ML20217K123
| ML20217K123 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 10/14/1999 |
| From: | CENTERIOR ENERGY |
| To: | |
| Shared Package | |
| ML20217K112 | List: |
| References | |
| RTR-REGGD-01.064 NUDOCS 9910260053 | |
| Download: ML20217K123 (17) | |
Text
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Altichm:nt 1 DBNPS Sirial Numbir 2620 PY-CEl/NRR-2438L Page 2 of 3 FENOCrir ren.,gynuci..,op.cating como.nr QUALITY ASSURANCE PROGRAM MANUAL 3)
Test personnel utilizing gas test methods for information or data collection activities (this includes those personnel performing local leak rate testing (LLRT) as :.tated in 10CFR50 Appendix J).
i 4)
Plant operation personnel concemed with day-to-day operation, maintenance, and certain tecimical services (the qualifications of these personnel shall conform to the requirements of Regulatory Guide 1.8).
Personnel who perform nondestructive examination activities shall meet the c.
qualification requirements of SNT-TC-1 A (1980) as described below.
2.
FENOC commits to the requirements of ANSI N45.2.6-1978 as modified by the commitments to Regulatory Guide 1.58.
3.
FENOC commits to the requirements of SNT-TC-1 A (1980) with the following clarifications:
a.
For Davis-Besse:
1)
The word "should" in the following paragraphs of SNT-TC-1 A (1980) shall be considered "shall": 4.3(1), 4.3(2), 4.3(3), 6.3, 7.1, 7.2, 8.1, 8.1.1(1), 8.1. l(2),
8.1. l (3), 8.1.1 (4), 8.1.2(1), 8.1.2(2), 8.1.3(1), 8.1.3(2), 8.1.4(1), 8.1.4(2),
8.1.4(3), 8.1.5, 8.3, 8.3. l(1), 8.3. l(2), 8.3.2(3), 8.3.4, 8.4.2, and 9.7.3.
2)
Paragraph 8.4.4 recommends a composite grade of 80% and a grade of 70% for the general, specific, and practical or the basic method, and specific examination. Davis-Besse commits to this recommendation.
b.
For Perry:
1)
Personnel who perform nondestructive examination activities (including NDE gas leak testing) shall meet the qualification requirements of SNT-TC-1 A (1980) as modified by ASME Code Case 356.
' M.
Regulatory Guide 1.64 (Revision 2) [ June 1976], Quality Assurance Requirementsfor the Design ofNuclear Power Punts t
1.
FENOC commits to the regulatory posit. ion of this Guide with the following clarifications:
Section C.2(1) addresses the use of a supervisor in design verification. If, in a.
exceptional circumstances, the supervisor is the only technically qualified individual available. the design verification or checking shall be conducted by the supervisor with the following provisions:
9910260053 991014 Table 1 PDR ADOCK 05000346 Regulatory Commitments P
POR Revision 0 25
i Att chment 1 DBNPS Strial Number 2620 PY-CEl/NRR-2438L FENO Cricstenergr uuci.., op.,nting co,nonny
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QUALITY ASSURANCE PROGRAM MANUAL 1)
The other reqvrements of Section C.2 of this Guide shall be met.
2)
Thejustification shall be individually documented and approved by the next level of supervision.
3)
Quilty assurance audits shall include review of frequency and effecti teness of the use of the immediate supervisor to assure that this provision is used only in exceptional circumstances.
93 b.
An individual who contributed to a given design may participate in a group c4AM verification of that design provided that the individual who contributed to the design does not (1) verify his contribution to the design, or (2) serve as chairman or leader of the group verification activity.
m
_w m
2.
FENOC commits to the requirements of ANSI N45.2.11-1974 with the clarifications as noted above for the use of an immediate supervisor for design verification activities and conduct of group verification activities.
N.
Regulatory Guide 1.74 (Revision 0) [ February 1974J, Guality Assurance Terms and Definitions 1.
FENOC commits to the regulatory position of this Guide.
2.
FENOC commits to the requirements of ANSI N45.2.10-1973.
O.. Regulatory Guide 1.88 (Revision 2) [ October 1976], Collection, Storage and
' Maintenance ofNuclear Power Plant Quality Assurance Records 1.
FENOC commits to the regulatory position of this Guide.
2.
FENOC commits to the requirements of ANSI N45.2.9-1974 with the following clarifications:
a.
For Davis-Besse:
1)
Add the following definitiorn to those of ANSI N45.2.9:
a)
As-Built - Docume.ated data that describes the condition achieved in a product. An installation shall be considered to be in an "as built" or "rsonstructed" condition ifit is installed within the tolerance indicated in the design output documents or has been evaluated and documented as an acceptable condition.
Table 1 Regulatory Commitments Revision 0 26
.,l Attichmtnt 2 DBNPS Strial Number 2620 PY-CEl/NRR-2438L Page 1 of 13
, Revised Quality Assurance Proaram Chanaes at the Perry Nuclear Power Plant (PNPP)
This attachment presents the NRC staff's comments on the PNPP portion of the
. August 19,1999 submittal, followed by the PNPP staff's response. The PNPP staff's responses are in bold print.-
- 1. Regarding PNPP USAR Table 1.8-2, Regulatory Guide 1.28 (Revision 2 - 2/79):
ASME Code Quality Assurance Program is not required to cover non-code related items. Also, suppliers possessing an ASME Code Section lli Certificate are not necessarily subjected to an implementation audit of their quality assurance program.
Further explanation of the NRC position is contained in the following Information Notices:
(1) Information Notice 86-21 (2) Information Notice 86-21, Supplement 1 (3) Information Notice 86-21, Supplement 2 (4) Information Notice 88-95.
The PNPP staff withdraws the request for the change in position. The current PNPP level of commitment to Regulatory Guide 1.28 will be maintained. The proposed FirstEnergy Nuclear Operating Company (FENOC) Qc
" Assurance Program Manual (QAPM) has been clarified to reflect this levC.,r commitment. This change is now considered not to be a reduction in commitment to the ')NPP Quality Assurance Program. The revised section of the FENOC QAPM is provided for information only; refer to Page 17, item C.
- 2. Regarding PNPP USAR Table 1.8-2, Regulatory Guide 1.37 (Revision 0 - 3/73):
1.ack of information. (However, based upon the discussion held with the NRC staff on September 30,1999 and October 7,1999, the PNPP staff understands the concern to be the proposed position did not provide any type of limit for the materials in question.)
- The PNPP staff agrees to clarify the proposed position. The proposed FENOC QAPM was revised to state that materials will be controlled through administrative procedures in order to minimize the effects of intergranular stress corrosion
. cracking. This change continues to be considered a reduction in commitment to the PNPP Quality Assurance Program. As detailed in the August 19,1999 letter, this proposed change is acceptable because it does not diminish the effectiveness of implementing quality assurance program requirements, and the proposed program continues to satisfy the requirements of 10 CFR 50, Appendix B. The revised section of the FENOC QAPM is enclosed; refer to Page 21, item G.1.c.
~ 3. Regarding PNPP USAR Table 1.8-2, Regulatory Guide 1.38 (Revision 2 - 5/77):
ANSI N45.2.2 already allows for a range of controls depending on the importance of the item to safety or reliability. Thts addition of new categories with a different level of controls is not clearly described.
Attachmsnt 2 DBNPS Strial Numbrr 2020 PY-CEUNRR-2438L Page 2 of 13 The PNPP staff withdraws the request for the change in position. The current PNPP
. level of commitment to Regulatory Guide 1.38 will be maintained. The proposed FENOC QAPM has been clarified to reflect this level of commitment. This change is 1
now considered not to be a reduction in commitment to the PNPP Quality Assurance Program. The revised section of the FENOC QAPM is provided for information only; refer to Page 22, item H.
- 4. Regarding PNPP USAR Tada 1.8-2, Regulatory Guide 1.39 (Revision 2 - 9/77):
ANSI N45.2.3, Section 2.1 already allows for a range of five zones that encome es all situations. A clear explanation of an alternative has not been establishV The PNPP staff withdraws the request for the change in position. The current PNPP level of commitment to Regulatory Guide 1.39 will be maintained. The proposed FENOC QAPM has been clarified to reflect this level of commitment. This change is now considered not to be a reduction in commitment to the PNPP Quality Assurance Program. The revised section of the FENOC QAPM is provided for information only; refer to Page 23, ltem f.
- 5. Regarding PNPP USAR Table 1.8-2, Regulatory Guide 1.94 (Revision 1 - 4/76):
A defined set of guidance that will be used for the development of procedures has not j
been described.
The PNPP staff agrees to clarify the proposed position. The position now states that ANSI N45.2.5 will be used to develop structural concrete or steel procedures, instead of stating the standard will be used as nuidance (the underlined words indicate the changes). The proposed FENOC QAPM was revised to reflect this position. This change continues to be considerod a reduction in commitment to the PNPP Quality Assurance Program. As detailed in the August 19,1999 letter, this proposed change is acceptable because it does not diminish the effectiveness of implementing quality assurance program requirements, and the proposed program continues to satisfy the requirements of 10 CFR 50, Appendix B. The revised section of the FENOC QAPM is enclosed; refer to Page 28, item P.2.a.
- 6. Regarding PNPP USAR Table 1.8-2, Regulatory Guide 1.123 (Revision 1 - 7/77):
The supplier has no reasonable way to verify that the item or service being furnished complies with the procurement requirements.
The PNPP staff withdraws the request for the change in position. The current PNPP level of commitment to Regulatory Guide 1.123 will be maintained. The proposed j
FENOC QAPM has been clarified to reflect this level of commitment. This change is j
now considered net to be a reduction in commitment to the PNPP Quality Assurance i
Program. The revised section of the FENOC QAPM is provided for information only-refer to Page 30, item R.
l l
Attachm:nt 2 I
DBNPS Serial Numbrr 2620 PY-CEl/NRR-2438L Page 3 of 13
Not enough information was supplied to reach a conclusion. Please describe in the quality assurance plan the documents (if any) that the audit frequencies are listed in.
For example, the audit frequency of fire protection is stated in the Section XX.XX of PNPP (or DBNPS) Fire Protection Plan or the audit frequency for emergency procedures is stated in Section XX.XX of PNPP (or DBNPS) Emergency Plan. If the QA plan is the document that controls the audit frequency then state in the QA plan the audit frequency. The audit frequency is a reason (able) level of detail expected in the QA plan.
The PNPP staff understands that the concern with the proposed position is associated with what audits are being performed and their associated periodicity and not the activities of the Company Nuclear Review Board. The list of quality assurance audits with the performance frequencies has been incorporated into the proposed FENOC QAPM. This change is now considered not to be a reduction in commitment to the PNPP Quality Assurance Program. The revised section of the FENOC QAPM is provided for information only; refer to Pages 15 and 16, Section 2.a, " Audit."
The current level of detail describes the controls necessary for computer controls which may not be considered if the removalis approved.
The PNPP staff withdraws the request for the change in position. The proposed FENOC QAPM has been clarified to describe controls associated with computer programs. This change is now considered not to be a reduction in commitment to the PNPP Quality Assurance Program. The revised portion of the FENOC QAPM is provided for information only; refer to Pages 5 and 6, Section 1.e " Methodology."
lBEORMATION ONLY mi n2 einemee,2e2o
.E Of PY-CEl/NRR-2438L v vFirstEnergy Nuclear Operating Company Page4of13 E
QUALITY ASSURANCE PROGRAM MANUAL A.
Regulatory Guide 1.8 (Revision 1) [ September 1975], PersonnelSelection and Training 1.
FENOC commits to the regulatory position of this Guide with the following clarifications:
Regulatory Guide 1.8 states "The RPM should have a bachelor's degree or the a.
equivalent in a science or engineering subject including some formal training in radiation protection and at least 5 years of professional experience in applied radiation protection." It is FENOC's position that equivalent as used in this Regulatory Guide for the bachelor's. degree means (a) four years of post secondary schooling in science or engineering,'or (b) four years of applied experience at a nuclear facility in the area for which qualification is sought, or (c) four years of operational or technical experience or training in nuclear power, or (d) any combination of the above totaling four years. The years of experience used to meet the education requirements as allowed by this exception shall not be used to also meet the experience requirements.
b.
Other modifications to the regulatory position of this Guide are as specified in the site's Technical Specifications and USARs.
2.
FENOC commits to the requirements of ANSI N18.1-1971 as modified by the site's Technical Specifications and USARs.
1 B.
Regulatory Gulde 1.26 (Revision 3-R) [ March 1976], Quality Group Classi/Ication, andStandardsfor Water, Steam, andRadioactive-Waste-Containing Components of Nu:learPowerPlan's 1.
FENOC commits to the regulatory position of this Guide as described in each plant's l
j C.
Regulatory Guide 1.28 (Revision 2) [ February 1979], Quality Assurance Program TH5 i
Requirements (Design and Construction)
CQp(7[
i 1.
FENOC commits to the regulatory position of this Guide.
/
j i
2.
FENOC D.
Regulatory Guide 1.29, Selsmic Design Classification j
i 1.
FENOC commits to the regulatory position of this Guide as described in each plant's i
I l!EORMATiSH ORY I
Table 1 Regulatory Commitments Revision 0 17
i Att chment 2 DBNPS Sirial Numbtr 2620 PY-CEl/NRR-2438L i
FENO Crirnten.cgr nucion, oporneing company QUALITY ASSURANCE PROGRAM MANUAL possible revision upon identification of new or revised source material potentially affecting the intent ofprocedures.
G.
Regulatory Guide 1.37 (Revision 0) [ March 1973], Quality Assurance Requirementsfor Cleaning ofFluid Systems and Associated Components of Water-CooledNuclear Power Plants 1.
FENOC commits to the regulatory position of this Guide with the following clarifications:
i For operations, Regulatory Guide 1.37 will be applied to activities comparable in a.
nature and extent to construction activities.
b.
Regulatory Position C.3 requires that the water quality for final flushes of fluid systems and associated components be at least equivalent to the quality required for normal operation. This requirement is not applied to dissolved oxygen or nitrogen nor does it infer that additives normally in the system water shall be added to the flush water.
Regulatorybon C.4 requires that chemical components that could c.
ntribute to N
intergranular cracking or stress corrosion cracking should not be used with austenitic stainless steel and nickel-based alloys. It is FENOC's position that materials such as O h-b inks, temperature indicating crayons, labels, wrapping materials (other than polyethylene), water soluble materials, desiccants, lubricants, and NDE penetrant i
(
materials and couplants, which contact stainless steel or nickel-based alloy material surfaces contain no more than trace amounts oflead, zinc, copper, or lower melting alloys or compounds. Maximum allowable levels of water leachable chloride ions, y
total halogens and sulfur compounds shall be defined and imposed on the aforementioned materials. These materials will be controlled through administrative procedures which are, in part, designed to minimize their effects on intergranular cracking or stress corrosion crackin'g.
2.
FENOC commits to the requirements of ANSI N45.2.1 1973 with the following tiarifications:
During mainter.nce and modification activities, FENOC shall control the opening of a.
clean system; and shall conduct inspections to verify that affected system cleanliness levels shall not be adversely affected by the maintenance or modification activity.
When system cleanliness is affected, specific cleaning procedures which incorporate the applicable portions of this Standard shall be developed and implemented to maintain system cleanliness.
b.
Section 2.4 reouires that personnel who perform inspection, examination or testing activities required by this Standard be qualified in accordance with ANSI N45.2.6. In Table 1 Regulatory Commitments Revision 0 21
3NE0RMAT10N ONLY3"I'"
DBNPS S: rial Number 2620 FENO Crir,renorgy nucio.c oporating company QUALITY ASSURANCE PROGRAM MANUAL lieu of this, personnel who perform cleanliness inspections may alternatively be qualified in accordance with Regulatory Guide 1.8.
I.
Regulatory Guide 1.38 (Revision 2) [May 1977], Quality Assurance Requirementsfor l
Packaging, Shipping, ReceMng, Storage, and Handling ofItemsfor Water-Cooled Nuclear Power Plants
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1.
FENOC commits to the regulatory position of this Guide for activities comparable in nature and extent to construction phase activities
}
2.
FENOC commits to the requirements of ANSI N45.2.2-1978 with the following clarifications:
l a.
Sections 3 and 4 specify a four level classification system for the packaging and l
shipping ofitems. In lieu of these requirements, commercial grade items shall be packaged and shipped in accordance with standard commercial practices.
b.
Section 5.2.l requires preliminary visual inspection or examination for shipping damage to be performed prior to unloading. In lieu of this requirement, visual inspection shall be performed during unloading and unpacking.
j Section 5.5 provides for " rework" and "use-as-is" dispositions for nonconforming c.
items. As an alternative, the " repair" disposition (as defined by ANSI N45.2.10-j 1973) shall also be used.
d.
Section 6.5 requires that items released from storage and placed in their final I
locations within the power plant be inspected and cared for in accordance with the f
requirements of Section 6 of this Standard and other applicable Standards. In lieu of
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this requirement, FENOC shall, whenever feasible, store items within their appropriate storage area and move the equipment to the plant areas for staging only in f sufficient time to support its installation. Within the plant, the equipment shall be staged at locations which provide equivalent environmental conditions under which it is designed to operate. Materials placed in staging areas shall be stored in accordance i
l with the applicable requirements of Paragraphs 6.1,6.3 and 6.4.2 of ANSI N45.2.2.
l e.
Various Sections of ANSI N45.2.2 address the use of non-halegenated materials when in contact with austenitic stainless steel or nickel-based alloys. The exceptions j
applicable to Regulatory Guide 1.37 regarding this subject also apply to ANSI N45.2.2.
f.
Section A.3.4.2 addresses inert gas blankets. There may be cases involving large or l
l complex shapes for which an inert or dry air purge flow is provided rather than static gas blankets in order to provide adequate protection due to difficulty of providing a l
1 Table 1 T@h CdAMGE Regulatory Commitments Revision 0 JNFORMATION ONEY
7 v
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{.
Attachm:nt 2
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DBNPS Strial Numb r 2620
,1NE0RMATION ONLY "M= "*'
PENO CFirstEnergy Nuclear Operating Company
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QUALITY ASSURANCE PROGRAM MANUAL leak-proof barrier. In these cases, a positive pressure purge flow may be used as an alternative to a leak-proof barrier. _
I.
Regulatory Guide 1.39 (Revision 2) [ September 1977], Housekeeping Requirementsfor Water-CooledNuclearPower Plants MS I
1.
FENOC commits to the regulatory position of this Guide.
CH/W6d 2.
FENOC conunits to the requirements of ANSI N45.2.3-1973.
J.
Regulatory Guide 1.54 (Revision 0) [ June 1973], Guality Assurance Requirementsfor Protective Coatings Applied to Water-CooledNuclear Power Plants 1.
FENOC commits to the regulatory position of this Guide with the following clarifications:
a.
This Regulatory Guide and its associated ANSI Standard implies that a significant amount of coating work is required at the plant site. Although this is correct for i
construction sites, the coating work at an operating site generally consists of repair and touchup work following maintenance and repair activities or the initial coating of components such as hangers, supports, and piping during facility modifications.
Therefore, in lieu of the full requirements of this Regulatory Guide and ANSI N101.4, FENOC shall impose the following requirements:
1)
The quality assurance requirements of Section 3 of ANSI N101.4 applicable to the coating manufacturer shall be imposed on the coating manufacturer through the procurement process.
2)
Coating application procedures shall be developed based on the manufacturer's recommendations for application of the selected coating systems.
3)
Coating applicators shall be qualified to demonstrate their ability to satisfactorily apply the coatings in accordance with the manufacturer's recommendations.
4)
Quality control personnel shall perform inspections to verify conformance of the. coating application procedures. Section 6 of ANSI N101.4 shall be used as guidelines in the establishment of the inspection program.
t l
5)
Quality control personnel shall be qualified to the requirements of Regulatory Guide 1.58 (Revision 1).
6)
Documentation demonstrating conformance to the above requirements shall be maintained.
ORMATION ORY neaniatory commEm'c'nts Revision 0 23
m-
- t DBNPS Strial Number 2620 PY-CEl/NRR.2438L FENOCRrstEnr Nuclear Operating Company QUALITY ASSURANCE PROGRAM MANUAL b.
For Perry:
1)
Where duplicate records are not maintained, records will be stored in a facility whose construction incorporates features recommended in ANSI N45.2.9, with the following exceptions:
a)
Door assemblies are Underwriter's Laboratory listed with a three-hour rating to provide fire protection in accordance with ASTM E-152.
b)
For storage of special processed records (such as radiographs and microfilm), humidity and temperature controls shall be provided so as to maintain an environmental condition as prescribed in Paragraph 6.1.1 of ANSI PH 1.43-1979 in lieu of the last paragraph in Section 5.6 of ANSI N45.2.9-1974.
c)
Active records may be temporarily stored in one-hour fire rated cabinets. The use of the one-hour fire rated cabinets for such records shall be limited to temporary storage prior to the time records are transferred to the permanent records storage facility.
This temporary storage is limited to approximately three months.
P.
Regulatory Guide 1.94 (Revision 1) [ April 1976], Guality Assurance Requirements forInstallation, Inspection and Testing ofConcrete andStructuralSteelDuring the Construction Phase ofNuclear Power Plants 1.
FENOC commits to the regulatory position of this Guide for activities comparable i
in nature and extent to construction phase activities.
NOC commits to the requirements of ANSI N45.2.5-1974 with the followin[
clarification:
i Section 2.2 requires that installation, inspection, and test procedures be kept
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a.
Tili5 current with the latest infonnation. This Standard was written to addressI C$$g requirements associated with construction phase activities. However, duringI the operations phase, activities associated with installation, inspection, and testing of structural concrete and structural steel are very minor in frequency and extent. Consequently, procedures for these activities shall only be reviewed or updated prior to commencing the activity. The procedures for stnictural concrete and structural steel installation, inspection, and testing
\\
activities will be developed using the provisions of ANSI N45.2.5 - 1974.
Table 1 Regulatory Commitments Revision 0 28
l Attachm:nt 2 J* NE0RMATION ONLY
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- Page 9 of 13 FENO CFirstEnergy Nuclear Operating Company QUALITY ASSURANCE PROGRAM MANUAL R.
Regulatory Guide 1.123 (Revision 1) [ July 1977], Quality Assurance Requirements for Control ofProcurement ofItems and Servicesfor Nuclear Power Plants 1.
FENOC commits to the regulatory position of this Guide.
1 cHMGS 2.
FENOC commits to the requirements of ANSI N45.2.13-1976 with the following clarifications:
t a.
Section 4 provides for the selection of procurement sources. For " commercial grade" items and for non-safety related items within the scope of the Quality Assurance Program for which there are no quality assurance program or I
quality documentation requirements, the requirements of this Section need not
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be adhered to. However, the procurement documents shall specify requirements specific to the item being procured, sufficient to provide adequate certification or other records to ensure that item:: and activities meet the specified requirements.
b.
Section 8.2 provides requirements for the control of nonconformances.
Suppliers qualified by FENOC as design agents in accordance with Regulatory Guides 1.64 and 1.123 may be permitted under specific l
contractual provisions to disposition nonconformances as "use-as-is" or
" repair" on behalf of FENOC. All nonconformances dispositioned "use-as-is" or " repair" by suppliers qualified by FENOC as design agents on behalf of
}
FENOC are required to be submitted to FENOC for engineering approval at the time equipment is received on site. If FENOC determines that a disposition has been incorrectly made, a nonconformance report is generated on site to document the problem and effect resolution.
c.
Section 10.2.d is interpreted as follows: The person attesting to a certificate shall be an authorized and responsible employee of the supplier and shall be
)
identified by the supplier.
S.
Regulatory Guide 1.144 (Revision 1) [ September 1980], Auditing of Quality Assurance Programsfor Nuclear Power Plants 1.
FENOC commits to the regulatory position of this Guide for activities that are comparable in nature and extent to construction phase activities.
2.
FENOC commits to the requirements of ANSI N45.2.12-1977 with the following clarification:
a.
Section 4.5.1 of this Standard discusses follow-up and corrective actions.
FENOC may utilize the provisions of the corrective action program outlined
!NFORMATl0N ONLY nes*torycod""e'ts' Revision 0 30
1, DBNPS Strial Number 2320 PY-CEl/NRR-2438L i
FirstEnergy Nuclear Operating Company QUALITY ASSURANCE PROGRAM MANUAL Personnel performing audits have no direct responsibilities in the area they are assessing.
c.
d.
Audits are accomplished using procedures, or other appropriate means that are of a detail commensurate with the activity's complexity and importance to safety.
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2.
Audit A program of planned and periodic audits is established and implemented to confirm that activities affecting quality comply with the QAPM and that the QAPM has been i
implemented effectively. Audits will be conducted as required by the applicable Code of i
Federal Regulations, Technical Specifications, safety analysis reports, and commitments t
j by various correspondence to the NRC.
l.
Audit schedules assure that the following areas are audited at the indicated frequencies, or more frequently as performance dictates.
The conformance of unit operation to provisions contained within the a.
Technical Specifications and applicable license conditions at ieast once per 24 months.
b.
The performance, training and qualification of the station staff at least once per 24 months.
The results of actions taken to correct deficiencies occurring in unit c.
)
equipment, structures, systems or method of operation that affect nuclear f
safety at least once per 24 months.
d.
. The performance of activities required by the QAPM to meet the requirements of 10CFR50, Appendix B at least once per 24 months.
The fire protection program controls and implementing procedures at least e.
once per 24 months.
f.
The fire protection equipment and program implementation at least once per l
12 months utilizing either qualified licensee personnel or an outside fire 4
protection consultant.
l j
g.
The fire protection equipment and program implementation at least once per k
36 months utilizing a qualified outside fire protection consultant.
I h.
The Radiological Enviromental Monitoring Program (REMP) and
$):$
radiological effluents monitoring activities and implementing procedures a'.
cH/)N(,g k least once per 24 months.
l i.
The Offsite Dose Calculation Manual and implementing procedures at least once per 24 months.
j.
The Process Control Program and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.
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Att chment 2 DBNPS Stri:1 Number 2620 i(1 %v %rFirstEnergy Nuclear Operating Company yf FY-CEl/NRR-2438L b
Page 11 of 13 QUALITY ASSURANCE PROGRAM MANUAL k.
Any other area of facility operation considered appropriate by the offsite h
review committee or the site executive responsible for overall plant nuclear l
y, operations support, and engineering.
2.
Audits shall provide an objective evaluation of quality related practices, procedures, instructions, activities, and items and a review of documents and records, as applicable.
3.
Audits shall be performed in accordance with approved written procedures or checklists. Items from previous audits shall be reviewed and reaudited, as appropriate. The checklists are used as guides to the auditor.
4.
Scheduling and resource allocation are based on the status and safety importance of the activity or process being assessed.
5.
Scheduling is dynamic and resources are supplemented when the effectiveness of the quality assurance program is in doubt.
6.
Audit reports are written and distributed to the appropriate levels of management for review. Follow-up action, including reaudit of deficient areas, is initiated as deemed appropriate.
7.
Implementation of delegated portions of the quality assurance program is assessed.
8.
Audits are conducted using predetennined acceptance criteria.
9.
Additional details concerning audits may be found in the Regulatory Guides and associated Standards as committed to in Section A.7 and Table 1 (e.g., Regulatory Guides 1.33 and 1.144).
D.
INDEPENDENT SAFETY REVIEW 1.
Description a.
Independent safety review is performed to meet the individual unit's commitment to perform the functions described in NUREG-0737,Section I.B.1.2, " Independent Safety Engineering Group."
16 Revision 0
Att:chment 2 j
DBNPS Sirial Number 2620 I
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. )[L.)(1 %r %vFirstEnergy Nuclear Operating Company C
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7.
l Except where alternatives are identified, FENOC complies with the QA guidance documents I
a.
listed on Table 1. If the guidance in any of these documents is in conflict with the QAPM, I
the guidance provided in the QAPM is the controlling guidance. Additionally, the following clarifications apply to all guidance documents listed in Table 1.
1 1.
For modifications and nonroutine maintenance, guidance applicable to construction-like activities is applicable to comparable plant activities. Except that the inspection of modifications, repairs, rework, and replacements shall be in accordance with the original design and inspection rquirements or a documented approved alternative.
l 2.
The definitions provided by Regulatory Guide 1.74 and associated clarifications as described in Table 1 apply wherever the defined term is used in the QAPM and i
associated guidance documents.
3.
Clarification to a guidance document applies wherever the giddance document is invoked.
I 4.
In each of the ANSI Standards, other documents (e.g., other Standards, Codes, Regulations, tables, or appendices) are referenced or described. These other documents are only quality assurance program requirements if explicitly committed to in the QAPM. If not explicitly committed to, these documents are not considered as quality assurance program requirements, although they may be used as guidance.
5.
Guidance applicable to safety related items and activities is applicable to comparable items and activities controlled by 10CFR72.
i b.
The NRC is to be notified of QAPM changes in accordance with 10 CFR 50.54(a).
I B.
PERFORMANCE / VERIFICATION 1.
Methodology a.
Personnel performing work activities such as design, engineering, procurement, manufacturing, construction, installation, startup, maintenance, modification, operation, 2
and decommissioning are responsible for achieving acceptable quality.
b.
Personnel performing verification activities are responsible for verifying the achievement of acceptable quality.
Work is accomplished and verified using instructions, procedures, or other appropriate c.
means that are of a detail commensurate with the activity's complexity and importance to l
safety.
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l Attichmint 2 DBNPS S: rial Numbir 2620 l
PY-CEl/NRR-2438L A
FirstEnergy Nuclear Operating Company QUALITY ASSURANCE PROGRAM MANUAL d.
Criteria that define acceptable quality are specified, and quality is verified against these criteria.
THi5 Computer programs used in safety related design analyses or operational activities are e.
controlled through administrative procedures.
2.
Design Control The design control program is established and implemented to assure that the activities a.
associated with the design of systems, components, structures, and equipment and modifications thereto, are executed in a planned, controlled, and orderly manner.
b.
The program includes provisions to control design inputs, processes, outputs, changes, interfaces, records, and organizational interfaces, c.
Design inputs (e.g., performance, regulatory, quality, and quality verification requirements) are to be correctly translated into design outputs (e.g., specifications, drawings, procedures, and instructions).
d.
The final design output is to relate to the design input in sufficient detail to permit verification.
e.
The design process is to ensure that items and activities are selected and independently verified consistent with their importance to safety to ensure they are suitable for their intended application.
f.
Changes to final designs (including field changes and modifications) and dispositions of non-conforming items to either use-as.is or repair are to be subjected to design control measures commensurate with those applied to the original design and approved by the organization that performed the original design or a qualified designee.
g.
Interface controls (internal and external between participating design organizations and across technical disciplines) for the purpose of developing, reviewing, approving, releasing, distributing, and revising design inputs and outputs are defined in procedures.
h.
Design documentation and records, which provide evidence that the design and design verification process was performed in accordance with this program, shall be collected, stored, and maintained in accordance with documented procedures. This documentation includes final design documents, such as drawings and specifications, and revisions thereto and documentation which identifies the important steps, including sources of design inputs that support the fimal design.
6 Revision 0
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-l DBNPS Sarial Number 2620 PY-CEl/NRR-2438L Page 1 of 1 COMMITMENT LIST THE FOLLOWING LIST IDENTIFIES THOSE ACTIONS COMMl'ITED TO BY THE 1
DAVIS-BESSE NUCLEAR POWER STATION (DBNPS) IN THIS DOCUMENT. ANY
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OTHER ACTIONS DISCUSSED IN THE SUBMITTAL REPRESENT INTENDED OR l
PLANNED ACTIONS BY THE DBNPS. THEY ARE DESCRIBED ONLY FOR INFORMATION AND ARE NOT REGULATORY COMMITMENTS. PLEASE NOTIFY THE MANAGER - REGULATORY AFFAIRS (419-321-8466) AT THE DBNPS OF ANY l
QUESTIONS REGARDING THIS DOCUMENT OR ANY ASSOCIATED j
j COMMITMENTS DUE DATE None N/A j
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Attachm*nt 4 DBNPS Serial Number 2620 PY-CEl/NRR-2438L Page 1 of 1 COMMITMENT LIST THE FOLLOWING LIST IDENTIFIES THOSE ACTIONS COMMITTED TO BY THE PERRY NUCLEAR POWER PLANT (PNPP)IN THIS DOCUMENT. ANY OTHER ACTIONS DISCUSSED IN THE SUBMITTAL REPRESENT INTENJED OR PLANNED ACTIONS BY THE PNPP. THEY ARE DESCRIBED ONLY FOR INFORMATION AND l
ARE NOT REGULATORY COMMITMENTS. PLEASE NOTIFY THE MANAGER -
REGULATORY AFFAIRS (440-280-6305) AT THE PNPP OF ANY QUESTIONS REGARDING THIS DOCUMENT OR ANY ASSOCIATED REGULATORY COMMITMENTS.
COMMITMENTS DUE DATE 1
None N/A r
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