ML20138G590

Proposed Rev 1 to Cyap QA Program for Haddam Neck Plant

ML20138G590
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	04/25/1997
From:	CONNECTICUT YANKEE ATOMIC POWER CO.
To:
Shared Package
ML20138G587	List: CY-97-046, Forwards Proposed Rev 1 to Cyap QA Program for Haddam Neck Plant ML20138G590
References
NUDOCS 9705060338
Download: ML20138G590 (152)

Text

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TABLE OF CONTENTS CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM (CYOAP)

IIADDAM NECK PLANT Abstract Policy Statement Quality Assurance Program Chapters

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L; QAP 1.0 Organization; Organizational Charts Ky*(-

QAP 2.0 Quality Assurance Program s

QAP 3.0 Design Control QAP 4.0 Procurement Document Control QAP 5.0 Procedures, Instructions and Drawings QAP 6.0 Document Control QAP 7.0 Control of Purchased Material, Equipment and Services QAP 8.0 identification and Control of Materials, Parts and Components QAP 9.0 Control of Special Processes .

QAP 10.0 Inspection -

QAP 11.0 Test Control QAP 12.0 Control of Measuring and Testing Equipment O QAP 13.0 QAP 14.0 Handling, Storage, and Shipping Inspection. Test, and Operating Status QAP 15.0 Nonconforming Materials, Parts, Components, or Services QAP 16.0 Corrective Action QAP 17.0 Quality Assurance Records QAP 18.0 Audits Appendices A. Category 1 Systems, Structures and Components B. Qualification and Experience Requirements, Vice President - Nuclear Oversight C. Regulatory Guide and ANSI Standard Commitments D. Glossary of Quality Assurance Terms E. Program Exceptions TABLE OF CONTENTO i CYQAP REV: 01

j O, CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT ABSTRACT Nonheast Utilities (NU) has developed and is implementing a comprehensive Quality Assurance Program for the Connecticut Yankee Atomic Power Company's Haddam Neck Plant to assure conformance with established regulatory requirements as set forth by the Nuclear Regulatory Commission (NRC). The participants in this Quality Assurance Program assure that the maintenance and modification of the Haddam Neck Plant is performed in a safe and effective manner.

This Connecticut Yankee Quality Assurance Program (CYQAP) complies with the requirements set forth in 10 CFR 50 Appendix B, along with applicable sections of the Safety Analysis Report (SAR), and is responsive to the NRC Regulatory Guide 1.70, that describe the information required to be presented in the Quality Assurance Section of the SARs for nuclear power plants.

This CYQAP is also established, maintained and executed for Radioactive Material Transport Packages as allowed by 10 CFR 71.101(f). Quality Assurance Provisions for Fire Protection activities are detailed in the Connecticut Yankee Fire Protection Program.

This CYQAP applies to the safety functions of systems, structures, and components and are considered quality activities as defined in the CYQAP. Safety systems, structures and components  ;

are functionally identified in Appendix A herein. Applicability of Appendix A to the CY Updated  ;

Final Safety Analysis Report (UFSAR) is addressed by the specific design bases and licensing commitments. Portions of the CYQAP are also applicable to the Fire Protection Quality Assurance (FPQA) and the Radwaste Quality Assurance (RWQA) programs.

This CYQAP is committed to utilize the guidance obtained from the regulatory documents and their endorsed standards as referenced in Appendix C.

ABSTRACT il CYQAP REV: 01

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• POLICY STATEMENT OUALITY ASSURANCE PROGRAM l

Northeast Utilities has established a Quality Assurance Program for each nuclear site operated by the Northeast Utilities system. These QA programs have been developed to achieve quality assurance in all activities affecting the safe operation of the associated nuclear units.  :

The quality assurance programs established at each nuclear site by Nonheast Utilities are as follows: 1 Millstone Station, Units 1,2,3 and Site - Northeast Utilities Quality Assurance Program l (NUQAP)  ;

i Seabrook Station - Operational Quality Assurance Program (OQAP)

Haddam Neck Plant (HNP)- Connecticut Yankee Quality Assurance Program for the Haddam Neck Plant ( CYQAP)

The program described herein is the Connecticut Yankee Quality Assurance Program for the Haddam Neck Plant. The policies, requirements and tasks contained in this program description have been developed to achieve a recognized need for quality assurance for maintenance and modification activities during the decommissioning of the HNP to ensure that adequate quality requirements are being complied with to safeguard employees (NU and contract) and the public.

CY procedures which implement the program at the Haddam Neck Plant are developed and approved in accordance with Connecticut Yankee administrative procedures.

The CYQAP is responsive to applicable codes, Nuclear Regulatory Commission regulatory requirements, accepted industrial standards and revisions thereto. Provisions are established to update the CYQAP in accordance with revisions to codes, standards and regulatory requirements and to inform cognizant personnel to implement appropriate action to assure that the highest standard of quality is achieved for systems, structures, components and services for the HNP.

The controls which implement the actions identified in the CYQAP are station and departmental procedures and instmetions which delineate actions and steps necessary to accomplish quality requirements. Procedures and instructions are written by company groups, divisions, departments, branches, or sections, which have the responsibility for implementing actions assigned to them as delineated by the CYQAP.

The development and overall responsibility for this Quality Assurance Program lies with the President and Chief Executive Officer - NU Nuclear Group. Corporate authority is delegated to the Vice President-Nuclear Oversight for the preparation and administration of the Connecticut Yankee Quality Assurance Program (CYQAP). The Executive Vice President and Chief Nuclear Officer for i Connecticut Yankee and the CY Directors are responsible for the implementation of the Quality Assurance Program within their Departments.

O POLICY STATEMENT lii CYQAP REV: 01

QAP1.0 ORGANIZATION

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1.1 INTRODUCTION

The Chairman, Chief Executive Officer, and President of Northeast Utilities (NU) has the ultimate responsibility for the NU Nuclear Program. While retaining full responsibility and overall authority, the Chairman has delegated the necessary authori+y and responsibility for all NU Nuclear Operations to the President and Chief Executive Officer - NU Nuclear Group. The NU Nuclear Group includes the Northeast Utilities Service Company (NUSCO) which provides support services to NU's nuclear plants including the Connecticut Yankee Atomic Power Company (CYAPCO) which operates the Haddam Neck Plant (HNP). The President and Chief Executive Officer - Nuclear Group is also the President of NUSCO and the President and Chief Executive Officer of CYAPCO.

1.2 PROGRAM RESPONSIBILITY 1.2.1 The President and Chief Executive Officer - NU Nuclear Group has overall responsibility for the development of the CYQAP for the Haddam Neck Plant. While retaining full responsibility and overall authority, the President and Chief Executive Officer has delegated corporate authority for the preparation and administration of the CYQAP to the Vice President n - Nuclear Oversight. (See Figure 1-1)

U l.2.1.1 The President and Chief Executive Officer maintains contact with the cuality assurance activities through meetings with the Vice President - Nuclear Oversight, the receipt of various documents, such as: periodic progress reports, Nuclear Safety Assessment Board meeting notes, and audits related to CY's nuclear program implementation at the Haddam Neck Plant.

1.2.1.2 The President and Chief Executive Officer resolves all disputes  ;

related to the implementation of this CYQAP for which resolution  !

is not achieved at the appropriate organizational levels within the nuclear organization.

1.3 GENERAL RESPONSIBILITIES 1.3.1. The head of each CY department performing quality activities is responsible for: j i

a. Administering those activities within their organization which are l required by the CYQAP:

(v QAP 1.0 1 CYQAP REV: 01

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b. Ensuring implementation of the CY Quality Assurance Program:

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c. Establishing and clearly defining the duties and responsibilities of personnel within their organization who perform quality activities;

d. Planning, selecting, and ensuring that personnel are trained to meet j the requirements of the CYQAP; and

e. Performing and coordinating quality activities within their  :

organization and interfacing with the CY Oversight organization as  !

j required in program implementation.

1.3.2.' Each individual performing or verifying activities affecting quality is  !

responsible to conduct those activities in accordance with the requirements i of the CYQAP and implementing procedures.

i 1.3.3 The responsibility, authority, and organizational relationship for t

performing quality activities within each organization is established in CY

, organizational charts, policy statements, and written job or functional i descriptions. .

i l.4 ORGANIZATION CONNECTICUT YANKEF AT THE HADDAM NECK PLANT j The President and Chief Executive Officer - NU Nuclear Group- reports to the i NU Chairman, President, and Chief Executive Officer. He has overall l responsibility for the development and implementation of the CYQAP. The

! President and Chief Executive Officer has delegated the necessary authority and j has assigned responsibility for development and implementation of the CYQAP 1 for the Haddam Neck Plant respectively to the Vice President - Nuclear Oversight, and the Executive Vice President and Chief Nuclear Officer -

Connecticut Yankee. (See Figure 1-2).

l 1.4.1 The Vice President - Nuclear Oversight responsibilities include:

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a. Direction of the CY Quality Assurance Program;

[ b. Implementation of policies and procedures; 4

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c. Verifications through a planned program of audits, surveillances, and l inspections to assure compliance with 10 CFR 50, Appendix B and other regu:atory requirements; and i

d. The implementation of the CYQAP requirements.

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QAP 1.0 2 CYQAP I

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- 1 p The Vice President provides management with objective evidence of the iV performance of activities affecting quality, independent of the individual '

or group directly responsible for performing the specific activity. He has j the authority and organizational freedom to verify activities affecting I J quality. This is performed independent of undue influences and j j

responsibilities for schedules and costs. He has the responsibility and l l authority, delineated in writing, to stop unsatisfactory work and control

! further processing, delivery, or installation of nonconforming materials.

He also has the responsibility and authority to identify quality problems, to j recommend or provide solutions, and to verify their implementation.

i The Vice President - Nuclear Oversight is also responsible for the Employee Concerns Program, Independent Safety Engineering and Operating Experience Program and the Audit program. Specifically, the i

key support activities for the Nuclear Oversight program at the HNP are provided by-3 1.4.1.1 Director - Employee Concerns The Director - Employee Cpncems is responsible for the direction

. and administration of the Employee Concerns Prograiu for

Northeast Utilities. The Director assures that nuclear safety

, concerns receive appropriate management attention and that

{ concerns are addressed in a timely manner.

1.4.1.2 Director- Audits and Evaluation The Director - Audits and Evaluation is responsible for the i direction and administration of the audit program to verify: I

! compliance with 10 CFR 50, Appendix B, other regulatory l

! requirements; and implementation of the CYQAP requirements l and evaluate performance. The Director provides support to the j CYQAP as described in the Nuclear Oversight Department  !

Procedures.

l 1.4.1.3 Director - Performance Evaluation The Director - Performance Evaluation is responsible for the direction and administration of the Nuclear Oversight program at

the HNP as well as the other nuclear units within the NU system.

l At CY he is assisted by the the Manager - CY Oversight.

1.4.1.4 Manager - CY Oversight The Manager - CY Oversight manages the audit, surveillance and i inspection activities of the H'NP.

He is responsible for:

CYQAP

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a. Managing the Nuclear Oversight program for audits, suneillances and inspections;

b. Verifying compliance with 10 CFR 50, Appendix B and other regulatory requirements;

c. Verifying the imldtNfatation of the CYQAP The Nuclear Oversight Organization is described in the Northeast Utilities Quality Assurance Program Topical Report (NUQAP). The specific functions within the Nuclear Oversight organization applied to the CYQAP are described herein. Additional support functions are provided on an as needed or as requested support basis,

f. Serving as the primary NU Nuclear Oversight management interface with HNP management; and

g. Stop unsatisfactqry work.

The Manager - CY Oversight is a member of the CY Nuclear Safety Assessment Board.

O The Manager-CY Oversight has direct communication to the CY staff, Directors and Executive Vice President and provides the daily interaction on matters affecting quality, nuclear safety, and nuclear related activities.

1.4.1.5 Manager - Nuclear Safety Engineering The Mar,ager-Nuclear Safety Engineering manages the day-to-day activities of the Northeast Utilities Independent Safety Engineering Program and the Operating Experience Program in compliance with the appropriate unit Technical Specifications and licensing commitments. Operating Experience personnel are assignea to support the CY Oversight Manager. The Manager-Nuclear Safety Engineering provides technical direction for the CY Operating Experience activities.

QAP 1.0 4 CYQAP REV: 01

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1.4.2 The Executive Vice President and Chief Nuclear Officer -The CY EVP

& CNO has the overall responsibility to implement the CYQAP at the

) HNP and in providing support services to the operating staff.

l.4.2.1 The Director Site Operations and Decommissioning (DSOD) is responsible for implementation of the CYQAP for the unit and is responsible for the HNP's safe operation. He has control over those support activities necessary for safe operation, maintenance and decommissioning of the plant. He has delegated the necessary i authority and assigned responsibility for the management of these i j activities to the:

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! i 1.4.2.1.1 Unit Director i

The Unit Director is responsible for the direction and

, administration of the unit's' Operations, Mechanical, Electrical, and I&C, unit Maintenance and Modifications, Technical ,

Specification Surveillance Planning and Scheduling, Security, y) Chemistry, Health Physics, and Radwaste activities. The Plant Operations Review Committee (PORC) reports to the Unit Director in compliance with Technical Specifications.

1.4.2.1.2 Engineering Director The Engineering Director is responsible for the administration of Unit Design Engineering, Radiation Protection Engineering, Engineering Programs, Configuration Management Program, and Licensing. He is responsible for maintaining the Design Bases in accordance with the Licensing Bases. He is also responsible for regulatory compliance; commitment management; self assessment and corrective action programs administration.

1.4.2.1.3 Business Manager The Business Manager is responsible for managing and coordinating the financial reporting and control functions for CYAPCO during decommissioning. He oversees materials, inventory reduction and salvage and the administration of contracts.

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QAP 1.0 5 CYQAP REV: 01 9

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l 1.4.2.1.4 Decommissionine Project Mananer 1 The Decommissioning Project Manager is responsible for the overall management of work planning and scheduling for unit l operations, decommissioning, demolition, and dismantling l activities. l i

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\ QAP 1.0 6 CYQAP REV: 01 J

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CY ORGANIZATIONAL STRUCTURE President and Chief Executive Officer-NU Nuclear Group l i

Vice President-Nuclear Oversight l Executive Vice President and Chief Nuclear Officer -CY l Director-Performance Evaluation l DirectorSite Operations and Decommissioning l CY Oversight Manager Unit Director l_

l Engineering Director l_ ,

Business Manager n;# {

FIGURE l-1 Rev 01 Decommissioning Project Manager l 1

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CY ORGANIZATION and QUALITY FUNCTION Vice President- Nuclear Oversight Executive Vice President and Nuclear Safety Assessment Board Chief Nuclear Officer Director-Performance Evaluation  ; Director Site Operations and Decommissioning CY Oversight Manager Unit Director l Manager-NSE l Engineering Director l l

i I TD l Business Manager lNuc Safety Engl lQA Engineering l Decomm.issionmg Project Manager l QA Supervisor l l

Note i T D-Technical Direction

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l Audit ll QA 5talT l 2 Audit Schedules and Audit Reports are approsed by the Director-Audits and Evaluation The CY Oversight Manager is also supported by the Director-Audits and Evaluathm QAP 1.0 .

CYQAP Rev 01 FIGURE l-2

2.0 QUALITY ASSURANCE PROGRAM 4

2.1 GENERAL REOUIREMENTS NU has established the CYQAP for the HNP which complies with the criteria of 10 CFR 50, Appendix B and follows the guidance referred to in Appendix C and Appendix E, herein. The quality assurance requirements set forth herein, supplemented by the Quality Assurance Procedures, provide the primary basis of the Program and the NU Policy with regard to quality assurance. This program is established for the HNP in a manner intended to accomplish the required level of quality and is carried out throughout the life of the plant. It includes quality activities during the maintenance and modification of the HNP.

The CYQAP is also established, maintained and executed with regard to 4

Radioactive Material Transport Packages described in 10 CFR 71.101(f).

The CYQAP applies in its entirety to activities affecting the safety functions of systems, structures and components. Such activities are quality activities as defined in Appendix A herein. Portions of the CYQAP are also applicable to the Fire Protection Quality Assurance (FPQA)and the Radwaste Quality Assurance (RWQA) programs which are delineated as Augmented Quality in established procedures.

n U The requirements of this Program are implemented by Connecticut Yankee Atomic Power Company which operates the HNP and their vendors performing activities affecting quality systems, structures, and components at the IBIP.

Procedures define the required indoctrination and training of personnel performing activities affecting quality, as necessary, to assure that suitable proficiency is achieved and maintained.

Training sessions are documented. The content is described, attendees and attendance date(s) indicated, and the results of the training session (s)( e.g.,

satisfactory examination results) recorded.

(V QAP 2.0 7 CYQAP REV: 01

A periodic program review of the status and adequacy of the CYQAP is accomplished by:

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() e audits, surveillances and inspections; e CY Nuclear Safety Assessment Board (NSAB) reviews; and e oversight of the CYQAP audit program.

Vendors are required to review the status and adequacy of that part of the Quality Assurance Program for which they have designated responsibility.

2.2 IMPLEMENTATION 2.2.1 GOALS AND OBJECTIVES The goals of the CYQAP are to maintain quality levels in an effective and efficient manner and to assure a high degree of functional integrity and reliability of quality systems, structures and components. To meet this goal, the following objectives of the CYQAP have been defined:

a. Define through documented procedures, the quality activities that apply to the maintenance and modification of the HNP;

]n b. Establish, assign, and document the responsibilities for the conduct of those activities affecting quality systems, structures and components;

c. Establish confidence that:

. The maintenance and modification of the HNP is performed in a manner consistent with NU Policies, and

. Quality activities are performed by responsible personnel, and are verified through a system of audits, surveillances, and inspections of those organizations with quality responsibilities;

d. Appraise the President and Chief Executive Officer - NU Nuclear Group of unresolved problems and trends which could have a significant effect on nuclear safety.

. (~'s V QAP 2.0 - 8 CYQAP REV: 01

2.2.2 PROGRAM DOCUMENTATION (VD The CYQAP defines the NU nuclear goals and objectives and is used as guidance for the development of the various implementing procedures. Revisions to the CYQAP will be made as needed to reflect current requirements and descriptions of activities prior to implementation. These revisions will be made in accordance with CY procedures.

Revisions to the CYQAP, which reduce commitments previously accepted by the NRC, are submitted to the NRC for review and approval prior to implementation.

Revisions which do not reduce previously accepted commitments are periodically submitted to the NRC as required by 10 CFR 50.54 (a)(3) and 10 CFR 50.55 (f)(3).

Quality procedures are developed, reviewed and approved by the departments performing quality activities. The CY Oversight Department reviews other department quality procedures for compliance with the CYQAP and concurs on such procedures. Changes to procedures are subjected to the same degree of control as that utilized in the preparation of the original document.

2.2.3 SYSTEMS STRUCTURES. AND COMPONENTS The requirements of the CYQAP shall apply, as a minimum, to all safety related systems, structures, and components, as addressed in the Safety Analysis Reports (SARs). Safety systems, structures, and components are identified in Appendix A of the CYQAP and also as specifically identified in the CY UFSAR that address Section 3.2.1 of NRC Regulatory Guide 1.70. Currently, the Materials, Equipment, and Parts List (MEPL) program provides instructions to identify structures, systems, components, parts, materials, and consumables that need to be safety-related or augmented quality. (The CY Engineering organization is considering an alternate process that can be utilized by the CY organization in place of the MEPL program that will provide the necessary guidance to perform and document determinations of systems and components in order to comply with the quality requirements contained herein. Process changes will be performed in accordance with CY administrative procedures and QAP 5.0)

For systems, structures and components, covered by the ASME Code, procedures describe the measures taken to assure that the quality assurance requirements contained in the code are supplemented by the specific guidance of the applicable i I

regulatory guides listed in Appendix C of this Program.

n b QAP 2.0 9  !

CYQAP REV: 01

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1 For systems, structures and components, regulatory commitments and procedures describe the measures taken to assure that the quality assurance requirements are V met.

l The degree of control over activities affecting quality systems, structures, and components is consistent with their importance to safety. The CYQAP provides controls that include the use of appropriate equipment; establishment of suitable j controls over special processes and skills necessary to attain the required quality; and the need for verification of quality by inspection and test.

l CY Oversight and applicable CY line organizationsjointly determine and identify l the extent quality assurance controls are to be applied to quality structures, systems, and components. The quality assurance controls are in conformance with this CYQAP, which complies with 10 CFR 50, Appendix B.

2.2.4 PARTICIPATING ORGANIZATIONS Northeast Utilities requires that its vendors invoke upon their subcontractors, via Purchase Orders / Contracts, requirements for a quality assurance program to meet the applicable criteria of 10 CFR 50, Appendix B including the applicable elements of the Regulatory Guides and their endersed Standards identified in Appendix C herein. However, NU retains overall responsibility for the QA n Program. The specific quality activities performed by these organizations are

() specified in the procurement documents. Nuclear Materials and Document Management is responsible for the review and approval of vendor quality assurance programs prior to initiation of contracted activities. The object of the review is to verify that the vendors have an adequate quality assurance program to meet applicable requirements of 10 CFR 50, Appendix B.

In addition to the initial review, Nuclear Materials and Document Management is responsible for the subsequent performance, as appropriate, of audits, surveillances, and inspection of a vendor's quality assurance program to assure continued implementation of quality requirements. Nuclear Materials and Document Management has contracted the performance of this function to the Yankee Atomic Electric Company (YAEC)in accordance with the Northeast Utilities Quality Assurance Program.

The Nuclear Oversight Department also performs on-site audits, surveillances, and inspections, as appropriate, of the vendor activities.

Vendors may be delegated the execution of quality assurance functions by contract. These contracts are reviewed and approved in accordance with program requirements.

QAP 2.0 10 CYQAP REV: 01

2.2.5 INDOCTRINATION AND TRAINING l

( A program is established and maintained for quality assurance indoctrination and training which provides confidence that the required level of personnel competence and skill is achieved and maintained in the performance of quality ,

activities. Quality procedures delineate the requirements for an indoctrination i program to assure that personnel responsible for performing quality activities are instructed in the purpose. scope, and implementation of quality procedures and instructions and that compliance to these documents is mandatory. Each CY Director is responsible for ensuring appropriate indoctrination and training of assigned personnel performing quality activities. ,

1 Nuclear training programs shall be developed and implemented to provide training for individuals attached to or associated with the HNP. Additional guidance is established in procedures.

Implementing procedures describe the nuclear training program requirements which assure that:

Documentation of formal training and qualification programs includes the i objective, content of the program, attendees, date of attendance, and examination results, as applicable; m

l ) Proficiency of personnel performing and verifying activities affecting V

quality is established and maintained. Personnel proficiency is established and maintained by training, examination / testing, and/or certification based upon the requirements of the activity. Acceptance criteria are developed to determine if individuals are properly trained and qualified; and Certificates or other documentation of qualification clearly delineate the specific functions personnel are qualified to perform and the criteria used to qualify personnelin each function.

2.2.6 MANAGEMENT OVERSIGHT OF THE OUALITY ASSURANCE PROGRAM The CY Executive Vice President and Chief Nuclear Officer ensures that a management review of the CY Quality Assurance Program is conducted annually to assess the effectiveness of the QA program. This is accomplished by performing an independent assessment of the program in accordance with the Technical Specifications. In addition, the CY Nuclear Safety Assessment Board performs an oversight of the program in accordance with the approved charter.

Results of the assessments and reports are forwarded to the Executive Vice President and Chief Nuclear Officer and the Vice President-Nuclear Oversight for ps appropriate corrective action, as necessary.

\ QAP 2.0 11 CYQAP REV: 01 e

QAP3.0 DESIGN CONTROL A)

V 3.1 GENERAL REOUIREMENTS The CY Engineering Director is responsible for controlling design work, administering design control activities (including design interface), and design modifications for quality I systems, structures and components.

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The CYQAP for design control is established to assure that the applicable design requirements, such as design bases, regulatory requirements, codes, technical standards and quality standards are identified in design documents which are reviewed, approved and controlled in accordance with established procedures. Such controls include a review for suitability of application of materials, equipment, pans and processes that are essential to the functions of the systems, structures and components. Changes to, and deviations from, j specified requirements are identified, documented and controlled.

The responsibility for the design control program rests Uth the CY Engineering Director. l The division of responsibilities and jurisdictional boundari:s for program implementation are set forth in the appropriate CY administrative procedures. Although other organizations may be delegated the task of establishing and executing the design control program or any part thereof, the CY Engineering Director will retain the ultimate responsibility for the program. The applicable requirements of the CYQAP will be imposed on other p organizations delegated the task of establishing or executing the program in accordance V with QAP 4.0, " Procurement Document Control" and QAP 7.0," Control of Purchased Material, Equipment and Services," herein.

The interface controls, both intemal and external, for organizations performing design work for quality systems, structures and components are identified and implemented in accordance with documented procedures. This identification includes those organizations providing criteria, designs, specifications and technical direction.

Measures are applied to verify the adequacy of design. The extent of design verification is specified and documented by the responsible organization. The individuals performing design verification should not:

(1) have immediate supervisory responsibility for the individual performing the design; (2) have specified a singular design approach; (3) have ruled out certain design considerations; or (4) have established the design inputs for the particular design aspect being verified.

O QAP 3.0 12 V CYQAP REV: 01 o

The independent design verification should not dilute or replace the responsibility of the

/7 supervisors for the quality of work performed under their supersision. Where changes to V previously verified designs have been made, design verifications are required for the change, including evaluation of the effects of those changes on the overall design. Design verification may be accomplished by testing. Tests to demonstrate adequacy under adverse design conditions shall comply with the requirements c,f QAP 11.0, " TEST CONTROL."

Design errors and deficiencies which adversely affect quality systems, structures and components in design process are documented, and appropriate corrective action is taken.

These design errors and deficiencies are documented in accordance with design change procedures or as defined in QAP 16.0," Corrective Action."

3.2 IMPLEMENTATION The CY Engineering Director is responsible for the design, design review, engineering approval of design changes, design evaluation and design control at the HNP. The function may be delegated to other organizations to perfomi the design activity, or any part thereof, but the responsibility for overall design remains with the CY Engineering Director. In all cases, final engineering decisions and ultimate design control of systems, structures and components related to the HNP is the responsibility, of the CY Engineering Director.

The CY Oversight department performs audits, surveillances, and inspections, to verify that

,m Departments are effectively complying with the CYQAP and procedural requirements for

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design control.

Nuclear Materials and Document Management is responsible for the performance, as appropriate, of oft-site audits, surveillances, and inspections, to verify that vendors are effectively complying with the CYQAP and/or the NUQAP and procedural requirements for design control.

CY and NU Oversight perform, as appropriate, on-site audits, surveillances, and inspections of these vendor activities.

3.2.1 DESIGN PROCESS Design control measures are applied to design analyses, such as: stress, thermal, hydraulic, nuclear radiation, accident and seismic analyses; compatibility of materials; accessibility for required inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and test. Measures establi.shed to ccntrol design documents are described in QAP 6.0," Document Control."

O b QAP 3.0 13 CYQAP REV: 01

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Program procedures and instructions define the method of implementing design

,O control measures. These measures require that applicable design requirements,

d such as, design bases, regulatory requirements, codes and standards, are translated 4

into specifications, drawings, procedures or instructions. Instructions further l

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require that appropriate quality standards are specified and included in design l documents. All materials, equipment, parts and processes, including standard "off I the shell" commercial or previously approved items essential to the quality functions, are selected and reviewed for suitability of application.

l The basis for selection may include industry standards, material and prototype i hardware testing programs, and design review. '

CY procedures assure that a documented check is performed to verify the accuracy and completeness of design drawings and specifications before release for use.

Design drawings and specifications issued for design changes are reviewed for completeness and accuracy before being released to operations, in accordance with CY procedures.

CY procedures describe the provisions to assiire< hat design drawings and specifications are prepared, reviewed and approved in accordance with company procedures, and that the documents contain the necessary quality assurance O requirements, such as inspections and test requirements, acceptance requirements, and the extent of documenting inspection and test results.

3.2.2 DESIGN CHANGE CONTROL Procedures and instructions govern design change control during modifications to the HNP. Control of discrepant or deficient design conditions, and reported unsatisfactory performance, provide for the identification of design changes and a documented method to control these changes. Design and specification changes are subject to design control measures commensurate with those applied during the original design.

An independent review and approval of design changes is performed by the organization that conducted the original design reviews, unless another qualified organization is designated to perform this function.

Proposed design change modifications are submitted to management for processing and review. This review includes the review by the Plant Operations Review Committee (PORC). PORC advises the CY Unit Director on matters relating to nuclear safety. Composition, responsibilities, and authority of the QAP 3.0 14 CYQAP REV: 01

committee are defined in Section 6 of the CY Technical Sp'ecifications. If the ,

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U proposed change involves a quality system structure or component, the change will be reviewed by qualified engineering personnel for technical adequacy.

Reviews of the safety evaluations associated with design change requests are performed by the CY Nuclear Safety Assessment Board. The sequence of the NS AB review depends u' pon the determination of whether an unreviewed safety 1

question is involved (i.e., in accordance with 10 CFR 50.59, if a proposed change j in the facility involves an unreviewed safety question then the NSAB and NRC l

approval is required prior to implementation). '

The combination of these independent reviews by the PORC and NSAB are performed to assure that:

a. The adequacy of the p oposed change is substantiated;

b. Unreviewed safety questions are properly identified and dispositioned per 10 CFR 50.59; and

c. Nuclear safety requirements have been addressed.

Errors and deficiencies in design, including the design process, that could adversely affect quality structures, systems, and components are documented and

/~~N corrective action is taken in accordance with QAP 16.0," Corrective Action."

U Notification of design changes are transmitted to responsible plant personnel as ,

part of the design package close out. CY procedures describe this notia ation l which assures that personnel are made aware of design change modifications.

3.2.3 DESIGN INTERFACE CONTROL The CY Engineering Director is responsible for review, coordination and documentation of design interfaces. Procedures provide for the method for identifying design interfaces, changes, and modifications affecting drawings and design documents.

Procedures and instructions identify design interfaces which are controlled by the l Executive Vice President and Chief Nuclear Officer.

3.2.4 INDEPENDENT DESIGN VERIFICATION Design changes are reviewed for adequacy and the sign-off performed by a person other than the originator of the design. Design verification is documented in j accordance with procedures or instmetions. Simplified calculations or computer n

] QAP 3.0 CYQAP 15 REV: 01 l

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I programs may be utilized as alternate means of design verification. When design

, verification is performed by testing, the tests are performed using approved procedures, which specify the authority and responsibility of design verification personnel. Ultimate responsibility for design adequacy and evaluation is retained by the CY Engineering Director.

Design verification (if other than by qualification testing) is normally completed

prior to release for procurement, manufacturing, and construction, or to another organization for use in other design activities. For those cases where design verification cannot be completed prior to release for procurement, manufacturing, i and construction, procedures ensure that design verification is completed prior to the point when the installation is declared operational.

, CY procedures describe the requirements which assure the following when testing l is considered as an alternate method of design verification:

a. Specifications or procedures provide criteria that specify when i

! verification should be by test.

b. Prototype, component or feature testing is performed as early as possible prior to installation of plant equipm'entror prior to the point when the ,

installation is declared operational.  !

c. Verification by test performed under conditions that simulate the most adverse conditions as determined by analysis.

Particular emphasis is placed on assuring that designs are in conformance with applicable codes, and on selecting the proper design verification or checking ,

method. Procedures and instructions provide the requirements and necessary controls for design verification. These controls include a review to assure that design characteristics can be controlled, verification that there is adequate accessibility for inspection or test, and that inspection and test acceptance criteria are incorporated. Documentation of reviews is provided. j CY procedures include requirements which identify the responsibility of design verifiers, the areas and features to be verified, and the extent af the documentation.

QAP 3.0 16 CYQAP ,

REV: 01

J CY procedures assure that procedural control is established for design documents i that reflect the commitments of the SAR. These procedural controls vary for O} design documents which receive formal design verification by several disciplines or organizations, and those which can be reviewed by a single individual. The i specific design documents and specialized reviews are determined and used as l

required by the design changes and modifications. '

CY procedures are established to assure that verified computer programs are certified for a specific use.

The CY Engineering Director is responsible for assuring that design documents provided by vendors are adequately approved and maintained.

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O P QAP 3.0 17 CYQAP REV: 01 )

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QAF4.0 PROCUREMENT DOCUMENT CONTROL b

V 4.1 GENERAL REOUIREMENTS The procurement of materials, equipment, parts and/or senices required during the maintenance and modification of quality systems, structures and components at the HNP is performed in a controlled manner which assures compliance with applicable regulatory requirements, procedures, quality assurance standards and regulations affecting procurement documents. Changes to procurement documents are subject to the same degree of control as utilized in the preparation of the original documents.

4.2 IMPLEMENTATION l

4.2.1 PROGRAM Material and senice requests are reviewed for technical adequacy and verification

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of the quality designation. The appropriate engineering management reviews and

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approves material and service requests, as applicable. j Nuclear Materials and Document Management personnel perform a procurement engineering evaluation to ensure the inclusion arid adequacy of technical and quality assurance requirements prior to the issuance of the Purchase Order.

l Material for which technical and quality assurance requirements have been i (V'T previously established are procured without additional procurement engineering  !

evaluation.

Vendors utilized in the maintenance and modification of the HNP are responsible to implement measures for control of procurement documents associated with quality material, equipment, parts and services to ensure applicable requirements including quality assurance requirements are specified.

Nuclear Materials and Document Management performs, as appropriate, off-site audits, surveillances, and inspections to ensure that vendors are effectively complying with the requirements for the control of procurement documents.

CY Oversight performs, as appropriate, on-site audits, surveillances, and insreections of these vendor activities.

Changes to procurement documents are subjected to the same degree of control as that utilized in the preparation of the original document. The procurement of spare j or replacement parts for quality systems, structures, or components is subject to the controls of the CYQAP and implementing procedure requirements. The spare or replacement parts are subject to controls equivalent to original or subsequent l O QAP 4.0 18 CYQAP REV: 01 l

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codes and standards. The use of subsequent codes and standards are controlled m j accordance with the design change control requirements in QAP 3.0, " Design  :

Control." l Procurement engineering evaluations of quality related material and services requests are performed by Nuclear Materials and Document Management l personnel to ensure that:

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a. Adequate technical requirements are specified; l

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b. The quality assurance requirements are correctly stated, auditable and j l controllable; and

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c. There are adequate acceptance and rejection crit:ria.

l l l 4.2.2 PROCUREMENT DOCUMENT PROVISIO i I

Procurement documents are prepared, reviewed and approved in accordance with procedures of the issuing organization or department and are avaifable for l

verification. These procedures require that procurement documents consist of the .

following, as necessary: -

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a. The scope of work to be performed; O b. Technical requirements (specified or referenced) including the applicable I

components and materials identification requirements, drawings,  !

specifications, procedures, instructions, codes and regulations, and the I identification of applicable test, inspection and acceptance requirements, I or special process instructions;  ;

c. CYQAP requirements to be imposed on contractors which include the applicable requirements of 10 CFR 50, Appendix B, and the NRC .

regulatory position contained in the Regulatory Guides and their endorsed ANSI Standards listed in Appendix C, herein;

d. Right of access which provides, as appropriate, for access to contractor  !

facilities and records for inspection or audit by NUSCO/CYAPCO or its designated representative; and provides access for events such as those requiring notification of hold points; and/or l e. The documentation required to be prepared, maintained, and/or submitted to NUSCO/CYAPCO or its representative for review, approval or historical record. The time of submittal of this documentation and the QAP 4.0 19 l CYQAP REV: 01 1

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retention and disposition of quality as urance records which are not O submitted to NUSCO / CYAPCO is prescribed, as applicable, for Nuclear Grade procurements.

4.2.3 SELFCTION OF PROCUREMENT SOURCES If the vendor is not specified, the function of procurement source selection is the responsibility of the NUSCO Purchasing Department. The Purchasing Department verifies that the procurement document has been reviewed and approved, and that the vendor has been approved for procurement prior to issuing the purchase order for the material, equipment, parts and services.

Purchase Orders / Contracts may be issued to organizations with unapproved quality assurance programs. These procurement documents to unapproved organizations contain detailed supplementary quality assurance requirements and/or witness / hold points to verify NUSCO/CY requirements.

Material requisitions are reviewed by Nuclear Materials and Document Management to ensure appropriate quality assurance requirements are specified.

These requirements, included in the procur,ement document, as necessary, include acceptance criteria, audits, surveillances and/or inspections at the vendor's facilities with scheduled witness / hold points during the fabrication process and/or prior to shipment of the procured item. Acceptance inspections and tests O determined by NUSCO/CYAPCO shall be performed after receipt at the HNP but prior to operability.

QAP 4.0 20 CYQAP REV

01

QAP5.0 PROCEDURES. INSTRUCTIONS. AND DRAWINGS

5.1 GENERAL REOUIREMENTS 4

The CYQAP provides measures for the preparation, review, approval, control and distribution of procedures, instr 6ctions and drawings of activities affecting quality systems, structures and components during maintenance, modification, and decommissioning of the HNP. The documents include appropriate quantitative and qualitative acceptance criteria which specify the activity to be performed; the methods of construction and testing to be employed; material, equipment or parts to be used; a sequence of operation and the required documentation.

5.2 IMPLEMENTATION J

J Quality procedures provide direction for personnel performing quality functions. CY Oversight reviews and concurs with quality procedures as defined in the CY administrative control procedures. Comments concerning compliance with the CYQAP and regulatory

requirements are resolved prior to issuance of the procedure.

l Vendors utilized in the maintenance and modification of the HNP may be delegated I

responsibility for preparing, maintaining, issuing andv' erifying the implementation of

! program documents which are selectively reviewed / approved by the appropriate Director. i Nuclear Materials and Document Management is responsible for the performance, as  ;

appropriate, of off-site audits, surveillances, and inspections of the quality assurance l programs to ensure the vendors are effectively complying with the requirements for I procedures and instructions.

l CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of these vendor activities. Vendor programs are required to clearly delineate the actions to be accomplished in the preparation, review and control of procedures, instructions and drawings and the methods for complying with 10 CFR 50, Appendix B.

5.2.1 PROCEDURES AND INSTRUCTIONS Procedures and instructions for activities affecting quality are prepared, reviewed, and approved in accordance with written procedures and instructions.

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QAP 5.0 CYQAP 21 REV: 01 e

The appropriate CY Director ensures that any vendors utilized in the maintenance O and modification of tb HNP, implement quality assurance programs which contain written instructions for preparation, review and approval of procedures and instructions affecting quality. In addition, vendor's site quality procedures  !

and quality control inspection procedures are reviewed for concurrence by CY  :

Oversight to assure contpliance with the vendor's QA Program.

The CY line organization is responsible for the preparation, review and approval  ;

of plant quality procedures. The procedures include test procedures and overall i site administrative procedures which implement the requirements of the CYQAP. )

CY Oversight reviews and concurs with quality procedures and special process manuals and procedures. The criteria for documents requiring CY review are  !

defined in CY administrative procedures to ensure that:

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a. Administrative manuals and procedures which implement the CYQAP are reviewed for compliance with the CYQAP and applicable Appendix C guides and standards, and

b. Work Procedures / Work Documents used to perform quality activities are reviewed to assure appropriate. quality assurance controls have been specified.

5.2.2 DRAWINGS O The design control and verification measures described in QAP 3.0, are applicable for the review and approval of drawings. Review and approval of new drawings or changes to existing drawings are described in CY procedures. The originating organization may delegate to other organizations or departments the work of design and review activities, or any part thereof, but retains responsibility for this work.

The measures taken to assure the preparation of as-built drawings and related documentation in a timely manner to accurately reflect the plant are described in CY procedures. Drawings critical to the maintenance of the long term fuel storage are updated prior to system turnover to operation and are available to the operating personnel.

5.2.3 ACCEPTANCE CRITERIA Review and approval of departmental procedures, instructions and drawings is described in CY procedures to ensure the inclusion of adequate quantitative and qualitative acceptance criteria for determining satisfactory work performance and quality compliance. These criteria apply to quality activities as defined in the CYQAP, O QAP 5.0 CYQAP 22 REV: 01

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QAP6.0 DOCUMENT CONTROL U 6.1 GENERAL REOUIREMENTS The CYQAP provides measures to assure controlled distribution of documents pertinent to Quality Activities affecting the safety related functions of stmetures, systems, and components in accordance with CY quality procedures and 10 CFR 50, Appendix B.

Documents such as procedures, instructions, drawings, specifications and reports are prepared, reviewed for appropriate qualitative and quantitative acceptance criteria, and approved by authorized personnel in the afTected organization. Approved controlled documents are distributed to affected locations in accordance with a controlled distribution list. Changes to controlled documents are reviewed and approved by the same organization which performed the original review and approval, unless otherwise specified in the implementing procedures. Measures are provided for controlling documents to preclude the possibility of the use of outdated documents.

6.2 IMPLEMENTATION 6.2.1 RESPONSIBILITY .

CY procedures and instructions delineate the measures ~ for controlling documents

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U including direction for the review for adequacy, approval by authorized personnel, distribution of controlled documents and verification that changes are promptly incorporated and implemented. These control measures apply to applicable documents a Tecting systems, structures and components for the maintenance and modification of the HNP, such as:

a. Design Specifications;

b. Design, Manufacturing, Construction and %stallation Drawings;

c. As-Built Documents;

d. Quality Assurance Program Manuals, Procedures and Instructions;

e. Manufacturing, Inspection and Testing Instructions;

f. Test Procedures;

g. Calculations;

h. Engineering Record Correspondence; QAP 6.0 23 k CYQAP REV: 01

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i. Design Basis Documentation; J. Final Safety Analysis Reports;  !

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k. Procurement Documents;

< l. Design Change Records; - i 1

l m. CY Quality Assurance Program; 1 2

n. Nonconformance Reports; and i i 2

o. Computer Codes. -l 1 .

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- CY procedures describe the measures taken for the control of documents to assure  !

j review and concurrence, as necessary, with regards to quality assurance aspects. ,

i j The requirements for control of procurement documents are contained in QAP l

4.0, " Procurement Document Control." During all phases of plant life, it is the '

I responsibility of each organization issuing controlled documents to employ I document control procedures. The issuing organization is additionally responsible =

l for distribution of the documents to appropriate locations. There shall be  !

[- provisions to assure that approved changes are included in instructions, j procedures, drawings and other documents pc ior to implementation of the changes.

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l Vendors utilized by CY in the maintenance and modification of the HNP are

! responsible for implementing measures for review, approval, control and distribution of controlled documents, to ensure they are effectively complying with the requirements for document control.

i

! Nuclear Materials and Document Management is responsible for the performance, j' as appropriate, of off-site audits, surveillances, and inspections of the vendors to j verify compliance with their approved quality assurance programs. I l 1 4

J i CY Oversight performs, as appropriate, on-site audits, surveillances, and )

! inspections of these vendor activities. l 6.2.2 DISTRIBUTION OF CONTROLLED DOCUMENTS l

4 CY procedures, specify in what manner controlled documents and revisions j thereof, are distributed to appropriate locations, prior to commencing the work. j QAP 6.0 24  :

CYQAP-

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/O 6.2.3 DRAWING CONTROL

U The Nuclear Document Services Organization is responsible to implement a program for the retention and retrieval of drawings and records submitted by cognizant CY personnel. The Nuclear Document Services Organization maintains a drawing status file which includes drawings (newly issued or revised) with the

! latest revision and current status.

j The vendors utilized during the maintenance and modification of the HNP may be j delegated the function ofdrawing control and must furnish periodic status reports  ;

listing the revisions of applicable drawings issued.

Nuclear Materials and Document Management is responsible for the performance of off-site audits, surveillances, and inspections of vendors to verify they are

effectively complying with their programs for document control of drawings.

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CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of vendor activities.

6.2.4 INSTRUCTION AND PROCEDURE CONTROL .

,p CY Oversight performs audits, surveillances, and inspections of departments and, l d as appropriate, any on-site vendors utilized in maintenance and modification to i the HNP to ensure they are effectively complying with their QA program for

control of procedures and instructions.

The originating department is responsible for establishing adequate control over

quality procedures and instructions issued by the vendor. The responsible

, organization also issues status reports or revised indices listing the latest revision

] of applicable controlled documents issued by the vendor. Procedures identify

! requirements for assuring controlled documents are available at the work location prior to commencing work.

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QAP 6.0 25 CYQAP i

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QAP7.0 CONTROL OF PURCHASED MATERIAL. EQUIPMENT.

J AND SERVICES 7.1 GENERAL REOUIREMENTS Measures for the control of procured material, equipment, parts and services by or for CY related to the safety of nuclear power plants are established and imposed by the CYQAP l during maintenance and modification to the HNP to ensure conformance to procurement documents. These measures include provisions for source evaluation and selection, .

submission ofobjective evidence by the contractor or subcontractor, inspection at the vendor source and examination ofitems upon delivery. Control of quality by vendors and subcontractors is assessed for effectiveness at intervals consistent with the importance, complexity and quantity of the product or service. i 7.2 IMPLEMENTATION The evaluation and selection of vendors is performed in accordance with procedures, which specify that procurement source evaluation and . selection measures are performed to detennine vendor capability and delineate responsibilities of qualified personnel involved in the evaluation and selection process. -

7.2.1 VENDOR OUALIFICATIONS O

Nuclear Materials and Document Management utilizes one or more of the following methods in evaluating the qualifications of a potential supplier:

a. Audits and/or coordinated review of a potential supplier utilizing NU/CY personnel and/or YAEC personnel;

b. Other utility supplier audits and evaluations;

c. Nuclear Procurement Issues Committee (NUPIC) audits;

d. ASME N, NA, NPT, NV. or MM/ MS Certificate of Authorization;

e. Commercial grade surveys and/or coordinated review of a potential supplier utilizing one or more departments, (i.e., Engineering, Operations and/or Purchasing); or

f. Source inspection / surveillance.

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QAP 7.0 CYQAP 26 REV: 01 d

j Evaluations ensure that suppliers employ a quality assurance program that

( conforms to applicable portions of the NUQAP Topical Report and/or the CYQAP.

$ Nuclear Materials and Document Management is responsible for maintaining documented evidence of the evaluation and acceptance of the vendor's quality assurance program. The determination of vendor approval is based on such factors as prior performance, quality performance data, audits, commercial grade surveys, surveillances and evaluations of the supplier's quality assurance program.

Veradors' Certificates of Conformance are periodically evaluated by audits, commercial grade surveys, surveillances, independent inspections and tests, to assure they are valid. This verification of Certificates of Conformance is documented.

7.2.2 SOURCE INSPECTION Nuclear Materials and Document Management is responsible for the performance of source inspections at suppliers' facilities to ensure that the requirements of a Purchase Order / Contract have been met. ,

Source inspections are perfonned in accordance with procedures which provide for the method ofinspection, the extent of documentation required, and those O responsible for implementing those instructions.

Inspection ofitems occurs either when verifications of procurement requirements cannot be determined upon receipt or the vendor's QA program has not been .

accepted by Nuclear Materials and Document Management.

Nuclear Materials and Document Management has contracted the performance of the vendor source inspection function to the Yankee Atomic Electric Company (YAEC) in accordance with the NUQAP Topical Report. CY has accepted the NU vendor QA process described in the NUQAP Topical Report based on audits performed to accept the YAEC process.

7.2.3 RECEIPT INSPECTION Receipt inspection for procured items is performed by Nuclear Materials and Document Management in accordance with quality procedures which delineate requirements and responsibilities necessary to perform inspection functions. An exception to this is Chemistry performing receipt inspection for diesel fuel in accordance with CY procedures. Contractual obligation fulfillment and specified requirements are verified during receipt inspections.

QAP 7.0 27 CYQAP REV: 01

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C Receipt inspection of supplier-furnished material and equipment is performed to assure that material, components, equipment and acceptance records are examined in accordance with predetermined inspection instructions prior to acceptance, i

installation and operation. Receipt inspections include, as appropriate:

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a. Measures for verifying that the shipment is complete, prcperly identified, 1 undamaged and corresponds with the required documentation; 1

b. Measures for inspection of the item and review of supporting j documentation (e.g., mill test reports, NDE reports) as required by the

purchase documents;

c. Measures for inspection and acceptance ofitems in accordance with predetermined methods; i

d. Measures for identifying and controlling acceptable items including l identification ofinspection status prior to release from the receipt 2

inspection area; '

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e. Measures for identifying, segregating and handling nonconforming items; l

p f. Measures to ascertain that inspection records or certificates of

( conformance are acceptable prior to release for installation; and/or j l

g. In cases involving procurement of services, the project engineer or )

, department head shall designate the means by which services may be

accepted, and is given the authority to accept services in accordance with methods defined in NU or CY procedures.

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7.2.4 VENDOR FURNISHED RECORDS Records required to be furnished by the vendor are specified in the procurement document. Certifications or documentation provided by the supplier which attests to conformance, identifies that all the specific procurement requirements have I been met (either by reference to the purchase order or by delineation).

4

The vendor must furnish the following records as a minimmn:

i a. Documentation that identifies the purchased material or equipment and the specific procurement requirements. (e.g., codes, standards and specifications) which have been met by the items; and, l

O QAP 7.0 CYQAP 28 REV: 01  !

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b. Documentation that identifies any procurement requirements which have l not been met, together with a description of those nonconformances  !

') dispositioned " accept as is" or " repair."

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The responsible Nuclear Materials and Document Management and/or other i Department personnel shall review for acceptability those dccuments which  !

pertain to the requirements in the procurement document, in accordance with the NUQAP Topical Report and/or the CYQAP and its applicable procedures.

l The Department that is contracting on-site QA services shall be responsible for l the review and acceptability of vendor personnel / equipment certifications prior to j the start of work. Nuclear Oversight or CY Oversight will provide oversight of I these activities via audit, surveillance, or inspection.

7.2.5 COMMERCIAL DEDICATION l

NUSCO / CY procedures address the measures taken to assure that commercial grade items, where specific quality assurance controls for nuclear applications cannot be imposed in a practicable manner, that special dedicatiori requirements are established and implemented. ,

i These measures follow the guidance in Regulatory Guide 1.144, paragraph C.3.b (1) and Regulatory Guide 1.123 and applicable paragraphs of Section 10 of ANSI I N45.2.13.

These measures include appropriate requirements for special categorization and identification within the procurement document, receipt inspection, and additional controls during the installation and testing process to be performed by Nuclear Materials and Document Management, CY organization and/or other appropriate groups.

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QAP 7.0 29 CYQAP REV: 01 1

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QAP 8.0 IDENTIFICATION AND CONTROL OF MATERIALS. I PARTS AND COMPONENTS l 8.1 GENERAL REOUIREMENTS 1

The CY organization assures that the identification ofinspections, tests, and operation j status of structures, systems, and components is known by affected organizations. i The CYQAP provides measures for the identification and control of material, parts and l components, including partially fabricated assemblies, during maintenance and  !

modification to the HNP. To ensure that each item can be traced to associated documentation, the identification of the item is maintained by heat number, lot number, part l number, serial number, or~other appropriate methods, and is physically marked on the item and/or on records traceable to the item. Documentation associated with material, equipment, I and components delineated that these items have been designed, fabricated, manufactured, tested and/or inspected in accordance with the specified requirements. The object of these l

controls is to prevent the use ofincorrect or defective materials, parts and components, in j

accordance with 10 CFR 50, Appendix B.  ;

8.2 IMPLEMENTATION -

NUSCO and CY procedures establish the responsibilities and requirements for the  ;

f_D identification and control of materials, parts and components. The procedures assure that  ;

identification and control is maintained throughout fabrication, receipt, handling, storage j and installation ofitems. Provisions include

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a. Requirements for traceability to appropriate documentation, such as:  !

I e Purchase orders / contracts, l

e Manufacturing documents, e Drawings, e Specifications, e Certifications, e Inspection and test records, and

. Nonconformance reports.

QAP 8.0 30 CYQAP REV: 01 1

b. Controls to assure that the correct identification of an item is verified and (9

'v' documented prior to release for fabrication, assembly, shipping or installation,

c. Requirements which assure that the method or location of markings do not affect the function or quality of an item, or

d. Establishment ofidentification requirements in purchase orders, contracts, specifications, drawings, procedures or instructions.

During the maintenance and modification of the HNP, CY may delegate any portion of the implementation of the identification and control program to a vendor contracted to perform related quality activities. If delegated, contracts require that the vendor establish an identification and control program which meets the CYQAP requirement.

l Nuclear Materials and Document Management is responsible for the performance , as  :

appropriate, of off-site audits, surveillances, and inspections of the vendor's quality j assurance program, to ensure they are effectively cc nplying with the requirements for l identification and control of materiai. equipment and components.

l

. l CY Oversight performs, as appropriate on-site audits; surveillances, and inspections of the vendor activities. - l

,s m d Receipt inspections are performed to verify that materials, equipment and components are properly identified in accordance with procurement requirements. Nuclear Materials and Document Management is responsi' ale for assigning and applying permanent identification ,

to the items in accordance with crocedures. If the application of a serial number is not l' practical, other means ofidentification are implemented to assure proper identification and traceability.

In the event that the equipment, material or component is nonconforming or the identification becomes lost or illegible, the items are considered nonconforming and are identified and controlled in accordance with QAP 15.0," Nonconforming Materials, Parts, I Components, or Services."  !

l QAP 8.0 31 (09 CYQAP REV: 01

QAP9.0 CONTROL OF SPECIAL PROCESSES O

V 9.1 GENERAL REOUIREMENTS The CYQAP provides measures to assure control of special processes associated with quality systems, structures and components by the use ofqualified procedures, equipment and personnel during maintenance and modification of the HNP.

Special processes are performed under controlled conditions in accordance with special requirements and cay include, but are not limited to: welding, cleaning, heat treating, and nondestructive examination and/or testing.

9.2 IMPLEMENTATION During maintenance and modification of the HNP, CY Engineering ensures that special process data and documentation is reviewed; vendor's special process procedures used at the HNP are qualified and approved; and that personnel and equipment utilizing special processes are properly qualified prior to the start of work.

Nuclear Materials and Document Management is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspe'ctions to ensure the vendors are effectively complying with their quality assurance program req 6irements for control of p special processes.

U CY Oversight perfonns, as appropnate, on-site audits, surveillances, and inspections of the vendor activities.

NUSCO/CY special process procedures utilized during maintenance and modification of the HNP are prepared, reviewed and approved in accordance with procedures as specified in QAP 5.0, " Procedures, Instructions, and Drawings."

9.2.1 PROCEDURE OUALIFICATION AND CONTROL NUSCO/CY procedures specify that written process control documents are utilized and qualified, as required, in accordance with the applicable specification, codes or standards.

9.2.2 PERSONNEL OUALIFICATION AND CERTIFICATION Codes, standards and NUSCO/CY procedures specify personnel qualification / certification requirements. Personnel responsiole for the performance and verification of special processes are trained, tested, and certified as required by applicable specifications, codes and standards. Requirements for O

V QAP 9.0 CYQAP 32 REV: 01

the period of certification, retesting, and recertification of personnel are also

(] specified. Vendors qualify pe sonnel and maintain records of qualitied personnel

'V in accordance with applicable codes, standards, specifications, and vendor Purchase Order / Contract requi ements. The department that is contracting services is responsible for the r: view of records of qualified personnel, equipment and procedures associated with special processes.

CY Oversight performs, as appropriate, audits, and surveillances of the personnel  ;

qualification process.

l The NU Nuclear Oversight Department is responsible for ensuring that the l training, testing, and certification of NDE personnel at the IINP is in accordance l with the requirements of Regulatory Guide 1.58 (Rev.1,9/80) and ASNT i Recommended Practice No. SNT-TC-l A.

9.2.3 SPECIAL PROCESS RECORDS Records provide objective evidence that special processes were performed in accordance with procedures, by qualified personnel, and that when required by procedures, specifications, and codes, suel l performance was verified. Results of nondestructive examinations are recorded in accordance with applicable specifications, codes and standards. These records are retained by the vendor or o supplied to CY as required by contract or purchase order. If records are to be Q retained by the supplier, the contract or purchase order specifies the retention period and instruction for final disposition of records.

Special process documentation such as special process procedures, qualifying data, and personnel and equipment qualification records associated with the performance of special processes at nuclear power plants, are kept current and maintained in appropriate CY files, with final disposition to the Nuclear Document Services Facility.

/^\ QAP 9.0 33 V CYQAP REV: 01

QAP 10.0 INSPECTION O

10.1 GENERAL REOUIREMENTS i

4 Inspection of activities to verify the quality of systems, structures and components, which are performed by or for CY are executed in accordance with the CYQAP and appropriate procedures, instructions and drawings by qualified personnel independent from the

, individual or group performing the activity being inspected. Ifinspection is impossible or disadvantageous, indirect controls by monitoring processing methods, equipment and personnel are provided. Inspection notification and hold points are identified, as required, in the applicable documents.

10.2 IMPLEMENTATION 1

i 10.2.1 INSPECTION RESPONSIBILITIES During maintenance and modification of the HNP, procedures shall define the

, need for inspections (e.g., receipt inspections, installation, and product

acceptance).

CY Oversight shall ensure procedural requirements-are met by means of audits I and surveillances as defined in Nuclear Oversight Department procedures. l

. CY Oversight shall perform inspections of modification and maintenance

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activities on systems, structures, and components govemed by the CYQAP. The ,

, criteria used to determine when CY Oversight inspection shall be required for '

i these activities and for the preparation ofinspection plans shall be identified in l appropriate procedures. CY Oversight shall be responsible for this inspection function which includes: .

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a. Identification ofinspection personnel;

b. Review of work procedures and work documents to identify QA " hold" I pcints associated with the work ;

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c. Preparation and approval ofinspection plans ensuring that the necessary inspection requirements, methods, and acceptance criteria have been identified; and

, d. Documentation ofinspection results.

Nuclear Materials and Document Management is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspections to verify that any 1

O QAP 10.0 34 CYQAP REV: 01

vendor utilized in the maintenance and modification of the HNP are effectively complying with their quality assurance program requirements for inspection and for perfonning/ witnessing inspections at " hold" or " notification" points identified in procurement documents.

i. CY Oversight performs ~, as appropriate, on-site audits, surveillances, and inspections of vendor activities.

10.2.2 INSPECTION PLANS Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans are based on design specifications, procurement documents, drawings, other specifications, or previous experience, as 3

appropriate.

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During the performance of CY work activities, procedures provide criteria for the determination of accuracy requirements ofinspection equipment and when inspections are required. These procedures describe requirements for the preparation of surveillance and/or inspection plans by CY Oversight.

, The inspection criteria, including the use ofinspection equipment and their i

accuracy requirements, are specified in the CY Oversight surveillance / inspection

, p plans.

10.2.3 INSPECTION PERSONNEL AND INSPECTION DOCUMENT ACCESS Inspections are performed by individuals other than those who performed or directly supervised the activity being inspected. Inspection personnel are qualified and/or certified in accordance with appropriate codes, standards, and/or training programs; Inspections are performed by CY Oversight personnel or qualified contract personnel. The Department that is contracting on-site QA inspection services shall be responsible for the review and acceptability of vendor personnel / equipment certification prior to the initiation of the activity; When vendors are contracted to perform inspection services, their inspection plans / procedures are reviewed and concurred upon by CY Oversight in accordance with QAP 5.0, " Procedures, Instructions, and Drawings."

Access to drawings, procedures, specifications or other documented criteria necessary for the performance ofinspections is provided prior to performing the inspection activity.

QAP 10.0 35 CYQAP REV: 01 1

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10.2.4 INSPECTION PROCEDURES i

'(d 'h (a) Required inspection or surveillance activities are performed and documented in accordance with procedures and/or checklists. Inspection procedures, plans or checklists contain the following:  !

(1) Identification of characteristics to be inspected; (2) Identification of the individual or groups responsible for performing the inspections; (3) Requirements for the necessary measuring and test equipment and the required accuracy of this equipment; (4) Acceptance criteria; I (5) A description of the method ofinspection when other than direct visual examination using the unaided eye; (6) A record of the results of thp inspection; and/or (7) Record ofinspector or data recorder.

(b) Procedures specify surveillance of processing methods or testing and operation of equipment when inspection is impossible, inaccessible or not '

applicable.

(c) Modification, repair, replacement or rework items are inspected m )

accordance with original inspection requirements or approved alternatives.

10.2.5 MANDATORY HOLD AND NOTIFICATION POINTS l Mandatory hold points are utilized when an inspection / operation must be performed or witnessed and signed off by the responsible personnel before work  !

can proceed. Notification points are used to identify the operations or completed processes that CY Oversight or its representatives may elect to witness and/or inspect during the manufacturing or installation process. Mandatory hold and notification points, as required, are identified in procurement documents and work procedures / documents. Purchase Order / Contracts and work procedures / documents are subject to the review and concurrence for adequacy ofinspection, notification and/or mandatory hold controls by Nuclear Materials and Document Management and CY Oversight, respectively.

f QAP 10.0 36 CYQAP REV: 01

10.2.6 INSPECTION RESULTS EVALUATION l (^;

'V Inspection results are evaluated for acceptability in accordance with procedures which identify the responsible organization.

The evaluations are performed by the responsible personnel who are qualified in accordance with the appropriate Regulatory Guide / ANSI Standard commitments listed in Appendix C.

CY Oversight performs audits and surveillances to assure that inspections are performed per the requirements of applicable CY procedures.

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t) QAP 10.0 37

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s CYQAP REV: 01

QAP 11.0 TEST CONTROL O- 11.1 GENERAL REOUIREMENTS A documented test control program is established by the CYQAP for systems, structures and components to ensure that they will perform satisfactorily in service and that test results are documented in accordance with 10 CFR 50, Appendix B and other pertinent regulatory and/or technical requirements.

The test control program identifies the systems, structures and components to be tested, method of conducting tests, evaluation of tests and documentation of tests by qualified personnel to assure requirements have been satisfied.

The test control program is systematic and includes proof tests prior to installation, construction tests, operational tests, surveillance tests, and retest following repairs, replacements, preventative maintenance or modifications.

I 1.2 IMPLEMENTATION

'11.2.1 TEST PROGRAM .

Test requirements to determine or to verify the capability of an item to meet O specified requirements in accordance with engineering / design documents, Safety Analysis Reports (SAR), technical specifications, procedures or procurement documents, as appropriate, are accomplished by subjecting the item to a set of physical, chemical, environmental or operating conditions. Retest following repair, replacement or modification is performed in accordance with the original design requirements or acceptable alternatives and is performed when original test results are invalidated.

1 CY procedures are written and approved to delineate the methods and i responsibilities for controlling, accomplishing and documenting testing during maintenance and modification of the HNP.

Vendors utilized in the maintenance and modification of the HNP are responsible for implementing measures for the control of tests to ensure that materials,  ;

equipment and parts will perform satisfactorily. l I

Nuclear Materials and Document Management is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspections of selected proof tests when hold points have been identified in Purchase Order / Contracts of vendors to verify they are complying with their quality assurance program requirements for test control.

QAP 11.0 38 O' CYQAP REV: 01 l l

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CY Oversight performs, as appropriate, on-site audits, surveillances, and l O- mspections of the vendor activities.

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Proof tests, product acceptance tests, retests, and periodic surveillance tests are conducted by qualified personnel in accordance with procedures. Personnel performing tests ensure that calibrated equipment and instrumentation utilized are within the calibration interval specified. Documentation including test procedures  !

and data sheets are maintained in appropriate files.

I1.2.2 TEST PROCEDURE PREPARATION AND TEST PERFORMANCE Testing is accomplished in accordance with test procedures which incorporate or reference the requirements and acceptance criteria in the applicable design and procurement documents. The test procedure or test program documents include the following as a minimtun:

a. Instructions for the testing method used;  !

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b. Required test equipment and instrumentation;

c. Test requirements, such as acceptance and rejection criteria; C\

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d. Hold, notification, inspection and data collection points; I

e. Test prerequisites, such as: calibrated instrumentation; trained, qualified, and licensed or certified personnel; preparation, condition and completeness of the item to be tested; and/or suitable and controlled s

environmental conditions; 4

, f. Methods for documenting or recording tnt data and results; and/or

g. Provisions for data collection and storage.

11.2.3 TEST MOUIPMENT

, CY procedures provide the criteria for determining when a test is required and the accuracy requirements of test equipment.

The following steps are taken in the control of test equipment:

a. Test instrumentation is checked and calibrated in accordance with CY procedures to ensure accuracy;  !

QAP 11.0 39 l CYQAP ]

REV: 01 i l

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b. Plant instrumentation used in testing is calibrated. It is maintained in calibration at regular intervals in accordance with surveillance and/or 3

preventative maintenance procedures; and, 1

c. Where special instrumentation is required for testing, the requirements l are stated in the procedures. Instnunent characteristics, including accuracy requirements, are equivalent to or better than those specified by the vendor.  !

1 11.2.4 EVALUATION OF TEST RESULTS

)

The documented test results are evaluated against the predetermined acceptance I criteria by an individual or group having appropriate qualifications. The acceptance status of the test is documented. Deficiencies noted during the evaluation are documented and dispositioned in accordance with approved procedures.

The evaluation of test results may also be delegated to vendors. When delegated, J contracts require the vendor to assure the yse of qualified personnel, evaluate the data against predetermined criteria and docurnent the results of the evaluation and acceptance status of the test.

Nuclear Materials and Document Management is responsible for the performance of off-site audits, surveillances, and inspections, as appropriate, to verify that these vendors are effectively complying with their quality assurance program requirements for test control.

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of the activities.

QAP 11.0 40 CYQAP REV: 01 f

1 QAP 12.0 CONTROL OF MEASURING AND TESTING EQUIPMENT U 12.1 GENERAL RFOUIREMENTS The CYQAP provides measures for the control of measuring and testing equipment l (M&TE) used as the basis for acceptance in activities affecting quality during inspection. I testing and measurement of materials, equipment and parts. Periodic calibration and I adjustment of measuring and test equipment is performed and controlled to assure accuracy is maintained within limits necessary to verify that design and operating condition requirements have been met. Documentation is retained such that all items of M&TE are 1 traceable to their calibration records.

12.2 IMPLEMENTATION I l

12.2.1 GENERAL Procedures delineate the methods and responsibilities for the control, maintenance and calibration of M&TE including ponable and temporarily installed test instruments, tocJs, gages, fixtures, reference and transfer standards, and nondestructive test equipment. .

Documentation associated with M&TE is maintained in appropriate files, with eventual incorporation into the NU Nuclear Records Program. When the V information for the control, use, and calibration of M&TE is in electronic form, this information is controlled and protected in accordance with procedures.

The calibration program is implemented in accordance with the requirements defined in CY procedures which describe the measures utilized to maintain  !

M&TE. Functional groups are responsible for implementing these procedures l which comply with the requirements contained in specifications and drawings.

The Plant Operations Review Committee (PORC) reviews and approves M&TE  :

administrative procedures related to the M&TE calibration program.

1 Nucle:ar Materials and Document Management or the appropriate M&TE  !

Custodian, as delineated by the Purchase Order, is responsible for verifying that i receipt of calibrated equipment is in confonnance with the requirements of I procurement documents. Nuclear Materials and Document Management and CY Oversight are responsible for the calibrated M&TE used during their inspections, respectively.

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QAP 12.0 41 CYQAP REV: 01 ,

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4 j Department Heads / Supervisors are responsible to ensure that M&TE equipment is calibrated, issued, and controlled in accordance with the requirements of the

s procedures. The " activity" Supervisor shall ensure that the users of the M&TE are properly instructed in the use and control of the M&TE. HNP Departments are 1 responsible for calibrating M&TE within the required interval or removing the M&TE from service until the required calibration can be performed.

t i CY departments are also responsible for reviewing calibration data associated 1

with M&TE calibration by outside vendors in accordance with the procedures.

i CY Oversight performs audits, surveillances, and inspections to verify j implementation of the M&TE program.

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Vendors utilized in the maintenance and modification of the HNP are responsible l for implementing measures for the control of M&TE to ensure they are properly calibrated, adjusted and maintained at specified intervals in order to maintain

! accuracy within required limits.

1,

Nuclear Materials and Document Management is responsible for the ~ performance )

of off-site audits, surveillances, and inspec,tions, of the quality assurance programs of vendors to verify that they are effectively complying with their requirements

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for control of M&TE. '

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CY Oversight performs on-site audits, surveillances, and inspections, as

appropriate, of vendor activities.

i j 12.2.2 CALIBRATION STANDARDS 4

l Measuring and test equipment is calibrated at specified intervals based on the i- required accuracy, purpose, degree of usage, stability characteristics, and other l- conditions affecting the measurement. Measuring and test equipment shall be f permanently marked or tagged with a unique identification number and the date g

calibrated and next calibration date indicated on the M&TE.

CY procedures describe the measures taken to assure that reference and transfer i standards are traceable to nationally recognized standards and that, where national standards do not exist, provisions are established to document the basis for i calibration.

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Calibration of this equipment should be against standards that have an accuracy of

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at least four times the required accuracy of the equipment being calibrated. When this is not possible, the standards shall have an accuracy that assures the 1

equipment being calibrated will be within required tolerance. In addition, the calibrating standards shall have greater accuracy than secondary standards being j

calibrated. Calibrating standards with the same accuracy may be used if they can be shown to be adequate for the requirements and the basis of acceptance is documented.

12.2.3 "OUT OF TOLERANCE" CONTROL

! M&TE and reference standards when found out of tolerance are so identified and

removed from service. A timely review is conducted to determine the validity of I previous inspection or test results gained through use of the instrument, and of the acceptability ofitems previously measured or tested.

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! QAP 13.0 HANDLING. STORAGE AND SHIPPING G

13.1 GENERAL REOUIREMENTS Measures are established by the CYQAP using procedures, instructions and procurement documents to ensure proper han'dling, storage, shipping, cleaning and preservation of 1 material, equipment and parts. These measures are imposed during maintenance and modification activities in order to : reclude damage, loss or deterioration of materials, equipment and parts.

13.2 IMPI EMENTATION i

13.2.1 GENERAL 1

Procedures, instructions and procurement documents define the requirements and responsibilities for the handling, storage, shipment, cleaning and preservation of material, equipment, and parts required for implementation of established design and specification requirements.

Handling, storage, cleaning and preservation requirements of material, equipment and parts is conducted in accordance with procedures and procurement documents.

Vendors utilized in the maintenance and modification to the HNP are responsible for implementing measures for handling, storage, shipping, cleaning and preserving materials, equipment and parts to preclude damage, loss or deterioration.

Nuclear Materials and Document Management is responsible for off-site auditw surveillances, and inspections, as appropriate, to verify that vendors are effectively implementing and complying with the approved procedures and instructions for handling, storage, sidpping, cleaning and preservation of materials, equipment and parts.

CY Oversight performs on-site audiis, surveillances, and inspections,~as appropriate, of the activities.

13.2.2 ESTABLISHMENT OF SPECIAL HANDLING. STORAGE. SHIPPING.

CLEANING AND PRESERVATION REOUIREMENTS Special or additional handling, storage, shipping, cleaning and preservation requirements are to be identified and implemented as specified in procurement documents and approved procedures. These established requirements are O QAP 13.0 CYQAP 44 REV: 01

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, consistent with the regulatory positions of the NRC Regulatory Guides and their

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"d endorsed ANSI Standards listed in Appendix C herein, or specifications and/or vendor technical manuals, and will be consistent with accepted industry standards.  ;

I CY procedures describe the measures taken for the storage of chemicals. reagents (including control of she' lflife), lubricants, and other consumable materials.

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QAP 13.0 45 CYQAP REV: 01

QAP 14.0 INSPECTION. TEST AND OPERATING STATUS

'U 14.1 GENERAL REOUIREMENTS The CYQAP provides measures for indication, by the use of marking such as stamps, tags, labels or other suitable means, the status of tests and inspections of material, equipment and l parts throughout the maintenance and modification of the HNP to preclude the inadvertent  !

j bypassing ofinspection and test requirements. These measures provide for the identification ofitems which have satisfactorily passed required inspections and tests. Measures are also established for indicating the operating status of systems, structures and components to prevent inadvertent operation.

14.2 IMPLEMENTATION 14.2.1 GENERAL Vendors utilized in the maintenance and modification of the HNP are responsible for implementing approved measures for the identification ofinsp.ection and test status of material, equipment and parts to preclude the bypassing cf requirements. j

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Nuclear Materials and Document Manageme'n t is responsible for the performance of offsite audits, surveillances, and inspections of vendors, as appropriate, to fG verify that they are effectively complying with their requirements for d identification ofinspection and test status, in compliance with procedures and instructions.

Elements of this system require that vendors have a controlled manufacturing and test operation, in order to preclude the inadvertent bypassing of process inspections or tests, and to provide a positive identification of component statua throughout all phases of manufacturing, testing, and inspection by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other appropriate methods.

When Receipt Inspections are performed at Millstone Station or the HNP, Nuclear Materials and Document Management ensures that traceability is maintained for  ;

acceptable materials, equipment and parts, to indicate conformance to Purchase Order / Contract requirements. Material used at CY that requires traceability to be maintained is delineated in the appropriate CY procedure.

Nonconforming materials, equipment and parts are identified in accordance with  ;

QAP 15.0," Nonconforming Materials, Parts, Components, or Services" and/or i QAP 16.0," Corrective Action."

QAP 14.0 46 CYQAP REV: 01 l

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During tests and inspections of operating systems required to support the storage of the spent fuel, a status tagging system is implemented, as per approved procedures and instructions, to prevent inadvertent operations of systems, structures and coniponents.  !

l CY procedures describe the measures taken to control the altering of the sequence f i

of required tests, inspections and other operations. The review and approval for these actions is subject to the same control as taken during the original review and

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approval of tests, inspections and other operations. l l

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of the activities.

14.2.2 STATUS IDENTIFICATION AND CONTROL Procedures and instructions describe control of the application and removal of l' markings such as stamps, tags, labels, and other suitable means to indicate the status of systems, structures and components to prevent inadvertent operation, and f

to preclude omission of inspections, tests or other critical operatio'ns. These i procedures and instructions delineate the rgquirements, methods and  ;

responsibilities for indicating the status of th6 affected items. The complete status l of all items under the calibration system is recorded and maintained. j Records associated with status identification are maintained in accordance with procedures.

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i O QAP 14.0 CYQAP 47 REV: 01  ;

QAP 15,0 NONCONFORMING MATERIALS. PARTS. COMPONENTS.

OR SERVICES 15.1 GENERAL REOUIREMENTS i

The CYQAP requires that documentation and control of nonconforming materials, parts, i

components, or services utilized in systems. structures and components during maintenance l '

and modification of the 11NP be performed in accordance with procedures in order to prevent inadvertent use or installation. These procedure's include appropriate requirements for identification, documentation, segregation and disposition of nonconforming items, and notification to affected organizations.

15.2 IMPLEMENTATION 15.2.1 PROGRAM )

1 Procedures define personnel responsibilities and establish various measures for identification, documentation, segregation, review and disposition of nonconforming item reports. Report mechanisms are available to all NU l personnel.

• 15.2.2 DOCUMENTATION I O

V Documentation of nonconforming items requires identification of the items, description of the nonconformance, disposition of the nonconformance, inspection requirements and signature approval of the disposition.

Tagging systems are utilized to physically identify nonconforming items prior to installation. Nuclear Materials and Document Services utilizes tags for received material, parts and components.

15.2.3 EVALUATION AND DISPOSITION Evaluations are performed to determine the impact on system, structures and  ;

component operability and to determine the disposition of nonconforming items j and services. The evaluation determines whether an item or service is to be used as is, returned to vendor, repaired, or scrapped. An engineering evaluation is j performed, if necessary, prior to the resolution of nonconformances. These evaluations assure that the final condition does not adversely affect safety, operation or maintenance of the item or service, or of the component or system. l Repe::s involving deviation from design bases such as "use as is" or " repair" are forwarded to the appropriate engineering organization for review, and disposition.

Applicable information is accumulated and records are maintained. )

QAP 15.0 48 l CYQAP REV: 01 1

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V The need to release /use nonconforming materials, parts or components shall be based on such considerations as:

a. Impact on plant safety;

b. Safety of personnel;

c. Suitability of material or items in the "as is" condition, i.e., probability of eventual satisfactory resolution of the nonconforming without repair, rework c,r replacement;

d. Accessibility of material or items after release;

e. Cost of removal and repair or replacement should material or items eventually have to be removed, repaired, or replaced; and

f. Effect on the orderly progress of work.

Items repaired aie verified by reinspecting the items as originally inspected or by a documented method which is equivalent to'theoriginal inspection method.

Items repaired may require reinspection as defined in procedures.

(O) CY Oversight performs audits and surveillances to verify that dispositions for reports documenting nonconforming conditions are adequate.

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_ QAP 16.0 CORRECTIVE ACTION  !

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16.1 GENERAL REOUIREMENTS l

The CYQAP requires that an effective corrective action program be established for CY and their vendors to ensure that conditions adverse to quality are promptly identified and corrected as soon as practicable and documented in accordance with approved procedures.

These procedures include measures for determining the root cause and corrective action to l preclude recurrence for conditions evaluated as significant conditions adverse to quality. I 16.2 IMPLEMENTATION 16.2.1 PROGRAM Procedures define personnel responsibilities and establish various measures for identification, documentation, evaluation / review, disposition and correction of conditions adverse to quality. Reporting mechanisms are available to NU personnel.

16.2.2 CORRECTIVE ACTION AND FOLLOEUP Procedures describe the measures taken to evaluate if conditions adverse to quality exist and to determine the need for immediate corrective action or

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G disposition. The Executive Vice President and Chief Nuclear Officer is responsible for ensuring that the assigned personnel and their vendors working at HNP comply with the corrective action program and for ensuring '. hat corrective action is adequate and properly implemented in a timely manner at the HNP.

CY Oversight performs audits and surveillances to verify that organizations working at the HNP comply with the corrective action program and that corrective action is adequate and properly implemented in a timely manner.

The Executive Vice President and Chief Nuclear Officer has the final authority in the event that agreement on the action to be taken is not reached at the appropriate organization levels within the CY organization 16.2.3 RECURRENCE CONTROL Procedures provide responsibility and the process for determining appropriate significance based on actual or potential consequences for conditions adverse to quality and requirements for evaluation and corrective action.

(9 kJ QAP 16.0 50 CYQAP REV: 01

l Procedures also establish the responsibilities and measures taken to accomplish

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\s' these actions.

An analysis of conditions identified as adverse to quality is developed and adverse j trends are periodically reported to management by the organization responsible I

for controlling the problem reporting program. Trends concerning specific vendor performance shall be reported to the affected contractor for resolution, if appropriate.

CY Oversight performs audits and surveillances to verify that the corrective action program is adequate and controlled in accordance with procedures.

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QAP 17.0 QUALITY ASSURANCE RECORDS f .

l 17.1 GENERAL REOUIREMENTS The CYQAP provides for the maintenance, identification, retention and retrieval of records to furnish evidence of activities affecting quality during maintenance and modification of the 1INP. The records include but are not limited to: l

a. Operating logs and the results of reviews;

b. Inspections; I

c. Tests;

d. Audits; l

e. Monitoring of work performance; and,

f. Material analyses.

The records also include closely related data such as qualifications of personnel, procedures and equipment. Inspection and test records contain as a minimum but are not limited to:

O identification ofinspector or data recorder; and, the acceptability and the action taken in connection with any deficiencies and reponable occurrences noted. Procedures establish requirements concerning record retention such as duration, location and assigned responsibility.

17.2 IMPLEMENTATION Procedures and instructions establish the responsibilities and requirements for the maintenance, identification, retention and retrievability of records pertaining to materials, equipment, parts, processes or operations relating to systems, structures and components which when founded on observations, measurements or tests can be fully verified, and documented by cognizant personnel.

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l CY procedures define the documentation requirements for inspection and test records, as l appropriate.

Vendors utilized in the maintenance and modification of the HNP are responsible to l

l implement measures for identification, maintenance, retention, retrieval and turnover of l records to CY personnel which contain objective evidence of quality, as specified in i

Purchase Order / Contracts.

QAP 17.0 52  ;

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Nuclear Materials and Document Management is responsible for oft-site audits, V)

( surveillances, and inspections, of vendors, as appropriate, to verify they are effectively complying with their program for quality assurance records.

CY Oversight pedorms on-site audits, surveillances, and inspec ns, as appropriate, of these activities.

Qua;hy Assurance records are identified, controlled and maintained in appropriate files and are identifiable to specific systems, structures and components at HNP. When identification to a specific system, structure or component is not practical, records are filed by category I (e.g. specification, nonconformance reports, audits, etc.).

17.3 RETENTION 1

l CY quality assurance records are classified as life records or nonlife records as delineated i by NU Nuclear. Document Senices. Nonlife records are those documents that are I maintained for a specific period of time other than the lifetime of the in-service nuclear power plant or the particular component or pan. Life records are those documents that are maintained fbr the lifetime of the in-senice nuclear power plant or for the life of the particular component or part. Life records are those which would be of significant value in meeting one or more of the following criteria: -

(] a. Demonstrating capability for safe operations; C/

b. Maintaining, reworking, repairing, replacing or modifying the item;

c. Determining the cause of an accident or malfunction of an item; or

d. Providing required base line data for in-service inspection.

Records are reviewed and approved by the cognizant qualified personnel and vendors as appropriate, and are transmitted to NU Nuclear Document Services. The responsibility of the NU Nuclear Document Senices upon receipt of records, is to maintain and provide controlled retrievability of records affecting the HNP in such a manner as to prevent destruction of records by fire, flood, theft, and environmental conditions, such as temperature or humidity, as delineated in procedures.

im QAP 17,0

(") CYQAP 53 REV: 01

QAP 18.0 AUDITS

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18.1 GENERAL REOUIREMENTS The CYQAP requires that a comprehensive system ofplanned and periodic audits shall be carried out to verify compliance with the CYQAP during the maintenance and modification of the HNP.

Audits are conducted in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited.

Audit results are documented and reviewed by management having responsibility in the area audited and the responsible management takes the necessary action to address any audit findings revealed by the audit.

18.2 IMPLEMENTATION 18.2.1 PROGRAM The audit program requires audits of corporate and HNP quality activities under the oversight of the CY Nuclear Safety Assessment Board. Audits are performed on activities where the requirements of 10 CFR 50 and the HNP Technical q Specifications are being implemented.

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l Audits are regularly scheduled on the basis of the status and safety importance of I the activities being performed. Regularly scheduled audits are supplemented by J audits for one or more of the following conditions:

a. When significant changes are made in functional areas of the quality  ;

assurance program, such as significant reorganization or procedure revisions;  ;

b. When it is suspected that the quality of the item is in jeopardy due to deficiencies in the quality assurance program;

c. When a systematic, independent assessment of program effectiveness is considered necessary; and / or,

d. When necessary to verify implementation of required corrective action.

Schedules for the audit of CY activities are originated and maintained by CY Oversight. Schedules are approved by the Director-Audits and Evaluation.

QAP 18.0 54 CYQAP REV: 01 m

i Audits are performed as specified in Nuclear Oversight procedures by qualified

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V personnel, using a pre-established written audit plan prepared by the auditing l organization. Audits may include evaluation of the work areas, activities, i processes, items, and review documents and records to determine the I effectiveness ofimplementation and conformance to the CYQAP.

Approved vendors utilized in the maintenance and modification activities to the l

IINP are responsible for developing and implementing a system of planned and periodic audits to verify compliance with the effectiveness of all aspects of their  !

quality assurance programs.

Nuclear Materials and Document Management is responsible for verifying the acceptability of vendor audit programs and for the performance of subsequent off-site audits, as appropriate, to verify compliance with the effectiveness of all aspects of their quality assurance programs. Nuclear Materials and Document Management has contracted this audit function to the Yankee Atomic Electric Company (YAEC).

CY Oversight performs audits /surveillances of on-site vendors, as appropriate, so verify the effectiveness of appropriate aspects of their quality assurance programs.

In addition to the audits, other methods, such as surveillances, and inspections are (3 used to ensure that quality activities are in compliance with the CYQAP.

O 18.2.2 REPORTING OF AUDIT RESUL19 Audit results are reviewed, approved, and reported in accordance with Nuclear Oversight and Yankee Atomic Electric Company procedures, as applicable. The audit reports are issued to the appropriate management of the area audited to ensure appropriate and/or timely corrective action is taken to address any audit findings. In addition, audit data and reports are included as part of the review for quality trends and assessed in accordance with QAP 16.0," Corrective Action."

18.2.3 REVIEW. ACTION. AND FOLLOW-UP OF AUDIT FINDINGS Audit findings are reviewed and investigated by the management having the responsibility for the area audited. The responsible management is required to:

a. Take the necessary action to addresses any findings identified by the audit;

b. Report the results of such reviews and investigations; O QAP 18.0 55 CYQAP REV: 01

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c. Take the necessary actions to correct problems reported; and.

d. Report the completion of corrective actions within specified time frames.

, Follow-up of audit Endings is perfonned by the auditing organization, as necessary, to verify that appropriate actions have been taken to resolve audit i

findings. Actions on audit findings which cannot be resolved by affected l management and the Vice President - Nuclear Oversight are submitted for

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l resolution to the President and Chief Executive Officer - NU Nuclear Group.

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l8.2.4 RECORDS / REPORTS OF AUDITS l

Audit records, reports, and associated documentation pertinent to audits are i dispositioned to the appropriate Nuclear Document Services Facility, as specified in procedures.

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QAP 18.0 56  :

i CYQAP REV: 01

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APPENDIX A CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM CATEGORY I SYSTEMS. STRUCTURES. AND COMPONENTS The following systems, stmetures and components of a defiled nuclear power plant, l including their foundations and supports, are designated as Category 1. The pertinent quality i assurance requirements of 10 CFR 50, Appendix B should be applied, as a minimum, to all j quality activities affecting the safety function of these systems, structures, and components '

as listed below and for those items listed in the CY UFSAR which addresses Section 3.2.1 of NRC Regulatory Guide 1.70.

NOTE The safety classification of the systems, structures and components listed below may be revised based on engineering evaluations and a revision to the CY UFSAR during the decommissioning process. Revision of the safety classification in accordance with the CY Design Control process is not considered a reduction in the commitments.to the CYQAP, i

(a) Systems or portions of systems that are requirbd fer cooling the spent fuel storage pool.  ;

O V Cooling water and component cooling or portions of these systems including the (b) intake structures, that are required for cooling the spent fuel storage pool. ,

(c) Systems or portions of systems that are required to supply fuel for emergency equipment.

(d) Systems or portions of a system of a defueled nuclear power plant that are required for:

e Monitoring of systems safety-related functions; and,

. Actuation ofsafety-related functions.

" Required for monitoring," i.e., Those parameters that provide information that is essential to permit the control room operator to take specific manually controlled actions for the direct accomplishment of the specified safety function.

(e) The spent fuel storage pool structure, including the fuel racks.

APPENDIX A 57 CYQAP REV: 01

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(f) The control room, including its associated equipment and all equipment needed to O maintain the control room with safe habitability limits for personnel and safe emironmental limits for vital equipment.

(g) Systems other than radioactive waste management systems not covered by the above which contain or may contain radioactive materials and whose postulated failure would result in conservatively calculated potential offsite doses (using  ;

meteorology as prescribed by Regulatory Guides 1.3 and 1.4) which are more than 0.5 rem to the whole body or its equivalent to any part of the body.

(h) The Class IE electric systems, including the auxiliary systems for the onsite electric power supplies, that provide the emergency electric power needed for functioning of  ;

systems for the spent fuel storage.  :

l (i) Those portions of systems, structures or components whose continued function is i not required but whose failure will result in a reduction in maintaining the spent fuel ,

in a safe condition or could result in incapacitating injury to occupants of the control i room, should be designed and constructed so that the SSE will not cause such failures. i

. l (j) Items and services associated with Radioactive Material Transport Packages as described in 10 CFR 71.

CONSUMABLES The following specific consumables when utilized in safety related systems shall be included in those portions of the CYQAP, as applicable.

1. Emergency generator diesel fuels

2. Hydraulic snubber fluids

3. Reagents

4. Resins

5. Boric Acid

6. Lubricants APPENDIX A 58 CYQAP REV: 01

APPENDIX B [

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CONNECTICUT YANKEE OUAI ITY ASSURANCE PROGRAM 7 OUALIFICATION AND EXPERIENCE REOUIREMENTS VICE PRESIDENT - NUCLEAR OVERSIGHT The Vice President - Nuclear Oversight shall satisfy the following requirements:

Graduate of a four-year accredited engineering or science college or university, plus fifleen (15) or more years ofindustrial experience ir.-iuding five years in positions ofleadership, l such as lead engineer, project engineer, audit team leader, etc. At least two years of this l

experience should be associated with nuclear Quality Assurance Activities, and at least one l year of this experience is in a Quality Assurance Organization. A masters degree in l

engineering or business management is considered equivalent to two years of experience.

NOTE The education and experience requirements should not be treated as absolute when similar

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training or an outstanding record will provide reasonable assurance that a person can perform the requimitasks.

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V CYQAP REV: 01 1 l

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l APPENDIX C p

k) CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM REGULATORY GUIDE AND ANSI STANDARD COhjMITMENTS l NOTE The CYQAP is committed to utilize the guidance obtained from the following regulatory  ;

documents and their endorsed standards. Exceptions to these positions are listed in Appendix E, herein.

10 CFR 50, Appendix B- Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

10 CFR 50, Section 50.54, Condition of Licenses.

10 CFR 50, Section 55. Operator's Licenses and its Appendix A - Requalification Programs for Licensed Operators of Production and Utilization Facilities.

Regulatory Guide 1.8 R - 5/77 - Personnel Selection and Training - Endorses ANSI N18.1 -

1971. -

Regulatory Guide 1.28 - 2/79 - Quality Assurance Program Requirements (Design and O Construction) Endorses ANSI N45.2-1977.

O Regulatory Guide 1.30 -(Safety Guide 30),8-11 Quality Assurance Requirements for the Installation, Inspection, and Testing ofInstrumentation and Electrical Equipment - Endorses ANSI N45.2.4-1972.

Regulatory Guide 1.33 - 2/78 - Quality Assurance Program Requirements (Operation) - Endorses ANSI N18.7-1976/ANS3.2.

Regulatory Guide 1.37 - Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components cf Water-Cooled Nuclear Power Plants,3-16 Endorses ANSI N45.2.1 1973.

Regulatory Guide 1.38 - Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling ofItems for Water-Cooled Nuclear Power Plants,5/77 - Endorses ANSI .

N45.2.2 - 1972.

Regulatory Guide 1.39 - Housekeeping Requirements for Water-Cooled Nuclear Power Plants.

9/77 - Endorses ANSI N45.2.3-1973.

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V APPENDIX C 60 CYQAP

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Regulatory Guide 1.58 - Qualification of Nuclear Power Plant inspection, Examination, and T^') Testing Personnel, Rev.1,9/80 - Endorses ANSI N45.2.6-1978.

V Regulatory Guide 1.64 - Quality Assurance Requirements for the Design of Nuclear Power Plants.

6/76 - Endorses ANSI N45.2.11-1974.

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i Regulatory Guide 1.70 "A Guide for the Organization and Content of Safety Analysis R.eports" Revision 0, June 30,1966 was utilized for CY, however, certain revised sections of the CY UFSAR  ;

are written to the Revision 3 format. No new analyses have been performed which would be l required by Revision 3. l Regulatory Guide 1.88 - Collection, Storage, and Maintenance of Nuclear Power Plant Quality l Assurance Records - 10/76 Endorses ANSI N45.2.9-1974.

Regulatory Guide 1.94 - Quality Assurance Requirements for Installation, Inspection and Testing i of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plant -

l 4/76 - Endorses ANSI N45.2.5 - 1974 and Section 6.11 of ANSI N45.2.5-1978. I l

Regulatory Guide 1.116 - Quality Assurance Requirements for Installation, Inspect' ion, and Testing l Mechanical Equipment and Systems - 5/77 - Endorses ANSI N45.2.8-1975. '

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l Regulatory Guide 1.123 - Quality Assurance Requirements for Control'of Procurement ofItems

,n< and Services for Nuclear Power Plants - 7/77 - Endorses ANSI N45.2.13-1976.

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Regulatory Guide 1.144 - Auditing of Quality Assurance Programs for Nuclear Power Plants - Rev.

1 - 9/80 Endorses ANSI N45.2.12 - 1977.

Regulatory Guide 1.146 - Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants - 8/80 Endorses ANSI N45.2.23-1978.

Regulatory Guide 1.152 " Criteria for Digital Computers in Safety Systems of Nuclear Power Plants, " January 1996 - Endorses IEEE-ANS 7.4.3.2 - 1993.

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APPENDIX C 61 CYQAP REV: 01

APPENDIX D q

U CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM GLOSSARY OF OUALITY ASSURANCE TERMS Accent As Is - (also known as "Use-As-Is") A disposition which may be imposed for a nonconformance when it can be established that the discrepancy will result in no adverse conditions and that the item under consideration will continue to meet all engineering functional requirements including performance, maintainability, fit and safety.

Aoproved Vendors - Contractors, suppliers, and engineering service organizations who have been approved to provide quality related material, equipment, parts, and sersices, or computer software to the Nuclear Group under their QA Program.

As Built Documents - Documents which accurately describe the condition actually achieved in a system, structure, or component. These doctunents include: material certification and test data; reports ofinspections, examinations, and test results; drawing, specifications, procedures, and instructions; and records of nonconformance and their resolution.

Audit - A formal, documented activity performed in accordance with written checklists or procedures to verify by evaluation of objective evidence that a quality assurance program has been developed, documented, and implemented in accordance with applicable requirements.

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C/ Augmented Ouality - Nonsafety related items for which a design basis or regulatory commitment has been made. The augmented quality items are included within the scope of CY Quality Assurance Program. These items are the Fire Protection Quality Assurance (FPQA) and RWQA Radwaste Quality Assurance (RWQA) programs.

Calibration - The process by which measuring and test equipment are checked against standards of known higher accuracy and adjusted as necessary to ensure their compliance with designated specifications.

Category I - Designation given to systems, structures, and components of the HNP that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

Category I Systems. Structures. and Comoonents - Defined in the CY UFSAR and functionally described in Appendix A., herein.

Cleaning - Those actions performed to maintain an item in accordance with cleanliness requirements.

APPENDIX D 62

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CYQAP REV: 01

i Commercial Grade Item (CGI)- A commercial grade item per 10CFR21 is a structure, system, or component, or part thereof that affects its safety function, that was not designed and manufactured as a basic component. Commercial grade items do not include items where the design and manufacturing process require in-process inspections and verifications to ensure that defects or failures to comply are identified and corrected (i.e., one or more critical characteristics of the item cannot be verified).

Commercial Grade Survey - Activities conducted by the purchaser to ascertain and verify that a  ;

supplier, or manufacturer of commercial grade items, controls the technical and quality characteristics determined to be critical for satisfactory performance of specifically designated commercial grade items, as a method to accept those items for safety-related use.

Condition Adverse to Ouality - Failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances.

Connecticut Yankee Ouality Assurance Program (CYOAP)- Consists of the CYQAP, Nuclear Oversight Department Procedures and other CY Group / Division / Department / Branch /Section quality procedures.

Contractor - Any organization under contract for fumishing items or services. It includes the terms Vendor, Supplier, Subcontractor, Fabricator and subti'er levels of these where appropriate.

The Nuclear Steam Supply System (NSSS) Supplier is included in this category.

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Corrective Action - Action taken to correct identified conditions adverse to quality.

Decommission - means to remove (as a facility) safely from service and reduce residual radioactivity to a level that permits release of the property for unrestricted use and termination of license.(10 CFR 50.2)

Deficiencies - Departures from specified requirements.

Denartment - The use of the word department, throughout the CYQAP, can refer to any portion of the CY organization or support organizations from NU Nuclear (i.e., Group, Division, Department, Branch, Section, or Unit as applicable).

Design - Technical and management processes which lead to and include the issuance of design output documents such as drawings, specifications, and other documents defining technical requirements of systems, structures, and components.

Design Changes - Changes in drawings and specifications that define the design of systems, structures, and components of nuclear plants.

APPENDlX D 63 CYQAP REV: 01 u

Design Documents - The drawing, calculation, specification, or other document (s) that define the f~') Technical requirements of systems, structures, or components.

V IIandling - An act of physically moving an item by hand or by mechanical machinery, but not including transport modes.

HNP- IIaddam Neck Plant is used throughout this document to define the Connecticut Yankee plant site.

Identification - A means by which material, equipment and parts can be traced to their associated documentation through the use of heat numbers, lot numbers, part numbers, serial numbers, or other appropriate means.

lica - Any level of unit assembly, including structures, systems, subsystems, subassembly, component, part or material.

Insnection - A phase of quality control which, by means of examination, observation, or measurement, determines the conformance of material, supplics, components, parts, appmtenances, systems, processes, structures, or services to predetermine quality requirements.

Insoection Status - Identification of material, equipment, and parts that have completed inspection, either acceptable or unacceptable.

A

() Maintenance and Modifications - Refers to the required functions for design, construction, testing, l maintenance, operation, and modification of facilities at the HNP during decommissioning l activities.

Material Reauest - The computerized format used for identifying material and services to be procured using the Materials Information Management System (MIMS)

Measuring and Test Eauioment - Those instruments, gages, tools, fixtures, reference and transfer standards, nondestructive test equipment, and measuring devices used during inspection and testing to determine that the measuring and test parameters comply with appropriate requirements in specifications and drawings.

Nonconformance - A deficiency in characteristic documentation or procedure which renders the quality of an item unacceptable or indeterminate.

Northeast Utilities (NUT - A public utility holding company which owns Northeast Utilities Service Company and The Northeast Nuclear Energy Company and through its operating subsidiaries has a controlling interest in The Connecticut Yankee Atomic Power Company.

APPENDIX D 64

/ CYQAP REV: 01

P Northeast Utilities Service Comnany (NUSCO)- A wholly owned subsidiary of Northeast O Utilities that provides management, quality assurance, and various support functions for the Northeast Utilities nuclear power plants including the HNP.

Nuclear Document Services - The organization responsible for establishing the Corporate Nuclear Plant Records Program which is implemented at each Nuclear Document Services Facility.

Nuclear Grade - The procurement classification applied to all materials and services intended for items listed as Cat. I in the MEPL. These may require validating documentation such as  ;

Certificate of Material Test Report, Certificate of Conformance, Certificate of Compliance, I Personnel Qualifications, etc., as specified by codes or standards, and have been i designed / qualified for a nuclear application. Nuclear Grade items are manufactured / qualified under a 10 CFR 50, Appendix B program, with the vendor responsible for 10 CFR 50, Part 21. 1 The vendor should be approved and listed in the Approved Vendor List.

Nuclear Document Services Facilities (NDSF) - A facility which has been established for the purpose of handling HNP records in accordance with the Nuclear Records Program.

NUSCO Ouality Assurance Vendor List - A list identifying the approval status of the quality assurance programs of vendors; commonly referred to as the Approved Vendors List (formally entitled the Approved Suppliers List) - -

Obiective Evidence - Any statement of fact, information, or record, either quantitative or O. qualitative, pertaining to the quality of an item or service based on observation, measurements, or tests which can be verified.

Preservation - Those actions perfonned to maintain an item in its original and usable condition. i Procedures and Instructions - Documents that specify how an activity is to be performed. They may include methods to be employed; material, equipment, or parts to be used; and a sequence of operations.

Procurement Documents - Purchase requisitions / material requests, purchase orders, contracts, drawings, specifications or instructions used to define requirements for purchase.

Product Acceptance Test - Activities conducted as part of the receiving or source inspection process to verify acceptability of one or more critical characteristics of the item being inspected.

Proiect Engineer - An NU or contract employee assigned the responsibility to coordinate the engineering activities addressed in CYQAP.

APPENDIX D 65 CYQAP REV: 01

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Purchased Material. Eauinment. and Parts List (MEPL)- Items procured for installation in nuclear power generating facilities systems, structures, and components, and items procured as spare MEPL parts for potential installation in those systems, structures, and components. l Purchase Order / Contract - The document which provides the contractual basis for vendor material l

and services provided in accordance with CYQAP requirements.  !

l Purchased Service - Services provided by a vendor or consultant on a QA requisition when activities are performed under a quality assurance program other than the CYQAP.

l Ounlity Assurance Records - Any record pertaining to the quality of material, equipment, parts, .

processes, or operations relating to systems, structures and components which are founded on I observations, measurements, or tests which can be fully checked or verified. Such statements may l

be recorded on a written or preprinted document or tag. The statements are authorized with a I

signature or stamp identifiable to the person making the statement of fact.

Quality Activities - Activities govemed by this CYQAP are those that affect safety-related ,

functions of structures, systems, and components; these activities include designing, analyzing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing,' inspecting, testing, operating, maintaining, repairing, and modifying., Quality Activities also include activities associated with computer software used in implementing the CYQAP and Augmented Quality items as defined herein.

Ouality Procedures - The Nuclear Oversight Department procedures and other department procedures which implement the requirements of the CYQAP that are reviewed by Nuclear l Oversight or CY Oversight.

Repair - A disposition applied to nonconforming material, equipment, and pans that are unsuitable for their intended purpose which are modified by the use of additional operations and/

or processes so that they are suitable for their intended purpose but may not meet all specified requirements.

Retest - A test conducted prior to operation following installation inspections of work associated with maintenance and refueling to verify that systems, stmetures, and components will function satisfhetorily when in operation. A retest may also be performed when original test results are invalidated.

Return to Vendor - A disposition applied to nonconforming material, equipment, and parts that are unsuitable for their intended purpose but which are feasible to repair or rework at a vendor's facility.

APPENDIX D 66 CYQAP REV: 01

Safety Related Systems. Structures. and Comnoaents - Systems, Structures, and components

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V required to mitigate the consequences of postulated accidents.

Special Processes - Procesres for which the desired level of quality can only be assured through the use of additional process controls, and where control through direct inspection alone is inadequate, impossible, or disadvantageous. These processes are performed under controlled conditions in accordance with special requirements utilizing qualified procedures, equipment, and personnel. These special processes may include, but are not limited to welding, brazing, soldering, cleaning, heat treating, and nondestructive testing.

Storage - The act of holding items at the HNP or in an area other than its permanent location in the plant.

Surveillance .A documented record of the observation of work operations performed at CY or a vendor's site to assure compliance with applicable codes, standards, specifications, procedures, drawings, and procurement documents. Surveillances are not performed to a preplanned checklist.

Test and Ooeratine Status - Identification of material, equipment, and parts that are ready for test or operation, or an existing stage of a test operation.

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 (3 conditions.

O Vendor - Organizations that provide material, equipment, parts, and services, or computer software.

Yankee Atomic Electric Comoany (YAEC)- is an incorporated company in Massachusetts sponsored by New England utilities that provides ongoing support to nine commercial nuclear plants in New England for design, construction, engineering, quality assurance, licensing operation, and decommissioning services.

APPENDIX D 67 h" CYQAP REV: 01

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• 4 APPENDIX E CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM PROGRAM EXCEPTIONS

1. ANSI N45.2.9, states in part, " structure, doors, frames, and hardware should be Class A fire-related with a recommended four-hour minimum rating." The three record storage vaults at NNECO have a two-hour rating and the record vault door and hardware at CYAPCO has a three hour rating.

Both NNECO and CYAPCO's vaults are used for storage of documentation that is unsuitable for filming or awaiting filming.

A records organization exists along with written procedures addressing the control of quality assurance records.

2. ANSI N18.7-1976. paragraph 4.3.2.3 " Quorum" states in part: "A quorum for formal meetings of the (Independent Review) Committee held under the provisions of 4.3.2.2 shall consist of not less than a majority of the principals, or duly appointed alternates..."

A quorum of the Nuclear Safety Assessment Board shall consist of the Chairman or Vice Chairman and at least enough members to constituta a majority of the assigned members.

No more than a minority of the quorum has line respo'nsibility for operation / decommissioning of the HNP. No more than two alternates have voting status at p any meeting in fulfillment of the quorum requirements.

3. ANSI N45.2.9-1974. paragraph 1.4, definition of" Quality Assurance Records" states in part: "For the purposes of this standard, a document is considered a quality assurance record when the document has been completed."

Northeast Utilities has developed the following alternative defmition to provide guidance i during the interim period from the time a document is completed until it is transmitted to I the Nuclear Document Services Facility:

"A record is considered a working document until it is transmitted to the appropriate Nuclear Document Services Facility (NDSF) at which time it is designated as a Quality Assurance Record. The following maximum time limits are established for the transmittal of working documents to the NDSF:

Operations Documents - Documentation generated during Plant Operations may be maintained, as needed, by operating plant departments, for up to one year.

New Construction or Betterment Documents - Documents which evolve during new construction or betterment projects shall be transmitted to NDSF within 90 days of completion of a new construction project or turnover of a betterment project or plant operations.

APPENDIX E 68 CYQAP REV: 01 s.

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Procurement Documents -Inspection / Surveillance /Aud t Reports generated during Q

V vendor oversight activities which are used to maintain vendor status for current and future procurements may be maintained, as needed, by the Nuclear Oversight Department for up to three years.

All Other Working Documents - All other working documents shall be transmitted to NDSF within 6 months of their receipt or completion."

The requirements of ANSI N45.2.9-1974 do not apply to these " working documents" based on paragraph 1.1 of the ANSI standard which states:

"It (ANSI N45.2.9) is not intended to cover the preparation of the records nor to include working documents not yet designated as Quality Assurance Records."

4. Regulatorv Guide 1.64 - 6/76, the Regulatory position states, in part, "It should not be construed that such verification constitutes the required independent design verification."

Northeast Utilities has developed the following alternative to allow for adequate independent design verification:

This review may be performed by the originator's Supervisor, only if the Supervisor:

Did not specify a singular design approach; Did not establish the design inputs or did not rule out certain design considerations; is the only individual in the organization competent to perform the review.

Where the Supervisor performs the design review, the next level of management shall fulfill the Supervisor's responsibilities.

b

5. ANSI N45.2.13 - 1976, paragraph 10.3.4, states in part, " Post-Installation Test requirements and acceptance documentation (should) shall be mutually established by the purchaser and supplier." Involvement by the supplier in establishing Post-Installation Test requirements and acceptance documentation is requested only when it is deemed necessary and proper by the responsible engineering organization.

Northeast Utilities no longer has any nuclear plants under construction. As a result, most procurements are made for spare parts from suppliers who are not the original equipment manufacturer. In these cases, the supplier may have little or no understanding or knowledge of either the operation of the system the component is to be installed in, or applicable Post-Installation Test requirements and acceptance documentation. As such, Northeast Utilities assumes responsibility for establishing Post Installation Test requirements and acceptance documentation.

6. MSI N45.2.2-1972, paragraph 1.2, states in part that, "The requirements of this standard apply to the work of any individual or organization that participates in the packaging, shipping, receiving, storage, and handling ofitems to be incorporated into nuclear power plants."

V APPENDIX E 69 CYQAP REV: 01 T

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l Since a portion of Nonheast Utilities procurement activities involve commercial suppliers l O which do not fully comply with the requirements of ANSI N45.2.2, Northeast Utilities U Nuclear Materials and Document Management organization verifies through source I

inspections, receipt inspection, and/or survey activities that the quality of the materials, items, components or equipment is preserved by those suppliers to the extent that packaging, shipping, storage and handling methods are employed which are commensurate with the nature of the product.

7. _ Regulatnry Guide 1.33 - 2/78. regarding audits, states in part:

(a) "The results of actions taken to correct deficiencies...at least once per 6 months."

(b) "... technical specifications and applicable license conditions - at least once per 12 months."

(c) "The performance, training, and qualifications of the facility staff- at least once per 12 months."

NU has developed an altemative which modifies these audit frequencies to at least once per 24 months. This alternative has previously been accepted by the NRC via license

amendments 181 for CY. .

This altemative also takes exception to (c) above. It deletes the requirement for Nuclear Oversight to audit the performance of the facility staff. This function will be performed by the Nuclear Safety Assessment Board.

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i APPENDIX E 70 CYQAP REV: 01

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j Connecticut Yankee l

Quality Assurance Program i

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Haddam Neck Plant '

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TABLE OF CONTENTS CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM (CVOAP) l HADDAM NECK PLANT I i

! Abstract I Policy Statement i Quality Assurance Program Chapters QAP 1.0 Organization; Organizational Charts QAP 2.0 Quality Assurance Program I

QAP 3.0 Design Control I

QAP 4.0 Procurement Document Control QAP 5.0 Procedures, Instructions and Drawmgs l QAP 6.0 Document Control )

QAP 7.0 Control of Purchased Material, Equipment and Semces  !

QAP 8.0 Identification and Control of Materials, Parts and Components i QAP 9.0 Control of Special Processes .

QAP 10.0 Inspection  ;

QAP 11.0 Test Control l s QAP 12.0 Control of Measuring and Testing Equipment s QAP 13.0 Handling, Storage, and Shipping  ;

QAP 14.0 Inspection, Test, and Operating Status QAP 15 0 Nonconforming Materials, Parts, Components, or Services QAP 16.0 Corrective Action  !

QAP 17.0 Quality Assurance Records QAP 18.0 Audits Appendices i A. Category I Systems, Structures and Components B. Qualification and Experience Requirements, Vice President - Nuclear Oversight C. Regulatory Guide and ANSI Standard Commitments D. Glossary of Quality Assurance Terms E. Program Exceptions

! TABLE OF CONTENTS i CYQAP l REV: 01 i '

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(~'N CONNECTICUT YANKEE ATOMIC POWER COMPANY

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HADDAM NECK PLANT ABSTRACT Northeast Utilities (NU) has developed and is implementing a comprehensive Quality Assurance Program for the Connecticut Yankee Atomic Power Company's Haddam Neck Plant to assure conformance with established regulatory requirements as set forth by the Nuclear Regulatory Commission (NRC). The participants in this Quality Assurance Program assure that the maintenance and modification of the Haddam Neck Plant is performed in a safe and effective ,

manner.  !

l This Connecticut Yankee Quality Assurance Program (CYQAP) complies with the requirements  !

I set forth in 10 CFR 50 Appendix B, along with applicable sections of the Snfety Analysis Report (SAR), and is responsive to the NRC Regulatory Guide 1.70, that describe the information required to be presented in the Quality Assurance Section of the SARs for nuclear power plants.

This CYQAP is also established, maintained and executed for Radioactive Material Transport Packages as allowed by 10 CFR 71.101(f). Quality Assurance Prgvisions for Fire Protection activities are detailed in the Connecticut Yankee Fire Protection Program.

O This CYQAP applies to the safety functions of systems, structures, and components and are considered quality activities as defined in the CYQAP. Safety systems, structures and components are functionally identified in Appendix A herein. Applicability of Appendix A to the CY Updated Final Safety Analysis Report (UFSAR)is addressed by the specific design bases and licensing commitments. Portions of the CYQAP are also applicable to the Fire Protection Quality Assurance (FPQA) and the Radwaste Quality Assurance (RWQA) programs.

This CYQAP is committed to utilize the guidance obtained from the regulatory documents and their endorsed standards as referenced in Appendix C.

V ABSTRACT ll CYQAP REV: 01

l POLICY STATEMENT OUALITY ASSURANCE PROGRAM  !

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d Northeast Utilities has established a Quality Assurance Program for each nuclear site operated by the Northeast Utilities system. These QA programs have been developed to achieve quality assurance in all activities affecting the safe operation of the associated nuclear units.

The quality assurance programs established at each nuclear site by Northeast Utilities are as follows:

1 Millstone Station, Units 1,2,3 and Site - Northeast Utilities Quality Assurance Program (NUQAP)

Seabrook Station - Operational Quality Assurance Program (OQAP)

Haddam Neck Plant (HNP)- Connecticut Yankee Quality Assurance Program for the Haddam Neck Plant ( CYQAP)

The program described herein is the Connecticut Yankee Quality Assurance Program for the l Haddam Neck Plant. The policies, requirements and tasks contained in this program description have been developed to achieve a recognized need for quality assurance for maintenance and modification activities during the decommissioning of the HNP to ensure that adequate quality requirements are being complied with to safeguard employees (NU and contract) and the public.

l CY procedures which implement the program at the Haddam Neck Plant are developed and I approved in accordance with Connecticut Yankee administrative procedures.  !

The CYQAP is responsive to applicable codes, Nuclear Regulatory Commission regulatory requirements, accepted industrial standards and revisions thereto. Provisions are established to I update the CYQAP in accordance with revisions to codes, standards and regulatory requirements and to inform cognizant personnel to implement appropriate action to assure that the highest standard of quality is achieved for systems, structures, components and services for the HNP.

The controls which implement the actions identified in the CYQAP are station and departmental procedures and instructions which delineate actions and steps necessary to accomplish quz.lity requirements. Procedures and instructions are written by company groups, divisions, departments, branches, or sections, which have the responsibility for implementing actions assigned to them as delineated by the CYQAP.

The development and overall responsibility for this Quality Assurance Program lies with the  !

President and Chief Executive Officer - NU Nuclear Group. Corporate authority is delegated to the  !

Vice President-Nuclear Oversight for the preparation and administration of the Connecticut Yankee I Quality Assurance Program (CYQAP). The Executive Vice President and Chief Nuclear Officer for Connecticut Yankee and the CY Directors are responsible for the implementation of the Quality Assurance Program within their Depanments.

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QAP1.0 ORGANIZATION INTRODUCTION l.1 The Chairman. Chief Executive Officer. and President of Northeast Utilities (NU) i has the ultimate responsibility for the NU Nuclear Program. While retaining full I responsibility and overall authority, the Chairman has delegated the necessary authority and responsibility for all NU Nuclear Operations to the President and Chief Executive Officer - NU Nuclear Group. The NU Nuclear Group includes the Northeast Utilities Service Company (NUSCO) which provides support services to

, NU's nuclear plants including the Connecticut Yankee Atomic Power Company (CYAPCO) which operates the Haddam Neck Plant (HNP). The President and Chief Executive Officer - Nuclear Group is also the President of NUSCO and the 4

President and Chief Executive Officer of CYAPCO.

1.2 PROGRAM RESPONSIBILITY l

l 1.2.1 The President and Chief Executive Officer- NU Nuclear Group has  !

overall responsibility for the development of the CYQAP for the Haddam j Neck Plant. While retaining full responsibility and overall authority, the j President and Chief Executive Ollicer has delegated corporate authority l for the preparation and administration of the CYQAP to the Vice President

- Nuclear Oversight. (See Figure 1-1) 1.2.1.1 The President and Chief Executive Officer maintains contact with the quality assurance activities through meetings with the Vice i President - Nuclear Oversight, the receipt of various documents, such as: periodic progress reports, Nuclear Safety Assessment Board meeting notes, and audits related to CY's nuclear program implementation at the Haddam Neck Plant.

1.2.1.2 The President and Chief Executive Officer resolves all disputes related to the implementation of this CYQAP for which resolution is not achieved at the appropriate organizational levels within the nuclear organization.

1.3 GENERAL RESPONSIBILITIES 1.3.1. The head of each CY department performing quality activities is responsible for:

a. Administering those activities within their organization which are required by the CYQAP;

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QAP 1.0 1 CYQAP REV: 01 9

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b. Ensuring implementation of the CY Quality Assurance Program; i

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V c. Establishing and clearly defining the duties and responsibilities of j i personnel within their organization who perform quality activities;  !

d. Planning, selecting, and ensuring that personnel are trained to meet l

the requirements of the CYQAP; and

e. Performing and coordinating quality activities within their I organization and interfacing with the C : Oversight organization as required in program implementation.

1.3.2. Each individual performing or verifying activities affecting quality is 3 responsible to conduct those activities in accordance with the requirements of the CYQAP and implementing procedures.

1.3.3 The responsibility, authority, and organizational relationship for 1

performing quality activities within each organization is established in CY

$ organizational charts, policy statements, and written job or functional l descriptions. ,

l.4 ORGANIZATION CONNECTICUT YANKEE AT THE HADDAM NECK PLANT O The President and Chief Executive Officer - NU Nuclear Group- reports to the

> NU Chairman, President, and Chief Executive Officer. He has overall responsibility for the development and implementation of the CYQAP. The President and Chief Executive Officer has delegated the necessary authority and has assigned responsibility for development and implementation of the CYQAP 4

for the Haddam Neck Plant respectively to the Vice President - Nuclear Oversight, and the Executive Vice President and Chief Nuclear Officer -

Connecticut Yankee. (See Figure 1-2).

1.4.1 The Vice President - Nuclear Oversight responsibilities include:

a. Direction of the CY Quality Assurance Program;

b. Implementation of policies and procedures;

c. Verifications through a planned program of audits, surveillances, and inspections to assure compliance with 10 CFR 50, Appendix B and other regulatory requirements; and

d. The implementation of the CYQAP requirements.

QAP 1.0 2 i CYQAP REV: 01

' g The Vice President provides management with objective evidence of the performance of activities affecting quality, independent of the individual or group directly responsible for performing the specific activity. He has j the authority and organizational freedom to verify activities affectmg l quality. This is performed independent of undue influences and l

responsibilities for schedules and costs. He has the responsibility and l authority, delineated in writing, to stop unsatisfactory work and control further processing, delivery, or installation of nonconforming materials. l He also has the responsibility and authority to identify quality problems, to recommend or provide solutions, and to verify their implementation.

The Vice President - Nuclear Oversight is also responsible for the l

Employee Concerns Program, Independent Safety Engineering and i Operating Experience Program and the Audit program. Specifically, the i key support activities for the Nuclear Oversight program at the HNP are j provided by:

1.4.1.1 Director - Emniovee Concerns The Director - Employee Concems is responsible for the direction and administration of the Employee Concerns Program for Northeast Utilities. The Director assures that nuclear safety concems receive appropriate management attention and that l

[ concerns are addressed in a timely manner.

1.4.1.2 Director- Audits and Evaluation The Director - Audits and Evaluation is responsible for the direction and administration of the audit program to verify:

compliance with 10 CFR 50, Appendix B, other regulatory requirements; and implementation of the CYQAP requirements and evaluate performance. The Director provides support to the

~CYQAP as described in the Nuclear Oversight Department Procedures.

1.4.1.3 Director - Performance Evaluation The Director - Performance Evaluation is responsible for the direction and administration of the Nuclear Oversight program at the HNP as well as the other nuclear units within the NU system.

At CY he is assisted by the the Manager - CY Oversight.

1.4.1.4 Manager - CY Oversight The Manager - CY Oversight manages the audit, surveillance and inspection activities of the HNP.

He is responsible for:

CYQAP REV: 01

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i e a. Managing the Nuclear Oversight program for audits, surveillances andinspections;

- b. Verifying compliance with 10 CFR 50, Appendix B and other regulatory requirements;

c. Verifying the imldeffntation of the CYQAP

_ _ ..:_ _ _.... l The Nuclear Oversight Organization is described in the Northeast Utilities Quality Assurance Program Topical Report (NUQAP). The i i specific functions within the Nuclear Oversight organization  !

applied to the CYQAP are described herein. Additional support functions are provided on an as needed or as requested support basis.

f. Serving as the primary NU Nuclear Oversight manag~ ment interface with HNP management; and

g. Stop unsatisfactory work.

The Manager - CY Oversight is a member of the CY Nuclear i Safety Assessment Board. )

O The Manager-CY Oversight has direct communication to the CY staff, Directors and Executive Vice President and provides the daily interaction on matters affecting quality, nuclear safety, and nuclear related activities.

1.4.1.5 Manager- Nuclear Safety Engineering The Manager-Nuclear Safety Engineering manages the day-to-day activities of the Northeast Utilities Independent Safety Engineering Program and the Operating Experience Program in compliance with the appropriate unit Technical Specifications and licensing commitments. Operating Experience personnel are assigned to j support the CY Oversight Manager. The Manager-Nuclear Safety Engineering provides technical direction for the CY Operating l Experience activities.

l QAP 1.0 4 CYQAP REV: 01 a

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V l 1.4.2 The Executive Vice President and Chief Nuclear Officer -The CY EVP

& CNO has the overall responsibility to implement the CYQAP at the HNP and in providing support services to the operating staff.

1.4.2.1 The Director Site Operations and Decommissioning (DSOD) is responsible for implementation of the CYQAP for the unit and is i responsible for the HNP's safe operation. He has control over those support activities necessary for safe operation, maintenance and 1

decommissioning of the plant. He has delegated the necessary authority and assigned responsibility for the management of these activities to the:

1.4.2.1.1 Unit Director The Unit Director is responsible for the direction and administration of the unit's' Operations, Mechanical, Electrical, and I&C, unit Mainte-ance and Modifications, Technical

,- Specification Surveillance Planning and Scheduling, Security, Chemistry, Health Physics, and Radwaste activities. The Plant Operations Review Committee (PORC) reports to the Unit i Director in compliance with Technical Specifications.

1.4.2.1.2 Engineering Director The Engineering Director is responsible for the administration of Unit Design Engineering, Radiation Protection Engineering, Engineering Programs, Configuration Management Program, and Licensing. He is responsible for maintaining the Design Bases in accordance with the Licensing Bases. He is also responsible for regulatory compliance; commitment management; self assessment and corrective action programs administration.

1.4.2.1.3 Business Manager The Business Manager is responsible for managing and coordinating the financial reporting and control functions for CYAPCO during decommissioning. He oversees materials, inventory reduction and salvage and the administration of contracts.

OV QAP 1.0 5 CYQAP REV: 01

1.4.2.1.4 Decommissionine Project Mananer

, ,Q The Decommissioning Project Manager is responsible for the V overall management of work planning and scheduling for unit operations, decommissioning, demolition, and dismantling activities.

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i C} QAP 1.0 6 CYQAP i REV: 01

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CY ORGANIZATIONAL STRUCTURE i

President and Chief Executive OITicer-NU Nuclear Group l 1

Vice President-Nuclear Oversight l Executive Vice President and Chief Nuclear Officer -CY l J

Director-Performance Evaluation l Director Site Operations and Decommissioning l CY Oversight Manager Unit Director [

l Engineering Director

{

Business Manager F

E$li? FIGURE l-1 Rev 01 Decommissioning Project Manager F

O CY ORGANIZATION and QUALITY FUNCTION Vice President- Nuclear Oversight Executive Vice President and Nuclear Safety Assessment Board Chief Nuclear Officer Director-Performance Evaluation l Director Site Operations and l l Decommissioning ,

CY Oversight Manager Unit Director l Manager-NSE l ,

Engineering Director l I

TD 6

^ Business Manager lNuc Safety Engl ., l l '

lQA Engineering l Decommissioning . l Project Manager l l QA Supervisor l I

Note:

1. T D -Techmcal Direction A -Adninumaine an runcttonal Duccten l Audit ll QA StalT l 2 Audit Schedules and Audit Reports are approved by the Director-Audits and Evaluatum lhe CY Oversight Manager is also supported by the Drector-Audits and Ihaluation QAP 1.0 CYQAP Rev 01 FIGURE l-2

2.0 OUALITY ASSURANCE PROGRAM

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2.1 GENERAL REOUIREMENTS NU has established the CYQAP for the HNP which complies with the criteria of 10 CFR 50, Appendix B an'd follows the guidance referred to in Appendix C and Appendix E, herein. The quality assurance requirements set forth herein, supplemented by the Quality Assurance Procedures, provide the primary basis of the Program and the NU Policy with regard to quality assurance. This program is established for the HNP in a manner intended to accomplish the required level of quality and is carried out throughout the life of the plant. It includes quality activities during the maintenance and modification of the HNP.

The CYQAP is also established, maintained and executed with regard to Radioactive Material Transport Packages described in 10 CFR 71.101(f).

The CYQAP applies in its entirety to activities affecting the safety functions of systems, structures and components. Such activities are quality activities as defined in Appendix A herein. Portions of the CYQAP are also applicable to the Fire Protection Quality Assurance (FPQAland the Radwaste Quality Assurance (RWQA) programs which are delineated as Augmented Quality in established procedures.

L The requirements of this Program are implemented by Connecticut Yankee Atomic Power Company which operates the HNP and their vendors performing activities affecting quality systems, structures, and components at the HNP.

Procedures define the required indoctrination and training of personnel performing activities affecting quality, as necessary, to assure that suitable proficiency is achieved and maintained.

Training sessions are documented. The content is described, attendees and attendance date(s) indicated, and the results of the training session (s)( e.g.,

satisfactory exammation results) recorded.

QAP 2.0 7 CYQAP REV: 01 l I

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.. - . . . . . . ~ - . . - . , - . . - - - - - - . - . - . . . - _ - . - . . - . , _

i f A periodic program. review of the status and adequacy of the CYQAP is accomplished by: ,

e audits, surveillances and inspections; e CY Nuclear Safety Assessment Board (NSAB) reviews; arid o

i e oversight of the CYQAP audit program.

i Vendors are required to review the status and adequacy of that part of the Quality Assurance Program for which they have designated responsibility.

! 2.2 IMPLEMENTATION 2.2.1 GOALS AND OBJECTIVES j The goals of the CYQAP are to maintain quality levels in an effective and

efficient manner and to assure a high degree of functional integrity and reliability j of quality systems, structures and components. To meet this goal, the following objectives of the CYQAP have been defined

{ a. Define through documented procedure's, the quality activities that apply to j the maintenance and modification of the HNP; -

b. Establish, assign, and document the responsibilities for the conduct of those activities affecting quality systems, structures and components;

c. Establish confidence that: i e The maintenance and modification of the HNP is performed in a manner consistent with NU Policies, and l

l e Quality activities are performed by responsible personnel, and are verified '

through a system of audits, surveillances, and inspections of those  ;

orgeaizations with quality responsibilities; l

d. Appraise the President and Chief Executive Officer - NU Nuclear Group of unresolved problems and trends which could have a significant effect on nuclear safety.

O QAP 2.0 CYQAP 8

REV: 01

2.2.2 PROGRAM DOCUMENTATION o

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The CYQAP defines the NU nuclear goals and objectives and is used as guidance for the development of the various implementing procedures. Revisions to the CYQAP will be made as needed to reflect current requirements and descriptions of activities prior to implementation. These revisions will be made in accordance with CY procedures.

Revisions to the CYQAP, which reduce commitments previously accepted by the NRC, are submitted to the NRC for review and approval prior to implementation.

Revisions which do not reduce previously accepted commitments are periodically submitted to the NRC as required by 10 CFR 50.54 (a)(3) and 10 CFR 50.55 (t)(3).

Quality procedures are developed, reviewed and approved by the departments performing quality activities. The CY Oversight Department reviews other department quality procedures for compliance with the CYQAP and concurs on such procedures. Changes to procedures are subjected to the same' degree of control as that utilized in the preparation of the original document.

2.2.3 SYSTEMS. STRUCTURES. AND COMPONENTS The requirements of the CYQAP shall apply, as a minimum, to all safety related syrtems, structures, and components, as addressed in the Safety Analysis Reports (SARs). Safety systems, structures, and components are identified in Appendix A of the CYQAP and also as specifically identified in the CY UFSAR that address Section 3.2.1 of NRC Regulatory Guide 1.70. Currently, the Materials, Equipment, and Parts List (MEPL) program provides instructions to identify

structures, systems, components, parts, materials, and consumables that need to be safety-related or augmented quality. (The CY Engineering organization is considering an altemate process that can be utilized by the CY organization in place of the MEPL pmgram that will provide the necessary guidance to perform and document detem:inations of systems and components in order to comply with the quality requirements contained herein. Process changes will be performed in accordance with CY administrative procedures and QAP 5.0)

For systems, structures and components, covered by the ASME Code, procedures describe the measures taken to assure that the quality assurance requirements contained in the code are supplemented by the specific guidance of the applicable regulatory guides listed in Appendix C of this Program.

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V QAP 2.0 9 CYQAP REV: 01

For systems, structures and components, regulatory commitments and procedures q describe the measures taken to assure that the quality assurance requirements are v met.

The degree of control over activities affecting quality systems, structures, and components is consistent with their importance to safety. The CYQAP provides controls that include the use of appropriate equipment; establishment of suitable controls over special processes and skills necessary to attain the required quality; I and the need for verification of quality by inspection and test. '

CY Oversight and applicable CY line organizations jointly determine and identify  ;

the extent quality assurance controls are to be applied to quality structures, systems, and components. The quality assurance controls are in conformance  !

with this CYQAP, which complies with 10 CFR 50, Appendix B. )

2.2.4 PARTICIPATING ORGANIZATIONS Northeast Utilities requires that its vendors invoke upon their subcontractors, via Purchase Orders / Contracts, requirements for a quality assurance p'rogram to meet the applicable criteria of 10 CFR 50, Appe,ndix B including the applicable elements of the Regulatory Guides and their endorsed Standards identified in Appendix C herein. However, NU retains overall responsibility for the QA Program. The specific quality activities performed by these organizations are

( ) specified in the procurement documents. Nuclear Materials and Document Management is responsible for the review and approval of vendor quality assurance programs prior to initiation of contracted activities. The object of the review is to verify that the vendors have an adequate quality assurance program to meet applicable requirements of 10 CFR 50, Appendix B.

In addition to the initial review, Nuclear Materials and Document Management is responsible for the subsequent performance, as appropriate, of audits, surveillances, and inspection of a vendor's quality assurance program to assure continued implementation of quality requirements. Nuclear Materials and Document Management has contracted the performance of this function to the Yankee Atomic Electric Company (YAEC)in accordance with the Northeast Utilities Quality Assurance Program.

The Nuclear Oversight Department also performs on-site audits, surveillances, and inspections, as appropriate, of the vendor activities.

Vendors may be delegated the execution of quality assurance functions by contract. These contracts are reviewed and approved in accordance with program requirements.

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( QAP 2.0 10 CYQAP REV: 01

2.2.5 INDOCTRINATION AND TRAINING f A prograrn is established and maintained for quality assurance indoctrination and training which provides confidence that the required level of personnel competence and skill is achieved and maintained in the performance of quality activities. Quality procedures delineate the requirements for an indoctrination program to assure that personnel responsible for performing quality activities are instructed in the purpose, scope, and implementation of quality procedures and instructions and that compliance to these documents is mandatory. Each CY Director is responsible for ensuring appropriate indoctrination and training of assigned personnel performing quality activities.

Nuclear training programs shall be developed and implemented to provide training for individuals attached to or associated with the HNP. Additional guidance is established in procedures.

Implementing procedures describe the nuclear training program requirements which assure that:

l Documentation of formal training and qualification programs includes the objective, content of the program, attendees, date of attendance, and examination results, as applicable; (3 Proficiency of personnel performing and verifying activities affecting V quality is established and maintained. Personnel proficiency is established and maintained by training, examination / testing, and/or certification based upon the requirements of the activity. Acceptance criteria are developed to determine ifindividuals are properly trained and qualified; and Certificates or other documentation of qualification clearly delineate the specific functions personnel are qualified to perform and the criteria used to qualify personnelin each function.

2.2.6 MANAGEMENT OVERSIGHT OF THE OUALITY ASSURANCE PROGRAM The CY Executive Vice President and Chief Nuclear Officer ensures that a management review of the CY Quality Assurance Progran is conducted annually to assess the effectiveness of the QA program. This is accomplished by performing an independent assessment of the program in accordance with the Technical Specifications. In addition, the CY Nuclear Safety Assessment Board performs an oversight of the program in accordance with the approved charter.

Results of the assessments and reports are forwarded to the Executive Vice President and Chief Nuclear Officer and the Vice President-Nuclear Oversight for appropriate corrective action, as necessary.

I V QAP 2.0 11 CYQAP REV: 01

l QAP3.0 DESIGN CONTROL  !

O 3.1 GENERAL REOUIREMENTS i

I 4

The CY Engineering Director is responsible for controlling design work, administering i 4

design control activities (including design interface), and design modifications for quality systems, structures and components. I l

l The CYQAP for design control is established to assure that the applicable design i requirements, such as design bases, regulatory requirements, codes, technical standards and 1

quality standards are identified in design documents which are reviewed, approved and controlled in accordance with established procedures. Such controls include a review for

]

suitability of application of materials, equipment, parts and processes that are essential to i the functions of the systems, structures and components. Changes to, and deviations from, )

specified requirements are identified, documented and controlled.

The responsibility for the design control program rests with the CY Engineering Director.

The division of responsibilities and jurisdictional boundaries for program implementation i are set forth in the appropriate CY administrative procedures. Although other organizations i may be delegated the task of establishing and executing the design control program or any part thereof, the CY Engineering Director will retain the nitimate responsibility for the

, program. The applicable requirements of the CYQAP will be imposed on other

, p organizations delegated the task of establishing or executing the program in accordance 4

V with QAP 4.0," Procurement Document Control" and QAP 7.0," Control of Purchased Material, Equipment and Services," herein.

3 The interface controls, both intemal and external, for organizations performing design work i for quality systems, structures and components are identified and implemented in accordance with documented procedures. This identification includes those organizations providing criteria, designs, specifications and technical direction.

Measures are applied to verify the adequacy of design. The extent of design verification is specified and documented by the responsible organization. The individuals performing i design verification should not:

4 (1) have immediate supervisory responsibility for the individual performing the design; (2) have specified a singular design approach; (3) have ruled out certain design considerations; or (4) have established the design inputs for the particular design aspect being verified.

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QAP 3.0 12 CYQAP REV: 01 9

The independent design verification should not dilute or replace the responsibility of the supervisors for the quality of work performed under their supersision. Where changes to O- previously verified designs have been made, design verifications are required for the change, including evaluation of the effects of those changes on the overall design. Design verification may be accomplished by testing. Tests to demonstrate adequacy under adverse design conditions shall comply with the requirements of QAP 11.0, " TEST CONTROL" Design errors and deficiencies which adversely affect quality systems, structures and components in design process are documented, and appropriate corrective action is taken.

These design errors and deficiencies are documented in accordance with design change procedures or as defined in QAP 16.0," Corrective Action."

3.2 IMPLEMENTATION The CY Engineering Director is responsible for the design, design review, engineering i approval ofdesign changes, design evaluation and design control at the HNP. The function may be delegated to other organizations to perform the design activity, or any part thereof, but the responsibility for overall design remains with the CY Engineering Director. In all cases, final engineering decisions and ultimate design control of systems, structures and components related to the HNP is the responsibility,of the CY Engineering Director.

The CY Oversight department performs audits, surveillances, and inspections, to verify that Departments are effectively complying with the CYQAP and procedural requirements for design control.

Nuclear Materials and Document Management is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspections, to verify that vendors are effectively complying with the CYQAP and/or the NUQAP and procedural requirements for design control.

CY and NU Oversight perform, as appropriate, on-site audits, surveillances, and inspections of these vendor activities.

3.2.1 DESIGN PROCESS Design control measures are applied to design analyses, such as: stress, thermal, hydraulic, nuclear radiation, accident and seismic analyses; compatibility of materials; accessibility for required inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and test. Measures established to control design documents are described in QAP 6.0," Document Control."

QAP 3.0 13 O CYQAP REV: 01

Program procedures and instructions define the method ofimplementing design control measures. These measures require that applicable design requirements.

such as, design bases, regulatory requirements, codes and standards, are translated into specifications, drawings, procedures or instructions. Instructions further require that appropriate quality standards are specified and included in design documents. All materials, equipment, parts and processes, including standard "off the shelf" commercial or previously approved items essemial to the quality functions, are selected and reviewed for suitability of application.

The basis for selection may include industry standards, material and prototype hardware testing programs, and design review.

CY procedures assure that a documented check is performed to verify the accuracy and completeness of design drawings and specifications before release for use. i l

Design drawings and specifications issued for design changes are reviewed for completeness and accuracy before being released to operations, in accordance with CY procedures.  !

I CY procedures describe the provisions to assure < hat design drawings and I specifications are prepared, reviewed and approved in accordance with company procedures, and that the documents contain the necessary quality assurance requirements, such as inspections and test requirements, acceptance requirements, and the extent of documenting inspection and test results.

3.2.2 DESIGN CHANGE CONTROL Procedures and instructions govern design change control during modifications to the HNP. Control of discrepant or deficient design conditions, and reported unsatisfactory performance, provide for the identification of design changes and a documented method to control these changes. Design and specification changes are subject to design control measures commensurate with those applied during the original design.

An independent review and approval of design changes is performed by the organization that conducted the original design reviews, unless another qualified organization is designated to perform this function.

Proposed design change modifications are submitted to management for processing and review. This review includes the review by the Plant Operations Review Committee (PORC). PORC advises the CY Unit Director on matters relating to nuclear safety. Composition, responsibilities, and authority of the QAP 3.0 14 O, CYQAP REV: 01

committee are defined in Section 6 of the CY Technical Specifications. If the ,

proposed change involves a quality system structure or component, the change '

V will be reviewed by qualified engineering personnel for technical adequacy.

Reviews of the safety evaluations associated with design change requests are i

- performed by the CY Nuclear Safety Assessment Board. The sequence of the i NSAB review depends ~u pon the determination of whether an unreviewed safety j question is involved (i.e., in accordance with 10 CFR 50.59, if a proposed change in the facility involves an unreviewed safety question then the NSAB and NRC approval is required prior to implementation).

j The combination of these independent reviews by the PORC and NSAB are i performed to assure that:

[ a. The adequacy of the proposed change is substantiated; i

b. Unreviewed safety questions are properly identified and dispositioned per

! 10 CFR 50.59; and l

c. Nuclear safety requirements have been addressed.

Errors and deficiencies in design, including the design process, that could adversely affect quality structures, systems, and comp 6nents are documented and corrective action is taken in accordance with QAP 16.0," Corrective Action."

O Notification of design changes are transmitted to responsible plant personnel as part of the design package close out. CY procedures describe this notification which assures that personnel are made aware of design change modifications.

3.2.3 DESIGN INTERFACE CONTROL The CY Engineering Director is responsible for review, coordination and documentation of design interfaces. Procedures provide for the method for identifying design interfaces, changes, and modifications affecting drawings and design documents.

Procedures and instructions identify design interfaces which are controlled by the Executive Vice President and Chief Nuclear Officer.

3.2.4 INDEPENDENT DESIGN VERIFICATION Design changes are reviewed for adequacy and the sign-off performed by a person other than the originator of the design. Design verification is documented in accordance with procedures or instructions. Simplified calculations or computer QAP 3.0 15 CYQAP REV: 01

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programs may be utilized as attemate means of design verification. When design

,q verification is performed by testing, the tests are performed using approved

' V procedures, which specify the authority and responsibility of design verification 4

personnel. Ultimate responsibility for design adequacy and evaluation is retained by the CY Engineering Director.

1 Design verification (if other tnan by qualification testing) is normally completed

, prior to release for procurement, manufacturing, and construction, or to anc.ther

' organization for use in other design activities. For those cases where design verification cannot be completed prior to release for procurement, manufacturing, and construction, procedures ensure that design verification is completed prior to the point when the installation is declared operational.

CY procedures describe the requirements which assure the following when testing is considered as an alternate method of design verification:

1 i

a. Specifications or procedures provide criteria that specify when

verification should be by test.

b. Prototype, component or feature, testing is performed as early as possible prior to installation of plant equipmentcor prior to the point when the j installation is declared operational.

n j l] c. Verification by test performed under conditions that simulate the most adverse conditions as determined by analysis.

l Particular emphasis is placed on assuring that designs are in conformance with applicable codes, and on selecting the proper design verification or checking method. Procedures and instructions provide the requirements and necessary i controls for design verification. These controls include a review to assure that

! design characteristics can be controlled, verification that there is adequate l accessibility for inspection or test, and that inspection and test acceptance criteria -

. are incorporated. Documentation of reviews is provided.

j CY procedures include requirements which identify the responsibility of design verifiers, the areas and features to be verified, and the extent of the documentation.

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i CY procedures assure that procedural control is established for design documents

'A that reflect the commitments of the SAR. These procedural controls vary for

!V design documents which receive formal design verification by several disciplines l i or organizations, and those which can be reviewed by a single individual. The  ;

specific design documents and specialized reviews are determined and used as

1. l required by the design changes and modifications.

l CY procedures are established to assure that verified computer programs are  ;

certified for a specific use. '

The CY Engineering Director is responsible for assuring that design documents  !

provided by vendors are adequately approved and maintained. 1 I

O QAP 3.0 CYQAP 17 REV: 01

QAP4.0 PROCUREMENT DOCUMENT CONTRQL 4.1 GENERAL REOUIREMENTS ~

The procurement of materials, equipment, parts and/or services required udng the maintenance and modification of quality systems, structures and components at the HNP is  ;

performed in a controlled manner which assures compliance with applicable regulatory l requirements, procedures, quality assurance standards and regulations affecting i

procurement documents. Changes to procurement documents are subject to the same degree l ofcontrol as utilized in the preparation of the original documents.

4.2 IMPLEMENTATION l

l 4.2.1 PROGRAM j Material and service requests are reviewed for technical adequacy and verification of the quality designation. The appropriate engineering management reviews and approves rnaterial and service requests, as applicable.

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Nuclear Materials and Document Management personnel perform a procurement engineering evaluation to ensure the inclusion and adequacy of technical and quality assurance requirements prior to the issuance of the Purchase Order.

p Material for which technical and quality assurance requirements have been Q previously established are procured without additional procurement engineering evaluation.

Vendors utilized in the maintenance and modification of the HNP are responsible to implement measures for control of procurement documents associated with quality material, equipment, parts and services to ensure applicable requirements including quality assurance requirements are specified.

Nuclear Materials and Document Management performs, as appropriate, off-site audits, surveillances, and inspections to ensure that vendors are effectively complying with the requirements for the control of procurement documents. I CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of these vendor activities.

Changes to procurement documents are subjected to the same degree of control as that utilized in the preparation of the original document. The procurement of spare or replacement parts for quality systems, structures, or components is subject to the controls of the CYQAP and implementing procedure requirements. The spare or replacement parts are subject to controls equivalent to original or subsequent

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QAP 4.0 18 CYQAP REV: 01 l

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codes and standards. The use of subsequent codes and standards are controlled m p accordance with the design change control requirements in QAP 3.0, " Design  ;

V Control."

l Procurement engineering evaluations of quality related material and services requests are performed by Nuclear Materials and Document Management personnel to ensure that:

a. Adequate technical requirements are specified;

b. The quality assurance requirements are correctly stated, auditable and controllable; and

c. There are adequate acceptance and rejection criteria.

4.2.2 PROCUREMENT DOCUMENT PROVISIONS Procurement documents are prepared, reviewed and approved in accordance with procedures of the issuing organization or department and are avail'able for verification. These procedures require that. procurement documents consist of the following, as necessary: -

a. The scope of work to be performed; O b. Technical requirements (specified or referenced) including the applicable components and materials identification requirements, drawings, specifications, procedures, instructions, codes and regulations, and the identification of applicable test, inspection and acceptance requirements, or special process instructions;

c. CYQAP requirements to be imposed on contractors which include the applicable requirements of 10 CFR 50, Appendix B, and the NRC regulatory position contained in the Regulatory Guides and their endorsed ANSI Standards listed in Appendix C, herein;

d. Right of access which provides, as appropriate, for access to contractor facilities and records for inspection or audit by NUSCO/CYAPCO or its designated representative; and provides access for events such as those requiring notification of hold points; and/or

e. The documentation required to be prepared, maintained, and/or submitted to NUSCO/CYAPCO or its representative for review, approval or historical record. De time of submittal of this documentation and the QAP 4.0 19

( CYQAP REV: 01

retention and disposition of quality assurance records which are not f submitted to NUSCO / CYAPCO is prescribed. as applicable, for Nuclear Grade procurements.

4.2.3 SELECTION OF PROCUREMENT SOURCES If the vendor is not specified, the function of procurement source selection is the responsibility of the NUSCO Purchasing Department. The Purchasing Department verifies that the procurement document has been reviewed and approved, and that the vendor has been approved for procurement prior to issuing the purchase order for the material, equipment, parts and services.

Purchase Orders / Contracts may be issued to organizations with unapproved quality assurance programs. These procurement documents to unapproved organizations contain detailed supplementary quality assurance requirements and/or witness / hold points to verify NUSCO/CY requirements.

Material requisitions are reviewed by Nuclear Materials and Document Management to ensure appropriate quality assurance requirements are specified.

These requirements, included in the procutement document, as necessary, include acceptance criteria, audits, surveillances and/or inspections at the vendor's facilities with scheduled witness / hold points during the fabrication process and/or prior to shipment of the procured item. Acceptance inspections and tests determined by NUSCO/CYAPCO shall be performed after receipt at the HNP but prior to operability.

QAP 4.0 20 O CYQAP-REV: 01

QAP5.0 PROCEDURES. INSTRUCTIONS. AND DRAWINGS n

v 5.1 GENERAL REOUIREMENTS i The CYQAP provides measures for the preparation, review, approval, control and I distribution of procedures, instructions and drawings of activities affecting quality systems, swetures and components during maintenance, modification, and decommissioning of the ]

IINP, The documents include appropriate quantitative and qualitative acceptance criteria l which specify the activity to be performed; the methods of constmetion and testing to be  !

employed; material, equipment or parts to be used; a sequence of operation and the required l documentation.

5.2 IMPLEMENTATION l

Quality procedures provide direction for personnel performing quality functions. CY l Oversight reviews and concurs with quality procedures as defined in the CY administrative i control procedures. Comments concerning compliance with the CYQAP and regulatory i requirements are resolved prior to issuance of the procedure.  !

Vendors utilized in the maintenance and modification of the HNP may be delegated i responsibility for preparing, maintaining, issuing and v' erifying the implementation of program documents which are selectively reviewed / approved b9 the appropriate Director. l C\

V Nuclear Materials and Document Management is responsible for the performance, as I appropriate, of off-site audits, surveillances, and inspections of the quality assurance  !

programs to ensure the vendors are effectively complying with the requirements for procedures and instructions.

CY_ Oversight performs, as appropriate, on-site audits, surveillances, and inspections of these vendor activities. Vendor programs are required to clearly delineate the actions to be accomplished in the preparation, review and control of procedures, instructions and drawings and the methods for complying with 10 CFR 50, Appendix B.

5.2.1 PROCEDURES AND INSTRUCTIONS Procedures and instructions for activities affecting quality are prepared, reviewed, and approved in accordance with written procedures and instructions.

(m QAP 5.0 21 i CYQAP REV: 01 O_

The appropriate CY Director ensures that any vendors utilized in the maintenance  !

O and modification of the HNP, implement quality assurance programs which contain written instructions for preparation, review and approval of procedures and instructions affecting quality. In addition, vendor's site quality procedures and quality control inspection procedures are reviewed for concurrence by CY 1 Oversight to assure compliance with the vendor's QA Program. )

i The CY line organization is responsible for the preparation, review and approval _j of plant quality procedures. The procedures include test procedures and overall -

site administrative procedures which implement the requirements of the CYQAP.

CY Oversight reviews and concurs with quality procedures and special process manuals and procedures. The criteria for documents requiring CY review are defined in CY administrative procedures to ensure that:

a. Administrative manuals and procedures which implement the CYQAP are reviewed for compliance with the CYQAP and applicable Appendix C guides and standards, and I

b. Work Procedures / Work Documents used to perform quality activities are reviewed to assure appropriate, quality assurance controls have been i

~ '

specified.

5.2.2 DRAWINGS O' The design control and verification measures described in QAP 3.0, are applicable for the review and approval of drawings. Review and approval of new drawings or changes to existing drawings are described in CY procedures. The originating organization may delegate to other organizations or departments the work of design and review activities, or any part thereof, but retains responsibility for this work.

The measures taken to assure the preparation of as-built drawings and related documentation in a timely manner to accurately reflect the plant are described in CY procedures. Drawings critical to the maintenance of the long term fuel storage are updated prior to system turnover to operation and are available to the operating personnel.

5.2.3 ACCEPTANCE CRITERIA Review and approval of departmental procedures, instructions and drawings is described in CY procedures to ensure the inclusion of adequate quantitative and qualitative acceptance criteria for determining satisfactory work performance and quality compliance. These criteria ' apply to quality activities as defined in the CYQAP.

O QAP 5.0 CYQAP 22 REV:' 01 1

1 n I

i QAP6.0 DOCUMENT CONTROL 6.1 GENERAL REOUIREMENTS The CYQAP provides measures to assure controlled distribution of documents pertinent to

- Quality Activities affecting the safety related functions of structures, systems, and components in accordance with CY quality procedures and 10 CFR 50, Appendix B. l Documents such as procedures, instructions, drawings, specifications and reports are prepared, reviewed for appropriate qualitative and quantitative acceptance criteria, and approved by authorized personnel in the affected organization. Approved controlled documents are distributed to affected locations in accordance with a controlled distributica list. Changes to controlled documents are reviewed and approved by the same organization which performed the original review and approval, unless othemise specified in the implementing procedures. Measures are provided for controlling documents to preclude the possibility of the use of outdated documents.

6.2 1MPLEMENTAILQM 6.2.1 RESPONSIBILITY .

CY procedures and instructions delineate the measures for controlling documents p including direction for the review for adequacy, approval by authorized personnel, y distribution of controll~1 documents and verification that changes are promptly incorporated and implemented. These control measures apply to applicable documents affecting systems, structures and components for the maintenance and modification of the HNP, such as:

a. Design Specifications;

b. Design, Manufacturing, Construction and Installation Drawings;

c. As-Built Documents;

d. Quality Assurance Program Manuals, Procedures and Instructions;

e. Manufacturing, Inspection and Testing Instructions;

f. Test Procedures;

g. Calculations;

h. Engineering Record Correspondence; QAP 6.0 23

{s CYQAP REV: 01 u

i. Design Basis Documentation;

j. Final Safety Analysis Reports;

k. Procurement Documents;

1. Design Change Records;

m. CY Quality Assurance Program;

n. Nonconformance Reports; and

o. Computer Codes.

CY procedures describe the measures taken for the control of documents to assure review and concurrence, as necessary, with regards to quality assurance aspects.

The requirements for control of procurement documents are contained in QAP 4.0, " Procurement Document Control." Dpring all phases of plant life, it is the responsibility of each organization issuing controlled documents to employ document control procedures. The issuing organization is additionally responsible for distribution of the documents to appropriate locations. There shall be provisions to assure that approved changes are included in instructions, procedures, drawings and other documents prior to implementation of the changes.

Vendors utilized by CY in the maintenance and modification of the HNP are responsible for implementing measures for review, approval, control and distribution of controlled documents, to ensure they are effectively complying with the requirements for document control.

Nuclear Materials and Document Managemem is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspections of the vendors to verify compliance with their approved quality assurance programs.

CY Oversight perfonns. as appropriate, on-site audits, surveillances, and inspections of these vendor activities.

6.2.2 DISTRIBUTION OF CONTROLLED DOCUMENTS CY procedures, specify in what manner controlled documents and revisions thereof, are distributed to appropriate locations, prior to commencing the work.

QAP 6.0 24

\ CYQAP REV: 01

4 l

l 6.2.3 DRAWING CONTROL O The Nuclear Document Services Organization is responsible to implement a program for the retention and retrieval of drawings and records submitted by cognizant CY personnel. The Nuclear Document Services Organization maintains i a drawing status file which includes drawings (newly issued or revised) with the  ;

latest revision and current status. l l

The vendors utilized during the maintenance and modification of the HNP may be delegated the function of drawing control and must furnish periodic status reports listing the revisions of applicable drawings issued.

Nuclear Materials and Document Management is responsible for the performance of off-site audits, surveillances, and inspections of vendors to verify they are effectively complying with their programs for document control of drawings.

CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of vendor activities.

6.2.4 INSTRUCTION AND PROCEDURE CdNTROL CY Oversight performs audits, surveillances, and inspections of departments and, as appropriate, any on-site vendors utilized in maintenance and modification to the HNP to ensure they are effectively complying with their QA program ar control of procedures and instructions. .

l The originating department is responsible for establishing adequate control over quality procedures and instructions issued by the vendor. The responsible organization also issues status reports or revised indices listing the latest revision of applicable controlled documents issued by the vendor. Procedures identify requirements for assuring controlled documents are available at the work location prior to commencing work.

l 1

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QAP 6.0 25 O CYQAP REV: 01

QAP7.0 CONTROL OF PURCHASED MATERIAL. EOUIPMENT.

Q AND SERVICES V

7.1 GENERAL REOUIREMENTS I Measures for the control of procured material, equipment, parts and services by or for CY related to the safety of nuclear power plants are established and imposed by the CYQAP during maintenance and modification to the HNP to ensure confomlance to procurement ,

documents. These measures include provisions for source evaluation and selection, I submission of objective evidence by the contractor or subcontractor, inspection at the vendor source and examination ofitems upon delivery. Control of quality by vendors and l subcontractors is assessed for effectiveness at intervals consistent with the importance,  !

complexity and quantity of the product or service.

7.2 IMPI EMENTATION 1

The evaluation and selection of vendors is performed in accordance with procedures, which l specify that procurement source evaluation and selection measures are performed to determine vendor capability and delineate responsibilities of qualified personnel involved in the evaluation and selection process. -

7.2.1 VENDOR OUALIFICATIONS V Nuclear Materials and Document Management utilizes one or more of the following methods in evaluating the qualifications of a potential supplier: l

a. Audits and/or coordinated review of a potential supplier utilizing NU/CY  ;

personnel and/or YAEC personnel; l

b. Other utility supplier audits and evaluations; i

c. Nuclear Procurement Issues Committee (NUPIC) audits;

d. ASME N, NA, NPT, NV, or MM/ MS Certificate of Authorization; l

e. Commercial grade surveys and/or coordinated review of a potential supplier utilizing one or more departments, (i.e., Engineering, Operations )

and/or Purchasing); or j l

f. Source inspection / surveillance.

l O QAP 7.0 26 l V CYQAP l REV: 01 l 1

l 1

._l

Evaluations ensure that suppliers employ a quality assurance program that l conforms to applicable portions of the NUQAP Topical Report and/or the l (~]

t V CYQAP.

Nuclear Materials and Document Management is responsible for maintaining i documented evidence of the evaluation and acceptance of the vendor's quality assurance program. The determination of vendor approval is based on such factors as prior performance, quality performance data, audits, commercial grade surveys, surveillances and evaluations of the supplier's quality assurance program.

Vendors' Certificates of Conformance are periodically evaluated by audits.

l commercial grade surveys, surveillances, independent inspections and tests, to assure they are valid. This verification of Certificates of Conformance is documented.

7.2.2 SOURCE INSPECTION Nuclear Materials and Document Management is responsible for the performance of source inspections at suppliers' facilities to ensure that the requirements of a Purchase Order / Contract have been met. .

Source inspections are performed in accordance with procedures which provide g for the method ofinspection, the extent of documentation required, and those

() responsible for implementing those instructions.

Inspection ofitems occurs either when verifications of procurement requirements cannot be determined upon receipt or the vendor's QA program has not been accepted by Nuclear Materials and Document Management.

Nuclear Materials and Document Management has contracted the performance of the vendor source inspection function to the Yankee Atomic Electric Company (YAEC) in accordance with the NUQAP Topical Report. CY has accepted the NU vendor QA process described in the NUQAP Topical Report based on audits performed to accept the YAEC process.

7.2.3 RECEIPT INSPECTION  :

1 1

Receipt inspection for procured items is performed by Nuclear Materials and l Document Management in accordance with quality procedures which delineate  !

requirements and responsibilities necessary to perform inspection functions. An exception to this is Chemistry performing receipt inspection for diesel fuel in l accordance with CY procedures. Contractual obligation fulfillment and specified requirements are verified during receipt inspections.

I (7 QAP 7.0 27

.b CYQAP REV: 01

, 1

l Receipt inspection of supplier-furnished material and equipment is performed to d,.m assure that material, components, equipment and acceptance records are examined in accordance with predetermined inspection instructions prior to ecceptance, installation and operation. Receipt inspections include, as appropriate:

a. Measures for verifying that the shipment is complete, properly identified, l

undamaged and corresponds with the required documentation; I

b. Measures for inspection of the item and review of supporting documentation (e.g., mill test reports, NDE reports) as required by the purchase documents;

c. Measures for inspection and acceptance ofitems in accordance with predetermined methods;

d. Measures for identifying and controlling acceptable items including identification ofinspection status prior to release from the receipt inspection area;

e. Measures for identifying, segregati6g and handling nonconforming items;

f. Measures to ascertain that inspection records or certificates of b'

d conformance are acceptable prior to release for installation; and/or

g. In cases involving procurement of services, the project engineer or department head shall designate the means by which services may be accepted, and is given the authority to accept services in accordance with methods defined in NU or CY procedures.

7.2.4 VENDOR FURNISHED RECORDS Records required to be furnished by the vendor are specified in the procurement document. Certifications or documentation provided by the supplier which attests to conformance, identifies that all the specific procurement requirements have been met (either by reference to the purchase order or by delineation).

The vendor must furnish the following records as a minimum:

a. Documentation that identifies the purchased material or equipment and the specific procurement requirements. (e.g., codes, standards and specifications) which have been met by the items; and, (q

/

_/

QAP 7.0 CYQAP 28 REV: 01

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b. Documentation that identifies any procurement requirements which have l

o not been met, together with a description of those nonconformances V dispositioned " accept as is" or " repair."

The responsible Nuclear Materials and Document Management and/or other  !

Departrnent personnel shall review f6r a'cceptability those documents which pertain to the requirements in the procurement document, in accordance with the ,

NUQAP Topical Report and/or the CYQAP and its applicable procedures.

The Departme it that is contracting on-site QA services shall be responsible for the review and acceptability of vendor personnel / equipment certifications prior to the start of work. Nuclear Oversight or CY Oversight will provide oversight of ,

these activities via audit, surveillance, or inspection.

l 7.2.5 COMMERCIAL DEDICATION NUSCO / CY procedures address the measures taken to assure that commercial grade items, where specific quality assurance controls for nuclear applications cannot be imposed in a practicable manner, that special dedicatiori requirements are established and implemented. ,

These measures follow the guidance in Regulatory Guide 1.144, paragraph C.3.b (1) and Regulatory Guide 1.123 and applicable paragraphs of Section 10 of ANSI

( ) N45.2.13.

These measures include appropriate requirements for special categorization and identification within the procurement document, receipt inspection, and additional controls during the installation and testing process to be performed by Nuclear Materials and Document Management, CY organization and/or other appropriate groups.

p QAP 7.0 29 V CYQAP REV: 01 u

QAP 8.0 IDENTIFICATION AND CONTROL OF MATERIALS.

( PARTS AND COMPONENTS 8.1 GENERAL REOUIREMENTS The CY organization assures that the identification ofinspections, tests, and operation status of structures, systems, and components is known by affected organizations.

The CYQAP provides measures for the identification and control of material, parts and components, including partially fabricated assemblies, during maintenance and modification to the HNP. To ensure that each item can be traced to associated documentation, the identification of the item is maintained by heat number, lot number, part number, serial number, or other appropriate methods, and is physically marked on the item and/or on records traceable to the item. Documentation associated with material, equipment, and components delineated that these items have been designed, fabricated, manufactured, tested and/or inspected in accordance with the specified requirements. The object of these controls is to prevent the use ofincorrect or defective materials, parts and components, in accordance with 10 CFR 50, Appendix B.

8.2 IMPLEMENTATION -

NUSCO and CY procedures establish the responsibilities and requirements for the identification and control of materials, parts and components. The procedures assure that identification and control is maintained throughout fabrication, receipt, handling, storage and installation ofitems. Provisions include:

i

a. Requirements for traceability to appropriate documentation, such as: i l

e Purchase orders / contracts, l

. Manufacturing documents,

. Drawings, e Specifications, e Certifications, e Inspection and test records, and

. Nonconfomiance reports.

QAP 8.0 30 CYQAP REV: 01

i l

1

b. ControS to assure that the correct identification of an item is verified and

[]'

'v documented prior to release for fabrication, assembly, shipping or installation,

c. Requirements which assure that the method or location of markings do not  ;

affect the function or quality of an item, or

d. EstaHishment ofidentification requirements in purchase orders, contracts, specifications, drawings, procedures or instructions.  ;

During the maintenance and modification of the HNP, CY may delegate any portion of the  !

implementation of the identification and control program to a vendor contracted to perform related quality activities. If delegated, contracts require that the vendor establish an identification and control program which meets the CYQAP requirement. l Nuclear Materials and Document Management is responsible for the performance , as appropriate, ofoff-site audits, surveillances, and inspections of the vendor's quality assurance program, to ensure they are effectively complying with the requirements for identification and control of material, equipment and components. I CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of the ,

vendor activities. - 1 i

(/ Receipt inspections are performed to verify that materials, equipment and components are l properly identified in accordance with procurement requirements. Nuclear Materials and 1 Document Management is responsible for assigning and applying permanent identification l

to the items in accordance with procedures. If the application of a serial number is not practical, other means ofidentification are implemented to assure proper identification and traceability.

1 I

In the event that the equipment, material or component is nonconforming er the l identification becomes lost or illegible, the items are considered nonconforming and are l

identified and controlled in accordance with QAP 15.0, " Nonconforming Materials, Parts, Components, or Services."

C)

'd QAP 8.0 31 CYQAP REV: 01 i

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QAP9.0 CONTROL OF SPECIAL PROCESSES 9.1 GENERAL REOUIREMENTS The CYQAP provides measures to assure control of special processes associated with quality systems, structures and components by the use of qualified procedures, equipment and personnel during maintenance and modification of the HNP. .

Special processes are performed under controlled conditions in accordance with special requirements and may include, but are not limited to: welding, cleaning, heat treating, and nondestructive examination and/or testing.

9.2 IMPI EMENTATION During maintenance and modification of the HNP, CY Engineering ensures that special process data and documentation is reviewed; vendor's special process procedures used at  :

the HNP are qualified and approved; and that personnel and equipment utilizing special processes are properly qualified prior to the start of work.

Nuclear Materials and Document Management is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspe'ctions to ensure the vendors are effectively complying with their quality assurance program regsirements for control of special processes.

CY Oversight performs, as appropriate, on-site audits, surveillances, and inspections of the vendor activities.  !

I I'

NUSCO/CY special process procedures utilized during maintenance and modification of the HNP are prepared, reviewed and approved in accordance with procedures as specified in QAF 5.0, " Procedures, Instructions, and Drawings."

9.2.1 PROCEDURE OUALIFICATION AND CONTROL NUSCO/CY procedures specify that written process control documents are utilized and qualified, as required, in accordance with the applicable specification, ,

codes or standards. ,

I 9.2.2 PERSONNEL OUALIFICATION AND CERTIFICATION Codes, standards and NUSCO/CY procedures specify personnel qualification / certification requirements. Personnel responsible for the performance and verification of special processes are trained, tested, and certified I

as required by applicable specifications, codes and standards. Requirements for

, QAP 9.0 32

\ CYQAP REV: 01 l

1 I

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the period of certification. retesting, and recertification of personnel are also p

specified. Vendors qualify personnel and maintain records of qualified personnel i

in accordance with applicable codes, standards, specifications, and vendor l

Purchase Order / Contract requirements. The department that is contracting {

service's is responsible for the review of records of qualified personnel, equipment I and procedures associated with special processes.

I CY Oversight performs, as appropriate, audits, and surveillances of the personnel qualification process.

)

The NU Nuclear Oversight Department is responsible for ensuring that the l training, testing, and certification of NDE personnel at the HNP is in accordance with the requirements of Regulatory Guide 1.58 (Rev.1,9/80) and ASNT l Recommended Practice No. SNT-TC-1 A.

9.2.3 SPECIAL PROCESS RECORDS l Records provide objective evidence that special processes were performed in accordance with procedures, by qualified personnel, and that when required by procedures, specifications, and codes, suci l performance was verified. Results of nondestructive examinations are recorded in accordance with applicable specifications, codes and standards. These records are retained by the vendor or e supplied to CY as required by contract or purchase order. If records are to be retained by the supplier, the contract or purchase order specifies the retention period and instruction for final disposition of records.

Special process documentation such as special process procedures, qualifying data, and personnel and equipment qualification records associated with the performance of special processes at nuclear power plants, are kept current and maintained in appropriate CY files, with final disposition to the Nuclear  !

Document Services Facility.

I I

OD QAP 9.0 CYQAP 33

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REV: 01 i

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QAP 10.0 INSPECTION

/

l 10.1 GENERAL REOUIREMENTS l l

Inspection of activities to verify the quality of systems, structures and components, which are performed by or for CY are executed in accordance with the CYQAP and appropriate procedures, instructions and drawings by qualified personnel independent from the individual or group performing the activity being inspected. Ifinspection is impossible or disadvantageous, indirect controls by monitoring processing methods, equipment and personnel are provided. Inspection notification and hold points are identified, as required, in the applicable documents, l

10.2 IMPLEMENTATION 10.2.1 INSPECTION RESPONSIBILITIES During maintenance and modification of the HNP, procedures shall define the need for inspections (e.g., receipt inspections, installation, and product acceptance).

CY Oversight shall ensure procedural requirements are met by means of audits and surveillances as defined in Nuclear Oversight Department procedures.

CY Oversight shall perform inspections of modification and maintenance activities on systems, structures, and components governed by the CYQAP. The l criteria used to determine when CY Oversight inspection shall be required for these activities and for the preparation ofinspection plans shall be identified in appropriate procedures. CY Oversight shall be responsible for this inspection function which includes:

a. Identification ofinspection personnel;

b. Review of work procedures and work documents to identify QA " hold" i points associated with the work ; l

c. Preparation and approval ofinspection plans ensuring that the necessary inspection requirements, methods, and acceptance criteria have been identified; and

d. Documentation ofinspection results.

Nuclear Materials and Document Management is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspections to verify that any QAP 10.0 34 O' CYQAP i

i REV: 01 e

vendor utilized in the maintenance and modification of the HNP are effectivelv ~ '

complying with their quality assurance program requirements for inspection ar1d for performing / witnessing inspections at " hold" or " notification" points identified in procurement documents.

CY Oversight performs', as appropriate, on-site audits, surveillances, and inspections of vendor activities.

10.2.2 INSPECTION PLANS Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans are based on design specifications, procurement documents, drawings, other specifications, or previous experience, as appropriate.

During the performance of CY work activities, procedures provide criteria for the determination of accuracy requirements ofinspection equipment and when inspections are required. These procedures describe requirements for the preparation of surveillance and/or inspection plans by CY Oversight. .

The inspection criteria, including the use ofinspection equipment and their accuracy requirements, are specified in the CY Oversight surveillance / inspection plans.

10.2.3 INSPECTION PERSONNEL AND INSPECTION DOCUMENT ACCESS l 1

Inspections are performed by individuals other than those who performed or directly supervised the activity being inspected. Inspection personnel are qualified and/or certified in accordance with appropriate codes, standards, and/or training programs; Inspections are performed by CY Oversight personnel or qualified contract personnel. The Department that is contracting on-site QA inspection services shall be responsible for the review and acceptability of vendor personnel / equipment certification prior to the initiation of the activity; When vendors are contracted to perform inspection services, their inspection I plans / procedures are reviewed and concurred upon by CY Oversight in accordance '

I with QAP 5.0, " Procedures, Instructions, and Drawings."

Access to drawings, procedures, specifications or other documented criteria necessary for the performance ofinspections is provided prior to performing the inspection activity.

( QAP 10.0 35 CYQAP REV: 01

. . . .- - -- - . - . - ~ _ . _. - - .- - - .- . -. - - - - .

1 10.2.4 INSPECTION PROCEDURES

'O O

(a) Required inspection or surveillance activities are performed and documented in accordance with procedures and/or checklists. Inspection l procedures, plans or checklists contain the following:

(1) Identification of characteristics to be inspected;

, (2) Identification of the individual or groups responsible for performing the inspections; i

(3) Requirements for the necessary measuring and test equipment and 4

the required accuracy of this equipment;

(4) Acceptance criteria;

(5) A description of the method ofinspection when other than direct i visual examination using the unaided eye; l (6) A record of the results of th,e inspection; and/or (7) Record ofinspector or data recorder.

3 (b) Procedures specify surveillance of processing methods or testing and operation of equipment when inspection is impossible, inaccessible or not l applicable.

) (c) Modification, repair, replacement or rework items are inspected in l

accordance with original inspection requirements or approved alternatives.  !

10.2.5 MANDATORY HOLD AND NOTIFICATION POINTS

Mandatory hold points are utilized when an inspection / operation must be performed or witnessed and signed off by the responsible personnel before work can proceed. Notification points are used to identify the operations or completed

processes that CY Oversight or its representatives may elect to witness and/or l inspect during the manufacturing or installation process. Mandatory hold and

~;- notification points, as required, are identified in procurement documents and work procedures / documents. Purchase Order / Contracts and work procedures / documents i are subject to the review and concurrence for adequacy ofinspection, notification l and/or mandatory hold controls by Nuclear Materials and Document Management and CY Oversight, respectively.

QAP 10.0 36

, CYQAP

REV

01 v

P 10.2.6 INSPECTION RESULTS EVALUATION 4

V Inspection results are evaluated for acceptability in accordance with procedures which identify the responsible organization.

The evaluations are performed by the responsible personnel who are qualified in accordance with the appropriate Regulatory Guide / ANSI Standard commitments listed in Appendix C.

I CY Oversight performs audits and surveillances to assure that inspections are performed per the requirements of applicable CY procedures. l

)

i QAP 10.0 37 O- CYQAP '

REV: 01 9

QAP 11.0 TEST CONTROL

'(VD 11.1 GENERAL REOUIREMENTS A documented test control program is established by the CYQAP for systems, structures and components to ensure that they will perform satisfactorily in service and that test results are doc niiet.1 d L accordance with 10 CFR 50, Appendix B and other pertinent regulatory and/or technical tecluirements.

The test control program identifies the systems, structures and components to be tested, method of conducting tests, evaluation of tests and documentation of tests by qualified personnel to assure requirements have been satisfied.

The test control program is systematic and includes proof tests prior to installation, construction tests, operational tests, surveillance tests, and retest following repairs, replacements, preventative maintenance or modifications.

I 1.2 IMPLEMENTATION 11.2.1 TEST PROGRAM .

Test requirements to determine or to verify the capability of an item to meet Q specified requirements in accordance with engineering / design documents, Safety V Analysis Reports (SAR), technical specifications, procedures or procurement l documents, as appropriate, are accomplished by subjecting the item to a set of I physical, chemical, environmental or operating conditions. Retest following repair, replacement or modification is performed in accordance with the original design requirements or acceptable alternatives and is performed when original test results are invalidated.

CY procedures are written and approved to delineate the methods and responsibilities for controlling, accomplishing and documenting testing during maintenance and modification of the HNP.

Vendors utilized in the maintenance and modification of the HNP are responsible

for implementing measures for the control of tests to ensure that materials, equipment and parts will perform satisfactorily.

Nuclear Materials and Document Management is responsible for the performance, as appropriate, of off-site audits, surveillances, and inspections of selected proof tests when hold points have been identified in Purchase Order / Contracts of I vendors to verify they are complying with their quality assurance program requirements for test control.  ;

f3 QAP 11.0 38 L CYQAP REV: 01

l

/] CY Oversight performs, as appropriate, on-site audits, surveillances, and U' inspections of the vendor activities.

Proof tests, product acceptance tests, retests. and periodic surveillance tests are conducted by qualified personnel in accordance with procedures. Personnel performing tests ensure that calibrated equipment and instrumentation utilized are within the calibration interval specified. Documentation including test procedures and data sheets are maintained in appropriate files.

I1.2.2 TEST PROCEDURE PREPARATION AND TEST PERFORMANCE Testing is accomplished in accordance with test procedures which incorporate or reference the requirements and acceptance criteria in the applicable design and procurement documents. The test procedure or test program documents include the following as a minimum:

a. Instructions for the testing method used;

b. Required test equipment and instrumentation;

c. Test requirements, such as acceptance and rejection criteria; (3

i () d Hold, notification, inspection and data collection points;

e. Test prerequisites, such as: calibrated instrumentation; trained, qualified, and licensed or certified personnel; preparation, condition and completeness of the item to be tested; and/or suitable and controlled environmental conditions;

f. Methods for documenting or recording test data and results; and/or

g. Provisions for data collection and storage.

I1.2.3 TEST EOUIPMENT CY procedures provide the criteria for determining when a test is required and the accuracy requirements of test equipment.

The fol!owing steps are taken in the control of test equipment:

a. Test instrumentation is checked and calibrated in accordance with CY procedures to ensure accuracy; (N

L QAP 11.0 39 CYQAP REV: 01

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b. Plant instrumentation used in testing is calibrated. It is maintained in calibration at regular intervals in accordance with surveillance and/or preventative maintenance procedures; and,

c. Where special instrumentation is required for testing, the requirements  !

are stated in the procedures. Instrument characteristics, including i

accuracy requirements, are equivalent to or better than those specified by the vendor. l 11.2.4 EVALUATION OF TEST RESULTS I I

The documented test results are evaluated against the predetermined acceptance aiteria by an individual or group having appropriate qualifications. The  ;

acceptance status of the test is documented. Deficiencies noted during the l evaluation are documented and dispositioned in accordance with approved I procedures.

1 The evaluation of test results may also be delegated to vendors. When delegated, contracts require the vendor to assure the t!se of qualified personnel, evaluate the i data against predetermined criteria and document the results of the evaluation and i acceptance status of the test.

l O

( ,/ Nuclear Materials and Document Management is responsible for the performance I

_ l of off-site audits, surveillances, and inspections, as appropriate, to verify that l these vendors are effectively complying with their quality assurance program  !

requirements for test control.

CY Oversight performs on-site audits, surveillances, and inspections, a-appropriate, of the activities.

QAP 11.0 40

(~'}

'- CYQAP REV: 01

1 l

QAP 12.0 CONTROL OF MEASURING AND TESTING EQUIPMENT O 12.1 GENERAL REOUIREMENTS i l

The CYQAP provides measures for the control of measuring and testmg eqmpment (M&TE) used as the basis for acceptance in activities affecting quality during inspection, testing and measurement of materials, equipment and parts. Periodic calibration and  !

adjustment of measuring and test equipment is performed and controlled to assure accuracy is maintained within limits necessary to verify that design and operating condition 2 requirements have been met. Documentation is retained such that all items of M&TE are traceable to their calibration records. .

12.2 IMPLEMENTATION i

12.2.1 GENERAL l Procedures delineate the methods and responsibilities for the control, maintenance j and calibration of M&TE including portable and temporarily installed test '

instruments, tools, gages, fixtures, reference and transfer standards, and  ;

nondestructive test equipment. .

l

~

i Docuruntation associated with M&TE is maintained in appropriate files, with l C evenmd incorporation into the NU Nuclear Records Program. When the information for the control, use, and calibration of M&TE is in electronic form, this information is controlled and protected in accordance with procedures.

l The calibration program is implemented in accordance with the requirements defined in CY procedures which describe the measures utilized to maintain M&TE. Functional groups are responsible for implementing these procedures which comply with the requirements contained in specifications and drawings.

The Plant Operations Review Committee (PORC) reviews and approves M&TE administrative procedures related to the MATE calibration program.

Nuclear Mateiials and Document Management or the appropriate M&TE Custodian, as delineated by the Purchase Order, is responsible for verifying that receipt of calibrated equipment is in conformance with the requirements of procurement documents. Nuclear Materials and Document Management and CY Oversight are responsible for the calibrated M&TE used during their inspections, respectively.

QAP 12.0 41 CYQAP REV: 01 9i

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l Department Heads / Supervisors are responsible to ensure that M&TE equipment f~ is calibrated, issued, and controlled in accordance with the requirements of the i C]/ procedures. The " activity" Supervisor shall ensure that the users of the M&TE are properly instructed in the use and control of the M&TE. HNP Departments are responsible for calibrating M&TE within the required interval or removing the M&TE from service until the required calibration can be performed.

CY departments are also responsible for reviewing calibration data associated with M&TE calibration by outside vendors in accordance with the procedures.

CY Oversight performs audits, surveillances, and inspections to verify implementation of the M&TE program.

Vendors utilized in the maintenance and modification of the HNP are responsible for implementing measures for the control of M&TE to ensure they are properly calibrated, adjusted and maintained at specified intervals in order to maintain i accuracy within required limits. )

l Nuclear Materials and Document Management is responsible for the performance of off-site audits, surveillances, and inspec,tions, of the quality assurance programs  !

of vendors to verify that they are effectively complying with their requirements for control of M&TE.

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('" CY Oversight performs on-site audits, surveillances, and inspections, as l appropriate, of vendor activities.

1 12.2.2 CAllBRATION STANDARDS l Measuring and test equipment is calibrated at specified intervals based on the i required accuracy, purpose, degree of usage, stability characteristics, and other l conditions affecting the measurement. Measuring and test equipment shall be permanently marked or tagged with a unique identification number and the date i l calibrated and next calibration date indicated on the M&TE.

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t l CY procedures describe the measures taken to assure that reference and transfer i l standards are traceable to nationally recognized standards and that, where national  ;

j standards do not exist, provisions are established to document the basis for l calibration. 4 l \

(N QAP 12.0 42 O CYQAP REV: 01 l

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Calibration of this equipment should be against standards that have an accuracy of O at least four times the required accuracy of the equipment being calibrated. When this is not possible, the standards shall have an accuracy that assures the equipment being calibrated will be within required tolerance. In addition, the calibrating standards shall have greater accuracy than secondary standards being calibrated. Calibrating standards with the same accuracy may be used if they can be shown to be adequate for the requirements and the basis of acceptance is documented.

12.2.3 "OUT OF TOLERANCE" CONTROL M&TE and reference standards when found out of tolerance are so identified and removed from service. A timely review is conducted to determine the validity of previous inspection or test results gained through use of 6e instrument, and of the acceptability ofitems previously measured or tested.

O O QAP 12.0 CYQAP 43 REV: 01

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QAP 13.0 HANDLING. STORAGE AND SHIPPING

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\ 13.1 CiENERAL REQUIREMENTS Measures are established by the CYQAP using procedures, instructions and procurement documents to ensure proper handling, storage, shipping, cleaning and preservation of material, equipment and parts. These measures are imposed during maintenance and modification activities in order to preclude damage, loss or deterioration of materials, equipment and parts. ,

1 13.2 IMPLEMENTATION l

13.2.1 GENERAL j l

Procedures, instructions and procurement documents define the requirements and i responsibilities for the handling, storage, shipment, cleaning and preservation of material, equipment, and parts required for implementation of established design  !

and specification requirements. I l

Handling, storage, cleaning and preservation requirements of material, equipment i and parts is conducted in accordance with procedures and procurement documents.

O d Vendors utilized in the maintenance and modification to the HNP are responsible for implementing measures for handling, storage, shipping, cleaning and preserving materials, equipment and parts to preclude damage, loss or deterioration.

l Nuclear Materials and Document Management is responsible for off-site audits, surveillances, and inspections, as appropriate, to verify that vendors are effectively implementing and complying with the approved procedures and instructions for handling, storage, shipping, cleaning and preservation of materials, equipment and parts. J CY Oversight performs on-site audits, surveillances, and inspections, as I appropriate, of the activities.

13.2.2 ESTABLISHMENT OF SPECIAL HANDLING. STORAGE. SHIPPING.

CLEANING AND PRESERVATION REOUIREMENTS Special or additional handling, storage, shipping, cleaning and preservation requirements are to be identified and implemented as specified in procurement documents and approved procedures. These established requirements are O QAP 13.0 CYQAP 44 REV: 01 u

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consistent with the regulatory positions of the NRC Regulatory Guides and their I lO

,d endorsed ANSI Standards listed in Appendix C herein, or specifications and/or  ;

i vendor technical manuals, and will be consistent with accepted industiy standards. i i  ;

- CY procedures describe the measures taken for the storage of chemicals, reagents ,

1 (including control of sh'elflife), lubricants, and other consumable materials.

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1 QAP 13.0 45' CYQAP REV: 01

i QAP 14.0 INSPECTION. TEST AND OPERATING STATUS h 14.1 GENERAL REOUIREMENTS The CYQAP provides measures for indication, by the use of marking such as stamps, tags, labels or other suitable means, the status of tests and inspections of material, equipment and parts throughout the maintenance and modification of the HNP to preclude the inadvertent l

bypassing ofinspection and test requirements. These measures provide for the identification of items which have satisfactorily passed required inspections and tests. Measures are also established for indicating the operating status of systems, structures and components to prevent inadvertent operation.

14.2 IMPLEMENTATION l 14.2.1 GENERAL Vendors utilized in the maintenance and modification of the HNP are responsible for implementing approved measures for the identification ofinspection and test status of material, equipment and parts to preclude the bypassing of requirements.

! Nuclear Materials and Document Management is responsible for the performance l

of offsite audits, surveillances, and inspections of vendors, as appropriate, to m verify that they are effectively complying with their requirements for

,(d I

identification ofinspection and test status, in compliance with procedures and l instructions.

Elements of this system require that vendors have a controlled manufacturing and i i test operation, in order to preclude the inadvertent bypassing of process l l inspections or tests, and to provide a positive identification of component status throughout all phases of manufacturing, testing, and inspection by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other j appropriate methods. '

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When Receipt Inspections are performed at Millstone Station or the HNP, Nuclear  !

Materials and Document Management ensures that traceability is maintained for l l acceptable materials, equipment and parts, to indicate conformance to Purchase

! Order / Contract requirements. Material used at CY that requires traceability to be

! maintained is delineated in the appropriate CY procedure.

Nonconforming materials, equipment and parts are identified in accordance with  !

QAP 15.0, " Nonconforming Materials, Parts, Components, or Services" and/or QAP 16.0," Corrective Action."

l O QAP 14.0 CYQAP 46 j REV: 01 l ,i

During tests and inspections of operating systems required to support the storage

,Q of the spent fuel, a status tagging system is implemented, as per approved V procedures and instructions, to prevent inadvertent operations of systems, structures and components.

CY procedures describe the measures taken to control the altering of the sequence of required tests, inspections and other operations. The review and approval for these actions is subject to the same control as taken during the original review and approval of tests, inspections and other operations.

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of the activities.

14.2.2 STATUS IDENTIFICATION AND CONTROL Procedures and instructions describe control'of the application and removal of markings such as stamps, tags, labels, and other suitable means to indicate the status of systems, structures and components to prevent inadvertent operation, and to preclude omission ofinspections, tests or other critical operations. These procedures and instructions delineate the rgquirements, methods and responsibilities for indicating the status of th6 affected items. The complete status of all items under the calibration system is recorded and maintained.

p C Records associated with status identification are maintained in accordance with procedures.

O QAP 14.0 47 O CYQAP REV: 01 l

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QAP 15.0 NONCONFORMING MATERIALS. PARTS. COMPONENTS.

O OR SERVICES U

15.1 GENERAL REOUIREMENTS l

The CYQAP requires that documentation and control of nonconfonning materials, parts. l components, or services utilized in systems, structures and components during maintenance l

and modification of the HNP be performed in accordance with procedures in order to I prevent inadvertent use or installation. These procedures include appropriate requirements for identification, documentation, segregation and disposition of nonconforming items, and notification to affected organizations.

15.2 IMPLEMENTATION 15.2.1 PROGRAM l Procedures define personnel responsibilities and establish various measures for

, identification, documentation, segregation, review and disposition of l

nonconforming item reports. Report mechanisms are available to all NU i personnel. -

j 15.2.2 DOCUMENTATION 4

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\ t U Documentation of nonconforming items requires identification of the items, description of the nonconformance, disposition of the nonconformance, inspection requirements and signature approval of the disposition.

Tagging systems are utilized to physically identify nonconforming items prior to installation. Nuclear Materials and Document Services utilizes tags for received material, parts and components.

15.2.3 EVALUATION AND DISPOSITION Evaluations are performed to determine the impact on system, structures and component operability and to determine the disposition of nonconforming items and services. The evaluation determines whether an item or service is to be used as is, returned to vendor, repaired, or scrapped. An engineering evaluation is performed, if necessary, prior to the resolution of nonconformances. These evaluations assure that the final condition does not adversely affect safety, operation or maintenance of the item or service, or of the component or system.

Reports involving deviation from design bases such as "use as is" or " repair" are forwarded to the appropriate engineering organization for review, and disposition.

Applicable information is accumulated and records are maintained.

' O QAP 15.0 48 V CYQAP REV: 01

The need to release /use nonconforming materials, parts or components shall be based on such considerations as:

a. Impact on plant safety;

b. Safetyofpersonnel;

c. Suitability of material or items in the "as is" condition, i.e., probability of-eventual satisfactory resolution of the nonconforming without repair,-

rework or replacement;

d. Accessibility of material or items after release;

e. Cost of removal and repair or replacement should material or items eventually have to be removed, repaired, or replaced; and

f. Effect on the orderly progress of work, Items repaired are verified by reinspecting,the items as originally inspected or by a documented method which is equivalent to'the original inspection method.

Items repaired rnay require reinspection as defined in procedures.

CY Oversight performs audits and surveillances to verify that dispositions for reports documenting nonconforming conditions are adequate.

QAP 15.0 49 CYQAP REV: 01

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QAP 16.0 CORRECTIVE ACTION w 16.1 DENERAL REOUIREMENTS The CYQAP requires that an effective corrective action program be established for CY and their vendors to ensure that conditions adverse to quality are promptly identified and corrected as soon as practicable and documented in accordance with approved procedures.

These procedures include measures for determining the root cause and corrective action to preclude recurrence for conditions evaluated as significant conditions adverse to quality.

16.2 IMPLEMENTATION 16.2.1 PROGRAM Procedures define personnel responsibilities and establish various measures for i identification, documentation, evaluation / review, disposition and correction of conditions adverse to quality. Reporting mechanisms are available to NU personnel.

16.2.2 CORRECTIVE ACTION AND FOLLOW-UP Procedures describe the measures taken to evaluate if conditions adverse to (s quality exist and to determine the need for immediate corrective action or

' \, disposition. The Executive Vic~e President and Chief Nuclear Officer is responsible for ensuring that the assigned personnel and their vendors working at HNP comply with the corrective action program and for ensuring that corrective action is adequate and properly implemented in a timely manner at the HNP.

CY Oversight performs audits and surveillances to verify that organizations working at the HNP comply with the corrective action program and that corrective action is adequate and properly implemented in a timely manner.

The Executive Vice President and Chief Nuclear Officer has the final authority in the event that agreement on the action to be taken is not reached at the appropriate organization levels within the CY organization 16.2.3 RECURRENCE CONTR( A Procedures provide responsibility and the process for determining appropriate significance based on actual or potential consequences for conditions adverse to quality and requirements for evaluation and corrective action.

QAP 16.0 50

\ CYQAP REV: 01 m

Procedures also establish the responsibilities and measures taken to accomplish these actions.

An analysis of conditions identified as adverse to quality is developed and adverse trends are periodically reported to management by the organization responsible for controlling the problem reporting program. Trends concerning specific vendor performance shall be reported to the affected contractor for resolution, if appropriate.

CY Oversight performs audits and surveillances to verify that the corrective action program is adequate and controlled in accordance with procedures.

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QAP 16.0 51 O' CYQAP REV: 01

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QAP 17.0 QUALITY ASSURANCE RECORDS

(~y 17.1 GENERAL REOUIREMENTS The CYQAP provides for the maintenance, identification, retention and retrieval of records to furnish evidence of activities affecting quality during maintenance and modification of the HNP. The records include but are not limited to:

a. Operating logs and the results of reviews;

b. Inspections;

! c. Tests;

d. Audits;

e. Monitoring of work performance; and,

f. Material analyses.

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The records also include closely related data such as qualifications of personnel, procedures and equipment. Inspection and test records contain as a minimum but are not limited to:

r^T identification ofinspector or data recorder; and, the acceptability and the action taken in V connection with any deficiencies and reportable occurrences noted. Procedures establish requirements concerning record retention such as durr. tion, location and assigned responsibility.

17.2 lh4PLEMENTATION Procedures and instructions establish the responsibilities and requirements for the maintenance, identification, retention and retrievability of records penaining to materials, equipment, parts, processes or operations relating to systems, structures and components which when founded on observations, measurements or tests can be fully verified, and documented by cognizant personnel.

CY procedures define the documentation requirements for inspection and test records, as appropriate.

Vendors utilized in the maintenance and modification of the HNP are responsible to implement measures for identification, maintenance, retention, retrieval and tumover of records to CY personnel which contain objective evidence of quality, as specified in Purchase Order / Contracts.

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QAP 17.0 52 CYQAP REV: 01 0

Nuclear Materials and Document Management is responsible for off-site audits,

'(] surveillances, and inspections, of vendors, as appropriate, to verify they are effectively

'v' complying with their program for quality assurance records.

CY Oversight performs on-site audits, surveillances, and inspections, as appropriate, of these activities.

~

Quality Assurance records are identified, controlled and maintained in appropriate files and are identifiable to specific systems, structures and components at HNP. When identification to a specifi:: system, structure or component is not practical, records are filed by category (e.g. specification, nonconformance reports, audits, etc.).

17.3 RETENTION CY quality assurance records are classified as life records or nonlife records as delineated by NU Nuclear Document Services. Nontife records are those documents that are maintained for a specific period of time other than the lifetime of the in-service nuclear power plant or the particular component or pan. Life records are those documents that are maintained for the lifetime of the in-service nuclear power plant or for the life of the particular component or part. Life records are those,which would be of significant value in I meeting one or more of the following criteria: - I

,q

, a. Demonstrating capability for safe operations; V

b. Maintaining, reworking, repairing, replacing or modifying the item;

c. Determining the cause of an accident or malfunction of an item; or

d. Providing required base line data for in-service inspection.

Records are reviewed and approved by the cognizant qualified personnel and vendors as appropriate, and are transmitted to NU Nuclear Document Services. The responsibility of the NU Nuclear Document Services upon receipt of records, is to maintain and provide controlled retrievability of records affecting the HNP in such a manner as to prevent destruction of records by fire, flood, theft, and environmental conditions, such as temperature or humidity, as delineated in procedures.

f QAP 17.0 53 (V) CYQAP REV: 01 l a

QAP 18.0 AUDITS C) 18.1 GENERAL REOUIREMENTS 1

The CYQAP requires that a comprehensive system of planned and periodic audits shall be carried out to verify compliance'with the CYQAP during the maintenance and modification of the HNP.

Audits are conducted in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited.

Audit results are documented and reviewed by management having responsibility in the area audited and the responsible management takes the necessary action to address any audit findings revealed by the audit.

18.2 IMPLEMENTATION 18.2.1 PROGRAM The audit program requires audits of corporate and HNP quality activities under the oversight of the CY Nuclear Safety Assessment Board. Audits are performed on activities where the requirements of 10 CFR 50 and the HNP Technical Specifications are being implemented.

Audits are regularly scheduled on the basis of the status and safety importance of the activities being performed. Regularly scheduled audits are supplemented by audits for one or more of the following conditions:

a. When significant changes are made in functional areas of the quality i assurance program, such as significant reorganization or procedure l revisions;

b. When it is suspected that the quality of the item is injeopardy due to I deficiencies in the quality assurance program; i

c. When a systematic, independent assessment of program effectiveness is considered necessary; and / or,

d. When necessary to verify. implementation of required corrective action.

Schedules for the audit of CY activities are originated and maintained by CY )

Oversight. Schedules are approved by the Director-Audits and Evaluation.

QAP 18.0 54 l CYQAP REV: 01 a

l Audits are performed as specified in Nuclear Oversight procedures by qualified

, Q personnel, using a pre-established written audit plan prepared by the auditing l V organization. Audits may include evaluation of the work areas, activities, processes, items, and review documents and records to determine the

{

l effectiveness ofimplementation and conformance to the CYQAP.

Approved vendors utilized in the maintenance and modification activities to the l IINP are responsible for developing and implementing a system of planned and periodic audits to verify compliance with the effectiveness of all aspects of their quality assurance programs.

Nuclear Materials and Document Management is responsible for verifying the acceptability of vendor audit programs and for the performance of subsequent off-site audits, as appropriate, to verify compliance with the effectiveness of all aspects of their quality assurance programs. Nuclear Materials and Document Management has contracted this audit function to the Yankee Atomic Electric Company (YAEC).

CY Oversight performs audits /surveillances of on-site vendors, as appropriate, to  ;

verify the effectiveness of appropriate aspects of their quality assurance programs. 1 In addition to the audits, other methods, such as surveillances, and inspections are

,m\ used to ensure that quality activities are in compliance with the CYQAP.

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18.2.2 REPORTING OF AUDIT RESULTS l Audit results are reviewed, approved, and reported in accordance with Nuclear Oversight and Yankee Atomic Electric Company procedures, as applicable. The audit reports are issued to the appropriate management of the area audited to ensure appropriate and/or timely corrective aedon is taken to address any audit  !

findings. In addition, audit data and reports are included as part of the review for l quality trends and assessed in accordance with QAP 16.0," Corrective Action."

18.2.3 REVIEW. ACTION. AND FOLLOW-UP OF AUDIT FINDINGS Audit findings are reviewed and investigated by the management having the responsibility for the area audited. The responsible management is required to:

a. Take the necessary action to addresses any findings identified by the audit;

b. Report the results of such reviews and investigations; l

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c. Take the necessary actions to correct problems reported; and.

d. Report the completion of corrective actions within specified time frames, i Follow-up of audit findings is performed by the auditing organization. as necessary, to verify that appropriate actions have bet en to resolve audit findings. Actions on audit findings which cannot be resolved by affected

' management and the Vice President - Nuclear Oversight are submitted for .

resolution to the President and Chief Executive Officer - NU Nuclear Group. .

I8.2.4 RECORDS / REPORTS OF AUDITS f

i Audit records, reports, and associated documentation pertinent to audits are 4

dispositioned to the appropriate Nuclear Document Services Facility, as specified t

in procedures.

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l QAP 18.0 56 CYQAP REV: 01

l APPENDIX A CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM i

CATEGORY I SYSTEMS. STRUCTURES. AND COMPONENTS l'

The following systems, structures and components of a defiled nuclear power plant, including their foundations and supports, are designated as Category I. The pertinent quality assurance requirements of 10 CFR 50, Appendix B should be applied, as a minimum, to all l quality activities affecting the safety function of these systems, structures, and components as listed below and for those items listed in the CY UFSAR which addresses Section 3.2.1 of NRC Regulatory Guide 1.70.

NOTE i The safety classification of the systems, structures and components listed below may be  !

revised based on engineering evaluations and a revision to the CY UFSAR during the decommissioning preess. Revision of the safety classification in accordance with the CY Design Control process is not considered a reduction in the commitments.to the CYQAP. I i

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(a) Systems or portions of systems that are regt$ir6d fer cooling the spent fuel storage l

pool.  ;

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C) (b) Cooling water and component cooling or portions of these systems including the intake structures, that are required for cooling the spent fuel storage pool.

(c) Systems or portions of systems that are required to supply fuel for emergency equipment.

(d) Systems or portions of a system of a defueled nuclear power plant that are required for:

. Monitoring of systems safety-related functions; and, e Actuation of safety-related functions.

" Required for monitoring," i.e., Those parameters that provide information that is essential to permit the control room operator to take specific manually controlled actions for the direct accomplishment of the specified safety function.

(e) The spent fuel storage pool structure, including the fuel racks.

,n APPENDIX A 57 CYQAP REV: 01 l

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lO lV (f) The control room, including its associated equipment and all equipment needed to maintain the control room with safe habitability limits for personnel and safe environmental limits for vital equipment.

(g) Systems other than radioactive waste management systems not covered by the above which contain or may contain radioactive materials and whose postulated failure would result in conservatively calculated potential offsite doses (using meteorology as prescribed by Regulatory Guides 1.3 and 1.4) which are more than 0.5 rem to the whole body or its equivalent to any part of the body.

l l (h) The Class IE electric systems, including the auxiliary systems for the onsite electric power supplies, that provide the emergency electric power needed for functioning of l systems for the spent fuel storage.

i (i) Those portions of systems, structures or components whose continued function is not required but whose failure will result in a reduction in maintaining the spent fuel in a safe condition or could result in incapacitating injury to occupants of the control room, should be designed and constructed so that the SSE will not cause such failures.

(j) Items and services associated with Radioactive Material Transport Packages as described in 10 CFR 71.

' CONSUMABLES The following specific consumables when utilized in safety related systems shall be included in those portions of the CYQAP, as applicable.

1. Emergency generator diesel fuels

2. Hydraulic snubber fluids

3. Reagents

4. Resins

5. Boric Acid

6. Lubricants l

i i APPENDlX A 58 l

CYQAP REV: 01 d

APPENDIX B f^

CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM OUALIFICATION AND EXPERIENCE REOUIREMENTS VICE PRESIDENT - NUCI EAR OVERSIGHT I The Vice President - Nuclear Oversight shall satisfy the following requirements:

Graduate of a four-year accredited engineering or science college or university, plus fifteen (15) or more years ofindustrial experience including five years in positions ofleadership, such as lead engineer, project engineer, audit team leader, etc. At least two years of this experience should be associated with nuclear Quality Assurance Activities, and at least one year of this experience is in a Quality Assurance Organization. A masters degree in engineering or business management is considered equivalent to two years of experience.

NOTE The education and experience requirements should not be treated as absolute when s - e' training or an outstanding record will provide rea80nable assurance that a person ce perform the required tasks.

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1 APPENDIX B 59 CYQAP l 1 REV: 01  ;

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APPENDIX C CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS NOTE The CYQAP is committed to utilize the guidance obtained from the following regulatory documents and their endorsed standards. Exceptions to these positions are listed in Appendix E, herein.

10 CFR 50, Appendix B- Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

10 CFR 50, Section 50.54, Condition of Licenses. )

10 CFR 50, Section 55, Operator's Licenses and its Appendix A - Requalification Programs for l Licensed Operators of Production and Utilization Facilities. j 1

Regulatory Guide 1.8 R - 5/77 - Personnel Selection and Training - Endorses ANSI N18.1 -

1971. -

Regulatory Guide 1.28 - 2/79 - Quality Assurance Program Requirements (Design and l

Construction) Endorses ANSI N45.2-1977. j Regulatory Guide 1.30 -(Safety Guide 30),8 11 Quality Assurance Requirements for the Installation, Inspection, and Testing ofInstrumentation and Electrical Equipment - Endorses ANSI l N45.2.4-1977 l l

Regulatory Guide 1.33 - 2/78 - Quality Assurance Program Requirements (Operation)- Endorses ANSI N18.7-1976/ANS3.2. i Regulatory Guide 1.37 - Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants,3-16 Endorses ANSI N45.2.1

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1973.

Regulatory Guide 1.38 - Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling ofItems for Water-Cooled Nuclear Power Plants,5/77 - Endorses ANSI N45.2.2 - 1972.

Regulatory Guide 1.39 - Housekeeping Requirements for Water-Cooled Nuclear Power Plants, 9/77 - Endorses ANSI N45.2.3-1973.

APPENDIX C 60 CYQAP REV: 01

Regulatory Guide 1.58 - Qualification of Nuclear Power Plant Inspection. Examination, and

() Testing Personnel, Rev.1,9/80 - Endorses ANSI N45.2.6-1978.

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Regulatory Guide 1.64 - Quality Assurance Requirements for the Design of Nuclear Power Plants.

6/76 - Endorses ANSI N45.2.11-1974.

Regulatory Guide 1.70 "A Guide for the Organization and Content of Safety Analysis Reports" Revision 0, June 30,1966 was utilized for CY, however, certain revised sections of the CY UFSAR are written to the Revision 3 format. No new analyses have been performed which would be required by Revision 3.

Regulatory Guide 1.88 - Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records - 10/76 Endorses ANSI N45.2.9-1974.

Regulatory Guide 1.94 - Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plant -

4/76 - Endorses ANSI N45.2.5 - 1974 and Section 6.11 of ANSI N45.2.5-1978.

Regulatory Guide 1.116 - Quality Assurance Requirements for Installation, Inspection, and Testing Mechanical Equipment and Systems - 5/77 - Endorses ANSI N45.2.8-1975.

Regulatory Guide 1.123 - Quality Assurance Requirements for Control'of Procurement ofItems g] and Services for Nuclear Power Plants - 7/77 - Endorses ANSI N45.2.13-1976.

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Regulatory Guide 1.144 - Auditing of Quality Assurance Programs for Nuclear Power Plants - Rev.

1 - 9/80 Endorses ANSI N45.2.12 - 1977.

Regulatory Guide 1.146 - Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants - 8/80 Endorses ANSI N45.2.23-1978.

Regulatory Guide 1.152 " Criteria for Digital Computers in Safety Systems of Nuclear Power Plants," January 1996 - Endorses IEEE-ANS 7.4.3.2 - 1993.

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APPENDIX C 61 CYQAP REV: 01

APPENDIX D b

V CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM GLOSSARY OF OUALITY ASSURANCE TERMS Accent As Is -(also known as "Use-As Is") A disposition which may be imposed for a nonconformance when it can be established that the discrepancy will result in no adverse conditions and that the item under consideration will continue to meet all engineering functional requirements including performance, maintainability, fit and safety.

Anproved Vendors - Contractors, suppliers, and engineering service organizations who have been approved to provide quality related material, equipment, parts, and services, or computer software to the Nuclear Group under their QA Program.

As Built Documenta - Documents which accurately describe the condition actually achieved in a system, structure, or component. These documents include: material certification and test data; reports ofinspections, examinations, and test results; drawing, specifications, procedures, and instructions; and records of nonconformance and their resolution.

Audit - A formal, documented activity performed in accord,ance with written checklists or procedures to verify by evaluation of objective evidence that a quality assurance program has been developed, documented, and implemented in accordance with applicable requirements.

Augmented Ouality - Nonsafety related items for which a design basis or regulatory commitment has been made. The augmented quality items are included within the scope of CY Quality Assurance Program. These items are the Fire Protection Quality Assurance (FPQA) and RWQA Radwaste Quality Assurance (RWQA) programs.

Ca!ibration - The process by which measuring and test equipment are checked against standards of known higher accuracy and adjusted as necessary to ensure their compliance with designated specifications.

Categorv i - Designation given to systems, structures, and components of the HNP that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

Category I Svoemt Structures. and Comoonents - Defined in the CY UFSAR and functionally described in Appendix A., herein.

Cleaning - Those actions performed to maintain an ite: accordance with cleanliness requirements.

APPENDlX D 62 CYQAP O' REV: 01 l

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l Commercial Grade item (CGI)- A commercial grade item per 10CFR21 is a structure, system, or l

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V component, or part thereof that atTects its safety function, that was not designed and manufactured as a baue componen:. Commercial grade items do not include items where the design and manufacturing process require in-process inspections and verifications to ensure that defects or failures to comply are identified and corrected (i.e., one or more critical characteristics of the item cannot be verified).

Commercial Grade Survev - Activities conducted by the purchaser to ascertain and verify that a supplier, or manufacturer of commercial grade items, controls the technical and quality characteristics determined to be critical for satisfactory performance of specifically designated commercial grade items, as a method to accept those items for safety-related use. j Condition Adverse to Ouality - Failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances.

1 Connecticut Yankee Ouality Assurance Program (CYOAP)- Consists of the CYQAP, Nuclear Oversight Department Procedures and other CY Group / Division / Department / Branch /Section quality procedures.

Contractor - Any organization under contract for furnishing items or services. It includes the l terms Vendor, Supplier, Subcontractor, Fabricator and subti'er levels of these where appropriate.

The Nuclear Steam Supply System (NSSS) Supplier is included in this category.

O b Corrective Action - Action taken to correct identified conditions adverse to quality. '

1 Decommission - means to remove (as a facility) safely from service and reduce residual radioactivity to a level that permits release of the property for unrestricted use and termination of license.(10 CFR 50.2)

Deficiencies - Departures from specified requirements.

Denartment - The use of the word department, throughout the CYQAP, can refer to any portion of the CY organization or support organizations from NU Nuclear (i.e., Group, Division, Department, Branch, Section, or Unit as applicable).

Design - Technical and management processes which lead to and include the issuance of design output documents such as drawings, specifications, and other documents defining technical requirements of systems, structures, and components.

Design Changes - Changes in drawings and specifications that define the design of systems, structures, and components of nuclear plants.

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! Design Documents - The drawing, calculation, specification, or other document (s) that define the Technical requirements of systems, structures, or components.

Handling - An act of physically moving an item by hand or by mechanical machinery, but not including transport modes.

HNP- Haddam Neck Plant is used throughout this document to define the Connecticut Yankee plant site.

Identification - A means by which material, equipment and parts can be traced to their associated documentation through the use of heat numbers, lot numbers, part numbers, serial numbers, or other appropriate means.

11em - Any level of unit assembly, including structures, systems, subsystems, subassembly, component, part or material.

Insoection - A phase of quality control which, by means of examination, observation, or measurement, determines the conformance of material, supplies, components, parts, appurtenances, systems, processes, structures, or services to predetermine quality' requirements.

Insoection Status - Identification of material, equipment, and parts that have completed inspection, either acceptable or unacceptable.

Maintenance and Modifications - Refers to the required functions for design, constmetion, testing, j maintenance, operation, and modification of facilities at the HNP during de. commissioning i activities.

Material Reauest - The computerized format used for identifying material and services to be procured using the Materials Information Management System (MIMS)

Measuring and Test Eauipment - Those instruments, gages, tools, fixtures, reference and transfer standards, nondestructive test equipment, and measuring devices used during inspection and testing to determine that the measuring and test parameters comply with appropriate requirements l in specifications and drawings. I Nonconformance - A deficiency in characteristic documentation or procedure which renders the quality of an item unacceptable or indeterminate.

Northeast Utilities (Nin - A public utility holding company which owns Northeast Utilities Service Company and The Northeast Nuclear Energy Company and through its operating subsidiaries has a controlling interest in The Connecticut Yankee Atomic Power Company.

APPENDIX D 64 CYQAP REV: 01 a

Nonheast Utilities Service Comnany (NUSCO)- A wholly owned subsidiary of Northeast Utilities that provides management, quality assurance, and various support functions for the V Northeast Utilities nuclear power plants including the liNP.

Nuclear Document Services - The organization responsible for establishing the Corporate Nuclear Plant Records Program which is implemented at each Nuclear Document Services Facility.

Nuclear Grade - The procurement classification applied to all materials and services intended for

, items listed as Cat. I in the MEPL. These may require validating documentation such as Certificate of Material Test Report, Certificate of Conformance, Certificate of Compliance, Personnel Qualifications, etc., as specified by codes or standards, and have been designed / qualified for a nuclear application. Nuclear Grade items are manufactured / qualified under a 10 CFR 50, Appendix B program, with the vendor responsible for 10 CFR 50, Part 21.

The vendor should be approved and listed in the Approved Vendor List.

Nuclear Document Services Facilities (NDSF1 - A facility which has been established for the purpose of handling HNP records in accordance with the Nuclear Records Program.

NUSCO Ouality Assurance Vendor List - A list identifying the approval status of'the quality assurance programs of vendors; commonly referred to as the Approved Vendors List (formally entitled the Approved Suppliers List) -

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Obiective Evidence - Any statement of fact, information, or record, either quantitative or qualitative, pertaining to the quality of an item or service based on observation, measurements, or tests which can be verified.

Preservation - Those actions performed to maintain an item in its original and usable condition.

Procedures and Instructions - Documents that specify how an Octivity is to be performed. They may include methods to be employed; material, equipment, or parts to be used; and a sequence of operations.

Procurement Documents - Purchase requisitions / material requests, purchase orders, contracts, drawings, specifications or instmetions used to define requirements for purchase.

Product Acceptance Test - Activities conducted as part of the receiving or source inspection process to verify acceptability of one or more critical characteristics of the item being inspected.

Project Engineer - An NU or contract employee assigned the responsibility to coordinate the engineering activities addressed in CYQAP.

APPENDIX D 65 CYQAP

[V REV: 01 9

Purchased Material. Eauioment. and Pans List (MEPIA - Items procured for installation in nuclear 73 power generating facilities systems, structures, and components, and items procured as spare Cl MEPL parts for potential installation in those systems, structures, and components.

Purchase Order /Contrac1 - The document which provides the contractual basis for vendor material and services provided in accordance with CYQAP requirements.

Purchased Service - Services provided by a vendor or consultant on a QA requisition when activities are performed under a quality assurance program other than the CYQAP.

Quality Assurance Records - Any record pertaining to the quality of material, equipment, parts, processes, or operations relating to systems, structures and components which are founded on observations, measurements, or tests which can be fully checked or verified. Such statements may be recorded on a written or preprinted document or tag. The statements are authorized with a signature or stamp identifiable to the person making the statement of fact.

Ouality Activities - Activities governed by this CYQAP are those that affect safety-related functions of structures, systems, and components; these activities include designing, analyzing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing,' inspecting, testing, operating, maintaining, repairing, and modifying., Quality Activities also include activities associated with computer software used in implementing the CYQAP and Augmented Quality items as defined herein.

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() Ouality Procedures - The Nuclear Oversight Department procedures and other department procedures which implement the requirements of the CYQAP that are reviewed by Nuclear Oversight or CY Oversight.

Repair - A disposition applied to nonconforming material, equipment, and parts that are unsuitable for their intended purpose which are modified by the use of additional operations and/

or processes so that they are suitable for their intended purpose but may not meet all specified requirements.

Retest - A test conducted prior to operation following installation inspections of work associated with maintenance and refueling to verify that systems, structures, and components will function satisfactorily when in operation. A retest may also be performed when original test results are i

invalidated.

Return to Vendor - A disposition applied to nonconforming material, equipment, and parts that are unsuitable for their intended purpose but which are feasible to repair or rework at a vendor's facility.

APPENDIX D 66 O CYQAP b REV: 01 0

l Safety Related Svstems. Structures. and Comoonents - Systems, Structures, and components IOV required to mitigate the consequences of postulated accidents.

Snecial Processes - Processes for which the desired level of quality can only be assured through the use of additional process controls, and where control through direct inspection alone is inadequate, impossible, or disadvantageous. These processes are performed under controlled conditions in accordance with special requirements utilizing qualified procedures, equipment, and personnel. These special processes may include, but are not limited to welding, brazing, soldering, cleaning, heat treating, and nondestructive testing.

Storage - The act of holding items at the HNP or in an area other than its permanent location in the plant.

Surveillance - A documented record of the observation of work operations performed at CY or a vendor's site to assure compliance with applicable codes, standards, specifications, procedures, drawings, and procurement documents. Surveillances are not performed to a preplanned checklist.

Test and Ooerating Status - Identification of material, equipment, and parts that are ready for test l or operation, or an existing stage of a test operation. i

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Testing - The determination or verification of the capability'of an item to meet specified 1 requirements by subjecting the item to a set of physical, chemical, environmental, or operating  ;

conditions.

Vendor - Organizations that provide material, equipment, parts, and services, or computer sofhvare.

Yankee Atomic Electric Comoany (YAEC1 - is an incorporated company in Massachusetts sponsored by New England utilities that provides ongoing support to nine commercial nuclear plants in New England for design, construction, engineering, quality assurance, licensing operation, and decommissioning services. i i

l APPENDIX D 67 CYQAP i REV: 01

l APPENDIX E O -

I CONNECTICUT YANKEE OUALITY ASSURANCE PROGRAM PROGRAM EXCEPTIONS

1. ANSI N45.2.9, states in part, " structure, doors, frames, and hardware should be Class A fire-related with a recommended four-hour minimum rating." The three record storage I vaults at NNECO have a two-hour rating and the record vault door and hardware at CYAPCO has a three hour rating.  :

Both NNECO and CYAPCO's vaults are used for storage of documentation that is

, unsuitable for filming or awaiting filming.

A records organization exists along with written procedures addressing the control of l quality assurance records. l i

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2. ANSI N18.7-1976. paragraph 4.3.2.3 " Quorum" states in part: "A quorum for formal meetings of the (Independent Review) Committee held under the provisions of 4.3.2.2 shall consist of not less than a majority of the principals, or duly appointed altemates.. "

A quorum of the Nuclear Safety Assessment Board shall consist of the Chairman or Vice Chairman and at least enough members to constitutg a majority of the assigned members.

No more than a minority of the quorum has line respo'nsibility for

operation / decommissioning of the HNP. No more than two altemates have voting status at j A any meeting in fulfillment of the quorum requirements.

a g 3. ANSI N45.2.9-1974, paragraph 1.4, definition of" Quality Assurance Records" states in part: "For the purposes of this standard, a document is considered a quality assurance record

, when the document has been completed."

Northeast Utilities has developed the following attemative def'mition to provide guidance during the interim period from the. time a document is completed until it is transmitted to l the Nuclear Document Services Facility: l "A record is considered a working document until it is transmitted to the appropriate Nuclear Document Services Facility (NDSF) at which time it is designated as a Quality  ;

Assurance Record. The following maximum time limits are established for the transmittal of working documents to the NDSF:

4 Ooerations Documents - Documentation generated during Plant Operations may be maintained, as needed, by operating plant departments, for up to one year.

New Construction or Betterment Documents - Documents which evolve during new  !

, construction or betterment projects shall be transmitted to NDSF within 90 days of a

completion of a new construction project or tumover of a betterment project or plant  ;

operations.

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Procurement Documents - Inspection / Surveillance / Audit Reports generated during

, vendor oversight activities which are used to maintain vendor status for current and s future procurements may be maintained, as needed, by the Nuclear Oversight Department for up to three years.

All Other Working Documents - All other working documents shall be transmitted to NDSF within 6 months of their receipt or completion."

The requirements of ANSI N45.2.9-1974 do not apply to these " working documents" based on paragraph 1.1 of the ANSI standard which states:

"It (ANSI N45.2.9) is not intended to cover the preparation of the records nor to include j working documents not yet designated as Quality Assurance Records."

4. Regulatorv Guide 1.64 - 6/76, the Regulatory position states,in part, "It should not be construed that such verification constitutes the required independent design verification."

Northeast Utilities has developed the following alternative to allow for adequate independent design verification:

This review may be performed by the originator's Supervisor, only if the Supervisor:

Did not specify a singular design approach; Did not establish the design inputs or did not rule out certain design considerations; Is the only individual in the organization competent to perform the review.

Where the Supervisor performs the design review, the next level of management shall fulfill the Supervisor's responsibilities.

5. ANSI N45.2.13 - 1976, paragraph 10.3.4, states in part, " Post-Installation Test requirements and acceptance documentation (should) shall be mutually established by the purchaser and supplier." Involvement by the supplier in establishing Post-Installation Test requirements and acceptance documentation is requested only when it is deemed necessary and proper by the responsible engineering organization.

Northeast Utilities no longer has any nuclear plants under construction. As a result, most procurements are made for spare parts from suppliers who are not the original equipment manufacturer. In these cases, the supplier may have little or no understanding or knowledge of either the operation of the system the component is to be installed in, or applicable Post-Installation Test requirements and acceptance documentation. As such Northeast Utilities assumes responsibility for establishing Post Installation Test requirements and acceptance i documentation.

6. ANSI N45.2.2-1972, paragraph 1.2, states in part that, "The requirements of this standard  ;

apply to the work of an individual or organization that participates in the packaging, shipping, receiving, storage, and handling ofitems to be incorporated into nuclear power ]

plants." j O' APPENDIX E 69 CYQAP REV: 01 a

Since a portion of Northeast Utilities procurement activities involve commercial suppliers f]

V which do not fully comply with the requirements of ANSI N45.2.2, Northeast Utilities Nuclear Materials and Document Management organization verifies through source inspections, receipt inspection, and/or survey activities that the quality of the materials, items, components or equipment is preserved by those suppliers to the extent that packaging, shipping, ;torage and handling methods are employed which are commensurate with the nature of the product.

7. Regulatory Guide 1.33 - 2/78. regarding audits, states in part:

(a) "The results of actions taken to correct deficiencies...at least once per 6 months."

(b) " .. technical specifications and applicable license conditions - at least once per 12 months."

(c) "The performance, training, and qualifications of the facility staff- at least once per 12 months."

NU has developed an altemative which modifies these audit frequencies to at least once per 24 months. This altemative has previously been accepted by the NRC via license amendments 181 for CY.

This altemative also takes exception to (c) above. It deletes the requirement for Nuclear Oversight to audit the performance of the facility staff. This function will be performed by the Nuclear Safety Assessment Board.

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