ML20211N840
| ML20211N840 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/02/1999 |
| From: | Bruce D NORTHEAST NUCLEAR ENERGY CO. |
| To: | |
| References | |
| MP-02-OST-BAP01, MP-02-OST-BAP01-R21, NUDOCS 9909130085 | |
| Download: ML20211N840 (116) | |
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- NDS Document Transmittal #158549 9/2/99 To: Nuclear Regulatory Commission Addressee uniques ido Document Control Desk ROUTINE distnbution Washington, D.C. 20666 l The following documents have been revised. You are currently on distribution for these documents. Verify that all documents are included in this distribution set.
DOCUM.ENI REV COPIES MP-02-OST-BAP01, CH1 21 1 Contr*d CW 34 l
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9909130085 990902 PDR ADOCK G5000245 P PDR Sign end retum this form es soon es received to: Diano ONeill x2451, NDS, B 475/3, Millstone Nuclear Power Station, Rope Ferry Rd.,
Weberford, CT. 06306 or FAX (860) 444-5711 Signature Date:
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1 Northeast 1 Utilities System I')
U Memo NO-99-0099 September 2,1999 TO: Northeast Utilities Quality Assurance Program Topical Report Controlled Copyholders FROM:
ebd b co-D. S. Bruce
SUBJECT:
NUQAP Topical Report Revision 21, Change 1 (Document No. MP-02-OST-BAP01) ,y Enclosed is NUQAP revision 21 and NUQAP revision 21 change 1. This enclosure includes the latest revision of the NUQAP, as approved by the NRC on 8/23/99. Change 1 to Revision 21 includes the changes incorporated into revision 20, changes 9 and 10, as SORC approved on j 7/1/99 and 7/7/99. Please replace the entire contents of the NUQAP with the enclosure.
p Change 1 changes are in bold anditalics with a revision bar in the right margin. The footer of (j the affected section will include a reference to change 1 The significant changes to Revision 21 from Revision 20 include the approval of the deletion of {
Recovery Officer, Nuclear Oversight (RONO), and delegation of appropriate responsibility to
{
. Director - Nuclear Oversight. Revision 21 was not issued without change 1 due to the necessity j
to include changes already incorporated into the Quality Assurance Program.
If you have any questions, contact D. Bruce at X3185.
Enclosure:
- 1. Revision 21, Quality Assurance Program Topical Report, including change 1 O. l (V
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TABLE OF CONTENTS NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
Q k/ TOPICAL REPORT- MILLSTONE POWER STATION
- Table of Contents Abstract Policy Statement introduction Quality Assurance Program QAP 1.0 Organization QAP 2.0 Quality Assurance Program QAP 3.0 Design Control
, QAP 4.0 Procurement Document Control QAP 5.0 Procedures, instructions and Drawings QAP 6.0 Document Control QAP 7.0 Control of Purchased Material, Equipment and Services QAP 8.0 identification and Control of Materials, Parts and Components QAP 9.0 Control of Special Processes QAP 10.0 - Inspection QAP11.0 ' Test Control l QAP12.0 O QAP13.0 QAP14.0 Control of Measuring and Testing Equipment Handling, Storage, and Shipping Inspection, Test, and Operating Status QAP15.0 Nonconforming Materials, Parts, Components, or Services QAP16.0 Corrective Action ;
QAP17.0 Quality Assurance Records QAP18.0 Audits I Appendices ' i A Category i Structures, Systems, and Components B Qualification and Experience Requirements C Regulatory Guide and ANSI /IEEE Standard Commitments D Glossary of Quality Assurance Terms E- Program Exceptions
'F Administrative Controls G Technical Specification Position Cross Reference l ,
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QAP-Table of Contents j' Rev. 21, Chg. 01 i Date: 9/2/99 Page 1 of 1
- g. . .
I O ABSTRACT NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT- MILLSTONE POWER STATION Northeast Utilities (NU) has developed, and is implementing, a comprehensive Quality Assurance Program for the Millstone Power Station to assure conformance with established regulatory requirements set forth by the Nuclear Regulatory Commission (NRC) and accepted industry standards. The participants in this Quality Assurance Program assure that the design, fabrication,- procurement, construction, testing, operation, refueling, maintenance, repair and modification of the Station nuclear power plants are performed in a safe and effective manner.
This Quality Assurance Program (NUQAP) Topical Report complies with the requirements set forth in Appendix B of 10 CFR 50, along with applicable sections of the Safety Analysis Report (SAR) for each license application, and is responsive to the United States NRC Regulatory Guide 1.70, which describes the information required to be presented in the Quality Assurance section of the SAR's for nuclear power plants.
This NUQAP is also established, maintained, and executed with regard to radioactive material transport packages as allowed by 10 CFR 71.101(f). Quality Assurance provisions for Fire Protection activities are detailed in the Northeast Utilities Fire Protection Program.
This NUQAP applies in its entirety to all activities affecting the safety-related functions of
- O structures, systems, and components. Safety-Related structures, systems, and components are functionally identified in Appendix A of this NUQAP and are designated Category I by Northeast Utilities. Applicability of Appendix A to each FSAR is addressed by existing nuclear unit specific design bases and licensing commitments, and also as specifically identifed in each FSAR addressing Section 3.2.1 of Regulatory Guide 1.70. This NUQAP is also applicable in its entirety to materials, equipment, parts, consumables, and services designated as Category 1. This NUQAP is applicable to other quality programs including Anticipated Transient Without Scram (ATWS) Quality Assurance which is applicable to MP-1 and MP-2 only (MP-3 commits to Generic Letter 85-06) and Electrical Equipment Qualification (EEQ) as defined by NU commitments. Portions of this NUQAP are also applic.able to Fire Protection Quality Assurance (FPQA), Station Blackout Quality Assurance (SBOQA) and Radwaste Quality Assurance (RWQA) which are delineated in applicable program manuals and procedures. Quality Assurance provisions for primary chemistry laboratory activities are detailed in the Northeast Utilities Nuclear Chemistry Laboratory Quality Assurance Manual.
This NUQAP is committed to utilize the guidance obtained from the regulatory documents and their endorsed standards identified in Appendix C of this NUQAP Topical Report.
O QAP - Abstract Rev. 21 Date: 9/2/99 Page 1 of 1
POLICY STATEMENT NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT - MILLSTONE POWER STATION This NortNeast Utilities Quality Assurance Program . (NUQAP) Topical Report has been developed to achieve quality assurance in all activities affecting the safe operation of the Millstone Nuclear Power Station. The policies, requirements and tasks contained in this program description have been developed to achieve quality assurance during activities that apply to the design, fabrication, procurement, construction, testing, operation, refueling, maintenance, repair,
' and modification of the Station's nuclear power plants.
Northeast Utilities procedures which implement this program are described in various manuals.
l This NUQAP applies in its entirety to all activities affecting the safety-related functions of j structures, systems, and components. Safety-Related structures, systems and components are functionally identified in Appendix A of this NUQAP and are designated Category I by Nortneast
, Utilities. Applicability of Appendix A to each FSAR is addressed by existing nuclear unit specific l design bases and licensing commitments, and also as specifically identified in each FSAR l addressing Section 3.2.1 of Regulatory Guide 1.70. This NUQAP is also applicable in its entirety to materials, equipment, parts, consumables, and services designated as Category I. This NUQAP is also applicable to other quality programs including Anticipated Transient Without Scram (ATWS) Quality Assurance which is applicable to MP-1 and MP-2 only (MP-3 commits to ,
Generic Letter 85-06) and Electrical Equipment Qualification (EEQ) as defined by NU l O' commitments. Portions of this NUQAP are also applicable to Fire Protection Quality Assurance
. (FPQA), Station Blackout Quality Assurance (SBOQA) and Radwaste Quality Assurance (RWQA) which are delineated in applicable program manuals and procedures. Quality Assurance provisions for primary chemistry laboratory activities are detailed in the Northeast Utilities Nuclear Chemistry Laboratory Quality Assurance Manual.
l l
The development and overall responsibility for this program lies with the President and CEO-NNECO, as delegated by the Chairman, President Chief Executive Officer of Northeast Utilities.
Corporate authority is delegated to the Director - Nuclear Oversight for the preparation and administration of this NUQAP Topical Report. Individual Vice Presidents are responsible for the implementation of their portion of this program. Audits of this program are the responsibility of the Director-Nuclear Oversight.
Any revisions or additions shall be approved by affected departments prior to the incorporation of such changes into the program. Final approval of revisions or additions to this Policy Statement rests with the President and CEO-NNECO.
= Y b & 2 ka s .-
President and CEO-NNECO O QAP Policy Statement Rev.: 21 Date: eliHW99 MM Page 1 of 1 E- . - . . . _ _ _ _ -- .- - . . . . - - - . . . . - - - - - . - . . . . . . . . - - - . .- - - - - . - . . - - . . . . . - . . - . . . . -
l lNTRODUCTION l
NORTHEAST UTILITIES QUALITY AS6tMANCE PROGRAM (NUQAP) l TOPICAL REPORT - MILLSTONE POWER STATION l
This Northeast Utilities Quality Assurance Program (NUQAP) Topical Report contains the quality assurance requirements which are relevant to the safety of the Millstone Station nuclear power plants. This NUQAP l Topical Report consists of three parts:
l 1. Introduction, which defines the purpose of the Topical Program and summarizes its scope and applicability;
- 2. The NUQAP, which is applicable in its entirety to all activities affecting the safety-related functions of structures, systems, and components. Safety-Related structures, systems, and components are functionally identified in Appendix A of this NUQAP and are designated Category I by Northeast Utilities.
i Applicability of Appendix A to each FSAR is addressed by existing nuclear unit specific design bases and i licensing comrntrnents, and also as specifically identified in each FSAR addressing Sechon 3.2.1 of l Regulatory Guide 1.70. This NUQAP is also applicable in its entirety to materials, equipment, parts, i
consumables, and services designated as Category 1. This NUQAP is applicable to other quality programs including Anticipated Transient Without Scram (ATWS) Quality Assurance which is applicable to MP-1 and
! MP-2 only (MP-3 commits to Generic Letter 85-06) and Electrical Equipment Qualificabon (EEQ) as defined by NU commitments. Portions of this NUQAP are also applicable to Fire Protection Quality l
Assurance (FPQA), Station Blackout Quality Assurance (SBOQA) and Radwaste Quality Assurance (RWQA) which are delineated in applicable program manuals and procedures.
- 3. Appendices, which provide supporting statements and tabulations.
This NUQAP Topical Report has been prepe A to document that a quality assurance program has been established and implemented to assure that adequate quality requirements are being complied with to O safeguard NU employees, contracted personnel and the public during the life of the Millstone Station nuclear power plants. In addition, there are other programs to safeguard NU employees, contracted personnel, and the public.
The controls which implement the actions identified in this 'NUQAP are procedures and instructions which delineate actions and steps necessary to accomplish quality requirements. Procedures and instructions are wntten by groups, divisions, departments, branches, or sections which have the responsibility for implementing schons as assigned by this NUQAP. Quality procedures and revisions thereto are reviewed by and concurred with by Nuclear Oversight in accordance with QAP 2.0, " Quality Assurance Program" and QAP 5.0,
" Procedures, Instructions, and Drawings".
This NUQAP is responsive to applicable codes, Nuclear Regulatory Commission regulatory requirements, accepted industrial standards and revisions thereto. Provisions are established to update this NUQAP Topical Report in accordance with revisions to codes, standards and regulatory requirements, and to inform cognizant personnel to implement appropriate acbon to assure the highest standard of quality is achieved for structures, systems, components, and services for the Millstone Station nuclear power plants.
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g 7 Director- Nuclear Oversight QAP Introduction Rev.: 21 Date: 9/2/99 Page 1 of 1
l 1.0 ORGANIZATION
1.1 INTRODUCTION
This section descnow the organizations involved in the operation and technical support of Millstone Nuclear Power Station (MNPS). In addition, this section describes the responsibilities governed by the Northeast (
Utilities (NU) Quality Assurance Program (NUQAP). Qualifications for key j personnel are found in the unit Technical SpeciHcations and Appendix B, (
" Qualification and Experience Requirements." !
NOTE in the remainder of QAP 1.0, references are made to station - wide :
functions that apply tc> all three units unless indicated otherwise. Where speclRed, some text applies specl6cally to Units 2 and 3, or to Unit 1. In either case, Units 2 and 3 organizations may supply services to, or use services from, the Unit 1 organization, with appropriate controls. Unit 1 is defueled andin a decommissioning mode.
1.2 ORGANIZATION 1
The Chairman, President and Chief Executive OMcer (CEO) of NU has ;
ultimate responsibility and overall authority for the NU nuclear program, '
and is the Chairman of Northeast Nuclear Energy Company (NNECO), the ;
licensed operator of Millstone Units 1, 2 and 3. The Chairman of NNECO \
has delegated the necessary responsibility and authority for all nuclear operations to the President and CEO-NNECO. In addition, Northeast Ut/Ilties Service Company (NUSCO) provides certain support services to NNECO. The President and CEO-NNECO is also the President-Generation Group of NUSCO.
1.3 KEYMANAGEMENTRESPONSIBILITIES AND AUTHORITY 1.3.1 Senior Vice President and CNO-Millstone (SVP & CNO)
The SVP & CNO has been delegated by the President and CEO-NNECO the necessary responsibility and authority for the management and direction of all activities related to the operation of MNPS. The SVP & CNO has overall responsibility for engineering, construction, operation, maintenance, modification and quality QAP - 1.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 1 of 16
1 p assurance including this NUQAP, at MNPS. The following report
'Gi directly to the SVP & CNO:
- Vice President (VP)-Nuclear Operations
- VP-Engineering Services
- VP Site Services
- VP-Human Services
- VP-Nuclear Oversight and Regulatory Affairs (NORA) 1.3.2 VP-Nuclear Operations (Units 2 and 3)
VP-Nuclear Operations is responsible for estabilshing common policies and standards pertaining to the operating units, the safe operation and maintenance of the units, and implementation of this NUQAP. The VP-Nuclear Operations is responsible for maintaining compliance with requirements of the Operating License and Technical SpeclHcations as well as appIlcable federal, state and locallaws, regulations and codes. The following report directly to the VP-Nuclear Operations:
Station Director (Units 2 and 3)
- Work Management (Units 2 and 3)
Maintenance (Units 2 and3) 1.3.3 VP-Engineering Services
- VP-Engineering Services is responsible for providing engineering services to support the operating units (Units 2 and 3), and implementation of this NUQAP. The following report directly to the VP-Engineering Services:
- Design Engineering
- Nuclear Engineering
- Plant Engineering 1.3.4 VP-Site Services VP-Site Services is responsible for site services in support of the station, and implementation of this NUQAP. The following report directly to the VP-Site Services:
- Site Services
- Nuclear Materials and Document Management
- Unit 1 GeneralManager 1.3.5 VP-Human Services The VP-Human Services is responsible for emergency planning and nuclear training, and implementation of this NUQAP. The following report directly to the VP-Human Services:
QAP - 1.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 2 of 16
O Nuclear Training Services e
- Emergency Planning The VP-Human Services is also responsible for the employee concerns program and human services, and for these two \
responsibilities, the VP-Human Services reports to the President '
and CEO-NNECO.
1 1.3.6 VP-Nuclear Oversight and Regulatory Affairs (NORA)
VP-NORA is responsible for the effective performance of Nuclear Oversight and Regulatory Affairs functions. The VP-NORA acts as i
advisor to the SVP & CNO and President and CEO-NNECO on items related to nuclear quality and safety at the station. Overall responsibility for the NUQAP has been delegated to the VP-NORA by the SVP & CNO. These responsibilities include:
- Direction of the quality assurance program Development and implementation of policies, plans, requirements, procedures, and audits l
- VerlHcation to assure compilance with 10CFR50
\
Appendix B and other regulatory requirements ,
- Verification of the implementation of the NUQAP TopicalReport requirements .
The following report directly to the VP-NORA:
- Director-Nuclear Oversight 1.3.7 Director-Nuclear Oversight i
? The VP-NORA has delegated to the Director-Nuclear Oversight the i
necessary authority and responsibility for the following:
- Preparation and issuance of the NUQAP Topical i
Report
- Verification of the implementation of NUQAP j requirements and of compilance with 10CFR50 i Appendix B and other regulatory requirements
- Identification of qualityproblems l
- Recommendations or solutions to quality problems
! and verlHcation of the implementation of the solutions ,
e independent Safety Engineering and Operating l Experience programs l Ver/Hcation is performed through a planned program of audits, surveillances andinspections by Nuclear Oversight. The Director.
Nuclear Oversight provides objective evidence to management of the performance of quality activities independent of the Individual or group directly responsible for performing the specific activity.
QAP - 1.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 3 of16 i
l The Director Nuclear Oversight has the authority and organizational 1
freedom to verify activities affecting quality. This is performed independent of undue influences and responsibilities for schedules i
and costs.
l in order to implement these responsibilities, the Director-Nuclear '
Oversight is provided "Stop Work" authority whereby he/she can 1
suspend unsatisfactory work and control further processing or installation of non-conforming meterials. The authority to stop work is assigned to Nuclear Oversight personnel and delineated in an approvedprocedure.
l l 1.3.8 Station Director (Units 2 and 3)
The Station Director is responsible for operations, nuclear safety, \
chemistry, and radiation protecdon activities. The Station Directoris responsible for the safe and etticient operation of the units. During accident situations, if currently holding an active SRO license on l the unit, the Station Director may relieve the Shift Manager of the responsibility of directing the licensed Control Room operators.
The following report to the Station Director:
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- Assistant Station Director-Safety (Units 2 and 3) ,
\
- Unit Operations (Units 2 and 3) 1 Radiation Protection and Waste Services (Units 2 ^
and 3) 1.3.9 Work Management (Units 2 and 3)
The Work Management group is responsible for on-line maintenance, cost and scheduling, and outage activities.
Responsibilities include the scheduling of surveillances required by Technical Specl6 cations. Unit 1 has a separate group for this function.
1.3.10 Maintenance (Units 2 and 3)
The Maintenance group is responsible for installation, maintenance, i
1 alterations, a4justment and calibration, replacement and repair of plant electrical and mechanical equipment, and instruments and controls. Responsibilities include establishing standards and frequency of calibration for instrumentation and ensuring instrumentation and related testing equipment are properly used, inspected and maintained. Unit 1 has a separate group for this function.
QAP - 1.0 Rev. 21 Chg. 01 Date: 9/2/99 Page 4 of 16
1.3.11 Design Engineering The Design Engineering group is responsible for design engineering functions, supporting activities, and engineering programs. The Unit 1 organization will share responsibility for certain systems shared between Unit 1 and Units 2 or 3.
1.3.12 Nuclear Engineering The Nuclear Engineering group is responsible for engineering activities in configuration management, safety analysis, and nuclear fuel. These activities include probabilistic risk assessment, radiological and radwaste engineering, design and configuration controland engineering assurance.
1.3.13 Plant Engineering The Plant Engineering group is responsible for engineering technical support and systems engineering, including reactor and material engineering.
1.3.14 Site Services .
The Site Services group is responsible for services in support of the station, including security and Hre protection.
1.3.15 Nuclear Materials and Document Management The Nuclear Materials and !;ocument Management group is responsible for nuclear records management and procurement. l Responsibilities include approval and oversight of vendors that provide quality-related mkterial and services including source and receiptinspection.
1.3:16 Unit 1 GeneralManager The Unit 1 General Manager is responsible for the safe and et!Iclent decommissioning of Unit 1, including operations, engineering, nuclear safety, radiation protection, maintenance and associated support services. The following report to the Unit 1 General Manager;
- Director-Unit 1 Operations
- Unit 1 Decommissioning
- Unit 1 Nuclear Safety and Regulatory Affairs O QAP - 1.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 5 of 16
1.3.16.1 Director-Unit 1 Ooerations The Director-Unit 1 Operations is responsible for the safe and etlicient operation of Unit 1 in its decommissioning mode. The Director-Unit Operations is also responsible for work management, maintenance, health physics, and radiological waste. The Manager-Health Physics fulfills the
" Health Physics Manager" position qualifications required by the Unit 1 Technical Specifications.
1.3.16.2 linit 1 Decommissionina The Unit 1 Decommissioning group is responsible for planning and executing the decommissioning of Unit 1, including associated engineering. The Unit 1 organization will share responsibility for certs!n systems shared between Unit 1 and Units 2 or 3.
1.3.16.3 Unit 1 Nuclear Safetv and Reaulatory Affairs The Unit 1 Nuclear Safety and Regulatory Affairs group is responsible for licensing and other activities in support of Unit 1 decommissioning.
1.3.17 Nuclear Training Services The Nuclear Training Services group is responsible for operator and technical training. The operator training group reports directly to the Director-Nuclear Training Services to provide sufficient organizational freedom and independence from operating pressures as required by the unit Technical Specifications.
1.3.18 Emergs cy Planning The Emergency Planning group is responsible for development and maintenance of the on-site radiological emergency plan and the '
development and coordination of required off-site radiological emergency response plans.
1.3.19 Assistant Station Director-Safety (Units 2 and 3)
The Assistant Station Director-Safety is responsible for the corrective actions program, procedures, and the shift technical advisors.
i QAP - 1.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 6 of 16
1.3.20 Unit Operations The Unit Operations groups report to the Station Director (Units 2 and 3) or to the Director - Unit 1 Operations (Unit 1). Each group includes the following key supervisory positions:
- Manager-Operations ;
- Assistant Manager Operations l
- Shift Manager (s)
- Unit Superv sor(s) 1.3.20.1 Mannaer-Onerations and Assistant Manaaer-Ocerations The Manager-Operations provides general supervision for 1 1
the operation of the respective unit, and coordinates unit operations with maintenance, work management, and other groups. As stipulated in Technical Specifications or I in Appendix B, the Manager-Operations or the Assistant Manager- Operations holds an appropriate license on the Unit (SRO on Units 2 and 3, CertlRed Fuel Handler on Unit 1). The Manager-Operations assures the safe and etNclent operation of the assigned unit in accordance with applicable licenses, operating instructions and procedures, emergency procedures and safety rules and O regulations. During accident situations, if currently holding an active SRO license on the unit, the Manager.
Operations may relieve the Shift Manager of the responsibility of directing the licensed Control Room operators. The Manager-Operations delegates the necessary authority and responsibility for various duties to the Assistant Malsager-Operations.
1.3.20.2 ShlN Mansaer l l
The Shift Managers report to the Assistant Manager.
Operations and are responsible for the Control Room command function. The Shift Manager holds an appropriate license on the unit (SRO on Units 2 and 3, CertlRed Fuel Handler on Unit 1). The Shift Manager directs and supervises the operation of the unit.
Administrative functions that detract from or are ,
subordinate to the management responsibility for assuring the safe operation of the plant are delegated to other operationalpersonnel not on duty in the Control Room. l QAP - 1.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 7 of 16
l 1
During accident situations, unless properly relieved, the I ]. Shift Manager remains in the Control Room and directs the activities of the licensed operators. The Shift Manager has direct authority to shut down the respective unit if, in the Shift Manager's opinion, serious abnormal conditions exist. A Unit 3 Shift Manager fulfills the facility staff requirements of the Shift Supervisor for the Unit 3 TechnicalSpecifications.
1.3.20.3 Unit Sunervisor The Unit Supervisor holds an appropriate license on the unit (SRO on Units 2 and 3, Certified Fuel Handler on Unit
- 1) nnd supervises the operators in the Control Room. The Urlt Supervisor directs activities of the licensed Control Poom operators, and may operate the controls of aquipment and piping systems from the Control Room or alternate station controllocation.
1.3.20.4 Control Ooerators (Units 2 and Unit 3)
Control Operators hold a Reactor Operator or Senior Reactor Operator Ilcense on the unit. The Control Operators are responsible to perform the following duties:
O.
- Start up, operate, and shut down nuclear plant equipment including, but not limited to, reactor, reactor auxillaries, turbine generator unit and its ;
auxillaries as necessary to satisfy system l requirements orstation conditions
- Test, as scheduled, control room instruments and controls
- Maintain required logs and calculations, observe these logs forindications of faulty operation, and notify the on-duty Unit Supervisor or the Shift Manager of abnormal plant conditions 1.3.20.5 Plant Eaulament Overstors Plant Equipment Operators are rssponsible to perform the following duties:
- Start up, operate, inspect, adjust, and shut down all auxiliary and other various plant equipment
- Perform or assist with scheduled operational tests
- Make minor repairs OAP - 1.0 Rev. 21, Chg 01 Date: 9/2/99 l Page 8 of 16 i
1.3.21 Radiation Protection and Waste Services (Units 2 and 3)
Radiation Protection and Waste Services group carries out health physics functions and reports to the Station Director to provide sufficient organizational freedom and independence from operating pressures as required by the unit Technical Specifications. The ManagerRadiation Protection and Waste Services fulfills the
" Health Physics Manager" position qualifications required by the '
unit Technical Specifications. Radiation protection services include the following:
scheduling and conducting radiation surveys including contamination sample collection
- determining contamination levels and assigning work restrictions through radiation work permits
- maintaining records and reports on radioadive contamination levels
- administering the personnel monitoring program and maintaining required records in accordance with federal and state codes Radiation Protection and Waste Services is also responsible for radioactive waste services.
1.4 QUALITY-RELATED RESPONSIBILITIES COMMON TO ALL DEPARTMENT HEADS The head of each department performing quality activities is responsible for:
- Administering those activities within their organization which are required by this NUQAP; l
- Ensuring implementation of the Quality Assurance Program; !
- Establishing and clearly defining the duties and responsibilities of personnel within their organization who perform quality activities;
- Planning, selecting, and training personnel to meet the requirements of the NUQAP Topical Report; and
- Performing and coordinating quality activities within their department and interfacing with the Nuclear Oversight department.
O QAP - 1.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 9 of 16
I Each individual performing or verifying activities affecting quality is responsible to conduct those activities in accordance with the requirements of this NUQAP and implementing procedures. These individuals shall have direct access to such levels of management as may be necessary to perform this function. '
The responsibility, authority, and organizational relationship for performing quality activities within each organization is estabIlshed and delineated in the NUSCO/NNECO organizational charts, policy ,
statements, and writtenJob or functional descriptions. l Vendors may be delegated the execution of quality assurance functions; however, NU shall retain responsibility for this Quality l Assurance Program. i 1.5 ANNUAL MANAGEMENT QUALITY ASSURANCE REVIEW The SVP & CNO is responsible for the assessment of the scope, status, implementation, and effectiveness of the NUQAP. To meet this ,
responsibility, a team of qualified individuals is appointed by the SVP &
CNO to perform an annual Management Quality Assurance Review. The team is made up ofIndividuals knowledgeable in quality assurance, quality activities, auditing, management responsibilities, and the NUQAP Topical O Report. This reviewis:
- A systematic evaluation;
- pre-planned toward the objective of determining the adequacy of the NUQAP and its compilance with Appendix B to 10 CFR 50 and other regulatory requirements; and
- capable of identifying, communicating, and tracking any required corrective action.
1.6 SPECIFIC NUQAP RESPONSIBILITIES The SVP & CNO resolves all disputes related to the implementation of the NUQAP for which resolution is not achieved at lower levels within the organization.
O QAP - 1.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 10 of 16
1 1.7 0 SUCCESSION OF RESPONSIBILITY FOR OVERALL PLANT OPERATION (Units 2 and 3) \
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The succession to responsibility for overallplant instructions or special orders, in the event of absences, incapacitation ofpersonnel or other emergencies, is as follows for Units 2 and 3:
- Vice President-Nuclear Operations
- Station Director Licensed Manager-Nuclear Operations or Licensed Assistant Maneger.
Operations designated by Vice President-Nuclear Operations
- Shift Manager (SRO)
- Licensed Unit Supervisor (SRO) 1.8 ORGANIZATION CHARTS NOTE The following organization charts are incorporated by reference in the Millstone Station Emergency Plan. Changes to these organization charts require an effectiveness review in accordance with 10 CFR 50.54 (q). ,
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2.0 QUALITY ASSURANCE PROGRAM 2.1 GENERAL REQUIREMENTS Northeast Utilities (NU) has established a Quality Assurance Program (NUQAP) for the Millstone Power Station which complies with the criteria of 10CFR50, Appendix B, and follows the regulatory documents and their endorsed ANSI /IEEE standards identified in Appendix C with exceptions as identified in Appendix E.
The quality assurance requirements set forth in the attached Policy Statement, supplemented by quality assurance procedures, provide the primary basis of this program and the NU policy with regard to quality assurance for all the Millstone Station nuclear power plants. This NUQAP Topical Report is established to accomplish the required level of quality in activities carried out throughout the life of the Station's nuclear power plants.
This NUQAP applies in its entirety to all activities affecting the safety-related functions of structures, systems and components. Safety-Related structures, systems and components are functionally identified in Appendix A of this NUQAP and are designated Category I by Northeast Utilities. Applicability of Appendix A to each FSAR is addressed by existing Nuclear Unit specific Design Bases and Licensing commitments, and also as specifically identifMKi in each FSAR addressing Section 3.2.1 of Regulatory Guide 1.70. This NUQAP is also applicable in its entirety to materials, equipment, parts, consumables and services O designated Category I.
This NUQAP applies to other quality programs including Anticipated Transient Without Scram (ATWS) Quality Assurance which is applicable to MP-1 and MP-2 only (MP-3 commits to Generic Letter 85-06) and Electrical Equipment Qualification (EEO) as defined by NU commitments. Portions of this NUQAP are also applicable to Fire Protection Quality Assurance (FPQA), Station Blackout !
Quality Assurance (SBOQA) and Radwaste Quality Assurance (RWQA) which are delineated in applicable procedures.
The Materials, Equipment, and Parts List (MEPL) Program provides instructions to identify structures, systems, components, materials, equipment, parts, consumables, quality software and activities that need to be identifMxi as safety-related or augmented quality.
The requirements of this NUQAP are implemented by Northeast Utilities Service Company (NUSCO), the Northeast Nuclear Energy Company (NNECO) which operates Millstone Power Station, and their vendors perfomiing activities affecting quality structures, systems, and components of the Station's nuclear power plants.
Procedures define the required indoctrination and training of personnel performing activities affecting quality, as necessary, to assure that suitable proficiency is achieved and maintained.
QAP - 2.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 1 of 7
Training sessions are documented. The content of the training sessions is described, attendees and attendance date indicated, and the results (e.g.,
examination results) of the training sessions recorded, as applicable.
Periodic program review of the status and adequacy of this NUQAP is accomplished by Nuclear Oversight audits, surveillances and inspections, by Nuclear Safety Assessment Board (NSAB) reviews, and by the independent review team which performs the annual Management Quality Assurance Review described herein and In QAP 1.0, " Organization", Section 1.5. Organizations outside NU are required to review the status and adequacy of that part of this NUQAP for which they have been delegated responsibility.
2.2 IMPLEMENTATION 2.2.1 GOALS AND OBJECTIVES The goals of this NUQAP are to maintain quality levels in an effective and efficient manner and to assure a high degree of functional integrity and reliability of Station nuclear power plant quality structures, systems, and components. To meet these goals, the following objectives of this NUQAP have been defined:
- a. Define, through procedures, the quality activities that apply to design, p fabrication, procurement, construction, testing, operation, refueling, repair, Q maintenance and modification of the Station nuclear power plants;
- b. Establish, assign, and document the responsibilities for the conduct of those activities affecting quality structures, systems, and components;
- c. Establish confidence that (a) quality activities for the Station nuclear power plants are performed consistent with NU policies and (b) quality activities are performed by qualified personnel, and are verified through a system of audits, surveillances, and inspections of those organizations with quality responsibilities;
- d. Apprise the Senior Vice President and Chief Nuclear Officer - Millstone (SVP d CNO) of unresolved problems and trends which could have a :
significant effect on nuclear power plant safety.
(D QAP - 2.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 2 of 7
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O V 2.2.2 PROGRAM DOCUMENTATION This NUQAP defines the NU nuclear policies, goals, and objectives, and ,
is used as guidance for the development of the various division, department, branch, or section procedures. Revisions to this NUQAP shall be made as needed to reflect current requirements and descriptions 1 of activities prior to implementation. These revisions shall be made in !
accordance with a NNECO Procedure.
Revisions to this NUQAP, which reduce commitments previously accepted by the NRC, are submitted to the NRC for review and approval prior to implementation.
Revisions which do not reduce previously accepted commitments are periodically submitted to the NRC as required by 10 CFR 50.54 (a)(3) and 10 CFR 50.55 (f)(3).
Quality procedures are developed by the departments performing quality activities. These procedures are reviewed for concurrence by the departments which are responsible for implementing portions of these procedures and are approved by the initiating department. The Nuclear Oversight Department reviews other department quality procedures for compliance with this NUQAP and concurs with such procedures as
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described in QAP 5.0, " Procedures, instructions and Drawings". l Changes to procedures are subjected to the same degree of control as that utilized in the preparation of the original document.
Each Vice President and Director is responsible for implementation of l this NUQAP within their organization which includes individual departmental procedure requirements applicable only to their respective activities. In addition, they are responsible for the preparation, approval, and distribution of those instructions, operating procedures, testing procedures, or other instructions where further guidance is necessary.
2.2.3 STRUCTURES. SYSTEMS AND COMPONENTS This NUQAP applies to all activities affecting the safety-related functions of the structures, systems and components as addressed in the Safety i Analysis Reports (SARs). Safety-Related structures, systems, and l components are functionally identified in Appendix A and also as '
specifically identified in each FSAR addressing Section 3.2.1 of NRC Regulatory Guide 1.70.
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QAP - 2.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 3 of 7
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, p, For structures, systems and components covered by the ASME Code,
!V NUSCO/NNECO procedures describe the measures taken to assure that the quality assurance requirements contained in the code are supplemented by the specific guidance of the applicable regulatory guides and endorsed ANSI standards listed in Appendix C.
For structures, systems and components, regulatory commitments and NUSCO/NNECO procedures describe the measures taken to assure that the quality assurance requirements are met.
The degree of control over activities affecting quality structures, systems, and components is consistent with their importance to safety. Such controls include use of appropriate equipment, establishment of suitable environmental conditions, and assurance that all prerequisites for a given activity have been satisfied. This NUQAP provides controls over special processes and skills necessary to attain the required quality, and the need for verification of quality by inspection and test.
The Nuclear Oversight Department and applicable NUSCO/NNECO technical organizations jointly determine and identify the extent quality
' assurance controls are applied to quality structures, systems, and components. The quality assurance controls are in conformance with this NUQAP, which complies with the 18 criteria set forth in Appendix B to 10 CFR 50, 2.2.4 PARTICIPATING ORGANIZATIONS The organization for Millstone Power Station activities affecting the quality of structures, systems, and components is identified in QAP 1.0,
" Organization", which also briefly describes assigned responsibilities.
The Nuclear Oversight Department is responsible for; a) the development, coordination, and administrative control of this NUQAP including coordination of Nuclear Oversight Department procedure review and approval; b) assuring issuance of this NUQAP Topical Report as a controlled document (as described in QAP 6.0, " Document Control", and; c)the review and concurrence with quality procedures and revisions written by other departments. Procedure reviews shall be performed in accordance with QAP 5.0,
- Procedures, Instructions, and Drawings".
Northeast Utilities (NU) requires that its approved vendors performing quality activities invoke upon their subvendors, via purchase orders / contracts, requirements for a quality assurance program to meet the applicable criteria of Appendix B to 10 CFR 50, including the l
applicable elements of the regulatory guides and their endorsed O QAP - 2.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 4 of 7 i
l q ANSI /IEEE standards identified in Appendix C. However, NU retains Q overall responsibility for the Millstone Power Station Quality Assurance Program. The specific quality activities performed by these organizations are specified in the procurement documents. Nuclear Materials and Document Management is responsible for the review and approval of these vendors' quality assurance programs prior to initiation of contracted !
activities.
The object of the review is to verify that these vendors have an adequate l quality assurance program to meet applicable requirements of j 10 CFR 50, Appendix B.
In addition to the initial review, Nuclear Materials and Document Management is responsible for the subsequent performance, as appropriate, of audits, surveillances, and inspections of approved vendor's quality assurance programs to assure continued implementation of quality requirements. Nuclear Materials and Document Management assures that the quality assurance programs of vendors that perform ,
quality activities are periodically reviewed to assure that the vendors are '
implementing adequate programs. Evaluation, review, and monitoring of vendor quality programs is conducted in accordance with section QAP 7.0, " Control of Purchased Material, Equipment and Services". !
s Vendors may be delegated the execution of quality assurance functions
) by Contract. These Contracts are reviewed and approved in accordance with this NUQAP. These vendors may be contracted to perform quality activities under their approved quality assurance program or directly under the requirements of this NUQAP.
2.2.5 INDOCTRINATION AND TRAINING l l
A program is established and maintained for quality assurance {
indoctrination and training which provides confidence that the required '
level of personnel competence and skill is achieved and maintained in the performance of quality activities. Quality procedures delineate the requirements for an indoctrination program to assure that personnel responsible for performing quality activities are instructed in the purpose, scope, and implementation of quality procedures and that compliance to I these documents is mandatory. Each NUSCO/NNECO Department is responsible for assuring assigned personnel who perform quality activities have been appropriately indoctrinated and trained.
Nuclear training programs shall be developed and implemented to j provide training for all individuals attached to or associated with the Station nuclear power plants. Additional guidance is established in NUSCO/NNECO procedures.
O V QAP - 2.0 Rev. 21, Chg. 01 '
l Date: 9/2/99 Page 5 of 7 1 l
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i Procedures describe the nuclear training program requirements which assure that:
- a. Documentation of formal training and qualification programs includes the objective, content of the program, attendees, date of attendance; and results (e.g., examination results), as applicable
- b. Proficiency of personnel performing and verifying activities affecting
[ . quality is established and maintained. Personnel proficiency is established and maintained by training, examination /te. sting, and/or certification based upon the requirements of the activity. Acceptance ,
criteria are developed to determine if individuals are properly trained and qualified;
- c. Certificates or other documentation of qualification clearly delineate the specific functions personnel are qualified to perform arid the criteria used to qualify personnelin each function.
This program also requires the head of each department to be responsible for a training plan which assures that personnel performitig quality activities are trained in the principles and techniques of the activity being performed.
2.2.6 MANAGEMENT PARTICIPATION
' Millstone Power Station Vice Presidents and Directors are responsible for implementing this NUQAP within their organization. The Director -
Nuclear Overs /pht will assist in development, coordination, and review of the program.
The SVP & CNO assures that a management review of this NUQAP is l conducted on an annual basis by an independent team to assess the scope, status, implementation, and effectiveness, and to assure compliance with NRC licensing commitments.
j Actions considered by the Management Quality Assurance Review may l l include, but are not limited to: i
- a. Review of selected procedures and documents;
- b. Verification of the implementation of selected procedural requirements;
- c. Review of past audit results and other inspection / review results such as those fro.n previous Management Quality Assurance Reviews, l the NRC or other departments.
O QAP - 2.0 i
1 Rev. 21, Chg. 01 Date: 9/2/99 Page 6 of 7 l
O The Management Quality Assurance Review's findings of deficiencies (
and recommendations for program improvement are forwarded to the SVP & CNO who shall assure appropriate corrective action is taken.
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O QAP - 2.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 7 of 7 j c, ;
1
,/] 3.0 DESIGN CONTROL V 1 3.1 GENERAL REQUIREMENTS This NUQAP provides measures to assure that the applicable design requirements, such as design bases, regulatory requirements, codes, technical standards and quality standards, are identified in design documents which are reviewed, approved and controlled in accordance with procedures. Such measures include review for suitability of application of materials, equipment, parts and processes that are essential to the functions of quality structures, systems, and components. Changes to, and deviations from specified requirements are identified, documented and controlled.
Engineering Services and Unit 1 Decommissioning are responsible for controlling l design work, administering design control activities (including design interface) and design modifications for quality structures, systems, and components.
The responsibility for administration of the design control program for the Millstone Station nuclear power plants rests with Engineering Services and Unit 1 Decommissioning as it relates to Unit 1 decommissioning. The division of responsibilities and jurisdictional boundaries for design control program implementation are set forth in NUSCO/NNECO procedures. Although other organizations may be delegated the task of establishing and executing the design I (G control program or any part thereof, Engineering Services and Unit 1 h Decommissioning shall retain overall responsibility for the program. The applicable requirements of this NUQAP shall be imposed on other organizations delegated the task of establishing or executing the design control program in accordance with QAP 4.0, " Procurement Document Control" and QAP 7.0, " Control of Purchased Material, Equipment and Services".
The interface controls, both intemal and extemal, for organizations performing design work for quality structures, systems, and components are identified and implemented in accordance with procedures. This identification includes those organizations providing criteria, designs, specifications and technical direction.
Measures are applied to verify the adequacy of design. The extent of design verification is specified and documented by the responsible organization. The individuals performing design verification should not (1) have immediate supervisory responsibility for the individual performing the design, (2)have specified a singular design approach, (3)have ruled out certain design considerations, or (4)have established the design inputs for the particular design aspect being verified. The independent design verification should not dilute or replace the responsibility of the supervisors for the quality of work performed under their supervision. Where changes to previously verified designs have been made, design verifications are required for the change, including evaluation of the effects of those changes on the overall design.
Design verification may be accomplished by testing. Tests to demonstrate adequacy n under adverse design conditions shall comply with the requirements of OAP 11.0, U QAP - 3.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 1 of 5 w
" Test Control". Design errors and deficiencies which adversely affect quality structures, systems, and components in the design process are documented and appropriate corrective action is taken. These design errors and deficiencies are documented in accordance with design change procedures or as defined in QAP 15.0,
" Nonconforming Material, Parts, Components, or Services" and/or QAP 16.0, "
Corrective Action".
3.2 IMPLEMENTATION Engineering Services and Unit 1 Decommissioning are responsible for the design, l design review, engineering approval of design changes, design evaluation and design control for the unit s. Although some portion of the design process may be delegated to other organizations, Engineering Services and Unit 1 Decommissioning organization have the responsibility for overall design and final engineering decisions and design control of quality structures, systems, and components.
Nuclear Oversight performs audits, surveillances, and inspections, as appropriate, to verify that NUSCO/NNECO departments are effectively complying with this NUQAP and procedural requirements for design control. Additionally, audits, surveillances and inspections are performed, as appropriate, to verify that vendors are effectively complying with their quality assurance program requirements for design control.
3.2.1 DESIGN PROCESJ Design control measures are applied to design analyses, such as, reactor physics, stress, thermal, hydraulic, nuclear radiation, acciderd and seismic analyses; compatibility of materials; accessibility for in-service inspection, maintenance, and repair; and delineation of acceptance criteria for ;
inspections and test. Measures established to control design documents are described in QAP 6.0, " Document Control".
Program procedures and instructions define the method of implementing !
design control measures. These measures require that applicable design requirements, such as, design bases, regulatory requirements, codes and standards, are translated into specifications, drawings, procedures or instructions. Procedures and instructions further require that appropriate l quality standards are specified and included in design documents. Materials, equipment, parts and processes, including standard "off the shelf' commercial or previously approved items essential to quality functions are selected and reviewed for suitability of application. The basis for selection may include industry standards, material and prototype hardware testing programs, and design review.
4 QAP - 3.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 2 of 5
l q Procedures assure that a documented check is performed to verify the l V accuracy and completeness of design drawings and specifications before release for procurement, fabrication or construction. Design drawings receive a documented check to verify dimensional accuracy.
Design drawings and specifications issued for design changes are reviewed for completeness and accuracy before release to operations, in accordance '
with design control procedures. I Procedures describe the provisions to assure that design drawings and specifications are prepared, reviewed and approved in accordance with NUSCO/NNECO requirements and that the documents contain the necessary quality assurance requirements, such as inspections and test requirements, acceptance requirements, and the extent of documenting inspection and test results.-
3.2.2 DESIGN CHANGE CONTROL Procedures and instructions ~ governing design change control. during modifications to the Station nuclear plants, the control of discrepant or !
deficient design conditions, and the reporting of unsatisfactory performance l provide for the identification of the need for design changes and a documented method to control these changes. Design and specification changes are subject to design control measures commensurate with those
- O applied during the original design as amended by applicable design or licensing basis changes.
An independent review and approval of design changes is performed by the ;
organization that conducted the original design reviews, unless such review :
is performed by NNECO or another qualified organization delegated by NNECO to perform this function.
Proposed design change modifications are submitted to the appropriate ;
Engineering Services endor Unit f Decommissioning management for l processing and review. This review includes the appropriate on-site review '
committee (s) as required by applicable procedures. If the change involves a quality structure, system or component, the change shall be reviewed by qualified engineering personnel for technical adequacy. Reviews of the safety evaluations associated with proposed design changes are performed by the Nuclear Safety Assessment Board (NSAB). The sequence of the NSAB review depends upon the determination of whether an unreviewed safety question is involved (i.e., in accordance with ANSI N18.7, if a proposed change in the facility involves an unreviewed safety question then the NSAB review is conducted prior to submittal of the proposed change to the NRC for review and the issuance of a license amendment for its implementation).
O QAP - 3.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 3 of 5
q The combination of these independent reviews by the on-site review Q committee (s) and NSAB Is performed to assure that:
- a. the adequacy of the proposed change is substantiated;
- b. unreviewed safety questions are properly identified and handled per 10 CFR 50.59;
- c. nuclear safety requirements have been addressed.
Errors and deficiencies in design, including the design process, that could adversely. affect quality structures, systems, and components are documented and corrective action is taken in accordance with QAP 15.0,
" Nonconforming Materials, Parts, Components, or Services" and/or QAP 16.0, " Corrective Action"..
Notification of design changes are transmitted to responsible plant personnel prior to implementation and as part of the design change package close out.
Procedures describe this notification which assures that personnel are made aware of design change modifications which may affect the performance of their duties.
3.2.3 DESIGN INTERFACE CONTROL ,
Procedures and instructions identify design interface controls and the resolution of design interface questions during modifications to the station nuclear power plants.
3.2.4 INDEPENDENT DESIGN VERIFICATION Original designs and design modifications are reviewed for adequacy and the sign-off performed by a person other than the originator of the design. The originator's supervisor may perform this independent review only if the !
supervisor: (1)did not specify a singular design approach, (2) did not '
establish the design inputs or rule out certain design considerations, (3)is the only individual in the organization competent to perform the review. l Where the supervisor performs the design review, the next level of !
management shall fulfill the supervisor's responsibilities. Design verification l is documented in accordance with procedures or instructions. Simplified l calculations or computer programs may be utilized as attemate means of design verification. When design verification is performed by testing, the tests are performed using procedures, which specify the authority and responsibility of design verification personnel. Responsibility for design adequacy and evaluation is retained by Engineering Services or Unit 1 Decommissioning as appropriate.
O QAP - 3.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 4 of 5
F Design verification (if other than by qualification testing) is normally completed prior to release for procurement, fabrication, and construction, or release to another organization for use in other design activities. For those cases where design verification cannot be completed prior to release for procurement, fabrication, and construction, procedures assure that design verification is completed prior to the point when the installation is declared operational.
i Procedures describe the requirements which assure the following when testing is considered as an attemate method of design verification:
i
- a. Specifications or procedures provide criteria that specify when ;
verification should be by test.
I
- b. Prototype, component or feature testing is performed as early as possible prior to installation of plant equipment, or prior to the point
' when the installation is declared operational.
- c. Verification by test performed under conditions that simulate the most adverse conditions as determined by analysis.
Particular emphasis is placed on assuring that designs are in conformance with applicable codes, and on selecting the proper design verification or O checking method. Procedures and instructions provide the requirements and necessary controls for design verification. These controls include a review to assure that design characteristics can be controlled, verification that there is adequate accessibility for inspection or test, and that inspection and test acceptance criteria are incorporated. Documentation of reviews is provided. I Procedures include requirements which identify the responsibility of design verifiers, the areas and features to be verified, and the extent of the documentation.
Procedures assure that procedural control is established for design documents that reflect the commitments of the nuclear unit FSAR. These procedural controls vary for design documents which receive formal design verification by several disciplines or organizations, and those which can be reviewed by a single individual. The specific design documents and specialized reviews are determined and used as required by the design changes and modifications.
Procedures are established to assure that verified computer programs are certified for a specific use.
i l
NNECO is responsible for assuring that the design documents generated by vendors for the Station nuclear power plants are technically correct, approved, and maintained.
OAP - 3.0 Rev. 21 Chg. 01 Date: 9/2/99 Page 5 of 5
4.0 PROCUREMENT DOCUMENT CONTROL
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4.1 GENERAL' REQUIREMENTS l
This NUQAP provides measures to control the procurement of materials, equipment, parts and services for quality structures, systems, and i components for the Millstone Station nuclear power plants to assure compliance with applicable regulatory requirements, procedures, quality assurance standards, and regulations affecting procurement documents.
Changes to procurement documents are subject to the same degree of control as utilized in the preparation of the original documents.
4.2 IMPLEMENTATION 4.2.1 PROGRAM A responsible engineer is selected for each modification to a Station nuclear power plant. The responsible engineer coordinates the preparation, review and approval of procurement documents for quality materials, equipment, parts and services, and assures the technical adequacy and inclusion of quality assurance requirements.
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Requests for materials, equipment, parts and services are reviewed for technical adequacy and verification of the quality ,
designation. The appropriate responsible engineer / nuclear unit )
management reviews and approves such requests in accordance with applicable procedures. Nuclear Materials and Document Management personnel then perform a procurement engineering evaluation to assure the inclusion and adequacy of quality assurance requirements prior to the issuance of the purchase order. Materials, equipment, and parts for which technical and quality assurance requirements have been previously established within the Material Infom1ation Management System are purchased without additional procurement engineering evaluations.
Vendors utilized to perform quality activities for the Station nuclear power plants are responsible to implement measures for control of associated procurement documents to assure applicable requirements including quality assurance requirements are specified.
Audits, surveiIlances, and inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for the control of procurement documents.
QAP - 4.0 Rev. 21 Date: 9/2/99 Page 1 of 3
4 e Changes to procurement documents, whether initiated by NNECO
\ or its representative, are subjected to the same degree of control as that utilized in the preparation of the original document. The procurement of spare or replacement parts for. quality structures, systems, or components is subject to the controls of this NUQAP and applicable procedure requirements. The spare or replacement parts are subject to controls equivalent to original or subsequent codes and standards. The use of subsequent codes and standards are controlled in accordance with QAP 3.0, " Design Control".
Procurement engineering evaluations of requests for quality materials, equipment, parts, and services requests are performed by Nuclear Materials and Document Management personnel to assure that:
- a. Adeqt ate technical requirements are specifed;
- b. The quality assurance requirements are correctly stated, auditable and controllable;
- c. There are adequate acceptance and rejection criteria.
4.2.2 PROCUREMENT DOCUMENT PROVISIONS i Procurement documents are prepared, reviewed and approved in accordance with applicable procedures of the issuing organization or department and are available for verification. These !
procedures require that procurement documents consist of the !
following, as necessary:
- a. The scope of work to be performed; i
- b. Technical requirements (specified or referenced) including the applicable components .and materials identification requirements, drawings, speedications, procedures, instructions, codes and regulations, and the identification of applicable test, inspection and acceptance requirements, or special process instructions;
- c. Quality assurance program requirements to be imposed on vendors which include the applicable requirements of 10 CER 50, Appendix B, and the NRC regulatory position contained in the regulatory guides and their endorsed ,
ANSI /IEEE standards listed in Appendix C. !
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p d. Right of access which provides, as appropriate, for access i
to vendor facilities and records for inspection or audit by NNECO or its designated representative; and provides access for events such as those requiring notification of hold points;
- e. The documentation required to be prepared, maintained, and/or submitted to NNECO or its representative for review, approval or historical record. The time of submittal of this documentation and the retention and disposition of quality assurance records which are not submitted to NNECO is prescribed, as applicable, for nuclear grade procurements.
.4.2.3 SELECTION OF PROCUREMENT SOURCES The vendor is specified during the procurement process based upon the vendor approval status, qualifications and capabilities to provide the product or service, performance history, and NNECO's ability to verify the quality of the product or service being purchaced. NNECO maintains an approved vendors list based upon the technical and quality capability as determined by a direct evaluation of the vendor's facilities and personnel and the implementation of the vendor's quality assurance program.
/~N t Procurement documents may be issuer' 'o vendors with unapproved quality assurance p.% grams. Thet e procurement documents to unapproved vendor contain detailed Jmplementary quality assurance requirements and/or witness / hold points to meet NNECO requirerrtnts.
Procurement documents arts reviewed by Nuclear Materials anJ Document Management to assure appropriate quality assurance requirements are specified. The requirements include, as necessary, audits, surveillances, or inspections at the vendor's facilities with scheduled witness / hold points during the fabrication process and/or prior to shipment of the procured items.
Acceptance inspections and tests determined by NNECO shall be performed after receipt at Millstone Power Station but prior to installation in the plant or prior to the point when the installation is declared operational.
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O 5.0 PROCEDURES. INSTRUCTIONS AND DRAWINGS 5.1 GENERAL REQUIREMENTS This NUQAP provides measures for the preparation, review, approval, control and i
distribution of procedures, instructions and drawings for activities affecting quality '
structures, systems,. and components of the Millstone Station nuclear power plants. The documents include appropriate quantitative and qualitative acceptance criteria which specify the activity to be performed, the methods of fabrication, construction, and testing to be employed; the materials, equipment or parts to be used; a sequence of operation, and the required documentation.
5.2 IMPLEMENTATION Quality procedures provide direction for personnel performing quality activities.
The Nuclear Oversight Department reviews and concurs with other department quality procedures which implement this NUQAP as described in Section 5.2.1 below. Comments conceming compliance with this NUQAP and regulatory requirements are resolved prior to issuance of the procedure. Any vendors utilized to perform quality activities for the Station nuclear power plants may be delegated responsibility for preparing, maintaining, issuing and verifying the implementation of appropriate program documents which are selectively reviewed / approved by the appropriate Director or Responsible Engineer. Audits, curveillances, and O inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for compliance with procedures and instructions. Vendor quality assurance programs are required to cleariy delineate the actions to be accomplished in the preparation, review and control of procedures, instructions and drawings and the methods for complying with 10 CFR 50, Appendix B.
5.2.1 P_ROCEDURES AND INSTRUCTIONS Procedures and instructions for activities affecting quality are prepared, reviewed, and approved in accordance with written procedures and instructions.
The cognizant Director or responsible engineer assures that any vendors utilized to perform quality activities for the Station nuclear power plants
' implement quality assurance programs which contain written instructions for preparation, review and approval of procedures and instructions affecting quality. In addition, vendor quality procedures and quality control inspection procedures which are to be used for onsite activities
. are reviewed for concurrence by Nuclear Oversight to assure compliance with the vendors quality assurance program.
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i NNECO is responsible for the preparation, review and approval of station and plant quality procedures. The procedures include test procedures and overall site administrative procedures which implement the requirements of this NUQAP. Each NUSCO/NNECO organization is also responsible for the preparation, review and approval of procedures covering quality activities in accordance with individual license requirements. The Nuclear Oversight Department reviews and concurs
) with quality procedures and special process procedures. The criteria for l documents requiring Nuclear Oversight review and concurrence and their identification are defined in quality procedures to assure:
I
! a. Administrative procedures and manuals comply with this NUQAP and applicable Appendix C regulatory guides and endorsed ANSI /IEEE l standards.
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- b. Work procedures and work documents used to perform quality activities have the necessary quality assurance controls as described in QAP 10.0, " Inspection". I 5.2.2 DRAWINGS l
The design control and verification measures described in QAP 3.0, l
- Design Control", are applicable for the review and approval of drawings.
n Review and approval of new drawings or modifications to existing Q drawings are described in NUSCO/NNECO procedures. The originating organization may delegate to other organizations or departments the work of design and review activities, or any part thereof, but retains responsibility for this work.
The measures taken to assure the preparation of as-built drawings and related documentation in a timely manner to accurately reflect the actual plant are described in NUSCO/NNECO procedures. Drawings critical to operation are updated prior to system tumover to operation and are available to the operating personnel.
5.2.3 ACCEPTANCE CRITERIA Cognizant Department Heads review and approve departmental -
procedures, instructions and drawings to assure the inclusion of L adequate quantitative and qualitative acceptance criteria, as appropriate, l for determining satisfactory work performance and quality compliance for applicable quality activities. ,
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6.0 DOCUMENT CONTROL 6.1 - GENERAL REQUIREMENTS This NUQAP provides measures to assure controlled distribution of documents pertinent to quality activities performed for the Millstone Station nuclear power plants in accordance with quality procedures.
Documents such as procedures, instructions, drawings, specifications and reports I are prepared, reviewed for appropriate qualitative and quantitative acceptance criteria, and approved by authorized personnel in the affected organization. i Approved controlled documents are distributed to affected locations in accordance
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with controlled distribution lists. Changes to controlled documents are reviewed and approved by the same organization which performed the original review and approval, unless otherwise specified in the applicable procedures. Measures are provided for controlling documents to preclude the possibility of use of outdated documents.
' 6.2 IMPLEMENTATION 6.2.1 RESPONSIBILITY NUSCO/NNECO procedures and instructions delineate the measures for O controlling documents including direction for the review for adequacy, approval by authorized personnel, distribution of controlled documents and verification that changes are promptly incorporated and '
implemented. These control measures apply to documents affecting quality structures, systems and components during the performance of quality activities for the Station nuclear power plants and include documents such as:
- a. Design Specifications; !
- b. Design, Manufacturing, Construction and Installation Drawings; i
- c. As-Built Documents;
- d. Quality Assurance Program Manuals, Procedures and Instructions;
- e. Manufacturing, inspection and Testing instructions;
- f. Test Procedures;
- g. Calculations;
- h. Engineedng Record Correspondence; Rev. 21 Date: 9/2/99 Page 1 of 3
- i. Design Basis Documentation Summaries (DBDS)
J J. Final Safety Analysis Reports;
- k. Procurement Documents;
- l. Design Change Records;
- m. Topical Report; l
- n. Nonconformance Reports; I
- o. Computer Codes NUSCO/NNECO procedures describe the measures taken by the Nuclear Oversight Department or individuals other than the person who generated the document but qualified in quality assurance for the control of documents to assure review and concurrence, as necessary, for such documents listed above with regards to quality assurance aspects.
The requirements for control of procurement documents are contained in QAP 4.0, " Procurement Document Control *. It is the responsibility of each organization issuing controlled documents to employ document control procedures. The issuing organization is additionally responsible O for distribution of the documents to appropriate locations. There shall be provisions to assure that approved changes are included in instructions, procedures, drawings and other documents prior to implementation of the changes.
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. Any vendors utilized to perform quality activities for the Station nuclear !
power plants are responsible for implementing measures for review, approval, control and distribution of controlled documents to assure they are effectively complying with the requirements for document control.
Audits, surveillances, and inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for document control.
6.2.2 DISTRIBUTION OF CONTROLLED DOCUMENTS !
NUSCO/NNECO procedures - specify in what manner controlled documents, and revisions thereof, are distributed to appropriate locations prior to commencing the work.
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l 6.2.3 DRAWING CONTROL Station Nuclear Document Services is responsible to implement a '
program, through applicable procedures, for the retention and retrieval of drawings and records submitted by cognizant NUSCO/NNECO personnel. Station Nuclear Document Services maintains a drawing status file which includes drawings newly issued or revised with the latest revision and current status.
Vendors utilized to perform quality activities for the Station nuclear power plants may be delegated the function of drawing control and must fumish i
periodic status reports listing the revisions of applicable drawings which they issue.
Audits, surveillances, and inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for control of drawings.
6.2.4 ~ PROCEDURE AND INSTRUCTION CONTROL Nuclear Oversight performs audits, surveillances, and inspections, as appropriate, to verify that NUSCO/NNECO Departments are effectively complying with this NUQAP and procedural requirements, for control of procedures and instructions. Audits, surveillances, and inspections are performed, as appropriate, to verify vendors utilized to perform quality activities are effectively complying with their quality assurance program requirements for control of procedures and instructions.
The originating department is responsible for establishing adequate control over quality procedures and instructions issued by them. The responsible organization also issues status reports or revised indices listing the latest revision of applicable controlled documents issued by them.
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7.0 CONTROL OF PURCHASED WIATERIAL. EQUIPMENT AND SERVICES l 7.1 GENERAL REQUIREMENTS This NUQAP provides measures for the control of purchased material, equipment, parts and services utilized in quality activities for the Millstone Station nuclear power plants to assure conformance to procurement documents. These measures include provisions for source evaluation and selection, submission of objective evidence by the vendor or subvendors, inspection at the vendor facility, and acceptance inspection and testing of the product upon delivery. Control of quality by vendors and their subvendors is assessed for effectiveness at intervals consistent with the importance, complexity and quantity of the product or service.
7.2 IMPLEMENTATION The evaluation and selection of vendors is performed in accordance with procedures, which specrfy that procurement source evaluation and selection measures are performed to determine vendor capability and delineate responsibilities of qualified personnel involved in the evaluation and selection process.
1 7.2.1 . VENDOR QUALIFICATIONS Nuclear Materials and Document Management utilizes one or more of the O following methods in evaluating the qualifications of a potential vendor: j l
- a. Audits performed by Nuclear Oversight or Nuclear Materials and Document Management and/or coordinated review of potential vendor-utilizing one or more departments (i.e., engineering, s/fe services, operations; procurement);
- b. Other utility vendor audits and evaluations;
- c. Nuclear Procurement issues Committee (NUPIC) audits; I
- d. ASME N, NA, NPT, NV, or MM/ MS Certificate of Authorization; l
- e. Commercial grade surveys and/or coordinated review of a potential vendor utilizing one or more departments, (i.e., engineering,. slie services, operations; procurement);
- f. Source inspechon/ surveillance.
I Evaluations assure that vendors providing quality material, equipment, parts !
and - services employ a quality . assurance prograrn that conforms to applicable portions of this NUQAP.
l Nuclear Materials and Document Management is responsible for assuring '
that documented evidence of the evaluation and acceptance of the vendor's QAP - 7.0 4 Rev. 21, Chg. 01 ;
Date: 9/2/99 Page 1 of 4
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i q quality assurance program is maintained. The determination of vendor
' Q approvalis based on such factors as prior performance, quality performance data, audits, commercial grade surveys, surveillances and evaluations of the ,
vendor's quality assurance program.
Vendor Certificates of Conformance are periodically evaluated by audits, commercial grade surveys, surveillances, independent inspections and tests, to assure they are valid. This verification of Certificates of Conformance is documented.
7.2.2 SOURCE INSPECTION Nuclear Materials and Document Management is responsible for the performance of source inspections at vendor facilities to assure that the requirements of a purchase order / contract have been met.
Source inspections are performed in accordance with procedures which provide for the method of inspection, the extent of documentation required and those responsible for implementing those instructions.
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inspection of items occurs either when verifications of procurement j requirements cannot be determined upon receipt or the vendor quality (
assurance program has not been accepted by Nuclear Materials and 1 Document Management.
s) l 7.2.3 RECEIPT INSPECTION l
Receipt inspection for procured items is performed by Nuclear Materials and l Document Management in accordance with quality procedures which I delineate requirements and responsibilities necessary to perform inspection functions. The exception to this is Reactor Engineering performing receipt inspection for new fuel assemblies in accordance with quality procedures.
Contractual obligation fulfillment and specified requirements are verified during receipt inspections.
Receipt inspection of vendor-fumished material, equipment, and parts is performed to assure that these items and acceptance records are examined in accordance with predetermined inspection instructions prior to acceptance, !
installation and operation. Receipt inspections include, as appropriate: I
- a. Measures for verifying that the shipment is complete, properly I identified, undamaged and correspends with the required documentation;
- b. Measures for inspection of the item's critical characteristics and review of supporting documentation (e.g., mill test reports, NDE reports) as
% required by the procurement documents; Iv ),
QAP - 7.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 2 of 4
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, p c. Measures for inspection and acceptance of items in accordance with Q predetermined methods;
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- d. Measures for identifying and controlling acceptable items including 4 ldentification of inspection status prior to release from the receiving inspection area;
- e. Measures for identifying, segregating and handling nonconforming items;
- f. Measures to ascertain that inspection records or Certificates of Conformance are acceptable prior to release for installation;
- g. In cases involving purchased services, the responsible engineer or Department Head shall designate the means by which services may be accepted, and is given the authority to accept services in accordance with methods defined in NUSCO/NNECO procedures.
7.2.4 VENDOR FURNISHED RECORDS Records required to be fumished by the vendor are specified in the procurement documents. Certifications or documentation provided by the vendor which attests to conformance, identifies that all the specific n procurement requirements have been met (either by reference to the purchase order or by delineation).
The vendor must fumish the following records as a minimum for nuclear grade purchases:
- a. Documentation that identifies the purchased material, equipment, or parts and the specific procurement requirements (e.g., codes, standards and specifications) which have been met by the items;
- b. Documentation that identifies any procurement requirements which have not been met, together with a description of those Nonconformances dispositioned " accept as is" or " repair."
The responsible Nuclear Materials and Document Management and/or engineering and other appropriate department personnel shall review for acceptability those documents which pertain to the requirements in the procurement document, in accordance with this NUQAP and applicable procedures.
The department that is contracting onsite quality assurance services shall be responsible for the review and acceptability of vendor personnel / equipment certifications prior to the start of work. The Nuclear Oversight department q shall provide oversight o, nese activities via surveillance, or inspection, as Q appropriate, to verify compliance with this requirement.
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7.2.5 COMMERCIAL DEDICATION NNECO procedures address the measures taken to assure that for commercial grade items, where specific quality assurance controls for nuclear applications cannot be imposed in a practicable manner, that special dedication requirements are established and implemented.
These measures follow the guidance in Regulatory Guide 1.144, paragraph C. 3. b (1) and Regulatory Guide 1.123 and applicable paragraphs of Section 10 of ANSI N45.2.13.
These measures include appropriate requirements for special categorization and identification within the procurement document, receiving inspection, and additional controls during the installation and testing process to be performed 1 by Nuclear Materials and Document Management, other NUSCO/NNECO Departments, or other appropriate groups. J I
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8.0 IDENTIFICATION AND CONTROL OF MATERIALS. PARTS AND COMPONENTS l 8.1 GENERAL REQUIREMENTS i
l This NUQAP provides measures for the identification and control of materials, parts and components, including partially fabricated assemblies utilized in quality activities for the !
Millstone Power Station. To assure that each item can be traced to assseiated documentation, the identification of the item is maintained by heat number, lot number, part number, serial number, or other appropriate methods, and is physically marked on the item and/or on records traceable to the item. Documentation associated with materials, parts, and components delineate that these items have been designed, fabricated, manufactured, tested and/or inspected in accordance with the specified requirements.
The object of these controls is to prevent the use of incorrect or defective materials, parts and components.
These measures also require NNECO assure that the identification of inspections, tests, and operation status of structures, systems, and components is known to affected organizations.
8.2 IMPLEMENTATION NNECO procedures establish the responsibilities and requirements for the identification and control of materials, parts and components. The procedures assure that identification and control are maintained throughout fabrication, receipt, handling, storage and O installation of items. Provisions include:
- a. Requirements for traceability to appropriate documentation such as: purchase ,
orders, contracts, manufacturing documents, drawings, specifications, j certifications, inspection and test records, and nonconformance reports-
- b. Controls to assure that the correct identification of an item is verified and i documented prior to release for fabrication, assembly, shipping or installation;
- c. Requirements which assure that the method or location of markings do not affect !
the function or quality of an item;
- d. Establishment of identification requirements in purchase orders, contracts, specifications, drawings, procedures or instructions.
' During the performance of quality activities for the Station nuclear power plants, NNECO may delegate any portion of the implementation of the identification and control program to a vendor if delegated, contracts require that the vendor establish an identification and control program which meets this NUQAP requirements. Audits, surveillances, and inspections are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for identification and control of materials, parts and components.
O QAP - 8.0 Rev. 21 Date: 9/2/99 Page 1 of 2 '
Receipt inspections are performed to verify that materials, parts and components are properly identified in accordance with procurement requirements. Nuclear Materials and Document Management is responsible for assigning and applying necessary identification to the items in accordance with applicable procedures to assure proper identification and traceabiltiy.
In the event that materials, parts or components are nonconforming or the identification becomes lost or illegible, the items are considered nonconforming and are identified and controlled in accordance with QAP 15.0, " Nonconforming Materials, Parts, Components, or Seivices",
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,7-~ 9.0 CONTROL OF SPECIAL PROCESSES L)g 9.1 GENERAL REQUIREMENTS This NUQAP provides measures to assure the control of special processes associated with quality structures, systems, and components of the Millstone Station nuclear power plants by the use of qualified procedures, equipment and personnel.
Special processes are performed under controlled conditions in accordance with special requirements and may include, but are not limited to: welding, cleaning, heat treating, and nondestructive examination and/or testing.
9.2 IMPLEMENTATION During quality activities performed for the Station's nuclear power plants, the responsible i engineer assures that special process data and documentation is reviewed, and that I vendor special process procedures utilized for the Station nuclear power plants are qualified and approved, and that personnel and equipment utilizing special processes are properly qualified prior to start of work. Audits, surveillances, and inspections are l performed, as appropriate to verify that these vendors are effectively complying with their quality assurance program requirements for control of special processes.
NUSCO/NNECO special process procedures utilized during quality activities for the gm s Station nuclear power plants are prepared, reviewed and approved in accordance with Q procedures as specified in QAP 5.0, " Procedures, instructions, and Drawings" 9.2.1 PROCEDURE QUALIFICATION AND CONTROL NUSCO/NNECO procedures specify that written process control documents are utilized and qualified, as required, in accordance with the applicable specification, codes or standards.
9.2.2 PERSONNEL QUALIFICATION AND CERTIFICATION Codes, standards and NUSCO/NNECO procedures specify personnel qualification / certification requirements. Personnel responsible for the performance and verification of special processes are trained, tested, and certified as required by applicat,ie specifications, codes and standards.
Requirements for the period of certification, examinations, and certification renewal of personnel are also specified. Vendors qualify personnel and maintain records of qualified personnel in accordance with applicable codes, standards, specifications, and vendor purchase order / contract requirements.
The department that is contracting services is responsible for the review of records of qualified personnel, equipment and procedures associated with n special processes. Nuclear Materials and Document Management or Nuclear QAP - 9.0 Rev.21 Date: 9/2/99 Page 1 of 2
Oversight shall provide an oversight function via audits, surveillances, or O- inspections, as appropriate.
The Nuclear Oversight Department is responsible for assuring the training, ,
' testing, and certification of all the Millstone Power Station NU NDE personnel is '
in accordance with the requirements of Regulatory Guide 1.58 (Rev.1, 9/80) and ASNT Recommended Practice No. SNT-TC-1A.
l 9.2.3 SPECIAL PROCESS RECORDS Records provide objective evidence that special processes were performed in accordance with applicable procedures, by qualified personnel, and that when required by. procedures, specifications and codes, such performance was verified. Results of nondestructive examinations are recorded in accordance with applicable specifications, codes and standards. These records are retained by the vendor or supplied to NNECO as required by contract or purchase order, if records are to be retained by the vendor, the contract or purchase order specifies the retention period and instruction for final disposition of records.
Special process documentation such as special process procedures, qualifying data, and personnel and equipment qualification records associated with the performance of special processes at Station nuclear power plants, are kept O current and maintained in appropriate NNECO files, with final disposition to the Station Nuclear Document Services Facility.
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10.1 GENERAL REQUIREMENTS This NUQAP provides measures to assure that inspections of Millstone Station nuclear power plants quality structures, systems, and components to verify conformance with documented procedures, instructions and drawings are executed in accordance with
. procedures by qualified personnel independent from the individual or group performing the activity being inspected, if inspection is impossible or disadvantageous, indirect controls by monitoring processing methods, equipment and personnel are provided. inspection notification and hold points are identified, as required, in the applicable documents.
10.2 lMPLEMENTATION 10.2.1 INSPECTION RESPONSIBILITIES During the performance of quality activities for the Station nuclear power plants, procedures shall define the need for inspection (e.g., reedpt inspection, installation, and product acceptance) to assure quality requirements are met Nuclear Oversight shall perform, as appropriate, audits and surveillances as defined in Nuclear Oversight procedures to verify that procedural requirements are met.
The Nuclear Oversight Department shall perform inspections of modification and maintenance activ; ties for quality structures, systems, and components. The criteria used to determine when Nuclear Oversight inspection shall be required for these activities and for the preparation of inspection plans shall be identified in Nuclear Oversight procedures. The Nuclear Oversight inspection function includes:
- a. Identification of inspection personnel;
- b. Review of work procedures and work documents for adequacy of ;
inspection and mandatory hold points; '
- c. Preparation and approval of inspection plans ensuring that the necessary inspection requirements, methods, and acceptance criteria have been identified;
- d. Dccumentation of inspection results.
Audits, s1rveillances, and inspections, are performed as appropriate, to verify that any sendor utilized to perform quality activities for the Station nuclear power plants aie effectively complying with their quality assurance program j requiremer.ts for inspection and for the performance or witnessing of inspections at hold or notification points identified in procurement documents. Nuclear i QAP - 10.0 Rev. 21 Date: 9/2/99 Page 1 of 4
O Oversight performs audits, surveillances, and inspections, as appropriate, of onsite vendor activities in this area. All audit, surveillance, and inspection activities are performed under requirements specified in quality procedures.
l 10.2.2 INSPECTION PLANS Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans are based on design specifications, procurement documents, drawings, other specifications, or previous experience, as appropriate.
During the performance of quality activities, procedures provide criteria for the determination of accuracy requirements of inspection equipment and when inspections are required. These procedures describe requirements for the preparation of inspection plans by the Nuclear Oversight Department. Audits and surveillances are performed by the Nuclear Oversight Department, as appropriate, to verify the implementation of the inspection plans.
The inspection criteria, including the use of inspection equipment and their-accuracy requirements, are specified in the work procedures, work documents, or inspection plans.
10.2.3 INSPECTION PERSONNEL AND INSPECTION DOCUMENT ACCESS .
Inspections are performed by individuals other than those who performed or directly supervised the activity being inspected. Inspection personnel are qualified and/or certified in accordance with appropriate codes, standards, and/or NU training programs; Inspections are performed by Nuclear Oversight Department personnel, qualified !
contracted personnel, and NUSCO/NNECO personnel who are independent from undue pressure such as cost, or schedule considerations. Nuclear Oversight shall '
assure the certification of its contracted inspection personnel is acceptable prior to the performance of inspection activities. When other departments are contracting for onsite quality assurance inspection services, these departments shall be responsible for the review and acceptability of personnel / equipment certification prior to the start of inspection activities. Nuclear Oversight shall perform audits and surveillances, as appropriate, to verify other department compliance with these I requirements.
When vendors are contracted to perform onsite inspection services, their quality control inspection plans / procedures are reviewed and concurred with by Nuclear Oversight in accordance with QAP 5.0, " Procedures, instructions, and Drawings".
Access to d%ngs, procedures, specifications or other documented criteria !
necessary for the performance of inspections is provided prior to performing the inspection activity, t
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10.2.4 INSPECTION PROCEDURES Required inspection or surveillance activities are performed and documented according to procedures and/or checklists. Inspection procedures, plans or checklists contain the following:
- a. Identification of characteristics to be inspected;
- b. Identification of the individual or groups responsible for performing the inspections;
- c. Requirements for the necessary measuring and test equipment and the required accuracy of this equipment;
- d. Acceptance criteria; -
- e. A description of the method of inspection when other than direct visual examination using the unaided eye;
- f. A record of the results of the inspection;
- g. Record of inspector or data recorder.
Procedures specify surveillance of processing methods or testing and operation of equipment when inspection is impossible, inaccessible or not applicable.
Modification, repair, replacement, or rework items are inspected in accordance with original inspection requirements or approved attematives. l l
10.2.5 MANDATORY HOLD AND NOTIFICATION POINTS Mandatory hold points are utilized when an inspection or operation must be performed or witnessed and signed off by the responsible personnel before work can proceed. Mandatory hold points are identified to assure attributes critical to achieving quality requirements at work completion have been verifed.
Mandatory notification points are used to identify the operations or completed processes that NNECO or its representatives may elect to witness and/or inspect during the fabrication, construction and installation process. Mandatory hold points and notification points, as required, are identified in procurement {
documents and onsite work procedures / work documents. Procurement documents and onsite work procedures / work documents are subject to the ')
review and concurrence for adequacy of inspection, notification and/or I mandatory hold controls by Nuclear Materials and Document Management and Nuclear Oversight, respectively. ,
1 O QAP - 10.0 Rev. 21 I Date: 9/2/99 l Page 3 of 4 1
l p 10.2.6 INSPECTION RESULTS EVALUATION 1 %J l Inspection results are evaluated for acceptability in accordance with applicable procedures which identify the responsible organization.
l The evaluations are performed by the personnel who are qualified in accordance with the appropriate regulatory guide and endorsed ANSI standard listed in Appendix C.
Nuclear Oversight performs audits and surveillances, as appropriate, to verify that inspections are performed in accordance with the requirements of applicable procedures, l
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l O 11.0 TEST CONTROL 11.1 GENERAL REQUIREMENTS This NUQAP requires a documented test control program for Millstone Station nuclear power plants quality structures, systems, end components be established to assure that they will perform satisfactorily in service and that test results are documented in accordance with appbcable regulatory and technical requirements.
The test control program identifies the quality structures, systems, and components to be tested, method of conducting tests, evaluation of tests and documentation of tests by qualified personnel to assure requirements have been satisfied.
The test control program is systematic and includes proof tests prior to installation, construction tests, operational tests, surveillance tests, and tests following repairs, reworks, replacements, preventive maintenance or modifications as required to verify performance will be satisfactory during operation.
11.2 IMPLEMENTATION 11.2.1 TEST PROGRAM Test requirements to determine or to verify the capability of an item to meet specified requirements in accordance with design documents, Safety Analysis Reports (SAR), Technical Specifications, procedures or procurement documents, as appropriate, are accomplished by subjecting the item to a set of physical, chemical, environmental or operating conditions. Tests following repair, rework, replacement, preventive maintenance or modification is performed, as required, in accordance with the original design requirements of the item or acceptable attematives, as applicable. A Test may be repeated when original test results are invalidated.
NUSCO/NNECO procedures delineate the methods and responsibilities for controlling, accomplishing and documenting testing of the Station nuclear power plants quality structures, systems, and components. i l
Vendors utilized to perform quality activities for the Station nuclear power plants I are responsible for implementing measures for the control of tests to assure that materials, equipment and parts used in quality structures, systems, and ,
components will perform satisfactorily. Audits, surveillances, and inspections, are l performed as appropriate, to verify the performance of selected proof tests when I hold points have been identified in purchase order / contracts and to verify these vendors are complying with their quality assurance program requirements for test control. Nuclear Oversight performs audits, surveillances, and inspections, as appropriate, of onsite vendor activities in this area. Nuclear Materials and Document Management and Nuclear Oversight are responsible for assuring documentation associated with these verification activities are maintained in the j QAP - 11.0 !
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appropriate files until forwarded to the Station Nuclear Records Facility in accordance with applicable procedures.
Proof tests, product acceptance tests, post maintenance or modification tests, and periodic surveillance tests are conducted by qualified personnel in accordance with applicable procedures. Personnel performing tests assure that calibrated equipment and instrumentation utilized are within the calibration interval specified. Documentation including test procedures and approved data sheets are maintained in appropriate files until forwarded to the Station Nuclear
' Records Facility in accordance with applicable procedures.
11.2.2 TEST PROCEDURE PREPARATION AND TEST PERFORMANCE Testing is accomplished in accordance with approved test procedures which incorporate or reference the requirements and acceptance criteria in the applicable design and procurement documents. The test procedure or test program documents include the following as a minimum:
- a. Instructions for the testing method used;
- b. Required test equipment and instrumentation; V
- c. Test requirements, such as acceptance criteria;
- d. Hold, notification, inspection points, if required, and data collection points; ,
- e. Test prerequisites such as: calibrated instrumentation; trained, qualified, and - licensed or certified personne!; preparation, condition and completeness of item to be tested; suitable and controlled environmental conditions;
- f. Methods for documenting or recording test data and results;
- g. Provisions for data collection and storage.
l 11.2.3 TEST EQUIPMENT i NUSCO/NNECO procedures provide the criteria, for determining when a test is required and the accuracy requirements of test equipment. The following steps are taken for the control of test equipment;
- a. To assure accuracy, test equipment is checked and calibrated in accordance with NUSCO/NNECO procedures;
- b. Plant instrumentation used in testing is calibrated. It is maintained in calibration at regular intervals in accordance with established surveillance and/or preventative maintenance procedures; OD QAP - 11.0 Rev. 21 Date: 9/2/99 Page 2 of 3
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- c. Where special instrumentation is required for testing, the requirements are iO stated in the procedures. Instrument characteristics, including accuracy requirements, are equivalent to or better than those specified by the vendor, 11.2.4 EVALUATION OF TEST RESULTS The documented test 'resuits are evaluated against the predetermined acceptance criteria by an individual or group having appropriate qualifications.
The acceptance status of the test is documented.' Deficiencies noted during the evaluation are documented and dispositioned in accordance with procedures.
The evaluation of test results may also be delegated to vendors.- When delegated, the vendor is required to assure the use of qualified personnel, evaluate the data against predetermined criteria and document the results of the evaluation and acceptance status of the test. Audits, surveillances, and inspections, are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for test control. Nuclear Oversight performs audits, surveillances, and inspections, as
. appropriate, of onsite vendor activities in this area.
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12.0 CONTROL OF MEASURING AND TESTING EQUIPMENT 12.1 GENERAL REQUIREMENTS -
This NUQAP provides measures for the control of measuring and testing equipment (M&TE) used as the basis for acceptance during inspection, testing, and measurement of materials, equipment, and parts affecting quality structures, systems, and components. Periodic calibration and-adjustment of M&TE is performed and controlled to assure accuracy is maintained within limits necessary to verify that design and operating condition requirements have been met. Documentation is retained such that all items of M&TE are traceable to their calibration records.
~ 12.2 IMPLEMENTATION 12.2.1 CALIBRATION PROGRAM Procedures delineate the methods and responsibilities for the control, maintenance and calibration'of M&TE including portable and temporarily installed instruments, tools, gages, fixtures, reference and transfer standards, and nondestructive test equipment.
Documentation associated with the calibration of all M&TE is maintained in
. appropriate files and retained as quality records in accordance with the NU Nuclear O Records Program. When the information for the control, use, and calibration of M&TE is in electronic form, this information is controlled and protected in accordance with applicable procedures.
The calibration program is implemented in accordance with the requirements defined in NUSCO/NNECO procedures which describe the measures utilized to maintain the calibration of the M&TE. Functional groups are responsible for implementing these procedures which comply with the requirements contained in specifications and drawings. Procedures related to the M&TE calibration program are reviewed and approved by the appropriate on-slie review committee or the Station Qualified l Reviewer Program, as defined in applicable procedures. Nuclear Materials and Document Management or the appropriate M&TE custodian, as delineated by the
- purchase order, is responsible for verifying that receipt of calibrated equipment is in coriformance with the requirements of procurement documents. Nuclear Materials l and Document Management and Nuclear Oversight are responsible for control of calibrated M&TE used during their inspections.
Department Heads / Job Supervisors are responsible to assure that M&TE is calibrated,' issued, and controlled in accordance with the requirements of applicable ;
procedures. 1 The Nuclear Oversight Department performs audits, surveillances, and inspections, as appropriate, to verify implementation of the calibration program. I
' Vendors utilized to perform quality activities for the Station nuclear power plants are l 0 responsible for implementing measures for the control of M&TE to assure the M&TE QAP - 12.0
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are properly calibrated, adjusted and maintained at specified intervals in order to maintain accuracy within required limits; Audits, surveillances, and inspections, are performed, as appropriate, to verify these vendors are effectively complying with their quality assurance program requirements for control of M&TE.
12.2.2 CALIBRATION STANDARDS Measuring and test equipment is calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement. Measuring and test equipment shall be permanently marked or tagged with a unique identification number and the date calibrated and next calibration date indicated on the M&TE.
Procedures describe the measures taken to assure that reference and transfer standards are traceable to nationally recognized standards and that, where national ,
standards do not exist, provisions are established to document the basis for calibration.
Calibration of this equipment should be against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated. When this is not _ possible, the standards shall have an accuracy that assures the equipment being calibrated shall be within required tolerance and the basis of acceptance is documented and authorized by the appropriate on-site review .
committee. In addition, the calibrating standards shall have greater accuracy than
( secondary standards being calibrated. Calibrating standards with the same accuracy may be used if they can be shown to be adequate for the requirements and the basis of acceptance is documented.
12.2.3 "OUT OF TOLERANCE" CONTROL M&TE and reference standards when found out of tolerance are so identified and removed from service. A timely review is conducted to determine the validity of previous inspection or test results gained through use of the instrument, and of the acceptability of items previously measured or tested. Where it is determined that use of out of tolerance measuring and test equipment may have resulted in a condition adverse to quality, the condition is promptly identified and corrective action is implemented in accordance with QAP 15. " Nonconforming Materials, Parts, Components or Services" and QAP 16, " Corrective Action" respectively as appropriate.
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Q v 13.0 HANDLING. STORAGE AND SHIPPING 13.1 GENERAL REQUIREMENTS l This NUQAP provid3s measures to assure proper handling, storage, shipping, cleaning and preservation of materials, equipment and parts used for Millstone Station nuclear power plant quality structures, systems, and components in order to preclude damage, loss or deterioration.
13.2 IMPLEMENTATION 13.2.1 GENERAL Procedures, instructions and procurement documents define the requirements and responsibilities for the handling, storage, shipping, cleaning and preservation of materials, equipment, and parts required for implementation of established design and specification requirements.
Handling, storage, shipping, cleaning and preservation of materials, equipment and parts is conducted in accordance with applicable procedures and procurement documents. Vendors utilized to perform quality activities for the Station nuclear power plants are responsible for implementing measures for !
handling, storage, shipping, cleaning and preservation of materials, equipment j and parts to preclude damage, loss or deterioration. Audits, surveillances, and i inspections are performed, as appropriate, to verify that these vendors are i effectively complying with their quality assurance program requirements for handling, storage, shipping, cleaning and preservation of materials, equipment '
and parts.
13.2.2 ESTABLISHMENT OF SPECIAL HANDLING. STORAGE. SHIPPING. ,
C_ LEANING AND PRESERVATION REQUIREMENTS Special or additional handling, storage, shipping, cleaning and preservation requirements are to be identified and implemented as specified in procurement documents and applicable procedures. These established requirements are consistent with the regulatory positions of the NRC regulatory guides and their endorsed ANSI standards listed in Appendix C, or specifications and/or vendor technical manuals, and shall be consistent with accepted industry standards. ,
NUSCO/NNECO procedures describe the measures taken for the storage of chemicals, reagents (including control of shelf life), lubricants, and other consumable materials.
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14.0 O INSPECTION. TEST AND OPERATING STATUS 14.1 GENERAL REQUIREMENTS This NUQAP provides measures for indication, by the use of marking such as stamps, tags, labels or other suitable means, the status of tests and inspections of materials, equipment and parts to preclude the inadvertent bypassing of inspection and test requirements during quality activities performed for the Millstone Station nuclear power plants. These measures provide for the identification of items which have satisfactorily passed required inspections and tests. Measures are also established for indicating the operating status of quality structures, systems, and components to prevent inadvertent operation.
14.2 IMPLEMENTATION 14.2.1 GENERAL Vendors utilized to perform quality activities for the Station nuclear power plants i
are responsible for implementing approved measures for the identification of inspection and test status of quality material, equipment and parts to preclude the bypassing of requirements. Audits, sunreillances, and inspections, are performed, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for identification of inspection O and test status. Elements of this system require that vendors have a controlled fabrication and test operation in order to preclude the inadvertent bypassing of process inspections or tests, and to provide a positive identification of component status throughout all phases of fabrication, testing, and inspection by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other appropriate methods. I i
When receipt inspections are performed at the Station, Nuclear Materials and Document Management assures that traceability is maintained for acceptable quality materials, equipment and parts to indicate conformance to purchase ,
order / contract requirements with the exception of nuclear fuel assemblies, for l which traceability is maintained by Reactor Engineering and Nuclear Engineering. Nonconforming materials, equipment and parts are identified in )
accordance with QAP 15.0, " Nonconforming Materials, Parts, Components, or 1 Services."
During tests and inspections of the Station nuclear power plants, a status tagging system is implemented by procedure to prevent inadvertent operations of quality structures, systems, and components.
I NUSCO/NNECO procedures describe the measures taken to control the altering of the sequence of required tests, inspections and other operations. The review ;
and approval for these actions is subject to the same control as taken during the i original review and approval of tests, inspections and other operations. l QAP - 14.0 Rev. 21 Date: 9/2/99-Page 1 of 2 l
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v f 14.2.2 STATUS IDENTIFICATION AND CONTROL
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Procedures and instructions describe control of the application and removal of markings such as stamps, tags, labels, and other suitable means to indicate the status of quality structures, systems, and components to prevent inadvertent operation, and to preclude omission of inspections, tests or other critical operations. These procedures and instructions delineate the requirements, methods and responsibilities for indicating the status of the affected items. The status of all items requiring calibration is recorded and maintained in accordance with applicable procedures.
Records associated with status identification are maintained in accordance with applicable procedures.
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15.0' NONCONFORMING MATERIALS. PARTS. COMPONENTS OR SERVICES 15.1 GENERAL REQUIREMENTS This NUQAP requires the documentation and control of nonconforming materials, parts, components, or services be performed in accordance with procedures to prevent l
inadvertent use or installation in Millstone Station nuclear power plant quality structures, I systems, or components. These procedures include requirements for identification, documentation, segregation and disposition of nonconforming items; and notification to affected organizations.
15.2 LMPLEMENTATION l 15.2.1 PROGRAM Procedures define personnel responsibilities and establish various measures for identification, documentation, segregation, review and disposition of nonconforming item reports. The means for reporting nonconforming items are i available to all NU and vendor personnel assigned at the Millstone Power Station and other personnel involved with Station quality activities.
15.2.2 DOCUMENTATION Documentation of nonconforming items requires identification of the items, i
description of the nonconformance, disposition of the nonconformance, inspection requirements and signature approval of the disposition.
Tagging systems are utilized to physically identify nonconforming items prior to installation. Nuclear Materials and Document Management utilizes tags for l l received materials, parts and components.
15.2.3 EVALUATION AND DISPOSITION l
Evaluations are performed to determine the disposition of nonconforming items 1 l
I and services. The evaluation determines whether an item or service is to be used as is, retumed to vendor, repaired, reworked, scrapped or salvaged. An engineering evaluation is performed, if necessary, prior to the resolution of nonconforming conditions. In addition, nonconformances are evaluated for impact on quality structure, system and component operability in accordance with applicable procedures. . These evaluations assure that the final condition does not adversely affect safety, operation or maintenance of the item or service.
Nonconforming item reports involving deviation from design bases such as "use as is" or " repair" are forwarded to the appropriate engineering organization for review, and disposition. Applicable information is accumulated and records are maintained.
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_p The need to release /use nonconforming materials, parts or components shall be V based on such considerations as:
- a. Impact on plant safety; j
- b. Safety of personnel;
- c. Suitability of items in the "as is" condition, i.e., probability of eventual {
satisfactory resolution of the nonconforming condition without repair, ;
rework or replacement.
- d. Accessibility of items after release;
- e. Cost of removal and repair or replacement should items eventually have to l be removed, repaired, or replaced;
- f. Effect on the orderly progress of work.
Items repaired are verified by inspecting the items as originally inspected or by a I documented method which is equivalent to the originalinspection method. Items reworked may require inspection to verify conformance to requirements as defined in applicable procedures.
A Nuclear Oversight performs audits and surveillances, as appropriate, to verify V that dispositions for reports documenting nonconforming conditions are adequate.
15.2.4 RECURRENCE CONTROL A trend analysis of nonconforming conditions documenting program / procedural problems is performed in accordance with procedures. The trend analysis results are periodically reported to upper management, including the senior onsite and offsite nuclear officers and the senior manager responsible for measuring the effectiveness of the quality assurance program, for review and assessment as part of the Station Corrective Action Program reporting as described in QAP 16.0, Corrective Action.
QAP - 15.0 Rev. 21, Chg. 01 Date: 9/2/99 Page 2 of 2
16.0 .Q.QRRECTIVE ACTION 16.1 GENERAL REQUIREMENTS This NUQAP requires that an effective corrective action program be established to assure that conditions adverse to quality at the Millstone Power Station are promptly identifed, corrected, and documented in accordance with procedures. These procedures include measures for reporting to appropriate levels of management and determining the root cause and corrective action to preclude recurrence for conditions evaluated as significant conditions adverse to quality.
16.2 IMPLEMENTATION 16.2.1 PROGRAM Procedures define personnel responsibilities and establish various measures for identification, documentation, review, engineering evaluation, disposition and correction of conditions adverse to quality. The means to identify conditions adverse to quality are available to all NU and vendor personnel assigned to the Millstone Power Station and other personnel involved with Station quality activities. i 16.2.2 CORRECTIVE ACTION AND FOLLOW-UP .
Procedures describe the measures taken to evaluate if conditions adverse to quality exist and to determine the need for immediate corrective action or disposition. Vice '
Presidents are responsible for assuring their assigned personnel and their vendors l working onsite comply with the corrective action program and for assuring that :
corrective action is adequate and properly implemented in a timely manner within their organization. The Nuclear Oversight Department performs audits and surveillances, as appropriate, to verify that NUSCO/NNECO departments are effectively complying with this NUQAP and procedural requirements for the corrective action program and that corrective action is adequate and properly implemented in a timely manner. Audits, surveillances, and inspections, are performed, as appropriate to assure that vendors comply with their corrective action program and that corrective action is adequate.
The Senior Vice President and Chief Nuclear OWicer - hfilistone has the final l authority in the event that agreement on the action to be taken is not reached at lower levels of the nuclear organization.
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16.2.3 RECURRENCE CONTROL Procedures identify responsibility and provide direction for determining appropriate significance level based on actual or potential consequences for conditions adverse to quality.
The significance level determines the need for a root cause determination and for I establishing the necessary action to prevent recurrence. In cases of significant conditions adverse to quality, the immediate corrective action, the cause, and recurrence control actions must be documented. Procedures establish the responsibilities and measures taken to accomplish these actions.
An analysis of adverse conditions is performed and trends which identify program / procedure problems are periodically reported to upper management, including the senior onsite and offsite nuclear officers and the senior manager responsible for measuring the effectiveness of the quality assurance program for review. Adverse trends conceming specific vendor performance shall be reported to the affected vendor for resolution and recurrence control, as appropriate.
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17.0 QUALITY ASSURANCE RECORDS
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17.1 GENERAL REQUIREMENTS This NUQAP requires the maintenance, identification, retention and retrieval of records to fumish evidence of quality activities performed for the Millstone Station nuclear power plants be implemented in accordance with procedures. These records include but are not limited to: operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance and material analyses. These records also include closely related data such as qualifications of personnel, procedures and equipment. Inspection and test records contain, as a minimum but are not limited to: identification of inspector or data recorder and the acceptability and the action taken in connection with any deficiencies and reportable occurrences noted. Procedures establish requirements conceming record i retention such as duration, location and assigned responsibility.
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17.2 IMPLEMENTATION NUSCO/NNECO procedures establish the responsibilities and requirements for the maintenance, identification, retention (e.g., duration, location) and retrievability of records pertaining to materials, equipment, parts, processes or operations relating to quality structures, systems, and components which when founded on observations, measurements or tests can be fully verified, and documented by cognizant personnel.
p i Vendors utilized to perform quality activities for the Station nuclear power plants are {
responsible to implement measures for identification, maintenance, retention, retrieval and I tumover to NNECO of documented and approved records which contain objective evidence of quality as specified in purchase orders / contracts. Audits, surveillances, and inspections, are performed, as appropriate, to verify that these vendors are effectively complying with their program for quality assurance records.
NUSCO/NNECO quality assurance records are identified, controlled and maintained in appropriate files and are identifiable to specific structures, systems, and components within the Station nuclear power plants. When identification to a specific structure, system, or component is not practical, records are filed by category (e.g., specification, nonconformance reports, audits, etc.).
(~') QAP - 17.0 Rev. 21 Date: 9/2/99 Page 1 of 2
17.3 RETENTION NUSCO/NNECO quality assurance records are classified as life records or non-life records as delineated by Nuclear Document Services. Non-life rccords are those documents that are maintained for a specific period of time other than the lifetime of a Station nuclear power plant or the particular component or part. Life records are those documents that are maintained for the lifetime of the in-service nuclear power plant or for the life of the particular component or part. In instances where more than one licensing basis document specifies a record retention requirement and they are different (e.g. QA Program commitment versus Unit Technical Specifications) the more restrictive requirement shall apply. Life records are those which would be of significant value in meeting one or more of the following criteria:
- a. Demonstrating capability for safe operations;
- b. Maintaining, reworking, repairing, replacing or modifying the item;
- c. - Determining the cause of an accident or malfunction of an item;
- d. Providing required base line data for in-service inspection.
Quality assurance records are reviewed and approved by the cognizant qualified NUSCO/NNECO personnel and vendors, as appropriate, and are transmitted to the Station Nuclear Document Records Facility. The responsibility of the Nuclear Document O Services Facility upon receipt of records is to maintain and provide controlled retrievability of records affecting the Station nuclear power plants, in such a manner as to prevent destruction of records by fire, flood, theft, and environmental conditions, such as temperature or humidity, as delineated in applicable procedures. l 1
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18.0 AUDITS 18.1 GENERAL REQUIREMENTS This NUQAP requires that a comprehensive system of planned and periodic audits shall be carried out to verify that quality activities for Millstone Station nuclear power plants are performed in compliance with this NUQAP and to determine the effectiveness of the program.
Audits are conducted in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited.
Audit results are documented and reviewed by management having responsibility in the area audited and the responsible management takes the necessary action to address any audit findings revealed by the audit.
18.2 IMPLEMENTATION 18.2.1 PROGRAM The audit program requires audits of Corporate and Station nuclear power plant quality activities under the oversight of the Nuclear Safety Assessment Board.
Audits are performed on activities where the requirements of 10 CFR 50, Appendix q) B and respective nuclear unit Technical Specifications are being implemented. In addition to those activities, audits are performed on areas associated with indoctrination and training programs, interface control among NNECO and vendors, >
vendor quality programs and the Nuclear Materials and Document Management procurement function. Audits are regularly scheduled on the basis of the status and safety importance of the activities being performed. Regularly scheduled audits are supplemented by audits for one or more of the following conditions:
- a. When significant changes are made in functional areas of the quality assurance program, such as significant reorganization or procedure revisions; b.' When it is suspected that the quality of the item is in jeopardy due to deficiencies in the quality assurance program;
- c. When a systematic, independent assessment of program effectiveness is j considered necessary;
- d. When necessary to verify implementation of required corrective action. !
Schedules for the audit of Corporate, and Station, quality activities are originated and l maintained by the Nuclear Oversight Department. Schedules for vendor quality J assurance activities are maintained by the Nucier Materials and Document
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QAP - 18.0 l Rev. 21, Chg. 01 !
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Audits are performed as specified in procedures by qualified personnel, using an audit plan prepared by the auditing organization. Audits may include evaluation of the work areas, activities, processes, items, and review of documents and records to determine the effectiveness of implementation and conformance to this NUQAP.
Approved vendors utilized to perform quality activities for the Station nuclear power plants are responsible for developing and implementing a system of planned and periodic audits to verify compliance with and to determine the effectiveness of all aspects of their quality assurance program. Nuclear Materials and Document Management is responsible for verifying the acceptability of vendor audit programs.
Audits, are performed as appropriate, to verify that these vendors are effectively complying with their quality assurance requirements.
In addition to the audits, other methods, such as surveillances and inspections are used to essure that quality activities are in compliance with this NUQAP.
18.2.2 REPORTING OF AUDIT RESULTS Audit results are reviewed, approved, and reported in accordance with Nuclear Oversight Department and Nuclear Materials and Document Management procedures, as applicable. The audit reports are issued to the appropriate management of the area audited to assure appropriate and/or timely corrective action is taken to address conditions adverse to quality identified by the audit (J ' ' " ' ' " ' ' ' " ' " ' ' ' " ' " ' ' ' * ' " " ' ' ' ' ' " ' ' ' ' ' " " * " ' ' ' ' " ' ' ' ' ' ' '" ' "
- for quality trends and assessed to assure the effectiveness of this NUQAP.
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18.2.3 REVIEW. ACTION. AND FOLLOW-UP OF AUDIT FINDINGS Audit findings that !nvolve conditions adverse to quality are reviewed and investigated by the management having the responsibility for the area audited. The responsible management is required to take the necessary action to address any corditions adverse to quality identified by the audit and: report the results of such reviews and investigations, take the necessary actions to correct problems reported, 4 and report the completion of corrective action within specified time frames. I Follow-up of audit findings involving conditions adverse to quality is performed by the auditing organization as necessary to verify appropriate actions have been taken to resolve audit findings.- ltems which cannot be resolved by affected management are submitted for resolution to the Senior Vice President and Chief Nuclear Officer -
niillstone.
18.2.4 RECORDS / REPORTS OF AUDITS Audit records, reports, and associated documentation are retained in the Station Nuclear Document Services Facility, as specified in applicable procedures.
QAP - 18.0 Rev. 21, Chg. 01 Date: 9/2/99 Page:2 of 2
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APPENDIX A NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT - MILLSTONE POWER STATION CATEGORY I STRUCTURES. SYSTEMS AND COMPONENTS The Materials, Equipment, and Parts List (MEPL) Program provides instructions to identify structures, systems, components, parts, materials, consumables, and quality software that need to be safety-related and designated as Category 1.
The following structures, systems, and components of a Millstone Station nuclear power plant, including their foundations and supports, are designated as Category 1. The pertinent quality assurance requirements of Appendix B to 10 CFR 50 are applied, to all activities affecting the safety-related function of the structures, systems, and components as listed below and to other items and services specifically identified by NU in each FSAR addressing Section 3.2.1 of NRC l Regulatory Guide 1.70.
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(a) The reactor coolant pressure boundary.
(b) The reactor core and reactor vessel intemais.
(c) Systems or portions of systems that are required for (1) emergency core cooling; (2) post-accident containment heat removal or; (3) post-accident containment atmosphere cleanup O (e.g., hydrogen removal system).
(d) Systems or portions of systems that are required for (1) reactor shutdown; (2) residual heat removal or; (3) cooling the spent fuel storage pool.
(e) Those portions of the steam systems of boiling water reactors extending from the outermost containment isolation up to but not including the turbine stop valve, and connected piping of 2-1/2 inches or larger nominal pipe size up to and including the first valve that is either normally closed or capable of automatic closure during all modes of normal reactor operation.
(f) Those portions of the steam and feedwater systems of pressurized water reactors extending from and including the secondary side of steam generators up to and including the outermost containment isolation valves, and connected piping of 2-1/2 inches or larger nominal pipe size up to and including the first valve (including a safety or relief valve) that is either normally closed or capable of automatic closure during all modes of normal reactor operation.
(g) Cooling water, component cooling and auxiliary feedwater systems or portions of these systems including the intake structures, that are required for (1) emergency core cooling; (2) post-accident containment heat removal; (3) post-accident containment atmosphere cleanup; (4) residual heat removal from the reactor or; (5) cooling the spent fuel storage pool.
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(h) Cooling water and seal water systems or portions of these systems that are required for i functioning of safety-related reactor coolant system components such as PWR reactor coolant pump seals.
(i)_ Systems or portions of systems that are required to supply fuel for emergency equipment.
(J) All electrical and mechanical devices and circuitry between the process and the actuated devices involved in generating or respor' ding to signals that provide protective functions of -
safeguard systems.
(k) Systems or portions of systems that are required for (1) monitoring of systems safety-related and; (2) actuation of systems safety-related.
" Required for monitoring,"i.e. Those parameters that provide information that is essential to permit the control room operator to take specific manually controlled actions for the direct accomplishment of the specified safety function.
(I) The spent fuel storage pool structure, including the fuel racks.
-(m) The reactivity control system (e.g., control rods, control rod drives, and boron injection system).
(n) The control room, including its associated equipment and all equipment needed to maintain the control room with safe habitability limits for personnel and safe environmental limits for O vital equipment.
(o) Primary and secondary reactor containment.
(p) Systems other than radioactive waste management systems not covered by items (a) through (o) above which contain or may contain radioactive materials and whose postulated failure would result in conservatively calculated potential offsite doses (using meteorology as prescribed by Regulatory Guides 1.3 and 1.4) which are more than 0.5 rem to the whole body or its equivalent to any part of the body.
(q) The Class IE electric systems, including the auxiliary systems for the onsite electric power supplies, that provide the emergency electric power needed for functioning of plant features included in items (a) through (p) above.
(r) Those portions of structures, systems, or components whose continued function is not required but whose failure could reduce the functioning of any plant feature included in items (a) through (q) above to an unacceptable safety level or could result in incapacitating injury to occupants of the control room should be designed and constructed so that the SSE would not cause such failures.
(s) ' Items and services associated with Radioactive Material Transport Packages as described in 10CFR71.
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l CONSUMABLES The following speedic consumables when utilized in safety-related systems shall be included in those portions of this NUQAP, as applicable.
- 1. Emergency generator diesel fuels
- 2. Hydraulic snubber fluids
- 3. Reagents
- 4. Resins
- 5. Boric Acid
- 6. Lubricants
- 7. Gas Turbine Fuel O
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QAP - Appendix A Rev. 21 Date: 90199 Page 3 of 3
APPENDIX B NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT- MILLSTONE POWER STATION
_ QUALIFICATION AND EXPERIENCE REQUIREMENTS l
This appendix consolidates specMc qualiHcation and experience requirements for several key posWons within the NNECO organization. Much of this material was relocated from the Unit 3 Final Safety Analysis Report.
DIRECTOR-NUCLEAR OVERSIGHT The Director-Nuclear Oversight shall satisfy the following requirements:
Graduate of a four-year accredited engineering or science college or university, plus fifteen (15) or more years of industrial experience including five years in positions of leadership, such as lead engineer, project engineer, Audit team leader, etc. At least two years of this experience should be associated with nuclear Quality Assurance Activities, and at least one year of this experience is in a Quality Assurance Organization. A masters degree in engineering or business management is considered equivalent to two years of experience.
Note: The education and experience requirements should not be treated as absolute when similar training or an outstanding record provides reasonable assurance that a person can perform the required tasks.
1 ANSI N18.11971 Reauirements 1 As stated in Appendix C, education and experience requirements for Millstone Station personnel are established by ANSI N18.1 as 1 endorsed by Regulatory Guide 1.8 1977, subject to the exceptions in Appendix E. The table below identmes ANSI N18.1 requirements applicable to speciHc positions at Millstone Units 2 and 3.
O QAP- Appendix B Rev. 21, Chg. 01 Date: 9/2/99 Page 1 of 2
O Table B-1 l Position Appilcable ANSI N18.1 1971 Requirements Station Director Plant Manager (4.2.1)*
Manager- Chemistry Radiochemistry (4.4.3)
Manager-Radiation Protection and Radiation Protection (4.4.4)
Waste Services See Note 1 Manager- Operations Operations Manager (4.2.2)
See Note 2 Shift Managers Supervisors Requiring AEC Licenses (4.3.1)
Unit Supervisors, Control Operators, Operators (4.5.1)
Plant Equipment Operators Manager-I&C Maintenance Instrumentation & Control (4.4.2) j Director- Maintenance Maintenance Manager (4.2.3) l Mechanics, Electricians, Technicians Repairmen (4.5.3)
(repairmen)
Manager- Unit System Engineering TechnicalManager (4.2.4) l Manager- Plant Support Engineering Manager- Common System Engineering Supervisor- Reactor Engineering Reactor Engineering and Physics (4.4.1) l O
- Numbers in 0 refer to section numbers in ANSI N18.1 1971.
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- 1. For the position of Manager- Radiation Protection and Waste Services, the qualiRcations considered as minimum acceptable substitutes for a bachelor's degree equivalent are: a high school diploma orits equivalent and four years of applied managerial experience at a nuclear facility in the area of radiation protection.
- 2. If the Unit 3 Manager- Operations does not hold an SRO license for Unit 3, then the Manager - Operations shall have held an SRO license at a pressurized water reactor (PWR), and the Assistant Manager - Operations shallhold an SRO license for Unit 3.
If the Unit 2 Manager - Operations does not hold an SRO license for Unit 2, then the Manager- Operations shall have held an SRO license at a PWR, and an individual serving in the capacity of the Assistant Manager-Operations shall hold an SRO for Unit 2.
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l APPENDIX C NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT - MILLSTONE POWER STATION REGULATORY GUIDE AND ANSI /IEEE STANDARD CRMMITMENTS NOTE: This NUQAP is committed to utilize the guidance obtained from the following regulatory documents and their endorsed standards. Exceptions to these positions are listed in Appendix E of this Topical Report.
Appendix B to 10 CFR, Part 50 - Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
10 CFR 50, Section 50.54, Condition of Licenses.
10 CFR 50, Part 55- Operator's Licenses and its Appendix A- Requalification Programs for Licensed Operators of Production and Utilization Facilities.
Regulatory Guide 1.8 - I - R - 5/77 - Personnel Selection and Training - Endorses ANSI N18.1 -
1971.
Regulatory Guide 1.28 - 2/79 - Quality Assurance Program Requirements (Design and O Construction) Endorses ANSI N45.2-1977.
Regulatory Guide 1.30- (Safety Guide 30), 8-11 Quality Assurance Requirements for the installation, inspection, and Testing of Instrumentation and Electrical Equipment - Endorses ANSI N45.2.4-1972.
Regulatory Guide 1.33 - 2/78 - Quality Assurance Program Requirements (Operation) - Endorses ANSI N18.7-1976/ANS3.2. ,
Regulatory Guide 1.37- Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants, 3-16 Endorses ANSI i N45.2.1 1973. j Regulatory Guide 1.38- Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of items for Water 4ooled Nuclear Power Piants, 5/77- Endorses ANSI N45.2.2 - 1972. i i
Regulatory Guide 1.39- Housekeeping Requirements for Water-Cooled Nuclear Power Plants, j 9/77 - Endorses ANSI N45.2.3-1973.
1 Regulatory Guide 1.58- Qualification of Nuclear Power Plant inspection, Examination, and
-Testing Personnel, Rev.1,9/80 - Endorses ANSI N45.2.6-1978.
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Regulatory Guide 1.64 - Quality Assurance Requirements for the Design of Nuclear Power Plants, 6/76 - Endorses ANSI N45.2.11-1974.
' Regulatory Guide 1.70 "A Guide for the Organization and Content of Safety Analysis Reports" Revision 0, June 30,1966 was utilized for Millstone Power Station Unit No. 2; however, certain revised sections of the Unit 2 Final Safety Analysis Report are written to the Revision 3 format. l Regulatory Guide 1.70 " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants- LWR Edition ," Revision 3, has been used in the update process for Millstone l Power Station Unit No.1 for format and to the nearest extent practical for content. No new analyses have been performed which would be required by Revision 3. Revision 3, November 1978 is utilized for Millstone Power Station Unit No. 3.
Regulatory Guide 1.88- Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records - 10/76 Endorses ANSI N45.2.9-1974.
Regulatory Guide 1.94 - Quality Assurance Requirements for Installation, inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plant - 4/76 - Endorses ANSI N45.2.5 - 1974 and Section 6.11 of ANSI N45.2.5-1978.
Regulatory Guide 1.116- Quality Assurance Requirements for Installation, inspection, and Testing Mechanical Equipment and Systems - 5/77 - Endorses ANSI N45.2.8-1975.
Regulatory Guide 1.123- Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants - 7/77 - Endorses ANSI N45.2.13-1976.
Regulatory Guide 1.144- Auditing of Quality Assurance Programs for Nuclear Power Plants-Rev.1 - 9/80 Endorses ANSI N45.2.12 - 1977.
Regulatory Guide 1.146 - Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants - 8/80 Endorses ANSI N45.2.23-1978.
Regulatory Guide 1.152 " Criteria for Digital Computers in Safety Systems of Nuclear Power Plants", January 1996 - Endorses IEEE ANS 7 - 4.3.2 - 1993.
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APPENDIX D NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT - MILLSTONE POWER STATION GLOSSARY OF QUALITY ASSURANCE TERMS Accept As is- (also known as "Use-As-Is") A disposition which may be imposed for a nonconformance when it can be established that the discrepancy will result in no adverse conditions and that the item under consideration will continue to meet all engineering functional requirements including performance, maintainability, fit and safety.
Aporoved Vendors - Vendors approved to provide material, equipment, parts or services under
- their quality assurance program.
As-Built Documents - Documents which accurately describe the condition actually achieved in a system, structure, or component. These documents include: material certification and test data; reports of inspections, examinations, and test results; drawing, specifications, procedures, and instructions; and records of nonconformance and their resolution.
A_ydit- A formal, documented activity performed in accordance with written procedures or checklists to verify by evaluation of objective evidence that a quality assurance program has been .
developed, documented, and implemented in accordance with applicable requirements.
Auomented Quality - Nonsafety-related items for which a design basis or regulatory commitment has been made. The augmented quality items are included within the scope of Quality Assurance Program. These items fall under nuclear indicators such as FPQA (Fire Protection Quality Assurance), RWQA (Radwaste Quality Assurance), ATWS (Anticipated Transient Without Scram) and SBOQA (Station Blackout Quality Assurance).
Calibration - The process by which measuring and test equipment are checked against standards
- of known higher accuracy r.and adjusted as necessary to assure their compliance with designated specifications. l Cateoorv I - Designation given to saisty-related structures, systems, and components (SSC) of a Northeast Utilities nuclear power plant amd material, equipment, parts, consumables, and services applicable to the safety-related furictions of these SSCs.
Cateoorv i Structures. Systems rmd Comoonents - Defined in each unit FSAR and functionally described in Appendix A.
Cleanino - Those. actions performed to maintain an item in accordance with cleanliness requirements.
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n p Commercial Grade item (CGI) - A commercial grade item per 10CFR21 is a structure, system, or Q component, or part thereof that affects its safety function that was not designed and manufactured as a basic component. Commercial grade items do not include items where the design and manufacturing process require in-process inspections and verifications to assure that defects or failures to comply are identified and corrected (i.e., one or more critical characteristics of the item cannot be verified).
Commercial Grade Survev - Activities conducted by the purchaser to ascertain and verify that a supplier or manufacturer of commercial grade items, controls the technical and quality characteristics determined to be critical for satisfactory performance of specifically designated commercial grade items, as a method to accept those items for safety-related use.
Condition Adverse to Quality - Failures, malfunctions, deficiencies, deviations, defective materials and equipment, abnormal occurrer.ces and nonconformances.
Contractor - Any organization under contract for fumishing items or services.
Corrective Action - Action taken to correct an identified condition adverse to quality.
Deficiencies - Departures from specified requirements.
Deoartment - The use of the word " Department" throughout this NUQAP can refer to any portion of the NUSCO/NNECO organization (i.e., Group, Division, Department, Branch, Section, or Unit, as applicable).
Desian - The technical and management process which leads to and includes the issuance of design output documents such as drawings, specifications,' and other documents defining technical requirements of structures, systems, and components.
Desian Chances - Changes in drawings and specifications that define the design of structures, systems, and components of nuclear power plants.
Desian Documenta - The drawing, calculation, specification, or other document (s) that define the technical requirements of structures, systems, or components.
'Enaineerina Service Oraanization - Organizations that provide services such as analysis, computer software, testing, and inspection.
Grouc - The use of the word "gproup"in Section 1.0 of this NUQAP rehrs to a portion of the NUSCO/NNECO orpanization (i.e., Department, Unit, Branch, as appilcable).
Handlina - An act of physically moving an item by hand or by mechanical machinery, but not including transport modes.
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identification - A means by which material, equipment and parts can be traced to their associated documentation through the use of heat numbers, lot numbers, part numbers, serial numbers, or other appropriate means.
Item - Any level of unit assembly, including structures, systems, subsystems, subassembly, component, part, or material.
Inspection - A phase of quality control which, by means of examination, observation, or measurement, determines the conformance of material, supplies, components, parts, appurtenances, systems, processes, structures, or services to predetermined quality requirements.
Inspection Status - Identification of material, equipment, and parts that have completed inspection, either acceptable or unacceptable. j i
Licensina Basis - The set of requirements that includes the applicable NRC regulations, plant - l specific NRC requirements, plant - specific design basis and regulatory commitments that are I
docketed and in effect. 1 Life Records - Those quality documents that are maintained for the lifetime of an in-service nuclear power plant (the duration of the operating license) or for the life of the particular component or part. Life records are those which would be of significant value in meeting one or more of the following criteria:
(1) demonstrating capability for safe operation.
(2) maintaining, reworking, repairing, replacing or modifying the item.
(3) determining the cause of an accident or malfunction of an item.
(4)- providing required base line data for in-service inspection.
Material Reauest - A formal electronic request for the purchase of material, equipment, parts and/or services.
Measurina and Test Eauioment - Those instruments, gages, tools, fixtures, reference and transfer standards, nondestructive test equipment, and measuring devices used during inspection and testing to determine that the measuring and test parameters comply with appropriate requirements in specifications and drawings.
Nonconformance - A deficiency in characteristic documentation or procedure which renders the !
quality of an item unacceptable or indeterminate.
]
Non-Life Records - Those quality documents that are maintained for a specific period of time other i than the lifetime of the in-service nuclear power plant or the particular component or part.
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1 Northeast Utilities (NU) - A public utility holding company which owns Northeast Utilities Service Company (NUSCO) and the Northeast Nuclear Energy Company (NNECO).
Northeast Nuclear Enerav Comoany (NNECO) - The Northeast Utilities Power Operating Company responsible for the operation of the Millstone Station nuclear power plants.
Northeast Utiliiies Service Company (NUSCO)- A wholly owned subsidiary of Northeast Utilities that provides support engineering, purchasing, and quality assurance services for the Millstone Station nuclear power plants.
Northeast Utilities Quality Assurance Proaram (NUQAP) - Millstone Power Station - Consist of this NUQAP Topical Report, Nuclear Oversight Department procedures and other NUSCO/NNECO Group / Division / Department / Branch /Section/ Unit quality procedures.
Nuclear Document Services - The organization responsible for establishing the Corporate Nuclear Plant Records Program which is implemented at each Nuclear Document Services Facility.
Nuclear G ade - The procurement classification applied to all materials and services intended for items listed as Category I (CAT I) in the MEPL. These may require validating documentation such as Certificate of Material Test Report, Certificate of Conformance, Certificate of Compliance, personnel qualifications, etc., as specified by codes or standards, and have been designed / qualified for a nuclear application. Nuclear Grade items are manufactured / qualified under a 10CFR50, Appendix B program with the vendor responsible for 10CFR21. The vendor should be an " Approved Vendor".
Nuclear Document Services Facilities (NDSF) - A facility which has been established for the purpose of handling nuclear power plant records in accordance with the Nuclear Records Program.
Obiective Evidence- Any statement of fact, information, or record, either quantitative or qualitative, pertaining to the quality of an item or service based on observation, measurements, or tests which can be verified. .
Preservation - Those actions performed to maintain an item in its original and usable condition.
Procedures and Instructions - Documents that specify how an activity is to be performed. They may include methods to be employed; material, equipment, or parts to be used; and a sequence of operations.
Procurement Documents - Purchase requisitions / material requests, purchase orders, contracts, j drawings, specifications or instructions used to define requirements for purchase.
Product Acceptance Test- Activities conducted as part of the receiving or source inspection process to verify acceptability of one or more critical characteristics of the item being inspected.
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p Purchased Material. Eculoment. and Parts (MEP)- Items procured for installation in the Millstone d Station nuclear power plants quality structures, systems, and components, and items procured as spare MEP for potential installation in those structures, systems, and components.
Purchased Services - Services provided by vendor when requested under a QA Material Request and performed under a quality assurance program other than this NUQAP. (Synonymous with
" Services" and " Quality Services" in this NUQAP)
Quality Activities- All activities affecting the safety functions of structures, systems, and components; these activities include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying. Quality activities also include those activities associated with Augmented Quality (including Radwaste Packaging and Shipping) and other regulated programs to which this NUQAP is applicable.
Quality Assurance Records- Any record pertaining to the quality of material, equipment, parts, processes, or operations relating to structures, systems, and components which are founded on observations, measurements, or tests which can be fully checked or verified. Such statements may be recorded on a written or preprinted document or tag. The statements are authorized with a signature or stamp identifiable to the person making the statement of fact.
Quality Structures. Systems and Components - Structures, systems, and components (SSC) including Safety-Related SSCs, Augmented Quality items, and items under other regulated programs to which this NUQAP is applicable.
G Quality Procedures- Those Nuclear Oversight Department and other department procedures which implement the requirements of this NUQAP.
Repair - A disposition applied to nonconforming material, equipment, and parts that are unsuitable !
for their intended purpose which are modified by the use of additional operations and/or processes so that they are suitable for their intended purpose but may not meet all specified I requirements.
Reportable item - An event or condition that could affect nuclear plant safety and must be reported to the NRC in accordance with regulatory requirements such as,10CFR50.72, 10CFR50.73, or 10CFR50.9(b).
Responsible Enaineer- A NNECO employee assigned the responsibility to coordinate the engineering activities addressed in NUQAP. The responsible engineer may be designated as the project engineer.
Retest- A test conducted prior to operation following installation inspections of work associated with maintenance and refueling to verify that structures, systems, and components will function satisfactorily when in operation. A retest may also be performed when original test results are invalidated.
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O Retum to Vendor - A disposition applied to nonconforming material, equipment, and parts that are unsuitable for their intended purpose but which are feasible to repair or rework at a vendor's facility.
l Rework- A disposition applied to nonconforming material, equipment, and parts that are unsuitable for their intended purpose due to incomplete operations or variations from original i
I engineering requirements but which are modified through the use of additional operations or processes to meet all specified requirements. '
Safetv-Related Structures. Systems and Components- Those structures, systems and components that are relied on to remain functional during and following design basis (postulated) events to assure:
- 1) The integrity of the reactor coolant pressure boundary;
- 2) The capability to shut down the reactor and maintain it in a safe shutdown condition; and
- 3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in 10CFR50.34(a)(1) or 10CFR100.11 as applicable.
Sionificant Condition Adverse to Quality - A condition adverse to quality involving actual or potential consequences that have a serious impact on public or personnel health and safety or l plant operations, and requiring a root cause evaluation to determine corrective action to prevent -
recurrence.
Special Processes - Processes for which the desired level of quality can only be assured through the use of additional process controls, and where control through direct inspection alone is inadequate, impossible, or disadvantageous. These processes are performed under controlled conditions in accordance with special requirements utilizing qualifMHf procedures, equipment, and personnel. Special processes may include, but are not limited to welding, brazing, soldering, cleaning, heat treating, and nondestructive testing.
Station Blackout - The complete loss of attemating current electric power to the essential and non-essential switchgear buses in a nuclear power plant as defined in 10CFR50.2. It involves the loss of offsite power concurrent with turbine trip and failure of the onsite emergency ac power system, but not the loss of available ac power to buses fed by Station batteries through inverters or the loss of power from attemate ac sources.
Storace - The act of holding an item at the site in an area other than its permanent location in a plant.
Surveillance- A documented record of the observation of work operations performed at the Millstone Power Station or vendor's site to assure compliance with applicable codes, standards, specifications, procedures, drawings, and procurement documents. Surveillance may be performed with a prepared checklist.
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Test and Ooeratino Status - Identification of material, equipment, and parts that are ready for test or operation, or an existing stage of a test operation. '
t-l Testina- The determination or verification of the capability of an item to meet specified l requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions.
Vendors - Organizations that provide material, equipment, parts, computer software, or services.
This includes contractors, engineering service organizations, and consultants. (Synonymous with
" Supplier"in this NUQAP)
Work Procedures and Work Documents - Procedures, instructions, and documents used to control and document maintenance and modification work performed on Millstone Station nuclear plant structures, systems, and components, i
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l APPENDIX E NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT- MILLSTONE POWER STATION
\
PROGRAM EXCEPTIONS
- 1. ANSI N45.2.9. states in part, " structure, doors, frames, and hardware should be Class A fire-related with a recommended four-hour minimum rating." The three record storage vaults at NNECO have a two-hour rating.
NNECO's vaults are used for storage of documentation that is unsuitable for filming or awaiting filming.
A records organization exists along with written procedures addressing the control of quality assurance records.
t
- 2. ANSI N18.7-1976. paragraph 4.3.2.3 " Quorum" states in part: "A quorum for formal meetings of the (Independent Review) Committee held under the provisions of 4.3.2.2 shall consist of not less than a majority of the principals, or duly appointed alternates..."
A quorum of the Nuclear Safety Assessment Board shall consist of the Chairman or Vice Chairman and at least enough members to constitute a majority of the assigned members.
O No more than a minority of the quorum shall have line responsibility for operation of one of Northeast Utilities' nuclear units. No more than two attemates shall be appointed voting status at any meeting in fuifillment of the quorum requirements.
- 3. ANSI N45.2.9-1974. paragraph 1.4, definition of " Quality Assurance Records" states in part: "For the purposes of this standard, a document is consicyeo' a quWy assurance record when the document has been completed."
Northeast Utilities has developed the following attemative definition to provide guidance during the interim period from the time a document is completed until it is transmitted to the Nuclear Document Services Facility:
"A record is considered a working document until it is transmitted to the Nuclear Document Services Facility (NDSF) at which time it is designated as a Quality Assurance Record.
The following maximum time limits are established for the transmittal of working documents to the NDSF: l Operations Documents - Documentation generated during plant operations may be maintained, as needed, by operating plant departments, for up to one year.
1 New Construction or Betterment Documents - Documents which evolve during new construction or betterment projects shall be transmitted to NDSF within 90 days of
. completion of a new construction project or tumover of a betterment project or plant operations.
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O V Procurement Documents - Inspection / Surveillance / Audit Reports generated during vendor oversight activities which are used to maintain vendor status for current and future procurements may be maintained, as needed, by Nuclear Materials and Document Management for up to three years.
All Other Workina Documents - All other working documents shall be transmitted to NDSF within 6 months of their receipt or completion."
The requirements of ANSI N45.2.g-1974 do not apply to these " working documents" based on paragraph 1.1 of the ANSI standard which states:
"It (ANSI N45.2.9) is not intended to cover the preparation of the records nor to include working documents not yet designated as Quality Assurance Records."
- 4. Reaulatory Guide 1.64 - 6/76. the Regulatory position states, in part, "It should not be construed that such verification constitutes the required independent design verification."
Northeast Utilities has developed the following attemative to allow for adequate '
independent design verification:
This review may be performed by the originators Supervisor, only if the Supervisor. !
Did not specify a singular design approach; Did not establish the design inputs or did not rule out certain Design considerations; 4 Is the only individual in the organization competent to perform the review. :
i Where the Supervisor performs the design review, the next level of management shall fulfill the Supervisors responsibilities.
- 5. ANSI N45.2.13 - 1976. paragraph 10.3.4, states in part, " Post-Installation Test requirements and acceptance documentation (should) shah be mutually established by the purchaser and suppl!er." Involvement by the supplier in establishing Post-Installation Test requirements and acceptance documentation is requested only when it is deemed necessary and proper by the responsible engineering organization.
Northeast Utilities no longer nas any nuclear p; ants under construction. As a result, most procurements are made for spare parts from suppliers who are not the original equipment manufacturer. In these cases, the supplier may have little or no understanding or knowledge of either the operation of the system the component is to be installed in, or applicable Post-Installation Test requirements and acceptance documentation. As such,
~
Northeast Utilities assumes responsibility for establishing Post Installation Test requirements and acceptance documentation.
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6.
ANSI N45.2.2-1972. paragraph 1.2, states in part that, 'The requirements of this standard V apply to the work of any individual or organization that participates in the packaging, shipping, receiving, storage, and handling of items to be incorporated into nuclear power plants."
Since a portion of Northeast Utilities procurement activities involve commercial suppliers which do not fully comply with the requirements of ANSI N45.2.2, the Northeast Nuclear Energy Company Nuclear Materials and Document Management organization verifies
- through source inspections, receipt inspection, and/or survey activities that the quality of the materials, items, components or equipment is preserved by those suppliers to the extent that packaging, shipping, storage and handling methods are employed which are commensurate with the nature of the product.
- 7. ANSI N18.1-1971. paragraph 4.2.2, states in part "The Operations Manager shall hold a Senior Reactor Operators license". NU has developed an attemative to this requirement which has been accepted by the NRC via amendment 132 for the Millstone Power Station
- Unit No. 3 license which allows that::
If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No. 3, then the Operations Manager shall have held a Senior Reactor Operator license at a pressurized water reactor, and the Assistant Operations Manager shall hold a Senior Reactor Operator license for Millstone Unit No. 3.
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- 8. ANSI N18.1-1971. paragraph 4.2.2, states in part "The Operations Mancger shall hold a Senior Reactor Operators license". NU has developed an attemative to this requirement which has been accepted by the NRC via amendment 190 for the Millstone Power Station Unit No. 2 license which allows that:
If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No. 2, then the Operations Manager shall have held a Senior Reactor Operator license at a pressurized water reactor, and an individual serving in the capacity of the Assistant Operations Manager shall hold a Senior Reactor Operator license for Millstone Unit No. 2.
- 9. Reaulatory Guide 1.33 - 2/78. regarding audits, states in part:
(a) %e results of actions taken to correct deficiencies...at least once per 6 months."
- (b) "... technical specificetions and applicable license conditions - at least once per 12 months."
(c) "The performance, training, and qualifications of the facility staff - at least once per 12
. months."
NU has developed an attemative which modifies these Audit frequencies to at least once per 24 months. This attemative has previously been accepted by the NRC via license amendments 79,184, and 104 for MP1, MP2, and MP3, respectively.
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p 10. Deleted C 11.
l ANSI N45.2.13-1976. paragraph 10.3.5., states in part, "in certain cases involving i
procurement of services only, such as third party inspection, engineering and consulting i
' services, and installation, repair, overhaul or maintenance work; the Purchaser may accept the sentice by any or all of the following methods:
(a) Technical verification of the data produced (b) Surveillance and/or audit of the activity (c) Review of the objective evidence for conformance to the procurement document requirements such as certifications, stress reports, etc."
in order to maintain the independence requirement of the NRC's August 14,1996 Order, NNECO will not perform an acceptance review of the work produced by the vendors contracted to conduct the Independent Corrective Action Verification Program. This work will be performed in accordance with the vendor's own approved,10 CFR 50 Appendix B Quality Assurance Program.
- 12. Deleted.
- 13. Reaulatory Guide 1.70 Revision 3. November 1978 Section 17.1.2.4 states in part: "The PSAR should include a listing of QA program procedures or instructions that will be used to implement the QA program for each major activity such as design, procurement, s construction, etc. The procedure list should identify which criteria of Appendix B to 10 CFR 50 are implemented by each procedure".
NU has developed an attemative to this requirement where procedure indices are maintained which identify the procedures that implement the Quality Assurance Program for Millstone Power Station and which, by title and originating organization, indicate the Appendix B to 10 CFR 50 criterion being implemented.
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APPENDIX F O
d NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT - MILLSTONE POWER STATION ADMINISTRATIVE CONTROLS' NOTE: ,
- 1. " Specification" numbers refer to the unit specific Technical Specification.
- 2. Unit specific titles are given in [ ] for generic titles used in Technical Specifications.
)-
INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)- Unit 3 Only Function The ISEG shall include, as part of its function, examination of unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources of unit design and operating experience information, including units of similar design, which may indicate areas for improving unit safety. The ISEG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activities, operations activities, or other means of improving unit safety to appropriate station / corporation management.
Composition p The ISEG shall be composed of at least four full-time personnel located on site to perform the functions described above for Millstone Unit 3. Each person shall have either (1) A bachelor's degree in engineering or related science and at least 2 years of professional level experience in his field, at least 1 year of which experience shall be in the nuclear field, or, (2) At least 10 years of professional level experience in his field, at least 5 years of which experience shall be in the nuclear field.
A minimum of 50% of these personnel shall have the qualifications specified in (1) above.
Responsibilities The ISEG shall be responsible for maintaining surveillance of unit activities to provide independent verification
- that these activities are performed correctly and that human errors are reduced as much as practical.
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Records A
V Records of activities performed by the ISEG shall be prepared and maintained, and quarterly reports of completed safety evaluations will be made to the Vice President-Nuclear Oversight.
' 'Not responsible for sign-off function REVIEW AND AUDIT Plant Operation Review Committee (PORC) - Unit 1 Only _
Function The PORC shall function to advise the designated manager (Director - Unit 1 Operations] l on all matters related to nuclear safety.
Composition The PORC shall be composed of nine to eleven members. Members shall collectively have experience and expertise in the following areas:
I Plant Operations p Engineering i
'Q Reactor Engineering Maintenance i
instrumentation and Controls Health Physics Chemistry Work Planning Quality Assurance The minimum qualifications of PORC members shall be that all members have an academic degree in an engineering or physical science field, or hold a management position, and have a minimum of five years technical experience in their respective field of expertise. The members of PORC shall be appointed in writing by the designated manager (Director - Unit 1 Operations). The Chairperson and attemate Chairperson of l the PORC shall be drawn from the PORC members and be appointed in writing by the designated manager (Director - Unit 1 Operations). l Altemates Altemate members shall be appointed in writing by the PORC Chairperson to serve on a temporary basis; however, no more than two attemates shall participate in PORC activities at any one time.
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r Meeting Frequency L The PORC shall meet at least once per calendar month and as convened by the PORC Chairperson.
Quorum A quorum of the PORC shall consist of the Chairperson, or Vice Chairperson, and four members including attemates.
Responsibilities The PORC shall be responsible for:
j a. Review of 1) all procedures, except common site procedures, required by Specification 6.8 and changes thereto, 2) all programs, except common site l programs, required by Specification 6.8 and changes thereto, 3) any other l proposed procedures, programs,.or changes thereto as determined by the designated manager (Director - Unit 1 Operations] to affect nuclear safety. l Procedures and programs required by Specification 6.8 that are designated for i
review and approval by the Station Qualified Reviewer Program do not require PORC review..
- b. Review of all proposed tests and experiments that affect nuclear safety.
- c. Review of all proposed changes to Sections 1.0 - 5.0 of the Technical Specifications.
- d. Review of all proposed changes or modifications to plant systems or equipment
! that affect nuclear safety.
l e. Investigation of all violations of the Technical Specifications and preparation and fonwarding of a report covering evaluation and recommendations to prevent recurrence to the designated officer [ Senior Vice President and CNO -
Millstone) and to the Chairperson of the Nuclear Safety Assessment Board.
- f. Review of all REPORTABLE EVENTS.
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- g. Review of facility operations to detect potential safety hazards.
j h. Performance of special reviews and investigations and reports thereon as l requested by the Chairperson of the Nuclear Safety Assessment Board. '
- i. Render determinations in writing if any item considered under (a) through (d) above, as appropriate and as provided by 10CFR50.59 or 10CFR50.92, constitutes an unreviewed safety question or requires a significant hazards consideration determination. ;
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J. Review of the unit-specific Fire Protection Program and implementing procedure.
Authority The PORC shall:
- a. Recommend to the designated manager [ Director - Unit 1 Operations] written l approval or disapproval of items considered under Responsibilities (a) through (d) above.
- b. Provide immediate written notification to the designated officer [ Senior Vice President and CNO - Millstone] and the Chairperson of the Nuclear Safety Assessment Board of disagreement between the PORC and the designated manager [ Director - Unit 1 Operations]; however,-the designated manager
[ Director - Unit 1 Operations] shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1.
Recor6 The PORC shall maintain written minutes of each meeting and copies shall be provided to the designated officer [ Senior Vice President and CNO - Millstone] and the Chairperson of the Nuclear Safety Assessment Board.
Plant Operations Review Committee (PORC) - Unit 2 Only Function -
The PORC shall function to advise the designated manager (Station Director) on l all matters related to nuclear safety.
Composition The PORC shall be composed of nine to eleven members. Members shall collectively have experience and expertise in the following areas:
Plant Operations Engineering -
Reactor Engineering Maintenance Instrumentation and Controls Health Physics -
Chemistry Work Planning Quality Assurance QAP - Appendix F REV. 21, Chg 01 DATE: 9/2/99 PAGE: 4 of 18 i
The minimum qualifications of PORC members shall be that all members have an academic degree in an engineering or physical science field, or hold a management
[_
- position, and have a minimum of five years technical experience in their respective field of expertise. The members of PORC shall be appointed in writing by the designated manager [ Station Director). The Chairperson and altemate Chairperson of the PORC l shall be drawn from the PORC members and be appointed in writing by the designated manager (Station Director).
l Altemates Altemate members shall be appointed in writing by the PORC Chairperson to serve on a temporary basis; however, no more than two attemates shall participate in PORC activities at any one time. >
Meeting Frequency The PORC shall meet at least once per calendar month and as convened by the PORC Chairperson.
Quorum A quorum of the PORC shall consist of the Chairperson, or Vice Chairperson, and four members including attemates.
Responsibilities The PORC shall be responsible for:
- a. Review of 1) all procedures, except common site procedures, required by Specification 6.8 and changes thereto, 2) all programs, except common site programs, required by Specification 6.8 and changes thereto, 3) any other proposed procedures, programs, or changes thereto as determined by the designated manager (Station Director) to affect nuclear safety. Procedures l and programs required by Specification 6.8 that are designated for review and approval by the Station Qualified Reviewer Program do not require PORC review.
l
- b. Review of all proposed tests and experiments that affect nuclear safety.
- c. Review of all proposed changes to Sections 1.0 - 5.0 of the Technical Specifications.
- d. Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.
p.-
QAP- Appendix F REV. 21, Chg 01 DATE: 9/2/99 PAGE: 5 of 18
- e. Investigation of all violations of the Technical Specifications and preparation and forwarding of a report covering evaluation and recommendations to prevent recurrence to the designated officer [ Senior Vice President and CNO
- Millstone] and to the Chairperson of the Nuclear Safety Assessment Board.
- f. Review of all REPORTABLE EVENTS.
- g. Review of facility operations to detect potential safety hazards.
- h. Performance of special reviews and investigations and reports thereon as requested by the Chairperson of the Nuclear Safety Assessment Board.
- i. Render determinations in writing if any item considered under (a) through (d) above, as appropriate and as provided by 10CFR50.59 or 10CFR50.92, constitutes an unreviewed safety question or requires a significent hazards consideration determination.
J. Review of the fire protection program and implementing procedure.
Authority The PORC shall:
a Recommend to the designated manager (Station Director] written approval l
\
or disapproval of items considered under Responsibilities (a) through (d) above.
- b. Provide immediate written notification to the designated officer (Senior Vice President and CNO - Millstone] and the Chairperson of the Nuclear Safety Assessment Board of disagreement between the PORC and the designated manager [SicWon D/roctor); however, the designated manager [Stadon Director] shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1.
- Records The PORC shall maintain written minutes of each meeting and copies shall be provided to the Senior Vice President and CNO - Millstone and Chairperson of the Nuclear Safety Assessment Board.
Plant Operations Review Committee (PORC) - Unit 3 Only O QAP - Appendix F REV. 21, Chg 01 DATE: 9/2/99 PAGE: 6 of18
F Function A '
Q The PORC shall function to advise the designated manager [ Station Director] on all matters related to nuclear safety. l Composition The PORC shall'be composed of nine to eleven members. Members shall collectively have experience and expertise in the following areas:
Plant Operations Engineering Reactor Engineering Maintenance Instrumentation and Controls Health Physics Chemistry
' Work Planning Quality Assurance The minimum qualifications of PORC members shall be that all members have an academic degree in an engineering or physical science field, or hold a management position, and have a minimum of five years technical experience in their respective field of expertise. The members of PORC shall be appointed in writing by the designated manager [ Station Director). The Chairperson and l
attemate Chairperson of the PORC shall be drawn from the PORC members and be appointed in writing by the designated manager [ Station Director). l Attemates All attemate members shall be appointed in writing by the PORC Chairperson to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.
Meeting Frequency The PORC shall meet at least once per calendar month and as convened by the !
PORC Chairperson. l Quorum -
The quorum of the PORC shall consist of the Chairperson or Vice Chairperson and four members including attemates.
Responsibilities The PORC shall be responsible for: i
- a. Review of: (1) all procedures, except common site procedures, required by Specification 6.8 and changes thereto, 2) all programs, n
v QAP - Appendix F REV. 21, Chg 01 DATE: 9/2/99 PAGE: 7 of 18
1 1
1 l
except common site programs required by Specification 6.8 and l -
changes thereto, and (3) any other proposed procedures, programs or !
l changes thereto as determined by the designated manager (Station
' l
, Director) to affect nuclear safety. Procedures and programs required by Specification 6.8 that are designated for review and approval by the Station Qualified Reviewer Program do not require PORC review.
l
- b. Review of all proposed tests and experiments that affect nuclear i safety; ;
- c. Review of all proposed changes to Sections 1.0-5.0 of the Technical Specifications;
- d. Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety;
- e. Investigation of all violations of the Technical Specifications, l
I including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence, to the i designated officer [ Senior Vice President and CNO - Millstone]
l and to the Chairperson of the Nuclear Safety Assessment Board;
- f. Review of all REPORTABLE EVENTS;
- g. i
- Review of facility operations to detect potential safety hazards;
- h. Performance of special reviews, investigations, or analyses and reports thereon as requested by the Chairperson of the Nuclear Safety Assessment Board.
i
- 1. Render determinations in writing if any item considered under (a) through (d) above, as appropriate and as provided by 10CFR50.59 or 10CFR50.92, constitutes an unreviewed safety
- l. question, or requires a significant hazards consideration determination.
J. Review of Unit Turbine Overspeed Protection Maintenance and Testing Program and revision thereto, t k. Review of the Fire Protection Program and implementing i
procedures.
Authority I l
The PORC shall: i I
3
- a. Recommend to the designated manager [ Station Director] written l i J approval or disapproval of items considered under Responsibilities a. !
l' through d. above; and ]
l l
i O QAP - Appendix F i
REV. 21, Chg 01 DATE: 9/2/99 PAGE: 8 of 18 L
i
- b. Provide written notification to the designated officer (Senior Vice r^ President and CNO - Millstone] and the Chairperson of the Nuclear
\
Safety Assessment Board of disagreement between the PORC and the f designated manager (Station Director); however, the designated manager (Station Director] shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1.
Records The PORC shall maintain written minutes of each meeting and copies shall be provided to the designated officer [ Senior Vice President and CNO - Millstone] and the Chairperson of the Nuclear Safety Assessment Board.
Site Operations Review Committee (SORC)
Function The SORC shall function to advise the designated officer (Senior Vice President and CNO- Millstone] on all matters related to nuclear safety of the entire Millstone Station Site.
Composition The SORC shall be composed of the:
Chairperson: Designated Officer [ Senior Vice Presider.t and CNO Millstone]
Member: Unit 1 Designated Manager [ Director - Unit 1 Operations]
Member: Unit 2 Designated Manager (See note below]
Member: Unit 3 Designated Manager [See note below]
Member: Designated Manager, Nuclear Services [ Manager- Radiation Protection and Waste Services]
Member: Designated Manager, General Services [ Director - Site Services]
Member: Designated Member of Unit 1 PORC [ Designated Member of Unit 1 PORC]
Member: Designated Member of Unit 2 PORC [ Designated Member of Unit 2 PORC]
Member: Designated Member of Unit 3 PORC [ Designated Member of Unit 3 PORC]
Member: Designated Member of Nuclear Oversight [ Designated Member of Nuclear Oversight]
NOTE: The positions of " Unit 2 Designated Manager" and " Unit 3 Designated Manager" shall be filled by any two of the following: Station Director, Assistant Station Director -
Safety, Manager. Operations (Millstone 2), Manager- Operations (Unit 3). i The senior designated Unit manager [ senior individual among the Unit 1 Designated Manager, Unit 2 Designated Manager, and Unit 3 Designated Manager]in attendance shall be the Vice-Chairperson.
QAP - Appendix F REV. 21, Chg 01 DATE: 9/2/99 PAGE: 9 of 18
Altemates:
1 O Alternate members shall be appointed in writing by the SORC Chairperson to serve on a temporary basis; however, no more than two attemates shall participate in SORC activities at one time.
Meeting Frequency The SORC shall meet at least once per six months and as convened by the SORC Chairperson.
Quorum A quorum of the SORC shall consist of the Chairperson or Vice Chairperson and five members including altemates.
Responsibilities The SORC shall be responsible for:
- a. Review of 1) all common site procedures required by Specification 6.8 and changes thereto, 2) all common site programs, required by Specification 6.8 and changes thereto, 3) any other proposed procedures, programs, or changes thereto as determined by the designated officer (Senior Vice President and CNO - Millstone] to affect site nuclear safety. Common site
, programs and procedures required by Specification 6.8 that are designated {
for review and approval by the Station Qualified Reviewer Program do not J require SORC review.
O b. Review of all proposed changes to Section 6.0 " Administrative Controls" of the Technical Specifications.
{
- c. Performance of special reviews and investigations and reports as requested by the Chairperson of the Nuclear Safety Assessment Board.
- d. Not used.
- e. Not used,
- f. Review of all common site proposed tests and experiments that affect nuclear safety.
- g. Review of all common site proposed changes or modifications to systems or equipment that affect nuclear safety,
- h. Render determinations in writing or meeting minutes if any item considered under (a) through (g) above, as appropriate and as provided by 10CFR50.59 or 10CFR50.92, constitutes an unreviewed safety question or requires a significant hazards consideration determination.
1
- i. Review of the common site fire protection program and implementing procedures.
QAP - Appendix F !
REV. 21, Chg 01 DATE: 9/2/99 PAGE: 10 of 18 l
l
Authority The SORC shall:
- a. Recommend to the designated officer (Senior Vice President and CNO -
Millstone) written approval or disapproval in meeting minutes of items considered under Responsibilities (a) through (g) above.
- b. Provide immediate written notification or meeting minutes to the designated senior officer [ President and Chief Executive Officer (CEO)] and the Chairperson of the Nuclear Safety Assessment Board of disagreement between the SORC and the designated officer { Senior Vice President and CNO - Millstone]; however, the designated senior officer [ Senior Vice President and CNO- Millstone] shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1.
Records The SORC shall maintain written minutes of each meeting and copies shall be provided to the designated officer [ Senior Vice President and CNO - Millstone) and Chairperson of the Nuclear Safety Assessment Board.
Nuclear Safety Assessment Board (NSAB)
Function The minimum qualifications of NSAB members are as follows:
- a. The Chairperson and NSAB members shall have:
- 1. An academic degree in an engineering or physical science field, or hold a senior management position, and I l
- 2. A minimum of five years technical experience in their respective field of expertise.
- b. The NSAB shall have experience in and shall function to provide independent oversight review and audit of designated activities in the areas of:
- 1. Nuclear power plant operations;
- 2. Nuclear engineering;
- 3. Chemistry and radiochemistry;
- 4. Metallurgy;
- 5. Instrumentation and control;
- 6. Radiological safety;
- 7. Mechanical and electrical engineering; and
(s OAP - Appendix F REV. 21, Chg 01 DATE: 9/2/99 PAGE: 11 of 18
- 8. Quality assurance practices.
The NSAB serves to advise the designated senior officer [ Senior Vice President and CNO - Millstone) on matters related to nuclear safety and notify the designated senior officer [ Senior Vice Prws/ dent and CNO - Millstone) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a safety significant disagreement between the NSAB and the organization or function being reviewed.
l Composition i
The designated senior officer [ Senior Vice President and CNO - Millstone] shall l appoint, in writing, a minimum of seven members to the NSAB and shall designate from this membership, in writing, a Chairperson and a Vice Chairperson. The membership shall function to provide independent review and audit in the areas listed in Function (b) above.
Altemates All alternate members shall be appointed, in writing, by the designated senior officer [ Senior Vice President and CNO - Millstone); however, no more than two {
attemates shall participate as members in NSAB activities at any one time.
Meeting Frequency The NSAB shall meet at least once per calendar quarter.
Quorum The quorum of the NSAB shall consist of a majority of NSAB members including the -
Chairperson or Vice Chairperson. No more than a minority of the quorum shall have line responsibility for operation of the same Northeast Utilities' nuclear unit. No more than two attemates shall be appointed as members at any meeting in fulfillment of the quorum <
requirements. l Review Responsibilities The NSAB shall be responsible for the review of:
- a. The safety evaluations for changes to procedures, equipment, or systems, and tests or experiments completed under the provisions of 10 CFR 50.59, to verify that such actions did not constitute an unreviewed safety question as defined in 10 CFR 50.59;
- b. Proposed changes to procedures, equipment, or systems that involve an unreviewed safety question as defined in 10 CFR 50.59;
- c. ' Proposed tests or experiments that involve an unreviewed safety question as defined in 10 CFR 50.59;
- d. Proposed changes to Technical Specifications and the Operating License; O QAP - Appendix F REV. 21, Chg 01 l DATE: 9/2/99 PAGE: 12 of 18
- e. Violations of applicable codes, regulations, orders, license requirements, or internal procedures having nuclear safety significance; V f. All Licensee Event Reports required by 10 CFR 50.73;
- g. Indications of significant unanticipated deficiencies in any aspect of design or operation of structures, systems, or components that could affect nuclear safety;
- h. Significant accidental, unplanned, or uncontro' lled radioactive releases, including corrective actions to prevent recurrence;
- i. Significant operating abnormalities or deviations from normal and expected performance of equipment that could affect nuclear safety;
- j. The performance of the corrective action program; and
- k. Audits and audit plans.
- l Reports or records of these reviews shall be forwarded to the designated senior officer
[ Senior Vice President and CNO - Millstone) within 30 days following completion of the l review.
Audit Program Responsibilities The NSAB audit program shall be the responsibility of the Nuclear Oversight Department. NSAB audits shall be performed at least once per 24 months in s accordance with administrative procedures [ Nuclear Group Procedures) and shall
( encompass:
- a. The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions;
- b. )
The training and qualifications of the unit staff; j
- c. The implementation of all programs required by Specification 6.8;
- d. The Fire Protection Program and implementing procedures.
- e. The fire protection equipment and program implementation utilizing either a qualified offsite license fire protection engineer or an outside independent fire protection consultant.
- f. Actions taken to correct deficiencies occurring in equipment, structures, systems, components, or method of operation that affect nuclear safety; and
- g. Other activities and documents as requested by the designated senior officer \ Senior Vice President and CNO - Millstone). l QAP - Appendix F REV. 21, Chg 01 DATE: 9/2/99 PAGE: 13 of 18
n l Records O Written records of reviews and audits shall be maintained. As a minimum these records shallinclude:
- a. Results of the activities conducted under the provisions of this NSAB Section;
- b. Deleted l
- c. Deleted l
Station Qualified Reviewer Program Function l The designated manager [ Unit 1 only - Director - Unit 1 Operations; Unit 2 and Unit 3 l
only - Station Director}, designated officer (Unit 1 only - Vice President - Site Services; Unit 2 and Unit 3 only - Vice President - Nuclear Operations), or designated senior officer [ Senior Vice President and CNO - Millstone] may establish a Station Qualified Reviewer Program whereby required reviews of designated procedures or classes of procedures required by PORC, Responsibilities item (a), and SORC, Responsibilities item (a) are performed by Station Qualified Reviewers and approved by designated managers [ Responsible Individual (s) for the procedure (s)]. These reviews are in lieu of reviews by the PORC or SORC. However, procedures which require a 10CFR50.59 evaluation must be reviewed by the PORC or SORC.
Responsibilities
, O The Station Qualified Reviewer Program shall:
- a. Provide for the review of designated procedures, programs, and changes thereto by a Qualified Reviewer (s) other than the individual who prepared the procedure, program, or change.
- b. Provide for cross-disciplinary review of procedures, programs, and changes thereto when organizations other than the preparing organization are affected by the procedure, program, or change.
- c. Ensure cross-disciplinary reviews are performed by a Qualified Reviewer (s) ;
in affected disciplines, or by other persons designated by cognizant j Managers or Directors as having specific expertise required to assess a j
.particular procedure, program, or change. Cross-disciplinary reviewers may i function as a committee.
- d. Provide for a screening of designated procedures, pregrams and changes ,i thereto to determine if an evaluation should be performed in accordance with the provisions of 10CFR50.59 to verify that an unreviewed safety question does not exist. This screening will be performed by personnel trained and qualified in performing 10CFR50.59 evaluations.
O QAP - Appendix F REV. 21, Chg 01 DATE: 9/2/99 PAGE: 14 of 18 l
- e. Provide for written recommendation by the Qualified Reviewer (s) to the responsible Manager for approval or disapproval of procedures and O
\,J programs considered under PORC, Responsibilities item (a) and SORC, Responsibilities item (a), and that the procedure or program was screened by a qualified individual and found not to require a 10 CFR 50.59 evaluation.
If the responsible manager determines that a new program, procedure, or change thereto requires a 10 CFR 50.59 evaluation, that Manager will ensure the required evaluation is performed to determine if the new procedure, program, or change involves an unreviewed safety question. The new procedure, program, or change will then be
'nrwarded with the 10 CFR 50.59 evaluation to PORC or SORC for review.
Personnel recommended to be Station Qualified Reviewers shall be designated in writing by the designated manager [ Unit 1 only - Director- Unit 1 Operations; Unit 2 and Unit 3 only - Station Director] or designated officer [ Senior Vice President and CNO - Millstone or: Unit 1 only - Vice President - Site Services, Unit 2 and Unit 3 only - Vice President - Nuclear Operations] for each procedure, program, or class of procedure or program within the scope of the Station Qualified Reviewer Program.
Temporary procedure changes shall be made in accordance with Specification 6.8.3 with the exception that changes to procedures for which reviews are assigned to Qualified Reviewers will be reviewed and approved as described in Responsibilities (a) through (e) above.
Records The review of procedures and programs performed under the Station Qualified Reviewer f- Program shall be documented in accordance with administrative procedures.
I Training and Qualification The training and qualification requirements of personnel desigrated as a Qualified Reviewer in accordance with the Station Qualified Reviewer Program shall be in accordance with administrative procedures. Qualified reviewers shall have:
- a. A Bachelors degree in engineering, related science or technical discipline, and two years of nuclear power plant experience; OR
- b. Six years of nuclear power plant experience; OR
- c. An equivalent combination of education and experience as approved by a Department Manager.
SAFETY LIMIT VIOLATION - Units 2 and 3 Only The Senior Vice President and CNO - Millstone and the Chairperson of the NSAB shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the event a Safety Limit is violated.
k.
QAP - Appendix F REV. 21, Chg 01 DATE: 9/2/99 PAGE: 15 of 18
p.
1 The Safety. Limit Violation Report shall be submitted to the Commission, the
[, Chairperson of the NSAB, and the Senior Vice President and CNO - Millstone, within 14 days of the violations.
(
RECORD RETENTION - Units 1 and 2 (1) The following records shall be retained for at least five yeais:
a.- Records and logs of facility operation covering time interval at each powerlevel.
- b. ' Records and logs of principal maintenance activities, inspections, repair and replacement of principalitems of equipment related to nuclear safety,
- c. All REPORTABLE EVENTS.
- d. Records of surveillance activities, inspections, and calibrations required by these technical specifications.
- e. Records of reactor tests and experiments.
- f. Records of changes made to operating procedures.
- g. Records of radioactive shipments.
- h. Records of sealed source leak tests and results.
- i. Records of annual physicalinventory of all sealed scurce material of record.
(2) The following records shall be retained for the duration of the facility operating license:
- a. Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.
- b. Records of new and irradiated fuel inventory, fuel transfers, and assembly bumup histories.
- c. Records of facility radiation and contamination surveys.
- d. Records of radiation exposure for all individuals entering radiation control areas.
- e. Records of gaseous and liquid radioactive materw., released to the environs.
- f. Records of transients or operational cycles for those facility components designed for a limited number of transients or cycles.
- g. Records of training and qualification for current members of the plant staff.
O QAP - Appendix F REV. 21, Chg 01 DATE: 9/2/99 ,,
PAGE: 16 of 18
)
I
L
- h. Records of inservice inspections performed pursuant to the Technical Specifications.
- i. Records of quality assurance activities required by the QA Manual.
J. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR Part 50.59.
k.' Records of meetings of the PORC, the NSAB, and the SORC.
1.
Records of Environmental Qualification which are covered under the provisions of Specification 6.13 (Unit 2 Only).
- m. Records of Environmental Qualification (Unit 1 Only).
- n. Records of reviews performed for changes made to the Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM) and the Process Control Program.
RECORD RETENTION - Unit 3 Only (1) In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated.
(2) The following records shall be retained for at least five years:
- a. Records and logs of unit operation covering time interval at each power level;
- b. Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuck ar safety;
- c. All REPORTABLE EVENTS;
- d. Records of surveillance activities, inspections, and calibrations required by Technical Specifications;
- c. Records of changes made to the procedures required by Specifications 6.8.1;
- f. Records of radioactivo i.nipments;
- g. Records of sealed source and fission detector leak tests and results; and
- h. Records of annual physical inventory of all sealed source material of record.
(3) The following recerds shall be retained for the duration of the unit Operating License:
- a. Records and drawing changes reflecting unit design modifications made to systems and equipmeitt described in the Final Safety Analysis Report; OAP - Appendix F REV. 21, Chg 01 -
DATE: 9/2/99 PAGE: 17 of 18
l b.
Records of new and irradiated fuel over,' tory, fuel transfers, and assembly burnup histories; (3) 1
- c. Records of radiation exposure for all idividuals entering radiation control areas;
- d. Records of gaseous and liquid radioactive material released to the environs;
- e. Records of transient or operational cycles for a.ose unit components 1
identified in Technical Specifications Table 5.7-1.
- f. Records of reactor tests and experiments;
- g. Records of training and qualification for current members of the unit staff;
- h. Records of inservice inspections performed pursuant to the Technical Specifications;
- i. Records of quality assurance activities required by the Quality Assurance Topical Report not listed in (2) a. through (2) h. above; I
J. Records of reviews performed for changes made to procedures or equipment '
or reviews of tests and experiments pursuant to 10 CFR Part 50.59;
- k. Records of meetings of the PORC, the NSAB, and the CORC;
- l. Records of the service lives of all hydraulic and mechanical snubbers O required by Technical Specifications 3.7.10 including the date at which the service life commences and associated installation and maintenance records;
- m. Records of secondary water sampling and water quality; and n Records of analyses required by the Radiological Environmental Monitoring Program that would permit evaluation of the accuracy of the analysis at a later date.
This should include procedures effective at specified times and QA records showing that these procedures were followed.
- o. Records of reviews performed for changes made to the Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM) and the Process Control Program.
' Relocation of Technical Specification Administrative Controls Related to Quality Assurance in Response to AL 95-06.
O QAP - Appendix F l
l REV. 21, Chg 01 '
DATE: 9/2/99 PAGE: 18 of 18
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