ML20082G322
| ML20082G322 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/10/1995 |
| From: | NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20082G308 | List: |
| References | |
| NUDOCS 9504130207 | |
| Download: ML20082G322 (91) | |
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0 NEBRASKA PUBLIC POWER DISTRICT ll u
1 COOPER NUCLEAR STATION i OUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT TABLE OF CONTENTS )
Corporate Policy Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v-1 1.0 PROGRAM DEFINITION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 j 1.1 Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1- 1 1.2 - ' Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -2
.1.3 Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4 1.4 Scope .... ............... ... . ..... . ...... . 1-6~
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-1.5 Definition of Terms . . . . . . . . . . -. . . . . . . . . . . . . .' . . . . 1-7 2.0
SUMMARY
DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 :
2.1 Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.2 Quality A'ssurance Program . . . . . . . . . . . . . . . . . . . . . . . 2-2 2.3 ' Design Control . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5 1 2.4 Procurement Document Control ................... 2-11 2.5 Instructions, Procedures & Drawings . . . . . . . . . . . . . . . . . 2-13 )
1 2.6 Document Control ............. ... ........... 2-14 1
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9504130207 950410 i Revision 10 l PDR ADOCK 05000299
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t TABLE OF CONTENTS (Cont'd) 2.7 Control of Purchased Material, Equipment, c'
and Services ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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? 2.8 Identification and Control of Parts, Materials,
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and Components ~ ............................-. 2-17 2.9 - Control of Special Processes - . .. ...... .... . ..... . . . 2-18 2.10 Inspection ..-............................... 2-19:
2.11 Test Control . ..............................2-20~
2.12 Control of Measuring and Test Equipment ............. 2-21.
2.13 Handling, Storage, and Shipping . . . . . . . . . . . . . . . . . . 2-22 2.14 Inspection, Testing, and Operating Status .............. 2-24 n 2.'15 Nonconforming Materials, Parts, or Components ......... 2 L 2.16 Corrective Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-26 2.17 Quality Assurance Records ....................... 2-28 ,
2.18 Audits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.19 Additional ANSI Standards ....................... 2 >
1 3.0 ORGANIZATION AND RESPONSIBILITIES . . . . . . . . . . . . . . . 3- 1 ' i i
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m 3.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 3.2 Nuclear Power Group Management ...... .... ..... .. . 3-2 3.2.1 Vice Prddent Production ..................32 3.2.} Vice President - Nuclear . . . . . . . . . . . . . . . . . . . . 3-2 1 i
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TABLE OF CONTENTS (Cont'd) d a
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j i~ 3.2.] Division Manager, Quality Assurance . . . . . . . . . . .-. . 2 -l 3.2.[ - Quality Assurance Operations Manager . . . . . . . . . . . . 3-4 3.2.[ Quality Assurance Assessment Manager: . . . . . .. . . . 3-6
- 3.2.[ Quality Assurance Supervisors . . . .. . . . . . . . . . . . 3-7 .
3.2.) Quality Assurance Staff . . . . . . . . . . . . . . . . . . . . 3-7 ,
3.2.[' Division Manager Nuclear Engineering and Construction 3-9
' 3.2.] Nuclear Fuel Manager ........ . .... ..... .. 3-10 .
3.2g Site Manager . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10 3.2.1) Plant Manager .. ... ...... .... .. . .... .. .. 3-10 3.2.1] Senior Manager - Site Support . . . . . . . . . . . . . . . 3- 1 1
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3.2.1) Senior Manager of Safety Assessment . . .<. . . . . . . . . 3 3.2.M Divhis 'fr.r.;;;r N;ckr.r Supper. ' . . . . . . . . . . . 3 11 :
3.2. Columbus General Office (CGO) Department Managers . 3-11 3.2.}] Cooper Nuclear Station (CNS) Department Manager . . . 3-12 3.3 Cooper Nuclear Station Personnel . . . . . . . . . . . . . . . . . 3-12 3.4 COO Personnel . . . . . . . . . .. .. . . . . . . . . . . . . . . . . . 3-12 3.5 Safety Review and Audit Board (SRAB) . . . . . . . . . . . . . . . 3-13 , 3.6 Station Operations Review Committee (SORC) . .- . . .. . . . . . . 3-13 3.7 Outside Suppliers, Contractors, Subcontractors,and Consultants . 3-13 L
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w4 3.. t n 1 1 s 3 TABLE OF CONTENTS (Cont'd)'
-f ^ - 4.0 QUAIJTY ASSURANCE DOCUMENTS . . . . . . . . . . . . . . . . . . . 4-11 t
4.1 - .NPPD Internal Documents ........................'4-1 . 4.1.1: Quality Control Inspection
...................4-2 4.1.2 Nuclear Quality Procedures (NQP) . . . . . . . . . . . . . . 4 ;
a- 4.1.3 Quality Assurance Plans (QAP): . . . . . . . . . . . . . . . 4 1 i
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5.0 METHOD OF IMPLEMENTATION . . . . . . . . . . . . . . . . . . . . . 5 : 6.0' RECORDS RETENTION AND' DISPOSITION ................6-1'
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7.0 REFERENCES
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-l 8.0 FIGURES ........................................-8-1 l 8.1 Quality Assurance Organizational Chart (Figure 1) . . . . . . . . . 8-1 9.0 . TABLES ....................................... 9-1 .!
9.1 Systems and Components Within Scope of the CNS QA Program (Table 1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-1 9.2 Four I.evel QA Program (Table 2) ..................9 1 i i
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-l CORPORATE POLICY STATEMENT i
This document establishes and describes the policies and practices of the. Quality J 4 Assurance Program applicable to the operation of the Cooper Nuclear Station and the support
' activities of all NPPD Nuclear Divisions. The District's policy with respect to nuclear safety
" and quality assurance is detailed in Section 1.2 of this document. , Each Nuclear Division is responsible for the development of policies and procedures l which implement this Quality Assurance Program. Other divisions and departments at NPPD may also have responsibilities under this program and shall comply as described in appropriate implementing procedures. The Safety Review and Audit Board, Station Operations Review Committee, and the' Quality Assurance Division shall monitor the District's nuclear program and provide management with evaluations and assessments regarding the effectiveness of the implementation r of the program. When evaluations and assessments identify a concern, management shall take J expeditious action to correct any undesirable condition (s) including, where appropriate, action ; to preclude repetition of such condition (s). District personnel shall have the organizational freedom to identify concerns and propose corrective and preventive action necessary to enhance the District's nuclear program. l
'l The assurance of safe and reliable operation of Cooper Nuclear Station is everyone's .j duty. Onlity shall be everyone's responsibility. ;
-i APPROVED- R President 33 Vice President - Nuclear -
'/in P;; A ; Prc.h;i= Division Manager - Quahty' Assurance l
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o + 3 I j c ~ 3x 1 COOPER NUCLEAR STATION : QUALITY ASSURANCE PROGRAM FOR OPERATION i I
, . POLICY DGCUMENT L
1.0 . PROGRAM DEFINITION q i b In accordance with the conditions of the Nuclear Regulatory Commission construction - permit-and operating license for the Cooper Nuclear Station, the ' management 'of , Nebraska Public Power District recognizes its responsibility for assuring that the Cooper ,
- Nuclear Station is designed, constructed, and operated in such a manner as to provide for the safety of the public. The importance of Quality Assurance in contributing to this _
safety as well as contributing to station reliability is also recognized. 1 The initial phases of the overall Quality Assurance Program, implemented during design - and construction, provided an independent check for the work performed on components, - structures, and systems of the station to assure that the design, analysis, materials of _ - construction, manufacture, installation, erection, and construction met quality standards required to assure reliable and safe operation. The CNS Quality Assurance Program for - Operation, as described herein, is implemented to provide an independent quality check on all phases of station operation, maintenance, and modification. 1.1 Purnose The purpose of this policy document is to provide a description of the Quality Assurance , Program to be followed during the operational phase of Cooper Nuclear Station and to f identify applicability of the policies and procedures described herein. This CNS Quality i Assurance Program for Operation was developed by Nebraska Public Power District in response to the requirements of 10CFR50, Appendix B. It provides a general description i of the Quality Assurance Program for Operation and requires that detailed instructions, j 1-1 Revision 10
n ~ M< 3 procedures, and drawings, as appropriate, be set forth in writing and carried out by each of the responsible organizations or individuals within the District. -
't.2 Policy ,
It is the policy of Nebraska Public Power District (NPPD) to use its best efforts to assure that the Cooper Nuclear Station is designed, constructed, maintained, and operated in a manner that will provide the highest practical degree of safety and reliability. Structures, components, and systems are designed, fabricated, erected, maintained, and modified to quality standards appropriate to their importance to the safety function. The Quality Assurance Documents will identify those structures, systems, and major components to be covered by the Quality Assuranc s Program in order to provide continuing compliance with thevt. standards throughout the cperating life of the station. Additionally, it is the policy of NPPD that activities affecting quality shall be documented by approved H instructions, procedures, .or drawings and such activities shall be implemented as documented. Such documentation sha!! contain adequate qualitative and/or quantitative acceptance criteria to provide a measure of accomplishment. It is the policy of Nebraska Public Power District (NPPD) to staff the Nuclear Power Group (NPG) with properly-trained personnel in all responsible positions and job assignments. Sufficient numbers oflicensed and senior licensed operating personnel will be available to assure proper operation of the station under all reasonably foreseeable circumstances including personnel turnover, vacations, and disability. All District personnel, as well as non-District personnel who work independently under . NPPD's QA Program, responsible for operating, maintaining, or designing safety-related systems and equipment shall receive formal instruction in Quality Assurance, including: basic principles of quality assurance,10CFR50 Appendix B, the contents of this policy document, and Quality. Assurance Documents, as applicable. 1-2 Revision 10
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# , 1 Trained: technical, engineering,1and (Quality L Assurance ~ personnel: shall be assigned !
y, v ~ surveillance and audit tasks to ensure compliance with the requirements of the documents _ q 4 _ . . :, which control station' operation, such as the NRC license, Updated SafetyLAnalysis ! Report, Technical Specifications,~ Operating Manual, QA Program for Operation,' and ,1 other such controlling? documents. ?During the time -personnel are performing QA functions, they shall be responsible to the QA Division to maintain the organizational " l in&g../.er.ce required by the QA Program. Ei
'It is the policy of Nebraska Public Pows District to maintain quality standards for i
, Cooper Nuclear Station which will ensure the high degree of reliability and safety needed to meet the overall objectives of supplying safe and dependable electric service to its : customers.
'f The CNS QA Program for Plant Operations utilizes the guidance provided by NRC publications WASH-1283 (5-24-74), WASH-1284 (10-26-73), and WASH-1309 (5-10-74) -
(" rainbow" series) except where specific exceptions and clarifications are noted within-this document. Where specific requirements included in the standards are in conflict with original design requirements set forth in the USAR and other appropriate design f documents, the origina1' design requirements shall govern. Later revisions to standards , presently committed to by CNS, may be specifically invoked by the design requirements , where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than original" condition. In summary, NPPD is committed to the continuous development of a Quality Assurance ) Program which will meet the requirements of 10CFR50, Appendix B, Quality Assurance [ Criteria for Nuclear Power Plants, and other applicable regulations as may be promulgated by the Nuclear Regulatory Commission. This commitment applies to all NPPD organizations to assure that a high standard of quality will be maintained during l l-3 Revision 10 l
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.l 1y nuclear plant operation. ' Section 2 of this document presents a summary discussion of 1
the'QA Program as applicable to the 18 criteria of 10CFR50, Appendix B. f I 4
.1.3 Obiectives . ,
In accordance with the policy statements above, the overall objective of the CNS Quality 9 Assurance Program for. Operation, as defined in Quality Assurance Plans (QAPs) and. Nuclear Quality Procedures (NQPs), is to set forth the Quality Assurance organizational' structure and personnel responsibilities and to set forth general requirements for the l preparation of written procedures and controls necessary for quality surveillance and auditing to verify the following: , a) Regulatory criteria, codes and standards, and design bases for safety-related systems (as defined in the CNS QA Progam) are incorporated into the test, operating, modifications, and maintenance : procedures and instructions to meet all requirements for nuclear' safety and station reliability; b) Results of all preoperational and operational tests of safety-related systems and components conform to the requirements of the drawings, specifications, procedures, and instructions, and that appropriate reports are prepared to document that all results of tests meet prescribed acceptance criteria; c) Nuclear Fuel is purchased, designed, manufactured, inspected, packaged, shipped, received, installed, and operated in the reactor in accordance with approved procedures, instructions, regulatory requirements, and license stipulations; l I l-4 Revision 10 l
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s y - 'd): The Station is operated, main'tained,. tested, refueled," repaired, ~and
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p %i regulatory requirements, and license stipulations, consistent with quality :
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1 standards equal to or better than' those in effect during design and. l construction; a 4 e) A system is established and maintained to control, safeguard, and permit ready retrieval of quality- related documentation generated for materials and: components during the design, fabrication, modification,- maintenance, and operation of CNS;
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f) Appropriate and complete reports, records, and logs are established and . maintained so as to provide a continuing record ~of quality-related , l activities associated with station safety and reliability throughout the life g of the station; g) The 'NPG personnel are subjected to periodic training, retraining, requalification, and examination such as to maintain and improve theirjob . skills which are essential to safe and reliable operation of the station; h) Station security and nuclear fuel accountability and safeguards are maintained in accordance with approved procedures and instructions; 1 L l i) Corrective action documents / reports and associated resolutions are to be properly controlled and filed in the appropriate quality-related record , files; l j) Inspection reports issued by the NRC are properly resolved and documented; l-5 Revision 10
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- k): Spent fuel shipment activities are to be accomplished in accordance with 3
regulatory requirements (10CFR Part 71).
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1.4L SGQDC The QA Program for Operation applies to those nuclear station structures,' systems, andl
' components that are designed to prevent or mitigate the consequences of postulated ;
accidents which could cause undue risk to the health and safety of the public, and to 't J l other selected systems and programs as defined in implementing QA Plans. The requirements of this program apply to all activities which affect the safety-related functions of those structures, systems, and components, including designing, purchasing,, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, . l operating,' maintaining, repairing, refueling, in-service inspection, and modifying. - : i This program specifically applies to, but is 'not necessarily limited to the nuclear fuel,~ the reactor coolant system and its auxiliaries and controls, the reactor protection and ' i
.l engineered safety systems, the reactor containment system, portions of the radioactive j waste disposal system, and other systems and components required for safe, efficient, and \
l reliable operation of the plant. A tabulation of those structures, systems, and components..
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which are covered by the QA Program is given m Table 1.
>q The Quality Assurance activities governing those structures, systems, and major I components shall be performed as described in the Quality Assurance Plans (QAPs) (see Section 4.1.3).
I The Quality Assurance Criteria in 10CFR50, Appendix B, are oriented primarily toward 2 engineering, manufacturing, and construction activities. Therefore, it is necessary to define, by specific Quality Assurance Documents, the manner in which the NRC Quality Assurance Criteria are to be applied to the station operating activities. Such Quality i 1-6 Revision 10 i
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' Assurance Documents shall be prepared in'accordance with the requirements specifisd ~
. in Sections 2.0 and 4.0 of this policy document.
The specifications, principles, and procedures which controlled the original procurement, fabrication, and construction have been carried over into' the QA aspects of station - operation to the greatest extent practicable. It is the' intent of NPPD management to maintain,' as a minimum, the quality _ level' achieved in' the ' original design and construction. 1.5 Definition of Terms Key words and phrases used to characterize this QA Program are defined herein to establish a basis for- uniform and consistent interpretation of the Quality Assurance-requirements. Definitions of these terms are based upon documents and standards issued by the AmericantNational Standards Institute (ANSI), NRC Safety and Regulatory Guides, professional societies involved in standards work (ANS, ASME, IEEE, et al.),- and on the basis of contemporary usage in the nuclear power industry; or shall be defined - i specifically to convey the intent of this particular program. Specific to the related ANSI Standard for this subject, the following commitment applies: ANSI N45.2.10-1973 " Quality Assurance Terms and Definitions," and the associated Regulatory Guide 1.74, are applicable to the CNS Operational ) QA Program, with the following clarification: ; l There may be instances where existing procedures contain definitions that may . l not be in strict accordance with those provided by this standard. As existing l procedures are revised, however, such definitions shall be evaluated to assure that all definitions meet those provided by this standard. 1-7 Revision 10
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<f To facilitate review and understanding of this policy document, the following basic terms 1
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e ::P ; are defined below along with appropriate QA Program requirements.' .! Assessment ; I A planned, methodical, Land comprehensive examination of an event, program, process, : . e, e activity, or function which'may include, compliance with existing NPG documents and/or - comparisons to existing industry information.-
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# g An activity to determine.through investigation,' the adequacy of, and adherence to, established procedures, instructions, specifications, codes, and standards or odier .;
i applicable contractual and licensing requirements, and the effectiveness -of i
'i implementation. i Clast For piping and valves, CLASS is determined by the applicable ASME Code.~ For seismic considerations, CLASS is determined by the USAR. (See also . Essential, -
Non-Essential, and Quality Commercial Grade.) Codes and Standards Documents issued by qualified organizations which contain standardized requirements for
- particular equipment or applications (e.g., ASTM Material Standards, ASME Pressure Vessel Code, etc.).
(Refer also to ANSI N45.2.10 for definition of " Standard".) CQDdition Report Condition Report (CR) is the vehicle utilized for identifying and correcting conditions adverse to giality, and significant conditions adverse to quality as described in 10CFR50, 1-8 Revision 10
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, , Appendix'B.' Condition Reports also provide a method for identification and cormction. S
. of those conditions not specifically described in 10CFR50, Appendix B.'
Controlling Documents ] J All those drawings,1 specifications,~ procedures, . instructions, manuals, . data books, ! Updated Safety Analysis Reports (USAR), Technical Specifications,'and the like, which ; have been approved.and issued by the appropriate authorities, and which prescribe thef conditions and limitations under which work is to be performed. j (Refer also to ANSI N45.2.10 for definition of " Documentation".)- Design Change l P A design change (generic application) is considered to be any change to a component, equipment, or structure that changes the design criteria, configuration, or margin'of '
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system integrity, or personnel safety. .For the purposes of definition, " design change" includes Design Changes, Equipment Specification Changes, etc. Dmionated Reoresentative
-i An individual or organization that is authorized by the purchaser to perform a specific function as identified / described in the procurement document. 1
^ s Emergency Procedures (Operating, Maintenance, or Repair) Those activities which must be performed without delay in order to: a) - Avoid further degradation of off-normal conditions which, in themselves, do not constitute an accident, but which could lead to an accident if not corrected promptly; l-9 Revision 10
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b) -- Reduce the consequences of an accident or hazardous condition which has j [already occurred;-- J 1 c)'- Implement an emergency plan;
'd)- Prepare for an anticipated act of nature. - j u ,
, Essential r .
j o i For purposes of applying and implementing' this Quality Assurance Program, the term' , ( " Essential" shall apply to the following: !
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a) All systems, structures, equipment, and components which are identified
-in the USAR as having been designed and built to Seismic Class I
. requirements; l b) All systems, structures, equipment, components, instrumen'ts, and:
controls which are identified in the USAR as being required to shut down the plant and maintain it in a safe shutdown condition; . c) All other systems, structures, equipment, components, instruments,-and controls which are placed in the " Essential" category by NPPD.' Evaluation An assessment of smaller scope; focusing on a portion of a process, a specific industry event / experience, or a specific CNS event / issue.- Primary emphasis ~is compliance with - o existing CNS management ~ expectations and goals, and secondarily for comparisons to: existing industry events / standards, 1-10 Revision 10 '
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'l Functional Organization Chart A pictorial description of the organization as it actually works showing actual lines of .!
~.. . yF direction, supervision, responsibility, authority, and communication. Such functional lines may or may not coincide with regular administrative channels. Inspection , The determination that physical characteristics meet predetermined requirements by visual . checks or by other techniques such as X-ray, ultrasonic or dye penetrant examination, - _ etc. (See also' Quality Control). (Refer also to ANSI N45.2.10 for definition of " Inspection".) Licenwl Station A' nuclear station which is designed and constructed so'as to meet requirements of ' : ! applicable regulatory criteria and is thereby eligible to receive a construction permit and :, operating license from the U.S. Nuclear Regulatory Commission. Imwer Tier Procurement < a Procurement by a rapplier from a subsupplier of items or services. 1 t 1-11 Revision 10
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e Maintenance Procedures Written instructions which define a preplanned maintenance program and prescribe the o methods, materials, and processes to be used to assure continuing quality and continuing operation of equipment within required performance characteristics.'
' Maior Maintenance. Renair. or Modification -
Those maintenance, repair, or modification activities performed on nuclear safety-related structures, systems, or components which involve: p a) Special craft or procedure qualifications to meet Code, . Standard, or Regulatory requirements; b) Alterations which affect overall structural integrity, essential performance characteristics, or margins of safety in design for nuclear safety-related - structures, systems, or components; c) Any permanent change to the facility that : requires a Technical Specification change or creation of an unreviewed safety question. Minor Maintenance. Reoair. or Modification Those maintenance or repair activities which are within a journeyman craftsman's capability, and which: a) Are prescribed in the equipment manufacturer's instruction books as necessary or desirable for most effective operation; 1-12 Revision 10 _ t .. . ..
[j;- n s, : b) - . Are prescribed as~ part of f a preplanned and approved routine: or- : I preventative maintenance p.rogram; i y c) . Any permanent change to the facilityjudged significant enough to warrant documentation that does not require a change in Technical Specification 'j
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y b Monitor j
- Periodically observe on a formal or informal basis whether work is being performed according to the requirements of the controlling documents (see also Surveillance).
Nonessential . Any structures, equipment, and components which may be important to reactor operation, 1 but are not required for preventing an accident which would endanger the public health and safety, and are not required for the mitigation of the consequences of these accidents. . l A Nonessential designated item shall not degrade the integrity of any item' designated Essential. Nuclear Ouality Procedures (NQPs) i Nuclear Quality Assurance Division Procedures that contain requirements / guidance for QA Division activities which affect activities of other divisions ' within the NPG 'and d 1 the District. NQPs define the responsibilities for implementation of the QA Program m: 1 I accordance with policies and practices herein defined as they apply to the QA Division. In addition, they provide guidance for surveillance, audit, and assessment / evaluation activities to be performed by the QA Staff. 1-13 Revision 10
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Off-Normal Condition Y
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M . A' condition which results when anfoperating variable departs from its normal range. To restom normal operating conditions following such a pertcrbation, action is taken under 14 - off-normal procedures so as to correct the condition which, if not corrected, could- [I degenerate into a condition requiring action under an emergency procedure. Operating Procedures Written instructions which define the normal method, means, and limits of operation, in - all modes, of a nuclear power station, a system or systems within the station, or station ~ processes.. Purchaser [ The organization responsible for issuance or administration or both of procurement documents. (Refer also'to ANSI N45.2.10 for definition of " Purchaser".) Ounlity Assurance
' All those planned and systematic actions performed for the purpose of establishing'a high level of confidence that:-
a) . Work performed on the project conforms with the requirements of the applicable codes, standards, license stipulations, safety analyses,- design = drawings, specifications, procedures, and instructions; l-14 Revision 10
w , , , y p N. , b) A structure, system, or component will perform satisfactorily in service; U and. _ c) Appropriate records, documentation and/or drawings are_ maintained to - g show compliance with a) and b) above. Oiinlity Anniirance Documents . Those documents inclusive of the QA Policy Document, Nuclear Quality Procedures, ,
~ QA Plans, Procedures (and associated data sheets), logs, etc., which have been approved - j for use, and whose intended function is to provide direction, verification, or-documentation for activities affecting quality.
i Onnlity Assurance Plans 1 Quality Assurance Plans are those documents specifically designed to provide detailed quality requirements for a given functional area. The plans are generated by applying f the,18' criteria of 10CFR50,- Appendix B, to each functional area and then deriving the { specific quality requirements for that area.
'Ouality Assurance Records Those records (see Reference 7.9) which have been completed and furnish documentary evidence of the quality of items and/or activities affecting~ quality.
' A document becomes a Quality Assurance Record when the activity related to the if F
' document becomes part of the operating condition of the plant. ;
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_, Ounlity Commercini Grada j i Classification of. a Commercial Grade ~ Item (CGI) intended for ' safety-related use, procured from a-Q.A. approved source and dedicated in accordance with approved ; station procedure; which meets the 10CFR21 definition of CGI. l Commercial Grade item (CGI) - An item that meets all of the following criteria: ~ q
,1 Not subject to design or specification requirements unique to nuclear H a) facilities or activities; b) - Used in applications other than nuclear facilities or activities; and c) Is ordered from the manufacturer's published product description, e.g.
catalogue, as an off-the-shelfitem. 1 Ouality Control u Those activities which deal directly with the measurement, observation, or verification of physical characteristics of materials, components, or systems which provide a basis for controlling. quality to !within predetermined limits, or requirements,j including' q adequate quantitative and/or qualitative acceptance criteria by which an activity can be measured. Ounlity Requirements Those factors which define limits which must be met so that the product will perform its intended function reliably throughout its design life. They include, but are not limited . 1 to, conditions important to proper material selection, manufacture, construction, and - 1-16 Revision 10
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inspection; substantiation that material or pans conform to all specification requirements,' testing to demonstrate adequacy of performance; protection of finished parts to prevent deterioration; and L conditions for operation,- maintenance, .and; repair which enable' i:: continuing ' operation within - prescribed margins -- of safety : and within - prescribed; performance limits. L Rieht of Acme The right of the purchaser or designated representative to enter the premises of a supplier, for the purpose of inspection, surveillance, or quality assurance audits. Regulatnry Criteria That body of NRC publications which define the conditions which must be met to obtain ' and hold an NRC Construction Permit, Operating License, and Licenses for individual
- operators.
' I l Review .1 v A deliberately critical examination.' The term includes the routine monitoring of station operation performed by the Site Manager and his staff as a normal management function,. and the formal independent evaluations of certain contemplated actions and after-the-fact investigation of anomalies conducted by a duly constituted review and audit group. 1 Safeguard (of Nuclear Material) Measure taken to prevent diversion of nuclear materials into unauthorized or illegal uses (see also Accountability). 1-17 Revision 10 l
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M ECBS i l l The performance by a supplier of activities such as design, fabrication, inspection,, ' nondestructive examination, repairs, installation, or training. l q d
.Sienifisant Conditions Adverse To Ouality q
l 1 Any conditions that could affect safety-related structures, systems, or components ability .j
- l to function within design requirements or adversely alter performance characteristics. ~:
l l Statian Permanent Record File
.l The file which is established for the purpose of accumulating and storing all documents : .)
1 and records pertaining to quality-related activities throughout the life of the nuclear plant. l 1
.J Supolier Evaluation i i
1 Those_ activities which determine the effectiveness of implementation of the supplier's 1 a L Quality Assurance Program. A variety of methods may be used to perform a supplier . j l evaluation and are described in the NQPs. R b Surveillance l
' Surveillance is the QA Audit function consisting of formal and informal observations to determine that work is being performed in accordance with the requirements of the' l-18 Revision 10 1
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. controlling documents and drawings (see also Audit and Monitor). Surveillance activities shall be performed in accordance with requirements specified in NQPs and QAPs.
' Surveillance Tacing es Periodic testing of structures, components, and systems related to nuclear safety, for the purpose of verifying ~.that such safety-related- structures, components, and systems continue to function or are in a state of readiness to perform their safety functions.
Testing . The determination or verification of the capability of an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental, or. operating conditions. (Refer also to ANSI N45.2.10 for definition of " Testing".) Traceability The capability to identify a particular component or material and to discover its' entire history, back through the written records of its material formulation (heat number), manufacture, inspection, installation, test, operation, maintenance, repair, .and replacement. Witness Formal observation by a knowledgeable person of a particular, prescheduled event during manufacturing, inspection, installation, testing, operation, maintenance, or repair. The 1-19 Revision 10
l 1 I purpose of witnessing is to provide direct observation and evaluation of an event,- i%t of the group performing the particular operation. ' 1 i t t i a b ( f i r ( 1-20 Revision 10 :
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SUMMARY
DESCRIITION
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. This section' defines the NPPD commitment for compliance to 10CFR50, Appendix B, . ]
t as applied to safety-related structures, systems, and components associated with Cooper Nuclear Station, i In. addition to describing commitments to 10CFR50, Appendix B, this Section also identifies NPPD's commitment' to selected ANSI Standards and- their' associated
- Regulatory Guides.
' 2.1 Ornanivation ,
The President and Chief Executive Officer (C.E.O.) (Figure 1) represents the highest level of management responsible for establishment of Quality Assurance policies, goals, - and objectives. The responsibility and authority for nuclear facility and General Office support activities (including QA) has been delegated to the Vice President - Nuclear through the Vice President Prchetion [Q$D. This authority includes the right to - , direct, enforce, and perform any action required to ensure all activities conducted at' Cooper Nuclear Station are in compliance with 10CFR50, Appendix B. In addition, the personnel assigned to the Quality Assurance Division shall have complete independence to perform audits, surveillances, inspections, verifications, assessments, evaluations and - shall be independent of those groups performing, designing, purchasing, fabricating,: shipping, storing, cleaning, - erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service inspecting, and modifying. Figure 1 of this document outlines the QA Division functional organization. Quality Assurance Personnel shall have sufficient authority and organizational freedom to: (1) Identify quality problems; 2-1 Revision 10
(2)' Initiate, recommend, or provide solutions' for conditions' adverse ' to quality; and, (3) Verify implementation of solutions. 2.2 Onnlity A=murance Program The program shall be implemented in accordance with written, approved Nuclear Quality ;. Procedures and Quality Assurance Plans developed by the Quality Assurance Division. The District's QA Program will comply with the Quality Assurance Guidelines contained in the Orange Book - WASH, 1284- 10-26-73. Design Control, Precurement Control, Quality Control, and Quality Assurance activities associated with plant modifications will similarly conform to the guidance provided within the Gray Book - WASH,1283- Rev.-1 and the Green Book - WASH, 1309- 5-10-74. Procedures will be ' prepared for each . 3 important activity of station operation which will clearly define the work to be performed - on a step-by-step basis and will identify, where appropriate, the results to be achieved. Mandatory QC Inspections or Tests will be performed on an independent basis to verify that specific work activities are being correctly completed (correct results obtained) and will be incorporated into the work procedures directly or by attachment. QA Audit activities will verify that the Quality Control Program is implemented. Specific to the related ANSI Standards for this criterion, the following commitments apply:
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- 1. ANSI N18.1-1971 " Selection and Training of Nuclear Power Plant Personnel,"
shall provide direction for selecting and training of personnel for the Nuclear Power Group. 2-2 Revision 10 -
u r L 2. JANSI N18.7-1972 "American National Standard for Administrative Controls for Nuclear Power Plants," and the associated Regulatory Guide 1.33, apply to the ;
.CNS Operational QA Program with the same exceptions as those taken in other sections.of this Policy Document to ANSI N45.2-12. e
- 3. ANSI N45.2-1977 " Quality Assurance Program Requirements for _ Nuclear Facilities," and associated Regulatory Guides 1.28 and 1.33, shall apply to 'the CNS Operational QA Program, with the following exceptions:
Where Section 11 " Inspection" identifies the reporting relationship between the inspector and the "immediate supervisors who are responsible for the work being inspected," the CNS QC Program only requires that - the individual performing the verification function shall not perform or directly supervise the work being inspected. Table 1 identifies the structures, systems, and major components associated with Cooper Nuclear Station covered by this program. Table 1 is not intended to be all inclusive. The Nuclear Operations,-Nuclear Support and Nuclear Engineering and Construction Divisions, with the assistance of the QA Division, will identify essential structures, . ' systems, and components to be included within the scope of the QA Program. The Quality Assurance Program is designed to provide control over all activities affecting quality of essential items to a degree consistent with their safety-related importance. These activities will be governed by approved plans and instructions and these documents shall be followed under controlled conditions. The Quality Assurance Plans and the Nuclear Quality Procedures will be reviewed periodically to assure that the requirements of the program are being met and new requirements are being incorporated. In addition to essential structures, systems, and components, applicable portions of this program shall be applied to selected nonessential structures, systems, and components 2-3 Revision 10 -
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a "j R important to station reliability and performance. Specific application will be identified ,
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-in dedicated Quality Assurance Plans.
L Special process controls, test equipment, tools, skills (training, if required) shall be used c
' during the conduct of inspection, verification and checking activities to assure a high ' =l standard of quality and reliability has been obtained on safety-related items covered by . I the. Quality ' Assurance Program. Test equipment and special tools will be calibrated -
against a specified secondary standard. Experienced individuals (which may include personnel from other divisions of the Nuclear Power Group (NPG), and/or outside qualified individuals) may be requested to assist in performing audits and inspections of certain CNS quality-related activities at the
. direction of the Division Manager of Quality Assurance. During these assignments, these individuals will have sufficient organizational freedom to identify and recommend ]
corrections for quality deficiencies noted. 1 The Nuclear Training Department, in addition to QA Staff personnel, provides i QA indoctrination for NPG employees as described in nuclear training' program ' descriptions. In addition, QA Staff members will attend a minimum of one training seminar / course per year sponsored by a qualified agency and/or school. Some courses - ! i' provided by the District's Nuclear Training Department shall be considered applicable to meeting this requirement.. Such determination shall be made by the Division Manager of Quality Assurance. For the purposes of meeting this requirement, activities such as attendance at national conventions, participation in owners group committee's activities,-
.c and other such related items may be considered equivalent to a seminar. Such instances shall be specifically approved by the Division Manager of Quality Assurance. Ongoing 4 QA training for personnel with nuclear plant responsibilities will be provided. Training activities will be audited periodically by the QA Staff to verify its scope and effectiveness.
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l T 2.3 '- Design Control . i I Implementing ~ procedures outline :the method for identifying, controlling, and
- implementing design changes within the Cooper Nuclear Station. .The procedures provide e the mechanism for correctly translating the design changes and regulatory requirements ~
into specifications, drawings, procedures, and instructions ~ They also. establish .the method of. reviews, interface . requirements ;(with original s design ' organization, if
. required),. approvals, and the organizations delegated the authority to implement the -
' design change.
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[ Design control measures shall include the review for suitability of application ofitems - that are essential to the safety-related function of the system involved. A necessary part - l of this review concerns'the safety classification of items to be procured. . In those ; instances where the normal methods of Section 2.7 cannot be applied and it is necessary to purchase " commercial-grade" off-the-shelf items for use in essential applications, , verification will be performed to ensure that the part utilized is functionally acceptable for the essential application. This verification may include dedication upon receipt, analysis, or other definitive method. All design changes initiated for Cooper Nuclear Station will be ' forwarded to the QA Division for review and independent evaluation. These reviews shall verify the compatibility of the design change with applicable codes, standards,'and regulatory i requirements. Items to consider include reactor physics, stress, thermal hydraulic and . - accident analyses, compatibility of materials, accessibility for in-service inspection, maintenance, repairs, and delineation of acceptance criteria for inspection and tests. I Final acceptance of the design change will require an independent verification or check ; of the design adequacy such as by the performance of design reviews, by the use of i 2-5 Revision 10'
1-alternate or simplified calculational methods, or by the performance of a suitable testing program. . Specific to the related ANSI Standards for this criterion, the following commitments-apply:
- 1. ANSI N45.2.11-1974 " Quality Ass nence Requirements for the Design of Nuclear Power Plants," and the associated Regulatory Guide 1.64, shall be applied to design activities involving safety-related modification work and the revision or development of plant design documents occurring during the operational phase of-CNS. However, where codes, standards, or design requirements are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the Updated Safety Analysis-Report (USAR), the USAR commitments shall govern. Later revisions of h applicable codes' and standards may be specifically invoked by the design l
l requirements where deemed appropriate, consistent with the overall commitment l to maintain the plant in an " equal to or better than" original condition.
- 2. ANSI N45.2.4-1972 " Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations," and its associated Regulatory Guide 1.30, shall be applicable to the CNS Operational QA Program for safety-related modification work, with the following exceptions / clarifications:
t (a) The definition of Class I and Class IE electrical equipment set forth by this standard does not conform to the equipment categories of CNS. Electrical items upon which the Operational QA Program is based are included in Table 1 of this policy document and the CNS "Q" List. The 2-6 Revision 10 , I
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E 1 scope and applicability of this standard shall necessarily be limited to these defmed areas. J l l
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-(b)_ Appropriate requirements for installation, inspection, and tests are defined in job specifications and work instructions developed as a part of_the w modification work package. - It is not intended that separate procedures , [
be establishedL which specifically. address the various areas of this - I standard. During the development of work packages, consideration will ~ l be given to the areas outlined in Section 2.3, as appropriate. (c) The requirements for installation, inspections, verifications, and tests shall be included in the work instructions. In the development of these instructions, consideration will be given to the guidance provided by Sections 4.0,5.0, and 6.0 of this standard, and appropriate requirements will be incorporated into the instructions. It is not intended that separate procedures be established to specifically ' address all of the areas referenced. . 1 (d) Application of- the guidance provided by the additional. codes and standards listed in Appendix B will be considered to the extent that such-codes and standards provide useful and practical guidance for the work l being performed. Commitments to the guidance of N45.2.4 shall'not include commitments to the guidance of referenced stc.urds. l 4
- 3. ANSI N45.2.5-1974 " Supplementary Quality Assurance Requirements for ;
Installation, Inspection, and Testing of Structural Concrete and Structural Steel i During the Construction Phase of Nuclear Power Plants," and its associated Regulatory Guide 1.94, shall be applicable to the CNS Operational QA Program for safety-related modification work, with the following exceptions / clarifications: _; 2-7 Revision 10 t
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; With respect to structural concrete, ' acceptability shall be documented in accordance with ' the District's Dedication - l Procedures , which will be verified by independent _QA audit.
w _(a) Appropriate requirements for installation, inspection, and tests will = ; be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifical!.y ' address the _ various areas of this standard. However, in the development of the work package, consideration will be given to the areas outlined in . > Section 2.2, as appropriate. E (b) The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied to all ; measuring and test equipment used by NPPD or their agents, test l laboratories, and contractors. Such requirements, however, will! ! not be imposed on commercial batch . plant facilities. >
. Instrumentation at commercial batch plant facilities will be ;
evaluated by NPG construction management personnel, or their designated representative, to determine that sufficient accuracy can be obtained. l (c) For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch : plants. For these small quantities of concrete, it is.umeasonable to expect commercial facilities to shut down normal operations to provide certified aggregate, cement, admixtures, fly ash, water, .) 2-8 Revision 10 . I
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, f etc.i In this respect the qualification tests required by Table A for . Laggregate; cement, admixtures, fly ash, and pozzolans; water and o .,.
. m ice will not be required. Appropriate evaluations will be made'to ' :
t determine that good ' quality and genera y-acceptable materials are used.- ' NPG; construction management evaluation,l coupled 'with . slump tests, air entrainment tests, and concrete cylinder strengths,~ .; will provide adequate control and qualification of the concrete. ! (d) Design mixes ~ consistent . with,- or ; equivalent . to, original requirements will be specified and the results of the' cylinder' tests L will be evaluated by NPG construction management based on the acceptance criteria associated with the original' design - mix : requirements. (e) The inspection requirements of Section 4.2.will not generally be
- performed as t e small quantities ' of concrete involved in
L modification work will no doubt be mixed using materials already in the batch plant bins. Control of storage of materials would not I be practicable. (f) If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per thei l requirements of ACI-304, ASTM C-94. Where certifications are . not available, two concrete test cylinders representing the first and last one-third of truck mixer contents shall be taken for evaluation of the mixer truck, over and above the normal concrete cylinders l taken to evaluate the in-place concrete. The concrete batch plant facility shall be inspected by NPG construction management and the CNS QA Staff to assure that reasonable controls are being 2-9 Revision 10
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y - - a K , , exercised with reference to the inspection guidelines set forth by~ -j
;- Section 4.3 (1) and (2).
i i (g) Inspection of fills and earthwork will meet the . general requirements set forth. The extent to. which individual inspection . requirements are met will depend upon the nature and scope of the- ; work to be performed. , s
* (h) . Except for normal batch. qualification tests -(slump,' air content, .
temperature, and compressive strength) and initial reinfoicing stael. l certification; the in-process tests required by Table B are generally ; applicable to the periodic control which must be exercised'with - , reference to long-term construction type programs. The in-process
' test requirement of Table B are not considered applicable' to short-term modification work as would be required by QA at CNS.
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( 4.. ANSI N45.2.8-1975 " Supplementary Quality. Assurance ~ Requirements for. : Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," shall be applicable to'the CNS Operational QA Program for safety-related modification work, with the following . clarification:
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Where specific design requirements included.in this standard or (a) referenced codes and standards are in conflict with original design requirements set forth in the USAR and other appropriate design - documents, the original design requirements shall govern. -l i i 4 4 2-10 Revision 10
, : 2.4= Procurement Document Control
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. Cooper Nuclear Station Procedures, Nuclear Engineerin~g and Construction Department Procedures,(Quality Assurance Plans, and Nuclear Quality Procedures are required to ,
define . the e applicable requirements,1 design - basis methods, and . procedures ' for ' l procurement of spare parts, materials, equipment, and services for essential nuclear. : systems. nese instructions and procedures shall also include provisions for assuring that. l the w=y- quality requirements are incorporated- directly into the procurement ' 3 documents for essential spare parts, material, equipment, and services. D ese instructions and procedures shall also include provisio~n for assuring tha't the necessary ,
. records are specified and provided to the District by the supplier. - -
s The basic principles and practices included in these procedures are expected'to be applicable to any purchasing activity necessary for operation of the station; however,- i additional special controls may be necessary for major modification or repair activities. . . y Procedures covering procurement provide for independent Quality Assurance review of essential and quality commercial grade purchasing documents; QA review and approval of suppliers; and QA Audit of contractor and supplier activities. a Revisions issued to any procurement document will be subjected to the same review and approval as the original order.
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, All procurement documents issued to suppliers of safety-related items or services require 1
that the supplier implement a. Quality Assurance Program that meets _the intent of -
.10CFR50, Appendix B (with the exception of those suppliers performing all work at-Cooper Nuclear Station or in the Columbus General Offices under the District's QA Progran). The Quality Assurance Programs submitted by the suppliers will be evaluated by NPPD- QA to. ascertain that they meet the criteria established in 10CFR50, 2-11 Revision 10 i
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- Appendix B. All safety-related suppliers shall appear on the applicable section of the
. NPPD Suppliers List.
To the maximum extent practicable, the as-built drawings and specifications for Cooper Nuclear Station _will be used in procurement of spare parts, material, and replacement parts. Where necessary, because of design modifications, or where it is necessary or desirable ; to upgrade quality in replacement parts or material, necessary modifications will be made to drawings and specifications to_ incorporate requirements for currently appropriate quality level. These modifications or upgrading of replacement parts will be accomplished in accordance with approved instructions, procedures,'and drawings. These documents will be subject to required reviews before being implemented. L Specific to the ANSI Standard related to this criterion, the following commitment applies: i g 1. ANSI N45.2.13-1976 " Quality Assurance Requirements for Control of-Procurement of Items and Services for Nuclear Power Plants," is applicable to l' the CNS Operational QA Program, with the following clarification: (a) It must be' acknowledged that equipment and components purchased during the design and construction phase were not purchased on the basis i i of present4y standards, especially with reference to supplier approval
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and supplier Quality Assurance Programs. In this respect, replacement parts and spare parts for existing equipment are often . limited to Such replacement parts or spare parts are sole-source suppliers. purchased to appropriate quality standards, verified by NPPD QA, to , maintain an " equal to or better than" condition but it is not considered 2-12 Revision 10
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. practicable ~ to backfit the' requirements of this standard to all such suppliers. -
' 2.5 : inatructions. Procedures. and' Drawings
'a
-Quality Assurance activities and other activities which have nuclear safety significance will be prescribed by documented instructions, drawings, and procedures as appropriate and shall be _ accomplished in accordance with these instructions, . procedures _'and -
drawings. These instructions .will be sufficiently detailed and explicit so that any-supervisor, inspector, or auditor can, by observation, determine whether or not activities . are being satisfactorily accomplished and documented. These documents shall include
, the qualitative and quantitative acceptance criteria necessary to assure satisfactory completion of the test procedure. Those acceptance criteria shall, where appropriate, require post installation testing prior to returning the component or system to service.
Repair maintenance activities on essential systems are performed in accordance with the Maintenance Work Request process. The required documentation for'special processes . are forwarded to the CNS QA' Staff for review along with special test procedures and special maintenance procedures. Document Hierarchy shall be as follows: Level I:
- License Basis Documents-Technical Specifications-Operating License
" Safety Analysis Report" 2-13 Revision 10
1 's
*' Updated Safety Analysis Report n
I- ; ~I 1 (
- NRC Correspondence (Commitments and SERs)
J . T
- Quality Assurance Policy Document i
level II:
- Design Specifications and Drawings LevelIII:
- Procedures
- Administrative Procedures Operational Procedures Work Procedures Nuclear Power Group Directives Nuclear Quality Procedures
' Level IV:
- Policies and Guidelines 2.6 . Document Control Administrative control procedures shall be established by the Nuclear Power Group (NPG) to control the identification, indexing, filing, retention, retrieval, and distribution of quality-related records and documents. Control procedures shall be reviewed and approved by authorized personnel and are distributed to and used at the site of the 2-14 Revision 10
v - astivity. These procedures shall also ensure that changes to quality-related records and documents receive the same level of review and approval as the original document.
'The overall objectives of NPPD document control are to: s
' a) Identify those records and documents which are used to control, maintain, -
modify,'or document quality-related' activities both at the CGO and at-
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CNS. O b)- Establish an index of quality-related records located at the CGO 'and at CNS to enable personnel involved in safety-related activities to determine - the proper documents to be used in the activity, c) Establish a filing system. I d) Establish periods of retention. e) Establish measures to control distribution and revisions. The CGO Manager of Office Systems Services, CNS station management, and the Quality Assurance Division will jointly establish lines of specific responsibility,
' interfaces, and document control procedures.
Specific to the ANSI Standard related to this criterion, the following commitment applies:
- 1. ANSI N45.2.9-1974 " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," and its associated Regulatory Guide 1.88 shall be applicable to the CNS Operational QA Program, with the following exception / clarification:
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- c. records genemted prior to implementation of this standard, it is not_ ._ j our intent to backfit the detailed requirements of this standard to,'
. , those records. All such records,'however, have been initially .; i designated for lifetime storage, until. specific. review dictates , c ; otherwise, and will be stored in the record storage facility. Record l
' indexes and filing systems shall be established to permit reasonable I identifbtion and retrieval. The records will-be stored and
-preserved per the requirements of Section 6.0 of this standard. .
2.7 Control of Purchaw Material. Equipment. and Services
- Ni1D receiving inspection instructions provide for determining that all purchased materials, equipment, and services purchased directly or through a contractor, supplier, ,
or subcontractor meet the requirements specified' on the original procurement , specifications, such as code, standards, specifications, dedication, nutterialidentification, t etc. The completed receipt inspection report will become part of the purchase' order 4 package. Procurement documents shall be available at the receiving area % identify the _; o ; receiving inspections required, t i Nuclear Quality Procedures provide' for evaluation of supplier's quality program to - determine effectiveness and compliance to the applicable 10CFR50 criteria as part of the -
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supplier selection process. These instructions shall describe the methods and techniques S used to evaluate the supplier's Quality Assurance Program. The QA Division shall re-evaluate the supplier's quality program at intervals consistent , with the importance, complexity, and quantity of the item or services to effectively , maintain control of quality. Procurement documentation will specify mandatory hold . 1 2-16 - Revision 10 - l
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d C ' w !po nts for: witnessing or inspection;of. purchased materials, equipment,.or services, if required by NPPD. . - ; w S Upon receipt at the station, material, parts, and equipment purchased and identified as
" Essential" or " Quality Commercial Grade" will be placed in a' segregated storage ares L R until all inspections are complete and all required certifications and documentation is l
received. a;
' Items in segregated areas will not bel issued, by the Warehouse, without the written a permission of the Site Manager or designee, and then only after proper arrangements i
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have been made to assure that necessary steps lwill be taken to bring all aspects of the particular item into conformance with normal requirements prior to the system containing , components in " Hold" status being considered operable. Suppliers of essential equipment, if appropriate, shall be required to provide certified-documentary evidence that the material supplied conforms to the purchase document -
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. requirements such as. material test report, code required test and inspection,. .
documentation, etc. A complete set of documentation required by the procurement document for all essential materials,' equipment, and services will be filed at Cooper Nuclear Station. 2.8 Identification and Control of Parts. Materials. and Comoonents To the maximum extent practicable, activities carried out during operation of the Cooper Nuclear Station will comply with the requirements for' identification and control of j l materials, parts, and components as set fonh in the as-built drawings and specifications q H for the station.- Where special measures are required to assure proper identification of , materials, parts, and components, such requir>;ments will be incorporated directly into the procurement documents for such parts and assemblies. Such identifications which 2-17 Revision 10
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i' U: . - (may include heat numbers,' serial numbers, or other means of identification of the item . o g iwill be incorporated into the procurement documents to provide means of traceability.- ; 1 Material received at the station (which has not been properly identified) will be segregated and tagged to indicate a ." Hold" status.' Except as indicated in Section 2.7
., above, such parts will not be issued or used prior to final acceptance. CNS procedures - ,
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~will incorporate requirements necessary to assure that the identification measures are-propefly. carried out at the station, that unacceptable items will not be used in essential. !
systems, and that the components to be 'used in essential systems receive independent verification'of component identity prior to installation. 2.9 Control of Snecial Procauac ! General maintenance ' procedures provide for performance of special processes .by , qualified personnel using qualified and approved procedures. Control procedures provide : 4 for QA' review, inspection, documentation of activities, and for proper integration of j QC Inspection. In'most cases, the procedures will be prepared only when a specific process is required in the maintenance, repair, or modification of essential equipment at CNS. 'Ihese procedures shall also require special processes, such as welding, heat treating, and NDE, to be controlled and performed by qualified personnel in accordance ; with ' qualified procedures. i Maintenance modification control methods and Station Operating procedures are reviewed by CNS QA personnel.. This review includes verification that necessary codes, ; standards, quality requirements, and acceptance criteria are incorporated to control l t special processes within established limits. .j r 2-18 Revision 10
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QualityJControl. inspections. haveI beEn assigned in this policy l document to the' organization basically responsible for the' performance of the activity. A, Peer QC;
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* ' Program will be. utilized in which QC inspections are normally ' performed by QC -
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Inspectors who have been selected from within the Nuclear Power Group, and who are , many timer. jut as ymlified to perform the work as they are to inspect the work. QC; . o
,, personnel will be qualified / certified, and will conduct the QC Program, in accuider.ce? ;
with NPPD's commitment to ANSI N45.2.6. This conduct of the QC Program will be : within the detail established in the CNS Operations Manual, Volume 12. E b Quality Assurance Audits, Assessments / Evaluations, and Surveillance of activities such as maintenance, repair and modifications will include direct observation; 'whereas ;
; operating functions will be monitored indirectly by observation and examination.of ~ l individual operating personnel and documentation at intervals consistent with the .
)
importance of the activity. Direct QA'or QC inspection'will also be conducted for activities such as refueling, radiochemistry, and environmental monitoring. Special inspections, such as those requiring qualification to ASNT-TC-1 A,'will.be contracted to - i approved suppliers. If direct inspection is impossible, indirect control methods will be specified in the instructions to provide a method of monitoring process methods and equipment. The results of all inspections will be placed in permanent record storage. : i Controlling documents pertaining to quality-related activities receive Station Operations . .
. Review Committee (SORC) approval to ensure incorporation of appropriate quality ;
, requirements. QA is a~non-voting member of SORC. .
i Specific to the ANSI Standard related to this criterion, the following commitment applies: i 2-19 Revision 10
f <y. '1% m i j n 1. ANSI N45.2.6-1978' " Qualifications of Inspection,. Examination, and Testing Personnel for Nuclear Power Plants," and its associated Regulatory. Guide 1.58 1
^is applicable to the' CNS Operational QA Program, withLthe following.'
exceptions / clarifications: ; _ (a)., It has always' been the belief of NPPD that, in order to be effective,-
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' Quality Control must be built into the operation of the plant. With this
.~in mind, Quality Control and test functions Lperformed at CNS are incorporated directly into the station procedures. Inspection points am 7 then performed and signed off by qualified personnel not directly:
-performing or supervising the step (s) .being inspected. Selection of- l QC candidates for certification'is a function of Station Management.- 'l Tactual certification of QC inspectors is the responsibility of the .
- QA Division. .
(b)- CNS does not have the in-house capability to perform nondestructive - je examinations in -accordance with SNT-TC-1A. These : services are , currently contracted to an approved supplier. Any ' required nondestructive examinations will be performed by personnel who are: qualified and certified per SNT-TC-1 A. j i 2.11 Test Control I Each type of test program performed by the station operating group will be defined by. ] 1 written procedures and instructions. These test programs include the preoperational tests, 1 1 start-up test instructions, operational testing and surveillance testing of structures, 'I
- systems, and components to demonstrate their capability to perform satisfactorily as a part of an integrated system. Acceptance tests will be developed for structures, systems, and components to demonstrate their capability to perform satisfactorily following repairs 2-20 Revision 10 I
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{, w sY ,, 3 j or modification prior to mtuming to' service.1 Test procedures will identify the inspector, [. . test performer, date, and data recorder. Each type of acceptance test has individual test - ; procedures which include Quality Control provisions, acceptance criteriaf and check y points for. observation lor checking : of important.' aspects.- These i test ' procedure
< prerequisites :will include the'testLinstrumentation requirements:and environmental >
,y j
conditions. : All Special Test Procedures, Special : Procedures,L and Station Operating ; Procedures are routinely reviewed by SORC, of which QA is a member. <
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Quality Assurance ' Audits, Assessments / Evaluations,' and Surveillance activities will be ' 1 performed by the Quality Assurance Staff members to assure that tests are.being-performed in accordance with the requirements of the procedures,'that'results are .. + evaluated and compared to the specified acceptance criteria, and that tests are being. -
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performed by appropriately trained personnel. In addition,' test procedures shall specify
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test requirements and quantitative and qualitative acceptance criteria' where appropriate. 1 i m 2.12 Control of Measuring and Test Equioment l Procedures shall define the~ requirements of inspection, maintenance, repair and calibration of all tools, gauges, instruments, and other measuring and testing devices which are used in activities which affect quality of safety-related equipment. Each permanent or temporary installed plant instrument performing an essential function ; has been identified and placed on a' regularly-scheduled program' of inspection, test, and. q recalibration. All test and measuring equipment required for calibration of the above- j equipment will also be placed on a regular program ofinspection, test, and recalibration and will be appropriately tagged. Documented calibration records are reviewed, as
.. required, to evaluate calibration performance and frequency, and changes are made as-may be necessary.
2-21 Revision 10 l i ________________l
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'1 J A Quality Assurance Plan will prescribe the QA functions to be performed relative to the
' calibration program. Quality . Control and Quality Assurance practices require independent checks of calibration activities. Quality Assurance Surveillance performed by the QA Staff members will verify that procedures are being properly followed; that adequate records of calibration and testing of measuring and test equipment are being -
generated, maintained, and that regularly scheduled adjustments are made to maintain necessary accuracy. For equipment used to calibrate process equipment, procedures will define action to be taken should regularly-scheduled calibration checks reveal an out of specification condition exists. When inspection, measuring, and test eqeipment are found . i . to be out of calibration, an evaluation shall be made, and documented, of the validity of previous inspection or test results and of the acceptability of items previously inspected or tested. Should the evaluation determine that previous inspection or test results obtained with the affected instrument are unacceptable, a Condition Report will be issued. Reference and transfer standards, traceable to the National Institute of Standards and Technology (formerly NBS), will be maintained at CNS. I Scheduled and/or unannounced audits or surveillances by the Quality Assurance Staff, the Safety Review and Audit Board, or NPPD management will include review of the calibration program. l 2.13 Handling. Storage. and Shippine The procedures for procurement and control of essential spare parts, materials, replacement parts, and equipment include the requirements for the control, handling, , cleaning, shipping, receiving, and storage of essential parts and material. Quality Assurance Plans and NQPs provide for surveillance and audit to assure that procedures are followed and that essential parts and materials are received, inspected, stored, and ; I controlled in such a manner so as to prevent degradation. ; 2-22 Revision 10 l
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- 3. Specific to the ANSI Standard relating to this' criterion,' the.following commitment applies:, $
- 1. - ANSI N45.2.2-1972 " Packaging, Shipping, Receiving, Storage, and Handling of -
Items for Nuclear Power Plants," and'its associated Regulatory Guide 1.38_is
- applicable to the' CNS Operational L QA Program, with the - following exceptions / clarifications: j (a) NPPD's QA program is structured to identify safety-related equipment ~ l and provide for designation of packaging, shipping, receiving, storage, !
and handling requirements for ' purchased parts and materials. .The 3 classifications of this standard cannot be applied directly to individual spare parts or subassemblies of the parent equipment. Due to difference in' volume, complexity, inspectability, etc., the packaging,. shipping, - handling, and storage requirements of spare parts and subassemblies will l necessarily be different from the requirements which may be imposed on the entire component or piece of parent equipment. ; (b) The majority.of items purchased for an operating plant . consist of components, subassemblies, and individual spare parts which could be used in a multitude of different applications. Such items are purchased to the most stringent requirement for their intended use. The volume and , characteristics of procurement during the operational phase ' differ significantly from those purchases ' made during the design and construction phase. Items requiring special storage protection will be' identified on the purchasing documents. Items that must be stored ' outdoors (equivalent of Level D) and items that must be stored in covered but unheated conditions (equivalent of Level C) will be evaluated on an f
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t individual case basis. However, it is not considered practicable to 2-23' Revision 10 W
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( pmelassify individual' parts by levels as required by Section 2.7 of this j 4 , standard. Shipping and packaging requirements for such items-will: 3 likewise be handled in the procurement documents, as appropriate. t (c)' QA Audits', Assessments / Evaluations, and Surveillances are performed to verify that the requirements of N45.2.2 are met except as noted in (a) and
- (b) above.
s.~ 2.14 Inanetinn. Test. and Ooeratine Status The NPPD status tagging procedure, already'in use throughout the system, has been = adapted for use in the Cooper Nuclear Station. Where practical, particular emphasis , shall be placed on tagging to prevent unauthorized operation or adjustment which could -
- endanger the safety of personnel, damage equipment, or invalidate the results of tests already performed. These tags shall indicate abnormal equipment test and inspection - _j status and reference special instructions for equipment located throughout the Cooper Nuclear Station.
Tagging prbcedures, where necessary, will require that equipment be tagged and that the associated power supplies, starters, switches and controls on the main control panel are l tagged as well, to warn against operation. In some cases, power supplies will_ be ; disconnected and tagged to prevent inadvertent operation. Tagging will be controlled by
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the Shift Supervisor by requiring that serially-numbered tags, obtained from the Control , Room, be used for all tagging purposes. Records will be maintained in the Control Room to enable operators and Shift Supervisors to determine the ' status of the equipment
. tagged.
A Temporary Modifications Control Program will be maintained to provide a method for recording the installation and removal ofjumpers, fuses, or wire terminal disconnections. 2-24 Revision 10
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'1his record will include the location,' reason, name of person authorizing action,'and name of person performing 'the installation. .
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Requirements for tagging are included in the applicable procedures. Status tagging'will ' >d
- be verified by audit and surveillance.
- 2.15 Nanennformine Materials. Parts. or Components Warehouse and maintenance procedures include requiremems for the identification and : !
tagging of nonconforming materials, parts, or components; (See Section 2.8). . Nonconforming items will be controlled in such a way as to prevent their inadvertent use or. installation. Such parts will be reinspected and reviewed for adequacy prior to returning them to the manufacturer, scrapping them, or arranging for them to be reworked to conform. Disposition of a nonconforming item will be determined by the l responsible supervisor in conjunction with the QA Staff. Written reports of decisions to :i repair or rework essential items will be reviewed and approved in accordance with' maintenance and/or design control procedures. Any decision to reduce requirements to permit use of nonconforming parts, materials, or components in essential systems, will be documented per th'e Corrective Action ; Program,and will be subject to Station Operations Review Committee (SORC) review and approval. Appropriate design modification documentation will be completed, if required. . Approved-Procedures will be utilized for repair and rework of essential parts and equipment. All such rework will be thoroughly' documented, including Quality Control and Quality Assurance Surveillance activities, to assure conformance with the - requirements of the specifications, procedures, and other controlling documents. ; 2-25 Revision 10 t _.______________________m___ _ _ _
m ., m: ' .1 1 w - w . hdal equipment classified as scrap will be identified and segregated in such a manner
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g , y , to prevent inadvertent use or installation'in an essential system. r n
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'J L2.16 Corrective Action Corrective Action Proeram (CAP)
The CAP for CNS shall provide the measures to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances are promptly identified and corrected. Measures taken
- to disposition significant conditions adverse to quality shall include; immediate actions taken, the cause of the condition, action taken to preclude recurrence, and corrective actions. The identification of significant conditions adverse to quality shall be documented and reported to the appropriate levels of management.
The. CAP shall be utilized,- by all personnel performing operation, maintenance, modification, or other quality related functions / activities at CNS, to document and report such deficiencies / discrepancies as: a) -Deviations from approved' procedures. i b) Nonconforming materials, parts, or components received from outside- ? suppliers on essential purchase orders. c) Nonconforming materials, parts, or components within the plant. d) Nonconforming materials brought on site without following established receiving and inspection procedures. e)- Orders or mcommendations to stop work. f) _ Reportable occurrences. g) 'Any other deficiency which violates the intent of the Quality Assurance Program and which could have a significant adverse effect on quality. h) Deviations which could be reportable under 10CFR21. 2-26 Revision 10
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3s A monthly report of open NPG Ahtion Item Tracking (NAIT) items shall be prepared and - n Edistributed ' to? NPG ' Senior -Management 'and Department Management personnel, including the Vice President-Nuclear. NRC Regulations which require formal reporting to'the NRC of failures,' malfunctions, deficiencies, unusual operating experiences, and deviations which may have a significant ' l effect on quality or safety _will be reviewed and evaluated.by the Station Operations Review Committee and, where appropriate, by the Safety Review and Audit Board. It - will be the responsibility of the Nuclear Group personnel to identify and promptly correct . all such deficiencies or - malfunctions either by . improved maintenance, - repairs, replacements, or modification. -In all cases, the objective and the corrective action will i not only be to correct the existing defect or deficiency, but also to include measures to determine cause and prevent recurrence of similar failures. - Quality Assurance activities will verify that corrective action is performed in accordance with approved written procedures and that the details of the corrective action are properly documented for the permanent station records. A separate report shall be prepared for each nonconformance. The intent of this separate report requirement is to simplify follow-up, corrective ~ action, record keeping, and tmnding. The QA Division shall issue a quarterly trend report to the Vice President - Nuclear,
- which may identify adverse trends that require corrective action.
t Deficiencies and/or deviations identified by QA Staff personnel shall be reported per the.- ; guidance defined in Nuclear Quality Procedures and/or the CNS Corrective Action Program.
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i 2-27 Revision 10
I. 2.17. ' Ounlity A=enrance Records All' activities having a significant effect on quality and safety will be thoroughly documented, and all such documentation will be incorporated into the record storage system. Procedures will require appropriate physical storage and personnel to maintain
. these files. Record identification,~ storage, retrieval, access, control, retention, and safeguarding of all quality-related records associated with CNS will be in accordance with approved procedures. Records to be maintained include all records accumulated during engineering and construction and those records generated during station operation, maintenance, and. modification as defined in the CNS Technical Specifications. These records shall also include qualification 'of personnel, equipment, and procedures.
Inspection and test records shall identify the inspector, data recorder, method of observation, results, acceptance, and all nonconformance reports issued to document noted deficiencies. CNS and/or Columbus General Office personnel will be allowed to maintain active working files at their work stations.- The time frame for submitting these records to record storage facilities will be determined by their respective administrative procedures. Administrative procedures shall provide for methods for changing records that provide clear identification of the change and must be initialed and dated by the person making the change and by persons authorized to approve the changes. i l The program will include Audits of record storage facilities to assure that the procedures and controls are properly implemented. The CGO Manager of Office Systems Services j and CNS station management will prepare detailed procedures for receiving records into : the facilities and for making decisions on removal and disposal of outdated or superseded records. Refer to Section 2.6 " Document Control" for the commitment to ANSI N45.2.9. 2-28 Revision 10
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2.18; Audils t %
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Scheduled and unscheduled audits will be' performed to veHfy compliance to CNS QA > Program requirements and to determine the effectiveness of the area audited.j Quality l Assurance Plans for each functional area of station operating activities have been or wil'1 e be prepared. These QA Plans identify the nature and extent' of Quality Assurance audit :, activities to be performed by QA Personnel or under the direction of management.' Audit ' responsibilities are assigned to the Division Manager of Quality' Assurance. : Audits performed under this direction (working with the Safety Review and Audit Board (SRAB) . as referenced in Section 3.5) will be conducted according to the QA Plans to verify compliance- with the Quality Assurance Program. Audits shall be performed in accordance with written instructions or checklists and conducted by trained personnel not >
-directly responsible for areas being audited. NPPD Management may request audits of j specific activities of particular concern to them. However, all such internal audits will l L be coordinated to avoid interference with the operating activities at the station. Upon completion of the audit, a formal report will be prepared and transmitted to the organization audited which will include an evaluation statement regarding the program's I effectiveness. All audit findings identified will be documented and appropriate follow-p ;
action will be taken to assure that corrective action has been implemented. Follow-up action, including readouts to verify corrective action, shall be fully documented.. Specific to the ANSI Standards relating to this criterion, the following commitments apply:
-i H 1. ANSI N45.2.12-1977 " Requirements for Auditing of Quality Assurance Programs -
for Nuclear Power Plants," and its associated Regulatory Guide 1.144, is applicable to the CNS Operational QA Program, and to the Supplier Audit Program. ; 2-29 Revision 10
Ing s 6; .. .
- L 2. :'Section 4.0 of ANSI N18.7-1972 " Administrative Controls for Nuclear Power . ,
. Plants," 'will be'uned as a guide for scheduling and conducting audits. ,
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- 3. The frequency of audits will-be in accordance with Regulatory Guide'1.33,. , ,
" Quality Assurance Program Requirements (Operation)".
'2.19 Additional ANSI Standards j I ANSI Standards applicable to the CNS QA Program for Operation, not directly related to the preceding sections, are discussed in this section:
5
- 1. ANSI N45.2.1-1973. " Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants," and its associated Regulatory Guide 1.37, is applicable to the CNS Operational QA Program, with ,
the following exceptions / clarifications: >1 (a) Cleaning requirements for almost all maintenance, repair, and- -j i modification work will be considered as a part of the overall job l requirements. In this respect, detailed cleaning procedures will not - generally be prepared as separate documents. Necessary requirements, ) I consistent with the scope of the work, will be included as a part of the ;j overall work instructions. System cleanness is controlled at CNS by the following methods: (1) Parts and components are checked for cleanness during receipt inspection and 1 stored in a manner that will ensure adequate levels of cleanness are being maintained.- 1
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- (2)l LWork instruction will be reviewed by. Quality Control to assure that adequate-cleaning and access controls are incorporated into work instruction and associated -
safety-related activities. ,
- (3) Parts and components ' are inspected for cleanness ~ prior to' installation in. i accordance'with CNS maintenance procedures.
, . .. (4) Work areas are maintained at a cleanliness level appropriate to the maintenance
~or modification activity being performed. .4 (5) Quality Control, Supervisory, or Engineering Inspections before, during, and after safety-related- maintenance or modification activities address system .
. cleanness.
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-l (6) Random QA Audit, Assessment / Evaluations, and Surveillance of safety-related' .j maintenance or modification activities requires verification of part, component, 'l and system cleanness. !
(b) For cleanness classifications where the scope of plant modification work - is such as to make application of the guidance provided by this standard practicable, the cleanness classifications and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work requirements. (c) For most modification or maintenance work, however, involving only. small portions or individual components of larger systems, it is not considered practicable to conduct cleanness tests with ASTM ABBE-70 Series. Appropriate cleanness will be maintained during the work and preoperational flushing will be conducted, consistent with the scope of the 2-31 Revision 10
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. work performed an'd the original design requirements. Controlling the .
. parts and components and thelwork area has.provided CNS with:
reasonable levels of assurance that system cleanness will be maintained. In addition.to' the above, the LWater Chemistry Department routinely samples and tests for system cleanliness, corrosion, crud buildup, etc. l J J
- 2. ANSI N45.2.3-1973 " Housekeeping During the Construction Phase of Nuclear ,
Power Plants," and its associated Regulatory Guide 1.39, is applicable to the CNS = Operational QA Program, with the following exceptions / clarifications: (a) The plant has been divided in zones for fire protection and security l purposes. The zone designated for cleanness in the ANSI Standard are primarily intended for control or work during construction of the plant. Therefore, the CNS facilities will not. be ' classified by the zones . , designated in the Standard general housekeeping rules. Limitations on-eating,= drinking, and smoking are already provided in existing CNS j procedures.. Where special cleanliness controls, tool, and material- . accountability are required for particular types of work, temporary clean areas will be designated and defined in the procedures and work packages . for accomplishing'the work. (b) Fire protection and prevention will be provided in accordance with NPPD evaluation of the CNS fire protection system as required by NRC - regulations.
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(c) Station . procedures have been reviewed to determine the' need for ; particular cleanness, housekeeping, and control provisions. Where indicated, procedures have been revised to incorporate such provisions, f using the guidance of ANSI N45.2.3. 2-32 Revision 10 l
J 3. .
- ANSI N45.2.23-1978, " Qualification of- Quality Assurance Program _ Audit Personnel for Nuclear Power Plants". This standard is applicable to' the Operational QA Program at CNS and to the Quality Assurance Division Training -
Program. - s 1 1 i 2-33' Revision 10 i
y , f i, 3.0 ORGANIZATION AND RESPONSIBILrrIES Nebraska Public Power District is solely responsible for the operation of the Cooper Nuclear Station and will. fulfill the objectives set. forth in the QualityfAssurance Program for Operation through its own organization and by contract with qualified - contractors and consultants. 3.1 General The overall Quality Assurance Program for Operation shall be conducted in accordance with the three levels of responsibility:: . Work Performance and Quality Control,
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Management / Supervision Oversight, . Quality Assurance Audit / Surveillance' and Assessments. Table 2 defines the three levels of.QA as they are to be implemented for station operation and also shows the comparison with similar principles which shall apply to nuclear fuel procurement and any future major engineering and construction activities for the Cooper Nuclear Station. It is intended that clearly separate lines of responsibility be maintained between those responsible for the operation of Cooper Nuclear Station and those responsible for auditing to verify that all quality and licensing requirements are consistently being met. QA responsibilities will vary depending upon the type of activity involved (See Section 4.1.3). Additional details on individual QA' responsibilities are given in the -
, paragraphs which follow, together with additional explanation of the interrelationships -
'between the various supervisors and managers involved.
3-1 Revision 10
- 2. _
l~' i 1 3.2~ NucWr Power Group Management h i e f"0".'"PT-@_G_eTE'il._ii3_6~assiiliF_di.lTe.tE46_65a_ndiFiliiEM-s _- - - - - u a-- . r.
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sis,_so_wi_a.agg 1 g 3.2.1 Vic Px;;d::: ' Produ;;ic: Th; Vic PK;;dca: Prcdu;;ic h th; x; pen;ib!; ;x;;u:ive off!= for ;!! CNS O=li:y A;;umn= x!;;;d =:ivi: ;. U; :::y d;!;g;;; x;pca;ibili:y :: :h; Vic Pai.d;;; N =!;= ;; in 3.2.2. b;!cw. 3.2.} Vice President - Nuclear 1,_1HiM5_i&ii_adis.trN.iiE._liF".~ud_asTifii"dlE.ti.BE.
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dis _ullHt_liiD Responsibility includes the Quality Assurance requirements governing those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. Pertinent activities include designing, purchasing, fabrication, handling, ' shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, - j refueling, in-service inspection and modifications that are associated with Cooper Nuclear Station. L The responsibility and authority over the Safety Review and Audit Board has been delegated to the Vice President - Nuclear. The Vice President - Nuclear reserves the authority to conduct, or order the auditing or monitoring of any operations activity, ) i I 3-2 Revision 10
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- at any time, to ascertain the effectiveness of the overall QA Program and to determine ;
that all aspects of the QA Program are being complied with. N __ ( 3.2.[ Division Manager. Ouality Assurance . The Division Manager of Quality Assurance, a member of the executive staff,' reporting to the _ Vice President - Nuclear, shall have the responsibility and authority
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I for administrating and maintaining a Quality Assurance Program for Operation in accordance with 10CFR50, Appendix B. Inherent in this responsibility is the authority . l to accept or reject any or all work, materials or equipment associated with Cooper ! Nuclear Station and Columbus GO. The Division Manager of Quality Assurance shall direct the preparation of plans and procedures for defining the Quality Assurance functions associated with Cooper Nuclear Station to ensure that such activities are t conducied in accordance with the Operating License' and appended Technical
~ Specifications. He shall also approve all plans and . procedures for defining and '
auditing the safety-related activities within the Cooper Nuclear Station and General Office. The actual audit functions to be performed are defined more completely by the body of Nuclear Quality Procedures , and Quality' Assurance Plans required by ~ Section 4.0 of this policy document. He shall also have administrative responsibility .
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for evaluating suppliers of nuclear safety-related equipment, materials, and spare parts ! I and for auditing the QA/QC activities of such suppliers. The Division Manager of Quality Assurance and Staff shall have the w=y organizational freedom and access within the Nuclear Power Group to institute the necessary Quality Assurance requirements, identify problems, and pursue prompt- ! corrective action. Figure 1 outlines the QA Division functional organization. ! i
- The Division Manager of Quality Assurance shall monitor the Quality Assurance ;
activities to the extent necessary for assuring compliance with the program. He shall 3 Revision 10 j
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L, review the effectiveness of the Quality _ Assurance Program with the: Vice President - 3 n.
; Nuclear on a regular basis.L In addition, the Division Manager of QA has'a direct line .-
o , of communication with the President and C.E.O. He shall serve as a' member of the Safety Review and Audit Board and provide additional QA Personnel to participate in ' .. SRAB activities when requested. ,
' NPPD Quality Assurance Staff, under the direction of the Division' Manager of Quality--
Assurance, shall have the responsibilitp and authority for implementation 'and ongoing - ,
' development of the Quality Assurance Program for Operations. In addition,'it shall- .
be the responsibility of the ' Quality Assurance' Division to monitor. the interface between the Nuclear Power Group Divisions.to ensure that plant modification and . ; repairs receive the proper design reviews and approvals. Unless otherwise provided for in writing, the QA Operations Manager'or the-QA .; Assessment Manager (depending on their availability) shall function as the Division ' i Manager of Quality Assurance in his absence. As shown in Table 2, he shall have responsibility for accomplishment of third level 2 QA Audits and shall obtain assistance and special expertise when necessary to , complete such audits effectively. t
'h 3.2.} ' Ouality' Assurance Operations Manager [
The Quality Assurance Operations Manager, reporting to the Division Manager of Quality Assurance, shall have the responsibility and authority for implementing and - - maintaining the Quality Assurance Program for Operation as described herein. ; He shall be responsible and have the authority to perform, direct, or coordinate- - QA Surveillance and Audit activities / programs within the Nuclear Power Group. 3-4 Revision 10
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>3 p QA review {of the design and engineeringifunctions _within the NPG,: including -
1 configuration management. shall: be: : included- in such: programs.
- These ,
s o-
- activities / programs shall determine if conformance'with the CNS QA Program for -
Operation 'and applicable federal regulations as defined in the QA Policy Document are being maintained. The QA Op'erations Manager shall advise and assist Senior Management and their , staffin all matters which affect'the quality of the station.- Similarly, he shall advise - and assist all . station personnel in matters regarding Quality Assurance'and Quality'_ d Control. In addition, _the QA Operations' Manager shall ensure that training programs and ; instruction.are provided for QA Operations personnel to enable them to effectively execute and monitor the Quality Assurance Program for Operation.1 The QA Operations Manager shall designate members of the QA Operations Staff upon request to provide training and instruction programs to enable CNS personnel to ! effectively execute the District QA Program. ; d ). The QA Operations Manager is also responsible for monitoring of open audit items , and interface with NRC during inspections at CNS. In addition, he shall also be i 1 responsible to verify that solutions to safety-related problems have been implemented ' ; and to perform scheduled audits of those activities as defined in Quality Assurance . Plans. Additional specific duties shall be defined in the Nuclear Quality Procedures j and Quality Assurance Plans, issued in accordance with Section 4.0 of this Policy Document.- : m : The QA Operations Manager or designee shall also serve as a non-voting member of > the Station Operating Review Committee (SORC). 3-5 Revision 10
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t i [ ' TheiQA, Operations Manager and Staff will observe operations,. maintenance,
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, :in-service ' inspection, . special : processes, repair or modifications, and; other .
safety-related ' activities covered by the' Quality _ Assurance Program, and recommend
..that work stop when such activity, in their opinion,'does not comply with approved'
. controlling documents. The Site Manager or designee is responsible to act on that! ;
recommendation and actually stop work unless it is determined such stoppage would - result'in a violation of the Technical Specification or other appauved documents - governing station operation or whether there are overriding considerations of safety j involved. - The QA Operations Manager will provide for a coordination fimetion for QC activities - 4 at CNS. This includes reviews of inspector certifications and performance and the , establishnsent of a training program. The. function 1will also provide the-communication path for the resolution of QC Inspector. concerns. The Quality Assurance. Operations Manager shall have the responsibility and authority . for the controlling, administrating, distributing, and coordinating changes and revisions to the Quality Assurance Program for Operation, subject to the requirements of Section 4.0 of the Policy Document. During absence of the QA Operations Manager, an individual from his staff will be . > designated to act on his behalf and serve as the nonvoting member of SORC.
. 3.2.] Ouality Assurance Assessment Manager
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. The Quality Assurance Assessment Manager, reporting to the Division Manager of Quality Assurance, shall have the responsibility and authority for implementing and maintaining the Quality Assurance Program for Operation, as described herein.
3-6 Revision 10
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. . nis responsibility . includes the authority for implementing and~ maintaining the QA' .;
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' Assessment / Evaluation Program and the program for evaluating suppliers for safety -
y related equipment, materials, spare parts, and services, and for auditing the.QA/QC
^ I activities of such suppliers.
The QA- Assessment Manager shall advise and assist Senior Management and their : f staff in all matters which affect the quality of the station. 4 The QA Assessment Manager and Staff shall have the responsibility for providing. guidance to NPG personnel in all matters affecting quality. They shall also establish
- and implement the program for evaluating suppliers for safety-related equipment,- .
materials, spare parts, and survices. Additional duties are defined in the Nuclear Quality Procedures and Quality Assurance Plans. The: Quality Assurance Assessment Manager is responsible for interface, along with :
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the Division Manager of QA, with NRC inspections conducted within the NPG. In addition, the QA Assessment Manager shall ensure that training programs and - [ instruction are provided for QA Assessment and QA Supplier personnel to enable them 1 to effectively execute and monitor the Quality Assurance Program for Operation. . 1
- 3.2.] Otmlity Assurance Suoervisors ne Quality Assurance Supervisors report to the applicable QA Manager and am responsible for the performance of work activities assigned. They are responsible to
- direct the performance of QA activities, and to identify any condition adverse to 3-7 Revision 10
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- quality to the appropriate QA M'anager. The QA Supervisors are responsible for the. ,
M : continued maintenance and upgrading of QA Program Documents. g 9Ih , g l 3.2.[ L Onlity Ansurance Staff ' q , J Onnlity Atenrance Supolier Staff ' 1 .
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*Ihe Quality Assurance Supplier Staff, reporting to the QA Assessment Manager, shall
,/ be responsible to assist and advise the- Q A Assessment Manager in all matters which
} could affect Quality Assurance activities within the NPG. This includes advising and ;
' assisting ' personnel in all matters regarding Quality Assurance, and verification that solutions to safety-related problems have been implemented. The QA Supplier Staff ,
shall . support the. CNS QA - Staff in quality matters such .as internal audits, surveillances, assessments / evaluations and outage coverage upon request, as agreed
. between the QA Assessment Manager and the QA Operations Manager.' ;
.i The QA Assessment Manager has designated the QA Supplier Supervisor and Staff
- the responsibility for the ongoing development and implementation of the ;
supplier evaluation program; review of procurement specifications and associated , drawings to determine if special requirements such as codes, standards, materials, tools, and inspections, etc., are properly included. CNS Ouality Assurance Staff e r
~ The CNS Quality Assurance Staff shall be responsible to assist and advise the CNS Quality Assurance Supervisors in all matters affecting the quality of the station. These duties include: procedure preparation, advising and assisting NPG personnel in all ,
matters regarding Quality Assurance and Quality Control, verification that solutions i to safety-related problems have been implemented, performance of QA activities < 3-8 Revision 10 l l
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- (audits, assessments, evaluations, and surveillances) within the NPG on an announced 7 h 'or unannounchd basis, and development and implementation of the QA engineering.
ifunction. '
' Additional duties shall be as defined in - Nuclear Quality Procedures and ' Quality LAssurance Plans issued in accordance with Section 4.0 of this policy document. '
Disagreements or differences of opinion on Quality Assurance matters are expected to be documented and resolved jointly by both_ the CNS and General Office ~ Quality Assurance Staff and appropriate CNS or Gene.al Office supervisory personnel. Where :
.such-resolution 'is not achieved within a reasonable period of time, unresolved differences shall be promptly reported to the appropriate Quality Assurance Manager for resolution jointly with the Division Manager of Quality Assurance and Senior Management personnel, as appropriate.
Secretary to the OA Operations Manager The Secretary to the QA Operations Manager shall be responsible for administering and documenting the controlled QA program document distribution.: Additional specific duties shall be as defined in the Nuclear Quality Procedures, and Quality ; Assurance Plans issued in accordance with Section 4.0 of this policy document. l I 3.2.g Division Manager - Nuclear Engineering and Construction The Division Manager of Nuclear Engineering and Construction under the direction of-the Vice' President - Nuclear shall provide technical assistance for plant. modification activities at Cooper Nuclear Station. Those Quality Assurance activities l associated with such modifications will be conducted in accordance with the CNS 1 Quality Assurance Program for Operations. These activities will be audited l 3-9 Revision 10
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m' 3 . periodically bi Quality Assurance Staff and quality-related problems shall be identified ' d c . J L , ' and reported to appropriate levels of management for resolution.
$ JThe Quality Assurance Staff will perform the necessary follow-up action to assure that _ -l t .
corrective action is implemented in a timely manner.' q i 3.2.] Nuchar Fuel Manager - , For those aspects of Fuel Management covered by the QA Program, the Nuclear Fuel - L Manager, under the direction of the Division Manager of Nuclear Engineering and h L Construction, shall be responsible to furnish technical assistance as required to the Plant Manager and the QA Staff. Such assistance shall not replace or supersede the - formal audits.
- J u 3.2.] Site Manager
~
The Site Manager and his staff, under the direction of the Vice President - Nuclear,
;shall be responsible and have the authority for assuring that Quality Assurance activities, as defined by this and other approved QA Program documents are complied with. Some of these responsibilities are delegated to CNS management personnel and -
include Quality Control and Inspection functions as defined in Table 2. . The actual functions to be performed shall be defined in lower tier documents such as NQPs, 4 QAPs, NPG Directives, etc. 1 l j
._3.2.1) Plant Manager j d
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.The Seni or Manager of Site Support, under the direction of the Site Manager, M
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of keeping abreast of significant quality activities. : 3.2.1), Senior Manager of Safety Assessment The Senior Manager of Safety Assessment, under the direction of the Site Manager, , shall provide the management focal point for Nuclear Safety at CNS. This includes responsi ty or __t a_n__ __ _ev_e_n -~ .-_. ~. in e- _a-__- +---._, _ .- . e
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pp - ,_ , f' m O' m 53.2.1]i ' cahimhus Geneml office (CGo) Deoartment Managers CGO Departmental Managers report to either the M1Risi@iXt @gR$g[{lgthe Division Manager - Nuclear Engineering and Construction = i; Divii; 'in,, ;
+
"d.;.;.;h.". ::: i;s.t;d in 1; USAR and are responsible for implementation of
. t QA Program objectives within their area of responsibility.
3.2.1] Cooper Nuclear Station (CNS) Deoartment Mananers V CNS departmental managers, either directly or indirectly, report to the Site Manager as described in the CNS USAR and are responsible for implementation of QA Program objectives within their area of responsibility. r 3.3 Cooner Nuclear Station Personnel The operational duties and responsibilities of the Cooper Nuclear Station personnel are o described in the CNS Procedures Manual, Reference 7.5. In addition, the Cooper j l Nuclear Station personnel are assigned Quality Control and inspection functions. Station personnel, under the direction of the Site Manager and his staff, are responsible for assuring that the station is tested, operated, maintained, and modified in accordance with approved plans and procedures. 3.4 CGO Personnel 1 The duties and responsibilities of CGO personnel are described herein and in the appropriate implementing documents. These documents address the CGO responsibility for such items as design, procurement, modification, and licensing. q Reporting through department and division managers described previously, theirs is the first-line responsibility for implementing this program in the CGO. 3-12 Revision 10
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? 3.5 ' Nety Review and Audit Anard 1 ,
a The Safety Review and Audit Board (SRAB) has been established to provide am . indapandent review and audit of designated activities. The board must: verify that
- op: ration of the plant is consistent with' company policy and rules, approved operating n ,
procedures, and operating license provisions; review important proposed plant t changes, tests, and procedures verify that licensee events are promptly investigated and cormeted in a manner which reduces the probability of recurrence of such'-
+ . events;and detect trends which may not be apparent to a day-to-day observer.
Specific duties and responsibilities of SRAB, including auditing, are identified in the - CNS Radiological Technical . Specifications. (Reference 7.14), and in the SRAB Reference Manual.- 3.6 Station Operations Review Committee The Station Operations . Review Committee (SORC) has been established to advise the Plant Manager in all matters regarding operational safety. Specific duties and responsibilities of SORC are identified in Reference 7.14, CNS Radiological Technical Specifications. 3.7 Outside Suooliers. Contractors. Subcontractors. and Consultants During the life of Cooper Nuclear Station, it will be occasionally necessary to obtain assistance from outside suppliers and contractors. At all times, these outside suppliers, contractors, and consultants will work under the direction of the NPPD organization
.having primary responsibility for the particular work being performed. In those instances in which outside suppliers or contractors merely furnish personnel to augment the normal station or CGO staff for particular activities, such outside ~
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_ _ - _ _ - . _ m g._ 4-t , , , i 1 p
- contractor personnel shall be required to ' perform their work in accordance with the .
k . CNS Quality Assurance Documents and other appropriate CNS1 procedures and' , F' , instructions. In those instances in which 'outside suppliers, contractors,. and subcontractors are assigned primary responsibility for a particular activity, such outside
. contractor shall be required to maintain a Quality Assurance and Quality' Control Program and organization appropriate to the work to be performed. All suppliers, N contractors, and consultants performing work classified as essential shall be maintained on the appropriate section of the CNS Approved Suppliers List. Selection of outside' suppliers or contractors shall require the active participation of the Quality Assurance Division in evaluating and approving their Quality _ Assurance Program and reviewing the procurement documents prior to awarding the contract. <
j In every instance in which outside contractors have responsibility for work at CNS on - . safety-related nuclear systems, they shall be. contractually required.to work to' procedures approved by the District's Station- Operations Review Committee. , Recognized standards or existing proprietary procedures may be used, but they must be specifically invoked in writing and clearly identified as to their applicability to.the - CNS work. In addition, any outside contractor performing work at Cooper Nuclear Station under
\
their own quality assurance program shall be contractually required to prepam, prior to performing the work, a Project QA Plan specific to the work to be performed at the Station. Contractors and consultants performing safety-related work under the District's Quality Assurance Program shall be contractually required to perform the work under District l supervision and in accordance with the CNS Quality Assurance Program for l Operation. District personnel responsible for such work shall assure that - ; contractor / consultant personnel are qualified to do the work and have been provided 3-14 Revision 10
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n , Additionally, any calibrated tools and formal instruction in quality. assurance. i < equipment pauvided by the contractor shall be recalibrated at Cooper Nuclear Station or by a District approved source, prior to'use. If'any pottion 'of work on safety-related nuclear systems is to be subcontracted, the
-. prime contractor shall impose the appropriate QA requirements on the subcontractor. .
. NPPD QA shall have direct access to and communication with the contractor's -
personnel at all levels, both at their home office and in~ the field. Prior to performing work at Cooper Nuclear Station which affects safety-related i equipment, outside suppliers, contractors, consultants, and selected representatives from the NPPD Nuclear Operation and Nuclear Engineering and Construction-Divisions shall jointly develop and enforce written agreements and/or procedures which clearly define the limits of the work; interface between contractor and station 2 personnel; status and custody tagging procedures; contractor personnel dosimetry; and any other aspects which bear on station or personnel security and safety. Such agreements shall be reviewed by the Quality Assurance Division to ensure compliance with applicable Quality Assurance Program requirements..
-1 At all times when outside suppliers, contractors, and consultants are obtained to assist in the execution of this QA program, the responsibility for effectiveness of these support organizations activities will remain with NPPD.
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(4.0 ? QUALITY ASSURANCE DOCUMENTS
'Ihe CNS Quality Assurance Program is defined by written policies, procedures, and
. plans which shall be implemented throughout the operating life of the station. .
1 4.1- NPPD Internal Documents Work procedures are based on the requirements of the Quality Assurance Program.. ,
.i Preparation and maintenance of basic work procedures is performed by engineering -
and operating groups, separately from the Nuclear Quality Proceduits and QA Plans. Mandatory QC checkpoints shall be incorporated directly in or attached to, the work ] procedures to facilitate coordination between the specific work activity and the Quality ; Control function. 'It is not the intent to include the preparation of basic work : I procedures under the responsibility.of QA, nor is it the intent to incorporate basic ; 1 work procedures into the QA Program Documents.- Work procedures, however, shall .! be reviewed by' Quality Assurance for proper implementation of-the QA Program . :l objectives. i The format and content of NQPs and QAPs, shall be as specified_ by a Quality . , Assurance Procedure. - Significant changes shall.be reviewed and approved by the ' same levels of management as for the original document. Each change, when. ! approved and issued, shall be distributed through a controlled distribution system. i Particular circumstances may occur while some work is in progress, which necessitates a change to an approved work procedure. When such circumstances arise, the changes . must be authorized per procedure. The written record shall clearly show the nature . , and extent of the change and the reason for requiring such change. ; t 4-1 Revision 10 [
n . {: t , > f,2 J K4.1.1 Ounlity control inawtian 1 4 a l De Quality. Control Inspection function shall be performed by individual (s) other than those who are actually performing the step (s) being inspected or who are providing , direct, hands-on, at-the-job supervision.' The Cooper Nuclear Station management, as - 1 part of their normal management function, are responsible for implementation of the -
- 4 . Quality Control requirements of the Peer QC program; however, the QA Operations Manager is responsible to review and accept control methods prior to implementation.
Quality Assurance Management, working with NPG Management, shall verify that' l a adequate Quality Control inspections are incorporated directly in, or attached to, the work procedures and shall periodically inspect work performance to assure that the - , procedures containing Quality Control inspections are ' being followed. De
~
QC Program shall identify the specific work which is to be subjected to inspection or ; verification and shall provide in detail the elements of work to be inspected which j include:
- 1. Identity of the inspector or data recorder.
- 2. Type of inspection or verification.
- 3. Results (data to be recorded).
-i
- 4. ' Acceptance (qualitative or quantitative) criteria. j 1
- 5. Method of disposition of unsatisfactory inspection results.
i
- 6. Reporting requirements.
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.In addition, clear instructions shall be given regarding the timing,-frequency or j
.l scheduling, and notification requirements for such inspections so as to obtain maximum ' i
.i effectiveness and to minimize delays in completion 'of the work. - l l
l g' -It must be recognized that certain work, particularly in nonroutine maintenance or < 1 repair, cannot be anticipated. Therefore, procedures and Quality. Control Inspection
" requirements cannot be prepared until a particular problem has been detected and!
evaluated.- Routine maintenance and repair of essential systems and components generally requires ' > performance of a complete or partial Surveillance Procedure prior to placing' the system back in service. This type of QC (actual performance or functional testing)c following completion of work is considered a unique advantage' on an operating 0 ' facility. Such surveillance testing may be performed by the individuals who performed the maintenance activity. Records of the surveillance will be reviewed by the system . l engineer or other supervisory / management personnel. : 4.1.2 Nuclear Ouality Procedures (NOP) J The Quality Assurance staff shall prepare NQPs approved by the Division Manager ;j of Quality Assurance and the Vice President - Nuclear. As described in Section 1.5'- of this document, NQPs define Quality Assurance activities and responsibilities which
~l cross divisional boundaries. When approved, NQPs become a part of the CNS Quality ~ j Assurance Program for Operation.
1 1 4-3 Revision 10 :
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; 4.1.3 - ' Ouality Assurance Plans (OAP)
QAPs shall be developed which encompass those functional areas described within, b defining the scope of the QA program. Quality Assurance Staff shall develop QAPs , as needed. As described in Section 1.5 of this document, these QA Plans - outline specific Quality Assurance activities and shall become a part of the CNS Quality . Assurance Program for Operation. Distribution of these Plans will be to those individuals who are responsible for that particular activity. t The format and content of QAPs shall be specified in a NQP to provide uniformity L and to assure that each plan is complete and adequate for the intended purpose. The QAPs shall be prepared by the Quality Assurance Staff and shall be reviewed and approved by the Division Manager of Quality Assurance. In addition, when significant changes have been made to these documents, the QAP will be routed to affected Senior Management personnel for review and comment. The QAPs shall define the specific work which is to be subjected to Quality Assurance review, surveillance, and audit, and the manner in which such review, surveillance, and audit is to be implemented. Checklists shall be prepared per the guidance provided in Nuclear Quality Procedures, defining the scope of QA Surveillance or QA Audit activities . + a) 06ality Assurance Surveillance The Quality Assurance Surveillance function is intended to provide an independent verification, on a continuing basis, that work is being 4-4 Revision 10
-- - - - _ -,-.3 ,~r- , .-
y' q !? 'L '. performed -in 'accordance with. the requirements of- the controlling - documents. Such surveillances may be performance-based or compliance
, oriented depending on the nature of the function being evaluated. The Quality Assurance Surveillance activities are not intended to duplicate QC_. ,
a c
= Inspection activities, however, duplication may occur, in the effort to ,
satisfy ' both . Quality Assurance ' Surveilknce and Quality: Control - requirements.
~
The objectives of Quality Assurance Surveillance are to verify that the > Quality Control Inspection Program is being effectively implemented; that personnel performing Quality functions are properly; qualified;Lthat , adequate information is recorded to provide a complete and accurate quality history; and that deficiencies are identified, corrected, recorded, and corrective action is taken to prevent recurrence. - This philosophy shall be taken into account in developing the checklists , as guidance for the conduct of Quality As:urance Surveillance activities. QA Surveillance shall be as prescribed in NQPs and QAPs. The QA checklists shall identify the area of work to be subjected to surveillance and shall provide necessary instructions. The timing, . frequency, or schedule for the surveillance shall be coordinated with the work being evaluated to ensure maximum effectiveness with minimum impact on the progress of the work. , b) Ouality Assurance Audits A comprehensive system of planned and periodic audits shall be implemented to verify compliance with all aspects of the Quality 4-5 Revision 10
t
' Assurance Program and to determine the effectiveness of the program .
The audits shall be performed in accordance with written procedures or checklists by appropriately trained personnel 'not having direct responsibilities for the work being audited. Depending on the nature of : < u the function being audited, the audits are conducted in a performance-based manner to the maximum extent practical. The audits are : L . - supplemented by performance-based and- compliance - oriented
; surveillances, the results of which become part of the final audit package.
The . Quality Assurarice Assessment Manager and Quality Assurance Operations Manager shall have the responsibility and authority for ; planning and executing Quality Assurance Audits identified by approved QAPs. However, the SRAB, or any manager or executive in the chain of organization above the Site Manager, or above the Quality Assurance Supervisors and Managers may initiate and carry out special Quality Assurance Audits within the guidelines provided by this Quality Assurance Program. Audit results shall be reported in writing to the NPG Management in accordance with the requirements of NQPs and the results shall be reviewed with the Management responsible for the area of activity audited. Appropriate follow-up action shall be taken and documented as directed by the appropriate Quality Assurance Manager or Supervisor. l Internal instructions and guidelines include descriptions and timing of- I 1ypes c4cdits to be performed; information for initiating and performing audits; and information for preparing audit reports. l l Each QAP will be implemented through the use of the appropriate checklist. On the basis that some Quality Assurance Audits are to be conducted or directed by management, it is essential to maintain a high degree of flexibility in the manner of conducting an audit. It is intended i H 4-6 Revision 10 I 1
, , - that the QAPs provide audit guidelines to assure that areas to be audited -
- are sufficiently defined in advance and that audit personnel are adequately prepared to make a meaningful audit with a minimum ofinterference with the progress of the-work. Also, flexibility is required to permit the-auditor to adapt his procedures to the conditions existing at the time the audit is made. ,
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7 .m u ,, 5.0 METHOD OF IMPLEMENTATION 1 The CNS QA Program for Plant Operations will utilize the guidance provided by NRC publications WASH-1283 (5-24-74), WASH-1284 (10-26-73), and WASH-1309 ( . (5-10-74) (" rainbow" series) except as noted in the " Specific Exceptions" of this
-i section.
i The existing operational QA Program does not address all of the detailed requirements x set forth in the " rainbow books." A detailed review has been made to determine- i where the CNS QA Program differs from the ANSI Standards cited in the " rainbow ; books." With respect to the applicability of the " rainbow books" and the associated standards, , it is impracticable to apply all of the requirements set forth by these documents to a j , plant for which important, and (in some respects) irreversible commitments, were : j made at the start of commercial operation (1974). It is also impracticable to apply f requirements to an operating plant which were intended solely for the design and : construction phase. In the event that construction activities are undertaken, the District- ! will commit to compliance with the applicable portions'of the WASH Series ANSI ; Standards. It is NPPD's intent to apply quality standards to maintenance, repair, and modification activities which will provide results which are equal to or better_than the ' , original construction. The detailed methods of implementation shall be as provided for in written and 1, approved procedures prepared in accordance with Section 4.0. f The Quality Assurance Managers or designees shall review and comment on the NPG procedures to ascertain that necessary quality requirements are included. Procedure changes will be incorporated as necessary to correct identified control deficiencies 'or 5-1 Revision 10 -
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needs. Differences of opinion on QA comments shall be resolved as indicated in Section 3.2.6. After review of the various NPG procedures and manuals, the Quality Assurance _ Managers shall review the appropriate NQPs and QAPs for the purpose of assuring - , that the overall QA Program objectives continue to be accomplished in each segment - k of the work to which this QA Program applies. t Quality Assurance activities'shall be coordinated with .the SRAB and SORC. QA activities shall be conducted in a manner and on a schedule 'to assure , organization, supervision, communications, and technical and administrative practices 4 clearly provide for smooth, orderly, controlled, and safe execution of all safety-related . functicr.z.
.i Written reports of all QA activities, including descriptions of deficiencies and resolution thereof, shall be incorporated into the official QA file. Corrective' action on deficiencies shall include resolution of the specific deficiency and verification that .i corrective action has been implemented to prevent occurrence of similar deficiencies :
in the future. A report of QA Audits performed (internal and external) shall be submitted to the Vice President - Nuclear by the Division Manager of Quality l Assurance annually. 2 The Quality Assurance Staff shall maintain an up-to-date summary of the CNS Quality .' Assurance Policies, Procedures, and Plans, showing how this QA Program for ~ Operation implements the NRC guidelines contained in 10CFR50, Appendix B. .l I
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-l 5-2 Revision 10 -
3 6.0 RECORDS RETEliIlON AND DISPOSITION Instructions have been prepared by the responsible organizations to provide guidelines for CNS and CGO record retention and disposition in accordance with this policy document and applicable regulatory criteria. As a minimum, these procedures cover the following: a) Records content and location; b) Principal location from which records are to be controlled; - c) Complete records inventory and master index; d) Conditions of storage, access, and security; e) System of records identification, retrieval, and control; f) System of records transfer and disposal.
. Quality Assurance records (reference 7,9) will be entered into the controlled records system per the requirements of station procedure and ANSI N45.2.9 - 1974.
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5 1
17.0 REFERENCES
J The following' documents were used in the preparation of the Quality ~ Assurance l Program for Operation of the'. Cooper Nuclear _ Station. It is intended that these -l documents be used on a continuing basis in the performance of Quality Assurance activities for station operation since they offer measurement criteria against which the QA Program can be evaluated. 7.1 Quality Assurance Criteria for Nuclear Power Plants 10CFR50, Appendix B j (USNRC). 7.2 Standard of Administrative Controls for Nuclear Power Plants, American National - Standard ANSI 18.7 - 1972. 7.3 Updated Safety Analysis Report, Cooper Nuclear Station, Nebraska Public Power District (NRC Docket 50-298). 7.4 Environmental Report--Operating License Stage, Cooper Nuclear Station, Nebraska. Public Power District (NRC Docket 50-298). 7.5 Cooper Nuclear Station Procedures Manual. I t 7.6 Safety Rules, Nebraska Public Power District. 7.7- Safety Guides for Water-Cooled Nuclear Power Plants (USNRC), as appropriate. i 7.8 Quality Assurance Requirements for Nuclear Power Plants ANSI N45.2 - 1977. l 7-1 Revision 10
' 7.9 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records : for Nuclear Power Plants ANSI N45.2.9 - 1974. 7.10 Quality Assurance Terms and Definitions ANSI N45.2.10 - 1973. 7.11 Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.11 - 1974. l 7.12 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants ANSI N45.2.12 - 1977. - 7.13 Supplementary Quality Assurance Requirements for Control of Procurement of , Equipment, Materials, and Services for Nuclear Power Plants ANSI N45.2.13 - 1976. 7.14 CNS Radiological Technical Specifications. 7.15 ANSI N45.2.23-1978 " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" 1 7-2 Revision 10
g W I8 ~ FIGURE 1 NebraskaPublic hh President & CEO - ----- q NUCLEAR POWER GROUP QUALITY ASSURANCE DIVISION l Vice r.w:dcat-Predse::;a i I
- Responsible for Second and Third Levels l of the QA Program.as described in Table 2. Vice President-Nuclear l
- - Direct Communication ~l I
Division Manager-Quality Assurance -- d QA Operations Manager Secretary to the QA Assessment Manager QA Operations Manager QA Audit Superviser QA Programs Supervisor QA Assessment Supervisor- QA Supplier Supervisor QA Audit Staf[ QA Programs Staff QA Assessment Stafi QA Supplier Staff) (4 (5) (4) (53 8-1
4 TABLE 1 SYSTEMS AND COMPONENTS WITHIN THE SCOPE OF THE OUALITY ASSURANCE PROGRAM-
' I. NUCLEAR STEAM SUPPLY SYSTEM A. Reactor Primary. Vessel B. Reactor Primary Vessel Supports C. Control Rods and Drive System Equipment Necessary for Scram Operation
~ D. Control Rod Drive Housing E. Fuel Assemblies F.- Core Shroud l
G. Steam Dryer , H. Steam Separator , H. REACTOR COOLANT SYSTEMS A. ADS - Automatic Depressurization System . B. HPCI - High Pressure Coolant Injection System C.- LPCI - Iow Pressure Coolant Injection System D. CS - Core Spray System E. RCIC - Reactor Core Isolation Cooling III. REACTOR PROTECTION AND ENGINFFRFD SAFEGUARD SYSTEMS ; A. Reactor Protection System B. Standby Liquid Control C. Standby Gas Treatment . D. Diesel Generators "i
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t 9-1 Revision 10
J- ', Tahle 1 (Cont'd.) E. Electrical Aux Power - 1.- Critical 4160 V Equipment
- 2. Critical 480 V Equipment F. Neutron Monitoring Systems -
- 1. APRM - Average Power Range Monitor
- 2. IRM -Intermediate Range Monitor
- 3. LPRM '- Low Power Range Monitor
- 4. RBM - Rod Block Monitor
- 5. SRM - Source Range Monitor
- 6. TIP - Traversing In Core Probe ~
G. DC Power Supply H. Nuclear System Leak Detection I. Containment Isolation System J. Nuclear Boiler and Related Instrumentation K. Primary Containment L. Rod Position Indicator IV. NUCLEAR FUEL SYSTEMR A. Refueling Interlocks for Fuel Handling and Vessel Servicing Equipment.'- B. Fuel Pool Liner and Gates C. Fuel Pool Cooling and Cleanup 9-2 Revision 10
y-4 - 1 Table 1 (Cont'O V. - RADIOACTIVE WASTE DISPOSAL SYSTEMS A. Process Radiation Monitoring System
- 1. Off-Gas Radioactivity Monitoring
- 2. Main Steam Line Monitoring
- 3. Reactor Building Vent Monitoring (GE)
- 4. Drywell and Suppression System Leak Rate
- 5. Liquid Process Radiation Monitoring B. Radioactive Waste Processing System
- 1. Dewatering System
- 2. Radioactive Waste Shipping VI. OTHER SUPPORT SYSTEMS A. Reactor Equipment Cooling ;
B. Service Water C. Emergency Bypass Function on Control Room Heating, Vent, and AC D. Reactor Recirculating (Pressure Retaining Parts Only) E. Class I, II, and III Code Items F. Reactor Feed Pumps (Pressure Retaining Parts Only) O. Reactor Building H&V H. Fire Protection I. Security J. Instrument Air 1 l l 9-3 Revision 10 - l
1 b Table 1 (Cont'd.) VH. STRUCTURES (SEISMICS) A.. Reactor Building B. Control Building C. Elevated Release Point D.- Intake Structure
- E. Diesel Generator Building F. Radwaste Building (Below Grade)
- Note - 1. This listing is not intended to be all inclusive.
- 2. Application of the QA Program to these systems and components shall be >
consistent with the safety-related significance of the system or component. t
.i h
9-4 Revision 10
Table 2 - THREE LEVEL QUALITY ASSURANCE PROGRAM EXPLANATION OF FIRST, SECOND, AND THIRD LEVEL QA RESPONSIBILITIES a) ' FIRST I RVEL - Work Performance procedures are adequate for the and Ouality Control. activity they prescribe. Persons _ performing these audits are not
# Each person performing work for directly involved in the day-to-day CNS is charged with the first-line Inspection or. - Quality Control ,
responsibility for adherence to functions. Audits and/or quality practices and procedures. An surveillances will normally be-individual other than the one doing performed by or under the direction the work (not to include immediate of the appropriate QA Manager. In , supervisor) will have primary addition, SRAB shall be responsible responsibility for Quality Control. for reviewing the results of audits Pseser.cl at this level are charged and follow-up audits as described in with the responsibilit Technical Specifications. The Quality inspection, witnessing,y and sign-off,for direct Assurance Staff is also responsible attesting that work has been for the evaluation of audit results and 4 i performed in accordance with the for verifying that identified ; quality requirements of the corrective action requirements have i controlling documents. been implementd. , b) SECOND LEVEL Personnel performing assessments - Manneement/Suoervision Oversieht. are not directly involved in the day- ' to-day Inspection or Quality Control Supervision and management functions. Assessments willnormally : , personnel are- responsible for be performed under the direction of l providing workers and QC people the Quality Assurance Assessment with the proper procedures and Manager or Senior line Management guidance for performing quality personnel, or at the discretion of on-work. These Managers and site or off-site safety review bodies. Supervisors are then responsible for Such assessments are conducted to second level oversight as provide the highest level of overview appropriate for work involved. The of implementation of the- Quality Quality Assurance Managers are' Assurance - Program ' as herein responsible for assuring that described. controlling documents for safety-related activities include appropriate quality requirements. c) THIRD LEVEL-Ouality Assurance Audit / Surveillance and Assessments. L
- QA Staff is responsible for L maintaining surveillance and audits j of the work at CNS and the CGO to E assure that Quality Control and '
inspection programs . are being implemented and that quality requirements are in fact being met.
'Ihis includes verification that ,
activities are properly performed and ] 9-5 Revision 10
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