S_cong Reflects tFJe changes and Poi,y .pii 1, the addition of the OA i Line 2 thru 4, Replaced: Vice Program for pow President.Engineenng'with Director, radioactive material for i

Engineering' transport to Appendix C.

l f Line 9, Added:"In addition, Quality Assurance Program apples to packaging radioactive material for l

transport as defined in Appendix C of this program?

Page 5-7

! REV.12 REV.13 REV.14 REASON l Section 11. _ QUALITY ASSURANCE PROGRAM (Continued)

I Subsection B. Responsibilities Reflects status of plant Pare v..pt.1 foilowing subunssion of 10 l Line 1 & 3. Deleted "Operationar CFR 50.82 certifcations and an editorial change.

l from " Operational Quality Assurance' l Line 4, Modified as follows.

"...Section I, " Organization," ef-thes

program "

Reflects status of plant l $_ubsection C. Impleir,e. 6 tion j Paragraph 1, Line 1, Deleted: fonowing submissx>n of 10

! "Operationar CFR 50.82 certifcations.

Reflects an editorialchange l Subsection C. ImoFementation l Paragraph 2, Line 3, Deleted: "of the OA Program" Reflects status of plant

! Subsection C. Imsir.entation Note 2, Line 2, Deleted: foHowing st2nrussion of 10 j "Operationar from "the Maine CFR 50.82 certifications.

! Yankee Operational Quality i Assurance Program' l Subsection C. Implementation Reflects status of plant i Note 4, Line 1, Deleted: following submission of 10 CFR 50.82 certifcations.

l "Operationar from " changes to the

! Operational Quality Assurance Program" i Subsection E.Trainina Reflects title change item 2, Line 1, Replace " Plant Manager" with " Directors'"

l Subsection F. ANSI Standards and Reaulatory Guides First sentence, Deleted Reflects status of plant

' "Operationar from "The Operational following submission of 10

Quality Assurance Program" CFR 50.82 certifcations.

Page 5-8

~ ~ -

L______

l REV.12 REV.13 REV.14 REASON Section II. QUALITY ASSURANCE PROGRAM (Continued)

Subsection F. ANSI Standards and Reaulatorv Guides (Continued)

Item 1. ANSI N18.1 -1971 This is an ve.tatim Sub-Item a. ALTERNATIVE Replace dupfcation of TS 5.3.1.c.

. " .Section 5.3.1.c of Technica: This duplication has not Specification." with *...the following: changed the description of Technicians shall meet or exceed the the ALTERNATIVE in any l minimum qualifications of: way. The TS requirement is

1. Two years experience applicable to explicitly duplicated in their specialty, or anticipation of the TS

2. Two years of related academic relocation as desdibed in training in engineering or science and Proposed Technical i one year experience applicable to Specircation Change No.

their specialty and successful 207.

completion of a qualification program j applicable to their specialty.'

! Item 1. ANSI N18.1 - 1971 Added The subject of this change l *b. Exceotion: has been previously j Maine Yankee takes exception to the approved by the NRC in i Piavisions of Paragraphs 42.1, 4.22. Amendment No.160.

4.3.1,4.5.1,5.152 and 5.5.1 which requires the identfed positions to have NRC licenses ~

! *Altematire:

! In lieu c' the above, no r wsonnel are j required to hold NRC lic ises?

"c. Exception:

Maine Yankee takes exception to the provisions of paramoph 5.2 and 5.5.1 whch discusses training of candidates for l NRC examinations and retraining j respechvely7 l "Aftematim:

Maine Yankee wi!I provide Certifed Fuel l Handler (CFH) training on subjects applicable to the permanently defueled mode. In addition, CFH training need only j maintain proficiency in allowed activites."

Page 5-9

l REV.12 REV.13 REV.14 REASON

! Section 11. QUALITY ASSURANCE PROGRAM (Continued)

[ Subsection F. ANSI Standards and Reaulatorv Guides (Continued)

Item 2 ANSI N18.7 -1976 Sub- Ref'W%tus of plant item a, Exception, Line 3, Dele'ed followuva submisson of 10

, Operational from "...the Maine CFR SC 62 certifications.

l Yankee Operational Quality i Assurance

• Item 2 ANSI N18.7 -1976 Editorial l

l Sub-item c. Changed to "a" item 2 ANSI N18.7 -1976 The subject of this change f: Added: has been previously "c. EXCEPTION: approved by the NRC in Maine Yankee takes exception to A nendment No.160.

.I paragraph 5.2.1.1 of ANSI N 18.7-l 1976 which discusses the RO l authority and responsibility and paragraph 5.2.1.3 which discusses l

' the SRO responsibilities.

" ALTERNATIVE' No personnel are required to hold RO or SRO licenses.

Item 2 ANSI N18.7 - 1976 Refie.:ts editorial chargus Sub-item d. Changed to "e" and equivalent radiation ALTERNATIVE Line 2, Replace protechon practice j

• pocket dosimeter"with " Secondary l

Dosimetry Device' Item 2 ANSI N18.7 -1976 Editorial Change l

! Sub-item e. Changed to "g."

! Sub-item f. Changed to "h.'

Page 5-10

-l REV.12 REV.13 REV.14 REASON f Sect.on 11. QUALITY ASSURANCE PROGRAM (Continued) l Subsection F. ANSI Standards and Reaulatory Guides (Continued)

Item 2 ANSI N18.7-1976 Reflects status of plant Added: following submession of 10

• f. EXCEPTION: CFR 50.82 certifcations.

Maine Yankee takes exception to Ses N 5.3 of ANSI N 18.7-1976 j which requires procedures for starting up the reactor, steady state power j operations and load changing, j shutting down and tripping the

! reactor, and changing modes.~

' ALTERNATIVE-

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

Item 6 ANSI M45.2.3 -1973 Reflects status of plant item 6 ANSI N45.2.3 -1973 Sub-item a. Zone III Replaced: Sub-Item a. Zone ill Replaced first following subn-aht of 10

" Zone ill cnteria sha!! be applied to major p .y,p;, with: CFR 50.82 certifications.

portions of the Reactor Coolant System Zone crderia shall be applied to the i which are opened for inspection. Soent Fuel Pool and supporting

. maintenance. or repair. A., 'd-h are opened for With NOTE as modified below- impm. maintenance, or repair"

. (1) ano change > Added' (2)" Cleanliness shall be maintained

• NOTF c mmensurate e the w W The Zone I!! requirements may be peuvuned, so as to preclude the entry of expanded for certar.n

! (foreign material to the Reeeter maintenance / repair actmties if System.-

3) cno change >

deemed appropriate by plant lm The Zone III requirements maybe management. In such instances

. ,,-..cd appued for certain applicable sechons of Zones I & il maintenance / repair activities if may be specifMx1.

deemed appropriate by plant management. In such instances applicable sections of Zones I & il may be specified." _

Page 5-11

I REV.12 REV.13 REV.14 REASON Section 11. QUALITY ASSURANCE PROGRAM (Continued)

. Subsection F. ANSI Standards and Reoulatory Guides (Continued)

Item 14 ANSI N45.2.12 -1977 l Editorial Change Sub-Item c. Changed to "d*

.! Item 14 ANSI N45.2.12 - 1977 This is consistent with the l Added a new item 14 c.: time frame established in the i "c. EXCEPTION TechnicalSpecircatons Maine Yankee takes exception to the (5.5.B.11) thirty day requkement for issuance of the audit report.

ALTERNATIVE

, Maine Yankee wi!! issue audit reports l within thirty working days.

! Item 14 ANSI N45.2.12 -1977 The appupste location for l Modified as follows: these requirementsis the

./",;n "O^-, wcAJ g days. Ow cc^icc Correctrve Achon Program.

l

! ac;cacoag'etand;"; scc" bc as See Encl 4. Item No.1 i s,edfed i; "e audit docu;.4.. ; en I epp=ccd by cnonsgcaen" in l accordance with the time. frames

! contamed in the Correchve Achon

! Ficy.rv Item 20a. ALTERNATIVE Editorial Change Line 2 Replaced "FSAPJ with "DSAR*

l Section Ill. DESIGN CONTROL l Subwetion A.SCO_PEJ Reflects status of plant l Line 2 Deleted " Operational

• following submisson of 10 CFR 50.82 certiredvi6.

i t

j Subsection B. RESPONSIBILITIES Reflects a title change Item 2 Deleted:"Vice President.~

t Page 5-12

I REV.12 REV.13 REV.14 - REASON c Section lit. DESIGN CONTROL (Continued)

' ( Subsection B. RESPONSIBILITIES (Continued)

Item 2j Deleted "YNSD from "in it is inagevriote to specify accordance with YNSD the vendor of choecein the YA-GEN-9.~ Quality Assurance Program.

Item 2j Deleted: See Encl 4. Item No. 2

" Control of Fire Protecbon in accordance with YA-GEN-9.*

! Item 2 Editorial Change l Sub-item "k": Changed to "j' t Sub-item "C" : Changed to IC l Itesa 2 m.(2) Added or transferred I Line 2, Added:"... including responsibDity for

{ independent verification..." independent venfication.

i l

Item 2 Added Sub-Item "o": Documentation of existing j "o. Imposing requirements equivalent expectation.

to the above on contract organizations i that conduct desgn change activities

! independent of the Maine Yankee l processes

• Item 2 Editorial Change Sub-item "m": Change to *I*

3 Sub-item "n": Changed to "m' l Sub-item "o": Changed to "n*

! Item 3 Line 1, Deleted:"YNSD* It is inappropnate to speofy l Line 2 & 3, Deleted:"the Yankee the vendor of choice in tha

' Nuclear Services Division General Quality Assurance Program.

Specification'

/

Page 5-13

l REV.12 REV.13 REY.14 REASON Section ill. DESIGN CONTROL (Continued)

Subsection B. RESPONSIBILITIES (Continued)

! Item 3, Deleted Responsibility for the review l The Fire Protection Coordinator and approval of all design

! YNSD shall be responsible for review changesis already speciGed l of proposed design changes of fire under the respv.Gties of i protections systems in accordance the Director of Operations.

with the Yankee Nuclear Services See Encl. 4. Item No. 3 i Drvision General Specification YA-GEN-9.~

[

Item 5 Added: ftem 5 Deleted: It is inappivydate to specify f item 5 Deleted: *5. The Manager, Engineering the vendor of choice in the

! "S. The Manager. Engineering ~5. The Manager, Engineering l Support, via YNSD Services, shall be Support, via YNSD Services, shall be Support via YNSD Services, shall be Quality Assurance Program.

l responsible for responsibie for- responsible for' See Encl 4, Item 4

' a. Estab!ishing and implementing a a. Establishir.g and implementing a a. Establishing and implementing a system for processing design system for processirig design system for processing design changes. changes. changes.

b. Independent design verification b. Independent design verification of b. Independent design verification of of proposed design changes to proposed design changes to assure proposed design changes to assure assure the adequacy of design.* the adequacy of design." the adequacy of design.

f item "6", Changed to: *5" item "5", Changed to: ~6" Editorial Change Item 6 Replaced *Vice President One layerof management l

Operations

• with " Director. has been rernoved. The l OpweUv.6 Division reports Operations

• Changed to *3~ to the President.

See Enck 4. Item 5 Page 5-14

l REV.12 REV.13 REV.13 REASON Section IV. PROCUREMENT DOCUMENT CONTROL Subsection B. RESPONSIBILITIES Item ia, Line 3, Deleted: Reflecis status of piant

, Operational" follovnng subuni of 10 l CFR 50.82 certifications.

Item 2, Replaced:

• Finance and Reflects an organizational Administration

• with title change

" Decommissioning

• l Item 3, Deleted "Vice President.~ Editorial Change f' item 3a. Deleted: See End. 4. Item 6

" Paragraph 3a. Review of purdiasicg l specifications which detail the

{ technical requirements for material, j equipment, and service purchases

• l Item 3 Sub-item "b", changed to "a* Editorial Change i Sub-item "c". changed to "b"Section V. INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS Subsection B. RESPONSIBILITIES 1 l Item 1 Added "and/or audits" Editorial Change item 3, Line 1 Replaced:"Vice Editorial Change j j President. Engineering with 2

i

" Engineering Division" l

i Page 5-15

REV.12 REV.13 REV.14 REASON

!Section VI. DOCUMENT CONTROL.

l Subsection B. RESPONSIBILITIES I Item ia. Delete: . *at Maine Yankee Editorial Change and vendors."

l Item 2e. (4) Delete " Operational" Reflects status of plant i from " Operational Qua!ity Assurance" following submission of 10 CFR 50.82 certifications Item 2 Added: Documented an existing "f. Established storage, maintenance responsibility l

and document retention requirements for Quality Assurance records as applicable.'

Item 3 Replaced " Engineering"with item 3 Replaced "Vice President of Reflects title changes

Vice President of Engineering" Engineenng"with "The Engineering l Division"

{ Section VII: C_ONTROL OF PURCHASED MATERIAL EQUlPMENT AND SERVICES Subsection B. RESPONSIBILITIES Item 1a. Modified as follows: It is inappropnate to specify

" Performing audits and surveys

• the vendor of cfxpce.

Deleted "via YNSD Ouality included surveys.

l Assurance Department" . See Encl 4. Item 7 l

Item 1b. Deleted:"in conjunction with it is irtappropnate to speofy l

i YNSD-OA' the vendor of choice in the Quality Assurance Program I See Encl 4. Item 7 l Item ic. Modified as follows: It is inappiupdate to speafy

" Documentation and maintenance of the vendor of chon:e in the the results of vendor audits. surveys Ot.ality Assurance Pivgoiii.

and surveillances. " included surveys.

Deleted "in conjunction with YNSD- See Encl 4. Item 7 7

OA" Page 5-16 L

l REV.12 REV.13 REV.14 l REASON _.

Section Vll. CONTROL OF PURCHASED MATERIAL EQUIPMENT AND SER"lCES (Continued)

Subsection B. RESPONSIBlU_TlE_S (Continued) _-

Item ih. Deleted. ~in conjunction + tis inappopnate to specify with YNSD-Q4.' the vendor of chon:e in the Modified as follows: .~as pertsv4 Qua3y Assurait::e Prysni.

to vendor audit. survey and included surveys.

I surveillance... See Encl 4 Item 7 Item 2, Replaced

• Finance and Reflect;a1 Organistion Administration"with"D-. .osioning* T#le change i

l Section Vill. IDENTIFICATION AND CONTROL OF MATERIAL PANTS. AND COMPl NENTS

! Subsection B. RESPONSIBILITIES i Item 1 a, Deleted. covered by the ' Editorial Change i Operational Quality Assurance Program" l Item 2, Replaced:

• Finance and Reflects an Org aikoikni l Administration" vnth " Decommissioning ~ Title change

Section IX. CONTROL OF SPECIAL PROCESSFJ

! Subsection B. RESPONSIBILITIES i I Item 1.b. Replace Yankee Nudear it is inappivpaote to specify i i Services Division Welding and the vendor of choice in the j Nondestructive Examination. with Quality Assurance Prograni.

" approved' See Encl 4. Item 8 l

i item 3 Replaced:

" Yankee Nuclear Services"wnn i . .

l l Changed It" m "3" to *2d' i ltem "4", Changed to 7 Editorial Change I Section X. INSPECTION  !

Subsection B. RESPONSIBILITIES j

Item 1.f (8), Line 1 Deleted. ." normal Reflects subnunion of 10

, operaticns of the plant such as". CFR 50.82 certificat: orts.

l Page 5-17

! I i

l REV.12 REY.13 REV.14 REASON Section XI.IFJiLCONTROL Subsection B.E ;PONSISILITIEiS l Item 3 Replaced " Department

• with Reflects an Givoidzotivii

" Division ~ Title change l

i Section Xill. HANDLING. STORAGE AND SHIPPING Subsection B. RESPONSIBILITIES __

i Item 2 Replaced:"Frumce and Reflects an Orgacization A& ram 4 ion'with hn.auning- Title change l

l l Subsection Section XV. NONCONFORMING MATERIALS. PARTS. AND COMPONENTS B. RESPONSIBILI_TlES

{ ltem 1 Replaced. Plant Manager ~ Editorial Change I with Director Operations" l Section XVI. CORRECTIVE AC_I_IO_N i Subsection B. RESPONSIBIL._IT_JI S

- l Item 2 Deleted "2.The teaming Process Reflects an Organization f Department shaII be responsible for' change.

l Item 2a (1) and (2), Changed to"1c ResfuGty transferred j (1) and (2) as fo!!ows: " Establishing i procedures which prescribe:

l (1) Identification and Correction of j conditions adverse to quality (2) Significant conditions adverse l; to Quality, the cause and action

! taken to preclude repetition are i documented and reported to f management ~

. Item "3" Changed to "2" Editorial Change item "4" Changed to "3" Page 5-18

i REV.12 REV.13 REV.14 REASON l Section XVill. AUDITS

! Subsection B. RESPONSIBILITIES Item 1g Deleted: Item ig. Added. Item 1 g. Deleted: This is not a requirement of "g. Performing random informal "g. Performing random informal "g. Perfomung random informal 10 CFR 50 Appendix B.

, evaluation of plant activities.~ evaluation of plant activities.' evaluation of plant actisities." See Encl 4. Item 9 l Item "1 h", Changed to "19' Item "1 g", Changed to "1 h' Item "1 h", Changed to *1 g- Editorial Changes

,  ! Iter. 2b Replaced " deficiencies

• with Editorial Changes

! issues-item 3a Replaced

• deficiencies' with Editorial Changes f;

ssues" i Appendix B- MAINE YANKEE CLASSIFICATIONS l Applicability, Modified as follows: Reflects status of plant

! "This Appendix lists the systems, following submisson of 10 f structures and components (SSC) CFR 50.82 certdications.

i assocated with the storage control I and maintenance of spent fuelin a j safe condition ~...

Reflects status of plant lI. STRUCTURES

' Deleted:" containment (including following submission of 10 f penetrations) Safety Class 2" CFR 50.82 certirmations.

l Added "None' Reflects status of plant l II. ELF &CLRICAL SYSTEMS AND COMPONENTS folicmng su!nii@ of 10 Deleted: CFR 50.82 certifications.

"R. Heat Tracing for Post Accident Hydrogen Monitoring (IEEE Standard

- 622-1987)~

"S. Reactor Protection Systems" l "U. Emergency Feedwater Pump i Motors'

! Item "T", Changed to "R" Page 5-19

1 l REV.12 REV.13 REV.14 REASON l Appendix B- MAINE YANKEE CLASSIFICATIONS (Continued) l II. ELECTRICAL SYSTEMS AND Reflects status of plant

• COMPONENTS follomng subn-ass;cn of 10 Deleted "A" through "R". CFR 50.82 certE: cations.

! IV. MECHANICAL SYSTEMS AND Reflects status of plant COMPONENTS follomng submisson of 10

Paragraph 1, Line 3 Added: CFR 50.82 certfications.

"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 submittat As such, ANSI N '

18.2 does not apply to these systems l and components." ~

1 L

! Appendix B- MAINE YANKEE CLASSIFICATIONS (Continued)  !

j V. OTHER ITEMS RFQUIRING QUALITY ASSURANCE  ;

4 l Item S Deleted Reflects status of plant

] j ~5. Chemicals follomng submis-Jon of 10 i

a. Lithium Hydroxide CFR 50.82 certifications  ;

b. Hydrogen  :

c. Nitrogen L

d. Morphine

e. Hydrazine

f. Resins

• l

, l Item 6 Modified as follows: Reflects status of plant l Reagents for SFP purification and foliomng subm sson of 10  !

l liquid radwaste processing" CFR 50.82 certifications l l Changed to "5" i

I Item "7" Changed to "6" Editorial Change Page 5-70

l REV.12 REV.13 REY.14 REASON Appendix B- MAINE YANKEE CLASSIFICATIONS (Continued)

V. OTHER ITEMS REQUIRING QUAUTY ASSURANCE (Continued) l Items 8 and 9 Deleted Reflects status of plant j ~8. Control Element Assembles ~ following sutnru of 10

{ "9. Core Snpport Structure" CFR 50.82 cert:fications

! Item 11 Deleted "per YA-GEN-9" Editorial Change

! Items "10" thru "14" Editorial Change l Changed to ~7* thru *11" respectively -

i items 15 through 19 Deleted: Ref',ects status of plant

15. Nonmetallic thermalinsulation follomng submissaces of 10 used on safety class austenitic CFR 50.82 certifications stainless steel."

16. Nuclear Grade Point'

17. ContainmentVentitation/ Purge l " Filter Systein' j

' "18. Anticipated transient without Scram Response System'

~19. Station Blackout Equipment j (OAR unless already higher

, { classified as 1E. SC-1.2 or 3)~

Item 3 Deleted Reflects status of plant

~3. Diesel Fuel Oil (For the follomng submisson of 10  ;

Emergency Diesel Generators)~ CFR 50.82 certifications items "4" thru "11" Editorial Change

Changed to ~3" thru ~10" respectively

i f

t Page 5-21 I

! REV.12 REV.13 REV.14 REASON

\

j Appendix B- MAINE YANKEE CLASSIFICATIONS (Continued) i Table C.1, MECHANICAL SYSTEMS AND COMPONENTS CLASSIFICATION LIST Deleted the following: Reflects status of plant

Reactor Coolant System foliarwing submission of 10 Reactor Vessel CFR 50.82 certifications and Full Length Control Rod Drive revised accident analysis.

Mechanism Housing

! Part Length Control Rod Drive Mechanism Housing Steam Generator (tube side)

(shell side)

Pressurizer Reactor Coolant Piping and Fittings

! Reactor Coolant Surge Pipe

! and Fittings i Pressurizer Safety Valves Pressurizer Relief Valves Valves to Reactor Coolant System Boundary R: actor Coolant Pump Casing und Cover Feedwater System Emergency Feedwater Piping and Valves Emergency Feedwater Pumps Demineralized Water Storage Tank Feedwater Piping (inside containment and outside

containment to feed REG i isolation Valve)

! Auxiliary Feedwater Piping and

! Valves

! Auxiliary Feedwater Pumps i

Page 5-22

! REV.12 REV.13 REV.10 REASON Appendix B- MAINE YANKEE CLASSIFICATIONS (Continued)

Tatde C.1, MECHANICAL SYSTEMS AND COMPONENTS CLASSIFICATION LIST (Continued) l Deleted the following Reflects status of plant i Containment Sorav System following submisson of 10 I Spray Chemical Addition Tank CFR 50.82 certifications and

! Containment Spray Pumps revised accdent analysis.

! Chemica: and Volume Control System Regenerate Heat Exchanger Letdov :1 Heat Exchanger (tube snie)

(shell side)

Reactor Coolant Purification Demineralizers Reactor Coolant Filter Charging Pumps Centnfugal Auxiliary Charging Pumps Seal Water Supply Filters l Seal Water Retum Filter

' Seal Water Heat Exchanger tube side) f (she!! side)

(

Boric Acid Storage Tank Boric Acid Transfer Pumps Bonc Acid Filter Boric Acid Mix Tank Volume Control Tank l Letdown Flow Control Valves l Safety iniection System Refueling Water Storage Tank Safety injection Tanks Low Pressure Safety injection i Pumps Page. 5-23

l REV.12 REV.13 REV.10 REASON Appendix B- MAINE YANKEE CLASSIFICATIONS (Continued)

' Table C.1, MECHANICAL SYSTEMS AND COMPONENTS CLASSIFICATION LIS'i(Continued)

Deleted the following: Reflects status of plant Residual Heat Removal System following submission of 10 Residual Heat Exchangers CFR 50.82 certifications and revised accident analysis.

(tube side)

(shell side)

Main Steam System Main Steam Piping (from Steam Generator up to and including non-retum valves)

Safety Valves I

Atmospheric Dump Valve Steam Generator B!owdown System Piping (up to and including

< isolation valve)

I instrument Air System l Back -up air supply to containment Pu.ge and Isolation Valves l

(downstream of check valves)

Isolation air supply to Emergency Feedwater System Flow Control Valves (downstream of check valves)

Isolation air supply to Emergency Feedwater System isolation Valves (dr/wnstream of check valves)

Hydroaen Recombiner Taos Piping Valves Page 5-24

l REV.12 REV.13 REY.14 REASON Appendix B- MAINE YANKEE CLASSIEfC ATIONS (Continued) 1

' Table C.1, MECHANIOAL SYSTEMS AND COMPONENTS CLASSIFEATION LIST (Continued)

Deleted the following: Reflects statt;s of p! ant Service Water System following stdarsakai of 10 Service Water Pumps CFR 50.82 certifications and Valves and Piping revised acadent analysis.

Radioactive Gaseous Waste System Waste Gas Compressor Waste Gas Surge Tank Gas Decay Drums Comoonent Coolina Witer System

[

i Component Coo!ing Water Pump I Component Cooling Water Surge Tank Comporent Cooling Water Heat Exchangers Emeroency Diesel Generator System Diesel Feel Day Tank Diesel Engines Diesel Fuel Oil Transfer System Diesel Fuel Supply Tank l

i Emeroency Diesel Generator Startina Air System l

j Diesel Generator Air Tanies i Piping and Fittings Valves Filter Housings Spent Fuel Pool Cooling Pumps Spent Fuel Pool Heat Exchanger Spent Fuel Pool Cooling Loop Valves i Spent Fuel Pool Purification Pumps Expansion Joints I Fuel TransferTube and Flange Page 5-25

! REV.12 REV.13 REV.14 REASON Appendix B- MAINE YANKEE CLASSIFICATION _S (Continued)

Table C.1, MECHANICAL SYSTEMS AND COMPONENTS CLASSIFICATION 3 1,1 I(Continued)

Deleted the fellowing: Reflects status of plant Eouioment Drainaoe Svstem following submission of 10 High Pressure Drain Cooler CFR 50.82 certifications and Primary Drain Tank revised accident analysis.-

Primary Drains Degasifier Primary Drain Pumps Ventilation Filter Systems Spent Fuel Pool Deep Bed Filters Control Room Breathing Air System Control Room Recirculating Air

' System Modified as follows: Safety function limited to

" Spent Fuel Pool Cooling Loop Siphon Protection based Suction Piping from the poolwall up upon revised accident to and including the Siphon analysis.

Protection."

Changed Safety Class of" Fuel Based upon a reevaluation f

' under ANSI 18.2 Transfer Tube Outer Sleeve" from ~2" to ~3" l Appendix C. QUALITY PROGRAM APPROVAL FOR RADIOACTIVE MATERIAL PACKAGES Title Changed to:" Quality Assurance Editorial Change Program for Packaging Radioactive Material for Transport" Removed: Quality Assurance it is not approV iate to Program Approval For Radioactive merely attach the Approval Material Packages Certificate Certificate to the QAP.

nserted: Quality Assurance Program it is appropriate to include for Packaging Radioactive Material for the program in the Of P.

l Transport _

Page 5-26 I

ENCLOSURE 6

SUMMARY

OF 10 CFR 50.54(a) EVALUATION FOR Cll ANGES IN SAFETY CLASSIFICATIONS Maine Yankee Quality Assurance Program Appendix B states:

" Mechanical systems and components have been nuclear safety classified in accordance with ANSI Standard N18.2, " Nuclear Safety Criteria for the Design of Statiornry Pressurized Water Reactor Plants."

" 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 component to which they are associated except as noted . . ."

" Electrical and Instrumentetion systems and components designed in accordance with IEEE Standard 279. .

. and IEEE Standard 308. . . have been classified as safety class, and are listed below:"

" Items which require a degree of quality between non-nuclear safety class, and Ib or safety class 1,2, or 3, shall be designated a QA Related (QAR). QAR materials and components shall be in compliance with those parts of the QA program necessary to achieve the desired intermediate level of quality. A partial list of QA Related items follows:"

DISCUSSION (

SUMMARY

)

The change in systems safety classification is not being considered a reduction in commitment in that the commitments associated with the process for determining safety class are not being changed. The changes in safety class result from the submittal of 10CFR50.82(a)(1) certifications, the ec 7equential nonapplicability of certain regulations and the revised analyses now incorporated by 10CFR50.59 into our license basis. The

" decommissioning rule" published on July 29,1996 (61FR39278) explicitly indicated which regulations were no longer applicable to nuclear power reactor facilities which have submitted certifications of permanent cessation of reactor operation and permanent removal of fuel from the reac

or in accordance with 10 CFR 50.82(a)(1). The regulations which no longer apply include: Combustible Gas Control (50.44), Emergency Core Cooling Systems Acceptance Criteria (50.46 and App. K), Environmental Qualification (50.49), Containment Leakage Testing (50.54(o) and App. J), Fracture Prevention Measures (50.60,50.61, App. G and 11) and Anticipated Transient Without Scram Requirements (50.62). The revised analyses generally took credit for the year long decay effects associated with the spent fuel. Calculations were developed to determine the time to boil and boil off rate. A spent fuel pool structural integrity evaluation was perfonned to demonstrate the acceptability oflong term exposures to elevated temperatures. The results demonstrated that the time available

'o the operator to effect remedial action increased by an order of magnitude.

A review of the systems / components against the above considerations resulted in a large list of systems / components that no longer perform the safety functions described in ANSI N18.2. Therefore, those systems / components were declassified in accordance with commitments and processes for determining safety class. Associated support systems (water, air, instrumentation, etc.) that no longer support safety functions were similarly declassified. The revised structural analysis showed that the fuel pool was capable of sustaining the effects of boiling temperatures as a service condition. Therr" re, it was determined that all electrical systems / components could be declassified since the accidents and safety systems left no longer depend on electrical power to perform their functions (e.g. safety function is passive mechanical boundary, not active).

Make-up sources to the pool have historically been non-nuclear safety.

Page 6-1 i

The Safety Classifications and their applicability are as follows:

Safety Class 1 - (ANSI N18.2, par. 2.2.1) " Safety Class 1, SC-1, applies to components whose failure could cause a Condition 111 or Condition IV loss of reactor coolant," A loss of reactor coolant is no longer a M design basis accident due to the docketing of the certifications of the Permanent Cessation of Power Operation and Permanent Removal of the Fuel from the Reactor Vessel, Consequently, no components meet the definition or scope for Safety Class 1.

Safety Class 2 - (ANSI N18.2, par,2.2.2) " Safety Class 2, SC-2, applies to reactor containment and to those components: (1) of the reactor coolant pressure boundary not in Safety Class 1, (2) that are necessary to:

remove directly residual heat from the reactor, circulate reactor coolant for any safety system purpose, control within the reactor containment radioactivity released, control hydrogen in the reactor containment, or (3) of safety systems located inside the reactor containment." Maine Yankee is prohibited from entering a reactor operating condition in which containment integrity is required to be operable, Additionally 10CFR50.54(o) exempts facilities for which the certifications required under 10CFR50.82(a)(1) have been submitted. The reactor coolant pressure boundary, as defined in 10CFR50.2, no longer serves a safety function due to the permanent removal of fuel from the reactor; i.e. the " reactor coolant" no longer physically communicates with the fuel, Consequently, no components meet the definition or scope for Safety Class 2.

Safety Class 3 -(ANSI N18.2, par,2.2.3) " Safety Class 3, SC-3, applies to those components not in Safety Class 1 or Safety Class 2: (1) the failure of which would result in release to the environment of radioactive gases normally required to be held for decay, or that are necessary to: (2) provide or support any safety system function, (3) control outside the reactor containment airborne radioactivity released, or remove decay heat from spent fuel. Some components continue to meet the definition and scope for Safety Class 3 (e.g. portion of fuel pool cooling suction piping),

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