ML20236H147
| ML20236H147 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/25/1987 |
| From: | Howell S, Mccormick W, Reynolds J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20236H129 | List: |
| References | |
| CPC-2A, NUDOCS 8711030464 | |
| Download: ML20236H147 (86) | |
Text
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@ Company CPC H QUAI.lTY ASSURANCE PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS-m i !!!!!
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, Consumers P0Wer wmi.m 1. ucco, mica. s,.
Chairman & CEO POWERING A1ENWnAN'S PROGRESS General Offices: 212 West Mehegan Avenue, Jackson. MI 49201 e (517) 7881600
SUBJECT:
STATEMENT OF RESPONSIBILITY AND AUTHORITY REGARDING THE CONSUMERS POWER COMPANY QUALITY ASSURANCE PROGRAM FOR OPERATIONAL NUCLEAR POWER PLANTS As Chief Executive Officer of Consumers Power Company, I have the ultimate management authority for the establishment of Corporate Quality Assurance Policy. This Policy is provided in the Consumers Power Company Quality Assurance Program Description for Nuclear Power Plants. The Quality Assurance Program Description complies with the quality assurance requirements contained in Appendix B of 10CFR50, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and responds to the additional guidance-con-tained in ANSI N18.7, and to the ANSI N45.2 Series of Standards and corre-sponding Regulatory Guides within the context of applicability imposed by N18.7. The Quality Assurance Program Description for Operational Nuclear Power Plants outlines the actions that are implemented during the operational phase including fueling, testing, operation, refuel $ng, procurement, mainte-nance, repair, and modification design and construction of the safety-related portions of the nuclear power plants. I have delegated the authority for the establishment and maintenance of the Quality Assurance Program Description to the Executive Vice President, Energy Supply for operational phase activities and plant modifications, and in turn to the Executive Director, Nuclear Assurance. The Executive Director, Nuclear Assurance is also authorized to verify the effective implementation of the Quality Assurance Program Description. The Quality Assurance Program Description contains mandatory requirements which must be implemented and enforced by all responsible organizations and individuals. y, k. _/ - L'
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4. A C4G ENERGYCOMPANY
( CPC-2A 11 l l QUALITY ASSURANCE PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS REVISIOE 6 APPROVED BY: O.~- M.- Execiqpfe Vj.ce President, Energy Supply J W Reynolds ul2R87 Date 6 Executi M ice President, Energy Distribution 0kV Date Stephen H Howell
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Vice President, Nuclear Operdtions bfAW f7 Date F W Buckman JLO /JJ Vi~ce Pre ~siifElit, Energy' Supply Services YJYODate R B DeWitt 1 l /
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Vide' President, Distribution Operations
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Data R C Lincoln hdf0
,MTic W resident, Fuel Supply R J Odlevak d-Jf-77 Date '
Vite Prisident, General Services b~c~03~~$0 ' Dat.e R A Wells I ,
/ 4 V -6 7 Vice' President, Fossil & Hydro Operations Date G L Heins
Page 111 Rev 6 Date: 06/15/87 QUALITY ASSURANCE PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR POWER PLANTS CONTENTS Section Title Page Statement of Responsibility and Authority. . . . . . . 1 Approval Page. .. . .. . . . . . . . . . . . . ... 11 Contents . .. .. . . . . . . . . . . . . . . . . .. iii 1.0 Organization . .. . . . . . . . . . . . . . . . . . . 1 2.0 Quality Assurance Program. . . . . . . . . . . . ... 17 3.0 Design Control . . . . .. . . . . . . . . . . . .. . 23 4.0 Procurement Document Control . . . . . .. . . . ... 27 5.0 Instructions, Procedures and Drawings. . . . . . ... 29 6.0 Document Control . .. . . . . . . . . . . . . . . . . . '33 7.0 Control of Purchased Material, Equipment and Services . . . . . . . . . . . . . . . . . . ... 35 8.0 Identification and Control of Items. . . . . . . . . . 39 9.0 Control of Special Processes . . . . . . . . . . ... 41' 10.0 Inspection . . . . . . . . . . . . . . . . . . . . .. 43 11.0 Test Control . . . . . . . . . . . . . . . . . . . . . 45 12.0 Control of Measuring and Test Equipment. . . . . . .. 47 13.0 Handling, Storage and Shipping . . . . . . . . . ... 49 14.0 Inspection, Test and Operating Status. . . . . . ... 51 15.0 Nonconforming Materials, Parts or Components . . ... 53 16.0 Corrective Action . . . . . . . . . . . .. . . ... 55 17.0 Quality Assurance Records. . . . . . . . . . . . . . . . 57 18.0 Audits . .. . . . . . . . . . . . . . . . . . . . . . 59 PD1081-0535A-QA04-QA06
Page iv Rev 6 Date: 06/15/87 Section Title Page Appendix A Regulatory Guide and ANSI Standard Commitments . . . '
. . . . . . . . . .. .. 61 (2pp)-
Part 2 CP Co Exceptions to Operating Phase Standards and Regulatory Guides. ... . .. . . . . . . . . . .. 63 (21 pp) FIGURES 1 Consumers Power Company Corporat; Organization . .... . . . . . . . . ... . . . . . 11 2 Energy Supply Organization . . . . . . . . . . . . . 12 3 Nuclear Operations Department Organization . . . . . 13 4 Nuclear Assurance Organization . . . . . . . . . . . 14 5 Energy Distribution and General Services Organizations . . . . . . . . . . . . . . . 15 6 Energy Supply Services Organization . . . . . . . . 16 PD1081-0535A-QA04-QA06
'Page 1 Rev 6 Date: 06/15/87 1.0 ORGANIZATION 1.1 POLICY Consumers Power Company (CP Co) is responsible for. establishing and implementing the Quality Assurance Program, as described herein, for the operational phase of its nuclear power plants. Although authority for development and execution of some parts of the program is delegat-ed to others, such as contractors and consultants, CP Co retains overall responsibility.
This section of the Quality Assurance Program Description (QAPD) identifies the CP Co organizations responsible for activities affect-ing the quality of safety-related nuclear power plant structures, systems and components and describes the authority and duties assigned to them. It addresses responsibilities for both attaining quality objectives:and for the assurance functions of establishing and main-taining the' Quality Assurance Program and verifying that activities affecting the quality of safety-related items are performed in accor-dance with QA program requirements. Quality assurance functions (as defined above) are performed by personnel within formally designated Quality Assurance (QA) organiza-tional units. Specific areas of responsibility and authority are delegated to these units by the individual assigned overall responsi-~ bility and authority for the QA Program. The reporting level of the Nuclear Assurance organization affords sufficient authority and organizational freedom, including sufficient independence from the cost and schedule impacts of QA organization actions, to enable people in that organization to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. QA/QC functions at the nuclear plants are performed by onsite quality assurance organizations that report to the Executive Director, Nuclear Assurance. 1.2 IMPLEMENTATION 1.2.1 Source of Authority The President and Chief Executive Officer (see Figure 1 of Company Organization Charts) of CP Co is responsible for safe operation of CP Co nuclear power plants. Authority and responsibility for estab-lishing and implementing the QA Program for plant operations, mainte-nance and modifications is delegated through the Executive Vice President, Energy Supply to the Vice President, Nuclear Operations (see Figure 2). This delegation is formalized in a STATEMENT OF-RESPONSIBILITY AND AUTHORITY signed by the President and Chief Execu-tive Officer. Other quality-related functions are provided by other organizations as described herein. PD1081-0535A-QA06
l Page 2 Rev 6 Date: 06/15/87 1.2.2 Responsibility for Attaining Quality Objectives in the Nuclear Operations Organization The Vice President, Nuclear Operations is' responsible to the' Executive Vice. President, Energy Supply for operation and maintenance of CP Co nuclear power plants. Directors and Managers who report;to him are-responsible for directing the performance of; activities that affect safe plant operation and/or safety-related functions of structures,. systems and components of the operating nuclear power' plants in-accordance with QA Program requirements. l a. The Plant General Manager / Plant Superintendent (see Figure 3) are 1-responsible to the Vice President, Nuclear Operations for opera-tion and maintenance of the nuclear power plants in such a manner-as to achieve compliance with Plant licenses, applicable reguJa-tions and the QA Program. - Each Plant Genera 1' Manager or Plant Superintendent delegates to. appropriate managers and staff person - nel in his organization responsibility for carrying out applicable controls required by the-Quality Assurance Program. QA Program activities performed on the' authority of the Plant General Manager. or Superintendent include: Qualification of plant operating and maintenance personnel. . Control of preparation, review and approval of Q-List updates. Control of preparation, review and approval of plant procedures and instructions. Procurement planning for the plant including preparation of and-obtaining the required reviews and approval of purchase requests for spares, replacement items and consumables; and materials, items.and services for minor modifications; and submittal of-purchase request packages to Purchasing for procurement actions. Project responsibility for minor modifications including design, procurement, construction and testing activities, whether per-formed by CP Co or by outside contractors. Authorizing use of secondary calibration standards whose accuracy is equal to that of equipment being calibrated, and assuring that such use cannot result in operation outside Technical Specifica-tions limits. Maintaining Echelon III calibration facilities for Portable and Laboratory Measuring and Test Equipment (PL-M&TE) and Health Physics PL-M&TE (HPPL-M&TE). Calibration / maintenance of installed plant instrumentation. Controlling a calibration recall system. l Maintaining a Master List for plant-owned PL-M&TE. PDlu81-0535A-QA06
Page 3 Rev 6 Date: 06/15/87 l
-Operating om.slte Document Control' Centers. ,
Onsite evaluation of corrective action documents,' including initial determination of' deportability to the NRC. Providing for storage and protection of purchased materials and items and items awaiting disposition implementation after removal from service, assuring preservation of identification. Implementing security, fire protection,' health physics and emer-gency plans. Performing start-up and operational testing, such as precritical and criticality tests, low-power, power ascension and plant tests, and surveillance testing.. Maintaining equipment status control. Maintaining required controls over chemical standards and reagents.
' Conducting the inservice inspection program in accordance with technical specifications and State of Michigan rules.
Conducting a water chemistry program in accordance with technical specifications. Performing reactor engineering functions, such as fuel calcula-cions and specification, fuel movement calculations, reactor thermal profile studies, etc.
- b. The Nuclear Safety Board, chaired by the Executive Director, Nuclear Assurance Department (see Figure 3), the' Director,: Nuclear Safety, or a duly appointed alternate, is responsible for perfor-mance of the offsite safety review functions for the nuclear power plants as described in plant technical specifications,
- c. The Director, Nuclear Licensing (see Figure 3) is responsible for:
Accomplishing plant licensing activities including maintaining licensing documents up-to-date, interfacing with the NRC, accom-p11shing and/or tracking licensing commitments and coordinating internal action on NRC bulletins, generic letters, etc. Providing necessary corrective action processing and status reporting for assigned corrective action documenta, including offsite determination of NRC deportability,
- d. The Emergency Planning Administrator (see Figure 3) is responsible for coordinating Corporate Emergency Planning.
PD1081-0535A-QA06
Page 4 Rev 6 Date: 06/15/87
- e. The Executive Engineer, Nuclear Operations Department,-(see Figure
- 3) is responsible for the biennial assessment of QA' Program effectiveness.
- f. The Director, NLclear Training, is responsible for establishing,. q Laplementing and documenting the training of operations and technical support personnel, including QA Program indoctrination ,
and training. 1.2.3 Responsibility for Attaining Quality Objectives in the Energy Supply Services Organization The Vice President, Energy Supply Services (see Figure 6) is responsi-- ble to the Executive Vice President, Energy Supply for standards for calibration of M&TE, operating the personnel' dosimetry laboratory, training and major modifications to CP Ce nuclear power plants. Directors and Managers reporting to him are responsible for directing the performance of activities in accordance with QA Program requirements.
- a. The Executive Manager, Operating and Technical Services, (0&TS) is responsible, through Managers and Directors reporting to him, for:
Maintaining / testing electrical protective devices. Performing design verification testing associated with electrical protective devices, except when such testing is procured from approved outside contractors. , Maintaining the Company's Echelon II calibration facility for calibrating reference and secondary standards and general usage portable and laboratory measuring and test equipment. Controlling the calibration recall system for Portable and Labora-tory M&TE owned by 0&TS, and other departments, as requested. Maintaining a Master PL-M&TE List for O&TS PL-M&TE and for other departments, as requested. Maintaining a Company PL-M&TE Inventory List. Providing chemistry support to Nuclear Operations, as requested. Documenting justification for, and authorizing use of, reference calibration standards having an accuracy less than four times that of secondary standards being calibrated. Preparing and obtaining the required reviews and approvalsHof purchase requests for services, equipment and consumables, and submitting such requests to Purchasing for procurement action. PD1081-0535A-QA06
Page 5'
'Rev 6
-Date: 06/15/87 l
Operating the dosimetry laboratory-(including preparation and maintenance of occupational radiation and exposure records). Condacting performance tests.on materials, equipment _and systems. Performing nondestructive examination, and controlling / maintaining NDE equipment. Providing qualified NDE procedures and equipment and NDE personnel. Providing chemical and metallurgical analytical services. Providing necessary corrective action processing and status reporting for assigned corrective action documents.
- b. The Executive Manager, Projects, Engineering and Construction (PE&C) is responsible, through Managers and Directors reporting to him for:
Performing the engineering, construction, preoperational testing and overall project management of generating plant major modifica-tion projects. This includes functioning, as appropriate, as either the lead design organization when such projects are engi-neered in-house or as the Company's design reviewer when those projects are done by outside engineering organizations. Providing necessary corrective action processing and status reporting for assigned corrective action documents. Preparing and obtaining required reviews and approval of contracts and providing approved procurement packages to Purchasing for action, as assigned. Providing, as requested, technical support to Nuclear Operations in the areas of metallurgy, electrical, mechanical and civil-structural engineering.
- c. The Manager, Field Maintenance Services provides Field Maintenance Services for major modifications and plant outages.
- d. The Director, Technical Services provides electrical equipment and turbine-generator expertise.
- e. The Director, Planning, Training and Administration, is responsi- l ble, through the Managers and Directors reporting to him, for:
Operating the Skill Centers, and developing and qualifying special process procedures and qualifying personnel and equipment for welding and heat treating. PD1081-0535A-QA06
.f.
Page 6 l Rev 6 Date: 06/15/87: Providing necessary corrective action processing and status reporting for assigned corrective action documents. 1.2.4 Responsibility for Attaining Quality Objectives Outside Nuclear Operations and Energy Supply Services Certain functions that constitute part of the Nuclear Operations-QA Program are performed by CP Co organizational units outside the Nuclear Operations Department or Energy Supply Services, as follows: l a. The Manager, Information and Operations Management (see Figure 5) is responsible through the'Vice President, General Services.co the Executive Vice President, Energy Distribution for developing and maintaining the Fire Protection Plans.
- b. The Manager, Information and Operations Management, (see Figure 5) is also responsible for microfilming of specified QA records and plant engineering / design documents.
- c. The Manager, Purchasing and Materials Management (see Figure 5).is responsible through the Vice President, General Services to the Executive Vice President, Energy Distribution for initiating procurement action based on approved purchase requests received f rom organizations performing or supporting plant operation, maintenance or modification.
- d. The Director, Nuclear Fuel Supply (see Figure 2) is responsible through the Vice President, Gas Transmission / Fuel Supply to the Executive Vice President, Energy Supply for the procurement of nuclear fuel and associated services.
- e. The Director, Management and Budget (see Figure 2) is responsible through the Executive Vice President, Energy Supply for maintain-ing the Records Management System including required retention, protection and retrievability, operating the General Office (offsite) Document Control Center and for maintaining the Uniform File Index. This includes collecting, storing, maintaining, distributing and controlling plant engineering / design documents through the Engineering Records Center.
f. The Manager, Engineering and Construction Department (see' Figure
- 5) is responsible through the Vice President, Distribution Opera-tions to the Executive Vice President, Energy Distribution for determining settings for electrical protective systems and relay control systems, and for design, review and recommending changes to electrical protective schemes and associated settings.
PD1081-0535A-QA06
Page 7 Rev 6-Date: 06/15/87
- g. The Executive Engineer - System Dynamics and. Plant Auxiliaries is responsible through the Director - Power Resources cud System Planning and the Vice President, Fossil and Hydro Operations, to the Executive Vice President - Energy Supply for analytical studies to appraise the adequacy of electrical supply to safety-related equipment in nuclear power plants from the principle power supply facilities of=the transmission network and onsite power supply.
1.2.5 Responsibility for Nuclear Assurance Functions The Executive Director, Nuclear Assurance Department (see Figure 4), is responsible to the Vice President, Nuclear Operations for the definition, direction and effectiveness measurement of the Nuclear Operations QA Program, including modifications, and for verifying that activities affecting the quality of safety-related items are performed in accordance with QA Program requirements. The Executive Director's authority includes the following major functions for work under his jurisdiction: Establishing the QA Program for operating nuclear plants. Continuing evaluation of QA Program status and adequacy, reporting his conclusions to CP Co Management. Assuring that verification activities are accomplished by personnel not directly responsible for the work being performed. Stopping unsatisfactory work to control further processing, delivery or installation of nonconforming materials or items. Recommending that a plant be shut down if such action appears neces-sary (the order is issued by the Vice President, Nuclear Operations or the Plant General Manager / Superintendent). Reviewing and concurring with organizational administrative procedures and procedure changes for compliance with QA Program requirements. Assuring routine attendance and participation by NAD staff at meetings of the Plant Review Committee. Assuring that nonconforming items are properly identified, segregated and dispositioned. The Executive Director's job description includes the following prerequisites: Previous management experience; knowledge of quality assurance regulations, policies, practices and standards; and experi-ence working in quality assurance or related activities in reactor design, construction or operations, or in a similar high technology. industry. The quality management office, consisting of the Executive-PD1081-0535A-QA06
Page 8 Rev 6 Date: 06/15/87 Director and his immediate staff, meet or exceed the qualifications established in Paragraph 4.4.5 of ANSI /ANS 3.1, 12/79 Draft as endorsed by Regulatory Guide 1.8. The Executive Director, Nuclear Assurance has no other duties or responsibilities unrelated to QA that would prevent his full attention to QA matters, is sufficiently free from schedule and cost pressures to give appropriate weight to quality considerations in his decisions and recommendations, and has direct access-to high enough levels of Management to obtain' resolution of. quality problems. . As Executive Director, he delegates authority and holds his_ organization responsi-ble for accomplishing QA functions for operational nuclear power plants, as follows:
- a. The Palisades Plant QA Director and the Big Rock Point Plant QA Superintendent are required to posse a the educational and experi-ence qualifications specified in Regulatory Guide 1.8. Each is responsible to the Executive Director - Nuclear Assurance for-the fol2owing operating phase activities for work under his jurisdiction:
Plant site quality assurance surveillance of safety-related activities, including operations, maintenance, modifications, procurement, testing, etc. Review of and concurrence with plant administrative procedures for compliance with Nuclear Operations QA Program requirements. Verification of onsite corrective action implementation and the effectiveness of corrective action for significant safety-related problems, including, for modifications, that nonconformances are incorporated into the appropriate corrective system. Review of and concurrence with quality requirements of procurement request packages for plant site-originated procurement. Plant onsite QA engineering associated wit!' t; modification design, procurement, construction and testing, including verification that quality-related test prerequisites have been accomplished, identi-fication and participation in resolution of installation inspec-tion and test problems and nonconformances, and maintenance and reporting of status of hardware and test quality and corrective-action. Vendor surveys for local. procurement, source surveillance / inspection at supplier facilities, and review of supplier quality-related documentation. Plant site quality control inspection program, including receiv-ing inspection and inspection and acceptance activities. associated l with maintenance, modifications, testing and fuel handling. PD1081-0535A-QA06
Page.9 Rev 6 Date: 06/15/87 Participation in daily work schedule and status meetings to remain abreast of day-to-day work assignments throughout the plant and to assure adequate QA coverage relative to procedural and inspection controls, acceptance criteria and staffing'and qualification of site QA personnel to carry out their assignments. Review of and concurrence with test procedures (including preop, functional, inservice baseline and modification tests) and in ' structions for QA aspects, and to identify necessary Hold and Notification points. Review and approval of inspection procedure s and plant onsite inspection planning. Review of work authorizing documents. Review and concurrence with administrative procedures that control' methods for indicating inspection, test and operating status and attachment / removal of inspection status indicators. Review and concurrence with Q-Lists and Q-List changes to assure compliance with QA Program commitments and to assure that the extent that QA controls are to be applied to specific structures, systems and componente is appropriate,
- b. The Director, Quality Assurance Support is responsible-to-the Executive Director, Nuclear Assurance for the Nuclear' Operations QA Audit Program, QA Program Development, Corporate Office QA Engineering for modifications Design and Procurement and Special-Studiei including the following:
QA aulit program (plant sites and Corporate Office), including follrw-up on corrective action for audit findings. Ver.fication of the implementation and effectiveness of Corporate Of.. ice corrective action for ignificant problems. Supplier surveys and evaluation including review / approval of supplier QA programs, and maintenance of tle NOD Approved Suppli-ers List. Review of and concurrence with quality requirements of procurement request packages generated in the Corporate Office. Corrective action program trend analysis and reporting. Maintenance / operation of corrective action system. Maintenance of the QA Program Description for Operational Nuclear Power Plants. PD1081-0535A-QA06
Page 10 i Rev.6 Date: 06/15/87-Review of Nuclear Operations Department Standards -(NODS) and review and concurrence with Corporate Office administrative procedures for compliance with QA Program requirements. Development and maintenance of Nuclear Assurance Department Procedures. q Analysis of new and/or changed regulatory direction, codes and . standards to determine their effect on the QA Program. Administrative control of Nuclear Operations Department-Standards. Corporate Office QA Engineering associated with modification design and procurement, including preparation of necessary quality assurance plans for integration with project plans, performance of source surveillance / inspection at supplier facilities, review of supplier quality-related documentation, and maintenance and reporting of status of hardware and test quality and corrective action (offsite). Development and maintenance of Plant Security Plans and contract administration for the security force.
- c. The Director, Nuclear Safety is responsible to the Executive Director, Nuclear Assurance for safety analyses, safety assess-ments, operating experience reviews including NRC Information Notices, probabilistic risk assessment, administrative and'techni-cal support for Nuclear Safety Board activities and technical support for onsite review organizations.
- d. The Corporate Health Physicist is responsible to the Executive Director, Nuclear Assurance for assessing the effectiveness of the corporate Health Physics program. He maintains standards.for control of Radiological Materialn and personnel exposure and recommends program improvements to reduce on-site and offsite radiation exposure caused by plant operations.
PD1081-0535A-QA06
Page 11 Rev 6 Date: 06/15/87 i PRESEDff ' AND GIEF EXECUTIVE OTTIcER
/
[ L I exec vier msmorf zxEc VIcE msmorf DERcY DISTRIBUTION DfERcY SUPPLY Figure 1 - Consumers Power Company Corporate Organization PD1081-0535A-QA06
Page 12 Rev 6 Date: 06/15/87-l EXECUTIVE - t VICE PRESIDENT ENERCY SUPPLT
/
\
VICE PRESIDENT DIRECTOR VICE PRESIDENT VICE PRESIDENT . VICE PRESIDENT ENERCY SUPPLY MANAGEMENT CAS TRANSMISSION / NUCLEAR POSSIL & HYDRO SERVICES AND BUDGET . PLTL St PPLY OPERATIONS OPERATIONS
,- ~/ -/
OIRECTOR, DIRECTOR POWER RESOCRCES & NUC'J.AR SYSTEM PLANNINC .FL'EL SUPPLY EXECUTIVE ENCR, SYSTEM DYNAMICS
& PLANI AUX Figure 2 - Energy Supply Organization PD1081-0535A-QA06
Page 13-
, 1. Rev'6 Date: 06/15/87 l
l NUCLEAR OPERATION DEPAltDIENE ' VICE PRZSIDENI NUCLEAR EXECL' RIVE ENGINEER 8A[g EXEC DIRECTORa
- NUCLEAR ASSURANCE l
1 i 3 q NUCLEAR NUCLEAR CO W RATE' ~
.WCLEAR PLuf!S LICENSINC RGE j g ASSURANCE SUP/CEN MCR i DIRECTOR ADMINISTRATOR EXEC DIRECTOR
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/ O NUCLEAR f TRAINING DEPARTMENT DIRECTOR Figure 3 - Nuclear Operacions Department Organization PD1081-0535A-QA06
Page-14
'Rev 6
;Date: 06/15/87 g NUCLEAR OFFSITE ASSURANCE ONSITE N N EXEC OIRECTOR
\ CORPORATE-
\ HEALTH PHYSICIST s
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PALISADES BIG ROCK PT I NUCLEAR' QA QA l SAFETY QA SUPPORT-DIRECTOR SUPT. l DIRECTOR DIRECTOR I
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i PLANT l SAFETY ENGINEERING I I ADMR. Figure 4 - Nuclear . Assurance Organir.ation PD1081-0535A-QA06
Page 15 Rev 6 Date: 06/15/87
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EXECUTIVE VICE PRESIDENT ENERGY DISTRIBUTION I VICE PRESIDENT DISTRIBUTION VICE PRESIDENT OPDATIONS CENERAL SERVICES MANAGER ENGINEERING AND INFORMA ON CONS W CTION gg AND_OPERAIIONS MANAWW (CRAPHIC OPERATIONS) (FIRE PROTECTION)- DIVISION R AD SYSTEM PLAMING
- AND PROIECTION Figure 5 - Energy Distribution and General Services Organization PD1081-0535A-QA06
l Page 16 Rev 6 Date: 06/15/87' l ) l VICE PRESIDENT S ENERCY SLTPLY SERV EXECLTIVE MANAGER EXECLTIVE MANAGER DIRECTOR OPERATING AND PROJECIS, ENGR PIANNING, TRAINING TECHNICAL SERVICES & CONSTRUCTION AND ADMINISTRATION DIRECTon MaAGER TECHNICAL FIELD MAINT SERVICES SERVICES Figure 6 - 2nergy Supply Services Organization PD1081-0535A-QA06
f Page 17J Rev 6 Date: 06/15/87 2.0 QUALITY ASSURANCE PROGRAM 2;l POLICY Policies that define and establish the Consumers Power Company (CP Co) Quality Assurance Program for Operational Nuclear Power Plants are stated in the individual sections of this document. The program is implemented through procedures and instructions responsive to provi-sions of the QAFD and will be carried out for the life of each plant. Quality assurance controls apply to activities affecting the quality of safety-related structures, systems and components, to an extent based on the importance of those structures, systems, or components to safety. Such activities are performed under suitably controlled conditions, inciv41ng the use of appropriate equipment, maintenance of proper environmental conditions, assignment of qualified personnel and assurance that all applicable prerequisites have been met. Quality Assurance Program status, scope, adequacy and compliance with 10CFR50 Appendix B are regularly reviewed by CP Co Management through reports, meetings and review of audit results. Biennially, a pre-planned and documented assessment of the Nuclear Operations QA Program is performed by a management team independent of the Nuclear Assurance Department. 2.2 IMPLEMENTATION 2.2.1 The President of Consumers Power Company, as Chief Executive Officer, has stated in a formal STATEMENT OF RESPONSIBILITY AND AUTHORITY, signed by him, that it is corporate policy to comply with the provi-sions of applicable legislation and regulations pertaining to quality assurance for nuclear power plants as defined by 10CFR50 Appendix B. The statement makes this QAPD and the associated implementing proce-dures and instructions mandatory and requires compliance by all responsible organizations and individuals. It identifies the Manage-ment positions in the Company vested with responsibility and authority for implementing the Program and assuring its effectiveness, 2.2.2 The Quality Assurance Program at CP Co consists of controls exercised by organizations responsible for attaining quality objectives and by organizations responsible for assurance functions (see Section 1.0, ORGANIZATION). 2.2.3 The affectivity and applicability of this QAPD are as follows:
- a. For Big Rock Point and Palisades, the QAPD became effective on April 1,1902, with full implementation ou January 1,1983,
- b. The QA Program described in this QAPD is intended to apply for the life of CP Co's nuclear power plants.
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c. The QA' Program' applies activitiesaffectibgithequalitybf tk@,1 systems,1 components safety-relatedLetructurb . consumables during plant' operation, maintenance,ftesting and.all modifications.. These activfties having*a" direct impact on Q-listeditems:shallbe.ptdcedur.blyLcontrolled. Safety--tie 12tedi
. structures, system, componenha M d related consumables are;identi ,
fied-in Q-Lists,1which are developed'and maintained for'eagh plantL 1
- in accordance with..the criteriaof Regulatory Guidefl.29qast clarified by; Item No. 20a iniPart 2 of' Appendix A?to this A4PD.
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2.2.4 This QAPD, organized. to present thej CP?Co'. Quality.' Assuranh4 Program
'for Operational: Nuclear Power Plants In the order of the118Lcriteria i of.10CFR50 Appendix B, state's'CP Co policy ' J forJeach'of tLO hriteria'.
anddescribeshowthe'controispertinent.toeachar4cid1[e(ou't'lAny; . changes made;to this QAPD that do not. reduce then cormitm9nts previous , ly-accepted.by theTNRC.must be submitted-to:tho'NRC at least{annuq11y. ' Any changes-made to)this QAPD.that do: reduce:the' commitments. previous-ly accepted by the NRC must be submitted to the:NRC and:receiveiNRCL < approval prior to implementation. The " submittal .of;the ' changes , ;h described7 above'shall be made in accordance with.theLrequiremehts of- <
, (I j 10CFR50.54.
QR q The program described in chis'QAPD will not be changed in,any way that. would prevent it from mee,tng the criteria of.10CFR50' Appendix B.~ 9 g 2.2.5 Documents used for implementing the provisions of the QAPD include thei d following: .1
.i a.
Nuclear Operations Department Standards ~(NODS)'and/or'administra-tive procedures specify the standard methods of~ accomplishing operational phase activities. Because the-Quality Assurance Program is an integral part of the operational phase activities.- the methods for implementing Quality Assurance Program controls are integrated into these documents. The Nuclear: Assurance-Department reviews the N0DS and administrative-procedures!for- y
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compliance with QA Program requirements'and Corporate'QA policy.. .. J
- b. When Contractors perform work under their'own quality assurance y programs, these programs are reviewed for~ compliance with the' ;
applicable requirements.of 10CFR50 Appendix B and the contract and. are approved by Nuclear Assurance priorito.the' start)of work.- ;j4 l ,,
- c. ?b d
Applicable elements of the operations Quality Assurance Program ' d are applied to emergency plans, security plan 6 radiation and fire -
.y protection plans'for CP Co nuclear power plants. :These' plans-describe QA controls applicable. to associated equipment' and -
M activities. ]*;-
.p 2.2.6 Provisions of the Quality Assurance Program'for Operational Nuclear Power Plancs apply to activities affecting the quality 'of safety-related structures, systems, components and related consumables'.
Appendix A to this QAPD lists the ANSI Standards and-Regulatory Guides PD1081-0535A-QA06
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r.ndixAalsodescribesnecessaryexcep- 3'
.h tions ' and clarf fidntions to the requirements of those documents. The-scope of the r#dgram and the extent to'dhich its controls are applied-are established as follows: '
$ jh L' a. CP Co uses the criteria specified in Regulatory Guides 1.26 and k- 1.29 in engineering analysis of an item's function in relation to safe operation and shutdown to 1dentify. structures, systems and components to which the Quality Assurance. Program applies (See '
Appendix A). N' 13 3' b. This identification process resultr'in the classification of equipment as either Q or non Q, and the inclusion of this classi-l ! ficat1on in an equipment data base. .This data base is.available for inquiry by individuals involved.in plant operation. The
; classification of structures, cystems and consumables is also
[' identified, documented.Tand controlled.
, c. The extent to which controls specified in the Quality Assurance Program are anlied to Q-listed items is determined for each item considering its delative"importance to safe;y; Such determina-IC e, tions are bued'on data in such documents as the plant risk analysis, plant Technical Specifications and the FSAR/FHSR (See !
Appendix A).l l 2.2.7 Activitics affecting the quality of safety-related. items are accom-plished under controlled conditions. Preparations for such activities imlude confit.nntiAthat prerequisites have been met, such as:
- a. Assigned personnel are qualified.
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- b. Work has been planned to-the proper revisions of applicable engineering and/or techna.c.al specifications.
( c. Specified equipment and/or tools, if any, are on hand to be used.
- d. Materials and items are in an acceptable status,
- e. Systems or g ractures on which work is to be performed are in the proper condition for the task.
- f. Authorized current instructions / procedures for the work are t available for use.. ,
) g g.
s-4 Iceme and facilities that could be damaged by the work have been protected, as required.
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- h. Provisions have been made for spectal controls, processes, tests ,
orand verification methods.
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Page 20. Rev 6 Date: 06/15/87
- 2. 2. 8 . Development, control and use of computer programs affecting nuclear power plant design and operation'at CP Co are subject to QA Program design controls (see Section 3.0,. DESIGN CONTROL).
2.2.9 Responsibility and authority for planning and implementing'indoctrina-tion and training are specifically^ designated in the CP Co'organiza-
. tion (see Section 1.0, ORGANIZATION),
- a. The training and indoctrination program provides for' ongoing.
training and periodic refamiliarization with the Quality Assurance Program for Operational Nuclear Power Plants,
- b. Personnel who perform inspection and examination functions are -
qualified in accordance with requirements of Regulatory. Guide 1.58, SNT TC-1A, or the ASME Code, as applicable.
- c. Personnel who participate in quality assurance audits are quali-fied in'accordance with Regulatory Guide 1.146.
- d. Personnel assigned duties such as special cleaning processes, welding, etc, are qualified in accordance with-applicable codes, standards and regulatory guides,
- e. The training / qualification program for personnel performing QA functions includes provisions for retraining, reexamination and decertification to ensure that proficiency is maintained. ,
l
- f. Certificates of qualification for personnel performing QA func- 1 j
tions designate specific functions that the named personnel are ! qualified to perform and indicate the performance criteria on l which the qualification was based.
- g. Training and qualification records including documentation of objectives, content of program, attendees and dates' of attendance are maintained at least as long as the personnel involved are performing activities to which the training / qualification is relevaat.
I
- h. Personnel responsible for performing activities that affect quality are instructed as to-the requirements identified in l
applicable quality related manuals, instructions and procedures. 2.2.10 Status and adequacy of the quality assurance program are. regularly assessed by CP Co Management. The following activities constitute formal elements of that assessment:
- a. Audit reports, including follow-up on corrective action accom-- I plishment and effectiveness, are distributed to appropriate levels of Management (see Section 18.0, AUDIT).
PD1081-0535A-QA06
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4 , Dates;;06/15/87 L b. Semi- annual QA' Program. Status Meetings are lieldi,involvihg the.-
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"Vice Presidentf. Nuclear.' Operations, the: Executive Director,
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- Nuclear Assurance and'.the; Man' agers'of.the organizations,responsi : - @
.ble for implementing elements of.the1QA Program for' Operational ~y.g
. Nuclear Power Plants.
c.- Managementiteams; independent from the; Quality Assurance organiza-
- tion, . but: knowledgeable. in l auditing Jandi quality.; assurance,; bienni-c -
ally. review.the: effectiveness.of(the-Quality.' Assurance Program for:-
, Operational. Nuclear Power Plants.i lConcidsions'and' recommendations-Jare: reported to theiExecutive;Vice. Pre'sident,sEnergy.; Supply."
- Correctivefactionsinresponse'torecommendations}are'tracke'dlinf'7
.the regular corrective action track 1ng system (see'Section 16.0,
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1 CORRECTIVE ACTION)..
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j Pagn 23 Rev'6 Date: 06/15/87 3.0 DESIGN CONTROL 3.1 POLICY Modifications to safety-related structures, systems and components are accomplished in accordance with approved designs. Activities to develop such designs are controlled. Depending on the type'of modifi-cation, these activities include design and field engineering; the performance of physics, seismic, stress, thermal, hydraulic, radiation and Safety Analysis Report (SAR) accident analyses; the development and control of associated computer programs; studies of material compatibility; accessibility for inservice inspection and maintenance; and determination of quality standards. The controls apply to prepa-ration and review of design documents, including the correct transla - tion of applicable regulatory requirements and design bases into design, procurement and procedural documents. l 3.2 IMPLEMENTATION I l 3.2.1 Authority and responsibility for modification activities under the ( cognizance of the Nuclear Operations Department and Projects, Engi-I neering and Construction (PE&C) are described in Section 1.0, ORGANIZATION. This authority and responsibility includes the pre-paration, review, approval and verification of the following design documents: a) System descriptions; b) Design input and criteria; c) Drawings and specifications; and d) Engineering analyses and associated computer programs. 3.2.2 Errors and deficiencies in approved design documents, or in design methods (such as computer codes) that could adversely affect struc-tures, systems and components are documented. Action is taken to assure that the errors and deficiencies are corrected. 3.2.3 Materials, parts and processes that are essential to safety-related functions are selected and specified, based on the requirements of applicable codes and standards or on known, successful use under similar conditions. This includes standard commercial materials, parts and processes. Alternatively, materials, parts and processes may be qualified for use through qualification testing (see Item 3.2.8). The adequacy of the selected materials, parts and processes is assurad through the required design. verifications or approvals. 3.2.4 Exceptions and waivers to or deviations from the engineering (quality) standards (ie, the required dimensions, material propertjas, features and other characteristics specified for modifications) are required by procedure and by contract, when applicable, to be documented and controlled. (See, also, Section 15 concerning the approval of "re-pair" or "use as is" dispositions of nonconformances.) 3.2.5 When modifications involve design interfaces between internal or external design organizations or across technical disciplines, these PD1081-0535A-QA06
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F finterfaces"are controlled. Proceduresareusedffor;thereview.1
' approval,-release, distribution and revision of: documents 1 involving: ,
4 , s >
. design interfaces'toiensure,that' structures, syst'e'ms and 2 components ' '
s;are compatible geometrically / functionally: and seithLprocesses andl .
' environment'. Lines'of communication.are established for; controlling
.' 'the: flow of needed design information'across: design; interfaces,1
. including changes:to the?information.as work progressest Decisionsy and, problem' resolutions linvolvingidesign: interfaces"are made;by"the!
CP Co organization.having responsibility;for engine'eringidirection ofa the design effort., ^ f 3.2.6 . Checks:are performed land documented tosverify/theLdimensional accuracy? and completeness of; design drawings:and= specifications?(ie, the: ,
-products of'a design process).
~
- 3. 2. 7 - ' Modification design' document: packages are'rev'iewed by'the Nuclear.~ s Assurance' Department to: assure thatjthe? documents lthat'they~contain; .-
have been prepared, verified',: reviewed and approved in' accordanceawith - Company procedures and.that.they contain:the nece_ssary qualitygassur-J , ance requirements.'1These requirements include thefinspection anditest! e requirements, quantitative and/or-qualitative, acceptance criteria andy the requirements for documenting: inspection andLtest-results. v. F 3.2.8 The extent-of and methods for.' design verification:are" documented.:'The extent of design verification performed is?a function ofLthelimpor-': tance of the item to' safety,. design complexity,Ndegree of standard 1za-- tion, the state-of-the-art and similarity.with previously? proven, designs. Methods for design verification' include evaluation of' thel applicability of standardized or previously proven.designsi alternate: calculations, qualification' testing and' design reviews.; These methods i may be used singly or in' combination', depending >on the n'eedsifor the' design under consideration. When design verification is done by evaluating standardized orLprevi-1 ously proven designs, the applicability of such designs ~1s confirmed. -o Any differences from the proven: design >are, documented land evaluated ~ for the intended application. Qualification testing of prototypes, components or features is used when the ability of an item to perform an essential safety function:
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4
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cannot otherwise be. adequately substantiated ~. This testing is per ' formed before plant equipment installation where possible, buttalways ' before reliance upon the item to perform a safety-relatedLfunction'.i Qualification testing-is performed'under conditions that simulate;the-most adverse design conditions, considering all; relevant (operating 4 modes. Test requirements, procedures and results are documented. > Results are evaluated to assure that.testsrequirements hav'.b'een: e satisfied. Modifications shown to be'necessary through testing are
-made, and any necessary retesting or-other verification is performed.L Scaling laws are established and verified :when applicable.;~ Test-configurations are clearly documented.
4 U PD1081-0535A-QA06
Pags 25 Rev 6~ Date: 06/15/87 ; i Design reviews are. performed by multi-organizational or inter-disciplinary groups or by single individuals. . Criteria are estab- ] l 11shed to determine when a formal group review 1s required and when review by an individual is sufficient. l Unless otherwise stated, the verification of design addresses all information conveyed by the design document. When the verification is limited to certain. areas or features, the scope or extent and any , limitations on the verification are documented. 3.2.9 Persons representing applicable technical disciplines are assigned to perform design verifications. These persons'are qualified by appro-priate education or experience but are not directly responsible for . the design. The designer's immediate supervisor may perform the verification, provided that: (1) He is the only technically qualified individual available, and r (2) He has not specified a singular design approach, ruled.out certain [ design considerations or established the design inputs for the . particular design aspect being verified, and
-)
(3) His review is either: i
- a. Approved in advance by the supervisor's management, with i documentation of the approval included in the design package. {
or l
- b. Controlled by a procedure reviewed and approved-by the Nuclear Assurance Department. Such procedure shall provide specific limitations regarding the types of design work that may or may not be verified by a designer's supervisor, and shall provide for clear documentation that the supervisor performed the design verification. l QA audits cover the frequency, effectiveness, and technical adequacy of the use of supervisors as design verifiers to guard against abuse.
3.i.10 When designs must be released for use before they have been fully coupleted or before they have been verified, the incomplete or unveri-fled parts of the design and the hold point to which work may proceed are identified. This hold point occurs before the work becomes irreversible or before the item is relied on to perform'a safety-related function. Justification for such early release is documented. 3.2.11 Computer codes used in design are appropriately documented, verified, certified for use and controlled. Their use is specified. PD1081-0535A-QA06
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3.2.12 ChangesT to ' design output - documents, ; including; field changes ,; are 4: i -
-c controlled /in a' manner commensurate with:that usedcfor-the..'origindli . -d design. Such changes lare evaluated :for,11mpa.:t. ; Those that .sff set ' .
fit, form'or1 function are. reviewed and approved by;.the:-same;.or; [d
. equivalent, organizations' that approved the: original design.:,. Informa-
' tion on. approved changes'is transmitted to all affected organizations.
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Date: 06/15/87 4.0- PROCUREMENT DOCUMENT CONTROL' 4.1, POLICY. Procurement' documents.for safety-related structures, systems, compo-nents and services define the characteristics of item (s) to be. pro-cured, identify applicable regulatory'and industry codes / standards requirements and specify supplier quality. assurance program require-ments to the extent necessary to assure adequate quality. 4.2 ' IMPLEMENTATION 4.2.1 Responsibilities and authorities for procurement. planning and for ) preparation,-review and' approval of procurement documents are delin-
~
j eated in Section 1.0, ORGANIZATION.' i Procurement request packages are reviewed and approved prior to
~
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submittal to the Purchasing and Materials Management Department. . i Review includes, verification by Nuclear Assurance' Department-that the: j necessary quality requirements are'specified. l q The responsible project engineer performs bid evaluations. i 4.2.2 Supplier selection is describsd in Section 7.0, CONTROL OF PURCHASED. MATERIALS, EQUIPMENT AND SERVICES. 1 4.2.3 The contents of procurement documents vary according to-the item (s) l being purchased and its function (s) in the plant. Provisions of this ; QAPD are considered for application to suppliers. As applicable, procurement documents include:
- a. Scope of work to be performed.
- b. Technical requirements, with applicable drawings,'t'ecifications, codes and standards identified by title, document namber and revision and date, with any required procedures sur.h as special' process instructions identified in such a way as to indicate source and need.
- c. Regulatory, administrative and reporting' requirements. l
- d. Quality requirements appropriate to the complexity and scope of the work, including necessary tests and inspections,
- e. A requirement for a documented QA Program, subject to Nuclear Assurance Department review and written concurrence prior to the start of work. <
- f. A requirement for the supplier to invoke applicable quality '
i requirements on subtier suppliers. 1 PD1081-0535B-QA06
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, ! Paged 281 Rev 6 .. . . , ,
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'y Provisions.,for access-to' supplier and'subtier suppliers'?facili-'
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- ties and records:for, inspections,Laurveillances.andiaudits.- ' >
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h.: , Identification"of' documentation to,be.provided by.the. supplier,- 1 ; identification;of-._ documents,be compatible with.the: Engineering l ' 4
' Records;Centerj Syst'em, ' the schedule Jof; submittals and 16ntifica-S ,
itionLof documentsirequiring:CPLCo approval.ic - g a 4.2;4 l Nuclear -Assurance' Department performs :and documents reviews lbf' pro'-i r
- curement r'equest packages to' assure'that:. 1 f.
, 1 L. a .'
Qualityrequirements(seeL4.2.3cof;this"Section)Eare;correctlp(" ,o i stated,L i nspectable,.and controllable. M ' ~ '
- b. Adequate acceptance andirejectio'n criteria are inhludhd2: ..g c; LThe procurementLdocuments,have been' prepared,T reviewed, and approved per the QA Program requirements. +
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-n 4.2.5 ' Changes to tiie technical or qua11tyL requirementslin procurement
. documents are controlled,in a manner'. commensurate with thatTused for?
the. original requirements; Those that.could i affect fit, form,'func-tion or the necessary. assurance-!of quality;are' reviewed'and approved, by the same, or equivalent, organizations that approved:the original.:. m
- procurement request packages.
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~Rev 6~ . d Date:.06/15/87 5
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-5.0 ' INSTRUCTIONS, PROCEDURES AND DRAWINGS i 5.1 POLICY- .
Activities.affecting the quality ~.of;safet'y-related' structures,. systems-and components.are accomplish'ed usingiinstructions,Lprocedures and.: drawings appropriate to the circumstances which. include. acceptances criteria for determining if an activity has,been satisfactorily' ' completed. j u 5.2 IMPLEMENTATION- > j The' authority and responsibility'for'performingiactivities.affecting: the quality of safety-related. structures, systems,and componentefare: u assigned as described in)Section 1.0, ORGANIZATION. Management . ] >- personnel assigned these ' responsibilitieslassure that the instruc-- _ > M l
- tions, procedures and drawings necessary to accomplish the activ1ty - W are prepared and implemented.
~
Instructions, procedures.and-drawings incorporate l(1).'a description of; the activity to oe' accomplished and (2) appropriate quant 1tative1(such-as tolerances and operating limits) and qualitative (such as workman - ship standards) acceptance. criteria sufficient to~ determine'that:the activity has been satisfactorily accomplished. J Temporary procedures may be issued to provide management instructions q which have short-term applicability. Temporary procedures include a-designation of the time period during which'they.may'be'used.- The procedures used'by CP Co to control'its activities include:the' -) following:
- 1. Administrative Procedures, including Nuclear Assurance Depattment. )
Procedures. 1
- 2. System procedures that describe the operation of the plant. R
- 3. Start-up procedures that provide for starting the. reactor from hot or cold condition and recovering from reactor trips.
~
1
- 4. Shutdown procedures that provide for controlled reactor' shutdown or shutdown following reactor trips.
.i 5.. Power operation and load changing' procedures.that provideifor steady state power operation and load changing, including response to unanticipated-load changes.
- 6. Process monitoring procedures that provide' for monitoritig plant <
system performance and which, as appropriate;-identify limits for , significant process parameters. l
)
.PD1081-0535B-QA06
Page 30 Rev 6 Date: 06/15/87
- 7. Fuel-handling procedures that provide for activities such as:
- a. Core alterations
- b. Refueling
- c. Fuel accountability
- d. Receipt and shipment of fuel i4 e '. Nuclear Safety measures 0
- 8. Maintenance procedures that provide for:
- a. Preparation for maintenance
]
- b. Performance of maintenance-
- c. Post-maintenance and operability checks and tests
- d. Use of supporting maintenance documents
- 9. Radiation control procedures that provide for:
- a. Implementation of the radiation control program including the acquisition of radiation data
- b. Identification of equipment for performing radiation surveys
- c. Measurement, evaluation and assessment of radiation hazards
- 10. Calibration and test procedures that provide for: :
- a. Periodic calibration and testing of safety-related instrumen- .
tation and control systems H
- b. Calibration of portable measuring and test equipment ~used in activities affecting safety I
- 11. Chemical-radiochemical control procedures that provide for a'ctivi-ties including:
- a. Sampling and analyses 1
- b. Maintenance of coolant quality
- c. Control of deleterious agents
- d. Control, treatment and management of radioactive wastes
% The control of radioactive calibration sources PD1081-0535B-QA06
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.12. Emergency procedures that' provide.; guidance for:l -i - i
- a. ' Operations during potential emergencies.softhat aitrained.
operator:will know inaadvance'the expec'ted course-of. events; < L J ' that will identify an emergency and..the immediate ' action' he? t ' i should take >
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- b. Identifying' symptoms'of: emergency conditions .
- 6. J x H A
.c. . Monitoring,aut'omatic. action o 1
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'd. Immediate: operator" action' 4 a ' j 1 ;s
- e. Subsequent: operator action'. ,
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- 13. Emergency Plan 1 implementing Procedures! 16 M
3 4 i L 14. Inspection,' test and. examination procedures that. identify:r q
- a. -Objectives- . l f
.-]
- b. . Acceptance criteria W
- c. Prerequisite and special' conditions.
- d. Limiting conditions '
j
- e. Test or inspection instructions .
.I
- f. Any required special equipment or' calibration'
- g. Hold and Witness points, as appropriate
- 15. Modification procedures that' provide for: y l
- a. Administrative control and technical support duri.ng plant modifications !
' . , 1.
- b. The basis for a consistent method of performing recurring:
engineering, construction'and quality assurance activities ; c.- Control of the interfaces between-CP Co'and.its-suppliers:
- d. Offsite management control"and visibility.
q . ( PD1081-0535B-QA06 , l (
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'e.~ Control"of onsite quality-related modification lactivitiescthat.,
assure the QA Program"isfimplemented.andcits:;effectivenessfiss.' q;- .$ y'.s iassessed-and"' reported 1 ..
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i Paga 33 , Rev 6 . l Date: 06/15/87 6.0 DOCUMENT CONTROL 6.1 POLICY q t Documents controlling safety-related activities within the scope defined in Section 2.0, QUALITY ASSURANCE PROGRAM are issued and changed according to established procedures. Documents such as instructions, procedures and drawings, including changes thereto, are reviewed for adequacy, approved for release by authorized personnel and are distributed and used at the location where a prescribed activity is performed.
\
Changes to controlled documents are reviewed and approved by the same j organizations that performed the original review and approval or by ^ other. qualified, responsible organizations specifically designated in l accordance with the procedures governing these documents. l 6.2 IMPLEMENTATION . ! 6.2.1 The authority'and responsibility for the control of documents are described in Section 1.0, ORGANIZATION. 6.2.2 Controls are established for approval, issue and change of documents in the following categories:
- a. Design documents (eg, calculations, drawings, specifications, analyses) including documents related to computer codes
- b. As-built drawings (record drawings) and related documents
- c. Procurement documents ,
- d. Instructions and procedures for activities such as fabrication, construction, modification, installation, inspection, test and plant maintenance and operation
- e. Procedures that implement the Quality Assurance Program
- f. Final Safety Analysis Report
- g. Reports of nonconformances
- h. Plant Technical Specifications 6.2.3 The review, approval, issue and change of the above documents are controlled by:
- a. Establishment of criteria to ensure that adequate technical and quality requirements are incorporated
- b. Identification of the. organizations responsible for review, approval, issue and revision PD1081-0535B-QA06 l
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Performance and documentation of a: review for' concurrence with~ l Quality: Assurance-related aspects of items 6.2.2'a, c,'d:(esceptl '
'{
for operating procedures)', e.andig by thefNuclear. Assurance ^ Department d'. Review of change's tofdocuments by'the;organizationithat1 performed - the initial review and approval l or- byL the organization. designated: in ac'cordance with the' procedure governing the review and approval! of-' specific ~ types .of documents : 6.2.4 Controlled documents are: issued and. distributed so that'?
- a. The documents areJavailableiat'the work' location: prior to.commenc
[ ing work i
- b. Obsolete or superseded documents .are removed from work areas and replaced.by_ applicable revisionsJin a:timelylmanner.
6.2.5 Master. lists or equivalent controls are;used.tohidentify:the current (
~
revision of instructions, procedures, sp~ccifications, drawing's: and;
. procurement documents. When master lista are usedithey are updated and distributed?to designated personne11who are responsible for-maintaining current copies of the. lists.
l 6.2.6 Accurate _as-built drawings (record drawings) and related' documentation l are prepared in a timely manner. d 1 i l Tu 1 1
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i q Page 35 1 Rev 6 ) Date: 06/15/87 ; 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1 POLICY Activities that implement approved procurement requests for safety- ' related material, equipment and services are controlled to assure conformance with procurement document requirements. Controls include I a system'of supplier evaluation and selection, source inspection, ; examination and acceptance of items and documents upon delivery, and i periodic assessment of supplier performance. Objective evidence of quality that demonstrates conformance with specified procurement document requirements is available to the nuclear power plant 81te j prior _to use of equipment, material or services. < 7.2 IMPLEMENTATION l 7.2.1 Authority and responsibility for implementing the controls outlined herein are described in Section 1.0, ORGANIZATION. I l 7.2.2 CP Co qualifies suppliers by performing a. documented evaluation of , their capability to provide items or services specified by procurement i documents. To remain qualified, suppliers involved in active procure-ments are reevaluated annually and are audited triennially. If the Coordinating Agency for Supplier Evaluation Register is used to establish the qualifications of the Supplier, the documentation identifies the audit used. Evaluation of suppliers holding applicable ASME Certificates of Authorization is done by reference to the current ASME listing of certificate holders. Supplier evaluation and triennial audits are not necessary when the items or services supplied are all of the following:
- a. Relatively simple and standard in design, manufacture and test, and
- b. Adaptable to standard or automated inspections or tests of the end product to verify quality characteristics after delivery, and
- c. Such that receiving inspection does not require operations that could adversely affect the integrity, function or cleanness of the item.
In the above cases, source and/or receipt inspection provides the necessary assurance of an acceptable item or service. 7.2.3 Supplier activities that affect quality are, verified in accordance with written procedures. These procedures provide the method of verifying (such as audit, surveillance or inspection) and documenting that the characteristics or processes meet the requirements of the procurement document. For commercial "off-the-shelf" items where the requirements for a specific quality assurance program appropriate for nuclear applications cannot be imposed in a practical manner, source PD1081-0535B-QA06
Page 36 1 Rev 6 Date:.06/15/87 verification is used to provide adequate assurance of adeeptability unless the quality of the item can be adequately verified upon' receipt. 7.2.4 Spare and replacement parts are. procured in such a manner lthat their performance and quality are at least equivalent'to those of the parts-that will be replaced.
- a. Specifications and codes referenced.in procurement documents for spare or replacement. items are at least equivalent to those for =
the original' items or to properly reviewed and approved revisions.
- b. Parts intended as' spares or replacements for "off-the-shelf" I items, or other items for which quality-requirements were not originally specified, are, evaluated for perfotmonceLat least equivalent to the original.
- c. Where quality requirements for the original items cannot be determined, requirements and controls are established by engineer-ing evaluation performed.by qualified individuals. The evaluation !
assures there is no adverse effect on interfaces,,interchangeabil-1 ity, safety, fit, form, function or compliance with applicable l regulatory or code requirements. Evaluation results are documented. '
- d. Any additional or modified design criteria, imposed after previous procurement of the item (s), are identified and incorporated.
7.2.5 Receipt inspections are performed to verify that items are undamaged and properly identified, that they conform with safety-related pro-curement requirements not previously verified by source. surveillance or inspection and that required supplier furnished documentation is available. Items inspected are identified as to their acceptance' status prior to their storage or release for installation. 7.2.6 Suppliers are required to furn1sh the following records:
- a. Applicable drawings and related engineering-documentation that identify the purchased item and the specific procurement require-ments (eg, codes, standards and specifications) met by the item.
- b. Documentation identifying any procurement requirements that.have not been met.
l
- c. A description of those nonconformances from the procurement requirements dispositioned " accept as is" or " repair."
- d. Quality records as specified in the procurement requirements.
1 Nuclear Assurance Department evaluates the acceptability of these documents during source and/or receipt inspection. PD1081-0535B-QA06
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'7.2.7 . : Suppl 1tr's: certificates of conformance are periodically" evaluated by. '
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. audits,' independent' inspections or tests tol assure ~that;they'are? .' ,
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' valid. .The.results of these evaluations' are'dscumented.
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l 1 8.0- IDENTIFICATION AND CONTROL OF ITEMS: . h
.8.1 POLICY
' Safety-relatedmaterials,partsand; components /(itemshareLidentified' '
and controlled to prevent their inadvertent use'.:' Identification.of j items is maintained either'on.the? items, their storagefareasfor
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containers or>on' records traceable'to the items ~.:
'8.2 IMPLEMENTATION 3 8.2.1 Controls are. established that provide for the11 identification!and? , f control'of materials (including:consumables), parts:and' components,' - 1 L (including partially fabricated assemblies). . Responsibility; for 7the' '
I identification and control of items is described;in Section 1.0,l 4 j ORGANIZATION. - 1
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8.2.2 Items are identified by physically marking the item, itsistorage area l or its container or by maintaining records traceable to;,the item. The.
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, method of identification is such that the' quality of the. item is'not- ; degraded.
, , ,1 8.2.3 Items arc traceable to' applicable drawings,. specifications or~other' pertinent documents to ensure that:only correct and acceptable; items
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are used. Verification of traceability is performed:and; documented = prior to release'for fabrication, assembly or installation. - l {I l l l
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CONTROL OF SPECIAL PROCESSES 1 9.1- POLICY.
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a Special processes af fecting safety-related structtires. : systems .and ' . . components are' controlled and are accomplished by? qualified lpersonneli 4 y using qualified procedures and' equipment in~accordance;with applicable. !
- codes, standards,Lapecifications, criterlatand ' other special: require-1 ments. ,
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l 9.2- ' IMPLEMENTATION > J 9.2.1. Processes subject.to special process controls'acLCP Co are those .'for' j which full verification or characterization by direct inspection;ist 9 impossible or impractical. -Such processes include welding, heat. _ treating, chemical-cleaning,. application of' protective; coatings,1
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concrete placement and nondestructive examination.x 9.2.2 .0 organizational' responsibility for' implementation ofJspecial~ proc' esses and.for qualification of procedures,. personnel, and equipment;.usedLto H' ; , d perform special processes is indicated in Section 1.0, ORGANIZATION. .. 9.2.3 Special process procedur~es are prepared by: p'ersonnel with . expertise #in . -3 the discipline involved. The procedures.are' reviewed for technical- I adequacy by other-. personnel with the,necessary. technical:competerae, ; and are qualified by testing, as necessary. -
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9.2.4 -Special process personnel qualification is determined by. individuals 1 authorized to administer the pertinent examinations. Certification-is I based on examination results. Personnel qualification is"kept current by performance of the special process (es). and/or reexamination at time; i intervals specified by applicable codes, specifications.and. standards.' . Unsatisfactory performance or, where applicable, failure.to' perform , i within the designated time intervals requires decertification.- . 9.2.5 For special processes that require qualified equipment, such equipment ~ is' qualified in accordance with applicable codes, standards and- 1 specifications. 9.2.6 ' Qualification records are maintained in accordance1with QAPD Section-
- 17. -
9.2.7 The Nuclear Assurance Department audits..special process qualification. ) activities and performs. inspection"and surveillance of special pro-- , cesses to assure they are satisfactorily. performed when specified by;
- applicable inspection planning and/or site procedures.'2Such inspection and surveillance includes verification;that process' data are recorded.
{ as required, are within specified limits.and.are performed:in accor ~ j dance with applicable requirements. ,. i i
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i I j Page 43 q Rev 6 : Date: 06/15/87 - 1 10.0 INSPECTION :) 10.1 POLICY d j Activities affecting the quality of safety-related structures. systems- ) and components are inspected to verify their.conformance with require- j ments. These inspections are performed by people other than those who perform the activity being inspected. Direct inspection, process - 1 monitoring, or both, are used:as necessary. Hold points are used as ; necessary to ensure that inspections are accomplished at the correct .< I points in the sequence of work activities. 10.2 IMPLEMENTATION .j 10.2.1 Organizational responsibilities are as described in Section 1.0, i ORGANIZATION. l l 10.2.2 Inspections are applied to procurement, maintenance, modification,- -l l testing, fuel handling and inservice inspection to verify that items -l and activities conform to specified. requirements. Work authorizing documents (eg;. procedures, instructions, maintenance work orders) are .j reviewed by the Nuclear Assurance Department in accordance with 1 established criteria to do the following as necessary: .j
- a. Determine the need for inspection (s). .
- b. Identify the inspection organization.
- c. Identify Hold and Notification points.
- d. Determine how and when the inspections are to be performed.
- e. Specify measuring and test equipment of the necessary accuracy for performing inspection.
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- f. Provide for documentation of inspection results to provide ade-quate objective evidence of acceptability.
Inspection is performed at each operation where it is necessary to verify quality. Process monitoring is used in whole or in part where direct inspection alone is impractical or inadequate. 10.2.3 Training and qualification programs for personnel who perform inspec-tions, including nondestructive examination, are established, imple-mented and documented in accordance with Section 2.0, QUALITY ASSURANCE PROGRAM.- These programs meet the requirements of, applicable codes and standards. The Nuclear Assurance Department reviews and concurs with any such programs that are not under its direct responsi-bility. Qualifications and certifications of inspection and NDE personnel are maintained. PD1081-0535B-QA06
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'the following'as appropriates: -
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- a. Identification.offapplicablA revisions' of) required? instructions f '
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- b. .Identif1 cation of character 1'st'ics[andfactivities;to be;inspectedk.
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c., Inspection methods. .
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- f. Acceptance and: rejection critedia.: .
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g.- Recording of.theLinspection:resultsiand the identification ofdthe.- r M l inspector.- 4 10.2.5 Inspection points are designated by-the Nhelear Assurance Department" l- as mandatory hold: points when-confirmation:is-neede'dtthat.the"worki accomplished up to that point 1s[ acceptable <beforeLthe workLean bel , , l allowed to proceed.further. Hold: point inspectionsiare; performed,~and-l work is released for: further processing' or use., by designated'~inspec ' l, tion personnel. Hold points may;be. waived.onlyibyidesignated Nuclear-Assurance Department personnel. '2 10.2.6 Inspections are performed and. documented.;in accordance'with the written instructions provided. Thev resultsiare 0evaluate'd:byidesignatf . ed personnel in order to ensure that;the;resultaisubstantiate'the- > acceptability of the item or. work. EvaluationLandl review!results'are; documented. 10.2.7 Inspection of. work associated only with_ normal; operation (ofjithe' plant,. such as-surveillance tests and. verifications ofl routine maintenance-may be performedLby individuals.inJ thelsame'groupjas that which. g performed the. work,-but not:by personnel ~who directly?perfoEmedLorL
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l.) supervised the work. Peer inspection is';acceptableiprovidEd:l t' '[; w 0-: E
- a. The quality of the work <can be: demonstrated'through;a functional $ Ali
-test when the work involves breaching'a pressure retaining' item.1 j
- b. Thequalificationcriteria-forthe:.inspectionpersonnelSavelbeenJ ' (q reviewed and : found acceptable .by' the.: Nuclear.. Assur.ance' Department.1 -
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11.1 20LICY
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Testing is performed in accordance with established programs to demonstrate that safety-related structures, systems and components . will perform satisfactorily in service. The testing is performed U accordancewithwrittenproceduresthatincorporatespecifiedreq/in_\ uist. A ments and acceptance criteria. The test program includes qualif Lea-{ { -; tion (as applicable), acceptance., pre-operational, start-up,
- p. .'
surveillance and maintenance tests. Test parameters, including any' . prerequisites, instrumentation requirements and environmental condi- Q -l tions are specified and met. Test results are documented and. i evaluated. (;(' 5- T> 11.2 IMPLEMENTATION w 11.2.1 Organizationdi responsibilities for test'ing are, described in; Sectica 1.0, ORGANIZATION. t l 3 11.2.2 Tests are performed in accordance with programs, procedures and- I
.triteria that designate when tests are required and'how they are,to be performed. Such testing includes the following:
- a. Qualification tests, as applicable, to verify. design adequacy in accordance with Secticn 3.0, DESIGN CONTROL.
- b. Acceptance tests of equipment'and componenti to assure their proper operation prior to delivery or to prl-operational tests.
- c. Pre-operational tests to assure proper and safe operation of j systems and equipment prior to start-up tests or operations.
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- d. Start-up rests, incluling precritical, criticality, low-power and power %scension tests, ' performed af ter refueling to assure proper q and safe operation of systems and equipment.
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- e. Surveillance tests to assure continuing proper and safe operation of systems and equipment. e J :
- f. Maintenance tests after preventive or corrective maintenance. j 11.2.3 Test procedures and instructions include provisions for the following, "
as applicable: , w 9 ;) a.' The requirements and acceptanceflimits iontained in applicable ' design and procurement documents. f: I
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- b. Test prerequisites such as calibrated instrumentation, adequate test equinment and instrumentation including' accuracy require-i ments, cotaplett. ness of the item to be tested,}s L2ablesand con-y
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! trolled environmental' conditions'and' provisions [for datas m .>
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- c. Instructions for perfm ming the' test'.; ..;wl Av , ,
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- d. Mandatory ins'pect' ion hold points:for-witness by.the appropriate.
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- f. -Methods of' documenting or recording test; data and'results.N ,
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;g. Assuring that. test prerequisites have been met._ '
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-- h . . QA-verification of completion of modification' activities.;
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> :. .J Test' procedures'and-instructions are reviewed by the engine'ering';
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N{p 4 organizations for. technical content'and-by1the Nuclear Assurance. f d Department for QALaspects.2 . 5' * ']
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11.2.4 The Nuclear Assurance' Department'verifles, through audits, inspection.?, - and surveillance, that t'est res' ltsuare , documented', . evaluated va ;Wf , their. acceptability is determined by responsible' personnel., 'Q' . s:{ . w j
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12.0 CONTROL DE EASURINGAk$ESTEQUIPMENT. - q 12.1 M POLICY; ,. p ,
- g. _j ktMeasuring'and testing equipment used in activities.affecting the; ;
'}qualityofsafet'y-relatedsystems,'componentsandstructuresare q properly identified, controlled, calibrated' and adjusted: at specified ' 1 intervals to ma1ntain accuracy within necessary limits. a 1 ~
12.2 IMPLEMEttr 7tNc. 3 ;( ' 12.2.1 The autb3rity and responsibility of personnel establishing. imple-mentingc 'and assuring effectiveness of calibration programs is de- j scribed in Section 1.0, ORGANIZATION. ' H 12:2.2 Procedures are established for measuring and test-equipment utilized inUh'e-measurement, inspection and monitoring of structures, systems ] anitc'omponents. These proced4r6s describe calibration technique and: j frequency and maintenance and control of..the. equipment. Y
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! / U.2.3 Measuring and test equipment'is O( iqualy'identSfiedLand'is traceable
,? to its calibration source. .;^ ,
NJ ;[ . 1 1 (2.2.4 CP Co(tuses a system of-labels to de' attached to, measuring ind test- R equipment tc(display the nesti? calibration due .date. Whert}}abels cannot be attached, a cotittol system is used that' identifies to : potential users any equipment beyond the calibration'due d'alt'e.
., _(Y, 12.2.5 ; Measuring and. test equipment (M&TEF and11:astalled Vlage ' instruments-tioniscalibrate4at specified integve,ls: based on Ltte. required accuracy, purpose, 'degre.a of usag41tability characteristics,' and '
other conditions affecting the measurement. .
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Calibration of M&TE is against standards that have an accuracy.of at leastfourtimestherequiredaccuracy'oftheequ@nentbeing.cali-trated or, when this is not.pessible, have an accuracy that assures the huipment befits , calibrated will be within required tolerance. and the basis of acceptance is documented and authorized by responsible management. . 1 Calibration standards ped for installed plant Instrumentation shall'. j-
,V norm E y have greater accgracy than.the instrum M acion being cali- K /[' bratec. '. Standards with dd same accur(>cy m' y Mbse'd when shh.m to be <
ade tv. ate f or specific calibration requiremeras., f The basis for 'this '
. acceptance is documentsdknd is approved by Eesh.otd.ible manageraent.
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, 12.2.6 Calibrating standgrds.have greater accuracy than standards being 4+' calibM ted. CalibrexQ3 standards with the same accuracy may be.us6,1( l if it can be shown $Nrhquate for the reqyzements and the basis of acceptance is document'eP and authorized by responsible management.
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12.2.7 '; Referenc'e and transfer? standardscare ' traceable to nationally.Lrecog- ; l
- nized. standards; whereinational' standards do,not exist, provisions;are.
Established'to: document the basis'for calibration. '
' n l; -12.2.8. When measuring and. testing: equipment'used"for.-inspection and' test?is:'
l-I
, found to'be-'outside of required' accuracy;11mitsi'at theitime;ofs cali s
.bration,; evaluations are conducted'to determine.theivalidity;of the: :
results obtained'since the most recent' calibration. LThe.!results of;~i-evaluations 'are' documented.- Retests or reinspection are performed on suspect items.1
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PagG.49-
-Rev'6' Date:L06/15/87-13.0 -HANDLING, STORAGE AND SHIPPING' 13.1- POLICY.
JActivities with the potential for causing contamination ~or deteriora-
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a tion that could adversely affect the ability of a safety-related item. to perform its intended safety! functions, andiactivities necessary,to: prevent undetected or uncorrectable damage are identified and. con-
-trolled. These activities include cleaning, packaging, preserving : Mg handling,' shipping and storing. Controls are. effected:through.the use:
of appropriate procedures and instructions implemented by suitably) Ltrained personnel.1 13.2 IMPLEMENTATION , q 13.2.1. The' authority and responsibility of personnel implementing'and assur-- ing the~ effectiveness of. material cleaning, handling," storing, packag - ing, preserving and shipping activities is described in'Section-1.0, ORGANIZATION. 13.2.2 ~ Precedures are used . to control the cleaning, handling,L atoring, . packaging, preserving and shipping of materials, components and. systems in accordance with design and procurement requirements., The6e-procedures include, but are notzlimited to, the;following functions:
- a. Cleaning, to assure . that . required cleanliness levels 'are achieved : q and maintained. ,
- b. Packaging and preservation,.co provide adequate protection'against? j damage or deterioration. When necessary,L these' procedures provide. 1 for special environments such as' inert gas atmospheres,. specific-moisture content levels and temperature. levels. ' q u
- c. Handling, to preclude damage or safety. hazards. ']
- d. Storing, to minimize the possibility.of' loss, damage to or deteri-oration of items in storage, including consumables.such as chemi - ;
I cals, reagents and lubricants. Storageiprocedures also provide
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methods to assure that specified shelf lives are not exceeded. i l i f
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~14.0. INSPECTION.-TEST AND.0PERATING STATUS ;
< I 14.1 POLICY- <
i Operating status of safety-related. structures, systems and components
'is indicated by tagging of valves and switches, or.by other specified means,.in such a manner as to prevent inadvertent operation. _The 1 status of. inspections and tests performed on individual items is ,
clearly indicated by markings and/or logging under' strict procedurals controls to prevent inadvertent bypassing of such inspections and- y tests..
.i
.14.2 IMPLEMENTATION '
~14.2.1 Organizational responsibilities are as described in Section 1.0,;
l ORGANIZATION. i i 14.2.2 For modification activities, including item fabrication,' installation. ,j
.and test, procurement documents,. service contracts and procedures j
specify the degree;of control required for the indication of'inspec-tion and test status of structures systems and components. < 14.2.3 Application and removal of inspection and~ welding stamps and of such- ,1 status indicators as tags, markings, labels,'etc, are controlled by- ' l plant procedures. 14.2.4 The sequence of inspections, tests and other operations important to safety are controlled by procedures. Changes in the approved: sequence . are subject to the~same review and approval as the; original. l 14.2.5 The status ' of nonconforming, inoperable or malfunctioning structures, - systems and components is clearly identified and documented'to' prevent' inadvertent use. i PD1081-0535B-QA06 1 q
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l l ' L5. 0 NONCONFORMING MATERIALS, PARTS.OR COMPONENTS 15.1 POLICY l Safety-related materials, parts or components that do not conform to' requirements are controlled in order to prevent their inadvertent use. Nonconforming items are identified, documented, segregated when ) practical and dispositioned. Affected organizations are notified of nonconformances. 1 15.2 IMPLEMENTATION 15.2.1 Items, services or activities that are deficient in characteristic, documentation or procedure, which render'the quality unacceptable or indeterminate, are identified as nonconforming.and any further_use is 4 controlled. Nonconformances are documented and dispositioned, and I notification is made to affected organizations. Personnel authorized. l to disposition, conditionally release and close out nonconformances j are designated. The authority and responsibility for the implementa- ]
'4 tion of activities related to the processing and control of noncon-forming materials, psrts or components are described in Section 1.0, l ORGANIZATION. !
l
- a. Nonconforming items are identified by marking, tagging or segre- i gating or by documented administrative controls. Documentation j describes the r.onconformance, the disposition of the nonconfor-mance and the inspection requirements. It also includes signature q approval of the disposition. t
- b. The Nuclear Assurance Department reviews the disposition of i nonconformances, and documents concurrence with the acceptance, 1 conditional release or repair of a nonconforming item,
- c. Items that have been repaired or reworked are inspected and tested in accordance with the original inspection and test requirements or alternatives that have been documented as acceptable and concurred with by the Nuclear Assurance Department.
- d. Items that have the disposition of " repair" or "use as is" require documentation justifying acceptability. The changes are recorded to denote the as-built condition.
15.2.2 Dispositions of conditionally released items are closed out before the items are relied upon to perform safety-related functions. 15.2.3 Prior to the initiation of preoperational testing on an item, all nonconformances are corrected or dispositioned and evaluated fur impact upon the item or the testing program. PD1081-0535B-QA06
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- iden'tify,qualityftrends. Trend. reports, which. highlight;significant; '
yj results,Jare. issued" periodically to' upper management:for, review andi e
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- 16.0 CORRECTIVE ACTION-16.1 POLICY Con'itions d adverse to quality of safety-related structures, systems, components or activities,: such as failures, malfunctions, deficien-cies, deviations, defective material'and equipment and nonconformances-aret identified promptly and corrected as'soon as practical. -
y :j For significant conditions. adverse to quality,-the cause"of-the- I condition is determined and corrective action is taken to: precludei ' repetition. In these cases,.the. condition, cause'and. corrective'
~
action taken is documented and reported to appropriate levels of; l management for review and assessment.. 16.2 IMPLEMENTATION 16.2.1 The responsibility'and' authority.for the control'Of' corrective action 1 , are described in Section 1.0, ORGANIZATION. l 16.2.2 Controls are establin.ad to assure that ' conditions adverse to quality ] are identified and do-aumented and that appropriate remedial: action is taken. l 16.2.3 For significant ccnditions adverse,toLquality,.necessary. corrective. action is promptly determined and recorded. Corrective ~ action in-: cludes determining the cause and extent of the condition, and taking . appropriate action to preclude similar problems in the future'. The H controls also assure that corrective action is implemented (in altimely "j manner. The Nuclear Assurance Department reviews and documents I concurrence with actions,taken to prevent recurrence;of.significant' conditions adverse to. quality, performs follow-up:to verify proper. implementation and' determines if additional action-(such.assaudit or. surveillance) is necessary to verify.the effectiveness of action (s) . taken. q
,i LPD1081-0535B-QA06 ,
._____m.___ ________m _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ _ . _ _ _ _ . . _ _ ._ m__ . _ _.__.._ _ _ . . ' _ ._
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Page 57 Rev 6 Date: 06/15/87 17.0 QUALITY ASSURANCE RECORDS 17.1 POLICY Records that furnish evidence of activities affecting the~ quality of safety-related structures, systems and components are maintained. They are accurate, complete and legible.and are protected against damage, deterioration or loss. They are identifiable.and retrievable. 17.2 IMPLEMENTATION 17.2.1 Responsibilities for the identification and control of QA records are described in Section 1.0, ORGANIZATION. 1 17.2.2 Documents that furnish evidence of activities affecting quality are generated and controlled in accordance with the procedures that govern those activities. Upon completion, these documents'are considered records. These records include:
- a. Results of reviews, inspections, surveillance, tests, audits and 4 material analyses
- b. Qualification of personnel, procedures and equipment
- c. Operating logs
- d. Maintenance and modification procedures and related inspection results
- e. Reportable occurrences
- f. Records required by the plant technical specifications
- g. Nonconformance reports
- h. Corrective action reports
- 1. Other documentation such as drawings, specifications, procurement documents, calibration procedures and reports 17.2.3 Inspection and test recordt contain the following where applicable:
- a. A description of the type of observation
- b. The date and results of the inspection or test
- c. Information related to conditions adverse to quality
- d. Inspector or data recorder identification
- e. Evidence as to the acceptabil1ty of the results PD1081-0535B-QA06
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- f. " Action taken.to resolve ~any diderepancies notsd ,
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i7;2.4 When.:al document becomes a: record; it is designated;as: permanent; or.: ? nonpermanent and then transmitted'to) file. Nonpermanent _-records have specified recentionDcimes... Permanent records-are maintained for7 the '.. g life lof?the item.- ,
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'17.2.5 , Temporary storage of~ completed'docume'ntsi during processing 'to';become , d, records'is in special fire-resistant' file; cabinets.-
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'17.2.6 Only authorized personnel may is'sueTeorrections;or supplements:to- " #
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17.2.7.1 Traceability'between the record:and.the' item or' activity _to-_which:it' ,
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tp 17.2.8' Records are stored.in~ remote, dual facilities toiprevent damage E 7= ,Q
' deterioration'or: loss due to natural or unnatural causes..MRecords~
that can only be stored as originals, such as radiographs'and some strip charts are retained in a four-hour fire -rated. f acility.
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21 j]r 1j 18;0: A DlTS- g w a 18'.1 = POLICY-L > 4
>W A comprehensive: system of' audits isicarried'out to provide-1ndependent..
evaluation of-compliance'with and the'effectivenessiof the. Quality ., Assurance Program,, including those elements tof th6 program implemented
- d by suppliers and contractors. 7 Audits are.. performed ~in~accordance with, written procedures lor. checklists by. qualified. personnel not,having u ..
?j
_ direct responsibilityRin the ' areas audited. . Audit result's areadocu ' h mented=and are reviewed'by management-.' Follow-up action is takeni ' where indicated. '
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]i 18.2 IMPLEMENTATION ,1 N
18.2.1 Responsibility and' authority for the audit program is described 1in
. :1 L Section31.0, ORGANIZATION.' '
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' i uj 18.2.2 Internal audits are performed in accordance.with e'stablished schedules: _ that reflect the. status.and importance to safety-of,the' activities i being performed. .All' areas where the requirements'of'10 CFR 50 M
]
Appendix B apply are audited within a period:of:two years.; The.: l following are audited at least once every 12-months: h
- a. Conformance of facility operations.with applicable conditions'of.: ,1 L the technical specifications'and license- j l
- b. The performance, training and qua11fications:ofqthe.f'a'111ty.
c' staff'
- c. Controls over plant modifications.: including 'the f requency, effectiveness and technical adequacy'of-the use of' supervisors as. >
( design verifiers, q 18.2.3 Audits of suppliers'and contractors _are scheduled. based on the status
~
and safety importance of the act1vities'being. performed and.aie- ._ g initiated early enough to assure effective quality. assurance d: ring: -' design, procurement, manufacturing, construction, installation, inspection and testing. .; 18.2.4 Principal contractors are required to audit their suppliers systemat-ically in accordance with the foregoing scheduling criteria. 'N 18.2.5 Regularly scheduled audits are supplemented by sp~ecial audits;when: significant changes are made in'the Quality. Assurance Program,Lwhen it is suspected that quality is in jeopardy or when an independent-assessment of program effectiveness is considered nec'essary. ,c 18.2.6 Audits include an' objective evaluation of. quality-relatedapractices,- i procedures , Instructions, activities and ; items"and. review of documentis ., and records:to confirm that the QA' Program is effective and prop'rly' e " implemented.
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Page 60 Rev 6
'Date: 06/15/87-18.2.7 Audit procedures and the scope, plans, checklists and'resdits of.
individual audits are documented. 18.2.8 Personnel selected for auditing assignments have. experience or are' given training commensurate with the needs of the audit and have no direct responsibilities in the areas audited. 18.2.9- Audit data are analyzed by the Nuclear Assurance Department. The resulting audit reports. identify any quality deficiencies and assess the effectiveness of the QA' Program in the area audited. LThe reports are distributed to the-responsible management of both the audited ~and-auditing organizations. 3 18.2.10 Management of the audited organization identLfies and takes appropri ate corrective action to correct observed deficiencies and to prevent recurrence of any sid nificant conditions adverse to quality. Follow-up is performed by the Nuclear Assurance Department to ensure that the appropriate corrective action is'taken and.is effective. Such fol-low-up includes reaudits when necessary. .) i 18.2.11 Audits of operational nuclear safety-related facility ac'tivities shall' y be' performed under the cognizance of Nuclear Safety Board (NSB). } I i i l l I i l i .PD1081-0535B-QA06
i Page 61' Rev 6 Date:-06/15/87.
/
QAPD MANUAL APPENDIX A, PART 1 REGULATORY GUIDE AND ANSI STANDARD COMMITMENTS The Consumers Power Company Quality Assurance Program complies with'the
. regulatory position of the Regulatory Guides referenced in this appendix as modified by the exceptions stated in Part 2.
- 1. Appendix B to 10 CFR, Part 50, Quality Assurance Criteria for Nuclear Power Plants and. Fuel Reprocessing Plants. ,
- 2. 10 CFR, Part 50.55a - Codes and Standards.
- 3. Regulatory Guide 1.8 - (9/80 Draft) - Personnel Qualification and Train-ing - Endorses ANSI /ANS 3.1 - (12/79 Draft).
- 4. Regulatory Guide.l.26 - (2/76, Rev 3) - Quality Group Classification,;and Standards for Water , Steam , and. Radioactive-Waste-Containing Components
! of Nuclear Power Plants.
- 5. Regulatory Guide 1.29 - (9/78, Rev. 3) - Seismic-Design Classification.
- 6. Regulatory Guide 1.30 (Safety Guide 30) - (8/11/72) - Quality' Assurance Requirements for the Installation, Inspection, and Iesting of Instrumen-tation and Electrical Equipment - Endorses ANSI N45.2.4 - 1972.
- 7. Regulatory Guide 1.33 - (2/78, nev 2) - Quality: Assurance Program Re- .)
quirements (Operation) - Endorses ANSI N18.7 .1976.-
- 8. Regulatory Guide 1.37 - (3/16/73) - Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.1 - 1973.
- 9. Regulatory Guide 1.38 - (5/77, Rev 2) - Quality Assurance Requirements -
for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.2 - 1972.
- 10. Regulatory Guide 1.39 - (9/77, Rev 2) - Housekeeping Requirements for Water-Cooled Nuclear Power Plants - Endorses ANSI N45.2.3 - 1973.
- 11. Regulatory Guide 1.58 - (9/80, Rev 1) - Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel - Endorses N45.2.6 1978.
Regulatory Guide 1.64 - (6/76, Rev 2) - Quality Assurance Requirements 12. for the Design Of Nuclear Power Plants - Endorses N45.2.11 - 1974,
- 13. Regulatory Guide 1.74 - (2/74) - Quality' Assurance Requirements, Terms and Definitions - Endorses ANSI N45.2.10 -'1973.
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14$<-RegulatoryGuide1.88-(10/76',.Revj2);-Collection':Stosage,andMainte-; , ,
- nance of. Nuclear Power- Plant - Quality Assurance - Records -l Endorses': N45.2.9i ,
- 1974.
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' 15'. ' Regulatory Guide 1.94 L(4/76,'.Rev'.1): .
Quality Assuranc'e Requirements I , l for Installation, Inspection, Land Testing ofsStructural Concrete and; - d Structural Steel During the Construction Phase of Nuclear, Power Plants? . J ; ) Endorses ANSI N45.2.5 - 1974. ' 1 ?' i
- 16. Regulatory Guide' 1.116 -' (5/77) . - Qual'ity Assurance' Requirements 1for; Installation, Inspection, and Testing of Mechanical Equipment andL ' '
Systems.'- Endorses ANSI N45.2.8 - 1975. 17 .' Regulatory Guide 1.123 .(7/77, Rev.;-1) ' Quality Assurance Requirements. , for Control'of Procurement of-Items and-Services:for: Nuclear. Power. Plan's t - Endorses N45.2.13 - 1976. l l 18. Regulatory Guide 1.1.,4 - (9/80, Rev 1) - Auditing'of? Quality: Assurance-Programs for Nuclear Power Plants'- Endorses'N45.2.12. 1977. ! 19. Regulatory' Guide' 1.146 - (8/80) - Qualification of Quality: Assurance:
- Program Audit Personnel for Nuclear Power Plants.--cEndorses'.N45.2.23:-
. 1978. .
m
- 20. Branch Technical Position ASB9.5.1 .(Rev,1)' Guidelines?for Fire Protection-for Nuclear Power Plants.
- 21. 10CFR50, Appendix R' Fire Protection Program for Nuclear Power Facilities-Operating Prior to January 1,1979,, Sections ;III G. , III J./andLIII 0. d m 1 4
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, :]:l QAFD MANUAL . ]
. APPENDIX A, PART'2: ., ., .{
CP C0 EXCEPTIONS TO OPERATING PHASE ~ STANDARDS 1 a AND REGULATORY GUIDES :
.l q
- 1. General ,
Requirement CertainRegulatorpGuides.invokeorimplyRegulatoryGubesandstan-- dards in addition to the, standard each'primarily; endorses. ,)
' l Certain.ANSl Standards invoke or. imply additional,standar'ds.
Exception / Interpretation- R The CP Co commitment refers to the' Regulatory Guides)and ANSI Standard ( specifically identified in Appendix A, Part 1.J Additional Regulatory; j Guides, ANSI Standards and similar documents implied'or referenced <ini ' those specifically identified are not part of this-commitmenc. q q 1 1
- 2. N18.7 General l
'1 Exception / Interpretation W
Consumers Power Company has established bo' t h an organizational unit' and a standing committee for independent review activities.- Together they form the independent review body. ' The standard numeric and. qualification requirement may not be met'by each group individually. Procedures will be establishedito specifylhow ' ' each group will be involved in review activities. l 2a. N18.7, Sec 3.4.2 3 q Requirement "The Plant Manager shall'have'overall responsibility for the. execution of the administrative controls and quality assurance. program at the ; plant to assure safety." Exception / Interpretation ., Since CP Co has more than one' nuclear unit and more than one organiza ' i tion providing services o chese units, overall~ responsibility cannot be centralized in a single on-site position. . Instead, ' responsibilities > are as designated.within the QA Program-Description. .
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;specifiedjin'both' number:.:and technical ~ disciplines-andLahallicollec h
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a; ,- ' - -' Q- 'f.b' t; Exc'eption/ Interpretation l l Lsa i( w'.
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. b r Nuclear Safety--- Nucl' ear' Assurance 1 Department'w'ill.notihaveimembersi
.specified by:. number:or by?technicalidisciplinesLandfits.memb'ersima'y noF li 'have:the experience'and(competencelrequired to: review problemsfin allb , .
q' , . . areas listed;in.chis section;'however 6the; Nuclear: Safety Board?(NSB)P
- L ' ' ' ' ' '
1will be specified b'y number and discipline :- g y
. , . ' n The NSB'will not specifically/ includea memb'eriquallfiddfin NondAstruc Y '
tive Testing but will use qualified technical consultants!.co, perform: g.,
'this'functionasdeterminednecessary/by.theNSB: Chairman.L.
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, a Requirement S 4
l" "When a standing > committee 1s' responsible foriche? independent reviewL" ',' . program,- it shall be' composed lof- no lessL than five; persons; of L whoin'no? l more than a minority are members [of thel onsite operating organization.) ' l g, Competent alternatives are permitted;ifEdesignatedLin advance. JThe'use= of alternates shall.be restricted to' legitimately.~ absences'ofb 4 principals." , m ,. l
- G l'
Exception / Interpretation
.' v
-See item 2. General ,
l 2d. Sec 4.3.3.1
-Requirement 4
E "... recommendations...'shall be disseminated'promptly to appropriate l members of management having responsibility.'in the' area' reviewed."" (: Exception / Interpretation t-l 1, Recommendations made as a result o'f reviewstwilligenerally;be conveyedi~ co the onsite or offsite standing committee.. - Procedures will,be' l maintained'specifying how recommendations'are tofbe considered.- , a; ,
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Page 65 Rev 6 Date: 06/15/87 2e. Sec 4.3.4 Requirement "The following subjects shall'be reviewed by the independent. review body:" Exception / Interpretation Subjects requiring review will be as specified in the Plant Technical Specifications. 2f. Sec 4.3.4(3) Requirement
" Changes in the Technical Specifications or license amendments relating to nuclear safety are to be reviewed by the independent review body prior to implementation, except in those cases where the change is identical to a previously reviewed proposed change.
Exception / Interpretation The Nuclear Safety Board (NSB) will not review Technical Specification l Changes after NRC approval prior to' implementation. The basis for this position is that NSB reviews all Technical Specification changes prior to submittal to the NRC. 2g. Sec 4.4 Requirement "The onsite operating organization shall provide, as part of the normal duties of plant supervisory personnel, ..." Exception / Interpretation Some of the responsibilities of the onsite operating organization described in Section 4.4 may be carried out by Nuclear Safety -_NAD as-described in plant technical specifications. 2h. Sec 4.5 Requirement ,
" Written reports of audits specified in ANSI N18.7 shall be reviewed by the independent review body and by appropriate members of Management including those having responsibility in the area audited."
PD1081-0535C-QA06 ,
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- Page.661 y Rev'64 ! 1 D Date:.0$/15/87 Exception / Interpretation The independent. review body reviews or arranges lfor reviews.of!tho'se c
audits over which it has cognizance, in accordance with'the' individual' plant Technical Specifications. . o Some'of the-QA audits. required-during the'operationaliphaseLare.in, ,
. w areas other than.those' requiring independent review in accordance with
~
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ANS1 N18.7, Section 4.3.4.
- 21. Sec 5.2.1 Requirement "The responsibilities and authorii:1es of the plant operating personnel. y shall be delineated." ' :)y Except1on/ Interpretation-On-site personnel not directly associated with operating activities, as defined in' ANSI N18.7, Section 2.2, are'not considered to be operating personnel.
, l 2j . Sec 5.2.'2-Requirement
" Temporary changes, which clearly do not change the intent of thei approved procedure, shall as a minimum be approved by two members of. ~1 the plant staff knowledgeable in the areas affected by thefprocedures. i At least one of these individuals shall'be the supervisor in charge of-t the shift and hold a senior operators license on-the unit affected."
Exception / Interpretation CP Co considers that this requirement applies,only to procedures-identified in plant technical specifications. Temporary changes.to these procedures shall be approved as described in plant: technical ' specifications. 2k. Sec 5.2.6 Requirement "In cases where required documentary evidence is not available,'the - associated' equipment or materials must be' considered nonconforming in t accordance with-Section 5.2.14. 'Until suitable documentary evidence.is-available to show the equipment or material is in conformance, affectedf ; systems shall be considered to be, inoperable.and reliance shallinot be ' placed on such systems.to fulfill their intended safety; functions."J [ PD1081-0535C-QA06 F
-Page 67 Rev 6 Date: 06/15/87.
Exception / Interpretation CP Co initiates appropriate. corrective action when it is discovered
'that documentary evidence does not exist for a test or inspection which
~
is required to verify equipment acceptability.- This action includes a y technical evaluation of the' equipment's operability status. '!
- 21. Sec 5.2.8 Requirement "A surveillance testing and inspection program...'shall include the establishment'of a master surveillance schedule' reflecting the status of all planned inplant surveillance tests and inspections." i Exception / Interpretation i
Separate master schedules may exist for different programs such as IS1, Pump and Valve Testing and Technical Specification Surveillance Testing. 2m. Sec 5.2.13.1 Requirement "To the extent necessary,' procurement documents shall require suppliers to provide a quality assurance program consistent with the pertinent requirements of ANSI N45.2 - 1971." Exception / Interpretation To the extent necessary, procurement documents require that the suppli-er have a documented quality assurance program consistent with the
~
pertinent requirements of ANSI N45.2 or other nationally recognized codes and standards. 2n. Sec 5.2.13.2 ' Requirement ANSI N18.7 and N45.2.13 specify that where required by code, regulation or contract, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of'such items. Exception / Interpretation The required documentary evidence is available at the site prior to _ ' use, but not necessarily prior to installation. This allows installa-tion to proceed while any missing documents are being obtained,;but precludes dependence on the item.for safety purposes. PD1081-0535C-QA06 __m____
Page 68
-Rev 6
- Date: 06/15/87 2o. Sec 5.2.16 Requirement Records shall be made and equipment' suitably marked to indicate cali :
bration status. Exception / Interpretation See Item 9b. ij 2p. Sec 5.3.5(4)- ' Requirement This section requires that where_ sections:of documents such as vendor- Lj manuals, operating and maintenance instructions'or drawings are incor-porated directly or by reference into a maintenance procedure, they shall receive the same level of review and approval as operating. procedures. l l Exception / Interpretation Such documents are reviewed by appropriately qualified personnel prior-l to use to ensure that, when used as instructions, they provide proper-and adequate information to ensure the required quality of work. Maintenance procedures which reference these documents receive the same level of review and approval as operating procedures. 3a. RG 1.33, Sec C4a i l Requirement The results of actions taken to correct deficiencies that affect nuclear safety and occur in facility equipment, structures, systems or method of operation are to be audited at least once per six months. Exception / Interpretation The corrective action system trend reports are reviewed by the indepen-l dent review body twice annually. In addition, the corrective action l system is audited at least once every two years with additional audits f and investigations performed as indicated necessary by the trend report f reviews. l l 4a. ANS 3.1, General s Exception / Interpretation I The CP Co commitment in this QA Program Description to ANS 3.1 is 5 limited to those requirements which apply to the training and qualifi-cation of personnel performing QA/QC functions. PD1081-0535C-QA06 L
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.Sa. .RG 1.8, C.3.1, General , Exception / Interpretation The CP Co commitment in this'QA-Program De'scription-is'11mited to.those
)
1 requirements'which apply to the training.and qualification of personnel.
' performing QA/QC functions. l 5b. C1.2.2 Requirement "When an individual'is hired to temporarily, function as a' plant employ-ee, such as for contracted services, evidence of previous. education, !
experience and training should.be provided and reviewed by the'appro- j priate professional-technical. group leaders. :The appropriate group 1 leaders should then determine'the content for'that individual's train-ing, including plant-specific training. -As a minimum, each individual-should receive General Employee Training." ; Exception / Interpretation- ' CP Co understands that this. requirement. applies both to CP Co' employees from another site and to contract personnel who are temporarily as-signed to a nuclear power plant either as replacements for' regular. employees or to augment the staff during outages.' CP Co employees so assigned possess the required qualifications as a prerequisite.to the assignment and the review is waived. The" qualifications.of contract personnel are reviewed and arrangements-made for any necessary train- , ing. Temporarily assigned personnel requiring unescorted access- t receive the site general orientation as embodied in General Employee Training. 6a. Ny .2.1, Sec 3.1 Requirement f i N45.2.1 establishes criteria for classifying items into " cleanness levels," and requires that items be so classified. Exception / Interpretation Instead of using the cleanness level classification system of N45.2.1, the required cleanness for specific items and activitle's..is' addressed on a case-by-case basis. I Cleanness is maintained, consistent with the work being performed,'so ' as to prevent the introduction of; foreign material. As.a minimum, cleanness inspections are performed prior to system closure. Such inspections are: documented.
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6b. .Sec'5"
. Requirement
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" Fitted and tack-welded' joints (which will not be 1mmediately' sealed!byL welding) shall'be wrapped with polyethylene or other nonhalogenated .
plastic film;until the. weldscan be completed."- Exception / Interpretation , il CP.Co sometimes uses.other nonhalogenated. material, compatible with the parent material,-since plastic film.is-subject to' damage:and doesLnoti always provide adequate protection. 'o 7a. N45.2.2', General' ' l Requirement' y N45.2.2'estab11shes requirements and criteria for classifying; safety-related items into protection levels. ,; Exception / Interpretation l q Instead of classifying safety-related' items.into protection levels,. controls over the packaging, shipping, handling and. storage of"such j items are established on a case-by-case basis with 'du'e :'regardifor the item's complexity, use and sensitivity to damage. Prior to'installa-tion or use, the items are inspecte'd and' serviced as'necessaryLto . assure that no damage.or deterization exists which could affect their function.- 7b. Sec 2.4 l Requirement
".. 0ffsite inspection, examination or'. testing shall'be audited and' monitored by personnel who are qualified in accordance with N45.2.6."
l Exception / Interpretation-Offaite inspection... examination or testing activities are' audited or-inspected by person's qualified and certified in accordance with ANSI N45.2.23-1978, as endorsed by Reg Guide 1.146,.or ANSI N45.2.6'..as ,- endorsed,by Reg Guide 1.58, respectively._ Monitoring activities'not' involving audit or' inspection may be-conducted by persons' trained and .. qualified to effect1vely carry out such tasks, but not'necessarily. Jl certified to either ANSI G45.2.23.or N45.2.6.-
.)
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Page 71 Rev 6 -
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7 c .- Sec 3.9 and Appendix A 3.9 l. Requirement "The item and the outside of containers shall be marked." (Further criteria for marking and tagging are given in the appendix'.) Exception / Interpretation
-i These requirements were' originally written for items packaged.and; ;
l j shipped to construction projects. - Full compliance is not always necessary in the case of items shipped to operating plants and may, in j ' i some cases, increase the probability of damage to.the item. The requirements are implemented to the extent necessary to assure trace- 1 ability and integrity of the item.
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7d. Sec 5.2.2 [ Requirement "The inspections shall be performed in an area equivalent to the level of storage." Exception / Interpretation Receiving inspection area environmental controls may be less stringent than storage environmental requirements for an item. However, such' inspections ar. performed in a manner and in an environment which do not endanger the required quality of the item. 7e. Sec 6.2.4
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Requirement "The use or storage of food, drinks and salt tablet dispensers in any storage area shall not be permitted." Exception / Interpretation Packaged food for emergency or extended overtime use.may be stored in material stock rooms. The packaging' assures that materials are not contaminated. Food will not be "used" in these areas. 7f. Sec 6.3.4 l Requirement "All items and their containers shall be plainly marked so that they are easily identified without excessive hand 11ng or unnecessary opening i of crates and boxes." PD1081-0535C-QA06
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1 '7g. 'Sec 6.41:
. 4 Requirement "Inspectionsandexaminationsshall'beperformedand(documented'onal periodic basis to assure thatithesintegritys o'f theiitem and11ts-
- container...is being maintained."'
Exception / Interpretation Je The' requirement implies that all inspections"addLexaminations 'f? o items?
'in' storage are to be performed'on the' same sche'dule..LInstead, the:
inspections and' examinations are! performed'and; documented!in accordance , with material-storage procedures:which identify the characteristics tof be; inspected and include'the required frequencies. .These procedures; are based on technical considerations which recogn'ze'thatiinspections1 i and frequencies needed vary from. item to item.- 8a. N45.2.3, Sec 2.1 Requirement
. .. . j Cleanness requirements for housekeeping l activities shall be established: j on the basis of five' zone. designations.. ,
l Exception / Interpretation i Instead of the five-level zone designation' system referenced in ANSIc N45.2.3, CP Co bases its controls over housekeeping'activitiesDon?a j consideration of what is necessary and appropriate for the a'ctivity 1 involved. The controls are effected.throu'gh procedures or instructions which, in the case of maintenance or modifications work, areLdeveloped .; on a case-by-case-basis. Factors considered'in' developing the proce- : dures and instructions include clean 11 ness' control,. personnel safety - " fire prevention and protection, radiation control.and security..The procedures and instructions'make use of-standard. janitorial and worka practices to the extent possible. However, 1'n preparing.these.proce-dures, consideration'.is also jriven. to the recommendations 'of Section 2.1 of ANSI N45.2.3. I
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'I 9a. N45.2.4, Sec 2.2 o 1
,G 'y Requirement Section 2.2 establishes prerequisites d.
installation, inspection and testing of which must be met'heforE,the
' instrumentation and electrid ,h1(
equipment may proceed. -These' prerequisites include.personneliqualifi- j cation, control of design, conforming andiprotected materials, and. , I, availability of specified documents. ;
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Exception / Interpretation During the operations phase, this requirement is' considered. to be applicable,to modifications and initial start-up of e.tectrical equip-tee nt . For routine or periodic inspection and testing, he prerequisite .. condirions will be achieved as necessary. E l
'l 9b. Sec 2.2(5) {
l b j Requirement ' q
.)' L Sect;1on 2'.2(5) of ANSI N45.2.4 lists documents which are to be avail- l ab W at the construction site. '
Exception / Clarification , 1 J All of the d6:usents listed are not necessarily required at the , plant' site for installation and testing. CP Co assures that thTy are avail-able to the site as necessary, ; 9c. Sec 6.2.1 . Requirement
" Items requiring calibration shall be tagged or. labeled on completion, dl '
Indicating date of calibration and identity of person that performed the calibration." Exception / Interpretation ' l Frequently, physical size and/or location of Installed Plant Instru- , 4 mentation (IPI) mandates that calibration labels or tags nc,t be affixed 1 to IPI. Instead, each instrument is uniquely identified and A.s trace-able to its calibration record. i A scheduled calibration program assures that each instrument's.c.alibra- ~ tion is currcnt. , PD1081-0535C-QA06
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Dar,e: 06/15/87 10a. N45.2.5, Sec 2.4 t i l-Requirement
Persons charged with engineering managerial responsibility of the .
inspection and testing organization at the' site in either'a resident or ' non-resident-capacityshallbecertifiedforLevelIIIc7pability." Exception / Interpretation f This standard (N45.2.5) was written for the construction phase of nuclear power plants; as such, it presumes significant activity in the , areas of concrete and structural steel which do not generally occur'at an operating plant. _At Consumers Power, persons having engineering managerial responsibility for inspections and tests
- may la, certified,i to Level III, or may meet other qualification criteria estab'11shed for i,, K the position, including, but not limitedLto, nuclear power'ind manage- f ment experience. For major modifications involving significant con- // <
crete or structural steel work, the services.of a properlyjleclifie'd " :- ., Level III individual will be obtained in at least an advisory capacity. ..
*within the scope of N45.2.5 ,
( l 10b. N45.2.5, Sec 2.5.2 Requirement "When discrepancies, malfunct1ons or inaccuracies in inspection and-testing equipment are found during calibration, all items inspected with that equipment since the last previous calibration s}}all'be 3 , considered unacceptable until an evaluation has been made'by the "t responsible authority and appropriate action taken." l ;3 J% Exception / Interpretation *
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CP Co uses the requirements of N18.7, Section 5.2.16, rather than N45.2.5, Section 2.5 2. The N18.7 requirements are more applicable to an operating plant. l 10c. Sec 5.4
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, Requirement
" Hand torque wrenches used for inspection shall be contro11e'd and must-be calibrated at least weekly _and more often if deemed necessasy.
)' f Impact torque wrenches used for inspection must be calibrated at lea 3t twice daily."
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, TorquewrenchesarecontrolledasmeasuritCrpdtdstequipment in j accordance ylth ANSI N18.7, Section 5.2.16. Calibration intervals are based.onuseandcalibrationhistoryrather/,hanasperN45.2.5 t lla. N45.2.6, Sec 1.2
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, Thi requirements of this standard apply to personnel who perform
? j "inspedicjs, examinations, a.M > tests during f a rication prior to and f during re'c eipt of items at theiconstrhdtion' s.', ep, during construction, L duringpreoperationalandstart-upyestingandduringoperacional.
phases of nuclear power p ants." i
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Except:p3 / Interpretation f ,( 3a) g Qualif%% tion of phant puGabandfo 'are involved. with testing associ-ated with pIant chation is priditsd'in specific plant , specifications. In ah'. ')on, p s elparticipaty2:dininsp,ectinat6s[lugwhotake 7 l data er mans'c. ervations, where special training is not required to peq .N fnh function, need not be qualififf in pcce,tdance with ANSI N45.{/.ti but need moly be trained to the extent necessary to perform the assigned fungtfon. i fi 12a. RG 1.58. Edc C.1 , 6 R_eguh eme;Lt, J "However, for qualificqtfon of personnel (1) who approve reoperation-al, start-up and operegional test precedures and test results and.(2)
/< who direct or supervise the conduct df individual preoperational.,'
/ start-up and operational tests, thei uidelines g contained in Regulatory Guide 1.8, Personnel Selection and Training, chould be' followed in lieu
[ of the Guidelines of ANSI N45.2.6 - 1978." Excep tf c d/ interpretation' CP Co endorses this position, as also stated in lla, above, except that
; d/fr,lte support organizations involved in testing may apply ANSI N49.2.6. Some of these departments have already developed their qualification prog: jams based on ANSI N45.2.6, and provide serv 14cs
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Page 76 Rev 6 Date: 06/15/87 12b. Sec C.5 Requirement "In addition, the individual should be capable of reviewing and approv-ing inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examina-tion and test _ objectives." Exception / Interpretation While a Level III individual should be capable of reviewing and'approv-ing inspection, examination and testing procedures.and of evaluating the adequacy of such procedures to accomplish the inspection, examina-tion and test objectives, this is not construed by CP Co as requiring personnel who review, approve or evaluate such procedures to be certi-fled as Level III personnel. 12c. Sec C.6 Requirement "Since only one set of recommendations is provided for the education and experience of personnel, a commitment to comply with the regulatory
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position of this guide in lieu of providing an alternative to the recommendations of the standard means that the specified education and-experience recommendations of the standard will be followed." Exception / Interpretation The education and experience recommendations given in ANSI N45 2.6, Section 3.5 will be treated as such, since our qualification and certification program is based upon these recommendations, and more significantly, upon satisfactory completion.of capability testing prior to certification. It is our position that a candidate should not be required to be a high school graduate or have earned the GED equivalent for the above reasons. 12.d Sec C.10 Requirement "Use of the measures outlined in these actions to establish that an individual has the required qualifications in lieu of required educa-tion and experience should result in documented evidence (ie, procedure and record of written test) demonstrating that the individual indeed does have comparable or equivalent competence to that which would be gained from having the required education and experience." PD1081-0535C-QA06
Page 77 l l Rev 6 Date: 06/15/87 Exception / Interpretation We will maintain documented objective evidence that demonstrates that an individual does have " comparable" or " equivalent" competence to that which would be gained from having the required education and experi-ence. However, this may take the form of documentation other than
" procedures and records of written test" such as documentation of' oral-tests and on-the-job performance demonstrations.
12e. General Imposition of these Regulatory Guides on CP Co suppliers and subtier suppliers will be on a case-by-case basis depending upon the item or service to be procured. 13a. N45.2.8, Sec 2.7 Requirement Section 2.7 requires that personnel performing inspection and test activities be qualified according to ANSI N45.2.6. Exception / Interpretation See Exception / Interpretation lla and 12a. Test personnel who are part of the plant staff need not be certified to N45.2.6, provided they meet applicable qualification criteria of plant Technical Specifications. 13b. Sec 2.9 Requirement Section 2.9 establishes prerequisites which must be met before the installation, inspection and testing of mechanical equipment may proceed. These prerequisites include personnel and procedure qualifi-cation, control of design, material selection and fabrication, and availability of specified documents. Exception / Interpretation During the operations phase, this requirement is considered to be applicable to modifications of c.echanical equipment. For routine or periodic inspection and testing, the prerequisites will be achieved as necessary. 13c. N45.2.8, Sec 2.9e l Requirement Section 2.9e of N45.2.8 lists documents relating to the specific stage of installation activity which are to be available at the construction site. PD1081-0535C-QA06
Page 78 Rev 6 Date: 06/15/87 Exception / Interpretation All of_the documents. listed are'not necessarily required at the plant site for installation and testing. CP Co assures that they are avail-able to the site as necessary. I 13d. Sec'2.9e Requirement Evidence that engineering or design changes are documented and approved shall be available at the construction site prior to installation. Exception / Interpretation Equipment may be installed before final approval of engineering or
' design changes. However, the system is not placed into service until-such changes are documented and approved.
l 13e. Sec 4.5.1 Requirement
" Installed systems and components shall be cleaned, flushed and condi-tioned according to the requirements of ANSI N45.2.1.- Special consid-eration shall be given to the following requirements:...."
(Requirements are given for chemical conditioning, flushing and process controls.) Exception / Interpretation Systems and components are cleaned, flushed and conditioned as deter-mined on a case-by-case basis. Measures are taken to help preclude the need for cleaning, flushing and conditioning through good practices during maintenance or modification activities. 14a. N45.2.9, Sec 5.4, Item 2 Requirement Records shall not be stored loosely. They shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers. Steel cabinets are preferred. Exception / Interpretation Records are suitably stored in steel file cabinets or on shelving in containers. Methods other than binders, folders or envelopes (for example, dividers) may be used to organize the records for storage. PD1081-0535C-QA06
Page'79 Rev 6 Date: 06/15/87 14b. Sec 6.2 Requirement "A list shall be maintained designating those personnel who shall have access to the files." Exception / Interpretation Rules are established governing access to and control of files as provided for in ANSI N45.2.9, Section 5.3, Item 5. These rules do not always include a requirement for a list of personnel who are authorized access. It should be noted that duplicate files and/or microforms exist for general use and backup. 14c. RG 1.88, C2 Requirement "Two methods of protection of quality assurance records from the hazards of fire are described in Subdivision 5.6 of ANSI N45.2.9-1974. NFPA No 232-1975 . . . also contains provisions for records protection equipment and records handling techniques that provide protection from the hazards of fire. This standard, within its scope of coverage, is considered by the NRC staff to provide an acceptable alternative to the fire protection provisions listed in Subdivision 5.6 . . . When NFPA 232-1975 is used, quality assurance records should be classified as NFPA Class 1 records . . ." Exception / Interpretation CP Co adheres to ANSI N45.2.9-1974, Subdivision 5.6 for the facility for permanent storage of non-duplicated records. Temporary storage of documents after completion and during processing as records is in file cabinets selected in accordance with provisions of NFPA 232-1975 for Class 1 records (usually NFPA Class C, I hour or UL-Class 350). 15a. RG 1.64, C2 Requirement "Regardless of their title, individuals performing design verification : should not (1) have immediate supervisory responsibility for the individual performing the design...." PD1081-0535C-QA06
Y Page 80 Rev 6' Date: 06/15/87 Exception / Interpretation CP Co follows the requirements of ANSI N45.2.11-1974, Section G.1,.and the guidance of Section 3E4(a) of the Standard Review Plan, with'the exception that use of supervisors as design verifiers may be controlled by a procedure instead of individual?.y approved in advance'in each case (see Section 3.2.9, herein). .This i.pproach is necessary to allow small organizational units (having limited numbers of technically qualified staff, or having.che only technics.11y qualified staff available in.the Company)'the flexibility,needed to most effectively accomplish their assigned tasks. 16a. RG 1.144, Sec C3a(1) Requirement This section requires that for operational phase activities, RG 1.33
" Quality Assurance Program Requirements (Operations)" are to be fol-lowed. One of the RG 1.33 requirements is that the results of actions taken to correct deficiencies-that affect nuclear safety and occur.in facility equipment, structures, systems, or method of operation are to-be audited at least once per six months.
Exception / Interpretation See Item 3a for the exception to this requirement. 16b. See C3a(2) Requirement Applicable elements of an organization's quality assurance program (for
" design and construction phase activities") should be audited at least anraally or at least once within the life of the activity, whichever is.
shorter. Exception / Interpretation Since most modificat1ons are straightforward, they are not audited individually. Instead, selected controls over modifications are audited periodically. 16c. Sec C3b(1) Requirement This section identifies procurement contracts which are exempted from being audited. PD1081-0535C-QA06
Page 81 Rev 6 Date: 06/15/87 Exception / Interpretation in addition to the exemptions of RG 1.144, CP Co considers that Author-ized Inspection Agencies, National Bureau of Standards or other State and Federal Agencies which may provide services to CP Co are not required to be audited. 17a. N45.2.13, Sec 3.2.2 Requirement N45.2.13 requires that technical requirements be specified in procure-ment documents by reference to technical requirement documents. , Technical requirement documents are to_be prepared, reviewed and I released under the requirements established by ANSI N45.2.11. Exception / Interpretation For replacement parts and materials", CP Co follows ANSI N18.7, Section 5.2.13, Subitem 1, which states: "Where the original item or part is found to be commercially 'off the shelf' or without specifically. { identified QA requirements, spare and replacement parts may be similar-ly procured, but care shall be exercised to ensure at least equivalent performance." 17b. Sec 3.2.3 Requirement
" Procurement documents shall require that the supplier have a document-ed quality assurance program that implements parts or all of ANSI N45.2 as well as applicable quality assurance program requirements of other nationally recognized codes and standards."
Exception / Interpretation Refer to Item 2m. 17c. Sec 3.3(a) Requirement Reviews of procurement documents shall be performed prior to release for bid and contract award. Exception / Interpretation Documents may be released for bid or contract award before completing the necessary reviews. However, these reviews are completed before the item or service is put into service or before work has progressed' beyond the point where it would be impractical to reverse the action taken. PD1081-0535C-QA06
I' Page 82 Rev 6 Date: 06/15/87 17d. Sec 3.3(b) Requirement
" Changes.made in the procurement documents as a result of the bid-evaluations or precontract negotiations shall be incorporated into the procurement documents.- The review of such changes and their effects shall be completed prior to contract award."
Exception / Interpretation This requirement applies only to quality related changes (ie, changes . to the procurement document provisions identified in ANSI N18.7, Section 5.2.13.1, Subitems 1 through 5.) The timing of reviews will be the same as for review of the original procurement document. 17e. Sec 7.5 Requirement
" Personnel responsible for performing verification' activities shall be !
qualified in accordance with ANSI N45.2.6 as applicable." Exception / Interpretation Consumers Power qualifies audit personnel according to N45.2.23. ~ Thus, personnel performing source verification audits may not be certified l according to N45.2.6. Personnel performing inspection as part of source verification will be certified to N45.2.6.- l 17f. Sec 10.1 Requirement "Where required by code, regulation or contract requirement, documen-tary evidence that items conform to procurement documents shall be available at the nuclear power plant site prior to installation or use of such items, regardless of acceptance methods." Exception / Interpretation Refer to Item 2n. l 17g. Sec 10.3.4 (as modified by RG 1.123, C6e) Requirement
" Post-installation test requirements and acceptance documentation shall be mutually established by the purchaser and supplier."
PD1081-0535C-QA06
l# Page 83 Rev 6 Date: 06/15/87-Exception / Interpretation In exercising its ultimate responsibility for its QA program,-CP Co establishes post-installation test requirements, giving due considera-tion to supplier recommendations. 18a. RG 1.26, General Requirement RG 1.26 establishes a system for classifying pressure boundary items into four quality groups, which are then correlated with ASME B6PV Code and ANSI Standards requirements. (However, RG 1.26 does not indicate which of the four quality groups are safety-related, and which are' 3 not.) Exception / Interpretation I l RG 1.26 was used as a reference to establish piping system boundaries, but not for defining specific quality groups or making safety-related determinations. Regulatory Guide 1.29, subject to Exception /Interpreta-tion 20a, is used to determine what systems and equipment are safety-related. 19a. Branch Technical Position ASB9.5.1 and 10CFR50 Appendix R, Sections III G., III J. and III 0., General Exception / Interpretation Fire protection measures, equipment and the individual plant Fire Protection Plans are in compliance with the NRC Safety Evaluation Reports and the required sections of 10CFR50 Appendix R except for the specific exemptions approved by the NRC. 20a. RG 1.29, General Requirement Apply pertinent Quality Assurance requirements of 10CFR50, Appendix B. Exception / Interpretation The pertinent QA requirements for these systems, structures and compo-nents will be determined in a graded manner using tools such as the plant specific Probabilistic Risk Assessment and the Technical Specifi-cations, and other docketed analyses to determine the degree which Appendix B of 10CFR50 applies. PD1081-0535C-QA06}}