ML20205R454

Rev 3 to QA Program for Cooper Nuclear Station

ML20205R454
Person / Time
Site:	Cooper
Issue date:	03/27/1987
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20205R453	List: ML20205R454 NLS8700150, Forwards Rev 3 to QA Program for Cooper Nuclear Station. Summary of Changes Made to Program Also Encl
References
NUDOCS 8704060352
Download: ML20205R454 (85)

Text

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Attschment "B" NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION QUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT TABLE OF CONTENTS J

Corporate Policy Statement . . . . ............... v 1.0 PROGRAM DEFINITION . . . . .. ... .............. 1-1 1.1 Purpose .......................... 1-1 1.2 Policy .......................... 1-2 1.3 Objectives ... . . . ... ............... 1-4 1.4 Scope ............................ 1-6 1.5 Definition of Terms . ..... ........-...... 1-7 2.0

SUMMARY

DESCRIPTION . . . . . ... ............... 2-1 2.1 Organization . .. . .... ............... .

2-1 2.2 Quality Assurance Program . . ............... 2-2 t

2.3 Design Control . . . . ... ............... 2-5 DR I ' ** * "

ADO !oh$298 PDR

TABLE OF CONTENTS (Cont'd.)

2.4 Procurement Document Control ............... 2-11 2.5 Instructions, Procedures & Drawings ............ 2-13 2.6 Document Control ... .................. 2-14 2.7 Control of Purchased Material, Equipment, and Services . .... .................. 2-16 2.8 Identification and Control of Parts, Materials, and Components ...................... 2-17 2.9 Control of Special Processes .......... ..... 2-18 2.10 Inspection . . ...................... 2-19 2.11 Test Control . .......... ............ 2-21 2.12 Control of Measuring and Test Equipment .......... 2-22 2.13 Handling, Storage, and Shipping .......... .... 2-23 2.14 Inspection, Testing, and Operating Status ......... 2-25 2.15 Nonconforming Materials, Parts, or Components ....... 2-26 2.16 Corrective Action ...... .......... . .... 2-29 2.17 Quality Assurance Records ................. 2-30 2.18 Audits . . . . ...................... 2-31 2.19 Additional ANSI Standards. ............ ..... 2-32 l l

3.0 ORGANIZATION AND RESPONSIBILITIES . ... ............ 3-1 3.1 General . . . . ... . ...... ....... ..... 3-1 3.2 Nuclear Power Group Management ... ........ .... 3-2 l 11 ' Revision 3-

TABLE OF CONTENTS'(Cont'd.)

l 3.2.1 Vice-President - Nuclear . ............. 3-2 3.2.2 Division Manager, Quality Assurance ....... 3-3 3.2.3 Quality Assurance Manager - CNS ..._...... 3-5 3.2.4 Quality Assurance Supervisor - G.O.. ....... 3-6 3.2.5 Quality Assurance Supervisors - CNS. . ...... 3-8 3.2.6 Quality Assurance Staff. . . . . . . . . . . . . . 3-8 3.2.7 Division Manager Nu'elear Engineering and Construction . ...... 3-10 3.2.8 Division Panager Nuclea r Operations . . . . . . . . . . . . . . . . 3-11 3.2.9 Division Manager - Nuclear Support ........ 3-11 3.2.10 G.O. Department Managers . . . . . . . . . . . . . 12 3.2.11 CNS Department Managers. . ............ 3-12 3.3 Cooper Nuclear Station Personnel . . . . . . . . . . . . . . 3-12 3.4 G.O. Personnel . . . . . . . . . . . ............ 3-13 3.5 Safety Review and Audit Board (SRAB) . . . . . . . . . . . . 3-13 1

3.6 Station Operations Review Committee (SORC) . . . . . . . . . 3-13 3.7 Outside Suppliers, Contractors, Subcontractors, and Consultants ...................... 3-14 l

4.0 QUALITY ASSURANCE DOCUMENTS . . . ................ 4-1 4.1 NPPD Internal Documents .................. 4-1 iii Revision 3

TABLE"0F CONTENTS (Cont'd.)

l 4.1.1 Quality Control Inspection'. . . . . . ...... .

4-2 4.1.2 Quality Assurance Instructions (QAI) . . . . . . . 4-4 4.1.3 Quality Assurance Plans (QAP) ... . . .-. . . . 4-4 5.0 METHOD OF IMPLEMENTATION .................... 5-1 1

6.0 RECORDS RETENTION AND DISPOSITION . . ...... ........ 6-1

7.0 REFERENCES

........................... 7 ,

8.0 FIGURES . . . . . . . . . . . . . . . . . . .. .. . . . . . .. . . . 8-1 8.1 Quality Assurance Organizational Chart (Figure 1) ..... 8-1 8.2 Nuclear Power Group Organizational Chart (Figure 2)- .... 8-2 9.0 TABLES ............................. 9-1 9.1 Systems and Components Within Scope of the CNS QA Program (Table 1) ..................... 9 9.2 Three Level QA Program (Table 2) . . . . . . . . . . . . . . 9-4 iv - r. Revision 3

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

. Section 1.2 of this document.

Each Nuclear Division is responsible for the development of policies l and procedures which implement this Quality Assurance Program. Other divisions f

and departments at NPPD may also have responsibilities under. this program and 4 shall comply as described in appropriate implementing procedures, i The Quality Assurance Division and established Safety Committees shall monitor the District's' nuclear program and provide management with evaluations 4

and assessments regarding the effectiveness of the implementation of the program.

j When evaluations and assessments identify a concern, management shall take I expeditious action to correct any undesirable condition (s) including, where f

l appropriate, action to preclude repetition of such condition (s).

District personnel shall have the organizational freedom to identify concerns and propose corrective and preventive' action necessary to enhance the District's nuclear program.

The assurance of safe and reliable operation of Cooper Nuclear Station is ~

everyone's duty. Quality shall be everyone's responsibility.

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President l

Approved:

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3 - z.7-91 Vice-Predident - Nuclear ks a // ~ ~ /s ~ mAm/ ~ ~

g-z?-57 Division 7taniger - Quality Assurance 4-

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t COOPER NUCLEAR STATION

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QUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT 1.0 PROGRAM DEFINITION In accordance with the conditions of the Nuclear Regulatory Commission construction permit and operating license for the Cooper Nuclear Station, the management of Nebraska Public Power District recognizes its responsibility for

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assuring that the Cooper Nuclear Station is designed, constructed, and operated in such a manner as to provide for the safety of the public. The importance of

. Quality Assurance in contributing to this safety as well as contributing to station reliability is also recognized.

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

station operation.

1.1 Purpose $

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e The purpose of this policy document is to provide a description of the Q{ality Assurance Program to be followed during Cooper Nuclear ~ Station 1-1 , Rev.ision 3

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'e, operational phase and to provide guidelines for implementation of the policies and procedures described herein. This CNS Quality Assurance Program kr Operation was developed by Nebraska Public Power District in response to the requirements of 10CFR50, Appendix B. This policy document p'rovides a general description of the Quality Assurance Program for. 0peration and requires that detailed Quality Assurance Documents be set forth in writing and carried out by each of the responsible organizations or individuals within the District.

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

procedures, or drawings and such activities shall be implemented as documented.

And further, such documentation shall contain adequate qualitative and/or l

quantitative acceptance criteria to provide a measure of accomplishment. l i l With regard to assurance of quality in all phases of station operation, it is the policy of Nebraska Public Power District (NPPD) to staff the plant with 1

properly-trained personnel in all responsible positions and job' assignments.

4 Sufficient numbers of licensed and senior licensed operating personnel will be f

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e available to assure proper operation of the station under all ' reasonably -

foreseeable circumstances of personnel turnover, vacations, disability, and the i

l like.

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All District personnel responsible for operating. maintaining, or i

designing safety-related systems and equipment shall receive formal instruction 1'

4 in Quality Assurance, including basic ' principles, 10CFR50, Appendix B, ~ the

contents of.this policy document, and Quality Assurance Documents as applicable.

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Trained technical, engineering, and Quality Assurance Personnel shall be assigned surveillance and audit tasks to ensure compliance with the i-

requirements of the documents which control station operation, such as the NRC i'

license, Safety Analysis Report, Technical Specifications, Operating Manual, 1 QA Program for Operation, and other such controlling documents. : Personnel i assignments shall be made by the normal line organization management and w*.11 be

verified by the QA Division. However, during the time personnel are performing j QA functions, they shall be responsible to the QA Division to effect' the t.

I organizational independence required by the QA Program.:

It is the policy of Nebraska Public Power District to maintain quality standards for the entire station which will ensure the high degree of reliability u

. 1 and safety needed to meet the overall objectives of supplying dependable electric

f. service to its customers.

l The CNS QA Program for Operation will use the guidance provided by NRC i 1 i

publications WASH-1283 (5-24-74), WASH-1284 (10-26-73), and WASH-1309 (5-10-74) 1

! (" rainbow" series) except where specific exceptions and clarifications are noted l

within this document.

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In summary, NPPD is committed to the continuous . development of a l Quality Assurance Program which will meet the requirements of .10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and other applicable regulations as may be promulgated by the Nuclear Regulatory

. Commission. This commitment applies to all NPPD organizations to assure' that a-high standard of quality will be maintained during nuclear plant operation.

! Section 2 of this document presents a summary discussion of the QA Program as j .

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applicable'to the 18 criteria of 10CFR50, Appendix B.

l 1.3 4 Objectives l r j In accordance with the policy statements above, the overall objective of the CNS Quality Assurance Program for Operation, as defined in Quality Assurance Instructions (QAI's) and Quality Assurance Plans (QAP's), is to set forth the Quality Assurance organizational structure an'd personnel responsibilities and to set forth guidelines for the preparation of written .

j procedures and controls necessary for quality surveillance and auditing to verify the following:

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1 l a) Regulatory criteria, codes and standards, and design bases for safety-related systems (as defined in the CNS QA Program) are incorporated into the test, operating and maintenance procedures and instructions to meet all requirements for nuclear safety and station reliability; i

b) Results of all preoperational and operational ~ tests of safety-related systems and components conform to the requirements of the l drawings, specifications, procedures, and instructions, and appropriate reports j are prepared to document that all results of tests meet prescribed acceptance criteria; i

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c) Nuclear Fuel is purchased, designed, manufactured, inspected, packaged, shipped, received, installed, and operated in the reactor in accordance with approved procedures and instructions, and in compliance with regulatory requirements and license stipulations.

d) The Station is operated, maintained, tested, refueled, repaired, and modified, in accordance with approved procedures and instructions, and in .

compliance with regulatory requirements and license stipulations and consistent with quality standards equal to or better than those in effect during design and construction; e) A system is set up and maintained to control, safeguard, and permit ready retrieval of quality-related documentation generated for materials and components during the design, fabrication, construction, and operation of CNS.

f) Appropriate and complete reports, records, and logs are initiated and maintained so as to provide a continuing record of quality-related activities associated with station safety and reliability throughout the life of the station.

g) The station personnel are subjected to periodic training, retraining, requalification, and examination such as to maintain and improve their job skills which are essential to safe and reliable operation of the station; h) Station security and nuclear fuel accountability and safeguards are maintained in accordance with approved procedures and instructions.

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6 i) Nonconformance reports are to be properly. reso1'ved .and filed in the quality-related record. files.

j) Inspection reports issued . by NRC are properly resolved and documented.

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

1.4 Scope

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The QA Program for Operation applier to those nuclear station structures, systems, and components that are designed to prevent or mitigate the consequences of postulated accidents which could cause undue r'isk to the health and safety of the public, and to other selected systems as defined in implementing QA Plans. The requirements of this program apply to all activities which affect the safety-related functions of those structures, systems, and components, including designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service inspection, and modifying. -

This program specifically applies to, but is not necessarily limited to the nuclear fuel, the reactor coolant system and its auxiliaries and controls, the reactor protection and engineered safety systems, the reactor containment system, portions of the radioactive waste disposal system, and other systems and 1-6 Revision 3 I

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

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

} The Quality Assurance Criteria in 10CFR50, Appendix B, are oriented primarily toward engineering, manufacturing, and construction activities.

Therefore, it is necessary to define, by specific Quality Assurance Documents, the manner in which the NRC Quality Assurance Criteria are to be applied to the 9

station operating activities. Such Quality Assurance Documents shall be prepared in accordance with the requirements specified in Sections 2.0 and 4.0 of this policy document.

The Specifications, principles, and procedures which controlled the original procurement, fabrication, and construction have been carried over into the QA aspects of station operation to the greatest extent practicable.

It is the intent of NPPD management to naintain, as a minimum, the quality level achieved in the original design and construction.

1.5 Definition of Terms Key words and phrases which are used to characterize this QA Prograa j

are defined in a Quality Assurance Instruction to establish a basis for uniform and consistent interpretation of the Quality Assurance requirements and-to provide some insight into the intent of these requirements. Definitions of these 1-7 Revision 3' b

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terms are based upon documents and standards issued by 'the American National i 8

Standards Institute (ANS1), by the NRC Safety and Regulatory Guides, and by the l

! several professional societies involved in standards ' work (ANS, ASME, IEEE,-

et al.)'; or shall be defined on the basis of contemporary usage in the nuclear power industry; or shall be defined specifically to convey .the intent. of this particular program. Specific to the related ANSI Standard for this subject, the i

! following commitment applies:

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1. ANSI N45.2.10-1973 " Quality Assurance Terms and Definitions," and i

the associated Regulatory Guide 1.74, are applicable to . the CNS Operational 3

I QA Prograa, with the following clarification:

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l There may be instances where existing procedures contain definitions that may not be in strict accordance with those provided by this

standard. As existing procedures are revised, however, such definitions shall be evaluated to assure that all definitions meet those provided by this standard.

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

requirements.

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Design Change A design change is considered to be any change to a component, 1

j equipment, or structure that changes the desigi criteria or margin of safety for 2

a system or component which could impact nucitar safety, equipment and system 1

integrity, or personnel safety.

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'l Essential 1

(See Safety-Related.)

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

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

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

Quality Assurance Documents Those documents inclusive of the QA Policy Document, QA Plans, QA Instructions, Procedures (and associated data sheets), logs, etc., which have been approved for use, and whose intended function is to provide direction, verification, or documentation for activities affecting quality. l 1-9 ' Revision 3

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Quality Assurance Instructions Quality Assurance Instructions shall provide guidelines for surveillance and audit activities of functional areas to be performed by the In addition, they shall define the responsibilities for implementation d

QA Staff.

of the QA Program in accordance with policies and practices herein defined.

Quality Assurance Plans l

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! Quality Assurance Plans are those documents specifically designed to i provide detailed quality requirements for a given functional area. . The plans are i

generated by applying the 18 criteria of 10CFR50, Appendix B, to each functional i

area and then deriving the specific quality requirements for that area.

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Quality Assurance Records i

4 Those quality-related records (see Reference 7.10) which have been completed and furnish documentary evidence of the quality of items and/or

{ activities affecting quality.

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l A document becomes a Quality Assurance Record when it is dedicated.

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! This dedication occurs when the activity related to the document becomes part of J

l the operating condition of the plant.

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Quality Control 4

4 Those activities which deal directly with the measurement, observation, )

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

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

Safety-Related All activities which af fect structures, systems, or components that prevent or' mitigate the consequences of postrelated accidents that could cause undue risk to the health and safety of the public.

Significant ' Conditions Adverse To Quality Any conditions that could affect safety-related structures, systems, or components ability to function within design requirements or alter performance characteristics.

Supplier Evaluation Those activities which determine the ef fectiveness of implementation of A variety ~of methods may be used to the supplier's Quality Assurance Program.

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

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SUMMARY

DESCRIPTION This section defines NPPD commitment to meet the requirements of the 18 criteria of 10CFR50, Appendix B, as it applies to safety-related structures, In addition, it systems, and components associated with Cooper Nuclear Station.

includes NPPD interpretation of the 18 criteria as they apply to an operating nuclear power plant.

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

2.1 Organization (Figure 1)

The President and Chief Executive Officer (C.E.O.)

represents the highest level of management for establishment of Quality Assurance policies, goals, and objectives. The responsibility and author'ity for nuclear facility and General Of fice support activities (including QA) has been delegated to the Vice-President - Nuclear. This authority includes the right to direct, enforce, and perform any action required to ensure all activities conducted at .

In addition, Cooper Nuclear Station are in compliance with 10CFR50, Appendix B.

the personnel assigned to the Quality Assurance Division shall have complete independence to perform audits, inspections, verifications and shall be independent of those groups performing, designing, purchasing, fabricating, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service inspecting, and 2-1 Revision 3

i modifying. Figure 1 of this document cutlines the QA Division functional organization. Quality Assurance Personnel shall have suf ficient authority and organizational freedom to:

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

2.2 Quality Assurance Program .

The program shall be implemented in accordance with written, approved Quality Assurance Plans and the guidelines developed by the Quality Assurance Division. The District's QA Program will comply with the Quality Assurance Guidelines contained in the Orange Book - WASil, 1284- 10-26-73. Design Control, Procurement Control Quality Control, and Quality Assurance activities associated with plant modifications will similarly conform to the guidances provided within the Gray Book - WASH, 1283- Rev.-1 and the Green Book - WASH, 1309- 5-10-74.

Procedures will be prepared for each important activity of station operation which will clearly define the work to be performed on a step-by-step basis and will identify, where appropriate, the results to be achieved. Mandatory QC or QA Inspections or Tests will be performed on an independent basis to verify that  !

procedures are being followed (correct results obtained) and will be incorporated into the work procedures directly or by attachment. QA Audit activities will accomplish the function of verifying that the Quality Control Program is in effect and that QC activities are being carried out as prescribed.

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

1. ANSI N18.1-1971 " Selection and Training of Nuclear Power Plant

Personnel." shall provide guidance for selecting and training of personnel for i

i the Nuclear Power Group.

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] '2 . ANSI N18.7-1972 "American National Standard for Administrative-

! Controls for Nuclear Power Plants " and the associated Regulatory Guide 1.33, l apply to the CNS Operational QA Program with the same exceptions as th'ose taken j in other sections of this Policy Document to ANSI N45.2-13.

i j 3. ANSI N45.2-1977 " Quality - Assurance Program Requirements for Nuclear Facilities " and associated Regulatory Guides 1.28 and 1.33, shall apply l 1 i to the CNS Operational QA Program, with the following exceptions:

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l (a) Where codes or standards are referenced, or are incorporated into this standard by reference, which are in conflict with original design i

commitments as set forth in the USAR,= the USAR commitments shall govern. Later

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

$ condition. '

i (b) Where Section 11 " Inspection" identifies the reporting i

I relationship between the inspector and the "immediate supervisors who are i

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

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the individual performing the verification function shall not perform or directly j supervise the work b'eing inspected. -

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

' Cooper Nuclear Station to be covered by this program. The Nuclear Operations and Nuclear Engineering and Construction Divisions, with the assistance . of the QA Division, will identify essential structures, systems, and components to be included within the scope of the QA Program. The Quality Assurance Program is designed to provide control over all activities affecting quality of essential .

items to a degree consistent with their safety-related importance. These i

activities will be governed by approved plans and instructions and these

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documents shall be followed under controlled conditions. The Quality Assurance Plans and Instructions will be reviewed periodically to assure that th'e requirements of the program are being met and new requirements are being incorporated. 4 i

1 In addition to essential structures, . systems, and components, applicable portions of this program shall be applied to selected nonessential

- structures, systems, and components important to station reliability and performance.

Specific application will be identified in dedicated Quality Assurance Plans.

Special process controls, test equipment, tools, skills'(training, if required) shall be used during the conduct of inspection, verification and checking activities to assure a high standard of quality and reliability has been obtained on safety-related items covered by the Quality Assurance Program. Test equipment and special tools will be calibrated against a specified ' secondary I

standard.

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Experienced designated individuals (which may include personnel from other divisions of the Nuclear Power Group (NPG), and/or outside qualified individuals) may.be requested to assist in performing audits and inspections of certain CNS quality-relcted activities at the direction of the Division Manager of Quality Assurance. During these assignments, these individuals will have sufficient organizational freedom to identify and recommend corrections for quality deficiencies noted.

The Nuclear Training Department, in addition to QA Staff personnel, provides QA indoctrination and on-the-job training for NPG employees as described in nuclear training pr6 gram descriptions. In addition, QA Staff members will attend a minimum of one training seminar per year by a qualified agency and/or school. Ongoing QA training for personnel with nuclear plant responsibilities will be provided. Training activities will be audited periodically by the i

QA Staff to verify its scope and effectiveness. .j l

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

The procedures provide the mechanism for correctly translating the design changes and regulatory requirements into specifications, drawings, procedures, and instructions. They also establish the method of reviews, interface requirements (with original design organization, if required), approvals, and the organizations delegated the authority to implement the design change.

Design control measures shall include the review for suitability of application of items that are essential to the safety-related function of the j 2-5 . Revision 3 w

system involved. This review will normally occur during the normal design change review or during review of the procurement document by Quality Assurance and the Engineering and/or Maintenance Departments. A necessary part of this review concerns the safety classification of items to be procured. In those instances where the normal methods of Section 2.7 cannot be applied and it is necessary to purchase " commercial-grade" off-the-shelf items for use in essential applications, verification will be performed to ensure that the part utilized is functionally acceptable for the essential application. ~ This verification may include acceptance testing upon receipt, analysis, or other definitive method.

All design changes initiated for Cooper Nuclear Station will be forwarded to the QA Division for review and independent evaluations. These reviews shall verify the compatibility of tne design change with applicable codes, standards, and regulatory requirements. Items to consider include reactor physics, stress, thermal hydraulic and accident analyses, compatibility of i

materials, accessibility for in-service inspection, maintenance, repairs, and delineation of acceptance criteria for inspection and tests.

4 Final acceptance of the design change will require an independent verification or check of the design adequacy such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

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

1. ANSI N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants," and the associated Regulatory Guide 1,64, shall be 2-6 , . Revision 3

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4 applied to design activities involving. safety-related modification work and the revision or development of plant design documents occurring during - the operational phase of CNS. The following clarification statement is provided:

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

2. ANSI N45.2.4-1972 " Installation, Inspection, and Testing

Requirements for Instrumentation and Electric Equipment During the Construction i

l of Nuclear Power Generating Stations," and its associated Regulatory Guide 1.30, shall be applicable to the CNS Operational QA Program for safety-related i modification work, with the following exceptions / clarifications:

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

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

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

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

During the development of work packages, consideration will be given to the areas outlined in Section 2.3, as appropriate.

-(d) The requirements for installation, inspections, verifications, and tests shall be included in the instructions. In the development of these instructions, consideration will be given to the guidance provided by Sections 4.0, 5.0, and 6.0 of this standard, and appropriate requirements will be incorporated into the instructions. It is not intended that separate procedures by established which specifically address all of the areas referenced.

(e) Application of the guidance provided by the additional codes and standards listed in Appendix B will be considered to the extent that such codes and standards provide useful and practical guidance for the work being performed.

Ccmmitments to the guidance of N45.2.4 shall not include commitments to the guidance of referenced standards.

3. ANSI N45.2.5-1974 " Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear' Power Plants," and its associated Regulatory Guides 1.94, shall be applicable to the CNS Operational QA Program for safety-related modification work, with the following exceptions / clarifications:

. (a) Appropriate requirements for installation, inspection, and tests will be set forth by job specifications and work instructions developed as a part l

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of the modification work' package.' 'It is not intended'that. separate' procedures be established which specifically address the various areas of - this ~ standard..

However, in the development of the work package, consideration will be given to .

the areas outlined in Section 2.2, as appropriate.

! -(b) The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied to all measuring and test  :

, equipment used by NPPD or their agents, test laboratories, and contractors. Such '!

requirements, however, will not be imposed on commercial batch plant facilities.

Instrumentation at commercial batch plant facilities will be evaluated by. NPG construction management personnel, or their designated representative, to -

determine that suffic'ient accuracy can be obtained and will be verified by an independent QA Audit. -

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(c) For small quantities of concrete involved in modification work. .

all concrete must be purchased from commercial concrete batch plants. For these l

small quantities of concrete, it is unreasonable to expect commercial facilities

to shut down normal operations to provide certified aggregate, cement, admixtures, fly ash, water, etc. In - this respect the qualification tests required by Table A for aggregate; cement, admixtures, fly a'sh, and pozzolans; water and ice will not be required. Appropriate evaluations will be made - to j determine that good quality and generally-acceptable materials are used. NPC

{ construction management evaluation, coupled with slump tests, air entrainment i tests, and concrete cylinder strengths, will provide adequate control and e

qualification of the concrete. The results of evaluation will be verified by an independent QA Audit.

1 (d) Design mixes consistent with, or equivalent to, original requirements will-be specified and the results of the cylinder tests wil1~ be

2-9 -

' Revision'3

4 s

evaluated by NPG construction management based on the acceptance criteria l

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

4 s

(e) The inspection requirements of Section 4.2 will not' generally'be performed as the small quantities of' concrete involved in modification work will no doubt be mixed using materials already in the batch plant bins. Control of ,

storage of materials would not be practicable.

t (f) If ava'ilable, appropriate certifications shall be obtained from -

the concrete supplie'r which verify the adequacy of- . truck ' mixers per the requirements of ACI-304, ASDI C-94. Where certifications are not available, two concrete test cylinders representing the firs't and last one-third of truck' mixer  ;

contents shall be taken for evaluation of the mixer truck, over and above the normal concrete cylinders taken to evaluate the in-place concrete. The concrete i batch plant facility shall be insp'ected by NPG construction management and the CNS QA Staff to assure thati reasonable controls are being exercised with reference to the inspection guidelines set forth by Section 4.3(1) and (2).

i-(g) Inspection of fills and earthwork will meet the general requirements set forth. The extent to which individual inspection requirements are met will depend upon the nature and scope of the work to be performed.

f 1

(h) Except for normal batch qualification tests (slump, air. content, temperature, and compressive} strength) and initial reinforcing steel certifications, the in-process tests required by Table B are generally applicable i i to the - periodic control which must- be - exercised with reference - to long-term 2-10 Revision 3

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4 construction type programs. The in-process test requirement of Table B are not considered applicable to short-term modification work as would.be required by QA at CNS.

4. ANSI N45.2.8-1975 " Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," shall be applicable to the CNS Operational QA Program for safety-related modification work, with the following clarification:

l I

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

2.4 Procurement Document Control 4

i i

Cooper Nuclear Station Procedures, Nuclear Engineering Department i Procedures, and Quality Assurance Plans and Instructions are required to define the applicable requirements, design basis methods, and procedures for procurement of spare parts, materials, and equipment for essentia1' nuclear systems. These instructions and procedures shall also include provisions for assuring that the necessary quality requirements are incorporated directly into the procurement documents for essential spare parts, material, and equipment. These instructions andj procedures shall also include provision for assuring that the . necessary records are supplied to the purchaser by the supplier.

1 J

l 2-11 -

Revision 3

,,(

l The basic principles and practices included in these procedures are  ;

4 expected to be applicable, in general, to any purchasing activity necessary for operation of the station; however, in the event that procurement is necessary for-major modification or repair activities, 'some additions may be necessary to provide adequate control.  !

Procedures ' covering procurement provide for - independent Quality i

Assurance review of the. essential purchasing documents;-review and approval of 4

suppliers; and QA Audit of contractor and supplier activities.

Change Orders issued on any procurement document will be subjected to the same review and approval as the original order.

-i In addition, all procurement documents issued to suppliers of safety-related items or services require that the supplier have a Quality Assurance Program that meets the intent of 10CFR50, Appendix =B. The Quality Assurance Program submitted by the supplier will be evaluated by NPPD QA to ascertain that they meet the criteria established in 10CFR50, Appendix B,' or an equivalent program which assures the necessary level of quality (as determined by NPPD QA).

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

Where necessary, because of design modifications, or where it is necessary or desirable to upgrade quality in replacement parts or material, necessary modifications will be made to' drawings and specifications to incorporate requirements for currently appropriate quality level. These 2-12 Revision 3

O modifications or upgrading of replacement parts will be accomplished in accordance with approved instructions, proceduros, and drawings. These documents i

will be subject to Station Operations Review Committee (SORC) review before being

. implemented.

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

1. ANSI N45.2.13-1979 " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants," is applicable to the CNS Operational QA Pr'ogram, with the following clarification:

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

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

2.5 Instructions, Procedures, and urawings Quality Assurance activities and other activities which have nuclear safety significance will be prescribed by documented instructions, drawings, and procedures as appropriatie and shall be accomplished in accordance with these instructions, procedures and drawings. These instructions will be sufficiently.

2-13 Revision 3.

g

' detailed and explicit so that _ any supervisor, inspector, or auditor can, .by observation, determine whether or not activities are being satisfactorily accomplished and documented. These documents shall include the qualitative and quantitative acceptance criteria necessary to assure satisf actory completion of the test procedure. Those acceptance criteria shall, where appropriate, require post installation testing prior to returning the component or system to service.

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

2.6 Document Control Administrative control procedures shall be established by the Columbus General Office (G.O.) and Cooper Nuclear Station (CNS) to control the identification, indexing, filing, retention, retrieval, and distribution of

quality-related records and documents. Control procedures shall be reviewed and approved by authorized personnel and are distributed to and used at.the site of the activity. These procedures shall also ensure that changes to quality-related records and documents receive the same level of review and approval as the original document.

1 l

The overall objectives of NPPD document control are to:

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

CNS.

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b) Establish' an index of _ quality-related records located . at the Columbus G.O. and at CNS so that personnel involved'in a safety-related activity. ,

can determine which documents are applicable to the activity and ' whether the documents at hand are of the latest revision.

c) Establish a filing system.

'd) Establish periods of' retention.

i 4

e) Establish measures to control distribution and revisions.

The G.O. Records Manager, CNS station management, and the Quality i

Assurance Division will jointly establish lines . of specific responsibility, j interfaces, and document control procedures.

f Specific to the ANSI Standard related to this criterion, the following i

j commitment applies:

i

1. ANSI N45.2.9-1974 " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," and its i

1 associated Regulatory Guide 1.88 shall be applicable to the CNS Operational

)

QA Program, with the following exception / clarification:

i i

! (a) For those design, manufacturing, construction, and operating -

records generated prior to implementation of this standard, it is not our intent l

{ to backfit the detailed requirements of this standard to those records. All such j records, however, have been initially designated for lifetime storage, until j specific review dictates otherwise, and will be stored in the record storage 2-15 . Revision 3- ,

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-facility. Appropriate-record indexes and filing system shall be established to e

! permit reasonable identification and retrieval. ~The records will be stored and f preserved per the requirements of Section"6.0 of this standard.

+

2.7 Control of Purchased Material, Equipment,'and Services 3

NPPD receiving inspection instructions provide for determining that all purchased ' materials , equipment, and services purchased directly or through a contractor, supplier, or subcontractor meet' the requirements specified on the original' procurement specifications, such as code, standards, specifications, special acceptance te' sting, material identification, etc. The completed receipt

inspection report will become part of the purchase order package. Procurement 2

documents shall be available at the receiving area to identify the receiving inspections required.

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

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

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2-16 Revision 3 8' '9e .

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

i r

4 Items in segregated. areas will not be issued, by the Warehouse, without l the written permission of the Division Manager of Nuclear Operations or designee 1

and only then after proper arrangements have been made to assure that necessary.

I steps will be taken to bring all aspects of the particular item into conformance 6

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1 with normal requirements prior to the system containing components in " Hold" status being returned to service.

1 Suppliers of essential equipment shall be required to provide certified.

1L j documentary evidence that the material supplied conforms to the purchase document 4

requirements such as material test report, code required test and inspection,'

i i documentation, etc. A complete set of documentation required by.the procurement i

i document for all essential materials, equipment, and services will be filed at i

J Cooper Nuclear Station.

i j-2.8 Identification and Control of Parts, Materials, and Components

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To the maximum extent practicable, activities . carried out during operation of the Cooper Nuclear Station will comply. with the requirements for t

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

l~ the as-built drawings and specifications for the station. Where special measures i

are required to assure proper identification of materials, parts, and components, i such requirements will be incorporated directly into the procurement documents j for such parts and assemblies. Such . identifications which may include heat j-2-17 Revision 3

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4 numbers, - serial numbers, or other means of identification of the item will . be

- incorporated into the procurement documents to provide means of traceability.

' Material received at the station (which has not been properly identified) will be i .

f. segregated and tagged 'to indicate a " Hold" status.- Except as indicated in

Section 2.7 above, such parts will' not be issued or used prior to final CNS procedures will' incorporate requirements necessary to assure l acceptance.

f that the identification measures are properly carried out at.the station, that

) unacceptab'le items will not be used in essential systems, and that the components ,

i- to be used in essential systems receive independent verification of component l identity prior to installation.

1 1

] 2.9, Control of Special Processes i

General maintenance procedures will provide for performance of any special processes by qualified personnel using qualified and approved procedures.

) Control procedures provide for QA review -inspection and documentation of i

activities, and for proper integration of QA/QC Inspection as necessary. In most cases, the procedures will.only be prepared in specific detail when it becomes

) necessary to apply a specific process in the maintenance, repair, or modification i

of some portion of the essential equipment for the' station. These procedures l shall also require that special processes, such as welding and heat. treating, are 4 .

j controlled and completed by qualified personnel in accordance with qualified .

l

} procedures, codes, and standards.

1 4

i Maintenance modification control methods and Station Operating-

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j procedures are reviewed by CNS QA personnel and such review includes verification i

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that .necessary codes standards, quality requirements, and acceptance criteria are incorporated to control special processes within the limits necessary for l-

- satisfactory' accomplishment of design objectives.

i-

} 2.10 Inspection j

Inspection of activities affecting quality (Quality Control) has been i

, assigned in this policy document to the organization basically responsible ~ for I

i '

i the performance of the activity. However, personnel . assigned to inspection activities will be persons other than those directly involved in .the actual l performance of ,the work in accordance with ANSI N45.2. - Quality Assurance Audits e and Surveillance of activities such as maintenance, repair, and modifications j will include direct observation; whereas operating functions will'be monitored'

) indirectly by observation and examination of individual operating personnel and '

i documentation at intervals consistent with importance of the activity. In many i

of these activities there will be specific hold points designated for which 1

{ independent inspections are to be performed prior'to proceeding to the next step of the work. All inspection and hold points will be incorporated directly into 1

the work procedures. Special inspections, such as those requiring qualification 1

j of performers to ASNT-TC-1A will be contracted to approved suppliers. Where

!- appropriate, inspections following work activities shall include tests of the i . .

! component or system.

i i l'

i Checklists shall be used during inspection activities to verify.that-i instructions, procedures, and drawings have been adhered to. The results of these inspections will be placed in permanent record storage. If direct i

j. inspection is impossible, indirect control methods will be specified in the i

j. instructions'to;provideamethodofmonitoringprocessmethodsandequipment.

l 2- 19 Revision 3 j . e . ~.

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l Quality Control activities are considered to be inspection activities and are an integral part of the management functions which govern the activities of any given organization. Controlling documents pertaining to quality-related activities receive QA review to ensure incorporation of quality requirements, including periodic audits, and additionally, that individuals performing quality control activities are other than those actually performing the work. -

' Specific to the ANSI Standard related to this criterion, the following

~

commitment applies:

1. ANSI N45.2.6-1978 " Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants," and its associated Regulatory Guide 1.58 is applicable to the CNS Operational QA Program, with the following '

exceptions / clarifications:

(a) It has always been the belief of NPPD that, ' in order to be effective, Quality Control must be built into the operation of-the plant. With this in mind, Quality Control and test functions performed at CNS are incorporated directly into the station procedures. Inspection points are then witnessed and signed off by members of the operating staff not directly involved

~ n in the activity being inspected. Selection of QC candidates for certification is a function of Station Management. Actual certification of QC inspectors is the responsibility of the QA Division.

(b) CNS does not have the in-house capability to perform nondestructive examinations in accordance with SNT-TC-1A. These services are l

2-20 Revision 3 w-

currently contracted to an approved vendor. Any required nondestructive .

examinations will be performed by personnel who are qualified and certified per SNT-TC-1A.

2.11 Test Control Each type of test program carried out by the station operating group l will be defined by written procedures and instructions. These test programs

! include the preoperational tests, start-up test instructions, operational testing and surveillance testing of structures, systems, and components to demonstrate their capability to perform satisfactorily as a part of.an integrated system.

Acceptance tests will be developed for structures, systems, and components to demonstrate their capability to perform satisfactorily following repairs or modification prior to returning to service. Test procedures will identify the i

inspector, test performer, and data recorder. Each type of acceptance test has 1

individual test procedures which include Quality Control provisions, acceptance criteria, and check points for observation or checking of important aspects, such j as prerequisite conditions for tests or results. These . test procedure prerequisites will include the test instrumentation requirements, environmental i conditions, and performance by appropriately trained personnel. All Special Test i

Procedures, Special Maintenance Procedures, and Station Operating Proc,edures are routinely reviewed by SORC, of which QA is a member.

I Quality Assurance Audit and Surveillance activities will be carried out i by the station Quality Assurance Staff members to assure that tests are being performed in accordance with the requirements of the procedures and that results  ;

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i are evaluated and compared to the limits prescribed for acceptance criteria. In addition, test procedures shall specify test requirements and quantitative and qualitative acceptance criteria where appropriate.-

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

Each installed plant instrument performing an essential function has been identified and placed on a regularly-scheduled program of inspection, test, 1

and recalibration. All test and measuring equipment utilized in calibration of the above equipment will be appropriately tagged. Documented calibration records will be reviewed, as required, to evaluate calibration performance and frequency, ,

and changes made as may be necessary.

A Quality Assurance Plan will prescribe the QA functions to be carried out relative to the calibration program. Quality Control and Quality Assurance practices require independent checks on the calibration activities and will be i verified by Quality Assurance Surveillances performed by the QA Staff members to assure that procedures are being properly carried out, that adequate records of  :

calibration and testing of neasuring equipment are being generated, maintained, and that regularly scheduled adjustments are made to maintain necessary accuracy.

For equipment used to calibrate process equipment, procedures will define action to be taken should regularly-scheduled calibration checks reveal an out of l

2-22 Revision 3

specification condition exists. When inspection, measuring, and test equipment are found to be out of calibration, an evaluation shall be made,'and documented, of the validity of previous inspection or test results and of the acceptability of items previously inspected or tested. Should the evaluation determine that previous inspection or test results obtained with the affected instrument are unacceptable, a Nonconformance Report (NCR) will be issued. Reference ' and transfer standards, traceable to the National Bureau of Standards for the calibration of applicable instrument at the CNS, will be maintained at CNS.

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

2.13 Handling, Storage, and Shipping The procedures for procurement and control of essential spare parts, materials, replacement parts, and equipment will include the necessary requirements to control handling, cleaning, shipping, receiving, aad storage of essential parts and material. The Quality Assurance Plans 'and Instructions include provisions for inspection and audit activities to assure that these j

procedures are followed and that essential parts and materials maintained at the station are received, inspected, stored, and controlled in such a manner as to prevent degradation. Warehouse personnel shall have the respo'nsibility for carrying out all the requirements specified by the approved station procedures'to assure that specific quality requirements are met.

2-23 Revision.3

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

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

i (a) Our program is structured to identify safety-related equipment and provide for designation of packaging, shipping, receiving, storage, and handling requirements for purchased parts and materials. The classifications of this standard cannot be applied directly to individual spare parts or subassemblies of the parent equipment. Due to difference in volume, complexity, inspectability, etc., the packaging, shipping, handling, and storage requirements of s;.are parts and subassemblies will necessarily be different from the requirements which may be imposed on the entire component or piece of parent equipment.

(b) The majority of items purchased for an operating plant consist of components, subassemblies, and individual spare parts which could be used in a multitude of different applications. Such items are purchased to the highest requirement of intended use. The volume and characteristics of purchases during the operational phase differ significantly from those purchases made during the design and construction phase, and storage facilities are considerably different.

Items that require special measures of storage protection will be identified as a part of the purchasing documents. Items that must be stored outdoors (equivalent of Level D) or items that must be stored in covered but unheated conditions (equivalent of Level C) will be evaluated on an individual case basis. However, 2-24 Revision 3

b,

~

it is not considered practicable to preclassify individual parts by levels as required by Section 2.7_of this standard. Shipping and packaging requirements for such items will likewise be handled in the purchase order documents, . as appropriate.

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

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

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

Tagging procedures, where necessary, will require that equipment be tagged and that the associated power supplies, starters, switches and controls on the main control panel be tagged as well to warn against operation. In some cases, power supplies will be disconnected and tagged to prevent inadvertent operation. Tagging will be controlled by the, Shif t Supervisor by requiring that 2-25 Revision 3 e,ee=& we

a 0-serially-numbered tags, obtained from the Control Room, be used for all tagging pearposes. Records will be maintained in the Control Room to enable operators and Shif t Supervisors to determine the status of .the equipment tagged. ,

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

e

i i

l Requirements for tagging are included in the applicable pr'ocedures, and j 4

] status tagging will.be one of the aspects of the work that will be verified by I

] audit and surveillance.

j I

i t

2.15 Nonconformina Materials, parts, or Components '

i I

f Procedures for control of the warehouse and for control of maintenance l

activities provide for identification and tagging of materials, parts, or i-components which do not conform to requirements (See Section 2.8).

i i

1 The Nonconformance Reporting Program shall . be used by all persons l

performing operation, maintenance, and Quality Control functions to record and t

report i

a) Deviations from approved procedures; i

s

review and approval.

i i

j Approved Procedures will be utilized for repair and rework of essential

parts and equipment. All such rework will be thoroughly documented, including Quality Control and Quality Assurance Surveillance activities, to assure 1

1 conformance with the requirements of the specifications, procedures, and other j

controlling documents.

i j

1 Any item of essential equipment which is classified as scrap will be I

identified and segregated in such a manner to prevent inadvertent use or i

installation in an essential system. i i

J The G.O. QA Department will compile an essential nonconformance report I quarterly to enable the Vice-President - Nuclear to establish adverse trends and 1 1

l Implement the appropriate corrective action.

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.j 2-28 Revision 3 NWOs1

f e-2.16 Corrective Action l

I

( NRC Regulations which require formal reporting to the'NRC of failures.

l malfunctions, deficiencies, unusual operating experiences, and deviations which

! may have a significant ef fect on quality or safety will be reviewed and evaluated i

by the Station Operations Review Committee and, where appropriate, by the Safety i Review and Audit Board. It will be thel responsibility of the Nuclear Group  ;

l

, personnel to identify and promptly correct all such deficiencies or malfunctions '

either.by improved maintenance, repairs.. replacements, or modification. In any  ;

case the objective and the corrective action will not only be to correct the existing defect or deficiency, but also to include measures to determine cause and prevent repetition of similar failures elsewhere in the station. Quality Assurance activities will verify that corrective action is performed in accordance with approved written procedures and that -the details of the corrective action are properly documented for the ' permanent station records.

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

Vice-President - Nuclear l

l SRAB Administrator

, 1 Division Manager - Nuclear Operations Division Hanager - Engineering and Construction Division Manager - Quality Assurance 2-29 Revision 3 I

__..__.._______.____.m_.___.____.____a _____.___._________________u_m._.m.

Division Manager - Nuclear Support G.O.' Quality Assurance Supervisor CNS Regulatory Compliance Specialist CNS Department Managers 2.17 Quality Assurance Records All activities having a significant effect on quality and safety will be thoroughly documented, and all such documentation will be inco.rporated into the record storage system. Procedures will require appropriate physical storage and personnel to maintain these files. Record identification. storage, retrieval, access, control, retention, and safeguarding of all such station records will be with approved procedures. Records to be maintained will consist of all records accumulated during engineering and construction plus the records generated during station operation and maintenance as defined in the CNS Technical Specifications. These records shall also include qualification of personnel and status of equipment and procedures. Inspection and test records shall identify the inspector, data taker, method of observation, results',

acceptance, and all nonconformance reports used to document nonconformances.

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

2-30 Revision 3

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

l The program will include Audits of record storage facilities to assure l that the procedures and controls are properly implemented. The G.O. Records Manager and CNS station management will prepare detailed procedures for incorporating material into the files and for making decisions on removal and disposal of outdated or superseded material from the files. Refer to Section 2.6

" Document Control" for the commitment to ANSI N45.2.9.

2.18 Audits .

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

I Audits performed under this direction (working with the Safety Review and Audit Board (SRAB) as referenced in Section 3.4) will be conducted according to the QA Plans to verify compliance with the Quality Assurance Program. Audits shall be performed in accordance with written instructions or checklists and conducted by trained personnel not responsible for areas being audited. In addition, other l members of the NPPD Executive Hansgement staff may audit or request audits of specific activities of particular concern to them. However, all such internal audits will necessarily be coordinated in such a way as to avoid unnecessary 2-31 Revision 3

I interference with the operating activities at the station. The provisions of ANSI N45.2.12 shall be applied to supplier audit programs. It is expected that some unannounced audits will be conducted, particularly with regard to those i

operating activities such as emergency procedures and operator _ qualifications. i Upon completion of the audit, a formal report will be prepared and transmitted to the organization audited which will include an evaluation statement regarding the program's effectiveness. All nonconformances identified as a result of these audits will be documented and appropriate follow-up action will be taken to assure that corrective action has been implemented. Follow-up action, including i

reaudits of any identified nonconformance area and verification of corrective action, shall be fully documented.

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

l l

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

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

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

l 2-32 Revision 3 t

i

o

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

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

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

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

. (2) Work instruction will be reviewed by Quality Control to assure i that adequate cleaning and access ccntrols are incorporated into work instruction and associated safety-related activities.

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

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

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

2-33 Revision 3 i

e

4 (6) Randon QA Audit and Surveillance of safety-related maintenance or

! modification activities requires verification of part, component, and system cleanness.

(a) For cleanness classifications where .the scope of plant modification work is such'as to make application of the guidance provided by.this standard practicable, the cleanness c1hssifications and requirements thereof i

shall be evaluated and applied,'as appropriate, as a part of the overall work i requirements.

I

} (b) For most modification or maintenance work, however, involving only

! small portions or individual components of larger systems, it is not considered d

{ practicable to conduct cleanness tests with ASTM E11-70 Series. Appropriate i

cleanness will be maintained during the work and preoperational flushing will be 4

l conducted, consistent with the scope of the work performed and the original i

design requirements. Flushing is an additional precaution to ensure system ,

l j cleanness. Controlling the parts and components and the work area has provided

) CNS with reasonable levels of assurance that system cleanness will be maintained, i-

] In addition to the above, the Water Chemistry Department routinely samplee and 4

tests for system cleanliness, corrosion, crud buildup, etc.

1 0 l 1 .

i 1. ANSI N45.2.3-1973 " Housekeeping During the Construction Phase of

, Nuclear Power Plants," and its associated Regulatory Guide 1.39, is applicable to t

j the CNS Operational QA Program, with the following exceptions / clarifications:

l (a) The plant has been div,ided in zones for fire protection and

) security purposes. The zone designated for cleanness in the ANSI Standard are i

l primarily ~ intended for control or work during construction of the plant.

i i 2-34 Revision 3 1

l l

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

• t '(b) Fire protection and prevention will be provided in accordance with 4 NPPD evaluation of the CNS fire protection system as required by NRC regulations.

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

2-35 Revision 3.

3.0 ORGANIZATION AND RESPONSIBILITIES

i. '

Nebraska'Public Power District is solely responsible for the operation -

of'the' Cooper Nuclear Station and will fulfill the objectives set forth-in the Quality. Assurance Program for Operation through its own organization and by -

contact with qualified contractors and consultants.-

i 3.1 General i

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

J Table 2 defines the three levels of-QA as they are to be carried out

! for station operation and also shows the coniparison with similar principles which shall apply to nuclear fuel procurement and any future major engineering and I

construction activities for the Cooper Nuclear Station.

i

! The Cooper Nuclear ' Station organization is presented in Figure 2, 1 ,

I showing the relationship of the Cooper Nuclear Station organization to other

• j .

j- support functions. This chart also shows the relationship of the Quality J

i. Assurance functions to other functions in the department and identifies the three I~ levels of Quality Assurance activities. It is intended that clearly separate lines of responsibility be maintained between those responsible for operating the 1

nuclear station and those responsible for auditing to verify that all quality and licensing requirements are consistently being met, i

I 4

3-1 Revision 3 '

I

% 4

'QA responsibilities within each QA lesel will vary depending upon the -

^

$ type of activity involved (See Section 4.1.3). Additional details on individual i

[- QA responsibilities are given in the paragraphs which follow . together : with -

i- -

i additional explanation of the interrelationships between the various supervisors and managers involved.

i 3.2 Nuclear Power Group Management J

3.2.1 Vice-President - Nuclear ,

t ,

~

The Vice-President - Nuclear is the responsible executive officer for-all CNS Quality Assurance-related activities. This responsibility includes the I

j Quality Assurance requirements governing those structures, systems, and i

components that prevent or mitigate the consequences of postulated accidents that l could cause undue risk to the health and safety of the public. Pertinent l activities include designing, purchasing, fabrication, handling, shipping; storing, cleaning, erecting, installing. -inspecting, testing, operating, 7

j maintaining, repairing, refueling, in-servie,e inspection and modifications that i'

are associated with Cooper Nuclear Station. The responsibility delegated to the l

!- Division Manager of Quality Assurance is the authority to define and implement i '

} the detailed requirenents of the Quality Assurance Program to assure that the '

! activities identified above meet all applicable controlling requirements. This j

authority includes the right to direct, enforce, and perform any actions required j to ensure the high standards of implementing a good Ouality Assurance Program.

The responsibility and authority over the Safety Review and Audit Board l

has been delegated to the Vice-President - Nuclear. The Vice-President - Nuclear

[ reserves the authority to conduct, or order the auditing or sionitoring of any-

! 4 l

i

) 3-2 Revision 3 i

l

. _ - . .. _ . . - .. - ..- _ __- m_._,.-_.____..-_.-..._ , _ - - . - - , _ _ . . - - _ . . , _ , . - . - - . . , . . _ . - __ . . ~ . . _ , . .

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s. -

o i

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, y -t operations activity,. at* any time. to ascertain the iffectiveness of the'overall

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QA Program and to determine that all aspects of the QA Program are'being complied

b. ,

with. j -

a -t F

h 3.2.2~ Division Manager, Quality Assurance

\

• e Divission Manager of Quality . Assurance, a member of theLexecutive

~

staff, reporting to the Vice-President - Nuclear, shall havq the responsibility {

' and authority for administrating and maintaining-a Quality Assurance Program for +

. . .)

Operation which is in. accordance with 10CFR33. Appendix B.

Inherent in this

+

responsibility is the authority to accept or reject any or all work, materials I or equipment associated with Cooper: Nuclear Station and Columbus;G.O. yThe ,

y .; -r ,;

~

Division Manager of Quality Assurance shall direct;! the preparation'of plans and instructions for defining the Qualitiy. hasurance functions associated with Cooper

<. . a Nuclear Station to ensure that such activities are conducted in'accordance with

. 'V ,,

the Operating License and appended Technical Specifications. He shall also

~

approve all plans and instructions for defining and auditing '

the safety-related '

e .

• y activities within the Cooper Nuclear Station and General Off:les.. The actual '*

audit functions to be performed are defined more completely [)y the body of j.

Quality Assurance Instructions and' Plans required by'Section 4.0 of this phlicy '

1 -

document. He shall also have direct responsibility;for eva,luating suppliers of-t f e

nuclear safety-related equipment, materials, and sparefparts and for auditing'the ,

QA/QC activities of such suppliers. y m l ) t i i[ f j, ,)

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f shall have the The Division Manager of Quality ' Assurance g, s and 3 tat (g necessary organizational freedom and access , within Columbt/s 'G.O. and Cooper 9( '

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_ - - - _ - . -- _ o N, --- = t.

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r Nuclear Station to institute the necessary Quality Assurance requirements, t

identify problems, and pursue prompt corrective action. Figure 1 outlines the

( QA Division functional organization.

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

NPPD Quality Assurance Staf f, under the direction of the Division Manager of Quality Assurance, shall have the responsibility and authority for implementation and ongoing development of the Quality Assurance Program for Operations which will meet the requirements of applicable federal regulations, codes, quality standards and other safety and environmental conditions that are required to assure safe and reliable nuclear power plant operations. In addition, it shall.be the responsibility of the Quality Assurance Division to _ _

monitor the interface between the Nuclear Operations and Nuclear Engineering and Construction Division to ensure that plant modification and repairs receive the proper design reviews and approvals.

' As shown in Table 2, he shall have responsibility for accomplishment of third level QA Audits and shall obtain assistance and special expertise when I

necessary to complete such audits effectively.

i ,/

\

3-4 Revision 3 i U'

._ _ _ . _ _ . ~ . _ _ . .. _ . _ . . ._ . . . . _ . . __ ._.

l

~

3.2.3 Quality Assurance Manager - CNS 1

The CNS Quality Assurance Manager, reporting administrative 1y to.the , P i

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

,I i

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

or coordinate QA Surveillance and Audit activities within Cooper Nuclear Station 1

l to determine if conformance wit!h NPPD Quality Assurance Manual and applicable t

federal regulations as defined in the NPPD QA Manual are being mainta'ined. The CNS QA Manager shall advise and' assist the Division' Manager,of Nuclear Operations in all matters which affect the quality of the station. Similarly, he shall 4

advise and assist all station personnel in matters regarding Quality Assurance "

and Quality Control. The - CNS QA Manager shall designate members . o( the CNS QA Staff upon request to provide 4. raining and instruction programs to enable CNS personnel to effectively execute the District QA Program. CNS QA Hanager is also t

4 responsible for tracking open audit items identified at-CNS to the station and 1 . .

interface with NRC during I&E inspections at CNS. In'additio'n, he shall also be responsible to verify that solutiors to safety-related problems have been

implemented and to perform scheduled audits.of those activities' listed in Section -

, 4.1.3 on an announced basis. Additional specific duties shall be defined in the~'

Quality Assurance Instru'etions and Plans issued in accordance with Section 4.0 of.

this Policy Document. The CNS QA Manager or . designee shall also serve as a 4

3-5 ~ Revision 3' t . ~

f.

non-voting member =of the Station Operating Review Committee (SORC). In addition, the administrative functions associated with the CNS QA Staff are under the direction of the CNS QA Manager. .

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

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

During absence of the CNS QA Manager, one of the CNS QA Supervisors -

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

3.2.4 Quality Assurance Supervisor - G.O.

The General Office Quality Assurance Supervisor, reporting administrative 1y to the Division Manager of . Quality Assurance, shall have the 3-6 Revision 3

, - - - , ,y

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

The General Office Quality Assurance Supervisor shall have the responsibility and authority for the controlling, administrating, distributing, and coordinating changes and additions to the Quality Assurance Program for  ;

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

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

The G.O. QA Supervisor shall establish a program in the G.O. for QA review of the design / engineering function. This will include configuration manag',ent.

3-7 Revision 3

v Additional specific duties shall be defined-in.the Quality Assurance.

Instructions and Plans issued in accordance with Section 4.0 of this Policy Document.

2 The General Office Quality Assurance Supervisor is responsible for interface, along with the Division Manager of QA, with NRC I&E' inspections at the j i

General Office.

~

In addition, he shall also provide training and ' instruction ~

programs to enable General Office personnel to effectively execute the District Quality Assurance Program.

/

3.2.5 Quality Assdrance Supervisors - CNS 4

i

The CNS Quality Assurance Supervisors, reporting ~ administratively to i

I the CNS QA Manager, are responsible to assist in carrying out the duties assigned a <

to the CNS QA Manager. They are responsible to direct the performance of audits-and surveillances, and to identify any condition adverse to quality to the CNS QA Manager. The CNS QA Supervisors are responsible for - the continued maintenance and upgrading of QA Program Documents as they apply to the daily .

operation of the Department. '

3.2.6 Quality Assurance Staff

General Office Quality Assurance Staff f

, The General Office Quality Assurance Staff 'shall be responsible to 4

assist and advise the General Office Quality Assurance Supervisor in all matters which could affect the Quality Assurance activities within the General Office.

3-8 Revision 3

. m., - _ . , ,.:,_,., , _ , , , .,_,,._4_ . _ . . . _ _ , , _ , . . . _ . . _ _ ., . . . .-,..-..D

, . -= _.

O This includes advising and assisting General Of fice personnel -in all matters regarding Quality Assurance, verify that solutions to safety-related problems s _ _

have been implemented, and perform audits and surveillances of work activities within the General Office on an announced or unannounced basis.

The G.O. QA Supervisor has designated a _ G.O. Staf f member the -

responsibility for the ongoing development and implementation of the supplier evaluation' program. This includes the review of procurement specifications and associated drawings to determine if special requirements such as codes, standards, materials, tools, and inspections, e t c .' , are included with safety-related systems or equipment requisitions generated by Nuclear Engineering and Construction or Nuclear Support.

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

of work activities within CNS on an announced or unannounced basis. Additional  !

specific duties shall be as defined in the Quality Assurance Plans and Instructions issued in accordance with Section 4.0 of this policy document.

I Disagreements or differences of opinion on Quality Assurance matters i are expected to be documented and resolved jointly by either the CNS or General Office Quality Assurance Staff and appropriate CNS or General Office supervisory  ;

3-9 Revision 3 N- ,

~a 4

personnel. Where such resolution is not achieved within a reasonable period of time, unresolved dif ferences shall be promptly reported to the appropriate Quality Assurance Manager for resolution' jointly with the Division Manager of Quality Assurance and the other respective Division Manager.

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

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

3-10 Revision 3

-~q ,- g- - m , ,

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.(

Nuclear Fuel Manager ,

'For those aspects of Fuel Management QA covered by the QA Program, the Nuclear Fuel Manager, under the- direction of the Division Manager of Nuclear-

~

Engineering and Construction, shall be responsible to furnish technical 4

assistance as required to the Division Manager - Nuclear Operation and the'-

QA Staff. Such reviews shall not replace or supersede the formal audits..

3 3.2.8 Division Manager - Nuclear Operations The. Division Manager of Nuclear-Operations, under.the direction of the-Vice-President - Nuclear, shall be responsible and have the authority for assuring that Quality Assurance activities, as defined by this and other approved QA Program Documents are complied with. Some of these responsibilities are delegated to CNS management personnel and include Quality Control and Inspection functions as defined in Table 2. The actual functions to be performed shall be i

} defined in the QAP's. .

i

{ The Division Manager of Nuclear Operations shall regularly review station activities for the purpose of keeping abreast of significant quality activities.

l l

3.2.9 Division Manager - Nuclear Support l

1, -1 The Division Manager of Nuclear Support, under the direction of 'the Vice-President - Nuclear, shall be responsible and have the authority for.

1 1 l

3-11 ' Revision 3 r--. , , , - - - - , , - - - - - -

e - - - - - , - . ,, , , , , - - - ,,..o - , ,

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

3.2.10 G.O. Department Managers C.O. Departmental Managers report to either the Division Manager -

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

3.2.11 CNS Department Managers CNS departmental managers' report to the Division Manager - Nuclear Operations as described in the CNS USAR and are responsible for implementation of QA Program objectives within their area of responsibility. '

3.3 Cooper Nuclear Station Personnel The operational duties and responsibilities of the Cooper Nuclear .

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

Station personnel, under the direction of the Division Manager - Nuclear Operation, are charged with the responsibility for assuring that the station is tested, operated, and maintained in accordance with approved plans and procedures, and such responsibilities include Quality Control functions.

3-12 Revision 3 5

3.4 G.O. Personnel The duties and responsibilities of G.O. personnel are described herein and in the appropriate implementing documents. These documents address the G.O.

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

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

Specific duties and responsibilities of SRAB, including auditing, are l 1

j identified in Reference 7.15, CNS Radiological Technical Specifications, and in i

. the SRAB Instructions and Guidelines..

i 3.6 Station Operations Review Committee The Station Operations Review Committee (SORC) has been established to advise the Division Manager - Nuclear Operation in all matters regarding operational safety.

4 3-13 ,

Revision 3 e

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

4 Specific duties and responsibilities of SORC are identified in

't Reference 7.15, CNS Radiological Technical Specifications.

3.7 Outside Suppliers, Contractors, Subcontractors, and Consultants During the life of Cooper Nuclear Station, it will be occasionally-necessary to obtain assistance from outside suppliers and contractors. 'At all times, these outside suppliers, contractors, and consultants will work under the direction of the NPPD organization having primary responsibility for the particular work being performed. In those instances in which outside suppliers or contractors merely' furnish personnel to augment the normal station staff for particular activities, such outside contractor personnel shall be required to perform their work in accordance with the CNS Quality Assurance Documents and other appropriate CNS procedures and instructions. In those instances in which outside suppliers, contractors, and subcontractors are assigned primary responsibility for a particular activity, such outside contractor shall be required to demonstrate that it has a Quality Assurance and, Quality Control Program and organization appropriate to the work to be performed. Selection of outside suppliers or contractors shall require the active participation of the Quality Assurance Department in evaluating and approving their Quality Assurance Program and reviewing the procurement documents prior to awarding the contract.

In every instance in which outside contractors have responsibility for work on safety-related nuclear systems, they shall be contractually required to work to procedures previously approved by the NPPD organization having primary responsibility for the particular work being performed. In addition, they shall ,

be contractually required to prepare, prior to performing the work, QA/QC Procedures specific to the work to be performed for the Cooper Nuclear 3-14 Revision 3 t

i s

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

If any portion of work on safety-related nuclear systems is to be

. subcontracted, the prime contractor shall impose QA requirements on the subcontractor consistent with this program.

Additionally the NPPD QA organization shall have direct access to and communication with the contractor's personnel at all levels, both at their home office and in the field.

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

As necessary to execute this QA Program, the District may obtain the services of a qualified consultant. When non-NPPD support is obtained, total' responsibility for effectiveness of support organizations activities will remain with NPPD.

3-15 Revision 3

4.0. QUALITY ASSURANCE DOCUMEh'IS I

l .

In conformance with 10CFR50 Appendix B, Criterion II, written policies. l

'l plans, and instructions shall be prepared to define the Quality Assurance Program- .i to be carried out over the operating life of the station. ,)

4.1 .NPPD Internal Documents 9

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

The work procedures are kept separate from the QA Plans and 1

Instructions in engineering, manufacturing, and construction, and it is-intended

]

that they be kept separate for operations activities. However, mandatory QA/QC checkpoints 'shall be incorporated directly into, or 'by attachment to the work procedures to facilitate coordination between the work and its Quality.

Control.

r Work procedures shall be reviewed by Quality Assurance for proper implementation of this Quality Assurance Program for Operation and for compliance with the criteria of 10CFR50, Appendix B.

4-1 Revision 3

1 6

[ :D t.

Quality Assurance Plans and Instructions shall be developed - in accordance with written guidelines. The format and-content shall be as specified

'by the Division Manager of Quality Assurance and shall.be documente'd by a Quality Assurance Instruction. -Significant changes shall be reviewed and approved via '

the same' channels as for the original document. Each such change, when approved 4

and issued, shall be accompanied by a Transmittal Notice. ,

1 i

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

4.1.1 Quality Control Inspection The Quality Control Inspection function must be performed _ by an individual other than those which are 'actually performing the work being controlled or inspected. The Cooper Nuclear Station management, as part of'their j normal managsment function, are responsible for preparation of . the Quality Control requirements-of this inspection program; however, the CNS QA Manager is responsible to review and accept control methods prior to implementation.

The CNS Quality Assurance Manager, working with the' CNS station management, shall verify that Quality Control Check Points have been incorporated directly into, or by attachments to, the work procedures which shall constitute ,

i the stations QC functions and shall periodically inspect work performance to assure that the procedures' containing Quality Control activities are being 4-2 Revision 3

!' ~

O

's followed. The QC checkpoints shall identify the specific work which is to be subjected to inspection or verification and shall provide in detail the elements of work to be inspected which include:

1. Identity of the inspector or data recorder.

2. Type of inspection or observation.

3. Results (data to be recorded).

~

4. Acceptance (qualitative or quantitative) criteria.

5. Method of disposition of nonconformance.

6. Reporting requirements.

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

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

l l

Routine maintenance and repair of essential systems and components l

generally requires performance of a complete or partial Surveillance Procedure 4 Revision 3 j

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

4.1.2 Quality Assurance Instructions (OAI)

In order to comply with 10CFR50, Appendix B, and this policy document, the Quality Assurance Staff shall prepare additional QAI's which shall be approved by the Division Manager of Quality Assurance.

Each QAI shall clearly identify the purpose, conditions, problem, or I

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

When approved QAI's shall become a part of the CNS Quality Assurance ll Program for Operation.

4.1.3 Quality Assurance Plans (QAP) l Concurrent with the preparation of work procedures, and during operations or maintenanc'e activities, Quality Assurance Staff shall develop additional QAP's as needed. These QA Plans will outline specffic Quality Assurance activities and shall become a part of the CNS Quality Assurance Program for Operation. Distribution of these. Plans will be to those individuals who are 4-4 Revision 3

_ _ _ - , , w

Q responsible for that particular activity., As a general guideline in defining the .

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

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

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

- Division Manager - Nuclear Operations .

- Division Manager - Nuclear Engineering and Construction

- Division Manager - Nuclear Support

~

The QAP's shall define the specific work whicp-is to be subjected to Quality Assurance review, surveillance, and audit, and the manner in which such '

~

review, surveillance, and audit is to be carried out.

Checklists shall be prepared af ter reviewing the work procedures describing the QA Surveillance or QA Audit guidelines. l 4-5 Revision 3

w

< Q.

a) Quality Assurance Surveillance The Quality Assurance Surveillance function is intended to provide an-in

. independent check, on a continuing basis, that work is being performed The Quality accordance with t.he requirements of the controlling documents.

~

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

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

This philosophy shall be taken into account in developing the checklists for Quality Assurance Surveillance activities to be carried out under each QAP. QA Surveillance shall be as prescribed in appropriate QAP's and QAI's.

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

minimum impact on the progress of the work.

4-6 . Revision 3

o r -o b) Quality Assurance Audits As required by 10CFR50, Appendix B,'a comprehensive sys' tem of planned and periodic audits shall be carried out to verify compliance with all aspects of-the Quality Assurance Program and to determine the effectiveness of the progr,,m. a The audits shall be performed in accordance with written procedures or checklists J

by appropriately trained personnel not having direct responsibilities for the work being audited. The General Office Quality Assurance Supervisor and CNS f

i Quality Assurance Manager shall have the responsibility and authority for i

l planning and executing Quality Assurance Audits identified b; approved QAP's. ,

However, the SRAB, or any manager or executive in the chain of organization above ,

, the Division Manager - Nuclear Operations, or above the Quality Assurance Supervisors and Managers may initiate and carry out special Quality Assurance i.

j Audits within the guidelines provided by'this Quality Assurance Program.. Audit .

I results shall be reported in writing to the Division Manager of Quality Assurance l and the results shall be reviewed with the Management responsible for the area of i

j activity audited. Appropriate follow-up action shall be taken and documented as 1

i directed by the appropriate Quality Assurance Manager or Supervisor.

r i

i l Internal instructions include descriptions and timing "of types of i

. l audits to be performed; guidelines for performing audits, ' procedures for initiating an audit, and guidelines for preparing audit. reports.

Each QAP will be implemented through the use of the appropriate 4

checklist. On the basis that some Quality Assurance Audits are to be conducted j or directed by management, it is essential to maintain a high degree of 1

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4-7 Revision 3

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4.

flexibility in the manner of conducting an audit. It is intended _that the QAP's provide audit gt;idelines to assure that areas to be audited are 'sufficiently defined in advance and that audit personnel are adequately prepared to make a-meaningful audit with a minimum of interference with the progress of the work.

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

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5.0 : METHOD OF IMPLFMENTATION t

The CNS QA Program for Plant Operations will utilize the guidance provided by NRC publications WASH-1283 (5-24-74), WASH-1284 (10-26-73), and WASH-1309 (5-10-74) (" rainbow" series) except as ' noted ' in the " Specific f':

! Exceptions" of this section.

A

'The existing operational QA Program does . not address all of the.

I detailed requirements set forth in the " rainbow books." A detailed review has i been made to determine where the CNS QA Program differs from the ANSI Standards i

cited in the " rainbow' books."

i i With respect to the applicability of the " rainbow books" and the 1

associated standards, it is impracticable to apply all of the requirements set-4

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

)

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

It is also impracticable to apply requirements to an operating plant which were intended solely for the design. and construction phase. In the event that construction activities are undertaken, the District will commit to compliance ,

with the applicable portions of the WASH Series ANSI Standards. It is NPPD's intent to apply quality standards to maintenance, repair, and sodification 4 -

activities which will provide results which are equal to or better than the i

4 original construction.

1 i.

~

The detailed methods of implementation of this Three Level Quality a

Assurance Program for Operation shall be as provided for in the body of QAI's and i

) QAP's prepared in accordance with Section 4.0. l l

5-1 Revision 3 J .

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[ .The ' Quality Assurance Managers and Supervisors or designees shall

. review and' comment on the NPG procedures to ascertain that necessary quality I

i requirements are included. Procedure changes will be incorporated as necessary to correct identified control deficiencies or needs. Differences of opinion on- -I QA cosmients shall be resolved as indicated in Section 3.2.3. '

i After review of the various NPG procedures and manuals, the Qu'ality Assurance Manager or Supervisor shall review the appropriate QAI's and QAP's for the purpose of assuring that the overall QA Program objectives continue to be

) accomplished in each segment of the work to which this QA Program applies.

i i .

) . Quality Assurance activities shall be coordinated with the SRAB and i

2 with the SORC. QA activities shall be conducted in a manner and on a schedule - ,

1 r which will assure that the organization, supervision, communications, and f technical and administrative practices clearly evidence smooth, orderly,~

1

, controlled, and safe execution of all safety-related functions. i i ,

I j Written reports of - all QA activities, . including descriptions of l l

i deficiencies and resolution thereof, shall be incorporated into the official-1 +

{ QA file. Corrective action on ' deficiencies must include resolution of the

] specific deficiency and verification that corrective action has been implemented 1 to prevent occurrence of similar deficiencies in the future. A report of i

) ,

QA Audits performed (internal and external) shall be . submitted, to the I Vice-President - Nuclear by the Division Manager of Quality Assurance yearly.

! l i

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

{ CNS Quality Assurance Policies, Instructions, and Plans, showing how this i QA Program for Operation implements the NRC guidelines contained in 10CFR50, ,

i j Appendix B.

l 5-2 Revision 3 ,

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

. minimum, these procedures cover the following:

a) Records content and location; i

b) Principal location from which records are to be controlled; l

4 c) Complete records inventory and master index;

)

d) Conditions of storage, access, and security; e) System of records identification, retrieval, and control; f) System of records transfer and disposal.  ;

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

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6-1 Revision 3

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A, . .

7.0 REFERENCES

The' following documents were used in. the preparation of the Quality' -

4 Assurance Program for Operation of the Cooper Nuclear Station. It is intended that these documents be used on a continuing basis in the performance of Quality Assurance activities for station operation since they offer measurement criteria

against which the QA Program can be evaluated.

i 7.1 Quality Assurance Criteria for Nuclear Power Plants 10CFR50, Appendix B

~

(USNRC).

7.2 Standard of' Administrative Controls for Nuclear Power Plants, American j -

National-Standard ANSI 18.7 - 1972.

7.3 Updated Safety Analysis Report, Cooper Nuclear Station, Nebraska Public Power District (NRC Docket 50-298).

7.4 Environmental Report--Operating License Stage, Cooper Nuclear Station, 3

Nebraska Public Power District (NRC Docket 50-298).

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

l 7.6 Cooper Nuclear Station Procedures Manual.

7.7 Safety Rules, Nebraska Public Power District.

l

.l 7-1 Revision 3 1

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. s 7.8; Safety Guides for Water-Co$ led Nuclear. Power, Plants (USNRC), as-appropriate.

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

7.10 Requirements for Collection Storage, and Maintenance of Quality

. Assurance Records for Nuclear Power Plants ANSI N45.2.9 .1974.

7.11 Quality Assurance Terms and Definitions ANSI N45.2.10 - 1973.

7.12 Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.11 - 1974. .

7.13 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants ANSI N45.2.12 - 1977.

7.14 Supplementary Quality Assurance Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants ANSI N45.2.13 - 1976.

7.15 CNS Radiological Technical Specifications. '

7-2 Revision 3 l h

e Quality Assurance

Superv isor - G.O. Staff President and Vice-President

• Chief Executive - Nuclear Officer l

l 1

Administrative

~l Secretary II ,

I Division Hansger

---

Quality Assurance

, 1 Operations

• Quality Assurance Staff

• Supervisor Quality

- Assurance Haneger-Ch5 Secretary Audit and

• Steno. Procurement ,

~

Secretary - 0.A. Supervisor Staff FICURE 1

• Responsible for Q. A. Second Level Surveillances and Third Level Q.A. Audits.

- ---- Direct Communications 8-1 Revision 3o f ,,., u !& -

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i ' FICURE

. e ,

t Board af Directers l '

• f

• _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _. _ _ _ ____ _ _ q pr,suent & Cto l

1 g 'tice-President l

[ Nclear a I 3RAE j

' ' ' l i  ! , l l 8 1 1 , i i Division Manager Division Nnager Oivtsion Manager Division Manaaer Nuclear Supoort 1 kclear Engineering hetear Operations Quality Assurance ' '

' & Conseruccion

+ L I Sr . ' .**an ag e r __ --

Nuclear . Tech. Support. Pr

[ C35 .% Go @

. Serv. lco: gras,

! Manager Si.pe rvi sor Prsgram buclear l , ntrol ;;

i k 2 ' 2 Overvie w _ Confi:urationl .

! Manager Manager l l l l ' d Doerations .--- _

l e .:33 CA GO 4 l Manager Outate 2 & Modifi-Ik Staff L 2 '

Staff Nuclear l helear l Engtneering cations Training I saJiological Manager d

Manager 2 -l Ma nag e r 2

l Manager A

+

I Nuclea r p hclear Projects . Enaineering-Licensing _l & Construction - Maintenance Manager

& Safety Manager. _ Manager J

, 4 Manager. J J_

A I Pl an t Se rvic e s hetear Fuels ' _ Hanager _

Co rpo r a te - _ Manager l J l Security 2 Manag e r I J .

t j '

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buclear Support C uetear Engineerang _ C.uclear Operations e Proc a '

Division Staff a & Construction - l Coners! ,.

Dtvision Staff *- :l Division.Staf f * ' Statt i . e .

3 w __ 4 x

- Direct Line Responsibility 1. SRA5 Chairman

_ _ - Direct Coordination

2. SORC Chairman

, a F

1 3

3 l - Responsihte for First Level Program Implementation 2 - Responsiste for Se"cond Level Program Implementation .

i '

I - kesponsitte tor Third Level Program Iciplementation

__ _ _ _ _8 - Not Directly Responsible. for 4 Program implementation -

~

• Supervisors (not sitown) are also stesponsible for Second Level Program Implementation

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'M TABLE n, eJ l' ,

7 h.

x 1, e SYSTEMS AND MAJOR COMPONENTS ,

f(A b .

COVERED BY THE QUALITY ASSCRANCE PROGRAM s in i, ' .

k. -

[1 N

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).

I. NUCLEAR STEAM SU PLY SYSTEM .

's' .

, , ., e > i, u a .,

a A. Reactor Prieary Vessel ' ' ~' "

/ .

s w y .

, x

4

, , '4 ' s . .

B. Reactor Primary Vessel Supports  %

], ,

Jp ; js y . s ,. - y, f,,n C. >,'ontrol Rods and Drive System Equipment Necesaarv.;for'Ocram Operation- ,

, p' L:. I.. M D. Control Rod Drive P.ousing w.. y

,j v

% Q' g i

, E. Fuel Assemb'.ies ',

d' ~ >

v

.l E

• y' i F. Core'Shrov ,: a

) t

- e . u, G. Steam Dryer \ \ ' .(,. , . y 's \ i'/ '

o ss x )- ,

p

( '\ . 4,. 't -

1 Sfaam Separator H.  !;

K' ' ('- '

( w j}' - -

li yq m h b I ' (,'

II. REACT 0k COOLANT SYSTEMS .

( '.

i l(, C 1

(

i

, , .s . \ - l, ' ) /,

• i

. l .1' e A. . ADS ' '- Autemaxic ,De pressurizatihr. Systec, ' '!

i t ., y , anqp s

- ' e. ,7

< 1 4 7

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Y \y i : 1 B. "HPCI,+ liigh Pressure Coohnt II.<jectior. $ stem ' *

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s C. ' LPG- - Low Pressure Coolant In,'je'ct' ired.E. facem y <)

e ( ,

( r.. s *

, y w s D. CS / Core Spray Systed ' /. ' c j ., Y ' ,

s , , ji " , r D , s. p- " ,'

E. KCIC-ReactorCorel1:olatAonMooling l- y ,

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t s

.\ s,

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III. REACTOR 4)ROTECTION ' AfD ENGItiEERE') SAFEG"ARD SYSTEMS s s F :. l- I s ,

b- , b _ .!

i fv

, -c V ( , N '-

A. Reactor Protection System

, y- .

,, 's,,'

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t b B. Rod' Sequence Control System , , ,.i + \ ' q?;

, sy,c 41 - ,

7 i

q..

4 .

1 s -

s s t

t. s 1, i- n e .-

,o Standby Liquid Contro; C. 4 s

T i-

.Qq' x ,.

s-- ,s.; -

'D., Standby Gas ?ryatment ~,: - t y- q  !

w a

s E. Diesel Generacpra s  % y Vj

, y , z r r m--

,  : F, . kl.ectric'a1. Aux Rover

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> u ,\ q s

i t Ns *

,, jp ,.,, ', P '

1,' Cr h'. cal W o0 V Eoa.fpment.. i

'ey s .,. '

i. ~ " ' ' ],

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7 e w ,

>, s s

2. CriticM 480 V Equipment ,

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I c Table 1 (Cont'd.)

G. Neutron Monitoring Systems i- '

1. APRM

2. IRM

3. LPRM

4. RBM c \s

\ 5. SRM

6. TIP s

H. DC Power Supply I. Nuclear System Leak Detection J. Containment Isolation System K. Nuclear Boiler and Related Instrumentation L. Primary Containment M. Rod Position Indicator IV. NUCLEAR FUEL SYSTEMS A. Refueling Interlocks for Fuel Handling and Vessel Servicing Equipment B. Fuel Pool Liner and Gates C. Fuel Pool Cooling and Cleanup V. RADIOACTIVE WASTE DISPOSAL SYSTEMS A. Process Radiation Monitoring System

1. Off-Gas Vent Pipe Radiation Monitoring M ,

2. Off-Gas Monitoring

3. Aug Off-Gas Monitoring

4. Main Steam Line Monitoring 2

5. Reactor Building Vent Monitoring (GE)

6. Drywell and Suppression System Leak Rate

7. Liquid Process Radiation Monitoring

~

9-2 Revision 3 h

)

( ,e

t 1;

e i . .

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. Table 1 (Cont'd.) x4 VI. OTHER SUPPORT SYSTEMS '

J A. Reactor Equipment Cooling B. Service Water C. Emergency Bypass Function on Control Room Heating, Vent, and AC D. Reactor Recirculating (Pressure Retaining Parts Only)

E. ,

Class 1, 11, and III Code' Items i F. Reactor Feed Pumps (Pressure Retaining Parts Only)

G. Reactor Building H&V H. Fire Protec, tion I. Security VII. STRUCTURES (SEISMICS)

A. Reactor Building B. Control Building '

C. Elevated Release Point D. Intake Structure s

E. Diesel Generator Building ,

F. Radwaste Building (Below Grade)

• Note - 1. . This listing is not intended to be all' inclusive.

. j.

2. Application of. the QA Program (to these systems and components.

shall be consistent with the safety-related significan'ce' of the system or component. ',

v ,

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. , 1 9 l 9-3 i Revision 3 m

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e e r i er e

• _ 4 _ _ . _ _ _ _ _ . .

r* '

*r Table 2 i

THREE LEVEL QUALITY ASSURANCE PROGRAM i

EXPLANATION OF FIRST, SECOND, AND THIRD LEVEL QA RESPONSIBILITIES -

'/

a). FIRST LEVEL-Quality Control & c) THIRD LEVEL-Quality Assurance Audit Inspection.

Persons performing these audits are

'An individual other than the one generally not involved in the day-doing the work (not to include to-day Inspection or-Quality' immediate supervisor) will have Control.. functions. Audits and/or primary responsibility for Quality surveillances will'normally be Control. Personnel at this level- performed by or under the direction are charged with the responsibility of the appropriate QA Manager or

for direct inspection, witnessing, Supervisor. In addition, SRAB and sign-off, attesting that work shall be responsible for reviewing has.been performed in accordance the results of audits and follow-

, with the quality requirements of up audits as described in the controlling documents. Reference 15. The Quality ,l- i

, , Assurance Staff is also responsible b) SECOND LEVEL-Ouality Assurance for the evaluation of audit results Surveillance / Audit. and for verifying that' identified corrective action requirements have The Quality Assurance Managers, ' been implemented.

Supervisors, and Staff are Il responsible for second level surveillance / audit as appropriate for work involved. The ChS Quality Assurance Manager and G.O. QA Supervisor are responsible for assuring that controlling documents-for safety-related activities include -

appropriate quality requirements.

QA Staff is responsible for maintaining surveillance and audits of the work at CNS and the G.O. to l .

assure that Quality Control and inspection programs are being implemented and that quality l requirements are in fact being met.

I 9-4 , Revision 3

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