ML20206J081
| ML20206J081 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/04/1999 |
| From: | NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20206J078 | List: |
| References | |
| NUDOCS 9905120110 | |
| Download: ML20206J081 (101) | |
Text
NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION OUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT TABLE OF CONTENTS Corporate Policy Statement ............................. .vi 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 2.3 Design Control ............. ..... ......... ... 2-5 2.4 Procurement Document Control ........... .. . . . 2-10 i i
2.5 Instructions, Procedures & Drawings ............. .... 2-13 l l
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2.6 Document Control ....... . ... . ..... .... 2-14 l
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9905120110 ADOCK990504 05000298; 1 .
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TABLE OF CONTENTS (Cont'd) )
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2.7 Control of Purchased Material, Equipment, and Services ............................... .. 2-16 4
2.8 Identification and Control of Parts, Materials, I and Components ..... .................... .... 2-17 l 2.9 Control of Special Processes ...................,. . 2-18 i l
l 2.10 Inspection .......................... ....... 2-19 l 1
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2.11 Test Control ............. . . . . . . . . . . . . . . . . . . . 2 -20 l
I 2.12 Control of Measuring and Test Equipment . . . . . . . . . . . . . . . 2-21 2.13 Handling, Storage, and Shipping . . . . . . . . . . . . . . . . . . . . . 2-22 l
l 2.14 Inspection, Testing, and Operating Status ............... 2-24 I
2.15 . Nonconforming Materials, Parts, or Components .......... 2-25 l
2.16 Corrective Action ................ ............ 2-26 1
2.17 Quality Assurance Records ........................ 2-27 2.18 Audits ......... ..................... .... 2-28 2.19 Additional ANSI Standards ........... .. ......... 2-31 ii Revision 14 e
l' TABLE OF CONTENTS (Cont'd) 3.0 ORGANIZATION AND RESPONSIBILITIES ................. 3-1 l
l 3.1 General ...................................... 3-1 l
l 3.2 Nuclear Power Group Management .................... 3-2
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3.2.1 Senior,Vice President of Energy Supply . . . . . . . . . . . . 3-2 1
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3.2.2 Senior Manager of Quality ' Assurance ............. 3-2 l l
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i 3.2.3 Quality Assurance Operations Manager ........... 3-4 l l
l 3.2.4 Quality Assurance Assessment Manager ........... 3-6 3.2.5 Quality Assurance Supervisors ................. 3-7 l
3.2.6 Quality Assurance Staff ...................... 3-7 )
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l 3.2.7 Vice President of_ Nuclear Energy; . . . . . . . . , . . . . . . . 3-9 3.2.8 General Manager;of Technical Services . .............3-9 l 3.2.9 Plant Manager ... ....................... 3-10 l
3.2.10 Senior Manager;of Safety Assessment / Site. Support . . . . 3-10 3.2.11 Senio Manager of Engineering . . . . . . . . . . . . . . . . . 3-10 iii Revision 14
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F TABLE OF CONTENTS (Cont'd) 3.3 Cooper Nuclear Station Personnel .............. ..... 3-11 3.4 Safety Review and Audit Board (SRAB) ................ 3-11 3.5 Station Operations Review Committee (SORC) . . . . . . . . . . . . 3 3.6 Outside Suppliers, Contractors, Subcontractors, and Consultants . 3-19 4.0 QUALITY ASSURANCE DOCUMENTS .................... 4-1 4.1 NPPD Internal Documents . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.1.1 Quality Control Inspection .......... ......... 4-2 4.1.2 Nuclear Quality Procedures (NQP) . . . . . . . . . . . . . . . 4 -3 4.1.3 Quality Assurance Plans (QAP) ................. 4-4 5.0 METHOD OF IMPLEMENTATION ....................... 5-1 6.0 RECORDS RETENTION AND DISPOSITION ............ ... 6-1
7.0 REFERENCES
7-1 8.0 FIGURES ............................. .......... 8-1 iv Revision 14 l l
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TABLE OF CONTENTS (Cont'd) 8.1 Quality Assurance Organizational Chart (Figure 1) . . . . . . . . . 8-1 l .
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l l 9.0 TABLES ........................... .......... ... 9-1 l
l l 9.1 Systems and Components Within Scope of the CNS QA I
Program (Table 1) ...................... ........ 9-1 l
1 l 9.2 Three Level QA Program (Table 2) .................... 9-5 i
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CORPORATE POI. ICY STATEMENT This document establishes and describes the policies and practices of the Quality Assurance Program applicable to the operation of the Cooper Nuclear Station and the support activities of all NPPD Nuclear Divisions. The District's policy with respect to nuclear safety l and quality assurance is detailed in Section 1.2 of this document.
1 Each Nuclear Division is responsible for the development of policies and procedures which implement this Quality Assurance Program. Other divisions and departments at NPPD -
I may also have responsibilities under this program and shall comply as described in appropriate implementing procedures.
The Safety Review and Audit Board, Station Operations Review Committee, and the j Quality Assurance Division shall monitor the District's nuclear program and provide management with evaluations and assessments regarding the effectiveness of the implementation of the program. When evaluations and assessments identify a concern, management shall take expeditious action to correct any undesirable condition (s) includmg, !
l where appropriate, action to preclude repetition of such condition (s).
District personnel shall have the organizational freedom to identify concerns and j 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. Ouality shall be everyone's responsibility.
APPROVED:
President & CEO Senior. Manager of Quality AssuranceT '. Senior Vice President of Energy Supply vi Revision 14
o COOPER NUCLEAR STATION !
OUALITY 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 l l
Nebraska Public Power District recognizes its responsibility for 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 i contributing to this safety as well as contributing to station reliability is also recognized.
i l 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, l i 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 assurance that structures, systems, and components will perform satisfactorily, and that the public health and safety will be maintained.
1.1 Purnose The purpose of this policy document is to provide a description of the Quality Assurance Program to be followed during the operational phase of Cooper Nuclear Station and to identify applicability of the policies and procedures described herein.
This CNS Quality Assurance Program for Operation was developed by Nebraska 1-1 Revision 14
Public Power District in response to the requirements of 10CFR50, Appendix B. It provides a general description of the Quality Assurance Program for Operation and requires that detailed instructions, procedures, and drawings, as appropriate, 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, erected, maintained, and modified to quality standards appropriate to their importance to the safety function. The Quality Assurance Documents will identify those structures, systems, and major 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 affecting quality shall be documented by approved instructions, procedures, or drawings and such activities shall be implemented as documented. Such documentation shall contain adequate qualitative and/or quantitative acceptance criteria to provide a measure of accomplishment, it is the policy of Nebraska Public Power District (NPPD) to staff the Nuclear Power Group (NPG) with properly-trained personnel in all responsible positions and job assignments. Sufficient numbers oflicensed and senior licensed operating personnel will be available to assure proper operation of the station under all reasonably foreseeable circumstances including personnel turnover, vacations, and disability.
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All District personnel, as well as non-District personnel who work independently under NPPD's QA Program, responsible for operating, maintaining, or designing safety-related systems and equipment shall receive formal instruction in Quality Assurance, including: basic principles of quality assurance,10CFR50 Appendix B, the contents of this policy document, and Quality Assurance documents, as applicable.
Trained technical, engineering, and Quality Assurance personnel shall be assigned surveillance and audit tasks to ensure compliance with the requirements of the documents which control station operation, such as the NRC license, Updated Safety Analysis Report, Technical Specifications, Operating Manual, QA Program for Operation, and other such controlling documents. During the time personnel are performing QA functions, they shall be responsible to the QA Division to maintain the organizational independence required by the QA Program.
It is the policy of Nebraska Public Power District to maintain quality standards for Cooper Nuclear Station which will ensure the high degree of reliability and safety needed to meet the overall objectives of supplying safe and dependable electric service to its customers.
The CNS QA Program for Plant Operations utilizes 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 where specific exceptions and clarifications are noted within this document. Where specific requirements included in the standards are in conflict with original design requirements set forth in the USAR and other appropriate design documents, the original design requirements shall govern. Later revisions to standards presently committed to by CNS, 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.
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In summary, NPPD is committed to the continuous development of a 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 applicable to the 18 criteria of 10CFR50, Appendix B.
1.3 Objectives The overall objective of this Policy Document and Quality Assurance Plans (QAPs) and j Nuclear Quality Procedures (NQPs), is to set forth the Quality Assurance I l
organizational structure and personnel responsibilities, and to articulate general requirements for implementation of the Quality Assurance Program for Cooper Nuclear Station to address the following activities, at a minimum:
a) Regulatory criteria, codes and standards, and design bases for safety-related ( .os (as defined in the CNS QA Program) are incorporated imo the test, operating, modifications, and maintenance procedures and instructions to meet all requirements for nuclear safety and station reliability; b) Results of all preoperational and operational tests of safety-related systems and components conform to the requirements of the drawings, specifications, procedures, and instructions, and that appropriate reports are prepared to document that all results of tests meet prescribed acceptance criteria; l-4 Revision 14
c) Nuclear Fuel is purchased, designed, manufactured, inspected, packaged, shipped, received, installed, and operated in the reactor in accordance with approved procedures, instructions, regulatory ,
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d) The Station is operated, maintained, tested, refueled, repaired, and modified, in accordance with approved procedures, instructions, regulatory requirements, and license stipulations, consistent with quality standards equal to or better than those in effect during design and construction; I I
e) A system is established and maintained to control, safeguard, and permit ready retrieval of quality- related documentation generated for materials and components during the design, fabrication, modification, maintenance, and operation of CNS; f) Appropriate and complete reports, records, and logs are established and maintained so as to provide a continuing record of quality-related i activities associated with station safety and reliability throughout the life of the station; l
l g) The NPG personnel are subjected to periodic training, retraining, requalification, and examination such as to maintain and improve their l 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; l-5 Revision 14
r i) Corrective action documents / reports and associated resolutions are to
! be properly controlled and filed in the appropriate quality-related l
l record files; j) Inspection reports issued by the 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 The QA Program for Operation applies to those nuclear station structures, systems, and components that are designed to prevent or mitigate the consequences of postulated accidents which could cause undue risk to the health and safety of the public, and to other selected systems and programs as defined in implementing QA Plans. The requirements of this program apply to all activities which affect the safety-related l 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 l
engineered safety systems, the reactor containment system, portions of the radioactive waste disposal system, and other systems and 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.
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The Quality Assurance activities governing those structures, systems, and major components shall be performed as described in the Quality Assurance Plans (QAPs)
(see 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 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 maintain, as a minimum, the quality level achieved in the original design and construction.
1.5 Definition of Terms Key words and phrases used to characterize this QA Program are defined herein to establish a basis for uniform and consistent interpretation of the Quality Assurance requirements. Definitions of these terms are based upon documents and standards issued by the American National Standards Institute (ANSI), NRC Safety and Regulatory Guides, professional societies involved in standards work (ANS, ASME, IEEE, et al.), and 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 following conunitment applies:
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i ANSI N45.2.10-1973 " Quality Assurance Terms and Definitions," and the associated Regulatory Guide 1.74, are applicable to the CNS Operational l
QA Program, with the following clarification:
l There may be instances where existing procedures contain defm' itions 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. 4 l
To facilitate review and understanding of this policy document, the following basic t
terms are defined below along with appropriate QA Program requirements. I Audit (
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An activity to determine through investigation, the adequacy of, and adherence to, established procedures, instructions, specifications, codes, and standards or other applicable contractual and licensing requirements, and the effectiveness of implementation.
Class For piping and valves, CLASS is determined by the applicable ASME Code. For seismic considerations, CLASS is determined by the USAR. (See also Essential, l Non-Essential, and Quality Commercial Grade.)
Codes and Standards Documents issued by qualified organizations which contain standardized requirements for particular equipment or applications (e.g., ASTM Material Standards, ASME Pressure Vessel Code, etc.).
(Refer also to ANSI N45.2.10 for definition of " Standard".)
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Condition Report l Condition Report (CR) is the vehicle utilized for identifying and correcting conditions 1
adverse to quality, and significant conditions adverse to quality as described in 10CFR50, Appendix B. Condition Reports also provide a method for identification i and correction of those conditions not specifically described in 10CFR50, Appendix B.
1 l Conditions Adverse to Ounlity
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' Any conditions _that could affect safety-related structures,~ systems,'or components
! ability. to function within design requirements or adversely alter performance characterisites.1 Corrective action process procedures shall provide criteria for determining the level of condition significance and respective resolution requirements,'
consistent.with 10CFR50 Appendix B Criterion XVI!
l Controlling Documents l
l All those drawings, specifications, procedures, instructions, manuals, data books, Updated Safety Analysis Reports (USAR), Technical Specifications, and the like, which have been approved and issued by the appropriate authorities, and which l prescribe the conditions and limitations under which work is to be performed.
l (Refer also to ANSI N45.2.10 for definition of " Documentation".)
Design Change A design change (generic application) is considered to be any change to a component, equipment, or structure that changes the design criteria, configuration, or margin of safety for a system or component which could impact nuclear safety, equipment and system integrity, or personnel safety.
Designated Representative An individual or organization that is authorized by the purchaser to perform a specific function as identified / described in the procurement document.
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Emergency Procedures (Operating, Maintenance, or Repair) l Those activities which must be performed without delay in order to:
a) Avoid further degradation of off-normal conditions which, in themselves, do not constitute an accident, but which could lead to an accident if not corrected promptly; b) Reduce the consequences of an accident or hazardous condition which has already occurred; c) Implement an emergency plan; d) Prepare for an anticipated act of nature.
Essential l For purposes of applying and implementing this Quality Assurance Program, the term
" Essential" shall apply to the following:
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a) All systems, structures, equipment, and components which are identified in the USAR as having been designed and built to Seismic
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Class I requirements; b) All systems, structures, equipment, components, instruments, and controls which are identified in the USAR as being required to shut down the plant and maintain it in a safe shutdown condition; c) All other systems, structures, equipment, components, instruments, and controls which are placed in the " Essential" category by NPPD, ;
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Functional Organization Chart ,
i A pictorial description of the organization as it actually works showing actual lines of I
direction, supervision, responsibility, authority, and communication. Such functional lines may or may not coincide with regular administrative channels, i
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n InsDeCtion The determination that physical characteristics meet predetermined requirements by visual checks or by other techniques such as X-ray, ultrasonic or dye penetrant examination, etc. (See also Quality Control).
(Refer also to ANSI N45.2.10 for definition of " Inspection".)
Licensed Station A nuclear station which is designed and constructed so as to meet requirements of applicable regulatory criteria and is thereby eligible to receive a construction permit and operating license from the U.S. Nuclear Regulatory Commission.
1 l Lower Tier Procurement Procurement by a supplier from a subsupplier of items or services.
l Maintenance Procedures Written instructions which define a preplanned maintenance program and prescribe the methods, materials, and processes to be used to assure continuing quality and continuing operation of equipment within required performance characteristics.
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Maior Maintenance. Renair. or Modification i
Those maintenance, repair, or modification activities performed on nuclear 1 ,
! safety-related structures, systems, or components which involve: l a) Special craft or procedure qualifications to meet Code, Standard, or Regulatory requirements; i
b) Alterations which affect overall structural integrity, essential j performance characteristics, or margins of safety in design for nuclear j safety-related structures, systems, or components; l l
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c) Any permanent change to the facility that requires a Technical Specification change or creation of an unreviewed safety question.
Minor Maintenance. Renair. or Modification Those maintenance or repair activities which are within a journeyman craftsman's capability, and which:
a) Are prescribed in the equipment manufacturer's instruction books as l necessary or desirable for most effective operation; b) Are prescribed as part of a preplanned and app: wd routine or preventative maintenance program; c) Any permanent change to the facility judged significant enough to warrant documentation that does not require a change in Technical J Specification or present an unreviewed safety question.
Monitor Periodically observe on a formal or informal basis whether work is being performed according to the requirements of the controlling documents (see also Surveillance).
Nonessential Any structures, equipment, and components which may be important to reactor operation, but are not required for preventing an accident which would endanger the public health and safety, and are not required for the mitigation of the consequences of these accidents. A Nonessential designated item shall not degrade the integrity of any item designated Essential.
Nuclear Power Group Management The Cooper Nuclear Station management comprised of the Senior Vice President of Energy Supply, the Vice President of Nuclear Energy, all Senior Managers, the Senior 1-12 Revision 14
Manager of Quality Assurance, and all other Managers of NPPD's Nuclear Power Group.
Nuclear Ouality Procedures (NQPs)
Nuclear Quality Assurance Division Procedures that contain requirements / guidance for QA Division activities which affe'ct activities of other divisions within the NPG and the District. NQPs define the responsibilities for implementation of the QA Program in accordance with policies and practices herein defined as they apply to the QA Division.
In addition, they provide guidance for activities to be performed by the QA Staff.
Off-Normal Condition A condition which results when an operating variable departs from its normal range.
To restore normal operating conditions following such a perturbation, action is taken under off-normal procedures so as to correct the condition which, if not corrected, could degenerate into a condition requiring action under an emergency procedure.
Operating Procedures Written instructions which define the normal method, means, and limits of operation, in all modes, of a nuclear power station, a system or systems within the station, or station processes.
Purchaser The organization responsible for issuance or administration or both of procurement documents. (Refer also to ANSI N45.2.10 for definition of " Purchaser".)
Ouality Assurance All those planned and systematic actions performed for the purpose of establishing i high level of confidence that:
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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; b) A structure, system, or component will perform satisfactorily in service; and c) Appropriate records, documentation and/or drawings are maintained to show compliance with a) and b) above.
Ouality Assurance Documents Those documents inclusive of the QA Policy Document, Nuclear Quality Procedures, QA Plans, 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.
Ouality Assurance Plans Quality Assurance Plans are those documents specifically designed to provide detailed quality requirements for a given functional area. The plans are generated by applying the 18 criteria of 10CFR50, Appendix B, to each functional area and then deriving the specific quality requirements for that area.
Ouality Assurance Records Those records (see Reference 7.9) which have been completed and furnish documentary evidence of the quality ofitems and/or activities affecting quality.
Control provisions shall be established for in-process records at the point at which they attest to completion of quality related activities.
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Ouality Commercial Grade Classification of a Comrnercial Grade Item (CGI) intended for safety-related use, procured from a QA approved source and dedicated in accordance with approved ,
station procedure; which meets the 10CFR21 definition of CGI.
Commercial Grade Item (CGI) - An item that meets all of the following criteria: i a) Not subject to design or specification requirements unique to nuclear facilities or activities; I J
b) Used in applications other than nuclear facilities or activities; and c) Is ordered from the manufacturer's published product description, e.g.
l l catalogue, as an off-the-shelf item.
t l Ouality Control l
Those activities which deal directly with the measurement, observation, or verification of physical characteristics of materials, components, or systems which provide a basis for controlling quality to within predetermined limits, or requirements, including adequate quantitative and/or qualitative acceptance criteria by which an activity can be measured.
l l l Ouality Reauirements Those factors which define limits which must be met so that the product will perform l its intended function reliably throughout its design life. They include, but are not limited to, conditions important to proper material selection, manufacture, construction, and inspection; substantiation that material or parts conform to all specification requirements, testing to demonstrate adequacy of performance; protection of finished parts to prevent deterioration; and conditions for operation, maintenance, and repair which enable continuing operation within prescribed margins of safety and within prescribed performance limits.
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l Right of Access The right of the purchaser or designated representative to enter the premises of a supplier for the purpose of inspection, surveillance, or quality assurance audits.
Regulatory Criteria l
l That body of NRC publications which define the conditions which must be met to i
obtain and hold an NRC Construction Permit, Operating License, and Licenses for individual operators.
I Review l
l A deliberately critical examination. The term includes the routine monitoring of station operation performed by the Senior Vice President of Energy Supply,and his staff as a normal management function, and the formal independent evaluations of certain contemplated actions and after-the-fact investigation of anomalies conducted by a duly constituted review and/or audit group.
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Safeguard (of Nuclear Material)
Measure taken to prevent diversion of nuclear materials into unauthorized or illegal uses (see also Accountability).
Safetv-Related (See " Essential")
l Services The performance by a supplier of activities such as design, fabrication, inspection, nondestructive examination, repairs, installation, or training.
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Station Permanent Record File The file which is established for the purpose of accumulating and storing all documents and records pertaining to quality-related activities throughout the life of the nuclear plant.
Supplier Evaluation Those activities which determine the effectiveness of implementation of the supplier's Quality Assurance Program. A variety of methods may be used to perform a supplier l
evaluation and are described in the NQPs.
Surveillance
, ; A~ surveillance is the documented act of observing activities and/or reviewing documentation to evaluate the' performance against specified requirements and commitments, including industry good. practicess Emphasis is placed on performance-based criterlatthat is observation of in-p.rogress. work activities and resultant documentation, in order to assess adequacy and effectiveness, as related to the safety, and reliability.of plant operation.-
Surveillance Testing Periodic testing of structures, components, and systems related to nuclear safety, for the purpose of verifying that such safety-related structures, components, and systems continue to function or are in a state of readiness to perform their safety functions.
l Testing The determination or verification of the capability of an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions. (Refer also to ANSI N45.2.10 for definition of " Testing".)
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Traceability The capability to identify a particular component or material and to discover its entire history, back through the written records of its material formulation (heat number),
manufacture, inspection, installation, test, operation, maintenance, repair, and replacement.
Witness Formal observation by a knowledgeable person of a particular, prescheduled event during manufacturing, inspection, installation, testing, operation, maintenance, or repair. The purpose of witnessing is to provide direct observation and evaluation of an event, independent of the group performing the particular operation. I l
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1 2.0
SUMMARY
DESCRIPTION This section def'mes the NPPD commitment for compliance to 10CFR50, Appendix B, as applied to safety-related structures, systems, and components associated with Cooper Nuclear Station.
I In addition to describing commitments to 10CFR50, Appendix B, this Section also i identifies NPPD's commitment to selected ANSI Standards and their associated Regulatory Guides.
2.1 Organization The President and Chief Executive Officer (C.E.O.) (Figure 1) represents the highest level of management responsible for establishment of Quality Assurance policies, goals, and objectives. The responsibility and authority as the nuclear officer has been delegated to the Vice President of Nuclear Energy from the President /CEO. This authority includes the right to direct, enforce, and perform any action required to ,
ensure all activities conducted at Cooper Nuclear Station are in compliance with 10CFR50, Appendix B. The Quality Assurance Division, which reports to the Senior Vice President of Energy Supply, shall have complete independence to perform all QA" overview functions 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 modifying.
Figure 1 of this document outlines the QA Division functional organization. Quality Assurance Personnel shall have sufficient authority and organizational freedom to:
(1) Identify quality problems; 2-1 Revision 14
l (2) Initiate, recommend, or provide solutions for conditions adverse to quality; and, (3) Verify implementation of solutions.
2.2 Ouality Assurance Program The Quality Assurance Program applies to all activities which affect nuclear safety.
This Policy Document identifies the industry Standards and Regulatory Guidance
- documents which are applicable to the implementation of the Quality Assurance Program for Cooper Nuclear Station. Specific exceptions to criteria contained within the referenced Standards are herein described in following sections, as applicable.
Specific implementing criteria for the Quality Assurance Program are contained in lower level implementing procedures. Procedures are prepared for each important activity of station operation which clearly define the work to be performed on a step-by-step basis and identify, where appropriate, the results to be achieved. Mandatory QC inspections or tests are performed on an independent basis to verify that specific work activities are being correctly completed (correct results obtained) and are incorporated into the work procedures directly or by attachment. Management review l and QA audit activities verify that the Quality Control Program is implemented.
I Procedures which implement the Quality Assurance Program will be reviewed periodically to assure that the requirements of the program are being met and new requirements are being incorporated, as appropriate.
Specific to the related ANSI Standards for this criterion, the following commitments apply:
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, 1. ANSI N18.1-1971 " Selection and Training of Nuclear Power Plant Personnel,"
shall provide direction for selecting and training of personnel for the Nuclear Power Group.
Regarding the qualifications of the specific positions of shift supervisor,- l senior. operator, licensed operator, shift technical advisor, and radiation l .
! protection manager, Cooper Nuclear Station shall comply .with the provisions of Regulatory Guide 1.8,^ revision 2, " Qualification and Training of Personnel for Nuclear Power Plants".'
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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 (Safety Guide 1
33), apply to the CNS Operational QA Program with the same exceptions as those taken in other sections of this Policy Document to ANSI N45.2-12.
- 3. ANSI N45.2-1977 " Quality Assurance Program Requirements for Nuclear Facilities," and associated Regulatory Guides 1.28 and 1.33, shall apply to the CNS Operational QA Program, with the following exceptions:
Where Section 11 " Inspection" identifies the reporting relationship l between the inspector and the "immediate supervisors who are l
responsible for the work being inspected," the CNS QC Program only l requires that the individual performing the verification function shall not perform or directly supervise the work being inspected.
Table 1 identifies the structures, systems, and major components associated with Cooper Nuclear Station covered by this program. Table 1 is not intended to be all inclusive. The Operations, Support and Engineering 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 2-3 Revision 14 l
L ,
l l
l- designed to provide control over all activities affecting quality of essential items to a i i
degree consistent with their safety-related importance. These activities will be governed by approved plans and instructions and these documents shall be followed under controlled conditions.
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 l in dedicated Quality Assurance Plans.
Special process controls, test equipment, tools, skills (training, if required) shall be l
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 standard.
Experienced 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-related activities at i the direction of the Senior 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 for NPG employees as described in nuclear training program descriptions. Cooper Nuclear Station personnel will receive training to familiarize them with the quality assurance program. The Quality Assurance Training Program for Quality Assurance auditors and audit team leaders provides initial training for the performance of fundamental QA tasks, and provides continuing training to enhance 2-4 Revision 14
both auditing skills and technical knowledge. Quality Assurance training for QA Staff and station personnel will be periodically evaluated and feedback provided to ensure effectiveness and improvement. The Quality Assurance Training Program and applicable training materials will receive management approval as required by governing programs and processes.
Training activities will be audited periodically by the QA Staff to verify its scope and effectiveness.
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, mterface requirements (with original design organization, if required), approvals, and the organizations delegated the authority to implement the design change.
l Design control measures shall include the review for suitability of application of items that are essential to the safety-related function of the system involved. 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-shelfitems 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 j dedication upon receipt, analysis, or other definitive method.
The Quality Assurance Division will periodically review design changes during any phase of development or implementation. Final acceptance of the design change will 2-5 Revision 14
c 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 l
methods, or by the performance of a suitable testing program.
Specific to the related ANSI Standards for this criterion, the following conunitments L
apply:
l t
- 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 l 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. However, 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 l
Updated Safety Analysis Report (USAR), the USAR conunitments 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 1
1 l condition. i l l l
- 2. ANSI N45.2.4-1972 " Installation, Inspection, and Testing Requirements for l Instrumentation and Electric Equipment During the Construction of Nuclear l
Power Generating Stations," and its associated Regulatory Guide 1.30, shall be applicable to the CNS Operational QA Program for safety-related modification I
work, with the following exceptions / clarifications:
(a) The definition of Class I and Class IE 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 2-6 Revision 14
included in Table 1 of this policy document and the CNS "Q" List. The scope and applicability of this standard shall necessarily be limited to these defined areas.
(b) Appropriate requirements for installation, inspection, and tests are 1
defined in job specifications and work instructions developed as a part i
of the modification work package. It is not intended that separate l 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.
(c) The requirements for installation, inspections, verifications, and tests i shall be included in the work 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 be established to specifically address all of the areas referenced.
(d) 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. Commitments 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 Guide 1.94, shall be applicable to the CNS Operational QA Program 2-7 Revision 14
for safety-related modification work, with the following exceptions /
clarifications:
NOTE With respect to structural concrete, acceptability shall be documented in accordance with the District's Dedication Procedures, which will be verified by independent QA audit.
(a) 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. 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 conunercial batch plant facilities. Instrumentation at commercial batch plant facilities will be evaluated by NPG construction management personnel, or their designated representative, to determine that sufficient accuracy can be obtained.
(c) For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch plants.
For these small quantities of concrete, it is unreasonable to expect commercial facilities to shut down normal operations to provide 2-8 Revision 14
certified aggregate, cement, admixtures, fly ash, water, etc. In this respect the qualification tests required by Table A for aggregate; i
cement, admixtures, fly ash, and pozzolans; water and ice will not be I required. Appropriate evaluations will be made to determine that good quality and generally-acceptable materials are used. NPG construction
{
management evaluation, coupled with slump tests, air entrainment tests, 1
and concrete cylinder strengths, will provide adequate control and l
qualification of the concrete.
i l
(d) Design mixes consistent with, or equivalent to, original requirements will be specified and the results of the cylinder tests will be evaluated by NPG construction management based on the acceptance criteria associated with the original design mix requirements.
(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 i
bins. Control of storage of materials would not be practicable.
l l (f) If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the l requirements of ACI-304, ASTM C-94. Where certifications are not available, two concrete test cylinders representing the first 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 batch plant facility shall be inspected by NPG construction management and the CNS QA Staff to assure that reasonable controls are being exercised with reference to the inspection guidelines set forth by Section 4.3 (1) and (2).
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(g) Inspection of fills and earthwork will meet the general requirements set forth. The extent to which individual inspection requirements are met I will depend upon the nature and scope of the work to be performed.
l l
l (h) Except for normal batch qualification tests (slump, air content, 4 temperature, and compressive strength) and initial reinforcing steel certifications, the in-process tests required by Table B are generally applicable to the periodic control which must be exercised with reference to long-term construction type programs. The in-process test j 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 l
Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," shall be applicable to the i
CNS Operational QA Program for safety-related modification work, with the i
following clarification:
(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.
2.4 Procurement Document Control Nuclear Power Group procedures are required to define the applicable requirements, design basis methods, and procedures for procurement of spare parts, materials, equipment, and services for essential nuclear systems. These instructions and procedures shall also include provisions for assuring that the necessary quality 2-10 Revision 14
1 l I i
j requirements are incorporated directly into the procurement documents for essential i
spare parts, material, equipment, and services. These instructions and procedures shall also include provision for assuring that the necessary records are specified and provided to the District by the supplier.
The basic principles and practices included in these procedures are expected to be applicable to any purchasing activity necessary for operation of the station; however, l
additional special controls may be necessary for major modification or repair activities.
Procedures provide for independent Quality Assurance review and approval of l suppliers, and QA Audit of contractor and supplier activities. Quality Assurance will periodically review procurement documents for essential and quality commercial grade purchases.
Revisions issued to any procurement document will be subjected to the same review
! and approval as the original order.
All procurement documents issued to suppliers of safety-related items or services require that the supplier implement a Quality Assurance Program that meets the intent
- of 10CFR50, Appendix B (with the exception of those suppliers performing all work at l
l Cooper Nuclear Station or in the Columbus General Offices under the District's QA Program). The Quality Assurance Programs submitted by the suppliers will be evaluated by NPPD QA to ascertain that they meet the criteria established in 10CFR50, Appendix B. All safety-related suppliers shall appear on the applicable section of the NPPD Suppliers List.
1 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.
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Where necessary, because of design modifications, or where it is necessary or desirable to upgrade quality in replacement parts or meerial, necessary modifications will be made to drawings and specifications to incorporate requirements for currently appropriate quality level. These modifications or upgrading of replacement parts will be accomplished in accordance with approved instructions, procedures, and drawings.
These documents will be subject to required reviews before being implemented.
Specific to the ANSI Standard related to this criterion, the following commitment .
I applies: '
- 1. ANSI N45.2.13-1976 " Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants" and it's associated Regulatory Guide 1.123 Revision 1, is applicable to the CNS Operational QA Program, 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 requirements of this standard to all such suppliers. ,
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2.5 Instructions. Procedures. and Drawings Quality Assurance activities and other activities which have nuclear safety significance j will be prescribed by documented instructions, drawings, and procedures as appropriate and shall be accomplished in accordance with these instructions, procedures and drawings. These instructions will be sufficiently detailed and explicit so that any supervisor, inspector, or auditor can, by observation, determine whether or not l activities are being satisfactorily accomplished and documented. These documents shall include the qualitative and quantitative acceptance criteria necessary to assure satisfactory completion of the test procedure. Those acceptance criteria shall, where appropriate, require post installation testing prior to returning the component or system i to service. Repair maintenance activities on essential systems are performed in l
l accordance with the Maintenance Work Request process. Quality Assurance will l periodically review procedures governing the conduct of special processes, special tests, and special maintenance, and will periodically evaluate the implementation and l results of such activities.
l Temporary changes to procedures which do not change the intent of the original procedure may be madeiprovided such changes are approved by two members of the i
operating staff holding SRO licenses ( Such changes shall be documented and subs _equently reviewed by the Plant Manager within one month?
Document Hierarchy shall be as follows:
Level I:
- License Basis Documents Technical Specifications Operating License 2-13 Revision 14 1
f Quality Assurance Policy Document i
" Safety Analysis Report" Updated Safety Analysis Report NRC Correspondence (Commitments and SERs)
" Technical Requirements Manual l l
- ~~
.Offsite Dose' Assessment Manual Level II:
- Design Specifications and Drawings Level Ill:
- Procedures Administrative Procedures Operational Procedures Work Procedures Nuclear Power Group Directives l
Nuclear Quality Procedures Level IV:
- Policies and Guidelines 2.6 Document Control Administrative control procedures shall be established by the Nuclear Power Group (NPG) 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 2-14 Revision 14
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 6
document.
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 in support of Cooper Nuclear Station.
b) Establish an index of quality-related records to enable personnel involved in safety-related activities to determine the proper documents to be used in the activity.
c) Establish a filing system. !
d) Establish periods of retention.
e) Establish measures to control distribution and revisions.
Nuclear Power Group Management is responsible for establishing effective interfaces, and document control procedures.
Specific to the ANSI Standard related to this criterion, the following commitment apphes:
- 1. ANSI N45.2.9-1974 " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," and its associated 2-15 Revision 14
f' Regulatory Guide 1.88 shall be applicable to the CNS Operational QA Program, with the following exception / clarification:
(a) For those design, manufacturing, construction, and operating records generated prior to implementation of this standard, it is not our intent to backfit the detailed requirements of this standard to those records. All such records, however, have been initially designated for lifetime storage, until specific review dictates otherwise, and will be stored in the record storage facility. Record indexes and filing systems shall be established to permit reasonable identification and retrieval. The
! records will be stored and preserved per the requirements of Section 6.0 of this standard.
1 2.7 Control of Purchased Material. Equipment. and Services i
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, dedication, material identification, etc. The completed receipt inspection report will become part of the purchase order package. Procurement documents shall be available at the receiving i area to identify the receiving inspections required.
Nuclear Quality Procedures provide for evaluation of supplier's quality program to determine effectiveness and compliance to the applicable 10CFR50 criteria as part of the supplier selection process. These instructions shall describe the methods and i
techniques used to evaluate the supplier's Quality Assurance Program.
2-16 Revision 14
f 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 effectively 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.
Upon receipt at the station, material, parts, and equipment purchased and identified as
" Essential" or " Quality Commercial Grade" will be placed in a segregated storage area until all inspections are complete and all required certifications and documentation is received.
Items in segregated areas will not be issued, by the Warehouse, without the written permission of the Vice President.of Nuclear Energy or designee, and then only after proper arrangements have been made to assure that necessary steps will be taken to bring all aspects of the particular item into conformance with normal requirements prior to the system containing components in " Hold" status being considered operable.
l Suppliers of essential equipment, if appropriate, shall be required to provide certified documentary evidence that the material supplied conforms to the purchase document I requirements such as material test report, code required test and inspection, documentation, etc. A complete set of documentation required by the procurement i document for all essential materials, equipment, and services will be filed at Cooper Nuclear Station.
2.8 Identification and Control of Parts. Materials. and Components To the maximum extent practicable, activities carried out during operation of the Cooper Nuclear Station will comply with the requirements for identification and control of materials, parts, and components as set forth in the as-built drawings and 2-17 Revisien 14
r specifications for the station. Where special measures are required to assure proper l l
identification of materials, parts, and components, such requirements will be incorporated directly into the procurement documents for such parts and assemblies. )
Such identifications which may include heat 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 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 acceptance. CNS procedures will incorporate requirements necessary to assure that the 1
ident.ification measures are properly carried out at the station, that unacceptable items l 1
will not be used in essential systems, and that the components to be used in essential 1
! systems receive independent verification of component identity prior to installation.
l 2.9 Control of Soecial Processes l l
l l
General maintenance procedures provide for performance of special processes by qualified personnel using qualified and approved procedures. Control procedures l provide for documentation of activities, and for proper integration of QC Inspection.
l In most cases, the procedures will be prepared only when a specific process is required in the maintenance, repair, or modification of essential equipment at CNS. These l procedures shall also require special processes, such as welding, heat treating, and l
l NDE, to be controlled and performed by qualified personnel in accordance with qualified procedures.
Maintenance modification control methods and Station Operating procedures are periodically reviewed by CNS QA personnel. This review includes verification that necessary codes, standards, quality requirements, and acceptance criteria are incorporated to control special processes within established limits.
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E 1 I
2.10 Jasoection Quality Control inspections have been assigned in this policy document to the organization basically responsible for the performance of the activity. A Peer QC i
Program will be utilized in which QC inspections are normally performed by QC l l I l Inspectors who have been selected from within the Nuclear Power Group, and who are many times just as qualified to perform the work as they are to inspect the work. QC l personnel will be qualified / certified in accordance with NPPD's commitment to ANSI l
j N45.2.6 and will conduct the QC Program inspections. Detail for the conduct of the QC Program will be procedurally established.
i l Quality Assurance Audits and Surveillance of activities such as examination of
, individual operating personnel and documentation are performed at intervals consistent l
l with the importance of the activity. Direct QA or QC inspection will also be conducted l for activities such as refueling, radiochemistry, and environmental monitoring. Special l inspections, such as those requiring qualification to ASNT-TC-1 A, will be contracted to approved suppliers. If direct inspection is impossible, indirect control methods will l be specified in the instructions to provide a method of monitoring process methods and l equipment. The results of all inspections will be placed in permanent record storage.
Controlling documents pertaining to quality-related activities receive Station Operations l Review Committee (SORC) approval to ensure incorporation of appropriate quality l
requirements. QA is a non-voting member of SORC.
l Specific to the ANSI Standard related to this criterion, the following commitment l
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 2-19 Revision 14
1 1
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 performed and signed off by qualified personnel not directly performing or supervising the step (s) 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-1 A These services are currently contracted to an approved supplier. Any required nondestructive examinations will be performed by personnel who are qualified and certified per SNT-TC-1 A.
2.11 Test Control Each type of test program performed by the station operating group will be def'med 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 inspector, test performer, date, and data recorder. Each type of acceptance 2-20 Revision 14
test has individual test procedures which include Quality Control provisions, acceptance criteria, and check points for observation or checking of important aspects.
These test procedure prerequisites will include the test instrumentation requirements and environmental conditions. All Special Test Procedures, Special Procedures, and Station Operating Procedures are routinely reviewed by SORC, of which QA is a member.
Quality Assurance Audits and Surveillance activities will be performed by the Quality Assurance Staff members to assure that tests are being performed in accordance with the requirements of the procedures, that results are evaluated and compared to the specified acceptance criteria, and that tests are being performed by appropriately trained personnel. In addition, test procedures shall specify test requirements and quantitative and qualitative acceptance criteria where appropriate.
2.12 Control of Measuring and Test Equioment 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 activities which effect quality of safety-related equipment.
Each permanent or temporary installed plant instrument performing an essential function has been identified and placed on a regularly-scheduled program of inspection, test, and recalibration. All test and measuring equipment required for calibration of the above equipment will also be placed on a regular program of inspection, test, and recalibration and will be appropriately tagged. Documented calibration records are reviewed, as required, to evaluate calibration performance and frequency, and changes are made as may be necessary, i
2-21 Revision 14
F
]
A Quality Assurance Plan will prescribe the QA functions to be performed relative to the calibration program. Quality Control and Quality Assurance practices require independent checks of calibration activities. Quality Assurance Surveillance performed by the QA Staff members will verify that procedures are being properly followed; that adequate records of calibration and testing of measuring and test equipment are being generated, rnaintained, and that regularly scheduled adjustments are made to maintain necessary accuracy. For equipment used to calibrate process equipment, procedures l
will define action to be taken should regularly-scheduled calibration checks reveal an l out of 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 i
i Condition Report will be issued. Reference and transfer standards, traceable to the National Institute of Standards and Technology (formerly NBS), will be maintained at CNS.
Scheduled and/or unannounced audits or surveillances by the Quality Assurance Staff, the Safety Review and Audit Board, or NPPD management will include review of the calibration program.
2.13 Handline. Storace. and Shipping l
l The procedures for procurement and control of essential spare parts, materials, replacement parts, and equipment include the requirements for the control, handling, cleaning, shipping, receiving, and storage of essential parts and material. Quality Assurance Plans and NQPs provide for surveillance and audit to assure that procedures are followed and that essential parts and materials are received, inspected, stored, and controlled in such a manner so as to prevent degradation.
2-22 Revision 14
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 exceptions / clarifications:
(a) NPPD's QA 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 spare 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 most stringent requirement for their intended use. The volume and characteristics of procurement during the operational phase differ significantly from those purchases made during the design and construction phase. Items requiring special storage protection will be identified on the purchasing dacuments. Items that must be stored outdoors (equivalent of Level D) and items that must be stored in covered but unheated conditions (equivalent of Level C) will be evaluated on an individual case basis. However, it is not considered practicable to preclassify individual parts by levels as required by 2-23 Revision 14 l
l
i Section 2.7 of this standard. Shipping and packaging requirements for such items will likewise be handled in the procurement documents, as appropriate, i i
l (c) QA Audits and Surveillances are performed to verify that the requirements of N45.2.2 are met except as noted in (a) and (b) above.
2.14 Insoection. Test. and Ooerating Status The NPPD status tagging procedure, already in use throughout the system, has been l
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. These tags shall indicate abnormal equipment test and inspection j 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 I
are 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 Shift Supervisor by requiring that serially-numbered tags, obtained from the Control Room, be used for all tagging purposes. Records will be maintained in the Control Room to enable operators and Shift Supervisors to determine the status of the equipment tagged.
A Temporary Modifications Control Program will be maintained to provide a method for recording the installation and removal of jumpers, fuses, or wire terminal 2-24 Revision 14
r l
1 l
l disconnections. This record will include the location, reason, name of person L
authorizing action, and name of person performing the installation.
i Requirements for tagging are included in the applicable procedures. Status tagging will be verified by audit and surveillance.
i !
! 2.15 Nonconforming, Materials. Parts. or Comoonents i
Warehouse and maintenance procedures include requirements for the identification and tagging of nonconforming materials, parts, or components, (See Section 2.8).
Nonconforming items will be controlled in such a way as to prevent their inadvertent 1
use or installation. Such parts will be reinspected and reviewed for adequacy prior to returning them to the manufacturer, scrapping them, or arranging for them to be reworked to conform. Disposition of a nonconforming item will be determined by the responsible supervisor in conjunction with the QA Staff. Written reports of decisions to repair or rework essential items will be reviewed and approved in accordance with maintenance and/or design control procedures.
1 1
l Any decision to reduce requirements to permit use of nonconforming parts, materials, or components in essential systems, will be documented per the Corrective Action Program, and will be subject to Station Operations Review Committee (SORC) review i and approval. Appropriate design modification documentation will be completed, if required.
l 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 Anurance Surveillance activities, to assure conformance with the requirements of the specifications, procedures, and other controlling documents.
l 2-25 Revision 14
i Essential equipment classified as scrap will be identified and segregated in such a e
manner to prevent inadvertent use or installation in an essential system.
2.16 Corrective Action The Corrective Action Program (CAP) for CNS shall provide the measures to assure that conditions adverse to quality, such as failures, malfunctio_ns, deficiencies, deviations, defective materials and equipment, and nonconformances are promptly identified and corrected. Measures taken to disposition significant conditions adverse to quality shall include; immediate actions taken, the cause of the condition, action taken to preclude recurrence, and corrective actions. The identification of significant conditions adverse to quality shall be documented and reported to the appropriate levels of management.
The CAP shall be atilized by all personnel performing operation, maintenance, modification, or other quality related functions / activities at CNS, to document and report such deficiencies / discrepancies as:
a) Deviations from approved procedures.
b) Nonconforming materials, parts, or components received from outside suppliers on essential purchase orders.
c) Nonconforming materials, parts, or components within the plant.
d) Nonconforming materials brought on site without following established
- receiving and inspection procedures. I i-i e) Orders or recommendations to stop work.
f) Reportable occurrences.
g) Any other deficiency which violates the intent of the Quality Assurance i Program and which could have a significant adverse effect on quality.
h) Deviations which could be reportable under 10CFR21.
, 2-26 Revision 14 L >
r A monthly report of open NPG Action Item Tracking (NAIT) items shall be prepared and distributed to NPG Senior Management and Department Management personnel, including the Vice; President of Nuclear Energy.
NRC Regulations which require formal reporting to the NRC of failures, malfunctions, deficiencies, unusual operating experiences, and deviations which may have a significant effect on quality or safety will be reviewed and evaluated by the Station Operations Review Committee and, where appropriate, by the Safety Review and Audit Board. It will be the responsibility of the Nuclear Group personnel to identify and I promptly correct all such deficiencies or malfunctions either by improved maintenance, l
repairs, replacements, or modification. In all cases, 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 recurrence of similar failures. Quality Assurance activities will verify that corrective action is performed in accordance with I
approved written procedures and that the details of the corrective action are properly documented for the permanent station records.
l l
A quarterly trend report shall be issued to the Senior Vice President of Energy Supply, I which may identify adverse trends that require corrective action.
l Deficiencies and/or deviations identified by QA Staff personnel shall be reported per the guidance defined in Nuclear Quality Procedures and/or the CNS Corrective Action Program.
l 2.17 Ouality Assurance Records All activities having a significant effect on quality and safety will be thoroughly l
documented, and all such documentation will be incorporated into the record storage system. Procedures will require appropriate physical storage and personnel to maintain 2-27 Revision 14
l these files. Record identification, storage, retrieval, access, control, retention, and
)
safeguarding of all quality-related records associated with CNS will be in accordance !
l with approved procedures. Records to be maintained include all records accumulated during engineering and construction and those records generated during station i operation, maintenance, and modification as defined in Section 6.0 of this~ standard.
These records shall also include qualification of personnel, equipment, and procedures.
Inspection and test records shall identify the inspector, data recorder, method of observation, results, acceptance, and all nonconformance reports issued to document noted deficiencies. i Nuclear Power Group 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.
l Administrative procedures shall provide for methods for changing records that provide clear identification of the change and must be initialed and dated by the person making the change and by persons authorized to approve the changes. l l
The program will include Audits of record storage facilities to assure that the i l
procedures and controls are properly implemented. Detailed procedures describe processes for receiving records into the facilities and for making decisions on removal and disposal of outdated or superseded records. Refer to Section 2.6 " Document Control" for the commitment to ANSI N45.2.9.
2.18 Audits Scheduled and unscheduled audits will be performed to assess the effectiveness and performance of programs and personnel within the scope of the CNS Quality Assurance Program. Quality Assurance Plans define the application of the Quality Assurance 2-28 Revision 14
T Program to operations, maintenance, engineering, plant support and other diverse activities and programs. NPPD Management may request audits of specific activities l 1
of specific concern to them. The scheduling of internal audits will be coordinated to avoid interference of operating activities at the station to the extent practical. The scope of each audit will be planned to focus, in part, on areas of vulnerability and on the quality of the product of the programs and personnel. Audits shall be performed in accordance with written instructions or checklists and conducted by trained personnel not directly responsible for areas being audited. Upon completion of the audit, a formal report will be prepared and transmitted to the organization audited, which will include l an evaluation statement regarding the program's effectiveness. All audit findings identified will be documented and appropriate follow-up action will be taken to assure j 1
that corrective action has been implemented. Follow-up action, including reaudits to -
verify corrective action, shall be fully documented. The audited organization shall review and investigate any adverse audit findings to determine and schedule appropriate l
corrective action including action to preclude recurrence, and shall respond as requested by the audit report. The Senior Manager of Quality Assurance is responsible to see that the requirements for audits described in this policy document are carried out. The Safety Review and Audit Board (SRAB) will provide oversight of the CNS I Quality Assurance Program and audit results.
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Audits'of selected. aspects of plant operation shall be performed under the. cognizance of SRAB with a frequency commensurate _with their safety significance.l Audits ]
performed by the Quality Assurance Department which meet this' specification shall be i i
l considered to meet the SRAB audit requirements-if the audit results are reviewed.by.
SRAB.fA representative _ portion of procedures and records.of the activities performed during the' audit period shall be audited and,;in addition,Lobservations_of performance of operating _and maintenance activities shall be included These audits shall encompass; l
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E 1
I al' Werification of compliance with internal rules, procedures _(for example:-
normal,loff-normal. emergency; operating, maintenance,; surveillance, test, and i
radiation control procedures) and applicable license conditions at least once per 24 months;
- b. ;.;The training, qualification, and performance.of the. operating staff at least once per 24 months.-
l c. ;The Emergency Plan and implementing procedures at least'once per 12 months.
I d .: 1The Security Plan and implementing procedures at least once per 12 months.-
- e. The fire protection programmatic controls including the implementing procedures at least once per 24' months by qualified licensee personnel.'
- f. - The fire protection equipment and program impl_ementation at least once per 12 months utilizing either a qualified'off-site licensee fire protection engineer (s) or ,
an outside. independent fire protection consultant.0 An outside independent fire protection consultant shall be utilized at least every third year.
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- g. The Radiological Environmental Monitoring Program and the Offsite Dose )
Assessment Manual with their implementing procedures at least once every 24 i months.
Specific to the ANSI Standards relating to this criterion, the following commitments apply:
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l 1. ANSI N45.2.12-1977 " Requirements for Auditing of Quality Assurance l
Programs for Nuclear Power Plants," and its associated Regulatory 2-30 Revision 14
Guide 1.144, is applicable to the CNS Operational QA Program, and to the Supplier Audit 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 audits.
- 3. The frequency of audits will be in accordance with Regulatory Guide 1.33,
" Quality Assurance Program Requirements (Operation)".
2.19 Additional ANSI Standards !
ANSI Standards applicable to the CNS QA Program for Operation, not directly related to the preceding sections, are discussed in this section:
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- 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 I the following exceptions / clarifications:
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I (a) Cleaning requirements for almost all maintenance, repair, and l l
modification work will be considered as a part of the overalljob 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:
I 2-31 Revision 14
(1) Parts and components are checked for cleanness during receipt I
inspection and stored in a manner that will ensure adequate levels
- of cleanness are being maintained.
l l (2) Work instruction for safety-related maintenance activities will be l'
l evaluateil by Shop Supervision to assure that adequate Foreign Material Exclusion (FME) controls are incorporated.
l (3) Parts and components are inspected for cleanness prior to l installation in accordance with CNS maintenance procedures.
l (4) Work areas are maintained at a cleanliness level appropriate to the maintenance or modification activity being performed.
l (5) Quality Control, Supervisory, or Engineering Inspections before, 1
during, and after safety-related maintenance or modification activities address system cleanness.
1 (6) Random QA Audit and Surveillance of safety-related maintenance or modification activities requires verification of part, component, 1
and system cleanness. I I
(b) 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 classifications and requirements thereof shall l
be evaluated and applied, as appropriate, as a part of the overall work requirements, i
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l (c) For most modification or maintenance work, however, involving only L
small portions or individual components of larger systems, it is not i
considered practicable to conduct cleanness tests with ASTM ABBE-70 l l
Series. Appropriate cleanness will be maintained during the work and preoperational flushing will be conducted, consistent with the scope of the work performed and the original design requirements. Controlling the parts and components and the work area has provided CNS with reasonable levels of assurance that system cleanness will be maintained.
In addition to the above, the Water Chemistry Department routinely samples and tests for system cleanliness, corrosion, crud buildup, etc.
- 2. ANSI N45.2.3-1973 " Housekeeping During the Construction Phase of Nuclear Power Plants," and its associated Regulatory Guide 1.39, is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
! (a) The plant has been divided in zones for fire protection and security purposes. The zone designated for cleanness in the ANSI Standard are primarily intended for control or work during construction of the plant.
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 cleanliness controls, tool, and material l
l accountability are required for particular types of work, temporary clean i areas will be designated and defined in the procedures and work i l
packages for accomplishing the work.
(b) Fire protection and prevention will be provided in accordance with NPPD evaluation of the CNS fire protection system as required by NRC l regulations.
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r i (c) Station procedures have been reviewed to determine the need for l
particular cleanness, housekeeping, and control provisions. Where indicated, procedures have been revised to incorporate such provisions, using the guidance of ANSI N45.2.3.
- 3. ANSI N45.2.23-1978, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants". This standard is applicable to the Operational QA Program at CNS and to the Quality Assurance Division Training Program.
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2-34 Revision 14 !
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3.0 ORGANIZATION AND RESPONSIBILITIES 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 contract with qualified contractors and consultants.
3.1 General The overall Quality Assurance Program for Operation shall be conducted in accordance with the three levels of responsibility: Work Performance and Quality Control, Management / Supervision Oversight, Quality Assurance Audit / Surveillance.
Table 2 def'mes the three levels of Quality Assurance as they are to be implemented for station operation. The three level concept is applicable to all safety related activities conducte.1 at Cooper Nuclear Station.
It is intended that clearly separate lines of responsibility be maintained between those responsible for the operation of Cooper Nuclear Station and those responsible for Quality Assurance oversight to verify that all quality and licensing requirements are consistently being met. QA responsibilities will vary depending upon the type of activity involved (See Section 4.1.3). Additional details on individual QA responsibilities are given in the paragraphs which follow, together with additional explanation of the interrelationships between the various supervisors and managers involved.
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3.2 Nuclear Power Group Management Management responsibilities include assuring that activities under their control are conducted in accordance with the CNS Quality Assurance Program for Operation.
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- This includes but is not limited to timely responses to QA Division Audit and i
Surveillance findings and implementation of appropriate corrective actions.
The responsibility and authority over the Safety Review and Audit Board has been delegated to the V. ice President of. Nuclear Energy;.
3.2.1 Senior Vice President of Energy Sunnly The Senior Vice_ President of Energy Supply, under the direction of the President /CEO - NPPD is the responsible executive officer for all CNS Quality Assurance related activities. Responsibility includes the implementation of quality assurance activities governing those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The Senior Vice President of Energy Supply, reserves the authority to conduct, or order the auditing or monitoring of any operations activity, at any time, to ascertain the effectiveness of the overall QA Program and to determine that all aspects of the QA Program are being complied with.
3.2.2 Senior Manneer of Ouality' Assurance l
1 The Senior. Manager of. Quality Assurance, a member of the executive staff, reporting to the Senior.Vice President of Energy Supply, shall have the responsibility and authority for administrating and maintaining a Quality Assurance Program for Operation in accordance with 10CFR50, Appendix B. Inherent in this responsibility 3-2 Revision 14
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is the authority to accept or reject any or all work, materials or equipment associated with Cooper Nuclear Station. The Senior Manager of, Quality Assurance.shall direct the preparation of plans and procedures for defining the Quality Assurance functions associated with Cooper Nuclear Station to ensure that such activities are conducted in accordance with the Operating License and appended Technical Specifications. He shall also approve all plans and procedures for defining and auditing the safety-related activities within the Cooper Nuclear Station and General Office. The actual audit functions to be performed are defined more completely by the body of Nuclear Quality Procedures, and Quality Assurance Plans required by Section 4.0 of this policy document. He shall also have administrative responsibility for evaluating g suppliers of nuclear safety-related equipment, materials, and spare parts and for auditing the QA/QC activities of such suppliers.
The Senior Manager of, Quality; Assurance and Staff shall have the necessary organizational freedom and access within the Nuclear Power Group to institute the necessary Quality Assurance requirements, identify problems, and pursue prompt corrective action. Figure 1 outlines the QA Division functional organization.
, The Senior Manager of Quality Assurance shall monitor the Quality Assurance l
activities to the extent necessary for assuring compliance with the program. He shall review the effectiveness of the Quality Assurance Program with the Senior Vice President of Energy Supply on a regular basis. In addition, the Senior Manager of Quality _ Assurance has a direct line of communication with the President and C.E.O.
He shall serve as a member of the Safety Review and Audit Board and provide additional QA Personnel to participate in SRAB activities when requested.
NPPD Quality Assurance Staff, under the direction of the Senior Manager of Quality.
Assurance, shall have the responsibility and authority for implementation and ongoing development of the Quality Assurance Program for Operations. In addition, 3-3 Revision 14
it shall be the responsibility of the Quality Assurance Division to monitor the l interface between the Nuclear Power Group Divisions to evaluate the effectiveness of 1
management to implement interdepartmental activities affecting quality.
Unless otherwise provided for in writing, the QA Operations Manager or the QA l Assessment Manager (depending on their availability) shall function as the Senior Manager of, Quality Assurance in his absence.
As shown in Table 2, he shall have responsibility for accomplishment of third level QA Audits and shall obtain assistance and special expertise when necessary to complete such audits effectively.
l 3.2.3 Ouality Assurance Operations Mananer The Quality Assurance Operations Manager, reporting to the Senior. Manager.of Quality' Assurance, shall have the responsibility and authority for implementing and maintaining the Quality Assurance Program for Operation as described herein.
l He shall be responsible and have the authority to perform, direct, or coordinate l l
Audit activities / programs within the Nuclear Power Group. QA review of the j design and engineering functions within the NPG, including configuration management shall be included in such programs. These activities / programs shall 1
determine if conformance with the CNS QA Program for Operation and applicable federal regulations as defined in the QA Policy Document are being maintained. !
l The QA Operations Manager shall advise and assist Senior Management and their staff in all matters which affect the quality of the station. Similarly, he shall advise and assist all station personnel in matters regarding Quality Assurance and Quality Control.
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l 3-4 Revision 14 l
i In addition, the QA Operations Manager shall ensure that training programs and instruction are provided for QA Operations personnel to enable them to effectively )
execute and monitor the Quality Assurance Program for Operation.
The QA Operations Manager shall designate members of the QA Operations Staff upon request to provide training and instruction programs to enable CNS personnel to effectively execute the District QA Program.
The QA Operations Manager is also responsible for monitoring of open audit items and interface with NRC during inspections at CNS. In addition, he shall also be responsible to verify that solutions to safety-related problems have been implemented and to perform scheduled audits of those activities as defined in Quality Assurance l Plans. Additional specific duties shall be defined in the Nuclear Quality Procedures and Quality Assurance Plans, issued in accordance with Section 4.0 of this Policy Document.
The QA Operations Manager or designee shall also serve as a non-voting member of the Station Operating Review Committee (SORC).
The QA Operations 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 recommend that work stop when such activity, in their opinion, does not comply with approved controlling documents. The Vice President'of Nuclear Energy,or designee is responsible to act on that recommendation and actually stop work unless it is 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.
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I The QA Operations Manager will provide for a coordination function for QC activities at CNS. This includes development and maintenance of program procedures, 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.
The Quality Assurance Operations Manager shall have the responsibility and .
authority for the controlling, administrating, distributing, and coordinating changes and revisions to the Quality Assurance Program for Operation, subject to the requirements of Section 4.0 of the Policy Document. j During absence of the QA Operations Manager, an individual from his staff will be designated to act on his behalf. A designated Quality Assurance representative will l attend SORC meetings on behalf of the QA Operations Manager during such i absences.
1 3.2.4 Ouality Assurance Assessment Manager The Quality Assurance Assessment Manager, reporting to the Senior Manager of Quality l Assurance, shall have the responsibility and authority for implementing and maintaining the Quality Assurance Program for Operation, as described herein.
This responsibility includes the authority for implementing and maintaining the QA Surveillance Program and the program for evaluating suppliers for safety-related equipment, materials, spare parts, and services, and for auditing the QA/QC activities of such suppliers.
The QA Assessment Manager shall advise and assist Senior Management and their staff in all matters which affect the quality of the station.
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The QA Assessment Manager and Staff shall have the responsibility for providing
! guidance to NPG personnel in all matters affecting quality. They shall also establish 1
and implement the program for evaluating suppliers for safety-related equipment, l materials, spare parts, and services. Additional duties are defined in the Nuclear Quality Procedures and Quality Assurance Plans.
l l The Quality Assurance Assessment Manager is responsible for interface, along with the Senior Manager of Quali,ty; Assurance, with NRC inspections conducted within the NPG. j l In addition, the QA Assessment Manager shall ensure that training programs and 3
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instruction are provided for QA Assessment and QA Supplier personnel to enable them to effectively execute and monitor the Quality Assurance Program for Operation. 1 l
l l l 3.2.5 Ouality Assurance Sunervisors l
The Quality Assurance Supervisors report to the applicable QA Manager and are !
- responsible for the performance of work activities assigned. They are responsible to l
l direct the performance of QA activities, and to identify any condition adverse to 1
quality to the appropriate QA Manager. The QA Supervisors are responsible for the continued maintenance and upgrading of QA Program Documents.
3.2.6 Ouality Assurance Staff Ouality Assurance Assessment Staff The Quality Assurance Assessment Staff, reporting to the QA Assessment Manager, shall be responsible to assist and advise the QA Assessment Manager in all matters 3-7 Revision 14
which could affect Quality Assurance activities within the NPG. This includes advising and assisting personnel in all matters regarding Quality Assurance, and verification that solutions to safety-related problems have been implemented. The QA Assessment Staff shall assist with performance of internal audits upon request, as agreed between the QA Assessment Manager and the QA Operations Manager.
The QA Assessment Manager has designated the QA Supplier Supervisor and Staff the responsibility for the ongoing development and implementation of the supplier evaluation program; review of procurement specifications and associated drawings to determine if special requirements such as codes, standards, materials, tools, and inspections, etc., are properly included. Responsibility for establishing and maintaining processes for the conduct of surveillances has been delegated to the QA
. Assessment Supervisor.
Quality Assurance Operations Staff The Quality Assurance Operations Staff shall be responsible to assist and advise the Quality Assurance Operations Manager, and other Nuclear Power Group personnel in all matters affecting the quality of the station. These duties include verification that solutions to safety-related problems have been implemented, and performance of QA activities (audits and surveillances) within the NPG on an announced or unannounced basis. Responsibility for administering the internal audit program has been delegated to the Quality Assurance Audit Supervisor.
Ouality Assurance Programs Supervisor The Quality Assurance Programs Supervisor shall be responsible for administering and documenting the controlled QA program document distribution. This position is responsible for preparation and processing of procedures for the Division and those I
3-8 Revision 14
I pertaining to the Quality Control Program. Additional specific duties shall be as defined in the Nuclear Quality Procedures, and Quality Assurance Plans issued in accordance with Section 4.0 of this policy document.
l Resolution of Disagreements l
l Disagreements or differences of opinion on Quality Assurance matters are expected to be documented and resolved jointly by both Quality Assurance Staff and line personnel. Where such resolution is not achieved within a reasonable period of time, unresolved differences shall be promptly reported to the appropriate Quality Assurance Manager for resolution jointly with the Senior Manager of. Quality 1
l Assurance and Senior Management personnel, as appropriate.
3.2.7 Vice President of Nur1*ar Energy The ,Vice President of Nuclear Energy and his staff, under the direction of the Senior l Vice _ President of Energy Supply, shall be responsible and have the authority for l assuring the 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 defined in I lower tier documents such as NQPs, QAPs, NPG Directives, etc. Training and l
Nuclear Licensing and Safety activities report directly to the VP of Nuclear Energy..
l l At timestthese responsbilities may be functionally. delegated to the. Senior Manager level;or abovei l
l 3.2.87 _ General Manneer of Technical Services The General Manager of Technical Services reports.directly to the Vice President of Nuclear Energy and is responsible for all Engineering and Materials Services activities; 3-9 Revision 14
l 3.2.9 Plant Manaoer ]
The Plant Manager under the direction of the Vice President of Nuclearjpergy, has overall responsibility for plant Operations, Maintenance, Radiological, Performance Analysis land Scheduling department functions. The Plant Manager shall regularly review the activities of those areas for which he is responsible for the purpose of l
i keeping abreast of significant quality activities.
I 3.2.10 hatar M-oer of Safarv Accaeamanusite Sunnort l
The Senior; Manager of SafetyfAssessment/ Site Support, under the direction of the ;
1 Vice President of N,uclear Energy, has responsibility for CNS activities associated j with Site Security, Administrative Support, Accounting, and Emergency i Preparedness. The Senior Manager of Safety Assessment / Site Support shall regularly review the activities of those areas for which he is responsible, keeping abreast of significant quality activities and oversight activities related to Nuclear Safety at CNS. This position provides the management focal point for Nuclear Safety at CNS.
I 3.2.11 Senior Mananer of Engineering l
The Senior Manager of Engineering, under the direction of the General Manager _of Technical Services shall be responsible for Station Engineering and 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 be audited periodically by Quality Assurance Staff aud quality-related problems shall be identified and reported to appropriate levels of management for resolution. The Quality Assurance Staff will perform the necessary follow-up action to assure that 3-10 Revision 14
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corrective action is implemented in a timely manner. For those aspects of Fuel Management covered by the QA Program, the Senior Manager of Engineering shall be responsible to furnish technical assistance as required to the Plant Manager and the QA Staff. Such assistance shall not replace or supersede the formal audits.
3.3 Cooper Nuclear Station Personnel The operational duties and responsibilities of the Cooper Nuclear Station personnel are described in the CNS Procedures Manual, Reference 7.5. In addition, the Cooper Nuclear Station personnel are assigned Quality Control inspection functions.
Station personnel, under the direction of the Vice President of Nuclear Energy and his staff, are responsible for assuring that the station is tested, operated, maintained, and modified in accordance with approved plans and procedures.
3.4 Safety Review and Audit Board The Safety Review and' Audit Board (SRAB) has been established to provide independent review and audit of designated activitiesli 1);fMembership; a.l Chairman 1
- b. _ ' Vice-Chairman c; Five Members d; 7 Consultants (as required)
The Board members shall collectively have the' capability required to review problems in the following areas: nuclear. power plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, instrumentation and control, radiological safety, mechanical and electrical engineering, quality assurance practices, and other appropriate fields' associated with the unique characteristics of 3-11 Revision 14
the nuclear _ power plant involved. When the nature of a particular problem dictates,(
special consultants will be utilized.'
Ahernate members shall be appointed.in writing by.the Board Chairman to serve'on a temporary, basis; however, no more than two alternates'shall' serve on the Board at any,one time.i i
l 2; Meeting frequency: Semiannually, and as required on' call of the Chairman.
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- 3. ; Quorum: Chairman or Vice. Chairman, plus four members including alternates.' j i
l No more'than a minority of the quorum shall be from groups holding line responsibility for the operation of the plant; 1
l 4.' Review; The following. subjects shall be reported to and reviewed by the NPPD l Safety. Review and Audit Board!
l
- a. 3 The. safety evaluations for 1) changes to procedures, equipment or systems i and 2) tests or experiments completed under the provision of Section 50.59,;10 CFR; to verify _that such' actions did not constitute an l
unreviewed safety question.
- b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety. question as defined in Section 50.59,10 CFRr c! j Proposed tests or experiments which involve an unreviewed safety.
question as defined in Section 50.59; 10 CFR.
- d. . Proposed changes to Appendix A Technical Specifications or the CNS Operating License.
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e2 Violations of applicable codes,; regulations, orders, Technical Specifications l; license requirements, or internal procedures or instructions having nuclear safe.ty; significance:
l f.': ;Significant ope. rating abnormalities,or deviations from normal and expected performance of plant equipment that could affect nuclear safety.-
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- g. TA.ll reportable events specified in Section 50.73.10.10 CFR Part 50?
h.E TAny indication.of an unanticipated. deficiency in some aspect of design or operation of safety.related structures, systems, or components:
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i.. _ ? Minutes of meetings of the Station Operations Review Conunittee.
J. S Disagreement between the recommendations of the Station Operations Review Committee'and the SORC Chairman.
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- k. ' Review of events covered under e, f, gs and h above. include reporting to appropriate members of management on the results of investigations and recommendations to preyent or reduce;the.probabilify of recurrence?
- 1. ' Detect trends that may not be apparent to a day-to-day observer; i
! 5. Authority: The NPPD Safety Review and Audit Board shall report to and be 1
l advisory to the Vice. President of Nuclear Energy on those areas of responsibility.specified in Section 3;4.4 and audit responsibilities specified in Section 2.18.of this' standard l i
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6/f Records! ; Minutes shall be recorded for all meetings of the NPPD Safety, Review! and' Audit Board and shall identify all documentary material reviewed.. ,
Copies of the minutes shall be forwarded.to the Senior Vice President of Energy. !
SupplyLVice President of Nuclear Energy, the Plant Manager, and such others '
as the. Chairman may designate within one month.of the meeting; 3.5 Station Operations Review Committee The Station Operations Review Committee (SORC) has been established to advise the Plant Manager in all matters regarding operational safety.
The organization and duties ~of. committees for the review and audit of station operation shall be as outlined belov(:
1 SORC,shall have a minimum of eight voting members comprised of the following:
a._ . Chairman: Plant Manager or alternate l
- b. Individuals from the following disciplines: ;
.- _ Operations
.- _ Radiological (Chemistry / Health Physics)
LMaintenance i , Engineering s; ; Reactor Engineering O Instrumentation and Control 3-14 Revision 14
The above, according to individual job _ title [shall meet the requirements as described in Sections 4.2,4.3:1s or 4.4 of the American' National Standards Institute N-18.1:
1971E" Selection'and Training of Personnel for_ Nuclear Power. Plants",'or Regulatory.. Guide 18,' revision 2,_" Qualification and Training of Personnel for.
Nuclear Power Plants", as stipulated in Section 2.2 of this standard; Non-voting members may also serve on SORC to broaden its expertise in other areas (e'g. Quality Assurance):
All alternate members shall be. appointed in. writing by;the.SORC Chairman to serve on a temporary basis; _however, no more. than two alternates shall participate as voting members in SORC at any one time; 2.; - Meeting Frequency; Monthly, and as required on call of the Chairman!
3; 1Quorumf SORC Chairman plus such.a number as to constitute a majority of the _
voting members: 4 4; Responsibilities:
- a. 'n Review all proposed normal, abnormal, maintenance, and emergency operating procedures specified below,;and proposed changes thereto, and any.other proposed procedures or changes thereto' determined by any member to effect nuclear safety;
- 1) The applicable procedures recommended in Regulatory Guide 1.33, Revision 2,[ Appendix A, February 1978; 3-15 Revision 14
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2)DThe emergency operating procedures. required to. implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1; as l l
stated in Generic Letter 82-33;~ j 1
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3)T;;Thel procedures that implement _the quality assurance program for.
l radioactive effluent and radiological environmental monitoring; i
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4); Fire Protecti_on Program . imp.lementation procedures; I
- 5) L ' Implementing procedures of the Safety Plan _and Emergency Plan; 6); ? Administrative procedures for shift overtime; and l
7); ;The procedures that implement all programs specified. in. Technical Specification 5.5:
- b. ". Review all proposed; tests and experiments and their results, which involve nuclear hazards not previously reviewed for conformance with Technical Specificationsn Submit _ tests.which;may constitute an unreviewed safety, question. to the NPPD Safety Review and Audit. Board for review!
- c. ~ Review proposed changes to Technical Specifications.-
d.: , L Review proposed changes or modifications to station systems equipment as discussed in the'USAR or which involves an unreviewed safety . question as defined.in 10CFR50.59(c). Submit changes to. equipment or systems having~ safety significance to the NPPD Safety Review and-Audit Board for review.-
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- e. _ Review station operation to detect potential nuclear safety hazards.
- f. Investigate all violations of Technical Specifications, including reporting evaluation and recommendations to prevent. recurrence, to the Senior Vice President of Energy.. Supply and to the Chairman of the NPPD Safety Review and Audit Board;
- g. JPerform special reviews and investigations and render reports thereon as requested by the Chairman of the Safety Review and~ Audit Board:
- h. . Review all reportable events specified in Section 50.7_3 to 10 CFR Pan 50 and submit results of this review to SRAB and the Senior Vice President of Energy Supply.
- i. : Review drill _s on emergency procedures. (including plant evacuation) and adequacy of communication with off site groups.
- j. . Periodically review procedures specified in Section 3.5.4.a of this standard as' set forth in administrative procedures.
- 5. " Authority a; The Station Operations Review Committee shall be advisory,
- b. ~ The Station Operations Review Committee shall recommend to the SORC Chairman approval or disapproval of proposals under items 4, a through e and j above.;In case of disagreement between the recommendations of the '
Station Operations Review Committee and the Plant Manager, the course determined by the. Plant Manager to be more conservative will be 3-17 Revision 14
I followedtfA; written summary of the disagreement will be sent to the _Vice President of Nuclear Energy,. Senior Vice President of Energy. Supply, and to,the NPPD, Safety.. Review and' Audit' Board.1 l
- c. The. Station Operations Review Committee shall report to the Chairman of ,
the.NPPD Safety Review and: Audit Board;on all. reviews and 1
investigations l conducted under items 4.f,14.g;'4.h, and 4;i, above.
- d. The. Station Operations Review Committee shall make determinations regarding whether or not proposals considered by the. Committee involve unreviewed safety. questions: This determination shall be subject to review .
1 by,.the_NPPD Safety-_ Review and Audit Board.'
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- 6. ~ Records:
Minutes shall be kept for all meetings of the. Station Operations Review Co_mmittee and shall include identification of all documentary material j reviewed. Copies of the minutes shall be forwarded to the Chairman of the NPPD Safety Review and-Audit Board and the Senior Vice President.of Energy.
Supply.within one month:
- 7. : Procedures:
Written procedures _for _ Committee operation shall be prepared and maintained describing.the method of submission and content _of presentations to the committee, proyisions for use of subcommittees,1 review and approval by members of written Committee evaluations and recommendations, dissemination of minutes, and such other matters as may be appropriate.-
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3.6 Outside Supoliers. 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 Nuclear Power Group 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 l
l and instructions. In those instances in which outside suppliers, contractors, and
- subcontractors are assigned primary responsibility for a particular activity, such 1
outside contractor shall be required to maintain a Quality Assurance and Quality Control Program and organization appropriate to the work to be performed. All l
suppliers, contractors, and consultants performing work classified as essential shall 1
be maintained on the appropriate section of the CNS Approved Suppliers List.
I Selection of outside suppliers or contractors shall require the active participation of I l the Quality Assurance Division in evaluating and approving their Quality Assurance l l
Program. !
In every instance in which outside contractors have responsibility for work at CNS on safety-rnated nuclear systems, they shall be contractually required to work to l
l procedurea approved by the District's Station Operations Review Committee.
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.
In addition, any outside contractor performing work at Cooper Nuclear Station under their own quality assurance program shall be contractually required to 3-19 Revision 14
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i prepare, prior to performing the work, a Project QA Plan specific to the work to be performed at the Station. )
1 Contractors and consultants performing safety-related work under the District's l Quality Assurance Program shall be contractually required to perform the work l
under District supervision and in accordance with the CNS Quality Assurance l
Program for Operation. District personnel responsible for such work shall assure that contractor / consultant personnel are qualified to do the work and have been -
provided formal instruction in quality assurance. Additionally, any calibrated tools l
and equipment provided by the contractor shall be recalibrated at Cooper Nuclear l Station or by a District approved source, prior to use.
If any portion of work on safety-related nuclear systems is to be subcontracted, the prime contractor shall impose the appropriate QA requirements on the subcontractor.
NPPD QA 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 performing work at Cooper Nuclear Station which affects safety-related equipment, outside suppliers, contractors, consultants, and selected representatives from the NPPD Nuclear Operation and Nuclear Engineering Divisions shall jointly develop and enforce written agreements and/or procedures which clearly define the limits of the work; interface between contractor and station personnel; 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 Division to ensure compliance with applicable Quality Assurance Program requirements, l
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At all times when outside suppliers, contractors, and consultants are obtained to assist in the execution of this QA program, the responsibility for effectiveness of
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4.0 OUALITY ASSURANCE DOCUMENTS l
The CNS Quality Assurance Program is defined by written policies, procedures, and plans which shall be implemented throughout the operating life of the station.
4.1 NPPD Internal Documents Work procedures are based on the requirements of the Quality Assurance Program.
Preparation and maintenance of basic work procedures is performed by engineering and operating groups, separately from the Nuclear Quality Procedures and QA Plans.
Mandatory QC checkpoints shall be incorporated directly in or attached to, the work procedures to facilitate coordination between the specific work activity and the Quality Control function. The applicable criteria of 10CFR50 Appendix B shall be incorporated into the basic work procedures as they are initiated and implemented.
Such initiation and use by the line organization shall be consistent with responsibilities ,
as described by the Three Level Quality Assurance Program (Table 2). The Quality Assurance organization shall provide independent oversight of work procedures randomly, periodically, and situationally, at any stage of procedure generation, implementation, or closeout.
The format and content of NQPs and QAPs, shall be as specified by a Quality Assurance Procedure. Significant changes shall be reviewed and approved by the same levels of management as for the original document. Each change, when approved and issued, shall be distributed through a controlled distribution system.
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 record shall clearly show the nature and extent of the change and the reason for requiring such change.
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l 4.1.1 Ouality Control Inspection I
The Quality Control inspection function shall be performed by individual (s) other than those who are actually performing the step (s) being inspected or who are providing direct, hands-on, at-the-job supervision. The Cooper Nuclear Station management, as part of their normal management function, are responsible for implementation of the Quality Control requirements of the Peer QC program; however, the QA Operations Manager is responsible to review and accept control methods prior to implementation.
Quality Assurance Management, working with NPG Management, shall verify that adequate Quality Control inspections are incorporated directly in, or I
attached to, the work procedures and shall periodically inspect work performance to assure that the procedures containing Quality Control inspections are being followed. The QC Program 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:
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- 1. Identity of the inspector or data recorder. !
- 2. Type of inspection or verification. 1
- 3. Results (data to be recorded).
- 4. Acceptance (qualitative or quantitative) criteria.
- 5. Method of disposition of unsatisfactory inspection results.
- 6. Reporting requirements.
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I In addition, clear instructions shall be given regarding the timing, frequency or scheduling, and notification requirements for such inspections so as to obtain i l
maximum effectiveness and to minimize delays in completion of the work. 1 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.
Routine maintenance and repair of essential systems and components generally requires performance of a complete or partial Surveillance Procedure prior to i 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 i
by the individuals who performed the maintenance activity. Records of the surveillance will be reviewed by the system engineer or other supervisory /
management personnel.
4.1.2 Nuclear Ouality Procedures (NOP) l The Quality Assurance staff shall prepare NQPs approved by the Senior Manager.of Quality l Assurance and the Senior Vice President of Energy Supply.
As described in Section 1.5 of this document, NQPs define Quality Assurance l activities and responsibilities which cross divisional boundaries. When approved, NQPs become a part of the CNS Quality Assurance Program for Operation.
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l 4.1.3 Ouality Assurance Plans (OAP) .
QAPs shall be developed which encompass those functional areas described within, defining the scope of the QA program. Quality Assurance Staff shall I i )
develop QAPs as needed. As described in Section 1.5 of this document, these l
l QA Plans outline specific Quality Assurance activities and shall become a part of the CNS Quality Assurance Program for Operation. Distribution of these l Plans will be to those individuals who are responsible for that particular activity.
The format and content of QAPs shall be specified in a NQP to provide j uniformity and to assure that each plan is complete and adequate for the intended purpose.
l The QAPs shall be prepared by the Quality Assurance Staff and shall be
! reviewed and approved by the Senior Manager of Quality' Assurance. In l addition, when significant changes have been made to these documents, the l QAP will be routed to affected Senior Management personnel for review and j comment.
l The QAPs shall define the specific work which is to be subjected to Quality Assurance review, surveillance, and audit, and the manner in which such review, surveillance, and audit is to be implemented.
Checklists shall be prepared per the guidance provided in Nuclear Quality Procedures, defining the scope of QA Surveillance or QA Audit activities.
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a) Ouality Assurance Surveillance l
The Quality Assurance Surveillance function is intended to provide an independent verification, on a continuing basis, that work is being performed in accordance with the requirements of the controlling documents. Such surveillances may be performance-based or compliance oriented depending on the nature of the function being evaluated. The Quality Assurance Surveillance activities are not intended to duplicate QC inspection activities, however, duplication may occur, in the effort to satisfy both Quality Assurance Surveillance and Quality Control j requirements.
l The objectives of Quality Assurance Surveillance are to verify that the Quality Control inspection program is being effectively implemented; that personnel performing Quality functions are properly qualified; that i I
adequate information is recorded to provide a complete and accurate quality history; and that deficiencies are identified, corrected, recorded, and corrective action is taken to prevent recurrence.
This philosophy .shall be taken into account in the conduct of Quality I Assurance Surveillance _ activities. QA~ Surveillance shall be as prescribed in NQPs and QAPs. The timing, frequen.cy, or schedule for the j surveillance shall be coordinated with the work being evaluated to ensure I
maximum effectiveness _with mmimum impact on the progress of the work.;
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b) Ouality Assurance Audits A comprehensive system including planned and periodic audits and audits l selected based upon indication of performance problems shall be l
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l implemented to verify compliance with all aspects of the Quality Assurance Program and to determine the effectiveness of the program.
The audits shall be performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities for the work being audited. Depending on the nature of the function being audited, the audits are conducted in a performance-l based manner to the maximum extent practical. The audits are i
supplemented by performance-based and compliance oriented surveillances. Quality Assurance Management shall have the responsibility and authority for implementation of the Quality Assurance activities to l
l audit programs defined by approved QAPs. However, the SRAB, or any l manager or executive in the chain of organization above the NPG Senior Managers, or above the Quality Assurance Supervisors and Managers may initiate and carry out special Quality Assurance Audits within the guidelines provided by this Quality Assurance Program. Audit results shall be reported in writing to the NPG Management in accordance with the requirements of NQPs and the results shall be reviewed with the Management responsible for the area of activity audited. Appropriate follow-up action shall be taken and documented as directed by the appropriate Quality Assurance Manager or Supervisor.
Audit Scoping Plans (ASPS) provide detail description of the scope within an audited area. NQPs describe the frequency of required audit activities, and provide guidance for audit schedules and reports.
Each ASP will be implemented through the use of an approved checklist.
On the basis that some Quality Assurance Audits are to be conducted or l
directed by management, it is essential to maintain a high degree of flexibility in the manner of conducting an audit. It is intended that the i
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ASPS provide audit guidelines to assure that areas to be audited are I l suiliciently defined in advance and that audit personnel are adequately prepared to make a meaningful audit with a minimum of interference with l 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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1 5.0 METHOD OF IMPLEMENTATION The Quality Assurance Program for Cooper Nuclear Station is implemented by the development and implementation of procedures, by management attention and oversight, and by critical assessment and overview by Senior Management and independent groups.
i The detailed methods of implementation shall be as provided for in written and approved procedures prepared in accordance with Section 4.0.
The Quality Assurance Managers or designees shall periodically, randomly, and situationally review and conunent on the NPG procedures to ascertain that necessary quality requirements are included. Problems identified by such review of procedures by Quality Assurance, will be communicated to the line organization in a timely 1
manner for correction. Differences of opinion on QA comments shall be resolved as indicated in Section 3.2.6.
Situational and periodic review of procedures by Quality Assurance will consider compatibility of lower tier procedures with requirements and conunitments of higher level documents.
1 Management is responsible for assessment of the effectiveness of implementation of program elements within their assigned areas, and for timely and effective resolution of conditions adverse to quality.
l Quality Assurance Division activities shall be coordinated with the SRAB and SORC.
Such activities shall be conducted in a manner and on a schedule to assure organization, supervision, communications, and technical and administrative practices l
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l clearly provide or smooth, orderly, controlled, and safe execution of all safety-related i functions.
Written reports of all QA activities, including descriptions of deficiencies and resolution thereof, shall be incorporated into the official QA file. Corrective action on i l deficiencies shall include resolution of the specific deficiency and verification that l
corrective action has been implemented to prevent occurrence of similar deficiencies in the future. A report of QA Audits performed (internal and external) shall be submitted i
l to the Senior Vice President.of Energy Supply by the Senior-Manager of Quality, l
l Assurance annually.
I The Quality Assurance Staff shall maintain an up-to-date summary of the CNS Quality Assurance Policies, Procedures, and Plans, showing how this QA Program for l Operation implements the NRC guidelines contained in 10CFR50, Appendix B. l l
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6.0 RECORDS RETENTION AND DISPOSITION Instructions have been prepared by the responsible organizations to provide guidelines for CNS and CGO record retention and disposition in accordance with this policy document and applicable regulatory criteria. As a minimum, these procedures cover l
the following:
l a) Records content and location; b) Principal location from which records are to be controlled; 1
1 c) Complete records inventory and master index; l
d) Conditions of storage, access, and security; e) System of records identification, retrieval, and control; l
f) System of records transfer and disposal.
Quality Assurance records (reference 7.9) will be entered into the controlled records system per the requirements of station procedure and ANSI N45.2.9 - 1974.
l 6.11 ~ 5 Year Retention Records and/or logs relative to the following items shall be kept in a'. manner convenient for review and shall.be retained for at least 5 years unless a longer period is I
required by.. applicable regulations.
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e a); ~ 1 Records lof normal station operation, including power levels and periods of operation at each power. level i
b)l Records of periodic checks l inspection and/or calibrations performed to verify that Surveillance Requirements are being met; c); ; . Records .of princip.al maintenanc.e activities, including inspection, repair, I substitution, Tor replacement of principal items of equ_ipment pertaining to nuclear safety; d) Records,of reportable events as specified in Section 3.5.4.h; l
e) ' : Records of changes _to plant proceduresi l
f) . : Records ~of special tests and experiments; g);. Records of_ wind . speed and direction.'
l 6.21 ; Life Retention Records and logs relating'to the following items shall be kept for the life of the plant:~
a)' f Records of changes made to the_ station as described'in the Safety Analysis l
Report and amendments and reflected in updated, corrected, and as-built l
l drawings and records; b). 1 Records of new and spent fuel inventory and assembly histories, c).: Records of. station radiation and contamination surveys.
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f d)j J Records of off-site environmental monitoring surveys.
e); ' Records. of radiation exposure for all station personnel, including all contractors and visitors to the station in accordance with 10 CFR 20.'
f) . , ERecords'of radioactivity.in liquid and gaseous wastes released to.the environment; g).; ; Design Fatigue Usage Evaluation l 1. . ' Monitoring, recording, and evaluation.will be met for various portions of the reactor coolant pressure boundary (RCPB) for which detailed fatigue usage evaluation per the ASME. Boiler and Pressure', Vessel Code Section IIIyas performedifor the. conditions defined in the design . specification.
The' locations to be monitored shall be:
l l a).( The .feedwater nozzles
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l b) The shell at or near the waterline, 1
I l c). The . flange studs
- 2. EMonitoring, Recording, Evaluating, and Reporting a); l Operational transients that occur during plant operations will, at least annually, be. reviewed and compared to the transient conditions !
I defined in the component stress report for the locations listed in 1 !
above, and used as a basis for the existing fatigue analysis.:
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- 1. See, paragraph N-415.2,~ASME Section III,;1%5_ Edition b); 1The number of transients which are comparable to or more severe 1
than the transients evaluated in the stress report Code fatigue usage calculations will be recorded.in an operating log boot. : For those 1
transients which are more severe ~ available data, such as the metal 1
and fluid temperatures l pressures, flow- rates, and.other. conditions will be recorded in the log book -
I c); l The. number of transient events that exceed the design specification quantity and the. number of transient e. vents _with a severity greater than that included in the existing , Code fatigue usage calculations shall be added. When this, sum exceeds the predicated number of design condition events by twenty five2,'a fatigue usage evaluation of such events will be performed for the.affected portion.of the RCPB.
h); Records .of current individual plant staff members. showing qualifications and the' completion of training.
i) . . Records ~of Environmental. Qualification.-
j): , Records of the service lives of all hydraulic and mechanical snubbers noted in Technical Requirements Manual T3.7.3, including the date at which the service life commences and associated. installation and maintenance records.
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2." . .y fThe code rules permit exclusioniof twenty-five (25) stress cycles from secondary stress and fatigue usage evaluation.;(See paragraphs N-412(t)(3) and, N-417.10(f) of the Summer;1968l Addenda to~ ASME Section III,1%8 Edition.)
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7.0 REFERENCES
l The following documents were used in the preparation of the Quality 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.
l 7.1 Quality Assurance Criteria for Nuclear Power Plants 10CFR50, Appendix B (USNRC).
l 7.2 Standard of Administrative Controls for Nuclear Power Plants, American National Standard ANSI 18.7 - 1972.
7.3 Updated Safety Analysis Report, Cooper Nuclear Station, Nebraska Public Power District (NRC Docket 50-298).
I 7.4 Environmental Report--Operating License Stage, Cooper Nuclear Station, Nebraska Public Power District (NRC Docket 50-298).
7.5 Cooper Nuclear Station Procedures Manual.
1 7.6 Safety Rules, Nebraska Public Power District ,
l 7.7 Safety Guides for Water-Cooled Nuclear Power Plants (USNRC), as appropriate.
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l l 7.8 Quality Assurance Requirements for Nuclear Power Plants ANSI N45.2 - 1977.
7.9 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records l for Nuclear Power Plants ANSI N45.2.9 - 1974 1
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l l 7.10 Quality Assurance Terms and Defm' ilions ANSI N45.2.10 - 1973.
l 7.11 Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.11 - 1974.
7.12 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants ANSI N45.2.12 - 1977.
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7.13 Supplementary Quality Assurance Requirements for Control of Procurement of l
t Equipment, Materials, and Services for Nuclear Power Plants ANSI N45.2.13 - 1976.
l 7.14 CNS Technical Specifications.
7.15 ANSI N45.2.23-1978 " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" l
7.162 (ASME Section III,1%5 Edition, paragraph N-415.2.
l 7.17lf Summer;19681 Addenda to, ASME Section III,;1968 Edition,; paragraph N-412(t)(3); and l N-4,? "'.1_0(f);
7;18hCNS Technical Requirements Manual.
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l TABLEI SYSTEMS AND COMPONENTS WITHIN THE SCOPE OF THE OUALITY ASSURANCE PROGRAM I. NUCL EAR STEAM SUPPLY SYSTEM A. Reactor Primary Vessel B. Reactor Primary Vessel Supports C. Control Rods and Drive System Equipment Necessary for Scram Operation D. Control Rod Drive Housing E. Fuel Asser.iblies l
F. Core Shroud G. Steam Dryer H. Steam Separator l
II. REACTOR COOLANT SYSTEMS A. ADS - Automatic Depressurization System B. HPCI - High Pressure Coolant Injection System C. LPCI - Low Pressure Coolant Injection System 1
1 D. CS - Core Spray System E. RCIC - Reactor Core Isolation Cooling III. REACTOR PROTECTION AND ENGINEERED SAFEGUARD SYSTEMS l
l A. Reactor Protection System l
B. Standby Liquid Control C. Standby Gas Treatment D. Diesel Generators l
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1 Table 1 (Cont'd.)
E. Electrical Aux Power
- 1. Critical 4160 V Equipment
- 2. Critical 480 V Equipment l
l F. Neutron Monitoring Systems
- 1. APRM - Average Power Range Monitor
- 2. IRM -Intermediate Range Monitor
- 3. LPRM - Low Power Range Monitor
- 4. RBM - Rod Block Monitor ,
- 5. SRM - Source Range Monitor
- 6. TIP - Traversing In Core Probe
! G. DC Power Supply ,
I H. Nuclear System Leak Detection i I. Containment Isolation System 1
! J. Nuclear Boiler and Related Instrumentation K. Primary Containment L. 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 l
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r Table 1 (Cont'd.)
V. RADIOACTIVE WASTE DISPOSAL SYSTEMS A. Process Radiation Monitoring System l
- 1. Off-Gas Radioactivity Monitoring l 2. Main Steam Line Monitoring
- 3. Reactor Building Vent Monitoring (GE)
- 4. Drywell and Suppression System Leak Rate
- 5. Liquid Process Radiation Monitoring B. Radioactive Waste Processing System
- 1. Dewatering System l
- 2. Radioactive Waste Shipping i
VI. OTHER SUPPORT SYSTEMS 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 I, II, and III Code Items F. Reactor Feed Pumps (Pressure Retaining Parts Only) l G. Reactor Building H&V H. Fire Protection I. Security J. Instrument Air l
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I Table 1 (Cont'd.) i l
VII. STRUCTURES (SEISMICS)
A. Reactor Building B. Control Building l C. Elevated Release Point
! D. Intake Structure E. Diesel Generator Building F. Radwaste Building (Below Grade)
- Note - 1. This listing is not intended to be all inclusive.
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! 2. Application of the QA Program to these systems and components shall l be consistent with the safety-related significance of the system or component.
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Table 2 THREE LEVEL QUALITY ASSURANCE PROGRAM EXPLANATION OF FIRST, SECOND, AND THIRD LEVEL QA RESPONSIBILITIES a) FIRST LEVEL - Work Performance This includes verification that and Ouality Control. activities are properly performed and procedures are adequate for the Each person performing work for activity they prescribe. Persons CNS is charged with the first-line performing these activities are not responsibility for adherence to directly involved in the day-to-day quality practices and procedures. Inspection or Quality Control An individual other than the one functions. Audits, surveillances will doing the work (not to include normally be performed by or under immediate supervision at the task the direction of the appropriate QA site) will have primary Manager. In addition, SRAB shall responsibility for Quality Control. be responsible for reviewing the Personnel at this level are charged results of audits and follow-up with the responsibility for direct audits as described in Section 3.4 of
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inspection, witnessing, and sign-off, th_is standard. The Quality attesting that work has been Assurance Staff is also responsible performed in accordance with the for the evaluation of audit results quality requirements of the and for verifying that identified controlling documents. corrective action requirements have been implemented.
b) SECOND LEVEL ,
Management /Suoervision Oversight. Personnel performing assessments are not directly involved in the day-Supervision and managemem to-day Inspection or Quality Control personnel are responsible for functions. Assessments will providing workers and QC people normally be performed under the with the proper procedures and direction of Senior line Management guidance for performing quality personnel, or at the discretion of on-work. These Managers and site or off-site safety review bodies.
Supervisors are then responsible for Such assessments are conducted to second level oversight as provide the highest level of appropriate for work involved. The overview ofimplementation of the QA Division will periodically Quality Assurance Program as review controlling documents for herein described.
safety-related activities to evaluate inclusion of appropriate quality requirements.
c) THIRD LEVEL-Ouality Assurance Audit / Surveillance and Assessments.
QA Staff is responsible for conducting surveillances, and audits of activities which affect quality to assure that Quality Control and inspection programs are being implemented and that quality requirements are in fact being met.
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