ML20236Q049
| ML20236Q049 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/13/1998 |
| From: | NORTHEAST NUCLEAR ENERGY CO. |
| To: | |
| References | |
| NUDOCS 9807170283 | |
| Download: ML20236Q049 (150) | |
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! >>>>>>> NUQAP TOPICAL REPORT. REVISION DISTRIBUTION <<<<<<<
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- :rth=t i Utilkies System l
1 o Memo July 6th,1998 048-PRG-098 TO: Northeast Utilities Quality Assurance Program Topical Report Controlled Copyholders d FROM: J.E. Beaucham
SUBJECT:
NUQAP Topical Report Revision 19, Change 01 Enclosed are NUQAP revision 19 including change 01. Please replace the entire contents of your manual with the enclosed document. This is a full page document revision. Change 01 has been included to reflect changes that have occurred between June of 1997 and 5/1/98 that have been evaluated as not requiring NRC approval in accordance with 10CFR50.54. The following conventions are used to identify the location of the changes: i e Revision 19 changes are in bold and /talics without revision bars.
. Change 01 changes are in bold and /tal/cs with a revision bar in the right margin. The
( footer of the affected section will include a reference to change 01. j insert the attached summary of changes document and NRC acceptance letter in the front of your manual. Please note that the new exception number 12 in Appendix E referred to in attachement 2 was deleted by license correspondence letter B17274, dated 6/9/98. If you have any questions contact J.E. Beauchamp at X2113. l Attachments: .
- 1. USNRC letter dated 6/24/98, subject: Approval of Proposed Revision 19 to the NU QA )
Program Topical Report.
- 2. Summary of Changes incorporated into revision 19 of the NUQAP.
- 3. Summary of changes incorporated as part of revision 19, change 01.
Enclosure:
Northeast Utilities Quality Assurance Program Topical Report revision 19, change 01. c ____ __ __ _ _ _ _ _ - _ _ _ _ _ . n
M uruq p t g j UNITED GTATES NUCLEAR REGULATORY COMMISSION o je WASHINGTON D.c. 20ess 4001 k*****/ June 24, 1998 Mr. Martin L Bowling, Jr. Recovery Officer - Technical Services jh@@@ h, l l
;v Northeast Nuclear Energy Company '
/ if d l c/o Ms. Patricia A. Loftus i g g 01993 ,. -
Director- Regulatory Affairs P. O. Box 128 / ,. jl ? Waterford, Connecticut 06385 /* Y l.%
SUBJECT:
APPROVAL OF PROPOSED REVISION 19 TO THE NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM TOPICAL REPORT (TAC NOS. M95739, M95740, AND M95741)
Dear Mr. Bowling:
On June 10,1996, Northeast Nuclear Energy Company (NNECO) transmitted proposed Revision 19 to the Northeast Utilities Quality Assurance Program (NUQAP) Topical Report for l NRC review and approval in accordance with 10 CFR 50.54(a)(3). As a result of requests for l additionalinformation by the NRC staff, significant organization changes, and the decision to l permanently shut down the Haddam Neck Plant, NNECO amended or clarified its original submittal by correspondence dated February 20,1997, June 3,1997, August 7,1997, November 25,1997, January 29,1998, April 6,1998, and June 9,1998. The proposed Revision 19 to the NUQAP submitted on June 3,1997, superseded the originalin its entirety. l 'bQ in its proposed Revision 19 to the NUQAP, dated June 3,1997, NNECO identified six new exceptions to previous quality assurance (QA) program description commitments, i.e, reductions in commitment pursuant to Section 50.54(a)(3), and several other changes. The enclosed safety . evaluation documents our review and the basis of our approval of your proposad Revision 19 to I the NUQAP. i While NNECO's proposed QA program exceptions described in the enclosed safety evaluation constitute reductions in commitments in the QA program description previously approved by the ; NRC, such exceptions continue to satisfy the provisions in the applicable American National : Standards institute (ANSI) standard and/or Regulatory Guides in accordance with Section 17.2 of the NRC's Standard Review Plan. Therefore, proposed Revision 19 to NNECO's NUQAP Topical Report, dated June 3,1997, as amended through June 9,1998, continues to comply with the quality assurance criteria of Append!x B to 10 CFR Part 50 and is acceptable. However, NNECO's exception to the provisions in paragraph 10.3.5 of ANSI N45.2.13-1976 constitutes a temoorarv. acceptable attemative to such provisions and applicable only to the vendors carrying out the Independent Corrective Action Verification Program pursuant to the NRC Confirmatory Order. l l O . L--___------- - - - -
q M. L Bowling \ N) i If you have any questions regarding this issue, please call Mr. Stephen Dembek of my staff at (301) 415-1455. Sincerely,
/ k Phillip F. McKee Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation Docket Nos. 50-245,50-336, and 50-423
Enclosure:
Safety Evaluation cc w/ encl: See next page O - l l L___-----__--
4
~
Mill: tone Nucle:r Power Station
- Units 1,2, and 3 cc:
O Ullian M. Cuoco, Esquire Mr. Charles Brinkman, Manager Washington Nuclear Operations Senior Nuclear Counsel ABB Combustion Engineering Northeast Utdsties Service Company 12300 Twinbrook Pkwy, Suite 330 P. O. Box 270 Rockville, MD 20852 Hartford, CT 06141-0270 Mr. John Streeter Mr. Kevin T. A. McCarthy, Director Recovery Officer - Nuclear Oversight Monitoring and Radiation Division Northeast Utilities Service Company Department of Environmental P. O. Box 128 Protection Waterford, CT 06385 79 Elm Street Hartford, CT 06106 5127 Senior Resident inspector Millstone Nuclear Power Station Mr. Allan Johanson, Assistant Director c/o U.S. Nuclear Regulatory Commission Office of Policy and Management P. O. Box 513 Policy Development and Planning Niantic, CT 06357 Division 450 Capitol Avenue - MS 52ERN Mr. David Amerine P. O. Box 341441 Vice President - Human Services Hartford, CT 06134-1441 Northeast Utilities Service Company P. O. Box 128 Regional Administrator, Region i Waterford, CT 06385 U.S. Nuclear Regulatory Commission 475 Allendale Road Mr. M. H. Brothers King of Prussia, PA 19406 Vice President - Operations Northeast Nuclear Energy Company First Selectmen P. O. Box 128 Town of Waterford Waterford, CT 06385 Hall of Records 200 Boston Post Road Mr. M. R. Scully, Executive Director Waterford, CT 06385 Connecticut Municipal Electric Energy Cooperative Mr. J. P. McElwain 30 Stott Avenue Recovery Officer- Millstone Units 1 and 2 Norwich, CT 06360 Northeast Nuclear Energy Company P. O. Box 128 Mr. William D. Meinert Waterford, CT 06385 Nuclear Engineer Massachusetts Municipal Wholesale Mr. Wayne D. Lanning Electric Company Deputy Director of Inspections P. O. Box 426 Special Projects Office Ludlow, MA 01056 475 Allendale Road King of Prussia, PA 19406-1415 Emest C. Hadley, Esq. 1040 B Main Street Mr. F. C. Rothen P. O. Box 549 Vice President-Work Services West Wareham, MA 02576 Northeast Utilities Service Company P.O. Box 128 Waterford, CT 06385 O 4
Millstona Nuclerr Power Station i Units 1,2, and 3 Citizens Regulatory Commission Mr. B. D. Kenyon (Acting) ATTN: Ms. Susan Perry Luxton Chief Nuclear Officer - Millstone 180 Great Neck Road Northeast Nuclear Energy Company Waterford, CT 06385 P. O. Box 128 Waterford, CT 06385 The Honorable Terry Concannon Nuclear Energy Advisory Council Deborah Katz, President Room 4035 Citizens Awareness Network Legislative Office Building P.O. Box 83 Capitol Avenue Shelbume Falls, MA 03170 Hartford, CT 06106 < Joseph R. Egan, Esq. Mr. G. D. Hicks Egan & Associates, P.C. Director- Unit 3 2300 N Street, NW Northeast Nuclear Energy Company Washington, D.C. 20037 P. O. Box 128 Waterford, CT 06385 Mr. J. A. Price Director - Unit 2 John W. Beck, President Northeast Nuclear Energy Company Little Harbor Consultants, Inc. P. O. Box 128 Millstone -ITPOP Project Office Waterford, CT 06385 P. O. Box 0630 Niantic, CT 06375-0630 Attomey Nicholas J. Scobbo, Jr. s Ferriter, Scobbo, Caruso, Rodophele, PC i s Mr. Evan W. Woollacott 1 Beacon Street,11th Floor I Co-Chair Boston, MA 02108 Nuclear Energy Advisory Council . 128 Terry's Plain Road Mr. E. J. Harkness Simsbury, CT 06070 Director- Unit i Operations Northeast Nuclear Energy Company Mr. Daniel L Curry P. O. Box 128 Project Director Waterford, Connecticut 06385 Parsons Power Group Inc. 2675 Morgantown Road Reading, PA 19607 Mr. Don Schopfer Verification Team Manager Sargent & Lundy 55 E. Monroe Street Chicago, IL 60603 Mr. P. D. Hinnenkamp Director- Unit Operations Northeast Nuclear Energy Company P. O. Box 128 Waterford, CT 06385 0-
p %g\ UNITED STATES g NUCLEAR REGULATORY COMMISSION i o WASHINGTON, D.C. Roses gem SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REI ATED TO PROPOSED REVISION 19 TO THE NORTHEAST UTILITIES OUALITY ASSURANCE PROGRAM TOPICAL REPORT NORTHEAST NUCI FAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION. UNITS 1. 2. AND 3 DOCKET NOS. 50-245. 50-336. AND 50-423
1.0 INTRODUCTION
On June 10,1996, Northeast Nuclear Energy Company (NNECO) transmitted proposed Revision 19 to the Northeast Utilities Quality Assurance Program (NUQAP) Topical Report for NRC review and approval in accordance with 10 CFR 50.54(a)(3). As a result of requests for additional information by the NRC staff, significant organization changes, and the decision to permanently shut down the Haddam Neck Plant, NNECO amended its original submittal by O correspondence dated February 20,1997 (Reference 4), June 3,1997 (Reference 5), August 7, 1997 (Reference 6), November 25,1997 (Reference 8), January 29,1998 (Reference 9), April 6, 1998 (Reference 11), and June 9,1998 (Reference 12). The proposed Revision 19 to the NUQAP submitted on June 3,1997, superseded the original (Reference 1) in its entirety.
2.0 BACKGROUND
in its proposed Revision 19 to the NUQAP, dated June 3,1997, NNECO identified six new exceptions (three of which were previously approved by the NRC by Technical Specification amenc'ments) to previous quality assurance (QA) program description commitments, i.e, reductions in commitment pursuant to Section 50.54(a)(3), and several changes in the following categories: Deletion of all reference to Connecticut Yankee (Haddam Neck Plant) and its operating company, Connecticut Yankee Atomic Power Company, e identification of the Millstone Power Station Organization responsible for quality activities Deletion of information/ reference to construction and pre-operational phases throughout l ' the NUQAP, and L = Editorial consistency. I O 4 L__-__-__-___--.
- 2.1 Summant of Pmoosed NUQAP Chanoes Not involvino QA Prooram Exceotions to NRC-Er dorsed American National Standards Institute (ANSI) Standards or Raou!storv Guides (BGal
- 1. Applicable program responsibilities previously assigned to Northeast Utilities Service Company / Nuclear Plant Operating Companies are now assigned to NNECO and reference
' is made to the " Millstone Power Station,"" Millstone Station," or " Station" as necessary for program deondion in the operations phase.
- 2. The NU Nuclear Organization for Millstone Power Station indicating the new organization names and titles are identified. For example, " Quality and Assessment Services" has been changed to the " Nuclear Oversight,"
- Director - Quality and Assessment Services" to "Vice President - Nuclear Oversight"; " Procurement Quality Services" to " Nuclear Materials and Document Management"; and the " Executive Vice President - Nuclear" to " President and Chief Executive Officer - NU Nuclear Group."
- 3. The role of the Yankee Atomic Electric Company as contracted to Nuclear Materials and Document Management for the offsite auditing, surveillance, ar;d inspection of vendors is identified.
- 4. The responsibilities of Nuclear Materials and Document Management and Nuclear Oversight for verifyin0 onsite and offsite vendor activities is clarified and the performance of audits, surveillance, and inspections is described as being performed "as appropriate" to indicate that the appropriate type and number of independent verification mechanisms are used to verify compliance with requirements and to make it consistent within the NUQAP.
- 5. The term " Quality Activities" was redefined and substituted for recurring words (e.g.,
i design, construction, testing, operation, refueling, maintenance, and modification) since j these activities are included in this new definition. ' 2.2 Summarv of Pronosed NUQAP Chanoes involvina QA Prooram Excentions to NRC-Endorsed ANSI Standards or RGs
- 1. ANSI N18.1-1971. paragraph 4.2.2, states, in part, "The Operations Manager shall hold a
, Senior Reactor Operator's license." NU has developed an attemative to this requirement, ! which has been accepted by the NRC by 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.
- 2. ANSI N18.1-1g71. paragraph 4.2.2, states, in part, "The Operations Manager shall hold a Senior Reactor Operator's license." NU has developed an altamative to this requirement, .
which has been accepted by the NRC by Amendment 190 for the Millstone Power Station Unit No. 2 iicense, which allows that: O 1-
t 3-if the Operatens 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 i serving in the capacity of the Assistant Operations Manager shall hold a Senior Reactor Operator license for Millstone Unit No. 2. l 3. ANSI N18.1-1971. paragraph 4.2.2, states, in part, "The Operations Manager shall hold a Senior Reactor Operator's license." NU has developed an altemative to this requirement, which has been accepted by the NRC by Amendment 83 for the Millstone Power Station, Unit No.1, bconse, which allows that: If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No.1, then the Operations Manager shall have held a Senior Reactor Operator license at a boiling water reactor, and the Assistant Operations Manager shall hold a Senior Reactor Operator licanse for Millstone Unit No. 1.
- 4. ANSI N45.2.13-1976 - NNECO is taking exception to the provisions in the ANSI standard l l for performing an acceptance review for purchased engineering and consulting services l
I under 10 CFR Part 50, Appendix B. In order to maintain independence of the vendors, NNECO will not perform an acceptance review of the work the vendors perfcrm for the independent Corrective Action Verification Program (ICAVP) requirement of the NRC's August 14,1996, Confirmatory Order. O 5. ANSI N45.2.3-1973 - Provisions for five Housekeeping Zones. NNECO has identified the ANSI Housekeeping Zone I as not being applicable to the Millstone units during their operations phase. In addition, as an altamative to the ANSI Zones 11 - V, NNECO has established a program for the Millstone units with a minimum of two housekeeping zones with foreign material exclusion procedures defining controls and countermeasures to meet ANSI Zones 11, Ill, IV, and V requirements.
- 6. Exception to NNECO's commitment to RG 1.70, Revision 3, November 1978. - RG 1.70, Revision 3, states that the preliminary safety analysis report (PSAR) should include a listing of QA program procedures or instructions that implement the QA program for each major activity and identify which criteria of Appendix B to 10 CFR Part 50 that are implemented by each procedure. In the past, the NUQAP Topical Report had contained this listing as Appendix C, " List of Typical Quality Assurance Related Procedures." Appendix C of the proposed Revision 19 no longer contains such a list. Indices currently maintained in accordance with QA program requirements identify the procedures that implement the QA program for Millstone Power Station and which, by title and originating organization, indicate the applicable 10 CFR Part 50, Appendix B criterion being implemented. This
. provides an attemative to maintaining a redundant list as an appendix in the NUQAP Topical Report.
3.0 EVALUATION Since QA program exceptions 1.3.1,1.3.2, and 1.3.3, above, have already received NRC approval as part of license amendments, this evaluation addresses ex,ceptions 1.3.4 though 1.3.6 only. These program exceptions constitute reductions in the licensee's QA program description commitments pursuant to Section 50.54(a)(3).
4 b 0 3.1 NUQAP F =h to Parmaraoh 10.3.5 of ANSI N45.2.13-1fr76 ANSI N45.2.13-1976, " Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants," paragraph 10.3.5., states, in part, in certain cases involving procurement of services only, such as third party inspection; engineering and consulting , services, and instaHatson, repair, ovsrhaul or maintenance work; the Purchaser may accept the l service by any or au of the following methods: l (a) Technical verification of the data produced l (b) Surveiuance and/or audit of the activity l (c) Review of the objective evidence for conformance to the procurement document l requirements such as certifications, stress reports, etc. l in order to maintain the independence requirement of the NRC's August 14,1996, Order (Reference 3), NNECO win not perform an acceptance review of the work produced by the vendors contracted to conduct the ICAVP. This work will be performed in accordance with the' l vendor's own NNEco-approved,10 CFR Part 50, Appendix B, Quality Assurance Program. l in an August 14,1996, Confirmatory Order to NNECO, the NRC directed the licensee 'To obtain the services of an organization, independent of the 1.icensee [ emphasis added) and its design contractors, to conduct a multi-disciplinary review of Millstone Units 1,2 , and 3. The review is to , provide independent verification that, for selected systems, the Licensee's CMP [ Configuration Management Program) has identified and resolved existing problems, documented and utilized licensing and design bases, and established programs, processes and procedures for effective O configuration management in the future." NNECO relies upon its commitment to the provisions in ANSI N45.2.13-1976 to satisfy the requirements of Criteria IV, " Procurement Document Control," of Appendix B to 10 CFR Part 50,
" Quality Assurance Criteria For Nuclear Power Plants and Fuel Reprocessing Plants."
The staff agrees that the licensee's exception to paragraph 10.3.5 of ANSI N45.2.13-1976, is a reasonable interpretation of the independence provision in the NRC Confirmatory Order. l Therefore, the staff concludes that NNECO's exception to the provisions in paragraph 10.3.5 of ANSI N45.2.13-1976 constitutes a temporary, acceptable attemative to such provisions and applicable only to the vendors carrying out the ICAVP pursuant to the NRC Confirmatory Order. l 3.2 NUQAP Exception to ANSI N45.2.3-1973. Subsection 2.1 ANSI N45.2.3-1973," Housekeeping During the Construction Phase of Nuclear Power Plants," Subsection 2.1, requires the establishment of five housekeeping zones. In its June 3,1997, letter NNECO proposed an altemative to this requirement that establishes for the Miustone units, as a minimum, a two-zone program to which ANSI Zones I through V requirements shau be applied as indicated below: ANSI Zone 1 requirements are not applicable to Minstone Station nuclear power plant operations and are therefore not applied; Millstone Station nuclear power plant foreign material exclusion (FME) O procedures include provisions for implementing controls and countermeasures
- i. -
[. l l b l I 5-that meet or exceed the ANSI Zone 11, lil, IV, and V requirements with the ! exception that west planning and the job supervisor shall determine when the I ANSI Zones 11 and ill logging requirements for material and personnel j accountability and clothing (i.e., gloves, shoe and head covering) are applied based upon retnevability and final inspection of the work performed. l Additionally, by letter dated January 29,1998, NNECO proposed to revise its previous exception to ANSI N45.2.31973, Subsection 2.1, in recognition that " construction type" activities could occur during the operations phase of a nuclear power plant. Accordingly, NNECO proposed a new attemative to the ANSI provisions that establishes for the Millstone units, as a minimum, a l two zone program to which ANSI Zones I through V requirements shall be applied as indicated-below: l Millstone Station nuclear power plant foreign material exclusion (FME) procedures include provisions for implementing controls and countermeasures that meet or exceed the ANSI Zone 1,11, Ill, IV, and V requirements with the exception that work planning and the job supervisor shall determine when the ANSI Zones I, il and ill logging requirements for material and personnel accountability and clothing (i.e., gloves, shoe and head covering) are applied based upon retrievability and final inspection of the work performed. l However, by letter dated June 9,1998, NNECO withdrew its proposed exception to ANSI N45.2.3-1973, Subsection 2.1. Therefore, Revision 19 to the NUQAP will continue to meet the provisions of ANSI N45.2.3-1973 with no exceptions. This is acceptable. ! O 3.3 NUQAP F-- =hr, to Serdian 17.1.2.4 of Reaulatorv Guide 1.70 Revision 3 (November 19ZE) Regulatory 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 l the QA pro 0 ram for each major activity such as design, procurement, 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 l that identify the procedures that implement the Quality Assurance Program for Millstone Power l' Station and which by title and originating organization, indicate the Appendix B to 10 CFR Part 50 criterion being implemented. This provides an attomative to maintaining a redundant list as an appendix in the NUQAP Topical Report. > Section 17.1, " Quality Assurance During The Design and Construction," of NUREG-75/087, )
"USNRC Standard Review Plan," (SRP), dated November 24,1975, states, on page 17.1-7, i paragraph 9, that the [ applicant's) Quality Assurance Program description is acceptable, in part, if i
"[a] listing of the QA procedures plus a matrix of these procedures cross referenced to each !
criterion of Appendoc B to 10 CFR Part 50 demonstrates that Appendix B provisions are fully implemented by documented procedures." Section 17.1 of the SRP provides the staff's acceptance criteria on this subject for nuclear power plants in the design and construction phase. O i l
4 6-O in Revision 1 to Section 17.1 of the SRP, provisions related to this area of QA program acceptance were modified as follows: " Existing or proposed QA procedures are identified -l reflecting that each criterion of 10 CFR 50 Appendix B will be met by documented procedure." (Page 17.1-9 Paragraph 2B4). Subsequently, in Revision 2 of the SRP (July 1982), these provisions were modified to read: " Existing or proposed QA procedures are identified reflecting that Regulatory Guides listed in subsection VI, General Design Criterion 1 of Appendix A to 10 CFR 50,10 CFR Part. 50, $50.55a, and each criterion of 10 CFR Part 50, Appendix B will be met , by documented procedures. In addition, activities conducted under 10 CFR Part 50, 650.55(e) l shall conform to the requirements of the QA program." Section 17.2, " Quality Assurance During the Operations Phase," Revision 2 (July 1981), endorses Section 17.1 of the SRP with respect to QA program acceptance in this area. Since the inclusion of a # sting of QA program procedures, or instructions that will be used to implement j the QA program, is not a pre-requisite for QA program acceptance in Section 17.2 of the SRP, NNECO's proposalis an acceptable attemative to Section 17.1.2.4 of RG 1.70.
4.0 CONCLUSION
While NNECO's proposed QA program exceptions described above constitute reductions in commitments in the QA program description previously approved by the NRC, such exceptions continue to satisfy the provisions in the applicable ANSI standard and/or Regulatory Guides in accordance with Section 17.2 of the SRP. Therefore, proposed Revision 19 to NNECO's ; NUQAP Topical Report, dated June 3,1997, and as amended through June 9,1998, continues to comply with the quality assurance criteria of Appendix B to 10 CFR Part 50 and is acceptable. O' However, NNECO's exception to the provisions in paragraph 10.3.5 of ANSI N45.2.13-1976 constitutes a temporarv. acceptable altamative to such provisions and applicable only to the vendors canying out the ICAVP pursuant to the NRC Confirmatory Order.
5.0 REFERENCES
- 1. T.C. Feigenbaum letter to the NRC, "Haddam Neck Plan, Millstone Nuclear Power Station, Units 1,2, and 3; Annual Reporting of Changes to the Quality Assurance Program; Proposed Revision 19 to the Northeast Utilities Quality Assurance Program Topical Report,"
dated June 10,1996
- 2. USNRC Letter to the Northeast Nuclear Energy Company, "10 CFR 50.54 Quality Assurance Program Change," dated August 7,1996
- 3. USNRC Letter to NNECO, " Confirmatory Order Establishing independent Corrective Action Verification Program (Effective immediately)- Millstone Nuclear Power Station, Units 1,2, and 3," dated August 14,1996
- 4. D.M. Goebel and T.C. Feigenbaum letter to the NRC, "Haddam Neck Plant Quality Assurance Program," dated February 20,1997
- 5. B.D. Kenyon letter to the USNRC, " Millstone Nuclear Power Station Units 1,2, and 3 -
l Annual Reporting of Changes to the Quality Assurance Program, Proposed Revision 19 to the Northeast Utilities Quality Assurance Program Topical Report - Millstone Nuclear Power Station," dated June 3,1997 O
. )
-7
- 6. B.D. Kenyon letter to the USNRC, " Millstone Nuclear Power Station Units 1,2, and 3 -
Annual Reporting of Changes to the Quality Assurance Program, Correction to Proposed Revision 19 to the Northeast Utilities Quality Assurance Prooram Tonical Reoort - Miffstone Nuclear Power Station." dated August 7,1997
- 7. USNRC Letter to NNECO, " Millstone Nuclear Power Station, Units 1,2, and 3 - Request for Additional information Regarding Proposed Revision 19 to the Northeast Utilities Quality Assurance Program Topical Repod," dated October 3,1997
- 8. B.D. Kenyon letter to the USNRC, " Millstone Nuclear Power Station, Units 1,2, and 3 -
AdditionalInformation Regarding Proposed Revision 19 to the Northeast Utilities Quality Assurance Prooram Tonical Report." dated November 25,1997
- 9. B.D. Kenyon letter to USNRC, " Millstone Nuclear Power Station Units 1,2, and 3 - Change to Proposed Revision 19 to the Northeast Utilities Quality Assurance Prooram (NUQAP)
Tonical Reoort." dated January 29,1998
- 10. USNRC Letter to NNECO,
- Request for Ad.1itional Information Regarding Revision 19 to the Northeast Utilities Quality Assurance Program, Millstone Nuclear Power Station, Units 1,2, and 3 (TAC NOs. M95739, M95740, and M95741)," dated March 13,1998
- 11. B.D. Kenyon letter to USNRC, " Millstone Nuclear Power Station Units 1,2, and 3 -
AdditionalInformation Regarding Proposed Revision 19 to the Northeast Utilities Quality Assurance Proaram Toolcal Reoort." dated April 6,1998 D
- 12. B.D. Kenyon letter to USNRC, " Millstone Nuclear Power Station Units 1,2, and 3 - '
Additional Information Regarding Proposed Revision 19 to the Northeast Utilities Quality Assurance Prooram Toolcal Reoort." dated June 9,1998 Principal Contributor: J. Peralta Dated: June 24, 1998 I i E- _ - - _ - - - - - - - - - - - - - - - - - -
h O Docket Nos. 50-245_ 50-336 50423 B16494
,e :.
Attachment 2 f 1 Millstone Nuclear Power Station, Units 1,2, and 3 Annual Reporting of Changes to the Quality Assurance Program Proposed Revision 19 to the Northeast Utilities Quality Assurance Program Topical Report - Millstone Nuclear Power Station Summary of Changes in Revision 19 0 O e 9e
*O e
9 e. L
U.S. Nuclear Regulatory CGi . ' :':-,
' 816494 \ Anschment 2 \ Page 1 Summary of Channes in Revision 19 GENERAL This summary identifies changes to NUQAP Revision'18 through Change 2 fohwhich NU has received NRC approval. The program changes of Revision 1g have been developed to:
e Make this NUQAP applicable to only Millstone Power Station by excluding all reference to _ Connecticut Yankee (Haddam Neck Plant) and its operating company, Connecticut Yankee Atomic Power Company (CYAPCO); . e identify the Millstone Power Station Organization responsible for quality activities; e Delete information/ reference to construction and pre-operational phases throughout; e Achieve more editorial consistency throughout. To facilitate NRC review, the changes except for typographical errors and minor editorial changes are represented in bolditalics. The changes and deletions are described below. DESCRIPTION OF GENERAL CHANGES MADE THROUGHOUT THE NUGAP
- 1. ' Applicable program responsibilities previously assigned to Northeast Utilities Service l g Company (NUSCO)/ Nuclear Plant Operating Companies (NUPOC) are now assigned to Northeast Nuclear Energy Company (NNECO) and reference is made to the " Millstone Power Station *,
- Millstone Station *, or
- Station" as necessary for program description in the operations phase.
- 2. The NU Nuclear Organization for Millstone Power Station indicating the new organization f names and titles are identified. For example,
- Quality and Assessment Services' has been l
changed to the " Nuclear Oversight"; " Director - Quality and Assessment Services" to "Vice , President - Nuclear Oversight"; " Procurement Quality Services" to " Nuclear Materials and Document Management", and the " Executive Vice President - Nuclear" to " President and Chief Executive Officer - NU Nuclear Group".
- 3. The role of the Yankee Atomic Electric Company (YAEC) as contracted to Nuclear Materials l and Document Management (NMDM) for the offsite auditing, surveillance, and inspection of vendors is identified.
- 4. The responsibilities of Nuclear Materials and Document Management and Nuclear Oversight
_ , , (or verifying onsite and offsite vendor activities is clarified and the performance of audits,
- surveillance, and inspections is described as being performed "as appropriate" to indicate that the appropriate type and number of independent verification mechanisms are used to verify compliance with requirements and to make consistent within the NUQAP. For example, revised wording in QAP 6.2.4 is:
"The Nuclear Oversight Department performs audits, surveillance, and inspections, as appropriate, of NUSCO/NNECO Departments and onsite vendors utilized to perform quality activities to verify they are effectively complying with this NUQAP and the vendor
U.S. Nuclear Regulatory Commission B16494 \ Attachment 2 \ Page 2 b Q quality assurance program requirements, respectively, for control of procedures and instructions." I Similar wording revision was made relating to the performance of offsite. vendor audits, surveillance, and inspections.
- 5. The term ' Quality Activities
- was redefined and substituted for recurring words, (e.g.,
design, construction, testing, operation, refueling, maintenance and modification) since these I activities are included in this new definition.
- 6. Other global editorial changes include:
i e Defined and used
- vendor" for engineer-constructors, contractors, suppliers, engineering l service organizations, etc.; for example, the phrase " engineer-constructors, contractors, suppliers and engineering service organizations utilized by NUSCO/NUPOC in the design, construction, testing, operation, maintenance, and modification to ensure" was i
changed to
- vendors utilized to perform quality activities for the Station nuclear power i
plants"; ( e Deleted words used to describe procedures, (e.g., " documented *, " approved *,
" implementing", and
- established") which are redundant to the term
- procedure" as described in the NUQAP and used the word
- applicable" where necessary; e Deleted reference to the construction and pre-operational phases terminology (e.g., the term
- Engineer-Constructor" was deleted from the NUQAP text and from the " Glossary of Terms *) to reflect the current
- operating
- status of the Millstone Station nuclear power plants; e Referred to the NUQAP Topical Report as the "NUQAP";
r
. Used " purchase order / contract
- vice " procurement documents
- where more appropriate; I
e included the title of the QAP Section number referenced in other QAP Sections;
- Substituted " fabrication" and " fabricated" for
- manufacturing
- and ' manufactured";
e Changed " Project Engineer" to
- Responsible Engineer";
e Added "ANSl* and *lEEE" as applicable before " standards" when relating to program l commitments, where applicable.
'D SCRIPTION OF OTHER CHANGES BY NUQAP TOPICAL REPORT SECTION TABLE OF CONTENTS e Deleted Revision 18 Appendix C," List of Typical Quality Assurance Related Procedures" and re-letter existing Revision 18 Appendices D, E, and F to C, D, and E, respectively (Basis for Appendix C deletion is provided in new Program Exception 13);
l
. - - - - - -- - - - - - - - - - - - - - ~- -~
l U.S. Nuclear Regulatory Commesion B16494 \ Attachment 2 \ Page 3 e Added *lEEE" to Revision 1g Appendix C list of applicable standards due to addition of new Regulatory Guide 1.152 endorsed IEEE standard. l- ABpTRACT I e Paragraph 1: Added " fabrication" and " refueling" activities to make consistent with QAP 2.0 1 verbiage; e Paragraph 4: Revised to correspond to wording of paragraph 3 of the Policy Statement. ' POLICY STATEMENT e Paragraph 1: Added new first sentence on quality assurance objectives, added " fabrication",
. and
- refueling
- sctivities to make consistent with QAP 2.0 verbiage; e Paragraph 2: Deleted words "which are referenced herein* since Revision 18 Appendix C, I
- List of Typical Quality Assurance Related Procedures" has been deleted from this revision (Basis for Appendix C deletion is provided in new Program Exception 13);
e Paragraph 3: Revised NUQAP applicability statement to more closely align with 10 CFR 50 Appendix B terminology; clarified applicability to materials, equipment, parts, consumables, . and services designated as " Category I"; and changed " Environmental Equipment Qualification" to " Electrical Equipment Qualification"; e Paragraph 4: Revised to identify President and Chief Executive Officer - NU Nuclear Group and Vice President - Nuclear Oversight for NUQAP responsibihties; added Recovery Officers as.having responsibility for implementing their portion of the NUQAP to reflect current recovery organization. INTRODUCTION e Paragraph 1, item 2: Revised to correspond to the applicable words in paragraph 3 of the Policy Statement. NUQAP 1.0 - ORGANIZATION Sections 1.1 - INTRODUCTION
- Revised to contain organizational information necessary for Millstone Power Station QA Rrogram description.
Section 1.2 - GENERAL . e Section 1.2.1: Deleted; no longer applicable to Millstone Power Station organization; L O e Section 1.2.2: Re-numbered to 1.2.1 and revised to describe President and CEO responsibility for the Millstone Power Station NUQAP and identify that QA Program responsibilities are identified in Nuclear Group Procedures; j
O U.S. Nuclear Regulatory Commession B16494 \ Attachment 2 \ Page 4
. Section 1.2.2.1: Re-numbered to 1.2.1.1, edited and combined into single paragraph:
. Section 1.2.2.2: Re-numbered to 1.2.1.2 and revised to remove unnecessary detail which is provided in QAP 2.0;
- New Section 1.2.1.3: Added words that the President and CEO resolves all NUQAP implementation issues not resolved at lower levels of the nuclear organization; e Section 1.2.2.3: Deleted; information redundant to information contained in new Section 1.4; e Section 1.2.3: Deleted this organizationalinformation as not necessary to be described in the NUQAP for Millstone Power Station since, as stated in the section, these services are provided as requested by the Nuclear Group in support of quality activities.
Section 1.3 - RESPONSIBILITIES
- Section 1.3.3: Added words to clearly state that personnel performing or verifying activities affecting quality shall have direct access to such management as necessary to perform this function as required by 10 CFR 50, Appendix B; O e New Section 1.3.5: Added words that vendors may be delegated QA functions to correspond to verbiage contained in QAP 2.0.
Section 1.4 - PARTICIPATING GROUPS - MILLSTONE POWER STATION e Changed to
- PARTICIPATING GROUPS - MILLSTONE POWER STATION" and rewritten to reflect new organization for Millstone Power Station; assigned applicable responsibilities and functions Nuclear Oversight, who now fulfills this role.
of the QAS Director in Revision 18 Sections 1.3.1 and 1.4.6 to the Vice President - Section 1.5 - OTHER NU PARTICIPATING GROUPS e Deleted description of these NU Groups as not necessary to be described in the NUQAP for Millstone Power Station since, as stated in this Revision 18 section, these services are provided as requested by the Nuclear Group in support of quality activities. Organization Chart. Floures 1.1 - 1.6
,_ Revised gures to reflect the Millstone Power Station Organization.
NUQAP 2.0'- QUALITY ASSURANCE PROGRAM ' Section 2.1 - General Requirements
. Paragraph 1: Revised to identify that exceptions to Revision 19 Appendix C are included in Revision 19 Appendix E; deleted last sentence as redundant to the two new NUQAP applicability paragraphs 3 and 4 described below;
l U.S. Nucisar Regulatory Commission B16494 \ Attachment 2 \ Page 5
. Paragraph 2: Revised to reflect NUQAP applicability as stated in the NUQAP Policy Statement;
{ l e Added new paragraph 3 to reflect NUQAP applicability to other quality programs as stated in the NUQAP Policy Statement; e Added new paragraph 4 to identify the Materials, Equipment, and Parts List (MEPL) Prograr.1 provides instructions to identify safety-related or augmented quality items and activitie::; e Paragraph 7: Edited and added " examination results* as an example training results , sessions that are documented "as applicable"; e Paragraph 8: Edited to clearly distinguish between Nuclear Oversight audits, surveillance, and inspections and NSAB review's; changed " audit" team to " review" team since this review ) is not an " audit" as described in the NUQAP; added words ' annual NUQAP Management l Review" to clearly define the source of the annual program review; and substituted *been delegated' for " designated" to be consistent with 10 CFR 50, Appendix B terminology relating to delegation of quality functions to vendors. Section 2.2.1 - Goats and Objectives
\
e Paragraph 1: Deleted unnecessary reference to the NUQAP Policy Statement: ' O + item c: Changed
- responsible" to " qualified" as requisite to perform quality activities; e Item e: Deleted item as unnecessary as a program goal since it is evident that poor quality 1 causes schedule delays and high costs due to rework.
Section 2.2.2 - Proaram Documentation ' l e Paragraph 4: Clarified that the departments which implement part of a procedure initiated by another department coricur with the procedure; deleted reference to Revision 18 Appendix C which has been deleted with this revision (Basis for Appendix C deletion is provided in new Program Exception 13), and identified that Nuclear Oversight reviews other department quality procedures as defined in QAP 5.0; e Paragraph 5: Clarifies that the Vice Presidents, Recovery Officers, and Directors as responsible for NUQAP implementation to be consistent with previous NUQAP verbiage. Section 2.2.3 - Structures. Systems. and Components
~ Paragraph 1: Made minor editorial changes; changed ' safety" to " safety-related" to make consistent with the Policy Statement; .-
Section 2.2.4 - Particioatina Organizations e Paragraph 2, item a): Clarified that Nuclear Oversight has " administrative" control of the NUQAP Topical Report; L ___ __ . _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ._ - - -.
U.S. Nuclear Regulatory Commission i B16494 \ Attachment 2 \ Page 6 0 Paragraph 2, item b): Clarified that Nuclear Oversight is responsible for assuring issuance of the NUCAP since it does not make actual distribution; e Paragraph 3: Added the word " approved
- before vendors to clarify the context of the paragraph as pertaining to
- approved" vendors; i.
- Paragraph 5: Added words to indicate that Yankee Atomic Electric Company (YAEC) has been contracted to perform the vendor audit function; e Paragraph 6: Added second sentence to indicate vendors can be contracted to perform work under their QA Program or directly under this NUQAP.
l Section 2.2.5 - Indoctrination and Trainino e Paragraph 1: Changed " Nuclear Oversight Department" to "esch NUSCO/NNECO Department" which includes the Nuclear Oversight Department as responsible for assuring training of personnel; l
. Paragraph 3, item a: Deleted
- implementing NUSCO/NNECO' as redundant with the
)
previous paragraph; j e Paragraph 3, item a: Added " examination results* as an example of "results* that are documented;
)
- Paragraph 4: Deleted *(including Quality and Assessment Services)* since Nuclear Oversight is included in
- Departments
- as defined in the NUQAP.
Section 2 2.6 - Manacement Participation
- e Paragraph 1
- Edited to indicate Vice Presidents, Recovery Officers, and Directors are i
responsible for these activities in their organizations; l - e Paragraph 2: Deleted the word " audit" since the review is not an audit as described in this l' NUQAP but a " review" performed in accordance with a Nuclear Group Procedure; changed l " group" to
- team
- to be consistent with QAP 1.0; i
e Paragraph 5: Clarified that the vendor management reviews their Quality Assurance Program and not this NUQAP. OAP 3.0 DESIGN CONTROL: Section 3.1 - General Requirements .
. Paragraph 1: Changed to reflect the Director - Engineering as having this responsibility; moved to be new paragraph 2 to be consistent with other NUQAP Sections;
- Paragraph 2: Changed to be new paragraph 1 and added word " quality" before structures, systems, and components to be consistent within QAP 3.0;
. U.S. Nucie:r Regulatory Corr. mission 816494 \ Attachrnent 21Page 7 e Paragraph 3: Revised to indicate that the administration of the design control program lies
)
! (A with Engineering Programs, that jurisdictional boundaries for design control program implementation'is set forth in Nuclear Group Procedures, and that the Unit Director - Engineering retains responsibility for program implementation for the unit. Seetion 3.2 - Implementation 2:
- Paragraph 1: Revised to indicate that the Director - Engineering of each nuclear unit is responsible for final engineering decisions and design control for the unit; combined last two '
sentences to remove redundancy. Section 3 2.1 - Desian Process e Paragraph 2: Added ' Procedure and" before " instructions" in the third sentence to make consistent with remainder of QAP 3.0; deleted "All" before " materials" in the fourth sentence as redundant to items " essential" to the quality function; e Paragraph 4: Deleted " plant" and "in-service' as redundant. I I Section 3.2.2 - Desian Chanoe Control e Paragraph 1: Edited to clarify sentence 1; added "as amended by applicable design or licensing basis changes" to last sentence to clearly define this configuration management requirement; O e Paragraph 2: Clarified to indicate NNECO can perform this review, e Paragraph 3: Deleted reference to the " Environmental Review Board" and its review of
" environmental questions" since this board no longer exists (This function is now performed by Environmental Services - Nuclear as defined in procedures); clarifed that NSAB reviews safety evaluations associated with design changes and not all design changes as could be inferred by current wording; added words to indicate that NRC review and license amendment issue are necessary for implementation of a proposed design change with an unreviewed safety question to preclude potential inference that the NSAB has final authority for implementation; e Last Paragraph: Added words to indicate notification is also made prior to implementation.
Section 3.2.3 - Desian Interface Control l i e Paragraphs 1 and 2: Deleted since these were related to pre-operational phase; i T Paragraph 3: Revised to indicate that design interface controls for modifications are provided through procedures and instructions. I Sectior 3.2.4 - Independent Desion Verification i O e Paragraph 1: Added wording from approved Revision 1g Program Exception 4 to indicate when an originator's supervisor may perform the independent design review to clearly identify
U.S. Nuclear R:gulatory Commession B16494 t Anschment 2iPage 8 these requirements in this section; revised to indicate the unit Director-Engineering as responsible for design adequacy;
- Paragraph Station; 3: Deleted *NUSCO/NUPOC'; this is a NNECO responsibility for Millstone Power 99 e Last Paragraph: Changed 'NUSCO* to *NNECO' and Edded the words "for the Station nuclear power plants"; changed " adequately generated" to ' technically correct" to clarify this requirement.
4.0 - PROCUREMENT DOCUMENT CONTROL Section 4.1 - General Requirements e Paragraph 1: Edited first sentence to make wording more consistent with other QAP
' General Requirements
- sections.
Section 4.2.1 - Prooram
. Paragraph 2: Deleted "NUSCO/NUPOC'; changed " purchase requisitions" to " requests for materials, equipment, parts, and services" in sentence 1 since purchasing is initiated by Material Requests using the Material Information and Management System (MIMS); clarified the procurement engineering function; added clarification that once material technical and quality requirements are in MIMS, additional procurement engineering evaluations are not required;
{ e Paragraph 5: Revised first sentence to make consistent with the rest of QAP 4.0 with respect to the
- procurement engineering";
- Paragraph 5, new subparagraph a: Changed to " adequate technical requirements are specified" to be consistent with similar words in QAP 4.0, and re-lettered existing '
subparagraphs "a* and *b" to *b' and *c", respectively; e Original paragraph 5, subparagraph c: Deleted since preparation, review, and approval of a
" Material Request" to meet NUQAP requirements is automated through the MIMS approval process and the other determinations identified in the section ensure that the technical and quality assurance requirements are met.
Sggion 4.2.3 - Selection of Procurement Sources e P,aragrapE 1: Revised to more clearly reflect how procurement sources are selected in the
' current operations environment, to better reflect the ANSI N45.2.13-1976 wording, and to reflect that approvals leading to a purchase order issue is an automated process under the Materials information Management System (MIMS);
i
- Paragraph 3: Added words to indicate acceptance inspections and tests are to be performed !
O prior to
- installation in the plant or prior to the point when the installation is declared operational" to clarify the requirement and make consister.1 with similar wording in the QAP 3.2.4.
i l
U.S. Nude:r Regulatory Commission B16494 \ Attachment 2iPage 9 5.0- PROCEDURES. INSTRUCTIONS. AND DRAWINGS Section 5.2 - Implementation v e , Sentence 1: Deleted "such as those listed in Appendix C* (since the Revision 18 Appendix C identified is deleted with this revision with its basis for deletion is provided in new Program Exception 13); added words *other department" quality procedures *which implement this NUQAP as described in Section 5.2.1 below". Although this revision deletes Revision 18, Appendix C, it does not delete the requirement for identification and Nuclear Oversight review of existing quality procedures and any new/ revised quality procedures developed to implement the program as currently required under existing guidance documents.
- Sentence 3:
Deleted wording that Nuclear Oversight receives controlled copies of quality procedures such as those listed in Revision 18 Appendix C as unnecessary for describing program requirements for procedure review by Nuclear Oversight and to reflect establishment of controlled document libraries at the site. Section 5.21 - Procedures and Instructions e Paragraph 2: Changed the
- Director of Maintenance Services" to
- cognizant Director" since any Director can contract for quality services; O
\j e Paragraph 3: Changed NUPOC to *NNECO' and " plant" to
- Millstone Power Station and Nuclear Unit' to reflect NUQAP applicability to Millstone Power Station only; deleted "such as those listed in Appendix C" when referring to procedures reviewed and concurred with by Nuclear Oversight since this appendix is being deleted in Revision 1g (Basis for Appendix C deletion is provided in new Program Exception 13); added wording to describe that program requirements for procedures requiring Nuclear Oversight review and their identification are contained in quality procedures:
*The criteria for documents requiring Nuclear Oversight review and concurrence and their identification are defined in quality procedures to assure: l 1
- 1. Administrative procedures and manuals comply with this NUQAP and applicable l Appendix C regulatory guides and endorsed ANSI /IEEE standards. I
- 2. Work procedures and work documents used to perform quality activities have the necessaiy quality assurance controls as described in QAP 10.0, " Inspection".
Section 5.2:2 - Drawinos
,~ ,
e Paragraph 1, sentence: Revised the second sentence to removo unnecessary specificity regarding supervisory review which is specified in proceduros und to read:
- Review and approval of new drawings and modifications to existing drawings are described in NNECO procedures".
O
-- --_-_--- --_--,----.______---s_- - - - - _ - - - - - - - - _ _ - - - - - - - - - - - - - - - - - - - - - - - - - _ _ - -- -- - - - - - - - - . _ - - - - --.
I U.S. Nuclear Regulatory Commission B16494 \ Attachment 2 \ Page 10
.j O .
1;..; tic,,,5.2 3 - Accentance Criteria I e Last Paragraph: Changed the examples of activities to which acceptance criteria were applicable to more general " applicable quality activities". :: l 6.5 - DOCUMENT CONTROL l Section 6.1 - General Requirements e Paragraph 1: Deleted reference to 10 CFR 50, Appendix B as redundant to Revision 1g Appendix C which identifies 10 CFR 50, Appendix B as a program commitment. Section 6.2.1 '- Responsibility l e Paragraph 1: Added new items "g. Calculations"; *h. Engineering Record Correspondence";
"l. Design. Basis Documentation (DBD)" and re-lettered existing items "g" *l" to "j' "o';
changed " requests" to " records" in new item *l.*(old "j'). i l Section 7.0 - CONTROL OF PURCHASED MATERIAL. EQUIPMENT AND SERVICES Section 7.1 - General Requirements e Edited to be more consistent with other
- General Requirements" sections.
l Section 7.2 - Implementation
- Paragraph 1: Deleted as unnecessary with the description of
- supplier" and " vendor" as L
synonymous and identified as such in the Glossary Of Terms. Section 7.21 - Vendor Qualifications l ' e Paragraph 2: Deleted *NU" and added "providing quality material, equipment, parts, and services
- to clarify the purpose of the evaluation;
- Paragraph 3, sentence 1: Changed " maintains
- to 'is responsible for ensuring that L " documented evidence .... is maintained" to reflect contracting of vendor audit function to L Yankee Atomic Electric Company (YAEC) and retention of such records by YAEC.
Section 7.2.5 - Source Inspection e New paragraph 4: Added to identify the vendor source inspection has 'oeen contracted to Yankee Atomic Electric Company (YAEC).
U.S. Nudeer Regulatory Commesen B16494 \ Attachment 2 \ Page 11 Section 7.2.3 - Receipt insoection e Paragraph 1, Sentence 2: Added gas turbine fuel and Millstone Power Station Unit No. 3 bulk hydrogen / nitrogen to Nuclear Materials and Document Management redeipt inspection exceptions;
- Paragraph 2, item b: Changed
- item" to " item's critical characteristics"; changed ' purchase" to
- procurement".
Section 7.2.4 - Vendor Fumished Records
. Paragraph 2: Added words "for nuclear grade purchases
- to clarify the applicability of documentation requirements;
- Paragraph 3: Added "and other appropriate department" to indicate other departments may be required to review such documentation as identified in the procurement documents; e Last paragraph: Changed " work observations" to " inspections" and added words "as appropriate to verify compliance with this requirement" to make consistent with other NUQAP wording relating to these oversight activities.
! 8.0-IDENTIFICATION AND CONTROL OF MATERIALS. PARTS. AND COMPONENTS 8.1 - General Requirements e Paragraph 1: Edited and made into paragraph 2;
- Paragraph 2: Changed to paragraph 1; changed
- equipment" to " parts
- to make paragraph wording consistent; deleted unnecessary reference to 10 CFR _50, Appendix B which is specified in Revision 1g Appendix C as a program commitment.
8.2 - Implementation
- Paragraph 1, items *a" and *d*: Changed " procurement documents" to " purchase orders, contracts" since these documents and others listed constitute " procurement documents" as defined in the NUQAP;
. Paragraphs 2, 3, and 4: Changed ' equipment" to " parts
- to make consistent with other
, etctions;
- Paragraph 3: Combined the last two sentences and deleted " permanent
- before
- identification
- and specific reference to serial number application as redundant to revised wording for applying the necessaryidentification in accordance with applicable procedures to O ensure proper identification and traceability,
U.S. Nuclear Regulatory Commission 816494 \ Attachment 2 iPage 12 9.0 - CONTROL OF SPECIAL PROCESSES 9 2.2 - Personnel Qualification and Certification e Changed *NUSCO/NUPOC* to
- Millstone Power Station NU" and added "for' assuring" sinc Auclear NDE personnel.
Oversight does not directly perform all required training for Millstone Power Stat 10.0 - INSPECTION 10.1 - General Requirements '
. Edited to make more consistent with other " General Requirements" sections; deleted "in accordance with the Quality Assurance Program (NUQAP)" as redundant.
10.2.1 - Inspection Responsibilities t e Paragraph 1, sentence 1: Deleted ' system tumover" as it relates to the pre-operational phase; added "to assure quality requirements are met" to clarify requirement for when ) !. inspection is required; ( e Paragraph 3: Clarified the Nuclear Oversight role in the inspection of maintenance and I modification activities and that the criteria for when such inspection is required and for the f' preparation of inspection plans shall be identified in Nuclear Oversight procedures;
. Paragraph 3; item b: Added "for adequacy of inspection and mandatory hold points" to reflect sir.Grwording in Section 10.2.5.
10 2.2 - Inspection Plans e Paragraph 3: Deleted as redundant to revised wording in QAP 10.0; e Paragraph 4: Changed ' Job Packages" to
- work procedures, work documents" for consistency in section wording.
10.2.3 - Insnection Personnel and Insoection Document Acess
. Deleted paragraph lettering for consistency with other sections of QAP 10.0 l e Paragraph.2', sentence 1: added " considerations" after " schedule";
E Naragraph 2, sentence 2: Changed to make consistent with 'QAP 7.0 and indicate departments other than Nuclear Oversight may contract for inspection services; to clearly define the responsibility for review of certification for acceptan' ce for contracted personnel l certifications; and to indicate that Nuclear Oversight will perform audits and surveillance as
- appropriate to verify compliance with requirements for assuring contracted personnel are properly certified; '
U.S. Nuclear R:gulatory Commission B16494 i Attachment 2 \ Page 13
- Add new paragraph 3: Added to clearly distinguish between the review of contracted personnet/ equipment certification and Nuclear Oversight review and concurrence with onsite vendor quality control inspection plans / procedures in accordance with QAP 5.0.
10 2.4 - Inspection Procedures .
- Deleted paragraph lettering and changed paragraph 1 numbering to lettering to make consistent with other sections of QAP 10.0.
10.2.5 - Mandatory Hold and Notification Points
- Added new sentence: ' Mandatory hold points are identified to ensure attributes critical to achieve quality requirements at work completion have been verified." to indicate general criteria for the use of mandatory hold points; e Clarified that Nuclear Materials and Document Management and Nuclear Oversight are responsible for the review and concurrence for adequacy of inspection for offsite and onsite activities.
11.0 - TEST CONTROL 11.1 - General Requirements e Paragraph 1: Deleted refarence to 10 CFR 50 Appendix B as redundant to Revision 1g Appendix C which identifies 10 CFR 50, Appendix B as a program commitment;
- Paragraph 3: Added " reworks" to include this in the maintenance activities following which retests are required, and added *as required to verify performance will be satisfactory during operation" to reiterate the purpose of the retest.
l 11.2.1 - Test Proaram
. Paragraph 1: Added " rework" and " preventive maintenance" and the words: *when required" to clarify that when retest is required it is performed in accordance with original design / acceptable attematives;
- Paragraph 1; new last sentence: Added to clarify and make consistent with
- Glossary of Terms" regarding retest when original test results are invalidated to the indicate that, for this situation, retest may or may not be required based upon evaluation of the condition and the need for retest;
~aParagraphs 3: Changed " observations" to
- verification activities" and added to last sentence, "until forwarded to the Station Nuclear Records Facility in. accordance with applicable procedures", to clarify that such records are ultimately transferred to Station Nuclear Records;
- Paragraph 4: Added to last sentence. *until forwarded to the Station Nuclear Records Facility in accordance 'with applicable procedures", to clarify that such records are ultimately transferred to Station Nuclear Records.
U.S. Nucle:r Regulatory Commission B16494 i Attachment 2 \ Page 14 O 11.2.2 - Test Procedure Preparation and Test Performance e Subparagraph d: Changed to read: " Hold, notification, and inspection points as required and data collection points" to clarify that not all these points are used in every test as implied by the words "as a minimum"in sentence 2 of paragraph 1. 11.2.3 - Test Eouiement
- Paragraphs 1 and 2: Deleted words relating to the operating phase and combined into new paragraph 1.
11.2.4 - Evaluation of Test Results e Paragraph 1 and 2: Changed " organization" to " vendor"; added *when delegated" to sentence 2. 12.0 - CONTROL OF MEASURING AND TESTING EQUIPMENI 12.1 - General Requirements 12 2.1 - Calibration Prooram (Added new Title) O e Paragraph 1: . Added word " temporarily" before installed fo clearly discriminate M&TE from permanently installed instrumentation used in testing which is " maintained in calibration at regular intervals in accordance with established surveillance and/or preventative maintenance procedures" as stated in QAP 11.2.3 b;
- Paragraph 2: Changed first sentence to qualify the doeurnentation retained; added program requirements when using information in electronic form; e Paragraph 3: Edited to indicate M&TE procedures are reviewed and approved by PORC/SORC or through the Station Qualified Reviewer Program as defined in applicable procedures, clarified that Nuclear Materials and Document Management or the appropriate M&TE Oura::dian as defined in the purchase order as responsible for verifying that calibrated equipment conforms to procurement documents;
- Paragraph 4: Edited and transferred PORC/SORC procedure review wording to paragraph 3; deleted last 2 sentences as redundant to the stated requirements for Department Heads / Job l . Supervisors being responsible to implement the M&TE program *in accordance with the i requirements of applicable procedures".
s. 52.2.2- Calibration Standards - I
- Paragraph 1: Changed last sentence to read:
- 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" to clarify the identification requirements; e Last paragraph: Edited and transferred to 12.2.1 - Program.
U.S. Nuclear Regulatory Commission ~ j B16494 \ Attachment 2 \ Page 15 LO 12.2.3 "Out of Tolerance" Control e Sentence 2: Added word ' timely" to indicate program requirements for timely review and resolution of the impact of M&TE found to be in this condition. " 13.0 - HANDLING. STORAGE. AND SHIPPING 13.1 - General Requirements j e Edited to be consistent with other " General Requirements" sections; deleted "in accordance with approved procedures, instructions, and procurement documents
- as redundant to wording of Section 13.2.1.
e 13.2.1 - General e Made minor editorial changes and included " General Changes" described above. l 14.0-INSPECTION. TEST. AND OPERATING STATUS 14.2.1 - General e Paragraph 2: Added nuclear fuel assemblies, diesel / gas turbine fuel, and bulk L,.' hydrogen / nitrogen as exceptions for which Nuclear Materials and Document Management is l not responsible for maintaining traceability of conformance to procurement requirements and l identifying responsible organizations. t 14.2 2 - Status identification and Control l l . Paragraph 1, last sentence: Changed to read: "The status o' all items requiring calibration is recorded and maintained in accordance with applicable procedures" to make more consistent with other NUQAP wording relating to calibration program requirements. 15.0 - NONCONFORMING MATERIALS. PARTS. COMPONENTS. OR SERVICES 15.1 - General Requirements l
. Edited to make consistent with other
- General Requirements" sections.
15.2.1 - Prooram
= Paragraph 1, sentence 2: Changed to include related wording in the " General Requirements" section and to indicate that the means to identify conditions adverse to qusMy at Millstone Power Station is available to all NU personnel and vendors assijned to the Station and other personnelinvolved with Station quality activities.
O o
U.S. Nuclear Regulatory Commission B18494 \ Anschment 2 \ Page 16 15.2.2 - Documentation e Paragraph 1, sentences 2 and 3: Deleted from this section, edited or transferred to new Section 15.2.4,
- Recurrence Control"; ;;.
. Paragraph 3: Edited and transferred this paragraph to Section 15.2.3 since these words are more appropriate in this section and are integral to the evaluation and disposition process.
15 2.3 - Evaluation and Disposition o Paragraph 1: Included engineering evaluation wording from Section 15.2.2; added words to indicate that nonconformances are evaluated for impact on quality structures, systems, and component operability in accordance with procedures;
- Paragraph 2, item c: Added ' condition" after " nonconforming".
New 15.2 4 - Recurrence Control e Established to extract trending requirements from Section 15.2.2 and clarify that trend analysis results documenting program / procedure problems are reported as part of the Station
' Corrective Action Program per QAP 16.0.
16 0 - CORRECTIVE ACTION 16.1 - General Requirements .
- Deleted "for NUSCO/NUPOC and their contractors
- as redundant to 16.2.1; added
- reporting to appropriate levels of management and" to the last sentence to reflect this 10 CFR 50, Appendix B requirement for significant conditions adverse to quality; added *sdverse to quality" after 'significant condition".
16.2.1 - Prooram e Sentence 1: Added *and correction" to include this activity in program requirements; i-
- Sentence 2: Changed to indicate that the means to identify conditions adverse to quality at Millstone Power Station is available to all NU personnel and vendors assigned to the station and other personnel involved with Station quality activities.
16.2.2 - Corrective Action and Follow-un Idded new sentence 2 to clearly indicate that the Vice. Presidents and Recovery Officers are responsible for the implementation of the corrective action program within their organization; changed *within NUSCO/NUPOC' to "of the nuclear organization". 16.2.3 - Recurrence Cor$[DI .
- Paragraph 3: Clarified that the trend analysis of adverse conditions is performed by the same organization having responsibility for controlling the problem reposting document.
U.S. Nuclear Regulatory Commission B16494 \ Attachment 2 \ Page 17 V 17.0- QUALITY ASSURANCE RECORDS 17.1 - General Requirements e Deleted last sentence as redundant to revised sentence 1 wording and revised wording in karagraph 1 of Section 17.2. 17.2 - Implementation '
- Paragraph 1: Added *(e.g., duration, location)" to sentence 1 to support deletion of same '
words from section 17.1; deleted *and instructions" to have consistent reference to
- procedures"in QAP 17.0;
- Paragraph 3, sentence 1: Added
- quality assurance" before " records".
17.3 - Retention !
- Paragraph 2: Added
- Quality assurance" before " records"; changed
- Plant Records" to i
- Document Services". t 18.0 - AUDITS '
l 18.1 - General Requirements
- Paragraph 1: Added *and to determine the effectiveness of the program" to reflect relevant 10 CFR 50, Appendix B wording; e Paragraph 2: Changed *and" to "or" to reflect 10 CFR 50, Appendix B wording.
18.2.1 - Proaram i e Paragraph 1: Added " Appendix B' after 10 CFR 50, changed " licensee" to "NNECO'; changed " function" to
- procurement function *;
- Paragraph 2: Clarified that Nuclear Oversight schedule responsibility pertains to Corporate, l Station, and onsite vendor audits; !
e Paragraph 3: Deleted the words ' preestablished written" in sentence 1 as redundant to " plan prepared by"; changed " Auditors evaluate" to " Audits may include evaluation of" the listed activities to indicate these are the type items included in an audit scope; Paragraph 4: Edited to more closely follow 10 CFR 50, Appendix B wording; added words that Yankee Atomic Electric Company has been contracted .to perform the vendor audit function. l O
7 .- l U.S. Nucdear Regulatory Commason
- 816494 t Attachment 2 iPage is 18.2 2 - Reportino of Audit Results e Changed to indicate audit results are reviewed, approved, and reported in accordance Nuclear Oversight or Yankee Atomic Electric Company procedures as' applicabit to distinguish between onsite and offsite vendor audits.
t 18 2.3 - Review of Audit Findinos and 18.2.4 - Resolution of Audit Findinos Edited and combined these sections into new Section 18.2.3,
- Review, Action, and Follow-Up of Audit Findings", to:
- l e Delete requirement for Nuclear Oversight to assign significance level to audit findings since i
audit findings are reported under the corrective action program document and the assignment of the significance level is the responsibility of the organization controlling the problem reporting document as established in quality procedures;
- Describe the audit report follow-up process in terms consistent with those in ANSI N45.2.12-1977, Section 4.5,
- Follow-up".
Aeoendix A - Cateoorv i Structures Systems and Comoonents
- New first paragraph: Added to repeat applicable QAP 2.0 wording identifying the Material, Equipment, and Parts List (MEPL) Program as providing instructions for identifying items as Category 1; e Paragraph 2: Edited to reflect 10 CFR 50, Appendix B wording; e Consumables List: Added bulk hydrogen and nitrogen to correspond to changes indicated in QAP 7.0.
Revision 18 Anoendix C - List of Tvolcal Quality A*surance Related Precedures
- Deleted this Appendix (Basis for deletion of Appendix C is described in new Program Exception 13) and re-lettered existing Revision 18 Appendices D, E, and F to C, D, and E, respectively.
Revision 10 Anoendix C - Raau!storv Guide and ANSI /IEEE Standard Commitments Revised Regulatory Guide 1.70 to reflect appropriate applicability to Millstone Power Station Unit No. 2 and delete reference to Connecticut Yankee; evised Regulatory Guide 1.152 to reflect the revision of the IEEE standard which will be applicable to the Millstone Power Station NUQAP for new modifications to digital computers in safety systems. O
U.S. Nudear Regulatory Commission 816494 \ Attachment 2 \ Page 19 Revision 19 Anoendix D - Glossary of Quality Assurance Terms Terms were added, revised / edited, or deleted as required to reflect conversion of the NUQAP applicability to Millstone Power Station only, to reflect Power Station operating: status, and to enhance program description consistency:
- Added Terms:
Approved Vendors Material Request Northeast Nuclear Energy Company (NNECO) Quality Structures Systems and Components Reportable item Responsible Engineer Vendors Work Procedures and Work Documents
. Revised / Edited Terms:
Augmented Quality Category l Category 1, Systems, Structures and Components Commercial Grade item (CGI) Department C Northeast Utilities ,i Northeast Utilities Service Company (NUSCO) k Northeast Utilities Quality Assurance Program (NUQAP) Nuclear Grade Procurement Documents Purchased Material, Equipment and Parts Purchased Services Quality Activities Retum to Supplier Safety Related Systems and Components Significant Condition Special Processes Surveillance
- QgjetedTerms:
Department Measuring and Test Equipment List l Design Phase / Operational Phase /Preoperational Phase Design Change Request (DCR) _- Engineer-Constructor l Nuclear Plant Operating Company (NUPOC) Operational Phase - Project / Plant Engineer Suppliers
' U.S. Nuclear Regulatory Commas;on B16494 \ Attachment 2iPage 20 /~N V Revision 19 Asser dix E - Presrern Exceptions
- Exception 1: Deleted reference to CYAPCO and associated amendment, changed 'two" to L *three" vaults for NNECO; e f*xception 3: Deleted word " appropriate";
i e Old Exception 7 to ANSI N45.2-1977: Deleted the exception to this standard regarding the audited organization not providing a follow up report as required by the standard; re-numbered Revision 18 exceptions 8, 9, and 10 to 7,8, and g, respectively; e Re-numbered Exception 7 to ANSI N18.1-1971: Revised to identify approved Unit 3 License l Amendment 132 and reflect applicable amendment wording; e Re-numbered Exception 8 to ANSI N18.1-1971: Revised to identify approved Unit 2 License Amendment 190 and reflect applicable amendment wording; e Re-numbered Exception 9 to Regulatory ~ Guide 1.33: Deleted reference to Connecticut Yankee (CY); deleted the last paragraph since Nuclear Oversight will perform the audit of the facility staff; e New Exception 10: Added to identify exception to ANSI N18.1-1971 and approved Unit 1 License Amendment 83 attemative to the requirement for the Operations Manager to hold a Senior Reactor Operator's License; _ e New Exception 11: Added exception to ANSI N45.2.13-1976 requirements' for NNECO accepting purchased services which will not be performed in order to maintain independence of the independent Corrective Action Verification Program requirement of the NRC's August 13,1996 Order; .
~
. New Exception 12: Added exception to ANSI N45.2.3-1973 requirement for five housekeeping zones. ' NNECO has identified the ANSI Housekeeping Zone I as not being applicable to Millstone Station nuclear power plants during their operations phase and has established a program with a minimum of two housekeeping zones with foreign material exclusion (FME) procedures defining controls and countermeasures to meet ANSI Zones ll, Ill,IV and V requirements.
- New EEception 13: Added exception to Regulatory Guide 1.70 Revision 3, November 1978 requirement that the PSAR include a listing of procedures or instructions that implement the QA Program for each major activity (such as design, procurement, construction, etc.)
together with the 10 CFR 50, Appendix B criteria implemented by each procedure. Indices
' identify procedures that implement the QA Program for Millstone Power Station and which, by title and originating organization, indicate the applicable Appendix B to 10 CFR 50 criterion being implemented. This provides an alternative to maintaining a list as an appendix in the NUQAP Topical Report.
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TABLE OF CONTENTS NORTHEAST UTILITIES OUALITY ASSURANCE PROGRAM (NUQAP) TOPICAL REPORT- MILLSTONE POWER STATION Table of Contents Abstract Policy Statement Introduction Quality Assurance Program QAP 1.0 Organization OAP 2.0 Quality Assurance Program QAP 0.0 Design Control QAP 4.0 Procurement Document Control QAP 5.0 Procedures, Instructions and Drawings OAP 6.0 Document Control QAP 7.0 Control of Purchased Material, Equipment and Services O OAP 8.0 identification and Control of Materials, Parts and Components OAP 9.0 Controlof SpecialProcesses QAP10.0 Inspection OAP11.0 Test Control QAP12.0 Control of Measuring and Testing Equipment QAP13.0 Handling, Storage, and Shipping QAP14.0 Inspection, Test, and Operating Status QAP15.0 Nonconforming Materials, Parts, Components, or Services QAP16.0 CorrectiveAction QAP17.0 Quality Assurance Records OAP18.0 Audits Appendices A. Category 1 Structures, Systems, and Components B. Qualification and Experience Requirements, Recovery Officer- l NuclearOversight C. Regulatory Guide and ANSI /IEEE Standard Commitments D. Glossaryof Quality AssuranceTerms E. Program Exceptions O QAP Table of Contents Rev.: 19 Change 01 Date: 7/15/98 Page 1 of1
ABSTRACT d 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 PowerStation 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 e 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-relatedfunctions of Q Q/ structures, systems, and components. components are functionally identified in Appendix A of this NUQAP and are Safety-Related structures, systems, and designated CategoryI by Northeast Utilities. Applicabilityof Appendix A to each FSAR is addressed by existing nuclear unit speclHc design bases and licensing commitments, and also as speciHcallyidentifiedin 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 designatedas CategoryI. 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 (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 program manuals and procedures. l Quality Assurance provisions for primary chemistry laboratory activities are detailed in the Northeast Utilities Nuclear Chemistry Laboratory Quality Assurance Manual. I This NUQAP is committed to utilize the guidance obtained from the regulatory documents and their endorsed standardsidentifiedin Appendix C of this NUQAP Topical Report. l l O QAP Abstract Rev.: 19 Chg. 01 Date: 7/15/98 Page 1 of 1
POLICY STATEMENT NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP) TOPICAL REPORT- MILLSTONEPOWER STATION This Northeast Utilities Quality Assurance Program (NUQAP) Topical Report has been developed to achieve quality assurancein 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 powerplants.
Northeast Utilities procedures which implement this program are described in various manuals. j l This NUQAP applies in its entirety to all activities affecting the safety-relatedfunctions of structures, systems, and components. Safety-Relatedstructures, systems, and components are functionally identified in Appendix A of this NUQAP and are designated Category I by Northeast Utilities. Appilcability of Appendix A to each FSAR is addressed by existing nuclear unit specific design bases and licensing commitments, and also as specificallyidentifiedin each FSAR addressing Section 3.2.1 of Regulatory Guide 1.70. This NUQAP is also applicablein its entitiety to matensis, equfpment, parts, consumables, and services designated as Category I. This NUQAP is also i applicable to other quality programs including Anticipated Transient Without Scram (ATWS) Quality Assurance which is appilcable to MP-1 and MP-2 only (MP-3 commits to Generic Letter 85-06) and ElectricalEquipmentQualification(EEQ) as defined by NU commitments. Portions of this NUQAP are also i applicable to Fire Protection Quality Assurance (FPQA), Station Blackout Quality Assurance (SBOQA) and l Radwaste Quality Assurance (RWQA) which are delineated in applicable program manuals and l procedures. Quality Assurance provisions for primary chemistry laboratory activities are detailed in the Northeast Utilities Nuclear Chemistry Laboratory Quality Assurance Manual l i The development and overall responsibility for this program lies with the President and Chief Executive Otticer- NU Nuclear Group as delegated by the Chainnan, President Chief Executive Officer of Northeast Utilities. Corporate authority is delegated to the Recovery Officer- Nuclear Oversight fnr the preparation and administration of this NUQAP Topical Report. Individual Vice Presidents, Recovery Otheers, and Directors are responsiblefor the implementationof their portion of this program. Audits of this program are the responsibility of the Recovery Officer- NuclearOversight. l l 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 Presidentand Chief Executive Officer. NU Nuclear Group. I a/ h l' Bruce D. Kenyon Q President and Chief Executive Offcer NU Nuclear Group j F QAP Introduction Rev.: 19 Change-1 Date: 7/15/98 Page 1 of 1 ! L________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ - - _ . _ - - _ _ - - - - _ _ - -
i INTRODUCTION em NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
\
v
) TOPICAL RE PORT - MILLSTONE POWER STA TION 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 Topical Report consists of three parts:
- 1. Introduction,which defines the purpose of the Topical Program and summarizesits scope and applicability;
- 2. The NUQAP, which is applicable in its entirety to all activities affecting the safety-relatedfunctions of structures, systems, and components. Safety-Relatedstructures, systems, and > aaponents are functionallyidentifiedin Appendix A of this NUQAP and are designated CategoryI by Northeast Utilities. Applicabilityof Appendix A to each FSAR is addressed by existing nuclear unit specific design basos and licensing commitments, and also as specifically !d'mtified in each FSAR addressing Section 3.2.1 of Regulatory Guide 1.70. This NUQAP is also appilcablein its entirety to materials, equipment, parts, consumables, and services designatedas CategoryI. 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 85-08) and Electrical Equipment Qualification (EEQ) 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 pr7 gram manuals and procedures.
- 3. Appendices, which provide supporting statements and tabulations.
n This NUQAP Topical Report has been prepared to document that a quality assurance program has been ( ) established and implemented to assure that adequate quality requirements are being complied with to
'd 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, contractrd personnel, ,
and the public. l 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 l written by groups, divisions, departments, branches, or sections which have the responsibility for implementing actions 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 action 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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Jhhn F. Streeter [ Recovery Officer - Nuclear Oversight l g () QAP Introduction Rev.: 19 Change 01 Date: 7/15/98 Page 1 of 1
1.0 ORGANIZATION
1.1 INTRODUCTION
The Chairman, President and ChiefExecutive Officer of Northeast Utilities (NU) has l the ultimate responsibility for the NU Nuclear Program. While retaining full responsibility and overall authority, the Chairman has delegated the necessary authority and responsibility for all nuclear operations to the President and Chief Executive Officer - NU Nuclear Group. The NU Nuclear Group includes the Northeast Utilities Service Company (NUSCO) which provides support services to NU's nuclear plants and the Northeast Nuclear Energy Company (NNECO) which operates Millstone Power Station Nuclear Units 1, 2, and 3. The President and Chief Executive Officer- NU Nuclear Group is also the President of NUSCO and the President and Chief Executive Officer of NNECO. l 1.2 GENERAL 1.2.1 The President and Chief Executive Officer - NU Nuclear Group directs specified nuclear related activities within NU and has the ultimate responsibility for the establishment and execution of the NU Quality 5 Assurance Program (NUQAP) for the Millstone Power Station. The President and CEO is cverall responsible for engineering, construction, operation, maintenance, modification, and quality assurance for the Station. O 1.2.1.1 Responsibilities of the President and Chief Executive Officer relating to the Quality Assurance Program are described in this QA Program Topical Report and applicable NUSCO/NNECO procedures. The President and CEO has contact with quality assurance activities through meetings with the Recovery Officer-Nuclear Overs /ght, the receipt of various documents such as: periodic progress reports, Nuclear Safety Assessment Board meeting notes, other reports, and audits related to the nuclear program and nuclear plant operations activities at Millstone Power Station. l 1.2.1.2 The President and CEO is responsible to assess the scope, status, implementation, and effectiveness of the Millstone Power Station NUQAP. To meet this responsibility, the President and CEO appoints a qualified team ofindividuals to perform an annual Management Quality Assurance Review. This Managemerd Quality Assurance Review is: a) A systematic evaluation; b) Preplanned toward the objective of determining the adequacy of the NUQAP andits compliance with Appendix B to 10 CFR 50 and other regulatory requirements; QAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 1 of 19
I l c) Capable of identifying, communicating, and tracking any l required corrective action; d) The team is made up of individuals knowledgeable in quality assurance, quality activities, auditing, management responsibilities, and the Millstone Power Station NUQAP TopicalReport. l 1.2.1.3 The President and CEO rescIves all disputes related to the implementation of this NUQAP for which resolution is not achieved at lowerlevels within the nuclear organization. 1.3 RESPONSIBILITIES 1.3.1 Overall responsibility for the NUQAP is assigned to the Recovery Officer - l Nuclear Oversight who reports to the President and Chief Executive Officer- NU Nuclear Group. These responsibilities include: direction of the Quality Assurance Program; implementation of policies, plans, requirements, procedures, and audits; verification to assure compliance with 10 CFR 50 Appendix B and other regubtory requirements; and verification of the implementation of the Millstone Power Station NUQAP Topical Report requirements. l 1.3.2 The head of each NUSCO/NNECO Department performing quality activities is
- (A) responsible for
- a. Administering those activities within their organization which are required by this NUQAP;
- b. Ensuring implementation of the Quality Assurance Program;
- c. Establishing r.nd clearly defining the duties and responsibilities of personnel wit'iin their organization who perform quality activities;
- d. Planning, selecting, and training personnel to meet the requirements of the NUQAP Topical Report; -
- e. Performing and coordinating quality activities within their department and interfacing with the Nuclear Oversight Department.
1.3.3 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. QAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 2 of 19
O 1.3.4 The responsibility, authority, and organizational relationship for performing quality activities within each organization is established and delineated in the NUSCO/NNECO organizational charts, policy statements, and written job or functional descriptions. 1.3.5 Vendors may be delegated the execution of quality assurance functions; however, NU shall retain responsibility for this Quality Assurance Program. 1.4 PARTICIPATING GROUPS - MILLSTONE POWER STAT /ON (Refer to Fiaure 1.0) c The President and Chief Executive Officer- NU Nuclear Group, reporting to the NU Chairman, President, and Chief Executive Officer, is overall responsible for the developmentandimplementation of this NUQAP. The Nuclear Safety Assessment Board reports to the President and Chief Executive Officer in compilance with Millstone Power Station nuclear unit Technical SpeciRcations. The President and Chief Executive Officer has delegated the necessary authority and has assigned responsibility for development and implementation of this NUQAP for Millstone PowerStation to the:
- Recovery Officer - Nuclear Oversight, l e Senior Vice President and Chief Nuclear Officer- Millstone Power Station, e Director- Special Projects l 1.4.1 The Recovery Officer - Nuclear Oversight is responsible for the l preparation and issuance of this NUQAP Topical Report and veriRcation of the implementation ofits requirements and compliance with 10 CFR 50, Appendix B and other regulatory requirements by the appilcable NUSCO/NNECO Department. VerlRcation is performed through a planned program of audits, surveillance, and inspections by Nuclear Oversight Sections. The Recovery Officer provides management with l objective evidence of the performance of quality activities independent of the individual or group directly responsible for performing the speclRc activity.
The Recovery Officer has the authority and organizational freedom to l verify all activities affecting quality. This is performed independent of undue inRuences and responsibilities for schedules and costs. The Recovery Officer has the responsibility and authority to stop l unsatisfactory work and control further processing or installation of nonconforming materials. The authority to stop work is assigned to Nuclear Oversight Department personnel and delineated in a NNECO Procedure. The Recovery Officer also has the responsibility and authority to identify quality problems, to recommend or provide solutions, and to verify theirimplementation. QAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 3 of 19
The Recovery Officer - Nuclear Oversight is also responsible for the Independent Safety Engineering and Operating Experience Programs. The Recovery Officer (refer to Figure 1.1) has delegated the necessary authority and responsibility for these activities to the: ! e Director- Audits andEvaluation,
- Director- Performance Evaluation, o Director- Analysis andPrograms.
1.4.1.1 Director - Audits and Evaluation is responsible for the day-to-day direction and administration of the audit program to verify compliance with 10CFR50, Appendix B and other regulatory requirements, to verify the implementation of these NUQAP requirements, and to evaluate performance against management expectations. 1.4.1.2 Director - Performance Evaluation is responsible for the day-to-day direction and administration of Nuclear Oversight program for surveillance and inspection to verify compliance with 10CFR50 Appendix B and other regulatory requirements, to verify the implementation of these NUQAP requirements, and to evaluate performance against management expectations. 1.4.1.3 Director - Analysis and Programs is responsible for the day-to-day direction and administration of NUQAP activities including: administration of this NUQAP Topical Report, independent trend analysis, Quality Procedure and Special Process review, and oversight of the Urut Configuration Management Programs. The Director is also responsible for the Nuclear Group Operating Experience (OE) Program and the Independent Safety Engineering Group (ISEG). l QAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 4 of 19
1.4.2 The Senior Vice President and Chief Nuclear Officer - Millstone Power 3 Station has the overall responsibility for the implementation of this NUQAP at the Millstone Station site and is responsible for overall operation of the Station. The Millstone Sile Operations Review l Committee (SORC) reports to the Senior Vice President and Chief Nuclear Officer in compliance with Millstone Power Station nuclear unit Technical Specifications. The Senior Vice President (refer to Figure 1.0) has delegated the necessary authority and has assigned responsibility for these activities to the: l
- Recovery Officer- Millstone Unit 1, l
- Recovery Officer- Millstone Unit 2,
\
- Vice President- Operations, o Vice President - Human Services, e Vice President - Nuclear Work Services, e Recovery Officer- Technical Services.
1.4.2.1 The Recovery Officer - Millstone Unit 1 is responsible for implementation of this NUQAP for the Unit and is responsible for overall unit safe operation and control over those onsite' l activities necessary for safe operation and maintenance of the plant. The Recovery OtScer(refer to Figure 1.2) has delegated the necessary authority and assigned responsibility for these activities to the: l
- Director. Unit Operations,
- Regulatory Readiness Officer 1.4.2.1.1 The Director- Unit Operations is responsible for the day-to-day direction and adtr:holstration of the Unit Operations, Maintenance. Modification, Work Planning, and Radiologie :/ Controls activities. The Plant Operations Review Committee (PORC) reports to the Director- Unit Operations in compliance with Technical SpeclHcations. The Manager of Health Physics reports to the Director of Unit Operations to provide sufficient organizational freedom and independence from operating pressures as required by the unit technical specifications. The Director has delegated the necessary authority and assigned responsibility for Unit activities to the:
- Manager- Operations e Manager- Engineering e Manager- Work Management
- Manager- Support Services e Manager- Chemistry e Manager- Health Physics OAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 5 of 19 )
1.4.2.1.2 The Regulatory Readiness Officeris responsible for O the day-to-day direction and administration of the Configuration Management Program and Regulatory Compliance activities. 1.4.2.2 The Recovery Of6cer - Millstone Unit 2 is responsible for implementation of this NUQAP for the Unit andis responsible for overall unit safe operation and control over those onsite l activities necessary forsafe operation and maintenance of the plant. The Recovery OtNcer(refer to Figure 1.3) has delegated the necessary authority and assigned responsibility for these activities to the:
- Unit Director, e Director- Engineering, e Director- Startup.
1.4.2.2.1 The Unit Director is responsible for the day-to-day direction and administration of the Unit Operations, Maintenance, Modification, Work Planning, and Radiological Controls activities. The Plant Operations Review Committee (PORC) reports to the Unit Director in compliance with Technical Specl6 cations. The Manager - Radiation Protection O reports directly to the Unit Director to provide sufficient organizational freedom and independence from operating pressures as required by the unit technical specifications. The Unit Director has delegated the necessary authority and assigned responsibility for the Unit activities to the:
- The Assistant Unit Director- Nuclear Safety,
- The ' Assistant Unit Director - Operations &
Maintenance, e The Manager Radiation Protection. [jb27] e ManagerofProjects 1.4.2.2.2 The Director - Engineering is responsible for the day-to-day direction and administration of Unit Design Engineering, Technical Support, Project Engineering, Programs, and for maintenance of the l Unit design basis in accordance with the Unit licensing basis. 1.4.2.2.3 The Director- Startup is responsible for the planning, scheduling, coordinating and reporting of ( Unit restart activities. QAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 6 of 19
1.4.2.3 The Vice President Operations is responsible for establishing O common policies and standards pertaining to the operating units, the safe operation of Millstone Unit 3, and implementation of this NUQAP. The Vice President of Operations has delegated the necessary authority and has assigned responsibility for the Unit 3 activities to the Vice President - Millstone Unit 3 The Vice President - Millstone Unit 3 is responsible for irnplementation of this NUQAP for the Unit and is responsible for overall unit safe operation and control over those onsite l activities necessary for safe operation and maintenance of the plant. The Vice President (refer to Figure 1.4) has delegated the necessary authority and assigned responsibility for these activities to the:
- Unit Dhector- Unit 3, e Director- Engineering Unit 3, e Manager - Motor Operated Valve Project.
1.4.2.3.1 The Unit Director is responsible for the day-to-day direction and administration of the Unit Operations, Maintenance, Modification, Work Planning, and Radiological Controls, activities. The Plant Operations Review Committee (PORC) reports to , the Unit Director in compilance with Technical i Ou Specifications. The Manager - Radiation Protection reports directly to the Unit Director to provide \ sufficient organizational freedom and independence i from operating pressures as required by the unit technical specifications. The director has delegated the necessary authority and assigned responsibility for the Unit activities to the:
- The Assistant Unit Director- Nuclear Safety, o The Assistant Unit Director - Operations &
Maintenance, e The Manager Radiation Protection. 1.4.2.3.2 The Director - Engineering is responsible for the day-to-day direction and administration of Unit Design Engineering, Technical Support, System Readiness, and for maintenance of the Unit design basis in accordance with the Unit licensing basis. 1.4.2.3.3 The Manager Motor Operated Valve Project is responsible for the day-to-day direction, and administration of the unit MOV project and associated Modification Engineering activities. O QAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 7 of 19
C 1.4.2.4 The Vice President - Human Services has responsibility for the Employee Concems and Nuclear Training Programs, and ] implementation of this NUQAP in providing Emergency Planning and Support Services to the Millstone Power Station. The Vice President (refer to Figure 1.5) has delegated the necessary authority and has assigned responsibility for these activities to the:
* ~ Director- Nuclear Training Services, e Director- Emergency Planning.
(
- Director- Employee Concerns 1.4.2.4.1 The Director -
Nuclear Training Services is responsible for the day-to-day direction and administration of Nuclear Training and related support services. The Manager of Operator Training reports directly to the Director of Nuclear Training to provide sufficient organizational freedom and independence from operating pressures as required by the unit technical specifications. 1.4.2.4.2 The Director - Emergency Planning is responsible for the development and maintenance of the on site O Radiological Emergency Plan and the development and coordination of required off site Radiological Emergency Response Plans. 1.4.2.4.3 Director - Employee Concerns Program is responsible for the day-to-day direction and administration of the Employee Concerns Program. The Director assures that nuclear safety concerns receive appropriate management attention and concerns are addressedin a timely manner. l l l l l 1 l l QAP 1.0 i Rev.: 19 Change 01 l Date: 7/15/98 ' Page 8 of 19 l
1.4.2.5 The Vice President - Nuclear Work Services has responsibility l O for implementation of this NUQAP in providing work related services in support of the Station. The Vice President (refer to Figure 1.6) has delegated the necessary authority and has l assigned responsibility for these activities to the: e Director- Nuclear Services, o Director-Information Technology, e Director - Nuclear Materials and Document Management, o Director- Contracts and Project Management, e Director- GeneralServices, . 1.4.2.5.1 The Director - Nuclear Services is responsible for the day-to-day direction and administration of Construction Support, Waste Management, Health Physics Support, Facilities Maintenance, and Testing Services forplant operations. 1.4.2.5.2 The Director - Information Technology responsible for the day-to-day direction and isl administration of Computer Services Support. 1.4.2.5.3 The Director - Nuclear Materials and Document l Management is responsible for the day-to-day direction and administration of Millstone Power O Station Stores, Procurement Engineering, and DocumentsfRecords control activities. The Director is also responsible for the approval of vendors and oversight of offsite vendors that provide quality l related material and services including source and receipt inspection. 1.4.2.5.4 The Director- Contracts and Project Management is l responsible for setting policy and for the day-to-day direction and administration of the Nuclear Contract Group. The Director is also responsible for project management teams for each of the Station nuclear units. 1.4.2.5.5 The Director - General Services is responsible for the day-to-day direction and administration of Station Security, Medical, - Safety, and Fire Protection activities. O QAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 9 of 19 l
i l 1.4.2.6 The Recovery Officer - Technical Services is responsible for
- Engineering and Technical Support Services at Millstone O\ Station. The Recovery Officer is responsible for implementation of the' Corrective Action, Configuration Management, and related Engineering Programs. The Recovery Officer is also responsible for Nuclear Engineering Support, the Regulatory Affairs interface, and the Independent Review Team. The Recovery Officer (refer to Figure 1.7) has i delegated the necessary authority and has assigned l responsibility for these activities to the I
e Director- Engineering Programs \ e Director- Corrective Actions ? e Director- Unit Services l e Director- Configuration Management Program
- Director- Nuclear Engineering i e Director- Regulatory Affairs e Manager-Independent Review Team 1.4.2.6.1 The Director - Engineering Programs is responsible i for the day-to-day direction and administration of l Engineering Programs and Standards, the {
Engineering Assurance Program, and the l administration of the Design and Configuration ' r Control Program and the Design Control Manual for ; the Station nuclear units. ; 1.4.2.6.2 The Director - Corrective Actions is responsible for the development and maintenance of the Corrective Action Program implemented for the Station including reporting of program performance indicators, analysis andidentification of trends, and l IdentiHcation of necessary preemptive corrective 1 action as required. i 1.4.2.6.3 The Director - Unit Services is responsible for the day-to-day direction and adr'dmstration of the Units 1, 2, and 3 Regulatory Cornpliance activities and the Station Administrative Procedures Group. l 1.4.2.6.4 The Director - Con 6guration Management Program is responsible for the day to-day direction and administration of the Unit Configuration Management Program activities. OAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 10 of 19
1.4.2.6.5 The Director - Nuclear Engineering is responsible for the day-to-day direction and administration of Nuclear Fuels, Radiological Engineering and Assessment, Radweste Engineering, Probabilistic Risk Assessment, Safety ' Analysis activities, and the Quality Software Program. 1.4.2.6.6 The Director- Regulatory Affairs, is responsible for the overall direction and administration of Regulatory Affairs and the Nuclear Regulatory Program activities for the Station. 1.4.2.6. 7 The Manager - Independent Review Team is responsible for conducting in depth and critical reviews of selected topics and events of critical importance to nuclear safety and/or organizational success. 1.4.3. The Director - Special Projects is responsible for the day-to-day direction and administration of Nuclear Operations Support Services and the performance of special projects in support of nuclear operations. O QAP 1.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 11 of 19
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l 2.0 QUALITY ASSURANCE PROGRAM 2.1 GENERAL REQUIREMENTS Northeast Utilities (NU) has established a Quality Assurance Program (NUQAP) for the Millstone Power Sta#on which complies with the criteria of 10CFR50, Appendix B, and follows the regulatory documents and their endorsed ANSI /IEEEstandardsidentified in Appendx C with exceptions as identifiedin Appendix E. The quality assurance requirements set forth in the attached Policy St2tement, supplemented by quality assurance procedures, provide the primary basis of this program and the NU policy with regard to quality assurance forall the Millstone Station nuclear power plants. This NUQAP Topical Report is established to accomplish the required level of quality in activities carried out l throughout the life of the Station's nuciear power plants. This NUQAP applies in its entirety to all activities affecting the safety-related functions of structures, systems and components. Safety-Reisted structures, systems and components are functionallyidentifiedin Appendx A of this NUQAP and are designated Category I by Northeast U#Ii#es. Applicabilityof Appendix A to each FSAR is addressed by existing Nuclear Unit specl6c Design Bases and Licensing commitments, and also as specificallyidentified in each FSAR addressing Section 3.2.1 of Regulatory Guide O 1.70. This NUQAP is also applicable in its entirety to materials, equipment, parts, consumables and services designated CategoryI. This NUQAP appIles to other qualityprograms including Anticipated l Transient Without Scram (A 1WS) Quality Assurance which is appilcable to MP-1 and MP-2 only (MP-3 commits to Generic Letter 85-06) and Electrical Equipment Quali6 cation (EEQ) as de6ned by NU commitments. Portions of this NUQAP are also applicable to Fire Protection Quality Assurance (FPQA), Station Blackout Quality Assurance (SBOQA) and Radweste Quality Assurance (RWQA) which are delineatedin applicableprocedures. 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 identi6ed as safety-relatedor augmented quality. The requirements of this NUQAP are implemented by Northeast Utilities Service j Company (NUSCO), the Northeast Nuclear Energy Company (NNECO) which operates Millstone Power Station, and their vendors puforming activities affecting quality structures, systems, and components of the S&#on's nuclear power plants. 1 I [O QAP - 2.0 Rev.: 19 Change 01 Date: 7/15/98 Page1 of 7 c_-_______________
~
Procedures define the required indoctrination and training of personnel performing
/ activities affecting quality, as necessary, to assure that suitable proficiency is achieved and maintained.
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, surveillance and inspections, by l Nuclear Safety Assessment Board (NSAB) reviews, and by the independent review team which performs the annual NUQAP Management Review described herein and QAP 1.0, " Organization", Section 1.2.1.2. 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. O To meet these goals, the following objectives of this NUQAP have been defined: b a. Define through procedures, the quality activ/fles that apply to design, fabrication, procurement, construction, testing, operation, refueling, repair, ] maintenanceand modificationof the Station nuclearpower 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 l system of audits, surveillance, and inspections of those organizationswith l
, quality responsibilities;
- d. Apprise the President and Chief Executive Officer- NU Nuclear Group of unresolved problems and trends which could have a significant effect on nuclear powerplantsafety. l I
\
QAP - 2.0 Rev.: 19 Change 01 Date: 7/15/98 Page2 of 7
l l C 2.2.2 PROGRAM DOCUMENTATION ( ! This NUQAP defines the NU nuclear policies, goals, and objectives, and l 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 of activities prior to implementation. These revisions shall be made in accordance with a NNECO Procedure. l Revisions to this NUQAP, which reduce commitments previously accepted by the NRC, are submitted to the NRC for review and approval prior to implementation. l 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 i activities. These procedures are reviewed for concurrence by the departments which are responsible for linplementing portions of these procedures and are approved by the initiating department. The Nuclear j Overs /pht Department reviews other department quality procedures for l compliance with this NUQAP and concurs with such procedures as described in QAP 5.0, " Procedures, instructions and Drawings", sj Changes to procedures are subjected to the same degree of control as that utilized in the preparation of the original document. Each Vice President, Recovery OMcer and Director is responsible for implementation of this NUQAP within their organization which includes 4 individual departmental procedure requirements applicable only to their respective activities. In addition, they are responsible for the preparation, approval, and distribution of those instruction,, 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 Analysis Reports (SARs). Safety-Related structures, systems and 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. O QAP - 2.0 Rev.: 19 Change 01 Date: 7/15/98 Page 3 of 7 w_________________________-_.
l ! n For structures, systems and components covered by the ASME Code, l (~) NUSCO/NNECO procedures describe the measures taken to assure that l the quality assurance requirements contained in the code are supplemented by the specific guidance of the applicable regulatory guides and endorsed ANSIstandards listed in Appendix C. For structures, systems and components, regulatory commitments and NUSCO/NNECO procedures describe the measures taken to assure that l 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 5 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 j need for verification of quality by inspection and test. { The Nuclear Oversight Department and applicable NUSCO/NNECO l technical organizations jointly determine and identify the extent quality assurance controls are applied to quality stiactures, 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 r 10 CFR 50. (<~~w/ i ?
~
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 i 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 controhed 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 applicable elements of the regulatory guides and their
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7 / QAP - 2.0 Rev.: 19 Changs 01 Date: 7/15/98 Page4 of 7
l p endorsed ANSl/IEEE standards identified in Appendix C. However, NU lV retains 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 l and approval of these vendors' quality assurance programs prior to
- initiation of contracted achvities.
i The object of the review is to verify that these vendors have an adequate quality assurance program to meet applicable requirements of 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, surveillance, and inspections of approved l vendor's quality assurance programs to assure continued implementation of quality requirements. In those cases where Nuclear Materials and Document Management contracts its oversight function to a qualified outside vendor the Nuclear Oversight Department conducts independent audits, surveillance, and inspections as appropriate. The Nuclear Oversight Department performs audits, surveillance, and inspections, as appropriate, of onsite vendor quality assurance programs to assure continued 'p. Implementation of quality requirements. O 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 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 these documents is mandatory. Each NUSCO/NNECO Department is responsible for assuring assigned personnel who perform quality
- activities have been appropriately indoctrinated and trained.
l O QAP - 2.0 Rev.: 19 Change 01 l Date: 7/15/98 Page 5 of 7
l r ( Nuclear training programs shall be developed and implemented to provide training for all individuals attached to or associated with the Station nuclear power plants. Additional guidance is established in NUSCO/NNECO procedures. l Procedures describe the nuclear training program requirements 'which assure that:
- a. Documentation of formal training and qualification programs includes I
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 / testing, 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 and 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 performing quality activities are trained in the principles and techniques of the activity being performed. 2.2.6 MANAGEMENT PARTICIPATION niillstone Power Station Vice Presidents, Recovery 09Ncers, and Directors are responsible for implementing this NUQAP within their organization. The Recovery 096cer - Nuclear Oversight will assist in development, coordination, and review of the program. The President and Chief Executive OtNcer - NU Nuclear Group assures that a Management Review of this NUQAP is conducted on an annual basis by an independent team to assess the scope, status, implementation, effectiveness, and to ' assure compliance to NRC licensing commitments. QAP - 2.0 Rev.: 19 Change 01 Date: 7/15/98 Page6 of 7 w__________-_-._____.__ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _- _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ . . _ _________..___-____________.________.______.____._-m._______.____
r yn Actions considered by the Management Review may include, but are not limited to:
- a. Review of selected procedures and documents;
- b. Verificationof the implementationof selected procedural requirements; l c. Review of past audit results and other inspection / review results i
such as those from previous Management Reviews, the NRC or other departments. The Management Review's findings of deficiencies and recommendations for program improvement are forwarded to the President and Ch/ef Executive Officer - NU Nuclear Group, who shall assure appropriate corrective action is taken. 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. iO U t p QAP - 2.0 Rev.: 19 Change 01 Date: 7/15/98 l Page 7 of 7 I l
l I p 3.0 PESIGN CONTROL
- O 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.
The Director I Manager - Engineering for each nuclear unit is l responsible for controlling design work, administering design control activities (including design interface) and design modifications for qua!ity structures, systems, and components. The responsibility for administration of the design control program for the Millstone Station nuclear power plants rests with Engineering Programs. The division of responsibilities and jurisdictional boundarles (3 for design control program implementation are set forth in V NUSCO/NNECO procedures. Although other organizations may be delegated the task of establishing and executing the design control program or any part thereof, the Director / Manager - Engineering of I each nuclear unit shall retain the responsibility for program implementationfor the unit. 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 OAP 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 QAP - 3.0 Rev.: 19 Change 01 Date: 7/15/98 Page 1 of 6 i l L_._______
- - _ - - _ _ _ _ _ _ _ _ _ _ - _ _ = _ _ - - _ _ _ _
- for the particular design aspect being venfied. The independent design
!, verification should not dilute or replace the responsibilityof 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 under adverse design conditions shall comply with the requirements of QAP 11.0, " 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" andler QAP 16.0, " Correcdve Acdon". 3.2 IMPLEMENTATION The Director / Manager - Engineering of each unit is responsible for the l design, design review, engineering approval of design changes, design evaluation and . design control ibr the unit except that Nuclear Engineering performs design / design changes in support of the reactor core reload. The function may. be delegated to other organizations to perform the design, or any part thereof, but the responsibility for overall p design and final engineering decisions and design control of quality ( structures, systems, and components related to the nuclear urWt is the responsibilityof the unit's Director / Manager - Engineering. l Nuclear Oversight performs audits, surveillance, and inspections, as
=f=9M, to verify that NUSCO/NNECO departments are effectively complying with this NUQAP and procedural requirements for design control. NuclearMaterials and Document Managements responsible for the performance of o# site audits, surveillance, and inspections, as appropriate,- to verify that vendors are effectively complying with their quality assurance program requirements for design control. Nuclear Oversight performs audits, surveillance, and inspecdons, as appropriate, of onsite vendoracdvides in this area.
3.2.1 DESIGN PROCESS Design control measures are applied to design analyses, such as, reactor physics, stress, thermal, hydraulic, nuclear radiation, I accident 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". i l QAP - 3.0 Rev.: 19 Change 01 l Date: 7/15/98 i Page 2 of 6 l
~
l 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 specification,, drawings, procedures or instructions. Procedures and instructions further require that appropriate 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. Procedures assure that a documented check is performed to verify the 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.
s a Procedures describe the provisions to assure that. design - i 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. i
< 3.2.2 DESIGN CHANGE CONTROL s
Procedures and instructions goveming design change control during modifications to the Station nuclear plants, the control of discrepant or deficient design conditions, and the reporting of unsatisfactory performance 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 applied during l the original design as amended by applicable design or . licensing basis changes. I QAP - 3.0
- Rev.: 19 Change 01 ,
Date: 7/15/98 ! Page 3 of 6 j l
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t 4 . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
f r 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 nuclear units management for processing and review. This review includes the Plant Operations Review Committee (PORC) / Site Operations Review Committee (SORC) as required by applicable procedures. PORCISORC is advisor to the Senior Vice President and Chief Nuclear Officer and Unit Directors (Millstone Units 2 & 3)/ Unit Operations Director (Millstone Unit No.1) on matters relating to nuclear safety. The composition, responsibilities, and authority of the SORC/PORC are defined in Section 6 of each nuclear unit Technical Specification. If the change involves a quality s.tructure, 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 g 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 forits implementation). The combination of these independent reviews by the PORC/SORC and NSAB are performed to assure that:
- a. the adequacy of the proposed change is substantiated;
- b. unreviewed safety questions are properly identified and j handled per 10 CFR 50.59; j
- 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 OAP 15.C, " Nonconforming Materials, Parts, Components, or Services" and/or QAP 16.0, " Corrective Action". : ln i V QAP - 3.0 Rev.: 19 Change 01 Date: 7/15/98 Page 4 of 6
O 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 modRcations to the station nuclearpowerplants. 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) dd not specify a singular design approach,~ (2) dd not ' establish the design inputs or wie out certain design considerations, (3)is the only indvidual in the organization competent to pert 6rm the review. Where the supervisor performs the design review, the next level of management shall futRel the supervisor's responsibilities. Design verification O is documented in accordance with procedures or instructions. Simplified calculations or computer programs may be utilized as altamate 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.
retained by theResponsibility forEngineering DirectorI nianager- design adequacy of each unit.and evaluation 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, l; fabrication, and construction, procedures assure that design verification is completed prior to the point when the installation is
. declared operational.
O QAP.3.0 Rev.: 19 Change 01 Date;-7/15/98 Page 5 of 6 L_________ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ - - _
.^ Procedures describe the requirements which assure the following when testing is considered as an attemate method of design verification:
- a. Specifications or procedures provide criteria that specify when verificationshould be by test.
- b. Prototype, component or feature testing is performea 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 checking method. Procedures and instructions provide the requirements and necessary controls for i 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 p reviews is provided. N.] 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. NNECO is responsible for assuring that the design documents generated by vendors for the Station nuclearpowerplants are technically correct, approved, and maintained. V QAP-3.0 Rev.: 19 Change 01 Date: 7/15/98 Page6 of 6
l
/~' 4.0 PROCUREMENT DOCUMENT CONTROL 4.1 GENERA 1. REQUIREMENTS This NUQAP provides measures to control the procurement of materials, equipment, parts and services for quality structures, systems, and 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 utilizedin the preparationof the originaldocuments. 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. ,r 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 information 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. Nuclear Materials and Document Management is responsible for
- the performance of offsite audits, surveillance, and inspections, as
\ appropriate, to verify that these vendors are effectively compiying with their quality assurance program requirements for the control of procurement documents. Nuclear Oversight performs audits, I QAP - 4.0 1 Rev.: 19 Date: 6/24/98 l Page 1 of 3
A surveillance, and inspections, as appropriate, of onsite vent'or
& activities in this area.
Changes to procurement documents, whether initiated by NNECO or its representative, are subjected to the same degree of control as l 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. Adequate technicalrequirements are speciRed;
- b. The quality assurance requirements are correctly stated, auditable and controllable;
- c. There are adequate acceptance and rejection criteria.
O 4.2.2 PROCUREMENT DOCUMENT PROVISIONS 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;
- b. Technical requirements (specified or referenced) including the applicable components and materials identification requirements, drawings, specifications, procedures, instructions, codes and regulations, and the identification of applicable test, inspection and acceptance requirements, or l' special processinstructions; I
1 l QAP - 4.0 l Rev.: 19 Date: 6/24/98 Page2 of 3 Li_._-_------______------- - . - _ - - - . - - - _ _ - - _ _ - . - - - - - _ - - - . - - - - - - - - - - - - - - - - - _ - - - - - - _ - - - - - - - - - - . - - - - . -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
1 l
- c. Quality assurance program requirements to be imposed on
( vendors which include the applicable requirements of 10 CFR 50, Appendix B, and the NRC regulatory position contained in the regulatory guides and their endorsed ANSI /IEEE standards listed in Appendix C.
- d. _ Right of access which provides, as appropriate, for access to vendorfacilities and records for inspection or audit by NNECO or its designated representative; and provides access for events such as those requiring notificationof hold points;
- e. The documentation required to be prepared, maintained, and/ g 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 #NECO is prescribed, as applicable, for nuclear grade procurement. i 4.2.3 SELECTION OF PROCUREMENT SOURCES The vendor is speclRed during the procurement process based upon the vendor approval status, quellRcations and capabilities to provide the product or service, performance history, and NNECO's ability to verify the quality of the product or service ..
Q being purchased. NNECO maintains an approved vendors list T based upon the technical and quality capability as determined by a direct evaluation of the vendor's facilides and personnel and the implementation of the vendor's quality assurance program. Procurement documents may be issued to vendors with unapproved quality . assurance programs. These procurement documents to unapproved vendors contain detailed supplementary quality assurance requirements and/or witness / hold points to meet NNECO < requirements. Procurement documents are reviewed by Nuclear Materials and Document Management to assure appropriate quality assurance requirements are specified. The requirements include, as necessary, audits, surveillance, 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 1 the plant or prior to the point when the installation is declared operational. b a QAP - 4.0 Rev.: 19 Date: 6/24/98 Page 3 of 3 l L
5.0 PROCEDURES. INSTRUCTIONS AND DRAWING _S 5.1 Q_ENERAL REQUIREMENTS This NUQAP provides measures for the preparation, review, approval, control and distribution of procedures, instructions and drawings for activities affecting quality structures, systems, and components of the Mi# stone Stadon nuclear power plants. The documents include appropriate quantitative and qualitative acceptance criteria which specify the activity to be performed, the methods of fabrication, l construction, and testing to be employed; the materials, equipment or parts to be used; a sequence of operation, and the required documentation. l 5.2 l 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 describedin 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 perfbrm quality activides for the Stadon nuclear power plants may be delegated responsibility for preparing, maintaining, issuing and verifying the l implementation of appropriate program documents ~ which are selectively reviewed / approved by the appropriate Director or responsible Engineer. In this
'% case, Nuclear Materials and Document Management is responsible for the l performance of offsite audits, surveillance, and inspections, as appropriate, to verify that these vendors are effectively complying with their qua#ty assurance program requirements for compliance with procedures and instructions. Nuclear Oversightperibrms audits, survelHances, and inspections, as appropriate, of onsite vendoracdvities in this aren. Vendor que#ty assurance programs are required to clearly 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 PROCEDURES 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, onsite vendor quality procedures and quality control inspection procedures are reviewed for QAP - 5.0 Rev.: 19 Change 01 Date: 7/15/98 Page 1 of 2
)
i G concurrence by Nuclear Oversight to assure compliance with the I
- k. vendor's quality assurance program.
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 l 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 documents requiring Nuclear Oversight review and concurrence and theiridentification are deHnedin quality procedures to assure: l
- a. Administrative procedures and manuals comply with this NUQAP and appilcable Appendix C regulatory guides and endorsed ANSI /IEEE standards.
- 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 I O V The design control and verification measures described in QAP 3.0,
" Design Control", are applicable for the review and approval of drawings. Review and approval of new drawings or modifications to existing drawings are described in NUSCO/NNECO procedures. The l originating organization may delegate to other organizations or
- departments the work of design and review activities, or any part thereof, I 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 l operation are updated prior to system tumover to operation and are available to the operating personnel. l l 5.2.3 ACCEPTANCE CRITERIA Cognizant Department Heads review and approve departmental procedures, instructions and drawings to assure the inclusion of adequate quantitative and qualitative acceptance criteria, as appropriate, for determining satisfactory work performance and quality compliance for appilcable quality activities. m QAP - 5.0 ! Rev.: 19 Change 01 Date: 7/15/98 Page 2 of 2
6.0 DOCUMENT CONTROL O 6.1 - GENERAL REQUIREMENTS This NUQAP provides measures to assure controlleddistribuWon of documents pertinent to quality activides performed for the Millstone Stadon nuclear power plants in accordance with quality procedures. Documents such as procedures, instructions, drawings, specifications and reports are prepared, reviewed for appropriate qualitative and quantitative acceptance criteria, and approved by authorized personnel in the affected organization.
- Approved controlled documents are distributed to affected locations in accordance 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 app # cable 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 acdvities for the StaWon nuclear power plants and include documents such as: l
- a. Design Specifications;
- b. Design, Manufacturing, Construction and Installation Drawings;
- c. As-Built Documents; i-
! d. Quality Assurance Program Manuals, Procedures and Instructions;
- e. Manufacturing, inspection and Testing Instructions;
- f. Test Procedures;
- g. Calculadons; i 0 h. Engineering Record Correspondence; QAP - 6.0 Rev.; 19 Change 01 Date: 7/15/98 Page 1 of 3
l i Design Basis Documentation Summaries (DBDS) J. FinalSafety Analysis Reports; I
- k. ProcurementDocuments; l
l 1. Design Change Records; l m. TopicalReport, i
- n. NonconformanceReports, .
- o. ComputerCodes.
NUSCO/NNECO procedures describe the measures taken by the Nuclear Oversigtet 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 O control procedures. The issuing organization is additionally responsible 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. Any vendors utilized to' perform quality activities for the Station nuclear power plants are responsible for implementing measures for i review, approval, control and distribution of controlled documents to assure they are effectively complying with the requirements for document control. Nuclear Materials and Document Management is l responsible for the performance of offsite audits, surveillance, and i inspections, as appropriate, to verify that these vendors are eSectively complying with their quality assurance program requirements for document control. Nuclear Oversight performs ; audits, surveillance, and inspections, as appropriate, of onsite ; vendor activities in this area. l 1 1 O OAP - 6.0 i i Rev.: 19 Change 01 Date: 7/15/98 Page 2 of 3
l I l l v 0 6.2.2 DISTRIBUTION OF CONTROLLED DOCUMENTS l
\
NUSCO/NNECO procedures specify in what manner controlled l I documents, and revisions thereof, are distributed to appropriate locations prior to commencing the work. 6.2.3 DRAWING CONTROL l Station Nuclear Document Services is responsible to implement a program, through appt/ cable procedures, for the retention and retrieval 1 of drawings and records submitted by cognizant NUSCO/NNECO j personnel. Station Nuclear Document Services maintains a drawing l status file which includes drawings newly issued or revised with the latest I 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 i furnish periodic status reports listing the revisions of applicable drawings j which they issue. l Nuclear Materials and Document Management is responsible for the O V performance of offsite audits, surveillance, and inspections, as appropriate, to verify that these vendors are effectively complying with i i their quality assurance program requirements for control of drawings. Nuclear Oversight performs audits, surveillance, and inspections, l ss appropriate, of onsite vendor activities in this area. i l 6.2.4 PROCEDURE AND INSTRUCTION CONTROL The Nuclear Oversight Department performs audits, surveillance, and inspections, as appropriate, of NUSCO/NNECO Departments and onsite vendors utilized to perform quality activities to verify they are ; effectively complying with this NUQAP and the vendor quality assurance program requirements, respect /vely, 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. l l l QAP - 6.0 Rev.: 19 Change 01 Date: 7/15/98 Page 3 of 3 a_________-______-_______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
'( ( 7.0 CONTROL OF PURCHASED MATERIAL EQUIPMENT AND SERVICES 7.1 GENERAL REQUIREMENTS This NUQAP provides measures for the control of purchased material, equipment, parts and services udilzed 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 tesdng 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 specify 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. 7.2.1 VENDOR QUALIFICATIONS Nuclear Materials and Document Management utilizes one or more of the following methods in evaluating the qualifications of a potential vendor:
- a. Audits and/or coordinated review of a potential vendor utilizing one or more departments (i.e., Engineering, Nuclear Work Services, Operations and/or Purchasing);
- b. Other utility vendor audits and evaluations;
- c. Nuclear Procurement issues Committee (NUPIC) audits;
- d. ASME N, NA, NPT, NV, or MM/ MS Certificate of Authorization; l
l
- e. Commercialgrade surveys and/or coordinated review of a potential vendor utilizing one or more departments, (i.e., Engineering, Nuclear Work Services, Operations and/or Purchasing);
1
- f. Source inspection / surveillance.
( QAP - 7.0 l Rev.: 19 Change 01 j Date: 7/15/98 f Page 1 of 4 l L___________---_--__________---_-__. _ - - - _ _ - - - - .- - - - _ - - . - - - -__----_--_--------------------------------------O
Evaluations assure that vendors providing quality material, equipment, O parts and services employ a quality assurance program that conforms to applicable portions of this NUQAP. Nuclear Materials and Document Management is responsible for assuring that documented evidence of the evaluation and acceptance of the vendor's quality assurance program is maintained. The determination of vendor approval is based on such factors as prior performance, quality performance data, audits, commercial grade surveys, surveillance and evaluations of the vendor's quality assurance program. Vendor Certificates of Conformance are periodically evaluated by audits, commercial grade surveys, surveillance, 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. Inspection of items occurs either when verifications of procurement I requirements cannot be determined upon receipt or the vendor quality assurance program has not been accepted by Nuclear Materials and Document Management. 7.2.3 BECEIPT INSPECTION j y Receipt inspection for procured items is performed by Nuclear Materials and Document Management in accordance with quality procedures which delineate requirements and responsibilities necessary to perform ; i inspection functions. The exceptions to this are Reactor Engineering ! performing receipt inspection for new fuel assemblies, and Unit Operations performing receipt inspection of bulk hydrogen / nitrogen for Millstone Power Station Unit No. 3 in accordance with quality procedures. Contractual obligation fulfillment and specified requirements l are verified during receipt inspections. j 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 O. QAP - 7.0 Rev.: 19 Change 01 Date: 7/15/98 Page 2 of 4 i
I q to acceptance, installation and operation. Receipt inspections include, as l Q appropnate:
- a. Measures for verifying that the shipment is complete, properiy identified, undamaged and corresponds with the required documentation;
- b. Measures for inspection of the item's crit / cal characteristics and review of supporting documentation (e.g., mill test reports, NDE reports) as required by the procurement documents;
- c. Measures for inspection and acceptance of items in accordance with predeterminedmethods;
- d. Measures for identifying and controlling acceptable items including identification 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; O
Q 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 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 p Nonconformances dispositioned " accept as is" or " repair."
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1 The responsible Nuclear Materials and Document Management and/or Q(3 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 shall provide oversight of these activities via audit, surveillance, or inspection, as appropriate, to verify compilance with this requirement. l 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. I 1 1 1 These measures follow the guidance in Regulatory Guide 1.144, paragraph C. 3. b (1) and Regulato y Guide 1.123 and applicable paragraphs of Section 10 of ANSI N45.2.13. 1 OV 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 by Nuclear Materials and Document Management, other NUSCO/NNECO Departments, or appropriate groups. other l. 1 l l l l ! g l QAP - 7.0 i Rev.: 19 Change 01 l Date: 7/15/98 i Page 4 of 4 ~ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
m 8.0 IDENTIFICATION AND CONTROL OF MATERIALS. PARTS AND COMPONENTS b 8.1 GENERAL REQUIREMENTS This NUQAP provides measures for the identification and control of materials, parts and components, including partially fabricated assemblies utilizedin quality activities for the Millstone Power Station. To assure that each item can be traced to associated 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. o 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. l 8.2 IMPLEMENTATION I NNECO procedures establish the responsibilities and requirements for the identification and control of materials, parts and components. The procedures assure that identification O and control are maintained throughout fabrication, receipt, handling, storage and installationofitems. Provisionsinclude: g i
- a. Requirements for traceability to appropriate documentation such as: purchase orders, contracts, manufacturing documents, drawings, specifications, certifications, inspection and test records, and nonconformance reports; I
- o. Controls to assure that the correct identification of an item is verified and documented prior to release for fabrication, assembly, shipping or installation;
- c. Requirements which assure that the method or location of markings do not affect 1
! the function or quality of an item; l f d. Establishment of identification requirements in purchase orders, contracts, specifications, drawings, procedures or instructions. . 1 During the performance of quality activities for the Station nuclear power plants, l ' 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. In this case, the Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillance, and inspections, 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. Nuclear QAP - 8.0 Rev.: 19 , Date: 6/24/98 Page 1 of 2 i'
O Oversight performs audits, surveillance, and inspections, as appropriate, of onsite vendoractivitiesin this area. 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 identificationand traceabiltiy. In the event that materials, parts or components are nonconforming or the identification I becomes lost or illegible, the items are considered nonconforming and are identified and l controlled in accordance with QAP 15.0, " Nonconforming Materials, Parts, ' Components, or Services". ! l 1 4 O OAP - 8.0 Rev.: 19 Date: 6/24/98 Page 2 of 2
9.0 CONTROL OF SPECIAL PROCESSES 9.1 GENERAL REQUIREMENTS This NUQAP provides measures to assure the control of special processes associated with quality structures, systems, and compononts 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 Stadon's nuclear power plants, the respons&ie engineer assures that special process data and documentation is reviewed, and that vendor special process procedures utilized for the Stadon nuclear power plants are qualified and approved, and that personnel and equipment utilizing special processes are properly qualified prior to start of work. Nuclear Materials and Document Afanagementis responsible fier the peribrmance of offsite audits, surveillance, and iraspections, as appropriate, to verify that these vendors are effectively complying with their quality assurance pogram requirements for control of specsal processes. Nuclear Oversight performs audits, survelilances, and inspections, as appropriate, of onsite vendoractividesin this area. NUSCO/NNECO special process procedures utilized during quality activities for the l Station nuclear power plants are prepared, reviewed and approved in accordance with 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 l 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 applicable specditations, codes and standards. Requirements for the period of certification, examinations, and certf# cation renewal of personnel are also specified Vendors qualify personnel and maintain records of qualified personnel in accordance with app!icable codes, standards, specifications, and vendorpurchase order / contract requirements. O QAP - 9.0 Rev.: 19 Change 01 Date: 7/15/98 Page 1 of 2
The department that is contracting services is responsible for the review of records of qualified personnel, equipment and procedures associated with special processes. The Nuclear Oversight Department shall provide an oversight function via audits, surveillance, or inspections, as appropriate. The Nuclear Overs / phi Department is responsible for assuring the training, testing, and certification of all the Afflisione 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.
' 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 O- data, and personnel and equipment qualification records associated with the performance of special processes at Station nuclear power plants, are kept current and maintained in appropriate NNECO files, with final disposition to the Station Nuclear Document Services Facility. I I l
. .O V QAP - 9.0 Rev.: 19 Change 01 Date: 7/15/98 Page 2 of 2 1
t
- 10. INSPECTION O 10.1 GENERAL REQUIREMENTS This NUQAP provides measures to assure that inspections of Afilistone Station nuclear l power plants quality structures, systems, and components to verify conformance 1 with documentedprocedures, instructions and drawings are executed in accordance l 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 f provided. Inspection notification and hold points are identified, as required, in the l applicabledocuments.
10.2 IMPLEMENTATION 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., receipt inspection, j installation, and product acceptance) to assure quality requirements are met. l Nuclear Oversight shall perform, as appropriate, audits and surveillance \ as deHne
- In Nuclear Oversight procedures to verify that procedural
/~ requireme. , are met.
The Nuclear Oversight Department shall perform inspections of modiHcation and maintenance activities for quality structures, systems, i 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 identlRed in Nuclear Oversight procedures. The Nuclear Oversight inspection function includes: l
- a. Identification of inspection personnel; i
l b. Review of work procedures and work documents for adequacy of t inspection and mandatoryholdpoints; !
- c. Preparation and approval of inspection plans ensuring that the necessary
( inspection requirements, methods, and acceptance criteria have been i identifed;
- d. Documentation of inspection results.
O QAP - 10.0 t I Rev.: 19 Change 01 Date: 7/15/98 Page 1 of 4
m Nuclear Materials and Document Management is responsible for the I performance of offsite audits, surveillance, and inspections, as appropriate, to verify that any vendor utilized to perform quality activities for the Station f nuclear power plants are effectively complying with their quality assurance program requirements for inspection and for the performance or witnessing of inspections at hold or notification points identified in procurement documents. Nuclear Oversight performs audits, surveillance, 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. 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 surventances are performed by the Nuclear Oversight Department, as appropriate, to verifythe implementation of the inspection plans. The inspection criteria, including the use of inspection equipment and their i accuracy requirements, are specified in the work procedures, work documents, orinspection plans. G.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 qualifed , and/or certified in accordance with appropriate codes, standards, and/or NU i training programs; insp7ctions are performed by Nuclear Oversight Department personnel, qualified contracted personnel, and NUSCO/NNECO personnel who are independent from l 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 QAP - 10.0 Rev.: 19 Change 01 Date: 7/15/98 Page 2 of 4
surveillance, as appropriate, to verify other department compliance with \O these requirements. When vendors are contracted to perform onsite inspection services, their quality controlinspection plans / procedures are reviewed and concurred with by Nuclear Oversightin accordance with QAP 5.0, " Procedures, Instructions, and Drawings". l Access to drawings, procedures, specifications or other documented criteria necessary for the performance of inspections is provided prior to performing the inspection activity. 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 O required accuracy of this equipment;
- d. Acceotarice criteria;
( e. A description of the method of inspection when other than direct visual examinationusing 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 alternatives. 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 identiMed to assure attributes O QAP - 10.0 Rev.: 19 Change 01 Date: 7/15/98 l Page 3 of 4
i 1 [% ( critical to achieving quality requirements at work completion have been ver/ fled. 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 point and notification points, as required, are identified in i procurement documents and onsite work procedures / work documents. l Procurement documents and onsite work procedures / work documents are ' subject to the review and concurrence for adequacy of inspection, notification and/or mandatory hold controls by Nuclear Materials and Document Management and Nuclear Oversight, respectively. , 10.2.6 INSPECTION RESULTS EVALUATION l Inspection results are evaluated for acceptability in accordance with applicable procedures which identify the responsible organization. The evaluations are performed by the personnel who are qualified in accordance ) with the appropriate regulatory guide and endorsed ANSI standard listed in l Appendix C. l i Nuclear Oversight performs audits and surveillance, as appropriate, to ver/fy that inspections are performed in accordance with the requirements of
/O applicable procedures.
b i j O QAP - 10.0 Rev.: 19 Change 01 Date: 7/15/98 Page 4 of 4
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, and components be established to assure that they will perform satisfactorily in service and that test results are documented in accordance with applicable 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 personnelto 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 willbe satisfactoryduring operation. 11.2 IMPLEMENTATION 11.2.1 TEST PROGRAM O 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, I 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 g original test results are invalidated. NUSCO/NNECO procedures delineate the methods and responsibilities for l controlling, accomplishing and documenting testing of the Station nuclear powerplants quality structures, systems, and components. Vendors utilized to perform quality activities for the Station nuclear power plants 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. Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillance, and inspections, as appropriate, to verify the performance of selected proof tests when hold points have been identified in purchase order / contracts and to verify these vendors are complying with their quality 7 assurance program requirements for test control. Nuclear Oversight performs audits, surveillance, and inspections, as appropriate, of onsite vendor QAP - 11.0 Rev.: 19 Change 01 Date: 7/15/98 Page 1 of 3
I p acdvides in Urls area. Nuclear Materials and Document Management and d ~ Nuclear Oversight are responsible for assuring documentation associated with Usese verMcation. acdvities are maintained in the appropriate files undl forwarded to the Stadon Nuclear Records Facility in accordance with l applicable procedures. Proof tests, product acceptance tests, post maintenance or, modMcation tests, and periodic surveillance tests are conducted by qualifed personnel in accordance with applicable procedures. Personnel performing tests assurgthat 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 Stadon 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 follov/ing as a minimum:
- a. Instructions for the testing method used;
- b. Required test equipment and instrumentation;
- c. Test requirements, such as acceptance criteria;
- d. Hold, notification, inspection points, if required, and data collection points; I
l-
- e. . Test prerequisites such as: calibrated instrumentation; trained, qualified, and licensed or certified personnel; preparation, condition and l 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
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l A () 11.2.3 TEST EQUIPMENT NUSCO/NNECO procedures provide the criteria for determining when a test is l 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 accordancewith NUSCOINNECO procedures; l
- 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;
- c. Where specialinstrumentationis required for testing, the requirements are 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 results are evaluated against the predetermined acceptance criteria by an individual or group having appropriate qualifications. i O The acceptance status of the test is documented. Deficiencies noted during the L evaluation are documented and dispositioned in accordance with procedures. The evaluation of test results may also be delegated to vendors. When l delegated, the vendor is required to assure the use of qualified personnel, evaluate the data against predetermined criteria and document the results of the l evaluation and acceptance status of the test. Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillance, and inspections, as appropr/ ate, to verify that these vendors are effectively complying with their quality assurance program requirements for test control. Nuclear Oversight performs audits, surveillance, and inspections, as appropriate, of onsite vendor activities in this area. l l l O QAP - 11.0 Rev.: 19 Change 01 Date: 7/15/98 Page 3 of 3 J
l l t p 12.0 CONTROL OF MEASURING AND TESTING EQUIPMENT V 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, l 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. Documentationis retained such that all items of M&TE are traceable to their { l calibration records. 12.2 IMPLEMENTATION l ! l
- 12.2.1 CALIBRATION PROGRAM I
Procedures delineate the methods and responsibilities for the control, maintenance j and calibration of M&TE including portable and temporarily installed instruments, l tools, gages, fixtures, reference and transfer standards, and nondestructive test l equipment. l l Documentation associated with the calibration of all M&TE is maintained in appropriate files and retained as quality records in accordance with the NU l O Nuclear Records Program. When the information for the control, use, and O calibration of M&TE is in electronic form, this information is controlled and protectedin accordance with applicable procedures. l The calibrationprocedures in NUSCOINNECO programwhich is implemented in accordance describe the measures with the requi utilized to maintain l 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 PORCISORC or the Station Qualified Reviewer Program, as defined in appIlcable 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 conformance with the requirements of procurement documents. Nuclear Materials 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 l procedures. The Nuclear Oversight Department performs audits, surveillance, and inspections, as appropriate, to verify implementation of the calibration program. O QAP - 12.0 l Rev.: 19 Change 01 I Date: 7/15/98 Page 1 of 2 l
Vendors utilized to perform quality activides for the Stadon nuclear power plants O are responsible for implementing measures for the control of M&TE to assure the M&TE are properly calibrated, adjusted and maintained at specified intervals in order to maintain accuracy within required limits. Nuclear Materials and Document Management is responsible for the performance of offsite audits, surveillance, and inspections, as appropriate, to verify these vendors are effectively complying with their quality assurance program requirements for control of M&TE. Nuclear Oversight performs audts, surveillance, and inspections, as appropriate, of onsite vendoracdvides in this area. 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 idendtication number and the date calibrated and next calibration date indicated on the MSTE. ' 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. O 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 Egceptance is documented and authorized by the SORC/PORC. In addition, the Nating Andards 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 condtion 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.
I O QAP - 12.0 Rev.: 19 Change 01 i Date: 7/15/98 Page 2 of 2 l
L p 13.0 HANDLING. STORAGE AND SHIPPING l 13.1 GENERAL REQUIREMENTS l This NUQAP provides 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. 112 IMPLEMENTATION i 13.2.1 GENERAL l 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 I 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 ,O handling, storage, shipping, cleaning and preservation of materials, equipment and parts to preclude damage, loss or deterioration. Nuclear Materials and Document Management is responsible for the performance of offsite audits, l surveillance, and inspections, as appropriate, to verify that these vendors are l effectively complying with their quality assurance program requirements for handling, storage, shipping, cleaning and preservation of materials, equipment I and parts. Nuclear Oversight performs audits, surveillance, and inspections, as appropriate, of onsite vendor activities in this area. 13.2.2 ESTABLISHMENT OF SPECIAL HANDLING. STORAGE. SHIPPING. CLEANING AND PRESERVATION REQUIREMENTS t l. 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. I l NUSCO/NNECO procedures describe the measures taken for the storage of j chemicals, reagents (including control of shelf life), lubricants, and other consumable materials. O O OAP - 13.0 Rev.: 19 Change 01 Date: 7/15/98 Page 1 of 1 w___---__________________-____-_-______________
14.0 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 1 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 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. Nuclear Materials and Document Management is responsible for the performance of offsite audits, O surveillance, and inspections, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for identification of inspection and test status. Nuclear Oversight performs audits, surveillance, and inspections, as appropriate, of onsite vendor activities in this area. 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. 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 ordericontract requirements with the exception of nuclear fuel assemblies, and bulk hydrogeninitrogen for Millstone Power Station Unit No. 3 for which traceability is maintained by Reactor Engineering, and Millstone Power Station Unit No. 3 Operations respectively.. Nonconforming materials, equipment and parts are identified in accordance with QAP 15.0,
" Nonconforming Materials, Parts, Components, or 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. QAP - 14.0 Rev.: 19 Change 01 Date: 7/15/98 Pageiof2
i l r~ t i\ i. l NUSCO/NNECO procedures describe the measures taken to control the altering of the sequence of required tests, inspections and other operations. and approval for these actions is subject to the same control as taken during the original review and approval of tests, inspections and other operations. 14.2.2 STATUS IDENTIFICATION AND CONTROL l l 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 l operation, and to preclude omission of inspections, tests or other critical l 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. I l l l ( l O QAP - 14.0 i Rev.: 19 Changc01 l Date: 7/15/98 Page 2of 2 i l
l l 15.0 NONCONFORMING MATERIALS. PARTS COMPONENTS OR SERVICES 15.1 GENERAL REQUIREMENTS i i This NUQAP requires the documentation and control of nonconforming materials, parts, i components, or services be performed in accordance with procedures to prevent inadvertent use or installation in Millstone Station nuclear power plant quality structures, systems, or components. These procedures include requirements for identification, documentation, segregation and disposition of nonconforming items; and l notification to affected organizations. i L 15.2 IMPLEMENTATION 15.2.1 PROGRAM Procedures define personnel responsibilities and establish various measures for i identification, documentation, segregation, review and disposition of l nonconforming item reports. The means for reporting nonconforming items are available to all NU and vendor personnel assigned at the Millstone Power i Station and other personnelinvolved with Station quality activities. \ f l 15.2.2 DOCUMENTATION 'O Documentation of nonconforming items requires identification of the items, description of the nonconformance, disposition of the nonconformance, 1 inspection requirements and signature approval of the disposition. Tagging systems are utilized to physically identify nonconforming items prior to installation. Nuclear Materials and Document Services utilizes tags for received materials, parts and components. 15.2.3 EVALUATION AND DISPOSITION Evaluations are performed to determine the disposition of nonconforming items and services. The evaluation determines whether an item or service is to be l used as is, retumed to vendor, repaired, reworked, scrapped or salvaged. An l l engineering evaluation is performed, if necessary, prior to the resolution of i nonconforming conditions. In addition, nonconformances are evaluated l 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 i 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. QAP - 15.0 ( Rev.: 19 Change 01 l Date: 7/15/98 Page 1 of 2 ,
j(p/ The need to release /use nonconforming materials, parts or components shall be based on such considerations as: i
- a. Impact on plant safety;
- b. Safety of personnel;
- c. Suitability of items in the "as is" condition, i.e., probability of eventual i
satisfactory resolution of the nonconforming condition without repair, j rework or replacement. l d. Accessibility of items after release;
- e. Cost of removal and repair or replacement should items eventually have to be removed, repaired, or replaced;
- f. Effect on the orderly progress of work.
l Items repaired are verified by inspecting the items as originally inspected or by l a documented method which is equivalent to the original inspection method. Items reworked may require inspection to verify conformance to requirements as defined in applicable procedures. l l rN Nuclear Oversight performs audits and surveillance, as appropriate, to verify l C that dispositions for reports documenting nonconforming conditions are adequate.' l l 15.2.4 RECURRENCE CONTROL j A trend analysis of nonconforming conditions documenting l l 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 describedin QAP 16.0, Corrective Action. l O QAP - 15.0 Rev.: 19 Change 01 Date: 7/15/98 Page 2 of 2
l 1 l i
/ 16.0 CORRECTIVE ACTION I 16.1 GENERAL REQUIREMENTS 1
This NUQAP requires that an effective corrective action program be established to assure i that conditions adverse to quality at the Millstone Power Station are promptly identified, I corrected, and documented in accordance with procedures. These procedures include measures for reporting to appropriatelevels 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. 16.2.2 CORRECTIVE ACTION AND FOLLOW-UP l 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 and Recovery OMcers are responsible for assuring their assigned personnel and their vendors working onsite comp ly 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 surveillance, as appropriate, to verify that other departments and their onsite l
vendors comply with the corrective action program and that corrective action is adequate and properly implemented in a timely manner. Nuclear Materials and Document Management ensures audits, surveillance, and inspections, as appropriate are performed of offsite vendors to assure they comply with l their corrective action program and that corrective action is adequate. The President and Chief Executive OMcer - NU Nuclear Group has the final l authority in the ever;t that agreement on the action to be taken is not reached at lower levels of the nuclear organization. I i OAP - 16.0 I Rev.: 19 Change 01 Date: 7/15/98 . Page 1 of 2 l !
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 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 l assurance program for review. Adverse trends conceming specific vendor performance shall be reported to the affected vendor for resolution and recurrence control, as appropriate. l n( QAP - 16.0 Rev.: 19 Change 01 Date: 7/15/98 Page 2 of 2 l {
17.0 QUALITY ASSURANCE RECORDS 17.1 GENERAL REQUIREMENTS l This NUQAP requires the maintenance, identification, retention and retrieval of records to i furnish evidence of quality activities performed for the Millstone Station nuclear power plants be implemented /n 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 l 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 retention such as duration, location and assigned responsibility. 17.2 l 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. Vendors utilized to perform quality activities for the Station nuclear power plants are responsible to implement measures for identification, maintenance, retention, retrieval and tumover to #NECO of documented and approved records which contain objective evidence of quality as specified in purchase orders / contracts. Nuclear Materials and Document Management is responsible for the per16tmance of offsite audits, surveillance, and inspections, as appropriate,to verify that these vendors are effectively complying with their program for quality assurance records. Nuclear Overs /phtperforms audits, surveillance and inspections, as appropriate, of onsite vendor activities in this area. ' NUSOO/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 structwe, system, or component is not practical, records are filed by category (e.g., specification, nonconformance reports, audits, etc.). i' QAP - 17.0 Rev.: 19 Change 01 l Date: 7/15/98 I Page 1 of 2 1 1 e--_____--_-_- _ _ - _ _ _ _ _ _ _ _ _ _ _ _
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 records 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 I the life of the particular component or part. in instances where more than one #consing , basis documentspeclMes a recordretendon requirementand they are diWerent(e.g. l QA Program commitment versus Unit Technical SpeclRcations) the more restricdve 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; i-l 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 r3 StsWon Nuclear DocumentRecords Facility. The responsibilityof the Nuclear Document V Services Facility upon receipt of records is to maintain and provide controlled retrievability of records affecting the SesWon 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 app # cable procedures.
I i O QAP - 17.0 ! Rev.: 19 Change 01 Date: 7/15/98 Page 2 of 2
! l l l l l L 18.0 AUDITS l 18.1 GENERAL REQUIREMENTS l i l This NUQAP requires that a comprehensive system of planned and periodic audits shall i be carried out to verify that quality activities for Millstone Station nuclear power l l ' plants are' performed in compliance with this NUGAP and to determine the l eMectivenessof the program. i Audits are conducted in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilitiesin the areas being audited. 1 (
- 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 I audit findings revealed by the audit.
- l. 18.2 IMPLEMENTATION 18.2.1 PROGRAM I
, The audit program requires audits of Corporate and Station nuclear power l plant quality activities under the oversight of the Nuclear Safety Assessment I Board. Audits are performed on activities where the requirements of 10 CFR 50, i l Appendir 8 and respective nucteer unit Technical Specifications are being l implemented. In addition to those activities, audits are performed on areas l associated with indoctrination and training programs, interface control among NNECO and vendors, and the Nuclear Materials and Document Management procurement function. Audits are regularly scheduled on the l basis of the status and safety importance of the activities being performed. L Regularly scheduled audits are supplemented by audits for one or more of the l- following conditions
- i L a. When significant changes are made in functional areas of the quality l l assurance program, such as significant reorganization or procedure revsons- -
- 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 considered necessary; i
- d. When necessary to verify implementation of required corrective action.
I 1 O QAP - 18.0 l i Rev.: 19 Change 01 Date: 7/15/98 Page:1 of 3 l
Schedules for the audit of Corporate, Station, and onsite vendor quality activities are originated and maintained by the Nuclear Oversight Department. l 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 l documents and records to determine the effectiveness of implementation and i conformance to this NUQAP. J I 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 and for the performance of subsequent offsite audits, as appropriate, to verify that these vendors are effectively l complying with their quality assurance requirements. Nuclear Overs /pht performs audits of onsite vendors, as appropriate, to verify that these vendors are effectively complying with their quality assurance l requirements. i in addition to the audits, other methods, such as surveillance and inspections are used to assure that quality activities are in compliance with this NUQAP. ' 18.2.2 REPORTING OF AUDIT RESULTS ; Audit results are reviewed, approved, and reportedin accordance with Nuclear I Oversight Department and Nuclear Materials and Document Management l \ procedures, as applicable. The audit reports are issued to the appropriate l management of the area audited to assure appropriate and/or timely corrective ! action is taken to address conditions adverse to quality identiRed by the l audit findings. In addition, audit data and reports are accumulated as part of the ! review for quality trends and assessed to assure the effectiveness of this NUQAP. 18.2.3 REVIEW. ACTION. AND FOLLOW-UP OF AUDIT FINDINGS , 4 Audit findings that involve conditions adverse to quality are reviewed and l t-Investigated by the management having the responsibility for the area audited. I The responsible management is required to take the necessary action to address any conditions adverse to quality identified by the audit and; report the results of such reviews and investigations, take the necessary actions to l correct problems reported, and report the completion of corrective action within speclRed time frames. O QAP - 18.0 Rev.: 19 Change 01 Date: 7/15/98 Page:2 of 3 i
O < Follow-up of audit findings involving conditions adverse to quality is l performed by the auditing organization as necessary to verify appropriate actions have been taken to resolve audit findings. Items which cannot be resolved by affected management are submitted for resolution to the President and Chief Executive Officer- NU Nuclear Group. 18.2.4 RECORDS / REPORTS OF AUDITS Audit records, reports, and associated documentation are retained in the l Station Nuclear Document Services Facility, as specified in applicable procedures.
,O V
I 1 I l LO QAP - 18.0 Rev.: 19 Change 01 l Date: 7/15/98 Page: 3 of 3 L__________________.
p APPENDIX A
'J NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT- MILLSTONE POWER STA TION 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-relatedand designatedas CategoryI. 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 Regulatory Guide 1.70. (a) The reactor coolant pressure boundary. (b) The reactor core and reactor vesselintemals.
, (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 (e.g., hydrogen removalsystem). (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 l 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 l 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, j (g) Cooling water, component cooling and auxiliary feedwater systems or portions of these t 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) coo!ing the spent fuel storage p pool. Y QAP- Appendix A I Rev.: 19 Date: 6/24/98 Page 1 of 3 L______________..___.___ __
I (h) Cooling water and seal water systems or portions of these systems that are required for 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 responding 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 accomplishmentof the specified safety function.
(1) 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 environmentallimits for vital equipment.
-(o) Primary and secondary reactor containment.
l (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. l (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 l items (a) through (q) above to an unacceptable safety level or could result in incapacitating i injury to occupants of the control room should be designed and constructed so that the SSE l would not cause such failures. I (s) Items and services associated with Radioactive Material Transport Packages as described in 10CFR71. O QAP- Appendix A Rev.: 19 Date: 6/24/98 Page2 of 3
l 1
,eq CONSUMABLES l V
The following specific consumables when utilized in safety-related systems shall be included in those portions of this NUQAP, as applicable. l
- 1. Emergency generatordieselfuels
- 2. Hydraulic snubberfluids
- 3. Reagents
- 4. Resins j
- 5. Boric Acid
- 6. Lubricants l
- 7. Gas Turbine Fuel l
- 8. Bulk Hydrogen (For Millstone Power Station Unit No. 3) '
i
- 9. Bulk Nitrogen (For Millstone Power Station Unit No. 3)
O I QAP - Appendix A Rev.: 19 Date: 6/24/98 Page 3 of 3
p a APPENDIX B NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP) TOPICAL REPORT- MILLSTONE POWER STATION QUALIFICATION AND EXPERIENCE REQUIREMENTS RECOVERYOFFICER - NUCLEAR OVERSIGHT l l The Recovery Officer- Nuclear Oversight shall satisfy the fol!owing l
. requirements:
l l Graduate of a four-year accredited engineering or science college or university, plus fifteen (15) or more years of industrial experience includirg five years in positions of leadership, such as lead engineer, project engineer, Audit team j 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 equivalentto two years of experience. > 13 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. l l J l l[ QAP- Appendix B Rev.: 19 Change 01 , Date: 7/15/98 l l Page iof1
APPENDlX C NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM /NUQAP) TOPICAL REPORT- MILLSTONE POWER STATION REGULATORY GUIDE AND ANSI /lFFF STANDARD COMMITMENTS I 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. , I 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 R - 5/77 - Personnel Selection and Training - Endorses ANSI N18.1 - 1971. O t, l Regulatory Guide 1.28 - 2/79 - Quality Assurance Program Requirements (Design and Construction) Endorses ANSI N45.2-1977. Regulatory Guide 1.30 - (Safety Guide 30), 8-11 Quality Assurance Requirements for l the Installation, inspection, and Testing of Instrumentation and Electrical Equipment- i Endorses ANSI N45.2.4-1972. I
. Regulatory Guide 1.33 - 2/78 - Quality Assurance Program Requirements (Operation)-
Endorses ANSI N18.7-1976/ANS3.2. l 1 L Regulatory Guide 1.37 - Quality Assurance Requirements for Cleaning of Fluid Systems -l l and Associated Components of Water-Cooled Nuclear Power Plants,3-16 Endorses
. ANSI N45.2.11973.
L Regulatory Guide 1.38- Quality Assurance Requirements for Packaging, Shipping, l Receiving, Storage and Handling of items for Water-Cooled Nuclear Power Plants, 5/77 - ) Endorses ANSI N45.2.2 - 1972. QAP - Appendix C Rev.: 19 i Date: 6/24/98 Page 1 of 2 l _ _ -_-_=____._____________-__-___-__-__-___
Regulatory Guide 1.39 - Housekeeping Requirements for Water-Cooled Nuclear Power Plants,9/77 - Endorses ANSI N45.2.3-1973. Regulatory Guide 1.58 - Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel, Rev.1, 9/80 - Endorses ANSI N45.2.6-1978. 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 udllzed liar Millstone Power Stenon Unit No. 2; however, certeln revised secdons are written to the Revision 3 format 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 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. l 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 Assuratice 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 g . 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 Digilat Computers in Safety Systerns of Nuclear
- Power Plants", January 1996 - Endorses IEEE ANS 7 - 4.3.2 - 1993.
i QAP - Appendix C l Rev.: 19 Date: 6/24/98 Page 2 of 2 _ _ _ _ _ __ ____._m____.-___ _ _ _ . __.____.m- _ _ _ . _ _ _ _ _ . _ . _ _ _ _ __m_._________ _ . _ _ ____ _ __ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ __.a
l L APPENDIX D NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP) TOPICAL REPORT- ntILLSTONEPOWER STATION GLOSSARY OF QUALITY ASSURANCETERMS l ! A' ccoot As is- (also known as "Use-As-Is") A disposition which may be imposed for a l 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 l requirements including performance, maintainability, fit and safety. 1 [ Aaproved Vendors - Vendors approved to provide material, equipment, parts or services i~ 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. ,t A_ydt- A formal, documented activity performed in accordance with written procedures or checklists to verify by evaluation of objective evidence thPi a quality assurance program has been developed, documented, and implemented in accordance with applicable requirements. Auumented Quahty - Nonsafety-relateditems for which a design basis nr 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 Protecdon Quality Assurance), RWOA (Radweste Quality Assurance),' ATWS (Anticipated Transient Without i Scram) and SBOQA (Stadon Blackout Quality Assurance). ! l: Ce;ibret;ca - The process by which measuring and test equipment are checked against standards of known higher accuracy and adjusted as necessary to assure their compliance with designated specifications. l Cateoorv i - Designation given to safety-related structures, systems, and components (SSC) of a i Northeast Utilities n'uclear power plant and material, equipment, parts, consumables, and ! services applicable to the safety-relatedfuncdons of these SSCs. j CMaaorv i Structures. Systems and Components - Defined in each unit FSAR and functiona#y l describodinAppendixA. l I O QAP - Appendix D Rev.:19 Change 01 l Date: 7/15/98 L Page 1 of 7
-. 2-__.___________ . _ _ _ _ _ _ _ _ _ _ _ _
iO 'O Cleanina - Those actions performed to maintain an item in accordance with cleanliness requirements. l Commercial Grade Item (CGI) - A commercialgrade item per 10CFR21 is a structure, system, or component orpart thereof that affects its safety fun: tion that was not designed andmanufacturedas a basic component. Commercialgradeitems do notinclude items where the design and manufacturingprocess require in-process inspections and I veri 6 cations to assure that defects or failures to comply are identifiedand corrected (i.e., one or more criticalcharacteristics of the item cannot be verified). Commercial Grade Survev - Activities conducted by the purchaser to ascertain and verify that a l supplier or manufacturer of commercial grade items, controls the technical and quality l characteristics determined to be critical for satisfactory performance of specifically designated commercialgrade items, as a method to accept those items for safety-related use. Condition Adverse to Quality - Failures, malfunctions, deficiencies, deviations, defective materials and equipment, abnormaloccurrences and nonconformances. l l 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. Department - 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 j l 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 Documents - The drawing, calculation, specification, or other document (s) that define the technical requirements of structures, systems, or components. ! Enaineerina Service Organization - Organizations that provide services such as analysis, j computer software, testing, and inspection. l l Handlina - An act of physically moving an item by hand or by mechanical machinery, but not includingtransport modes. l 1 QAP - Appendix D Rev.:19 Change 01 Date: 7/15/98 Page 2 of 7 ( E
A V 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 j other appropriate means. 1 Item - Any level of unit assembly, including structures, systems, subsystems, subassembly, component, part, or mt'erial. i inspection - A phase of quality control which, by means of examination, observation, or i measurement, determines the conformance of material, supplies, components, parts, appurtenances, systems, processes, structures, or services to predetermined quality requirements, insoection Status - Identification of material, equipment, and parts that have completed inspection, { eitheracceptable or unacceptable. Licensina Basis - The set of requirements that includes the applicable NRC regulations, plant - specific NRC requirements, plant - specific design basis and regulatory I commitments that are docketed and in effect. 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 j component or part. Life records are those which would be of significant value in meeting one or more of the following criteria: O (1) demonstrating capabilityfor 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. l ntaterial Reauest - A formal electronic request for the purchase of material, equipment, parts andforservices. M_easurina and Test Eauipment - Those instruments, gages, tools, fixtures, reference and transfer standards, nondestructive test equipment, and measuring devices used during inspection and i testing to determine that the measuring and test parameters comply with appropriate , requirementsin specifications and drawings. I 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 than the lifetime of the in-service nuclear power plant or the particularcomponent or part. C) .
~(/ QAP - Appendix D Rev.:19 Change 01 Date: 7/15/98 Page 3 of 7
I 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 Comnany (NNECO) - The Northeast Utilities Power Operating { Companyresponsible for the operation of the Millstone Station nuclearpowerplants. Northeast Utilities Service Company (NUSCO) - A wholly owned subsidiary of Northeast Utilities , that provides support engineering, purchasing, and quality assurance services for the Millstone I Station nuclear power plants. Northeast Utilities Quality Assurance Prooram (NUQAP)- Millstone Power Station - Consist of this NUQAP Topical Report, Nuclear Oversight Department procedures and other NUSCO/NNECO Group / Division / Department / Branch /Section/Unitquality procedures. * , Nuclear Document Services - The organization responsible for establishing the Corporate Nuclear 4 Plant Records Program which is implemented at each Nuclear Document Services Facility. Nuclear Grade - The procurement classification applied to all materials and services intended for items listed as CategoryI(CAT I) in the MEPL. These may require validating documentation i such as Certificate of MaterialTest 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 p under a 10CFR50, Appendix B program with the vendor responsible for 10CFR21. The vendor
- should be an " Approved Vendor".
1 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 i Program. i Objective 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 /materialrequests, purchase orders, contracts, drawings, specifications or instructions used to define requirements forpurchase. 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. { t , I l Cq QAP - Appendix D , Rev.: 19 Change 01 Date: 7/15/98 Page 4 of 7
O Purchased Material. Eouioment. and Parts (MEP) - Items procured for installation in the Afilistone Station nuclear power plants quality structures, systems, and components, and items procured as spare MEP for potentialinstallationin 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 otherregulatedprograms to which this NUQAPis applicable. Quality Assurance Records- Any record pertaining to the quality of material, equipment, parts, processes, or operatior's 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 Comoonents - Structures, syuems, and components (SSC) including Safety-Related SSCs, Augmented Quality items, and items under other p regulatedprograms to which this NUQAPis applicable. ,, I 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 l 1 processes so that they are suitable for their intended purpose but may not meet all specified requirements. Reoortable item - An event or condition that could affect nuclearplant safety and must be l reported to the NRC in accordance with regulatory requirements such as,10CFR50.72, 1 10CFR50.73, or 10CFR50.9(b). Responsible Enoineer- A NNECO employee assigned the responsibility to coordinate the engineering activities addressed in NUQAP. The responsible engineermay be designatedas theprojectengineer. 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 funcuon satisfactorily when in operation. A retest may also be performed when original test results are invalidated.
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QAP - Appendix D Rev.:19 Change 01 Date: 7/15/98 Page 5 of 7 i L_.--- _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - -
I Retum to Vendor - A disposition applied to nonconforming material, equipment, and parts that xO are unsuitable for their intended purpose but which are feasible to repair or rework at a vendor's facility. 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 engineering requirements but which are modified through the use of additional operations or processes to meet all specified requirements. Safety-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) Theintegrityof the reactorcoolantpressureboundary;
- 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.
Significant Condition Adverse to Quality - A condition adverse to quality involving actual or potential consequences that a serious impact on public or personnel health and safety or plant operations, and requiring a root cause evaluation to determine corrective action to prevent recurrence. Special Processes - Processes for which the desiredlevel 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 qualified 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 de#nedin 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. Storaoe - 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 Afillstone Power Station or vendor's site to assure compliance with app @able codes, standards, specifications, procedures, drawings, and procurement documents. Surveillance may be performed with a prepared checklist. QAP - Appendix D Rev.: 19 Change 01 Date: 7/15/98 Page 6 of 7
O Test and Operatina Status - Identification of material, equipment, and parts that are ready for test or operation, or an existing stage of a test operation. Testina- The determination or verification of the capability of an item to meet specified i requirements by subjecting the item to a set of physical, chemical, environmental, or operating ! conditions.
)
' l Verpciors - Organizations that provide material, equipment, parts, computer software, or l services. This includes contractors, engineering service organizations, and consultants. (Synonymous with " Supplier"in this NUQAP) l Work Procedures and Work Documents - Procedures, instructions, and documents used to \ control and document maintenance and modi 6 cation work performed on Millstone Station nuclearplant structures, systems, and components. O I i O QAP - Appendix D Rev.: 19 Change 01 Date: 7/15/98 i Page 7 of 7 I
/ APPENDIX E NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM (NUQAP)
TOPICAL REPORT- MILLSTONEPOWER 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.
- 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.
) No more than a minority of the quorum shall have line responsibilityfor operation of one of v Northeast Utilities' nuclear units. No more than two altemates shall be appointed voting status at any meeting in fulfillment 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 considered a quality assurance record when the document has been completed." ,
Northeast Utilities has developed the following alternative 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 documentsto the NDSF: Operations Documents - Documentation generated during plant operations may be maintained, as needed, by operating plant departments, for up to one year. (v'3 QAP - Appendix E Rev.: 19 Date: 6/24/98 i Page 1 of 5 l l L______._____. _ _ _ _ _ . _ _ _ _ _ _ . _ . _ _ ._ _.
l New Construction or Betterment Documents - Documents which evolve during new construction or betterment projects shall be transmitted to NDSF within 90 days of L completion of a new construction project or tumover of a betterment project or plant operations. l Procurement Documents - Inspection / Surveillance /AuditReports generated'during vendor oversight activities which are used to maintain vendor status for current and !; ~ future procurement 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 N45.2.9-1974 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 ;.eparai.ac of the records nor to include working documents not yet designateo as Quality Assur,.nce Records."
- 4. Reaulatorv 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 independentdesign verification-This review may be performed by the originator's 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; is the only individualin the organization competent to perform the review. Where the Supervisor performs the design review, the next level of management shall fulfill the Supervisor's responsibilities.
- 5. ' ANSI N45.2.13 - 1976. paragraph 10.3.4, states in part, " Post-Installation Test requirements and acceptance documentation (should) shall be mutually established by the purchaser and supplier." Involvement by the supplierin establishing Post-InstallationTest requirements and acceptance documentation is requested only when it is deemed necessary and proper by the responsible engineering organization.
Northeast Utilities no longer has any nuclear plants under construction. As a result, most procurement 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
/'
QAP - Appendix E Rev.: 19 Date: 6/24/98 Page 2 of 5
1 6 l p knowledge of either the operation of the system the component is to be installed in, or ( applicable Post-InstcIlationTest requirements and acceptance documentation. As such, Northeast Utilities assumes responsibility for establishing Post Installation Test requirements and acceptance documentation.
- 6. ANSI N45.2.2-1972, paragraph 1.2, states in part that, "The requirements of this standard 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 4 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 commensuratewith the nature of the product.
- 7. ANSI N18.1-1971. paragraph 4.2.2, states in part "The Operations Manager shall hold a l Senior Reactor Operator's 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
(}m Millstone Unit No. 3, then the Operations Managershall have held a Senior Reactor Operator license at a pressurized water reactor, and the Assistant Operations
- Manager shall hold a Senior Reactor Operatorlicense for Millstone Unit No. 3.
- 8. ANSI N18.1-1971, paragraph 4.2.2, states in part "The Operations Manager shall hold a l Senior Reactor Operator's license". NU has developed an attemative to this requirement ]
which has been accepted by the NRC via amendment 190 for the Millstone Power l 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 Managershall have held a Senior Reactor Operator license at a pressurized water reactor, and an Individual serving in the capacity of the Assistant Operations Managershall hold a Senior Reactor Operator license forMillstone Unit No. 2. I O V QAP - Appendix E Rev.: 19 Date: 6/24/98 Page 3 of 5 l I L-----___-_-_____--__.__
i 1 l
- 9. Reaulatory Guide 1.33 - 2/78. regarding audits, states in part:
(a) "The results of actions taken to correct deficiencies...atleast once per 6 months." (b) "... technical specifications 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 alternative which modifies these Audit frequencies to at least once per 24 months. This alternative has previously been accepted by the NRC via license amendments 79,184, and 104 for MP1, MP2, and MP3, respectively. <
- 10. ANSI N18.1-1971, paragraph 4.2.2, states in part "The Operations Manager shall hold a Senior Reactor operator's lirense." NU has developed an alternative to this requirement which has been accepted by the NRC via amendment 83 for the Millstone Power Station Unit No.1 license which allows that:
If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No.1, then the Operations Managershall have held a Senior Reactor Operator license at a boiling water reactor, and the Assistant Operations Manager shallhold a Senior Reactor Operatorlicense for Millstone Unit No.1.
- 11. ANSI N45.2.13-1976, paragraph 10.3.5., states in part, "in certain cases involving .
procurement of services only, such as third party inspection; engineering and { consulting services, and installation, repair, overhaul or maintenance work; the Purchasermay accept the service by any or all of the following methods: (a) Technical verMcation of the data produced (b) Surveillanceand/oraudit of the activity (c) Review of the objective evidence for conformance to the procurement document requirements such as certiHcations, 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 VerMcation Program. This work will be performed in accordance with the vendor's own approved,10 CFR 50 AppendixB QualityAssurarsceProgram.
- 12. Deleted. l QAP - Appendix E Rev. 19 Date: 6/24/98 Page 4 of 5
- 13. Regulatory Guide 1.70 Revision 3, November 1978 Section 17.1.2.4 states in part:
O "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, i procurement, construction, etc. The procedurelist shouldidentify which criteria of Appendix B to 10 CFR 50 are implementedby each procedure". NU has developed an alternative 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. ! l O l 4 QAP - Appendix E Rev.: 19 Date: 6/24/98 Page 5 oi6 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _}}